REACH reporting deadline for users of chromium trioxide on 18 December 2021 – updated guideline for users in the European Space Sector

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ASD-Eurospace wishes to remind users of chromium trioxide (CAS 1333-82-0) in the European Space Sector to report their monitoring data for workplace exposure, air and wastewater emission measurements to the European Chemicals Agency (ECHA) by 18 December 2021.

This requirement is set out in the EU REACH authorisation decision C(2020) 8797 final of 18 December 2020, which was issued by the European Commission to company Chemservice GmbH and others (“CTACSub Consortium”). It applies to all users of chromium trioxide as a substance or part of a mixture, who rely on this “upstream” decision under Article 56(2) of the EU REACH Regulation. These users were already required to submit their initial “REACH Article 66” notifications to ECHA by 23 March 2021 (CTACSub recommendation). For many users, the present reporting requirement will therefore be an update of their initial notifications. ECHA has already received close to 1,500 REACH Article 66 notifications from users of CrO3.

Earlier this autumn ECHA has issued a specific format to be used for reporting the monitoring data under the CTACSub authorisation decision; it is available here (if the link does not open, please look for it on the ECHA Article 66 notification page).

ASD-Eurospace is also pleased to share the update of the related REACH compliance guideline, available HERE, replacing the previous version (see Eurospace news alert of 9 February 2021). The update includes a number of clarifications and developments in 2021 in relation to the CTACSub authorisation.

The guideline aims to facilitate compliance for the continued use of chromium trioxide in chemical conversion coatings for space hardware after the REACH authorisation sunset date on 21 September 2017. It focuses on certain formulations by HENKEL, namely BONDERITE M-CR 1200 AERO, BONDERITE M-CR 1200S AERO and BONDERITE M-CR 600 AERO.

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.

Contacts:

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