SVHC – DOWNSTREAM USER NOTIFICATIONS OF AUTHORISED USE
700-155-003 Rockhard Chromate Primer, containing SVHC Pentazinc Chromate Octahydroxide (ZTC), EC No 256-418-0
The European Commission has recently published its decision to grant an authorisation for the following uses of pentazinc chromate octahydroxide (EC No 256-418-0)
Formulation of mixtures.
Use in stoved epoxy primer (700-155-003 Rockhard Chromate Primer) for corrosion protection of aircraft engine components in aerospace and aeroderivative applications.
According to Article 66 of the REACH Regulation ((EC) No. 1907/2006) any company using 700- 155-003 Rockhard Chromate Primer needs to notify ECHA about their use, unless they are also holders of authorisation for the use. Users of 700-155-003 need to inform ECHA of their use within three months of the first supply of the substance after the authorisation decision has been published in the Official Journal of the European Union (17/07/2019). Else, the use is not in compliance with the REACH Regulation.
You can find further information about the downstream user notifications process at:
To make this notification as easy as possible and facilitate the notifiers also to inform you about their use. Please be aware of the following:
Please include the authorisation numbers in section 2 of the safety data sheet, as per the requirement of the authorisation decision. (also reported in Section 15)
Please meet the obligation to notify uses to ECHA within three (3) months of the authorization decision published date of 17/July/2019.
Please advise your direct customers to inform their customers in the same manner if the authorisation covers also their use.
For Indestructible Paint customers (and their customers) please use the following web page: http://echa.europa.eu/support/dossier-submission-tools/reach-it/downstream-user- authorised-use This web page has also instructions on how Downstream Users can submit notifications to ECHA.
The authorisation decision for REACH/19/26/1 requires Downstream Users to provide to ECHA information from regular (at least annual) occupational measurements, including contextual information. The first measurements shall be conducted the latest twelve months from the date of the decision. This information, shall be provided to ECHA, who will then forward it to Indestructible, for the purpose of preparing a potential review report before the expiry of the authorisation review period. Please inform your customers (and their possible customers) that the required data needs to be provided as an attachment in their notifications. The deadline for downstream users to submit this information is twelve months from the date of the decision. As the deadline for the notification may be earlier than the deadline for the additional required data, downstream users can provide this data in an update of their notification, by the deadline set in the decision. Instructions about how you can retrieve the attachments that your downstream users will submit to ECHA can be found at the end of this letter.
Concurrently with authorization holder activities ECHA provide to notifiers information about the public version of the Commission’s decision as well as your e-mail address as per contact that you have assigned to the respective uses in your REACH-IT account: firstname.lastname@example.org. This will enable the users of your substance to easily provide information about their use directly to you. Such information should be helpful should you wish to prepare a review report before the expiry of the authorisation. Should you wish that we would provide another e-mail address, please update the information in your REACH-IT account accordingly.
Should you wish to have additional information or give comments please do not hesitate to contact ECHA. This would be appreciated so that ECHA can make the downstream user notification system to work well. ECHA contact point is Elina Liopa (email@example.com).
REACH Chromium Salts Update
Products containing Chromium Salts
You will be aware of the REACH regulations, and the evaluation of chemicals regarded as possible hazards to health or the environment. This evaluation can lead to chemicals being classed as “Substances of Very High Concern (SVHC’S)” with possible inclusion in annexe XIV of the regulations. At this stage, a sunset date will be placed on the use of the chemical beyond which, without authorisation from the European Chemicals Agency, ratified by the European Commission, the chemicals will not be available for sale or use within the EU.
Chromium salts have been placed into annexe XIV. Some are being supported for authorisation by interested parties. Indestructible Paint have applied for authorisation for zinc tetroxy chromate for continued use in Rockhard 700-155-003 baking chromate primer to MSRR 9226 and it has been granted an almost unprecedented 12 year recommendation for Authorisation by ECHA due to its currently irreplaceable use in certain aeroengine and flying uses. However, there are several that are not, and will, therefore, be unavailable now we have reached the sunset date of January 2019.
