Guides / Specs

The EU Chromium(VI) Restriction and Your Plated Parts: What to Change Now

October 1, 2026

If your parts carry a chromate conversion coat, a yellow or black hexavalent passivate on zinc, a chromic acid anodize or hard chrome, the EU restriction on chromium(VI) is the regulatory change to plan around over the next two years. The short answer for buyers: the final rule is not adopted yet, but the direction is clear, and drawings written today will still be in use when it applies. Move specs to Cr(VI)-free finishes where the part allows it, and get the chemistry in writing from every finishing supplier.

This guide covers where the process stands at the end of September 2026, which finishes it touches and a practical checklist for drawings and RFQs. It is general information for buyers, not legal advice. Your EU customer’s compliance team has the final word on what their parts need.

Where the EU chromium(VI) restriction stands

The European Chemicals Agency (ECHA) announced its restriction proposal on 29 April 2025. It covers chromium(VI) substances used in surface treatment, including chromium trioxide, chromic acid, dichromates and chromates, at 0.01% by weight or more in a mixture. The proposal would replace the current REACH authorisation system for these substances with a restriction: uses in categories such as electroplating on metal, electroplating on plastic and other surface treatment could continue only under conditions, including worker exposure limits that range from 0.1 to 5 µg Cr(VI)/m³ depending on the use category, plus caps on releases to air and water. An 18-month transition period was proposed.

Since then the file has moved through ECHA’s two scientific committees:

• June 2025 to December 2025: a six-month public consultation on the proposal.
• RAC final opinion: ECHA’s Risk Assessment Committee has adopted and published its final opinion.
• 11 June 2026: the Socio-Economic Analysis Committee (SEAC) adopted its draft opinion.
• 17 June to 17 August 2026: a 60-day consultation on the SEAC draft ran and has now closed. The ADCR consortium’s notice of the SEAC consultation sets out these dates.
• November 2026 (expected): SEAC adopts its final opinion. The file then goes to the European Commission and Member States, which decide on the final text for Annex XVII of REACH.

On timing, the European Commission’s updated Q&A (revised December 2025) points to entry into force between the end of 2027 and the beginning of 2028, followed by the 18-month transition. It also extends existing authorisation review periods to 1 January 2029 so that current authorisations do not lapse before the restriction applies. A summary of the Commission Q&A lists these points. Industry groups, from aerospace to surface treatment associations, have argued against the strictest limit values in the consultations, so the final numbers may still change. The direction is unlikely to.

Why it matters if you buy parts finished outside the EU

The proposal is written around how Cr(VI) substances are used in a plating line: worker exposure and emissions. A shop outside the EU does not operate under those limits. That does not make hexavalent finishes a safe long-term choice for parts sold into Europe, for three reasons.

Your customer’s spec will change first. EU OEMs that have to cut Cr(VI) from their own lines tend to remove it from drawings and supplier requirements across the board, including imported parts.

Other rules already apply to the finished part. RoHS limits hexavalent chromium in electrical and electronic equipment, and chromium trioxide and several chromates are on the REACH list of substances of very high concern. A hexavalent conversion coat or passivate can leave Cr(VI) on the surface of the part itself, which is what these rules look at. Hard chrome is different: the deposit is chromium metal, and the Cr(VI) sits in the bath, not on the finished part.

Supplier capacity follows the market. As European demand moves to trivalent and chrome-free processes, fewer shops will keep hexavalent lines running for small export lots. Qualifying a replacement now costs less than doing it under a deadline.

Which finishes are affected and the usual replacements

All performance notes below are typical. Qualify any replacement against your own drawing, test method and service conditions.

Current finish (Cr(VI))	Where it shows up	Usual Cr(VI)-free route	What to check
Yellow or black hexavalent passivate on zinc or zinc-nickel	Fasteners, brackets, housings	Trivalent passivate, with sealer or topcoat where more salt spray is needed	Salt spray class, color, friction coefficient on threads
Chromate conversion coat on aluminum	Paint pretreatment, electrical bonding	Trivalent chromium conversion coat or chrome-free zirconium or titanium based pretreatment	Electrical contact resistance, paint adhesion, customer approval
Chromic acid anodize	Aerospace aluminum, fatigue-sensitive parts	Tartaric-sulfuric or boric-sulfuric anodize, thin sulfuric anodize	Fatigue debit, customer or prime approval
Dichromate seal on anodize	Anodized aluminum needing corrosion resistance	Nickel acetate, hot water or trivalent-based seals	Corrosion test method, color shift
Decorative chrome	Visible trim, consumer products	Trivalent decorative chrome	Color match against existing parts (trivalent can differ slightly in tone)
Hard chrome	Rods, shafts, molds, wear surfaces	Trivalent hard chrome where available, electroless nickel, thermal spray, PVD	Hardness, thickness range, fatigue, grinding allowance

The hardest case is functional hard chrome. The deposit itself is not the concern, but the bath is, and there is no single replacement that matches it on thickness, hardness and cost on every part. The substitute depends on what the chrome is doing. For a comparison of finishes by substrate and job, see which finish fits your part.

Practical checklist for buyers

1. Audit your drawings. Search your part list for callouts that imply Cr(VI): “chromate”, “yellow zinc”, “Type II” under ASTM B633 without a trivalent note, MIL-DTL-5541 Type I, MIL-A-8625 Type I, “dichromate seal” or “hard chrome”. Old drawings often name a hexavalent process by default because it was the standard when the drawing was made.

2. Rewrite the finish note. Name the process and state the chemistry, for example “zinc plate per ASTM B633, trivalent passivate, no hexavalent chromium permitted”. For aluminum, name the Cr(VI)-free class of the spec your customer accepts. The spec cross-reference maps common callouts between standards.

3. Keep the performance requirement, not the old process. If the old finish passed a set number of salt spray hours, write the test method and the requirement, then let the shop propose a trivalent system that meets it. Trivalent passivates alone often need a sealer or topcoat to reach what a yellow chromate gave on zinc.

4. Ask each shop in writing. Which finishes on my part use Cr(VI) at any step, including passivate, seal and post-dip? What is the trivalent or chrome-free alternative you run in production today, not on trial? Can you supply a REACH and RoHS declaration for the finished part?

5. Plan a qualification run. Order first articles on the new finish, run your own tests (salt spray, adhesion, torque-tension on threaded parts, electrical resistance where it matters) and keep the reports with the part file.

6. Budget for the change. A trivalent passivate plus sealer can cost more per part than the hexavalent chromate it replaces, and hard chrome substitutes often cost more again. Qualification adds a lead-time step of its own. Ask for quotes on both finishes side by side so the difference is visible before you approve.

7. Watch the dates. The next marker is the SEAC final opinion expected in November 2026, then the Commission’s draft regulation. Recheck your plan when each one lands.

Hydrogen embrittlement does not go away

Changing the passivate does not change the plating. Hardened steel parts (over about 39 HRC) plated with zinc or zinc-nickel still need a hydrogen embrittlement relief bake after plating, whatever the topcoat chemistry. Keep the bake note on the drawing when you rewrite the finish callout.

See also: Coating rules for parts sold in the EU: all rules on one page.

How we help

We are a matching service, not a plating shop. Send your drawing, base material, current finish callout and target market, and note that you need a Cr(VI)-free finish. We pass the RFQ to up to three finishing shops that run trivalent or chrome-free processes for that finish, and you receive a reply within 24 business hours. Start with the RFQ form.

See also the ELV rules on hexavalent chromium for vehicle parts.

Frequently asked questions

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