REACH UK
Aerospace and Defence Chromates Reauthorisation
March 2022
For our suppliers of formulations (paint/coatings) who use chromates subject to authorisation under REACH Regulation. REACH Authorisations have been granted to the CTAC, CCST, GCCA and other Consortia providing 7 years review periods from the Sunset Dates. See table below for details of the Authorisation numbers associated with each of the consortia.
It is critical that the Aerospace & Defence (A&D) sector continues to function without supply chain disruption. This means certainty about the continued reliance on the use of chromates subject to authorisation is critical to each stakeholder in the A&D supply chain, and it is essential that every effort be made to ensure that disruptions will not occur within the supply chain in the future. The Aerospace and Defence Chromates Reauthorisation (ADCR) Consortium has been created to seek re-authorisation of certain chromates for some uses that continue to be essential to A&D companies and their supply chains. This includes re-authorisation in the EU and new applications for authorisation under UK REACH.
If you are a supplier located in Great Britain (GB), then your use continues to be covered by these EU REACH authorisations until the existing EU authorisation expires. The expiry date for existing authorisations applies to EU and UK REACH. For UK organisations, information on your use should have been communicated to the UK HSE before 1st March 2021. If you have not yet done this, we recommend you do this as soon as possible. This information should show compliance to the Exposure Scenario / CSR applicable to the existing authorisation. Once the EU authorisation expires, continued use will need to be covered by a UK REACH Authorisation.
Further information on the ADCR can be found on the following website:
https://www.adcr-consortium.eu/
Indestructible Paint is a member of the ADCR and is therefore providing this information to ask for your cooperation.
In order to ensure that longer review periods are received as part of the re-authorisation of critical residual uses, the ADCR is looking for your support.
- Indeed, as monitoring data and information on key functionalities have to be submitted to ECHA and in the UK – The H.S.E. future applications will be expected to include such data for the supply chains that will be covered by the re-authorisation applications.
- We therefore would ask that as a company within our supply chain, which is expected to continue to require use of the chromates under the ADCR Authorisations in the future, that you supply also, under commercial confidentiality, the related exposure and environmental monitoring data and information on key functionalities to the technical services team that is supporting the development of the ADCR dossiers.
All Downstream Users
All information that you provide will be only be used in an anonymised and aggregated way.
Contact details for the technical services team are as follows:
Risk & Policy Analysts (RPA) at: ADCR-info@rpaltd.co.uk
Your participation in this re-authorisation monitoring data collection is strongly recommended. However, providing data does not mean that your uses will definitely be covered by the ADCR, i.e. if you are a design-make supplier and you have not joined the ADCR.
If you use any of the products below you will be affected by UK reach & also encouraged to join ADCR.
If you require further information, please get in touch with our dedicated sales representative, Gary Payne on gary@indestructible.co.uk or 07837 880 087.
Chromate Primers containing Strontium Chromate and Pentazinc Chromate Octahydroxide (Zinc tetraoxy chromate, ZTC)
March 2022
UK REACH Status
To Indestructible Distributors and Clients in the UK
Indestructible Paint has been granted authorisation to continue supply of coatings containing strontium chromate and pentazinc chromate octahydroxide for aerospace and aero derivative applications. In order to continue to receive and use these coatings, you must read this briefing note and sign and complete the attached form.
Strontium Chromate (EC No: 232-142-6; CAS: 7789-06-2)
Authorisation has been granted for the following uses:
REACH/20/7/13 – Application of primers and speciality 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.
Only applications where the requirement for key functionalities can be demonstrated are authorised for continued use of Strontium Chromate containing coatings:
Key Functionalities – corrosion resistance; adhesion of paint/compatibility with binder system; layer thickness; chemical resistance; temperature resistance (thermal shock resistance), compatibility with substrate or processing temperatures.
Indestructible Paint coatings covered by the authorisation are as follows:
IP9064-6362; IP9064-6362-309; IP9064-9226; IP9064-C9553; IP3-6362; IP9168A; IP9310; IP9253-R2; 588-0066-2
A copy of the authorisations is available at this link: https://ec.europa.eu/docsroom/documents/40910/attachments/1/translations/en/renditions/native
The authorisation is valid until 22 January 2026. Up to this date, continued sales of primers containing this chemical within UK and the EU will be restricted for flight use only, as per the decision noted above. Sales after this date will be subject to a successful re-authorisation.
Pentazinc Chromate Octahydroxide (EC No. 256-418-0; CAS 49663-84-5)
Authorisation has been granted for the following uses:
REACH/19/26/1 – Use in stoved epoxy primer for corrosion protection of aircraft engine components in aerospace and aeroderivative applications.
Only applications where the requirement for Stoved Epoxy Primer for the Corrosion Protection of Aircraft Engine Components and Aeroderivative applications are authorised to continue use of Pentazinc Chromate Octahydroxide containing coatings:
Indestructible Paint coatings covered by the authorisation are as follows:
700-155-003
A copy of the authorisations is available at this link.
https://ec.europa.eu/docsroom/documents/37085/attachments/1/translations/en/renditions/native
The authorisation is valid until 22 January 2031. Up to this date, sales of primers containing this chemical within UK and the EU will be restricted aerospace and aeroderivative parts as described above. Sales after this date must be subject to a successful re-authorisation.
