The public consultation on the proposed restriction of chromium trioxide closed on 18 December 2026. A total of 251 submissions were received – significantly fewer than for PFAS, for example, but no less politically contentious. Vecco e.V. has analysed these submissions.

153 contributions came from companies, 58 from associations. In addition, there were contributions from government organisations and NGOs. The majority of the comments essentially support the industry’s positions. However, the views expressed by the Member States are decisive, as they will ultimately decide the way forward politically.

Four Member States have taken a stance: Germany, Sweden, Norway and Belgium. The trend is clear – stricter scientific limit values, greater pressure to substitute substances and a more restrictive approach to certain decorative applications.

In particular, the European occupational exposure limit (BOEL) of 5 µg/m³ is under criticism. Several countries are calling for a reduction to 1 µg/m³. Norway goes even further and is aiming for a gradual reduction in emission limits.

These are all heavy burdens for industry. But what is far more significant – and, in our view, absolutely incomprehensible – is Sweden’s demand for substitution plans, an analysis of alternatives based on end products and ancillary conditions, as is the case with authorisation. In this way, the restriction gets lost again in micromanagement.

Critics see this as “authorisation through the back door” – even though one of the guidelines in the EU Competitiveness Compass is actually “Simplification”.

What does this mean for industry, competitiveness and regulatory planning certainty?

Read the full analysis by Vecco e.V. in the members’ area and find out which political points of contention are now emerging.