Included in these are chromium salts used by Indestructible in the manufacture of IP9165-R1; Skydrol Resistant Primer, and IP9064-4853; Pre-Treatment Etch Primer Base and 588-0066/3.
PLEASE BE ADVISED THAT AS THE SUNSET DATE HAS PASSED THESE PRODUCTS ARE NO LONGER AVAILABLE.
Within the Indestructible range, there are alternative products, typically chrome salt-free, that can be considered as replacements. Samples of these can be provided for trials.
It should be remembered that the Rolls-Royce specification MSRR9032, to which IP9165-R1 was approved, was withdrawn several years ago with a recommendation from R-R for the use of MSRR9226 (Indestructible product code 700-155-003).
For more information, or to request samples of alternative materials, please get in touch with your usual sales contact or our sales office.
REACH Authorisation Update
Hexavalent Chrome containing products
An update about the Indestructible Paint Aerospace and Industrial products affected by REACH
Indestructible Paint has worked to obtain Authorisation for continued use for three Hexavalent Chrome containing compounds:
Chromium Trioxide – CAS: 1333-82-0
Strontium Chromate – CAS: 7789-06-2
Pentazinc Chromate Octahydroxide – CAS: 49663-84-5
Chromium Trioxide CAS: 1333-82-0, Authorisation obtained through the CTAC consortium to cover products:
IP9183-R1 Ipcote H/T Sacrificial coating
IP9184 KHAKI Khaki Ipseal H/T Inorganic Sealcoat
IP9184 GREEN Green Ipseal H/T Inorganic Sealcoat
IP9184 BLUE Blue Ipseal H/T Inorganic Sealcoat
IP9184 BLACK Black Ipseal H/T Inorganic Sealcoat
IP9356 Ipthin Thin Film Sacrificial Aluminium MSRR9356
IP9442 Smoothcote. CPW88
IP9444 Smoothseal Clear MSRR3010
IP9447-R1 Smooth Green Sealcoat
IP1041 Ipal Diffusion Coating
Products will be available after Sunset Date (21.09.2017)
Strontium Chromate CAS: 7789-06-2, Authorisation obtained through the CCST consortium to cover products:
IP9064-6362 Strontium chromate Primer Base
IP3-6362 2pk Low VOC Epoxy Chromate Primer
588-0060-2 Strontium Chromate Primer
Products will be available after the Sunset Date (22.01.2019)
Pentazinc Chromate Octahydroxide CAS: 49663-84-5, Authorisation held by Indestructible Paint to cover products:
700-155-003 Rockhard Chromate Primer
Products will be available after the Sunset Date (22.01.2019)
We also wish to inform you about the products affected by REACH that are not covered by the different Authorisations and will be obsoleted or phased-out after the respective “Sunset Dates”. We also want to inform herewith about product alternatives in case a compatible solution is available.
IP9064-4853/4854 Pretreat Etch Primer (refer to Sales for non-chrome alternative)
IP9165-R1 Skydrol resistant Primer (please use 700-155-003)
IP8015 Defstan 80-15/2 Pre-Treat Primer (refer to Sales for non-chrome alternative)
588-0060-3 Zinc Tetroxy Chromate Epoxy Primer (refer to sales)
We trust the above information is helpful for you. Please direct any questions and comments to your Indestructible sales contact or e-mail firstname.lastname@example.org
We appreciate your continued support and we are looking forward to continuing business with you.
Brexit and REACH
As sustaining members of the Institute of Materials Finishing (IMF) we work closely with their technical consultants to keep aware of the ever changing position with regard to the EU REACH regulations and the possible changes caused by Brexit.
If you have any concerns regarding REACH and the products we currently supply you, please do not hesitate to contact our Sales Department on +44 (0) 121 702 2485 or email us at email@example.com
Indestructible Paint, as a supplier of aerospace coatings, recognises the role that we have under REACH as a downstream chemical user. We recognise that the REACH regulation places a heavy burden of communication within the supply chain and poses a potential threat to any business operating within the European Union.
We are working with our supply chain and using the data available from ECHA to ensure that we are compliant with the REACH legislation and to avoid any loss of supply continuity.
