On April 29, 2025, the European Chemicals Agency (ECHA) announced its intent to propose a wide-reaching restriction on hexavalent chromium (Cr(VI)) substances under REACH. While the restriction is not yet in effect, a formal proposal is expected later this year—prompting global manufacturers, especially in the U.S., to begin evaluating potential impacts now. For companies that manufacture or export products containing Cr(VI), the coming changes could significantly influence regulatory obligations, product formulations, and access to the European market.
Why the EU is Targeting Chromium (VI)
Hexavalent chromium compounds are widely used for their anti-corrosive and surface-hardening properties in coatings, plating, and pigments. These functional materials are essential in heavy industrial sectors such as aerospace, automotive, and metal finishing. However, Cr(VI) substances are also classified as carcinogens and present serious health risks to workers, particularly through inhalation and dermal exposure.
ECHA has concluded that the existing authorization mechanism under REACH does not provide sufficient protection or efficiency in managing these risks. As a result, the agency plans to introduce a restriction under Annex XVII of the REACH Regulation—a move that would apply uniform limits across the EU without the need for individual use applications.
What’s Covered in the Planned ECHA Chromium (VI) Restriction
The upcoming proposal will cover many Cr(VI) substances already subject to authorization: chromium trioxide, sodium dichromate, potassium dichromate, ammonium dichromate, potassium chromate, and others. It will also expand regulation to additional compounds, including barium chromate, sodium chromate, strontium chromate, zinc chromate, and certain uses of chromium trioxide. Other structurally related compounds used in surface treatments and coatings are also expected to be included.
These substances are commonly applied in industrial processes such as electroplating, passivation, and anti-corrosion treatments, as well as in the formulation of primers and protective slurries. As a result, the restriction could affect a broad set of industries, including aerospace, automotive, defense, construction, electronics manufacturing, and industrial coatings—sectors where Cr(VI) plays a key role in extending product lifespan and performance under harsh conditions.
Where the Proposal Stands Today
The restriction has not yet been proposed. ECHA is scheduled to submit the formal proposal on October 4, 2025.
Once submitted, the restriction will undergo:
- A six-month public consultation period
- Scientific review by ECHA’s Committees for Risk Assessment (RAC) and Socio-Economic Analysis (SEAC)
- Final decision-making by the European Commission and EU Member States
If adopted, this restriction could replace the need for REACH Authorization for certain uses—streamlining regulation but also tightening overall conditions for use.
Global Implications: Why Producers Should Take Note
Even though the restriction is EU-based, its impact will extend well beyond Europe’s borders.
Exporters to the EU may need to cease certain uses of Cr(VI), prove compliance under new conditions, or reformulate products to remain eligible for the European market.
Suppliers to EU-facing industries, including U.S. and other international producers, could face increased pressure from downstream customers to verify Cr(VI)-free status or adapt inputs as part of enhanced supply chain due diligence.
The wider influence of EU policy is also worth noting. European chemicals regulation frequently sets a de facto global standard. Companies aiming to future-proof their product lines may benefit from early alignment, even in jurisdictions where legal requirements have not yet changed.
Timeline at a Glance
| Milestone | Date |
| ECHA announces intent | April 29, 2025 |
| Formal proposal submission | October 4, 2025 |
| Public consultation (6 months) | Late 2025–Early 2026 |
| Scientific review and opinion phase | Throughout 2026 |
| Potential entry into force | As early as 2027 |
Preparing for Change: Key Steps for Manufacturers
Global producers can begin preparing now to reduce compliance risk, avoid supply chain disruption, and meet growing customer demand for safer, more sustainable materials.
Recommended actions include:
- Auditing product portfolios: Identify where Cr(VI) substances are used in coatings, processes, or formulations.
- Engaging with suppliers and EU partners: Start conversations about possible changes and upcoming requirements.
- Evaluating safer alternatives: Explore non-Cr(VI) materials that meet performance and regulatory needs.
- Monitoring the proposal process: Participate in the consultation phase or follow updates through industry groups and regulatory alerts.
A Look Ahead
The ECHA chromium (VI) restriction reflects the EU’s broader push to reduce workplace exposure to hazardous substances. While the regulation has not yet been adopted, the trajectory is clear: stricter controls, more uniform application, and greater pressure on industry to transition to safer alternatives.
For manufacturers worldwide, this is a pivotal opportunity to assess chemical risks and begin adapting before regulatory deadlines force reactive changes. The restriction on hexavalent chromium is coming, but there’s still time to prepare. Whether you export directly to Europe or support EU-linked supply chains, early planning will position your business to respond with confidence and continuity.
If your business is navigating the complexities of REACH compliance or assessing the impact of upcoming chromium (VI) restrictions, Tetra Tech’s regulatory experts are here to help. With decades of experience in EU product compliance and reporting, we can support you at every stage—from portfolio audits to consultation strategy. Contact us at [email protected] to get started.
