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Chrome VI handling compliance

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(substances subject to authorisation within the regulation (EC) N°1907/2006 called REACH regulation)

Where can I find the list of substances subject to authorisation?

The objective of the authorisation procedure is to ensure that substances of very high concern (SVHC) are progressively replaced by other less hazardous substances or technologies when suitable economically and technically viable alternatives exist.

Where can I find the list of substances subject to authorisation?

The substances concerned and subject to authorisation are listed in Annex XIV of the REACH regulation.


Please note that this information is available in section 15 of the safety data sheet.

The particular case of Chrome VI

Chrome VI is a special case because its use is currently covered, for downstream users (DU), by the holders of the authorisation dossier (list of holders in point 4 of the questionnaire). It is an "upstream" dossier whose registrants have joined together in a consortium: the CETAC sub. Today, this concerns only Chrome VI.

What are the obligations related to the handling of a substance subject to authorisation covered by a Third Party
(upstream in the supply chain)?

When you purchase and handle a substance subject to an "upstream" authorisation dossier, you face several obligations, including:

  • Ensuring that your use of the substance is covered by your supplier

  • Compliance with the conditions of an authorisation granted to an upstream actor in its supply chain (conditions described in the Exposure Scenario attached to the eSDS)

  • Your notification of use to the ECHA (European Chemical Agency) within 3 months after the first delivery

What are the consequences of non-compliance?

Penal and administrative sanctions (non-exhaustive list)

 

Following a formal notice: 

 

  • Order the payment of a fine of up to €15,000 and a daily penalty of €1,500

  • Order the cessation of the activities concerned

  • Order a ban on the import, manufacture or placing on the market or a withdrawal from the market of substances, mixtures, articles, products or equipment.

If you: Manufacture, import or use, without the corresponding authorisation decision, a substance, as such or contained in a preparation or article, in disregard of Title VII of the REACH Regulation

 

  • 75000€ fine, up to 2 years in prison

If you: Fail to comply with prohibitions or risk reduction measures taken for the protection of health or the environment

  • 75000€ fine, up to 2 years in prison

Source: code de l’environnement, articles L. 521–12, L. 521–18 et L. 521–21

To this end, CEHTRA offers a simplified questionnaire to help you quickly assess whether you have little or no risk of non-compliance, or whether you need to implement corrective actions to be defined in more detail.