Status and further steps by downstream users
ERA as an association is not entitled to submit an application for authorization. Only companies using, selling or importing chromium trioxide are allowed to submit an authorization. Thus, ERA is not part or member of an authorization consortium like CTAC.
ERA member Kaspar Walter was member of the CTAC submission consortium to represent the gravure industry, and to provide the necessary data and process description of the application. Applicants were seven importers such as Lanxess Germany, Atotech Germany, Cromital, Enthone etc..
The authorization was approved by the EU Commission on 18 December 2020 and covers our industry – printers and engravers – as downstream users.
We have precisely explained in our circular email from 12 February which steps have to be taken by the companies (downstream users) to obtain their individual authorization.
The authorization to use chromium trioxide will expire by 21 September 2024.
For the time beyond, a new application has to be submitted at ECHA (European Chemical Agency).
To secure the authorization for our industry there are the following options:
1)Each individual company could submit its own application (as user). This however would be costly – up to € 200 000 minimum.
2) Each company covered by the current CTAC authorization as downstream user could continue to cooperate with CTACSub2 to get a prolongation. In case of interest the downstream user should get in touch with the lawyers of CTACSub to register by 31 March 2021 – ReachTeam@jonesday.com
(Costs: € 15 000 for small and medium size companies, € 30 000 for large size companies)
3) Kaspar Walter has submitted an own application (ChromExtend) to cover the gravure industry. ChromExtend covers the full supply chain: Kaspar Walter applies as importer, the printers and engraver are covered as downstream users. Unlike CTAC, which includes many branches and industries making the application complicated and less transparent as far as the process description is concerned, ChromExtend of Kaspar Walter only covers the gravure industry, which guarantees a precise and transparent description of our process in the application. The application has been submitted by Kaspar Walter at ECHA in February. The treatment of ChromExtend by ECHA will take at least one year before a final decision by the EU Commission can be expected. Anyhow, ChromExtend is right in time and there will be a decision before the running authorization expires in September 2024. As mentioned above, all gravure printers and engravers will be covered as downstream users by ChromExtend. Kaspar Walter as supplier of galvanic machinery has placed ChromExtend to secure the continuation of gravure printing beyond 2024. Kaspar Walter is bearing the costs for the application, they will not charge any fee from those who are covered as downstream users.