Please indicate which Use Categories (UC) from the list your comments apply to: 

• • • • UC1: Formulation of mixtures 

• • • • UC2: Electroplating on plastic substrate 

• • • • UC3: Electroplating on metal substrate 

• • • • UC4: Use of primers and other slurry coatings 

• • • • UC5: Other surface treatments (ETP and others) 

• • • • UC6: Uses as functional additive/process aid (closed list of uses) 

Have you already contributed to the previous call(s) for evidence during the preparation of this restriction dossier? If so, in which way is your current contribution different or complementary to the previous one? (maximum 5000 characters) 

Have you submitted an Application for Authorisation which has been or will be evaluated by the Committees? If yes, in which way is your current contribution different or complementary to your Application for Authorisation? (maximum 5000 characters)

Are you a downstream user of Chromium (VI) substances covered under an upstream Application for Authorisation by your supplier(s) and having submitted an Article 66 notification on your authorised uses? If so, in which way is your current contribution different or complementary to your notification? (maximum 5000 characters)

Please provide comments on substance identity, physical and chemical properties. (maximum 5000 characters)

Please provide comments on substance manufacturing and uses. (maximum 5000 characters)

Please provide comments on the hazard assessment. (maximum 5000 characters)

Please provide comments on the emissions and exposure assessment. (maximum 5000 characters)

Please provide comments on the risk assessment. (maximum 5000 characters)

Please provide comments on the expected effectiveness in risk reduction of the different restriction options. (maximum 5000 characters)

Please provide comments on the impact assessment (human health impacts, economic impacts, other impacts). (maximum 5000 characters)

Please provide comments on practicality, including enforceability. (maximum 5000 characters)

Please provide comments on monitorability. (maximum 5000 characters)

Please provide comments on the uncertainty analysis. (maximum 5000 characters)

If you have sites, or even production lines or rooms, in which more than one of the six Use Categories (UC) described in the Annex XV dossier are performed, please specify which ones. Please describe how these uses are segregated in the workplace if applicable. (maximum 5000 characters)

Decorative uses: The restriction dossier presents an assessment of the impact of banning “functional uses of Chromium (VI) substances with decorative character” (UC 2, UC 3) in Appendix E.1.4. Please indicate whether you agree or disagree with the assessment and back your arguments with factual (technical, economic) data/figures.

Additional questions for UC 2: Electroplating on plastic substrate is considered as a representative use of Chromium (VI) substances in which the Chromium (VI) is aiming to provide a ‘decorative character’ to articles among their technical functionalities. This decorative character could be e.g. achieving a specific colour or shine.

• • If you are an EEA-producer: Do you produce articles that have, among the technical functionalities of Chromium (VI), to provide decorative character to your article? If yes:
    • • Please provide a list of articles where the use of Chromium (VI) provides a decorative character to the article among its technical functions.
      • What is the market share of those articles compared to your total Chromium (VI)-related revenues?
      • What is the total amount of Chromium (VI) used to produce those articles (in tonnes per year)?
      • If you could not produce those articles in the EEA with Chromium (VI) substances, what would currently be your likely reaction?

• • If you are an EEA-importer: Do you import articles that are, or could be, coated with Chromium (VI) substances that have to meet particular aesthetic requirements required by European or international standards or customer requirements? If yes:
    • • Please provide an indicative description of those articles and the total amount of articles imported (in tonnes per year).
      • What are the sales’ trends of those articles?

(maximum 5000 characters)

For any relevant use not identified in the restriction dossier, please specify the Chromium (VI) substance and tonnage used in 2023, a short use description (including functionalities and products manufactured), the economic sectors involved and any evidence to support that the use is currently taking place in the EEA. In addition, please provide information on the exposure levels of workers and the general population resulting from this use, as well as on possible measures to reduce exposure and the costs you expect from the implementation of these measures. (maximum 5000 characters)

If you produce in the EEA coatings on articles with a residual Chromium (VI) content (e.g. for self-healing purposes), or import articles into the EEA with a residual Chromium (VI) content, what is the concentration of Chromium (VI) in the coating and what is the concentration of Chromium (VI) in the article? Please specify what kind of articles (e.g. provide a list) you produce/import with a residual Chromium (VI) content. What is the market share of those articles compared to your total Chromium (VI)-related revenues? What is the total amount of these articles produced or imported (in tonnes of articles per year, or, alternatively, in tonnes of Chromium (VI) content per year)? (maximum 5000 characters)

Please provide information on any additional instructions, procedures, guidelines, good practice examples, etc (not already mentioned in the dossier), that describe the conditions for using Chromium (VI) substances, such as risk reduction measures and operational conditions, and that enable you to meet the exposure and emissions limits. Please provide these as a link to the internet source. (maximum 5000 characters)

Do you consider that the costs of monitoring for workers and releases to the environment provided in the restriction dossier are representative of the current costs for monitoring campaigns in the EEA? If not, please provide further details supporting your response (number of samples, testing methods and cost in euros for each monitoring campaign, specifying if it applies to workplace measurements and/or measurements of the emissions to the environment). (maximum 5000 characters)

What are the current limits of quantification (LOQs) of the methods you use to monitor workplace exposure and environmental emissions? If so required, and if measurements would have to be done with an LOQ that is < 10% of the exposure and emission limits proposed in the different options in the Annex XV dossier, would you be able to reduce the LOQs to match these values (possibly requiring to change the sampling and analytical methods)? (maximum 5000 characters)

Are you aware of any other chromium (VI) substances, not in the scope of the restriction, which could be used as alternatives for the uses described in the restriction dossier? If yes, please indicate which substances appear suitable and for which uses. (maximum 5000 characters)

If you have already substituted Chromium (VI) substances in your processes and products, please provide details on the original use of the Chromium (VI) substances and the alternative you are using instead, on the investment required and actions undertaken to substitute Chromium (VI) substances in your operation, as well as on potential recurrent costs arising from the use of alternatives. (maximum 5000 characters)

If you have (partly) relocated the activities that require use of Chromium (VI) substances out of the EEA, or if you are planning to do so, please explain your motivation (e.g. has this been motivated by the possibility to continue using Chromium (VI) substances, or have you chosen to invest in alternative substances/technologies to Chromium (VI) in these non-EEA sites?) (maximum 5000 characters)

How do you expect that the restriction will affect the use of Chromium (VI) substances in your company (decrease, remain constant, increase)? Please justify your response. (maximum 5000 characters)