ECHA moves to restrict CrVI substances to protect health across the EU

13/5/2025

Why restrict hexavalent chromium compounds?

The European Chemicals Agency (ECHA) has proposed a new EU-wide restriction on a range of hexavalent chromium (Cr(VI)) compounds, seeking to mitigate the severe health risks associated with their use, especially in industrial workplaces.

Acting on a formal request from the European Commission, ECHA has conducted an in-depth assessment of the hazards posed by Cr(VI) substances. These compounds are among the most potent carcinogens found in the workplace and pose significant risks not only to workers directly handling them but also to surrounding environment exposed to emissions from industrial facilities. The risks include a heightened incidence of lung and intestinal cancers.

How are manufacturers affected by this restriction?  

To reduce the exposure risks and the hazard, ECHA is proposing a restriction on 13 Cr(VI) substances, with narrowly defined exemptions. The use of these substances would be banned except in certain use categories when they meet defined limits for worker exposure and environmental emissions. The exceptions cover specific industrial applications, including:

  • Formulation of mixtures
  • Electroplating on plastic substrates
  • Electroplating on metal substrates
  • Use of primers and other slurries
  • Other surface treatment
  • Functional additives or process aids  

Three restriction options proposed by ECHA

ECHA has outlined three potential restriction options to limit the use of Cr(VI) substances, each varying in stringency and expected impact:  

Option 1 (RO1): Europe-wide harmonization of current thresholds

Restriction Option 1 (RO1) with least stringent limits for worker exposure and environmental emissions. Approximately 90% of companies across the six targeted use categories already comply with these thresholds. The primary value of this option lies in setting harmonised standards across the European Union, offering a low-cost improvement in occupational and environmental health and safety.

Option 2 (RO2): Tougher but still accessible requirements

Restriction Option 2 (RO2) that introduces more demanding thresholds. Around 62% of companies currently comply with the proposed worker exposure limits, and about half meet the environmental emission standards. RO2 would thus raise the safety bar, significantly reducing exposure risks for both workers and the general population.  

It remains a viable option for many companies to continue using Cr(VI) under safer, more controlled conditions.

Option 3 (RO3): The strictest scenario

Restriction Option 3 (RO3) that sets the highest standards for exposure and emissions. Compliance data suggests that only about 32% of companies meet the proposed worker exposure limits and just 23% comply with the environmental thresholds. As a result, this option would necessitate substantial investments in risk management measures.

Public consultation: an opportunity for regulatory influence  

How and why take part in the consultation?

A six-month public consultation period will begin on 18 June 2025. During this phase, all interested stakeholders including industry, NGOs, and public health experts are invited to submit data-supported feedback.  

We strongly encourage you to participate in this public consultation, as your input may shape future regulatory decisions and help mitigate potential impacts on your industrial activities. Participating actively is a strategic way to stay ahead of regulatory developments and protect your operations.

Strategic support to maximize your impact

Our team is here to support you throughout the process, helping you structure and strengthen your contributions to ensure they are as impactful as possible. Contact our experts for a free meeting.

You can also read our latest articles about Chrome:

Why restrict hexavalent chromium compounds?

The European Chemicals Agency (ECHA) has proposed a new EU-wide restriction on a range of hexavalent chromium (Cr(VI)) compounds, seeking to mitigate the severe health risks associated with their use, especially in industrial workplaces.

Acting on a formal request from the European Commission, ECHA has conducted an in-depth assessment of the hazards posed by Cr(VI) substances. These compounds are among the most potent carcinogens found in the workplace and pose significant risks not only to workers directly handling them but also to surrounding environment exposed to emissions from industrial facilities. The risks include a heightened incidence of lung and intestinal cancers.

How are manufacturers affected by this restriction?  

To reduce the exposure risks and the hazard, ECHA is proposing a restriction on 13 Cr(VI) substances, with narrowly defined exemptions. The use of these substances would be banned except in certain use categories when they meet defined limits for worker exposure and environmental emissions. The exceptions cover specific industrial applications, including:

  • Formulation of mixtures
  • Electroplating on plastic substrates
  • Electroplating on metal substrates
  • Use of primers and other slurries
  • Other surface treatment
  • Functional additives or process aids  

Three restriction options proposed by ECHA

ECHA has outlined three potential restriction options to limit the use of Cr(VI) substances, each varying in stringency and expected impact:  

Option 1 (RO1): Europe-wide harmonization of current thresholds

Restriction Option 1 (RO1) with least stringent limits for worker exposure and environmental emissions. Approximately 90% of companies across the six targeted use categories already comply with these thresholds. The primary value of this option lies in setting harmonised standards across the European Union, offering a low-cost improvement in occupational and environmental health and safety.

Option 2 (RO2): Tougher but still accessible requirements

Restriction Option 2 (RO2) that introduces more demanding thresholds. Around 62% of companies currently comply with the proposed worker exposure limits, and about half meet the environmental emission standards. RO2 would thus raise the safety bar, significantly reducing exposure risks for both workers and the general population.  

It remains a viable option for many companies to continue using Cr(VI) under safer, more controlled conditions.

Option 3 (RO3): The strictest scenario

Restriction Option 3 (RO3) that sets the highest standards for exposure and emissions. Compliance data suggests that only about 32% of companies meet the proposed worker exposure limits and just 23% comply with the environmental thresholds. As a result, this option would necessitate substantial investments in risk management measures.

Public consultation: an opportunity for regulatory influence  

How and why take part in the consultation?

A six-month public consultation period will begin on 18 June 2025. During this phase, all interested stakeholders including industry, NGOs, and public health experts are invited to submit data-supported feedback.  

We strongly encourage you to participate in this public consultation, as your input may shape future regulatory decisions and help mitigate potential impacts on your industrial activities. Participating actively is a strategic way to stay ahead of regulatory developments and protect your operations.

Strategic support to maximize your impact

Our team is here to support you throughout the process, helping you structure and strengthen your contributions to ensure they are as impactful as possible. Contact our experts for a free meeting.

You can also read our latest articles about Chrome: