REACH Annex XVII: chromium(VI) restriction proposal moves toward final SEAC opinion

What changed

ECHA is advancing a restriction proposal for a group of certain chromium(VI) oxides, oxyacids and salts, aimed at reducing risks to human health from these substances. The proposal would limit use to specific use categories and introduce conditions such as worker exposure limit values and emission limits to air and water.

The SEAC draft-opinion public consultation ran from 17 June 2026 to 17 August 2026 (23:59 Helsinki time) and is now closed. The file has moved into the next step: SEAC will assess the submitted input before finalising its opinion.

Current regulatory stage

This is not yet a binding Annex XVII restriction. SEAC's final opinion is expected around the end of 2026. After that, ECHA sends the joint RAC and SEAC opinions to the European Commission, which decides whether to include the restriction in REACH Annex XVII — and, if so, on what terms and transition period.

Use categories under review

• Formulation of mixtures
• Electroplating on plastic substrate
• Electroplating on metal substrate
• Use of primers and other slurry coatings
• Other surface treatments
• Use as a functional additive or process aid

Why this needs attention

This proposal could significantly affect companies currently using Cr(VI) substances under REACH authorisation or in surface-treatment processes. The consultation considered a range of possible worker exposure limit values and emission limits to air and water, with the strictest options being the most disruptive for current processes; the final figures depend on SEAC's opinion and are not yet settled. Sectors most exposed include surface treatment, electroplating, aerospace, automotive, defence, machinery, electronics and metal finishing.

Compliance impact

Companies should not change SDSs or labels only because this restriction proposal is advancing — a REACH restriction proposal is not the same as a CLP harmonised classification. Affected companies should, however, prepare for possible operational change along this chain: Cr(VI) use → worker exposure control → emissions monitoring → authorisation/restriction transition → substitution planning → customer qualification.

Recommended actions

• Identify all Cr(VI) substances and mixtures used in EU/German operations.
• Map each use to the ECHA use categories: formulation, electroplating, primers/slurry coatings, surface treatment, or process aid.
• Collect recent personal exposure measurements, not only area monitoring.
• Quantify current Cr(VI) emissions to air and water as a baseline against any future limit.
• Review engineering controls: closed systems, local exhaust ventilation, bath covers, automation, scrubbers and wastewater treatment.
• Evaluate substitution options and document why alternatives are, or are not, technically feasible.
• Prepare investment estimates for exposure and emission reduction, in case tighter limits are adopted.
• Update customer qualification timelines, especially for aerospace, automotive, defence and electronics customers.
• Keep the regulatory status recorded as "REACH restriction proposal — under opinion-making," not as an adopted Annex XVII restriction.
• Maintain current REACH authorisation and workplace obligations until a final legal restriction is adopted.
• Set a review trigger for when SEAC's final opinion is published.