Continued use of chromium trioxide under EU REACH after granting of ADCR authorisations – updated guidelines of 8.5.2025 for users in the European Space Sector (Issue 7)

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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 8.5.2025 (MPTB-RL-MO-0186), available HERE.  

The described use continues to be allowed in the EU based on the latest available supplier Safety Data Sheet (SDS), if it is covered by the application for authorisation by Chemservice and others (known as the ‘CTACSub’ application), available here: ECHA-ID 0032-04. This applies until Henkel updates its SDS and label to align with the applicable new authorisations granted by the European Commission to members of the Aerospace and Defence Chromates Re-Authorisation (ADCR) Consortium on 28.10.2024 and 20.1.2025, which provide new continued use titles for DUs in the EEA until 20.12.2034.

In the meantime, DUs are already advised to prepare for compliance with those granted ADCR authorisations in order to meet upcoming compliance deadlines which could be as early as 28.10.2025, latest 20.1.2026. Once the applicable ADCR authorisation number for CCC is known from Henkel through its updated SDS, DUs also have to submit REACH Article 66 notifications to the European Chemicals Agency (ECHA).

Henkel has informed that the applicable aerospace authorisation number for CCC using chromium trioxide is REACH/24/61/3 (see Commission Implementing Decision C(2025) 94 final of 20.1.2025, available HERE); DUs are asked to refer to the updated SDS from Henkel they should soon receive for details.

The updated space sector guidelines of 8.5.2025 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, for chromium trioxide and other Cr(VI) substances, which is planned to eventually replace the authorisation system for these substances (adoption of a new restriction by COM could be taking effect around 2028).

Please note that the present guidelines replace the previous Issue 6 ref. MPTB-ESA-MO-0157 of 22.8.2024.

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.

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