The ECHA's draft for the restriction of various Cr(VI) compounds dates back to April 2025. This also includes chromium trioxide. This restriction is intended to make the authorization procedure obsolete in the foreseeable future. Since 18 June, comments on this draft can be submitted via an online portal in the form of a public consultation. The Zentralverband Oberflächentechnik e.V. (ZVO) is planning a general commentary. However, some of the questions asked are company-specific.
Questions on the content and possible consequences of the draft restriction
In the ZVO online dialog, Malte-Matthias Zimmer, ZVO Head of Environmental and Chemicals Policy, first addressed the content and possible consequences of the draft restriction. According to him, it contains a number of inconsistencies and unusual approaches. For example, the environmental impact of chromium trioxide is to be regulated by absolute values. These values are to be set for annual emissions to water and air. Limit values at the workplace and thus the respective level of protection are specified depending on use. Last but not least, it is noteworthy that the concept of limit values has been reverted to, which was rejected as inadequate 15 years ago.
Communicating industry interests in the best possible way
The questions from the public consultation were also presented and categorized. In addition, Dr. Zimmer discussed with the 30 or so participants how the questions should be answered so that each company can participate in its own interests, but also in the interests of the industry, so as not to leave the field to the NGOs. A small group of participants will come together again to develop ideas for commentary.