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ChromeXtend News

CURRENT INFORMATION ON CHROMIUM(VI) AUTHORIZATION

January 2024

Kaspar Walter ChromeXtend’s application for authorization is still being submitted to the European Commission for approval. According to current information, we now expect a vote on this in the first quarter of 2024.

All chromic acid users have been asked via REACH-IT to supply data as part of the reappraisal of chromium trioxide and to respond to the call for evidence.

WHAT DOES THIS MEAN FOR CHROMIC ACID USERS?

These users do not need to do anything for the moment. The usage granted with the annual measurements under the CTAC authorization currently remains unchanged. At some point during the first quarter of 2024, we are hoping to obtain a decision from the European Commission about ChromeXtend in accordance with the EChA recommendation.

The European Commission has asked EChA to reappraise chromium(VI) compounds. The intention is to transfer chromium trioxide and chromic acid from Annex XIV (prohibited substances subject to authorization) to Annex XVII (substances subject to restrictions). All users are therefore being asked to supply data to give EChA a good basis for reappraising these substances.

In response to the call for evidence, Kaspar Walter is currently preparing a draft for comment based on valid data. This will be submitted by Kaspar Walter, the ERA, and some representative customers in order to present the gravure printing and embossing industry in a comprehensive manner.

In addition every user of chromium trioxide could participate individually on the call for evidence. Kaspar Walter will be happy to support you. Please contact us.

If you have any further questions about chromium trioxide, please contact Mr. Christoph Tschaar: c.tschaar@kwalter.de or Chrome@kwalter.de, +49 160 99169242

November 2023

SUBMISSION OF MEASUREMENT RESULTS TO ECHA BY DECEMBER 18, 2023

K.Walter would like to remind chromium trioxide users that measurement results must be submitted to the European Chemical Agency (ECHA) via REACH-IT by December 18, 2023.

Please note that these measurement results must be provided annually.

For further questions on the subject of chromium trioxide, please contact Mr. Christoph Tschaar:
c.tschaar@kwalter.de, +49 160 991 69 242

WHAT SHOULD I KNOW AS A USER OF CHROMIC ACID?

On October 9, 2023, the European Commission published a document with detailed responses from the CTAC applicant. Three main points from this are relevant for the supply chain and users of chromic acid:

1.) The CTAC authorization annulled by the European Court of Justice (ECJ) on April 20, 2023 will be re-evaluated in the light of this decision. Authorizations with similar uses, such as K.Walter’s ChromeXtend, will also be analyzed with a view to harmonization.

2) The new EChA assessment on CTAC is expected to be decided beyond April 2024. Until one year after the ECJ decision, data collection will continue as before under the conditions set out in the CTAC authorization. After that, the “pending” status will apply again, similar to the situation before the 2020 decision on CTAC.

3) The European Commission has mandated EChA to re-evaluate the substances chromium trioxide and chromic acid. Due to the low processing speed and the high number of authorizations for Cr(VI), they are set to change from Annex XIV (prohibition/authorization) to Annex XVII (restriction). This by no means represents a future for Cr(VI) compounds, as Annex XVII also provides for a phasing out of the SVHC substance in accordance with the authorization.  The exact content of the restriction is not yet known and the change will take place in three years at the earliest.

 

WHAT DO I HAVE TO DO AS A USER OF CHROMIC ACID?

1) Chromic acid can still be used under the familiar safety conditions.

2) Measurements must still be reported in REACh IT. From 2024 there will be a change from REACh IT to IUCLID 6. Kaspar Walter supports its customers in dealing with the new software.

3) The decision on the authorization of K.Walter ChromeXtend is expected by December 13-14, 2023. Due to the delay caused by the ECJ ruling, we cannot say with certainty when the European Commission will decide on ChromeXtend. We continue to expect a transition period until 2032.

For further questions on the subject of chromium trioxide, please contact Mr. Christoph Tschaar:
c.tschaar@kwalter.de, +49 160 991 69 242

May 2023

Users can continue to use chromium trioxide for now

On April 20th, 2023, the European Court of Justice (ECJ) ruled in favor of a complaint by the European Parliament against the European Commission, resulting in the immediate nullification of the CTAC authorization for chromium trioxide. As a result, the current supply chain for chromium trioxide in Europe currently has no authorization.

