The European Chemicals Agency has opened a public consultation on the draft opinion supporting an EU-wide REACH hexavalent chromium restriction. The comment window runs from 17 June 2026 to 17 August 2026. For any manufacturer that uses chrome plating, conversion coatings, or Cr(VI)-based surface treatments, this consultation is the last structured opportunity to shape a rule that will reshape supplier qualification, documentation, and market access across the European Union.

This is not a routine restriction. The European Commission has directed ECHA to remove a defined group of Cr(VI) substances from the Authorisation List (Annex XIV) and simultaneously introduce a new restriction under Annex XVII. It is the first time in REACH's history that substances would be de-listed from authorisation in this way. Understanding the mechanics now, well before the expected 2028 entry into force, is a governance priority, not a technical footnote.

If your organisation needs to map Cr(VI) exposure across products and suppliers quickly, you can book a compliance risk assessment to understand your current exposure before the comment deadline closes.

Key Takeaways

📌 ECHA's draft SEAC opinion proposes moving certain Cr(VI) substances from REACH Annex XIV authorisation to a new Annex XVII restriction, the first de-listing of its kind.

⏳ The 60-day consultation closes on 17 August 2026. This is a comment deadline, not a compliance deadline.

⚠️ No new obligation applies today. Existing Annex XIV authorisation duties remain in force unchanged until the restriction enters into effect.

📊 SEAC is assessing eight restriction options with option-dependent limits for worker exposure and emissions to air and water. Values are not yet fixed.

🏭 Metal finishing, aerospace and defence, automotive, electronics, medical technology, sanitary fixtures, and pyrotechnics are directly affected.

🔗 Barium chromate is added to the restriction on regrettable-substitution grounds, even though it was never on Annex XIV.

🤖 Realistic entry into force is late 2027 to Q4 2028, followed by a proposed 18-month transition. Aerospace qualification cycles mean substitution scoping should start now.

Executive Regulatory Overview

The consultation concerns SEAC's draft opinion on an Annex XV restriction dossier covering certain chromium(VI) oxides, oxyacids, and salts. ECHA is the dossier submitter, acting on a Commission mandate issued on 27 September 2023. The proposal was announced on 29 April 2025, and SEAC adopted its draft opinion in June 2026. The Committee for Risk Assessment has completed its opinion. What remains is stakeholder input, SEAC's final opinion at its SEAC-73 meeting, and eventual Commission adoption.

For compliance leaders, the important distinction is legal status. This is a draft committee opinion open for comment. It is not adopted law. That distinction shapes every decision about timing, budgeting, and supplier communication. You can review the live status on the ECHA Restrictions under consideration page and track dossier progress through the ECHA registry of restriction intentions.

Because Cr(VI) sits alongside other chemical frameworks your teams already manage, treating it inside a single chemical and hazmat compliance program rather than as an isolated project reduces duplicated effort and keeps evidence consistent.

Why the Commission Is Moving Cr(VI) From Authorisation to Restriction

The rationale is workload and legal certainty, not a new hazard finding. Cr(VI) compounds are recognised Substances of Very High Concern due to carcinogenicity, and they already require authorisation. The problem is volume. The number of authorisation applications and reviews for these substances has gone significantly beyond the annual capacity of RAC and SEAC, causing severe processing delays.

Moving to a restriction is designed to fix that bottleneck. Once the Commission adopts the restriction, the in-scope substances will be removed from the Authorisation List. This is the first time such an action would occur under REACH. The two legal acts, the Annex XIV de-listing and the Annex XVII restriction, are intended to enter into application simultaneously so there is no gap where the substances are neither authorised nor restricted.

This matters for suppliers holding current authorisations. Derogations under the restriction may not mirror granted authorisations in scope or timing. Teams that manage this through REACH compliance should not assume a like-for-like carryover of existing authorisation terms.

