Today was the ECHA webinar and the start of the consultation process. I was really excited, but in the end, I found myself wondering what I had actually learned.

I will try to summarise my thoughts and impressions of the webinar for Vecco members:

Restriction proposal for certain chromium (VI) oxides, oxyacids and salts.

As of today, we are in phase 2 of the restriction. This marks the start of both the public consultation and the work of SEAC and RAC. As a result, important information must be provided by an ‘early deadline’ on 18 September, even though the public consultation will actually remain open until 18 December. Fortunately, this aspect has been addressed, as

participating in the public consultation in the second half of the period seems rather pointless. At the beginning of 2026, the RAC and SEAC's assessment will then be forwarded to the EU Commission.

Now to the actual results. The ECHA's approach is to be purely risk-based. This is why the wastewater values are relatively high and the air values very low, as emissions into the air are more problematic for residents living near the production facilities.

This brings us to a major problem (which I also asked about). There is no distinction based on company size. The argument here is that company size is irrelevant to residents. This gives several small companies in the same location an advantage, or rather, a large company would be better off having two locations than one large one...

Large companies URGENTLY need to get involved here.

The data was taken from the call for evidence. The older data from the authorisations (some of which is 10 years old) was ignored and only used to check consistency. (For me, this means that it is better to participate too often than too rarely if old data is not taken into account.)

This results in a curve for the proportion of businesses that comply with the air concentration limit, based on the data provided by the companies and associations.

This curve also shows that the coating of plastics (POP) has a lower average concentration of Cr(VI) in the air. Therefore, according to the ECHA's proposals, a lower limit value should be introduced here. The idea is that employees can be protected even better with little additional financial outlay. The fact that this does not fit in with the purely risk-based approach (i.e. every employee is equally important) is ignored.

However, the range of exposures is also enormous. This is one point where I am really disappointed with the ECHA. The aim should be to protect all employees in all locations in Europe adequately. Adequate in the sense of reasonable handling that protects employees and is still feasible. How can the values be so different? And why are the limit values not the same across Europe? This would be good for a fair market.

However, the annex to the proposal also contains a proposal for a general value. This raised the question of what applies if an employee works with both plastic and chrome at the same time.

Finally, the question of socio-economic analysis was addressed:

This clearly argues against proposal 3, although I would also consider proposal 2, with a negative benefit of 2.17 billion, to be loss-making. The absolute limit value could possibly be changed by protective measures (e.g. masks). These would then be individual for each country and not comparable...

The question of what happens with authorisations is not one of the tasks of the ECHA. I personally have no idea who is responsible for this, but I am looking forward to the answer (perhaps the Commission? Or perhaps no one?).

Yours, Dr Julius Gröne