Continued use of chromium trioxide under EU REACH after granting of ADCR authorisations – updated guidelines of 28.7.2025 for users in the European Space Sector (Issue 8)

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ASD-Eurospace wishes to update companies in the European Space Sector and their subcontractors about their right to continue use of chromium trioxide (CAS 1333-82-0) after the REACH authorisation sunset date on 21.9.2017. The use concerns formulations produced by Henkel formerly known as ‘Alodine’ in chemical conversion coating (CCC) and the repair or maintenance of such coating on aluminium alloy parts used in launchers and space vehicles.

Please view the updated space sector guidelines of 28.7.2025 (MPTB-RL-GD-0200), available HERE.  

Following the publication of updated versions of the relevant Safety Data Sheets (SDSs) by Henkel in the beginning of June 2025 to align with the EU REACH authorisations granted by the European Commission (COM) to members of the Aerospace and Defence Chromates Re-Authorisation (ADCR) Consortium, the Use in the European Economic Area (EEA) is continued to be allowed under authorisation number REACH/24/61/3 pertaining to upstream supplier Cromital S.P.A. according to Commission Implementing Decision of 20.1.2025, ref. C(2025) 94 final (link).

Downstream users (DUs) are advised to check the latest Henkel SDS for their specific products to see whether they have been updated accordingly. If so, compliance with authorisation decision C(2025) 94 final will be required – including a compliance deadline of 20.1.2026 for certain obligations – and new ECHA notifications should be done according to REACH Article 66(1).

This new ADCR-related authorisation thus principally replaces the initial ‘CTACSub’ authorisation (decision C(2020) 8797 final) / application (ECHA ID 0032-04, after annulment by the Court of Justice of the European Union in Case C-144/21) as legal title for continued use by DUs in the EEA. The new authorisation is set to be valid until 20 December 2034; however, the impact of the on-going EU REACH restriction process for certain chromium (VI) substances, including CrO3, needs to be monitored closely, as the restriction is aimed to replace the EU REACH authorisation system for these substances as early as from 2028.

The updated space sector guidelines of 28.7.2025 in the form of questions-and-answers contain further information and references on the required actions for downstream users to be in compliance with the REACH authorisation requirements.

In the updated guidelines you will also find information for the use if taking place in Great Britain or Switzerland; activities not requiring authorisation; and the REACH restriction initiative launched by ECHA, on request of the European Commission.

Please note that the present guidelines replace the previous Issue 7 ref. MPTB-RL-MO-0186 of 8.5.2025.

The present guidelines are being prepared and kept up to date 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.

Current STF participants include:

  • MPTB Members:
    • Industrial participants: Airbus Defence & Space; ArianeGroup; Avio; Beyond Gravity; OHB; Thales Alenia Space; ASD-Eurospace (as Secretariat)
    • Space agencies: ESA, CNES
    • Observer: European Defence Agency (EDA)
    • Consultant: REACHLaw Ltd.
  • Non-MPTB Members:
    • APP BV; Europropulsion

Contacts:

  • Secretariat: Valentin Marie, Research Analyst & Compliance Manager, ASD-EUROSPACE, valentin.marie@eurospace.org, +33 (0) 7 86 58 74 34
  • REACH Expert: Tim Becker, Senior Legal Advisor, REACHLaw Ltd., tim.becker@reachlaw.fi; +358 (0)40 773 8143