A number of Cr(VI) compounds currently used in the European space industry (especially for surface treatment), such as chromium trioxide and sodium dichromate, have been included in the List of Substances subject to Authorisation (Annex XIV) of the EU REACH Regulation (EC No 1907/2006) on chemicals in April 2013. This means that they must in principle not be used or placed on the market for use any longer in the European Economic Area (comprising all EU Member States, Norway, Iceland and Liechtenstein) after the "sunset date" on 21 September 2017, unless an authorisation for the specific use has been granted by the European Commision to the company using this substance or an eligible upstream supplier. Applications for authorization should be submitted by the “latest application date” on 21 March 2016. Further Cr(VI) compounds, such as strontium chromate, are expected to be included in Annex XIV in the beginning of 2014, with similar sunset and application dates.
The REACH Regulation impacts space systems manufacturing in many significant ways, and while research activities to generate alternative technical solutions have been launched, companies in the space industry will have to ensure due REACH authorisation, until suitable replacements have been identified, qualified and validated for all applications.
In order to ensure that appropriate authorisation dossiers are prepared for uses of prioritized Cr(VI) substances in the European space industry and enable a strong common voice on behalf of the sector, a Space Industry Space Chromates Task Force (TF) assisted by the consultant REACHLaw Ltd. has been set up on 12 June 2013.
The Space Chromates TF is open to all actual and potential users of prioritized Cr(VI) substances in the European space industry as well as their subcontractors.
The Space Chromates TF is supported by the European Space Agency (ESA).
In the first phase of its work the TF will determine the scope of work to be done, including the specific substances and uses for which authorisations should be sought, and launch co-ordinating activities with other authorization groups, suppliers and authorities. Companies willing to join the TF will be able to do so until the end of this phase (by mid-October 2013).
Please contact Pierre Lionnet at Eurospace for information.