Authorization of chromium trioxide – Requirements to be fulfilled by the downstream user

Since the EU has approved the authorization of the CTAC submission on 18 December 2020 which covers the gravure printers and cylinder makers as downstream users, the individual downstream user must comply with additional authorization conditions to further use chromium trioxide.

Holder of the CTAC authorization granted by the EU are the importers of chromium trioxide: Chemservice, Atotech, Boeing Distribution, Prospere Chemical Logistic, Cromital, Elementis Chromium and MacDermid Enthone.

The authorization includes functional plating which covers the gravure industry.

To obtain their individual authorization the downstream users (gravure printers, engravers and cylinder makers) have to take the following steps and to fulfill certain requirements:

• Registration of the use of chromium trioxide with ECHA (European Chemical Agency) by 18 March 2021.  To register the downstream user should ask his supplier of chromium trioxide for the safety data sheet which indicates the authorization code. Then the individual downstream user has to set up a REACH-IT account by using the following link https://reach-it.echa.europa.eu/reach/ to download the downstream user notification for authorized uses which has to be filled out. This form has to include the following information:
  – identity of the company
  – name of the substance
  – authorization code
  – contact data
  – description of the major functionality of the individual use of chromium trioxide (e.g. hardness)
• Fulfilling of the exposure control measures described in the new safety data sheet which the downstream user gets from his supplier of chromium trioxide until 18 March 2021 at the latest. This document specifies risk management measures to take and working conditions (e.g. protective gear) to keep. The risk management measures include worker exposure monitoring (e.g. first measurings have to be carried out until 18 June 2021) and environmental monitoring (e.g. waste water and exhaust air).
•  The results of the worker exposure and environmental monitoring must be transmitted to ECHA for validation until 18 December 2021 through the user’s REACH-IT account.
• The monitoring and reporting must be conducted annually.

The CTAC authorization is valid until 21 Sepember 2024.

For the time beyond a new application must be submitted at ECHA.  To secure the use of chromium trioxide for the gravure industry beyond 2024 ERA member Kaspar Walter meanwhile has submitted a new ChromeExtend application. For further information please contact Dr Julian Rotter of Kaspar Walter – j.rotter@kwalter.de

Optionally downstream users could continue to cooperate with CTACSub 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 at the latest – ReachTeam@jonesday.com