Critical uses of chromates throughout the entire Aerospace and Defence (A&D) industry are at risk – impacting both users of the chromates and chromates-based formulations, as well as the manufacture of parts and components where this involves use of the chromates.
Under the EU REACH Regulation such uses of the chromates requires Authorisation, which is granted by the EU Commission for a specific period of time (the “review period”). It is not possible to continue to use the chromates without an Authorisation.
REACH Authorisations have now been granted to the CTACSub, CCST and GCCA providing 7 years review periods from the Sunset Dates, and all three of these are relevant to A&D uses. The table [available at the link below] provides details of the Authorisation numbers associated with each of the consortium.
Although continued use of these chromates is currently authorised, it will be necessary to re-apply to extend the review period and to ensure the on-going use of the chromates while work progresses to find suitable alternatives.
In February 2023 the Consortium completed the submission of seven review reports (RR) and six new applications for authorisation (AfA) to ECHA. These submissions covered the use of five soluble chromates (chromium trioxide, sodium chromate, sodium dichromate, potassium dichromate and dichromium tris(chromate)) in surface treatment activities in the aerospace and defence (A&D) industry and its supply chains. These supplemented four RR and four AfA previously submitted in November 2022. These include renewals of applications for the original CTACSub, CCST and GCCA consortia. In addition, eight RR and nine AfA have been submitted for review by the UK authorities in accordance with the requirements of the UK REACH Regulation.
Preparation of this first tranche of RRs and AfAs has been supported by over 40 companies across the Aerospace and Defence supply chain, including the largest OEMs in Europe and the UK, as well as importers, formulators and distributors.
The substance/use combinations covered in the first tranche of submissions by the ADCR are shown in the table below. To support the requested review periods, the applications define more clearly each of the substance uses in terms of the actual conditions of use, as well as the associated worker and environmental exposures to the chromates.
| Uses of Cr(VI) substances for (re)authorisation | Chromium trioxide | Sodium dichromate | Potassium dichromate | Sodium chromate | Dichromium tris(chromate) |
|---|---|---|---|---|---|
| Anodising | X | ||||
| Conversion coating | X | X | X | X | |
| Electroplating | X | ||||
| Passivation of (non-Al) metallic coatings | X | X | X | ||
| Passivation of stainless steel | X | X | |||
| Anodise sealing | X | X | X | X | |
| Slurry coatings | X | ||||
| Chromate rinsing after phosphating | X | ||||
| Inorganic finish stripping | X | X | |||
| Pre-treatments | X | X | |||
| Formulation | X | X | X | X | X |
More information on the submissions and the next steps following submission can be found in the following communications:
Work on the second tranche of renewal applications started in 2022 covering substances used in primers and coatings:
For further information concerning the above or the ADCR consortium, please contact email:
The ADCR is now closed to new members with respect to gaining new authorisations covering the use of chromium trioxide (chromic acid), sodium dichromate, potassium dichromate, sodium chromate and dichromium (tris)chromate.