Key Facts on the Authorization of Chromates

for the Aviation Industry based on European REACH Regulation (Registration, Evaluation, Authorization and Restriction of Chemicals, EC 1907/2006) 

Table of Content


1. Basic Facts to know about REACH and the Authorization of Chromates
2. Frequently Asked Questions
3. Holder of Authorization
4. Authorized Substances
5. Mankiewicz Products Covered by Authorizations
6. Uses Covered by the Authorizations
7. Key obligations following the authorizations granted
8. Exposure Scenarios (ES)
9. Good Practice Sheets (GPS)
10. Notification acc. to Art. 66 of the REACH Regulation ((EC) No. 1907/2006))
11. Monitoring
12. Monitoring Reporting Template
13. Notification of Key Functionalities
14. Commission Implementing Decisions & Supporting Documents
15. Disclaimer

 

1. Basic Facts to Know about REACH and the Authorization of Chromates

The Registration, Evaluation and Authorization of Chemicals (“REACH”) (EU Regulation 1907/2006) regulates the manufacturing, import, and use of chemicals in the European Union. In addition to registration, REACH also provides for pre-market authorization of certain chemicals that are considered of particular concern. Those substances are listed in Annex XIV of REACH. Any company using a substance in the EU that is listed in Annex XIV must obtain a REACH authorization from the European Commission. The application for such REACH authorization must be filed with the European Chemicals Agency (‘ECHA’). The authorization process aims to ensure that substances of very high concern (SVHCs) are progressively replaced by less dangerous substances or technologies where technically and economically feasible alternatives are available.

 

2. Frequently Asked Questions

Jones Day, representing the CCST consortium, has regularly issued Q&A to properly inform about the status of authorization. The most recent version of Q&A is from April 2020 and can be found here

 

3. Holder of Authorization

FINALIN GmbH as authorization holder acts as full representative of Mankiewicz Gebr. & Co. (GmbH & Co. KG). The authorization numbers given for FINALIN GmbH are therefore fully applicable for the respective products of Mankiewicz Gebr. & Co. (GmbH & Co. KG).

 

4. Authorized Substances

FINALIN GmbH has been granted authorizations for below listed substances. Consequently, products including those substances may only be used for authorized aerospace applications. These particular uses are detailed in chapter “6. Uses covered by the authorizations”.

For the authorized substances, the following abbreviations will be used hereafter:

Strontium Chromate – SC
Pentazinc Chromate Octahydroxide – PCO
Potassium Hydroxyoctaoxodizincate Chromate – PH

SubstanceCAS-NoAuthor. No. Use 1 FormulationAuthor. No. Use 2 ApplicationDate of AuthorizationReview
Period
End of Review Period
SC7789-06-2REACH/20/7/4REACH/20/7/1416.04.20207 years22.01.2026
PCO49663-84-5REACH/20/11/1REACH/20/11/330.03.20207 years22.01.2026
PH49663-84-5REACH/20/6/1REACH/20/6/615.04.20207 years22.01.2026

5. Mankiewicz Products Covered by Authorizations

Product Name

Substance(s)Author. No. Use 1 FormulationAuthor. No. Use 2 Application
SEEVENAX® Low VOC Primer 113-07SCREACH/20/7/4REACH/20/7/14
SEEVENAX® Grundbeschichtung 113-22SCREACH/20/7/4REACH/20/7/14
SEEVENAX® Grundbeschichtung 113-22 (TUK)SCREACH/20/7/4REACH/20/7/14
SEEVENAX® Grundbeschichtung 113-25PHREACH/20/6/1REACH/20/6/6
SEEVENAX® Grundbeschichtung 113-82SCREACH/20/7/4REACH/20/7/14
SEEVENAX® Primer 313-01SCREACH/20/7/4REACH/20/7/14
SEEVENAX® Primer 313-01 (FlatPack)SCREACH/20/7/4REACH/20/7/14
SEEVENAX® Primer 313-81SCREACH/20/7/4REACH/20/7/14
SEEVENAX® Primer 313-81 (TUK)SCREACH/20/7/4REACH/20/7/14
CELEROL® WashPrimer 913-21PCO
PH
REACH/20/11/1
REACH/20/6/1
REACH/20/11/3
REACH/20/6/6

