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European Space Sector | Updated Guidelines for Continued Chromium Trioxide Following Commission Decision Annulment

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The European Space Sector has received updated guidelines regarding the continued use of chromium trioxide (CAS 1333-82-0) following the annulment of Commission decision C(2020) 8797. 

Users of chromium trioxide in the European Space Sector have been informed that they are permitted to maintain their usage within the boundaries of the European Commission decision C(2020) 8797, commonly known as the "CTACSub Authorisation Decision," until further notice, but no later than April 20, 2024.

This decision comes after the CJEU's verdict on April 20, 2023, in Case C-144/21 European Parliament v European Commission. Although the CJEU has annulled most aspects of the CTACSub Authorisation Decision, it has maintained its effects for a duration not exceeding one year from the date of judgment delivery, i.e., until April 20, 2024. The annulment was grounded in uncertainties regarding exposure assessment and the absence of suitable alternatives due to the broad scope of the CTACSub application for authorization.

The European Commission is presently engaged in analyzing the CJEU judgment and formulating the next steps concerning the revision of the CTACSub Authorisation decision, along with potential regulatory amendments.

For the sake of providing users with a clear understanding of the implications of the CJEU judgment and recommended actions, ASD-Eurospace has released an updated REACH compliance guideline on July 27, 2023 (ref. MPTB-ESA-MO-0126). This guideline supersedes the previous version from November 18, 2021. Noteworthy sections to review are questions and answers #1, 6, 7, 11, and 12.

The guideline's primary objective is to facilitate compliance for the continued use of chromium trioxide in chemical conversion coatings for space hardware, even after the REACH authorization sunset date on September 21, 2017. It specifically concentrates on certain HENKEL formulations, including BONDERITE M-CR 1200 AERO, BONDERITE M-CR 1200S AERO, and BONDERITE M-CR 600 AERO.

Furthermore, the updated guideline extends its recommendations for use beyond April 20, 2024, while also addressing recent developments, such as submissions made by the Aerospace and Defence Chromates Reauthorization Consortium (ADCR) to the European Chemicals Agency (ECHA) earlier this year. mptb-esa-mo-0126-cro3-henkel-issue5-27072023-final.pdf

The guideline has been meticulously curated and is continually updated by the Space Chromates Task Force (STF) under the Materials and Processes Technology Board of the European Space Components Coordination (ESCC MPTB). This cooperative initiative is led by the European Space Agency (ESA), national space agencies, and the space industry, as represented by ASD-Eurospace.

ASD-Eurospace intends to keep the space sector updated on pertinent developments related to this subject in the future.



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