Action required under EU REACH for continued use of chromium trioxide on space hardware

ASD-Eurospace is pleased to provide a guideline, available HERE, to facilitate compliance for the continued use of chromium trioxide in chemical conversion coatings for space hardware with the authorisation requirement under the EU Regulation (EC) No 1907/2006 (REACH).

The document aims to inform EU/EEA downstream users of certain formulations containing chromium trioxide, which is included in the REACH Authorisation List (Annex XIV). Therefore, its continued use as a substance or part of a mixture after the sunset date on 21 September 2017 is only allowed within the scope of an authorisation granted by the European Commission.

With Commission Implementing Decision C(2020) 8797 final of 18 December 2020, the European Commission has (partially) granted an authorisation for certain uses of chromium trioxide under REACH – valid until 21 September 2024 – to Chemservice GmbH and others. Downstream users of chromium trioxide can benefit from this authorisation under certain restrictive conditions, which are described in the guideline.

One important action for downstream users wishing to rely on this decision will be to notify the European Chemicals Agency (ECHA) about their authorized used, pursuant to REACH Article 66. The initial notification is due around March 2021.

It should be noted that the guideline focuses on certain formulations by HENKEL, namely BONDERITE M-CR 1200 AERO, BONDERITE M-CR 1200S AERO, BONDERITE M-CR 600 AERO. For possible other formulations containing chromium trioxide still being used, downstream users may investigate a similar approach to compliance with the REACH authorisation requirement.

The guideline has been prepared in the frame of the Space Chromates Task Force (STF) of the Materials and Processes Technology Board of the European Space Components Coordination (ESCC MPTB). The ESCC MPTB is a partnership between the European Space Agency (ESA), national space agencies, and space industry represented by ASD-Eurospace; it is chaired at present by ESA.