The ECJ has further decided that the current supply chain and use of chromium trioxide may continue until a new decision is made by the European Commission. According to the ECJ, this decision must be made within one year, by April 20th, 2024 at the latest.

What does this decision mean for you as a user of chromium trioxide?

  • You can continue to use chromium trioxide for now under the known safety regulations.
  • However, this permission is valid only until April 2024, or until a decision is made by the EU Commission before then.
  • It is now a matter of waiting to see what the new decision on CTAC authorization will be and how it will be executed in terms of regulations or content.

How does this decision affect the K.Walter authorization application for ChromeXtend?

The current ECJ decisions on the general CTAC application do not directly affect our specific application. In the meantime, the EU Commission’s decision on this matter has been postponed to the end of April due to the large number of applications to be reviewed. We now expect to be included in the agenda of the relevant EU committees and to have a vote on our application at the end of June 2023.

To emphasize the urgency of the vote on our application, we have sent a letter to the EU Commission again, highlighting the importance and significance of the pending vote for the entire European gravure and embossing industry. Our ChromeXtend authorization application was already submitted to the European Chemicals Agency (ECHA) in the spring of 2021. It covers the use of chromium trioxide for horizontal chrome plating systems in the gravure and embossing sector and is intended to provide users with planning and production security until around the end of 2032, in accordance with the ECHA recommendation for a review period.

The ECHA has considered the application to be very positive, as it addresses all the criticisms of the CTAC application and includes a clear forward-looking replacement plan. The ECHA emphasizes that chromium trioxide exposures can be significantly reduced through various measures thanks to the developed “Health and Safety” package. Thus, the already high safety standard in existing chrome plating systems can be further increased significantly.

For further questions on the subject of chromium trioxide, please contact Ms. Sylvia Berger (s.berger@kwalter.de, +49 89 785 96 188).

 

NOVEMBER 2022

Submission of measurement results to ECHA by 18.12.2022.

K.Walter would like to remind chromium trioxide users that measurement results must be submitted to the European Chemicals Agency (ECHA) via REACH-IT by December 18, 2022. Please note that these measurement results must be provided annually.

If you have any questions, please contact Ms. Sylvia Berger (s.berger@kwalter.de, +49 (0)89 785 96 188).

Submission of measurement results to ECHA by 18.12.2022

APRIL 2022

The next milestone has been reached. At the beginning of March 2022, the European Chemicals Agency (ECHA) submitted a detailed draft and voting recommendation to the EU Commission regarding the ChromeXtend authorization application for the European gravure and embossing industry. The Commission is likely to make its decision in the 4th quarter of 2022.

To ensure companies can continue to use currently indispensable chromium (VI) electrolytes beyond the expiration of the present CTAC authorization on September 24, 2024, K.Walter is working intensively and in cooperation with users on the strategic and technological “ChromeXtend” initiative.

As explained in the December 2021 update on ChromeXtend, the chromium trioxide exposure measurements for operating personnel that were reported by all participating customers were consistently low and within the legal limits. The authorization application was submitted to the ECHA in February 2021 and has been reviewed and processed in various procedures and dialogs to date. This application covers the use of chromium trioxide for the European gravure and embossing market.

The official recommendation that has now been communicated is the last step before the European Commission votes on the application.

Here are the key points in the ECHA’s recommendation:

  • 12-year review period (starting from the application submission date, i.e. up to 2032)
  • Further improvements are to be made to current exposure levels (see K.Walter Health and Safety Package)
  • Annual exposure measurements still to be mandatory
  • Authorization is to apply to horizontal chromium systems and the use of liquid chromium

Thanks to the excellent feedback from the organizations involved, K.Walter is highly optimistic that the application will be successful.

In December last year, K.Walter once again ran a major reminder and detailed support campaign to help all its customers submit the legally required notification to the ECHA and upload measurement data. Due to the positive feedback this support received, K.Walter will continue to offer this service to customers and expand it so it is available for all matters relating to chromium and its authorization process.

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).

 

Timeline and current status

December 2021

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

January 2021

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.

June 2020

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.

April 2020

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.

February 2020

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.

September 2019

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.

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