Of particular interest is the question of what impact the entry into force of the restriction will have on existing authorizations. As things stand at present, the restrictions are set to come into force in 2027, with existing authorizations losing their validity after 18 months at the latest. Authorization applications that have already been submitted would receive a correspondingly shorter authorization period.

Against this background, ECHA will give priority to applications for authorization of other substances over authorization applications and review reports for Cr(VI) substances in the period before the restriction comes into force. Furthermore, applications for authorization from new users will take priority over review reports for Cr(VI) substances. It is therefore unlikely that the process will be completed before the restriction comes into force, particularly for the submission of review reports.

In view of the emerging developments, it is all the more important that the industry takes advantage of the opportunity to comment on the Annex XV dossier prepared by ECHA and addresses the emerging issues. This must be done by September 18, 2025. Comment on ECHA website

Download the recent Q&A document via CIRCABC: European Commission updates Q&As on Chromium(VI) compounds