REACH hexavalent chromium restriction moving Cr(VI) from authorisation to restriction

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Substances and Use Categories in Scope

The dossier covers the Cr(VI) substances in Annex XIV entries 16-22 and 28-31, plus barium chromate as a new addition. Named substances include chromium trioxide (CAS 1333-82-0, EC 215-607-8), chromic acid, ammonium dichromate, potassium dichromate (CAS 7778-50-9, EC 231-906-6), sodium chromate, sodium dichromate, dichromium tris(chromate), pentazinc chromate octahydroxide, potassium hydroxyoctaoxodizincate dichromate, strontium chromate, and barium chromate (CAS 10294-40-3, EC 233-660-5). Official trackers describe at least 12 Cr(VI) compounds in scope, since some entries cover more than one substance.

Barium chromate is significant. It was never on Annex XIV. ECHA added it on regrettable-substitution grounds so companies cannot simply swap to a chemically similar, unrestricted alternative. The ECHA proposal announcement confirms this inclusion.

The draft restriction is structured around six use categories, and derogations follow these categories rather than product type. This is a critical point for BOM-level compliance intelligence, because you must classify each use, not just each part.

Six Use Categories (UC1-UC6)

The concentration trigger under the draft restriction is ≥ 0.01% w/w in mixtures, covering all stoichiometries and hydration forms. Mapping this threshold across a multi-tier supplier base is where BOM-level material mapping becomes decisive, since Cr(VI) can enter a product through coatings applied several tiers down.

Proposed Limit Values and the Eight Restriction Options

Here precision matters. The restriction would ban Cr(VI) uses except within the six categories, provided defined limits for worker exposure and environmental emissions are met. But those limits are not yet a single fixed set. SEAC is assessing eight options in parallel: three original options (RO1-RO3) and five alternative options (AO1-AO5), including a Maximum Release Factor approach of 0.01% or 0.1% instead of fixed emission caps.

Across these options, the ranges under discussion are broad. Worker 8-hour time-weighted average exposure spans roughly 0.1 to 5 µg Cr(VI)/m³. Air emission caps range from about 0.025 to 2.5 kg/year and water releases from 0.15 to 15 kg/year, depending on the option. The strictest original option, RO3, pairs the lowest emission limits with the tightest exposure controls. Because the final numbers are still open, any statement of a single definitive limit is premature.

A proposed uniform 18-month transition period is itself a live point of consultation. Industry bodies are already treating both the transition period and the specific limit values as contested. Keeping these moving parameters current is a regulatory intelligence and horizon scanning problem, not a one-time read.

REACH hexavalent chromium restriction proposed limit value ranges under review

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isible. Must read in five seconds and communicate that values are ranges, not final.

Industries and Product Categories Affected

The restriction reaches deep into durable-goods manufacturing. The clearest exposure sits in metal finishing and surface treatment, where electroplating on plastic and metal substrates and conversion coatings are core processes.

• Aerospace and defence: chrome plating and conversion coatings on structural and landing-gear components. Qualification cycles for alternatives are long, so early scoping matters for aerospace and defense supply chains.

• Automotive and mechanical engineering: functional and decorative plating across components managed by automotive manufacturers.

• Electronics: functional chrome plating and Cr(VI)-based conversion coatings on connectors and housings, an area where electronics manufacturers already track Cr(VI) under RoHS.

• Medical technology, sanitary and plumbing fixtures, and the energy sector.

• Pyrotechnics: barium chromate specifically, used in delay compositions.

• Chemical formulators: producers of Cr(VI)-containing mixtures for the uses above.

Cr(VI) is already restricted in electrical and electronic equipment under RoHS, so many electronics teams have partial data. The REACH restriction broadens the obligation well beyond EEE, which is why a centralized compliance data backbone spanning multiple frameworks avoids duplicated supplier requests.

What the Consultation Actually Requires Right Now

There is no new compliance obligation today. This is the operative point for executives allocating budget. Existing Annex XIV authorisation obligations remain in force unchanged. The only actionable date right now is the comment deadline of 17 August 2026.

Comments are submitted through ECHA's structured online form, which covers general non-confidential input plus structured questions on use categories, sector impact, the proposed 18-month transition period, and the specific limit-value options. If your operations depend on chrome plating or conversion coatings, deciding whether to comment, directly or through an industry association, is a strategic call worth making before the window closes.

For organisations weighing whether to respond, a compliance review with a specialist can help translate your process data into evidence that carries weight in the consultation.

