EU chemicals regulation is not always easy to understand. In heated political discourse, it sometimes helps to put yourself in the other person's seat. In December, the European Commission published a new Q&A on the regulation of Cr(VI). The key points are as follows:

The new year is starting with a surprise. Some Cr(VI) applicants have unexpectedly received mail in their REACH-IT accounts. For all applicants for authorisations that are covered by another consortium, such as CTACsub 2 or HAPOC 1, and for whom ECHA has not yet issued an invoice for the processing fee, the processing of these applications for chromium trioxide will be suspended til further notice.

The reason for the letter is the EU Commission's consideration of prioritising other substances in light of the upcoming restriction on chromium trioxide. At the same time, authorisation applications (AfA´s), including those from members of VECCO e.V., are to be extended without bureaucracy until January 2029.

Is this good or bad news at the start of the new year? Is the authorisation model already dead?  What seems clear is that all indicators point towards restrictions. Unfortunately, even after the conclusion of the public consultation, the details remain unclear and will likely only become clearer when the ECHA comitees publish their opinion in May 2026.

EU Commission Q&A in December 2025 remains vague

Clarity on the reasonable question of whether authorisations will continue to be valid after the restriction comes into force should be provided by a Q&A published by the European Commission on 10th December 2025. Unfortunately, the document also remains vague and refers only to potential scenarios. However, it is clearly stated that with the removal of Annex XIV, the authorisation requirement and thus the basis for authorisation will no longer apply.

However, there are also voices in the political scene in Brussels who argue that legally binding decisions cannot simply be withdrawn by the authorities. Possible deroga­tions based on authorizations and a right of choice for applicants as to whether they want to act after authorization or after restriction are also currently being discussed. However, the right to choose, which we consider a pragmatic solution, is immediately counteracted by the fact that the transfer period is defined as only 18 months. This is a slap in the face for every authorization holder.

And the document has even more surprises in petto for us. All of a sudden, the element of substitution is to be integrated. Yet it is precisely these detailed, product-specific assessment that have led us to this level of detail and bureaucratic madness. There is a danger that the new regulation will start with the same flaws as the old one. A regulatory loop for the insane.

VECCO is fighting against this with all its might

We must fight this with all our strength. Political lobbying, discussions with national politicians and public pressure by social media campaigns. There is no other way. That is our mission for the next two years. Finally, the good news. Despite all these considerations, applicants are still covered by HAPOC 1, witch was submitted before the latest application date. This means that, at the end of the day, you can at least save on the ECHA application fee. This is budget that can certainly be put to good use elsewhere in companies.

Vecco Board of Directors

You can find the Q&A document here:

→download

“The famous chair of the other person’“: 

→LINK