Continued use of chromium trioxide under EU REACH while new authorisation decisions are pending – updated guidelines of 22.8.2024 for users in the European Space Sector

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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 22.8.2024 (MPTB-RL-MO-0157), available HERE.  

The described use continues to be allowed in the EU until further notice if it is covered by the application for authorisation by Chemservice and others (known as the ‘CTACSub’ application), available here: ECHA-ID 0032-04. In case you should receive information from Henkel about a supplier switch away from CTACSub applicants, you must ensure coverage by the then applicable upstream application or review report, including the possible need to submit a new REACH Article 66 notification.

In the near future the use is likely to be covered by a new authorisation based on a submission by a group of companies (Haas Group International et al.) as part of the Aerospace and Defence Chromates Re-Authorisation Consortium (ADCR), available here: ECHA-ID 0337-02.

The updated space sector guidelines of 22.8.2024 in the form of questions-and-answers contain further information and references on the required actions for downstream users to be covered by the applicable upstream application or review report, and the future ADCR-based authorisation.

In the updated guidelines you will also find information for the use if taking place in Great Britain; 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 is currently expected by the end of 2026 at the earliest).

Please note that the present guidelines replace the previous Issue 5 ref. MPTB-ESA-MO-0126 of 27.7.2023 (published HERE).

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: Pierre Lionnet, Research and Managing Director, ASD-EUROSPACE, pierre.lionnet@eurospace.org, +33 (0)1 44 42 00 70
  • REACH Expert: Tim Becker, Senior Legal Advisor, REACHLaw Ltd., tim.becker@reachlaw.fi; +358 (0)40 773 8143