Documentation, Audit, and Supply Chain Impact

Even though the rule is years from application, the documentation problem starts now. To respond credibly to the consultation, and to prepare for eventual compliance, you need to know exactly where Cr(VI) sits across products and suppliers. That is a data problem before it is a chemistry problem.

Three audit contexts will eventually test this data. Customer audits, typically OEM-driven, will ask whether specific parts contain Cr(VI) above threshold. Regulatory inspections through ECHA-linked market surveillance will test declared status against evidence. Certification audits under ISO 9001, IATF 16949, and ISO 14001 will examine whether your management system tracks restricted-substance obligations. In each case, the objective is to be audit-ready, not audit-proof. No software eliminates findings. The realistic goal is to reduce surprises and shorten response time from days to hours.

That requires evidence-chain integrity: who provided each declaration, when, and with what authority. It also requires historic state tracking, treated as a data-versioning problem with time-stamped declarations and point-in-time retrieval, so you can show what you knew and when. This is the foundation of continuous audit-ready documentation and of the customer trust-center model that large OEMs increasingly expect from their suppliers.

Collecting Cr(VI) status across tiers is where multi-tier supply chain transparency and automated supplier data collection replace spreadsheet chasing that cannot scale to a use-category-based restriction.

Timeline and Enforcement Outlook

Based on currently available regulatory guidance, the best case is adoption by late 2027 or early 2028, with a more realistic path pointing to around Q4 2028. Even with an 18-month transition after adoption, aerospace and defence qualification timelines for plating alternatives are long enough that substitution scoping is warranted now.

Compliance Preparation Checklist

✅ Identify all Cr(VI) uses across products and the supplier base: chrome plating on plastic and metal substrates, conversion coatings, primers, slurry coatings, and functional additive or process-aid uses.

✅ Classify each use against the six categories UC1-UC6, since derogations follow use categories, not product type.

✅ Flag suppliers holding current Annex XIV authorisations and note that terms may not carry over one-for-one.

✅ Decide whether to submit consultation comments by 17 August 2026, particularly on the 18-month transition and the limit-value options.

✅ Begin scoping substitution and alternative-process options now for plating and coating uses with long qualification cycles.

✅ Track SEAC-73 and monitor whether the elective transition option for existing authorisation holders is confirmed.

✅ Consolidate Cr(VI) data with RoHS and REACH SVHC obligations to avoid duplicate supplier requests.

How AI-Native Compliance Automation Reduces the Burden

A use-category-based restriction across a multi-tier supply chain is difficult to manage manually. The work is not just collecting declarations. It is classifying each use, mapping the ≥0.01% w/w threshold to specific parts, and keeping option and timeline changes current through adoption.

AI-native compliance automation addresses each layer. CORA-powered regulatory intelligence monitors the dossier, the consultation, and eventual adoption, alerting teams to changes in scope, limits, and transition timing before they take effect. AI document parsing and certificate validation extracts Cr(VI) status from supplier declarations, test reports, and safety data sheets, flagging incomplete or inconsistent responses at intake rather than during an audit.

Linking that data to bill-of-materials structures turns raw declarations into BOM-level compliance intelligence, so procurement and quality teams can answer, at the part level, which products contain a restricted Cr(VI) substance above threshold. This is the shift from reactive, deadline-driven compliance toward continuous readiness. For teams still moving off spreadsheets, the broader case is covered in AI tools for compliance management.

REACH hexavalent chromium restriction compliance readiness workflow for manufacturers

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Executive Conclusion

The REACH hexavalent chromium restriction is a structural change to how the EU regulates a widely used class of surface-treatment chemistries. It is the first time REACH would de-list substances from authorisation and replace that regime with a restriction, and it reaches aerospace, automotive, electronics, medical, and metal-finishing supply chains at the same time.

Nothing is due today except a decision about whether to comment before 17 August 2026. But the data work that makes both a strong consultation response and eventual compliance possible starts now, because you cannot manage what you have not yet mapped. Organisations that consolidate Cr(VI) alongside their existing REACH and RoHS obligations, automate supplier data collection, and maintain audit-ready evidence will absorb the 2028 restriction with far less disruption than those that wait.

To understand your current Cr(VI) exposure across products and suppliers, book a compliance risk assessment or speak with a compliance specialist before the consultation window closes.