Exactly one year ago, the Paris 2024 Olympic Games came to a close, symbolised by the medals awarded to athletes. Yet by January 2025, more than a hundred bronze medals were already showing visible signs of deterioration(1).
The reason: a failure in surface treatment.
The usual, well-established surface treatment process could not be applied because of the unavailability of Chromium Trioxide (CrO₃), a key substance in the treatment process that has been subject to REACh authorisation since 2013(2). This issue arose from a lack of regulatory anticipation.
The Weight of Regulation in Industrial Decision-Making
Chromium Trioxide has been listed in Annex XIV of REACh for over a decade, meaning its use requires prior authorisation.
We won’t revisit the fundamentals of the REACh authorisation process or the central role of Annex XIV in managing substances of very high concern. It is now widely acknowledged that understanding and anticipating these regulatory requirements is essential for all actors in the value chain – from manufacturers and importers to formulators and applicators.
This case once again highlights that regulatory anticipation, impact assessment (technical and commercial), and consideration of long administrative timelines are not optional but key levers to protect industrial continuity and corporate reputation.
The Resilience of REACh: From Authorisation to Restriction
The Chromium (VI) authorisation case pushes the REACh framework to its limits, testing its adaptability and flexibility.
According to Article 60 of REACh, the duration of an authorisation is determined on a case-by-case basis, generally between 4 and 12 years. “Case-by-case” means that each application, for each legal entity, must be assessed on its own technical merits (alternatives, substitution, socio-economic analysis, human health and environmental risks). But how can hundreds of dossiers submitted since 2015 be managed efficiently?
The European Commission, via ECHA, is now shifting towards a restriction process: a generic ban with potential derogations. We discussed this evolution back in January(3).
Ongoing discussions are shaping the contours of this future restriction, reaffirming the core principles of REACh: protection of human health and the environment(4). The main direction is clear: a general ban on the use of Chromium (VI) compounds, unless strict conditions are met.
Practically, companies along the entire supply chain would only be allowed to continue using these substances if they can demonstrate strict control of occupational exposure and emissions below defined thresholds. The proper application of these regulatory requirements would then rely heavily on cooperation between industry and local authorities.
According to the current timeline, comments on the restriction report are being collected until mid-December 2025, and the RAC is expected to start reviewing the dossier during its September meeting.
This upcoming regulatory shift aims to simplify processes while requiring industry to tightly control exposures and emissions. A major question remains: how can consistent enforcement be ensured across different local contexts with varying resources and commitment?
🔎 Our Expertise
At EQUITOX, we support our clients in analysing REACh compliance, preparing authorisation dossiers, and adapting to new restriction requirements.
This case illustrates how technical, regulatory, and strategic challenges are now deeply interconnected.
📧 Contact us to anticipate and prepare for future regulatory developments.
References:
(1) https://traitementsetmateriaux.fr/des-medailles-en-peau-de-croco
(2) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32013R0348&qid=1644848496011
(3) https://www.linkedin.com/posts/equitox_voici-le-caracal-un-f%C3%A9lin-m%C3%A9connu-aux-nombreux-activity-7286053653700857856-5r2w?utm_source=share&utm_medium=member_desktop&rcm=ACoAAAiDPusB5WZNJoiUQLafrHI2e8LTz8F9ywE
(4) https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e18971243a