Over recent months, K.Walter has supported the implementation of the CTAC authorization in Europe and assisted users in a variety of ways. Across the board, the chromium trioxide exposures that have been measured have been low, and well below the legal limits.

K.Walter would like to remind chromium trioxide users once again that measurement results must be submitted to the European Chemicals Agency (ECHA) via REACH-IT by December 18. To assist in this process, K.Walter is once more offering support with completing the ECHA measurement template and uploading the data.

Since K.Walter submitted its application for authorization to the ECHA in February 2021, the application has been processed and handled by various ECHA bodies. There has been constructive dialog between K.Walter and the ECHA at various points and K.Walter has been able to answer the last substantive questions satisfactorily. Based on initial discussions about operating conditions and risk reduction measures, it appears that the ECHA views the high process standards and safety measures in gravure and embossing electroplating as credible and adequate.

We anticipate that the ECHA will complete its report on our application in the next few weeks and pass it on to the European Commission. Based on the ECHA recommendation, the Commission will evaluate the application once again and a legal text will then be drawn up. This text will be passed into law when the member states in the European Commission’s REACH Committee vote on it. Due to the large number of applications for authorization that have been presented to the Commission, it is currently anticipated that a final decision will be reached at the end of 2022/beginning of 2023.

If you have any questions about the implementation of the current chromium regulations, please contact Ms. Sylvia Berger (s.berger@kwalter.de, +49 (0)89 785 96 188).

Timeframe and current status of CTAC authorization

On December 18, 2020, the EU issued a positive ruling on CTAC authorization. The European gravure and embossing sector is therefore permitted to use chromium trioxide under the terms of the CTAC authorization until September 21, 2024.

European users of chromium trioxide must now comply with various regulations such as registering with the European Chemicals Agency (ECHA) and carrying out annual workplace exposure and environmental emissions measurements. To help customers meet the requirements, country-specific webinars have been held and detailed discussions have been organized on how the new provisions need to be put into practice. Information about this can be found here.

For further help with implementing the new regulations, do not hesitate to get in touch – we’re happy to provide our customers or anyone interested with advice or support. Please contact our project manager Julian Rotter (j.rotter@kwalter.de) directly.

To ensure chromium trioxide can continue to be used even after the CTAC authorization period, and therefore beyond 2024, K.Walter worked intensively last year on the ChromeXtend authorization application. This application, tailored specifically to the gravure and embossing sector, aims to safeguard hard chrome plating using chromium trioxide for the long term, beyond CTAC.

Initial discussions with the ECHA before submitting the application went well and there was very positive feedback on the extensive survey in the industry last year. We are now pleased to announce that K.Walter has completed the application and submitted it to the ECHA in February. The ChromeXtend authorization application has requested an authorization period of 12 years. A decision on authorization and its ultimate duration is expected between the start and middle of 2023.

The ChromeXtend authorization initiative launched by K.Walter for the use of chromium trioxide in the gravure printing and embossing industry continues to be driven forward. An important milestone has now been reached:

In the past weeks, we have asked cylinder manufacturers based in the European Economic Area to participate in a survey for ChromeXtend. We are pleased to report that we received an extensive response from 80 % of the 121 locations contacted. The data will now be evaluated anonymously and prepared for the registration dossier. As a result of the numerous responses, it is possible to provide comprehensive evidence of the high safety standards in cylinder production and to demonstrate the economic consequences of a potential ban. We would like to thank the companies for their support!

The submission of the authorization application is planned for the end of 2020. As we continue to anticipate an authorization period for the CTAC application till September 2024, this provides a secure period for approving the ChromeXtend application.

On May 13, the CTAC application was again discussed in the REACH committee of the EU, but no final decision was taken.

We will keep you up to date on how the application is progressing in this newsletter and at www.kwalter.de. Should you have any specific questions on this matter, you can also e-mail our project manager Dr. Julian Rotter at any time at j.rotter@kwalter.de.

During the past week, you might have received an information letter from the CTACSub Consortium asking you to prepare a substitution plan for chromium trioxide. The European Commission has decided that the authorization procedure will be suspended until a substitution strategy has been drafted by CTACSub. The request to draft a substitution plan concerns initially only those companies which fall under CTAC Use 3, the functional chromium plating with decorative character. The European rotogravure and embossing industry is consequently not affected since it is covered by Use 2, the functional hard chromium plating. We are anticipating a similar development for Use 2, which will further delay a decision by the European Commission on the use of chromium trioxide. You will be informed as soon as there are any new developments in this regard.