6. Uses Covered by the Authorizations

SubstanceAuth. No. 
Use 1
Description
of Use 1
Auth. No.
Use 2
Description of Use 2
SCREACH/20/7/4Formulation of mixtures intended exclusively for uses bearing authorization numbers REACH/20/7/10 to REACH/20/7/19REACH/20/7/14Application of primers and specialty coatings in the construction of aerospace and aeronautical parts, including aeroplanes / helicopters, spacecraft, satellites, launchers, engines, and for the maintenance of such constructions for the aerospace sector in which any of the following key functionalities is required: corrosion resistance, adhesion of paint / compatibility with binder system, layer thickness, chemical resistance, temperature resistance (thermal shock resistance), compatibility with substrate or processing temperatures
PCOREACH/20/11/1Formulation of mixtures exclusively for uses bearing authorization numbers REACH/20/11/2 and REACH/20/11/3REACH/20/11/3Use in wash primers, fuel tank primer and aluminized primer for the purpose of corrosion protection in aeronautic applications where any of the following key functionalities or properties is necessary for the intended use: corrosion resistance, active corrosion inhibition, adhesion, chemical resistance, layer thickness, temperature resistance, compatibility with other substrate/other coatings, dynamic performance (only for fuel tank primer) and appearance (only for aluminized primer)
PHREACH/20/6/1Formulation of mixtures intended exclusively for uses REACH/20/6/5 to REACH/20/6/9REACH/20/6/6In primer and coatings (including as wash primers) for the aerospace sector in which any of the following key functionalities is required: corrosion resistance, adhesion of paint / compatibility with binder system, layer thickness, chemical resistance, temperature resistance (thermal shock resistance), compatibility with substrate and processing temperatures

 

Any other use of the products is prohibited by law and will be punishable by fines. You and/or your sub-tiers as end-users of the products are solely responsible for the REACH-compliant application and compliance with the aforementioned requirements. Please inform your sub-tiers / end-customers accordingly about the restricted use and applicable work space conditions.

 

7. Key Obligations Following the Authorizations Granted

Authorization Holders

  • Print the Authorization Number on labels, MSDS and TDS
  • Inform customers about their use of authorized products
  • Provide the conditions of use of such product to the DU in the form of exposure scenarios (ES) as part of an updated MSDS

Downstream Users (DUs (Customers)) within the European Union

DUs in the supply chain of the applicants can continue their uses until the end of the respective review periods if they can demonstrate to the competent authorities of the EU Member States that

  • they belong to the same supply chain as the authorization holder
  • their uses fit within the use descriptions of the authorization decisions (see chapter “6. Uses covered by the authorizations”)
  • they are compliant with the operational conditions (OCs) and risk management measures (RMMs) set out in the Exposure Scenarios and the authorization decisions
  • the conditions of the authorization decisions are complied with.

Acc. to Article 66 REACH DUs must notify ECHA (via REACH-IT) that they use materials containing substances, which are subject to authorization and give the respective explanation and justification for the necessity of key functionalities. This notification has to be made at latest 3 months after the authorization decision was published in the Official Journal of the European Union. (see also chapter “10. Notification acc. to Art. 66 of the REACH Regulation ((EC) No. 1907/2006”)

SubstanceDate / DeadlineAction / Obligation
SC
PCO
PH
April 16, 2020
March 30, 2020
April 15, 2020
Authorization Decision issued
SC
PCO
PH
July 16, 2020
June 30, 2020
July 15, 2020
Implementation of new specific exposure scenarios as provided in the MSDS
SC
PCO
PH
July 23, 2020
July 6, 2020
July 22, 2020
Art. 66 notification to ECHA
SC
PCO
PH
Oct. 16, 2020
Sept. 30, 2020
Oct. 16, 2020
DUs to conduct first workers exposure measurement campaigns according to the monitoring template made available via GPS E2 here.
SC
PCO
PH
Oct. 16, 2020
Sept. 30, 2020
Oct. 16, 2020
DUs to implement monitoring programs for Chromium (VI) emissions to wastewater and air from LEV according to the monitoring template made available via GPS E3 here.
SC
PCO
PH
April 16, 2021
March 30, 2021
April 15, 2021
DUs to notify data from workers exposure measurements and air and waste water monitoring to ECHA under Art. 66 REACH. This will be an amendment of the previous Art. 66 notification. More detailed information can be found in the Annex 1 of the Jones Day Q&A.

 

Distributors within the European Union

  • Ensure that their customers within the European Union are aware of the authorization of the affected products, as well as the obligations connected with theses products
  • Forward  the conditions of use to your customer
  • Provide the exposure scenarios (ES) as part of an updated MSDS are made available to your customers

8. Exposure Scenarios (ES)

The authorization holders are obliged to develop specific exposure scenarios for representative processes, operations and individual tasks describing risk management measures (RMMs) and operational conditions (OCs) representative for all sites at which the authorized uses take place, which are used to control worker exposure to chromium (VI) and its emissions to the environment, in each of the specific scenarios.