Indestructible Paint is working to maintain the supply of our coating range with minimal disruption to our customer base. If the supply of one or more of our products is threatened for any reason, all affected customers will be notified immediately. Indestructible Paint is aware that we have coating end users who do not purchase directly from our UK facility. We therefore do not have a full listing of coating end users who will require notification of SVHC or product supply changes. Please contact your Account Co-Ordinator or our Sales Department if you feel there is a communication gap between your organisation and Indestructible Paint.
The REACH/EU requirement to authorise the use Hexavalent Chrome compounds will be the first instance of Chemical restriction that affects Indestructible Paint products. Indestructible Paint is an actor in both the CTAC and CCST Authorisation consortia that are submitting dossiers seeking the continued use of Hexalavent Chrome compounds.
Indestructible Paint is actively developing alternative coating technologies in order to combat current or predicted threats from chemical SVHC classification. Details for these projects are available for discussion via your Account Co-Ordinator or our Sales Department.
In reponse to our obligations under the regulation and enquiries from our customers, Indestructible Paint can confirm the following:
1. 2018 Registration Deadline
Indestructible Paint recognises that the 2018 chemical registration deadline is a potential threat to our business continuity.
Indestructible Paint is not intending to delete any products/product ranges due to the 2018 registration deadline. We have a close liasion with our Raw Material supplier and we are working closely with our supply chain to ensure that there is no immediate threat to any of our coatings.
At Indestructible Paint we identified that we use in the region of 500+ individual raw materials. Our Raw Materials inventory includes 1000+ individual chemical components. Within our capabilities we are monitoring the data issued by ECHA and the UK HSE to ensure that the chemicals we identified within our product range meet the required registration deadlines.
2. SVHC Notification
Indestructible Paint uses chemicals which are on the Candidate List of Substances of Very High Concern (SVHC) for authorisation. These include:
- Chromium Trioxide; CAS Number 1333-82-0 / EC Number 215-607-8 which is used in product codes: DOW 19; IP1041; IP9183-R1; IP9184-GREEN; IP9184-KHAKI-R1; IP9356; IP9442; IP9444 and PL177. ECHA have recommended a 7 year authorisation for flight and 4 years for industrial and ground based.
- Strontium Chromate; CAS Number 7789-06-2 / EC Number 232-142-6 which willaffect the following products: IP9064-6362; IP9064-9226; IP9253-R2; IP9310. Again, an ECHA recommendation for a 7 year authorisation for flight.
- Pentazinc Chromate Octahydroxide; CAS Number 49663-84-5 / EC NUmber 256-481-0 which is used in product codes: 700-155-003; IP9064-4853; LAS-4853; IP9165-R1; IP8015; 588-0060-3; 40021. ECHA have recommended a 12 year authorisation for flight.
- n-Methyl-2-Pyrrolidone; CAS Number 872-50-4 is listed on SVHC candidate list. The future of this solvent is currently under review.
Indestructible Paint Ltd is active in two Consortia, seeking authorisation fo rthe future use of Chromium Compounds after their sunset dates. The Consortium for Chromium Trioxide is C.T.A.C (Chromium Trioxide Authorisation Consortium) and C.C.S.T (Chrome Consortium for Surface Treatments) covers other Indestructible relevant chromium compounds.
Indestructible Paint is aware that proposals are in place to add further chemicals to the SVHC list as the REACH process matures. We will continuously update our communication as and when additional chemicals are proposed as an SVHC substance. Additionally, where a product contains a SVHC this is notified on the Certificate of Conformity, Delivery, Technical Data Sheet and SDS Documents.
If any user of Indestructible Paint coatings is concerned with the implications of the revisions to the SVHC list, please send an email to our Sales Department or your Account Co-Ordinator specifying the Indestructible Paint code for the coating in question. Compliance with REACH is an integral part of our business at Indestructible Paint. We will work closely with our customers to ensure a sustained supply of products and to develop the future generation of coating solutions.
Details of the current SVHC list can be found here.
CTAC – Chromium Trioxide Authorisation Consortium
Please download the files below, which will provide you with more details relating to CTAC
CSST – Chrome Consortium for Surface Treatments
Please download the files below, which will provide you with more details relating to CSST