Despite the current circumstances, work on ChromeXtend is progressing. At the moment, data is being collected from the gravure and embossing form manufacturers with the aim of providing a detailed picture of the industry in the authorization dossier. If you have not yet participated in the survey, we kindly ask you to do so until the end of April 2020. Only through the support of all companies can we achieve the longest possible approval period. You received your individualized links for the anonymous participation last on 18 March from chromeXtend@ramboll.com.

Owing to the Corona Pandemic the ERA Event CTA – Chromium Trioxide Authorization Symposium in Munich had to be postponed. As soon as the European travel restrictions have been lifted, we will announce a new date together with the ERA to present our authorization application and inform you about the latest developments at CTACSub.

We will keep you up to date on how the application is progressing in this newsletter and at www.kwalter.de. Should you have any specific questions on this matter, you can also e-mail our project manager Dr. Julian Rotter at any time at j.rotter@kwalter.de.

ChromeXtend is an industry initiative by K.Walter to enable the gravure and embossing sector to continue using chromium(VI)/chromium trioxide in the long term beyond 2024.

The European Commission has still not reached a decision regarding the review period for CTAC, and no agreement is expected before April. Despite these circumstances, we are still assuming the CTAC authorization will end in September 2024.

Regardless of this, preparation of the dossier for the ChromeXtend authorization application is well underway. The fact that over 120 production sites in the EU are dependent on the continued authorization of chromium trioxide makes it clear how important the application is for gravure printing in the EU.

The high process reliability of gravure electroplating in general – and the low consumption of chromium trioxide during cylinder manufacturing in particular – demonstrate that a specific industry application such as ChromeXtend is the right solution to ensure the long-term use of chromium trioxide. For example, the some 180 metric tons of chromium trioxide used each year to produce 1.25 million gravure cylinders accounts for just 1.5 percent of the total amount of chromium trioxide imported into the EU.

To prepare the dossier, various data needs to be collected from gravure form manufacturers so as to provide an accurate picture of our sector and obtain the longest possible authorization period. The data requested includes information such as the chemical risks when using chromium trioxide and the expected economic consequences of banning this substance. Our partner Ramboll will collect this data using the SurveyXact platform, save it in an anonymized form, and pass on the aggregated results to K.Walter. The relevant companies will be receiving an invitation to participate in the survey directly from Ramboll on February 25, 2020. A number of videos are also being prepared to help answer the questions. In all our interests, we would ask for your active participation.

A further key date in this connection is March 19, 2020, when the ERA will be hosting an event at NH Hotel Bavaria in Munich and will join K.Walter in presenting the ChromeXtend application and the results of the survey. The potential best practice when using chromium trioxide is also to be clarified during a discussion to further improve the safety standards. Other planned items on the agenda include a presentation relating to the necessary workplace exposure measurements and a user report from Hansgrohe SE, which received authorization for decorative chromium plating one year ago and has passed the first safety review. To register for the symposium and for further details, go to the ERA website at https://era-eu.org/current-events/cta-chromium-trioxide-authorization-meeting/1340/

We will keep you up to date on how the application is progressing in this newsletter and at www.kwalter.de. Should you have any specific questions on this matter, you can also e-mail our project manager Dr. Julian Rotter at any time at j.rotter@kwalter.de.

ChromeXtend is an initiative launched by K.Walter to secure an authorization from the European Commission that is tailored to the specific requirements of the gravure and embossing industry. The aim is to enable continued long-term use of chromium(VI), beyond 2024, in line with the highest possible safety standards.

Until there is a field-tested alternative, chromium(VI)-based electrolysis is the only way of chrome plating engraved gravure cylinders and embossing cylinders. Gravure printing only accounts for around one percent of all industrial chromium(VI) applications. It already satisfies very high safety standards compared with other industrial applications and, in our view, would derive no benefit from authorizations in other sectors. In our customers’ interests, we have therefore launched the ChromeXtend initiative to apply to the European Commission for long-term authorization of the chromium(VI) process beyond 2024. Our aim is to ensure our customers are not taking a financial risk if they justifiably opt to continue using gravure printing at the end of the current authorization phase. The ERA (European Rotogravure Association) is helping us with our application.

To ensure this application for authorization has a chance of securing a positive ruling from the EU Commission, we need the cooperation and active assistance of the entire gravure and embossing sector. We will therefore be contacting companies that use chrome plating during the authorization process – both directly and through the ERA – and asking them to supply us with information.

We will keep you up to date on how the application is progressing in our helioscope newsletter and at www.kwalter.de. Should you have any specific questions on this matter, please feel free to contact us at any time by emailing chrome@kwalter.de

Please also take a look at our factsheet “Everything you need to know about chromium”, which you can download here.