UK Authorisation from 1 January 2021
UK REACH:
Indestructible Paint will service legislative and client obligations for manufacture and supply of coatings with the UK and all other non-EU jurisdictions.
Your obligations as downstream user
Downstream users of the coatings listed above have specific obligations under the REACH Regulation and according to the conditions attached to the authorisation. You must familiarise yourself with these requirements.
Article 66 of the REACH regulations ((EC) No.1907/2006) requires downstream users to inform ECHA of their use. Further information about the downstream user notifications process can be found at: http://echa.europa.eu/support/dossier-submission-tools/reach-it/downstream-user-authorised-use.
For enquiries or further help please refer to https://echa.europa.eu/support/helpdesks
UK users should have informed the UK HSE by 01 March 2021 of their use and compliance to the authorisation conditions by submitting information through the HSE web pages: https://www.hse.gov.uk/reach/authorisation127h.htm
If you have not yet done this, we recommend you do this as soon as possible.
Our obligations as Authorisation Holders
An Only Representative requires us to maintain records of the usage of chromates through our supply chain. We need to track direct sales from Indestructible Paint to UK customers to ensure we comply with REACH. We also want to track indirect sales through distributors or other routes to UK customers to support compliance and continuation of chromate authorisations required for continuity of supply.
Appended to this letter is a form that we ask all customers that are UK or EU downstream users of substances covered by above authorisation(s) to complete, sign and return confirming that the product covered by the enquiry/order is used only for aerospace or aeroderivative use in accordance with the conditions of the authorisation.
Please return this document completed and signed to ensure prompt completion of the quotation and or shipping process.
We anticipate that the relevant REACH authority within UK and/or EU member state will be in contact with you to ensure that the product is applied in accordance with the authorisation, and for uses allowed in this same authorisation.
All customers must complete all details and return the form by e-mail to your sales contact,
This document MUST be completed and signed to ensure prompt completion of the quotation and or shipping process.
This document will be retained and filed against your order details and may be shared with local authorities.
In case of Queries please contact Gary Payne by email: gary@indestructible.co.uk or Tel: +44 7837 880 087
You may also contact ECHA for additional information or to give comments,
including any comments regarding the downstream user notification system.
For enquiries or further help please refer to https://echa.europa.eu/support/helpdesks
The Ipcote Range of Sacrificial Basecoats and Sealcoats Containing Chromium Trioxide:
March 2022
UK REACH Status
To Indestructible Distributors and Clients in the UK
The Indestructible “Ipcote” range of sacrificial basecoats and sealcoats contain chromium trioxide. In order to continue to receive and use these systems, you must read this briefing note and sign and complete the attached form.
Chromium Trioxide (EC No: 215-607-8; CAS: 1333-82-0)
For supply into the European Union, Indestructible Paint will supply through Boeing Distribution Inc and Wesco to cover authorisation for Aerospace and Industrial uses:
Indestructible Paint “Ipcote” range products covered by this communication are as follows:
IP9183-R1; IP9184 Green; IP9184-KH-R1; IP9184-Blue; IP9184-Black; IP9356; IP9442; IP9444; PL177; PL270; IP1041; DOW19
The authorisation is valid until 21st September 2024 . Up to this date, continued sales of the Ipcote range of products containing this chemical within UK will be restricted by the decision conditions noted above. Sales after this date will be subject to a successful re-authorisation.
UK Authorisation from 1 January 2021
Indestructible Paint is covered by downstream authorisation for our continued manufacture and supply of coatings in the Ipcote Range. Indestructible will continue direct supply of the Ipcote Range to UK and Non-EU clients.
Your obligations as downstream user
Downstream users of the coatings listed above have specific obligations under the REACH Regulation and according to the conditions attached to the authorisation. You must familiarise yourself with these requirements.
Article 66 of the REACH regulations ((EC) No.1907/2006) requires downstream users to inform ECHA of their use. Further information about the downstream user notifications process can be found at: http://echa.europa.eu/support/dossier-submission-tools/reach-it/downstream-user-authorised-use.
For enquiries or further help please refer to https://echa.europa.eu/support/helpdesks
UK users should have informed the UK HSE by 01 March 2021 of their use and compliance to the authorisation conditions by submitting information through the HSE web pages: https://www.hse.gov.uk/reach/authorisation127h.htm
If you have not yet done this, we recommend you do this as soon as possible.
Our obligations as Authorisation Holders
Conditions of the authorisations and commercial agreements require us to maintain records of the usage of chromates through our supply chain. We need to track direct sales from Indestructible Paint to UK customers to ensure we comply with REACH. We also require tracking of indirect sales through distributors or other routes to UK customers to support compliance and continuation of chromate authorisations required for continuity of supply.
Appended to this letter is a form that we ask all customers that are UK downstream users of substances covered by above authorisation(s) to complete, sign and return confirming that the product covered by the enquiry/order is used only for aerospace or aeroderivative use in accordance with the conditions of the authorisation.
Please return this document completed and signed to ensure prompt completion of the quotation and or shipping process.
We anticipate that the relevant REACH competent authority within the UK and/or EU member state will be in contact with you to ensure that the product is applied in accordance with the authorisation, and for uses allowed in this same authorisation.