These exposure scenarios are made available to the downstream users in an updated safety data sheet at the latest 3 months after the authorization has been granted. The downstream users shall apply the RMMs and OCs included in the specific exposure scenarios without undue delay.

 

9. Good Practice Sheets (GPS)

The authorization holders have developed easy-to-use practical advice to DUs in the form of so-called Good Practice Sheets (‘GPS’), which will be periodically updated if necessary. These are available here in section III. “Good Practice Sheets for Uses of Chromium Trioxide and Miscellaneous Chromates”.

 

10. Notification acc. to Art. 66 of the REACH Regulation ((EC) No. 1907/2006))

According to Article 66 of the REACH Regulation ((EC) No. 1907/2006) any company using above mentioned substances needs to notify ECHA about their use, unless they are also holders of authorization for the use. They will need to do so within three months of the first supply of the substance after the authorization decision has been published in the Official Journal of the European Union (22/04/2020). Else, their use is not in compliance with the REACH Regulation. 

Date of Publication in the Official Journal of the European Union:

SC: 23.04.2020
PCO: 06.04.2020
PH: 22.04.2020

Further information about the downstream user notifications process can be found here.

 

11. Monitoring

The authorization decision requires Downstream Users to provide to ECHA the information from the monitoring programmes, including the contextual information associated to each set of measurements. The required information needs to be provided as an attachment in their notifications, for the first time by

SC: 16.04.2021
PCO: 30.03.2021
PH: 15.04.2021

As the deadline for the notification may be earlier than the deadline for the additional required data, downstream users can provide this data in an update of their notification, by the deadline set in the decision (see above).

In addition, the downstream users shall include in the notification to ECHA a justified explanation of the key functionalities which are necessary for their use. This information should be provided in the field “Further description of the use”. Please see also chapter “13. Notification of Key Functionalities”below.

 

12. Monitoring Reporting Template

A Monitoring Reporting Template is provided to downstream users in the format of a GPS. These are available here in section III. “Good Practice Sheets for Uses of Chromium Trioxide and Miscellaneous Chromates”. GPS No. E2bis „Implementing and Reporting Worker Exposure Monitoring” and E3bis “Implementing and Reporting Environmental Monitoring”

 

13. Notification of Key Functionalities

A template for notification of key functionalities can be found in section “IV. Notification Template – Key Functionalities of Miscellaneous Chromates” here.  

 

14. Commission Implementing Decisions & Supporting Documents

The full list of authorization decisions from the European Commission can be found here.

This list of authorization decisions can be downloaded as .pdf document here, offering you full access to all documents, which are related the authorization of a certain substance. For the substances, that FINALIN GmbH is holding authorizations, please find below a summary of documents/reference:

 

Strontiumchromate (SC)

Commission Implementing Decision
Reference: C/2020/2076
English, German

Official Journal of the European Union (available in all European languages)
Exposure Scenario(s) from application (Chemical Safety Report - CSR)

Further ECHA Documentation
Use 1 – Formulation
Use 2 – Application

 

Pentazinc Chromate Octahydroxide (PCO)

Commission Implementing Decision
Reference: C/2020/1841, English

Official Journal of the European Union (available in all European languages)

Exposure Scenario(s) from application (Chemical Safety Report - CSR)
Use 1
Use 2

Further ECHA Documentation
Use 1 – Formulation
Use 2 – Application

 

Potassium Hydroxyoctaoxodizincate Chromate (PH)

Commission Implementing Decision
Reference: C/2020/2089, English

Official Journal of the European Union (available in all European languages)
Exposure Scenario(s) from application (Chemical Safety Report - CSR)

Further ECHA Documentation
Use 1 – Formulation
Use 2 – Application

 

15. Disclaimer

The information contained herein is believed to be reliable, but no representations, guarantees or warranties of any kind are made to its accuracy, suitability for particular applications or the results to be obtained. Our advice does not release you from the obligation to verify the information provided to check for updates for any information provided by us and to test our products as to their suitability for the intended processes and uses. Any liability on our part for damage resulting from improper use or faulty application whether based on contract, breach of contract, tort (including negligence and strict liability), or any other theory of law is expressly excluded, except as required by mandatory law, such as in case of personal injury or death.