Industry Insights · Regulation and environment · Sep 23, 2026

Hexavalent Chromium Regulations at a Glance — Specially Controlled Substances and Exposure Limits under the Occupational Safety and Health Act, EU REACH Authorization and Restriction, ELV and RoHS 0.1 % — What Anodizing and Chemical Conversion Coating Companies Should Prepare

Hexavalent chromium is a specially controlled substance under Korea's Occupational Safety and Health Act, with exposure limits of 0.01 mg/m³ (insoluble) and 0.05 mg/m³ (water-soluble). The EU is moving from REACH authorization (chromium trioxide sunset date 2017-09-21) to restriction, and ELV and RoHS set a limit of 0.1 %. This article summarizes what companies should prepare.

Hexavalent chromium is encountered in chemical conversion coatings applied before or after anodizing, in the phosphoric-chromic acid solution used for sealing quality tests and in chromic acid anodizing. Korean occupational safety and chemical laws and the EU's REACH, ELV and RoHS regulate it in different ways, so this article brings together what has been confirmed in published legislation.

Korea: Occupational Safety and Health Act

Hazardous substances subject to control and specially controlled substances: Annex 12 of the Rules on Occupational Safety and Health Standards (amended 2022-10-18) lists "chromium [7440-47-3] and its compounds" under metals item 24) and notes that "only hexavalent chromium compounds are specially controlled substances." The same annex also covers mixtures containing 0.1 % or more by weight of a specially controlled substance. When specially controlled substances are handled, the employer must inform workers that the substance is a specially controlled substance and which category, such as carcinogenicity, it falls under (Article 440).
Exposure limits: Annex 1 of the Exposure Standards for Chemical Substances and Physical Factors (Ministry of Employment and Labor Notice No. 2020-48, effective 2020-01-16) sets TWA 0.01 mg/m³ for chromium (VI) compounds (insoluble inorganic compounds) and TWA 0.05 mg/m³ for chromium (VI) compounds (water-soluble), both classified as carcinogen category 1A. In the same table, sulfuric acid is TWA 0.2 and STEL 0.6 mg/m³ (carcinogen 1A for strong acid mist only), and sodium hydroxide has a ceiling (C) limit of 2 mg/m³.
Exposure limits serve as the criteria for work environment monitoring (Article 125 of the Act), and whether workers handling hexavalent chromium require special health examinations should also be checked.

Korea: Chemicals Control Act

The Designation of Toxic Substances notice designates chromic anhydride (1333-82-0), chromic acid (7738-94-5) and its salts, and mixtures containing 0.1 % or more of these as toxic substances. Most hexavalent chromium conversion coating chemicals are therefore subject to hazardous chemical business licensing and handling standards.

EU REACH: From Authorization to Restriction

Chromium trioxide (EC 215-607-8) was included in REACH Annex XIV (substances subject to authorization) as Entry 16 by Commission Regulation (EU) No 348/2013 (2013-04-17), with a latest application date of 2016-03-21 and a sunset date of 2017-09-21. After the sunset date, it may not be used in the EU without authorization.
On 2023-10-11, ECHA announced that, at the Commission's request, it would prepare a restriction proposal for hexavalent chromium substances including Entries 16 and 17. The background is that the large number of authorization applications exceeded the capacity of its committees (RAC and SEAC). If the restriction is adopted, these substances will be removed from the authorization list.
On 2025-04-29, ECHA submitted the restriction proposal. Uses in formulation of mixtures, electroplating on plastic and metal substrates, primers and slurries, other surface treatments and functional additives would be permitted only where worker exposure and environmental emission limits are met, and barium chromate is also within scope. In June 2025, RAC and SEAC found the proposal to meet the Annex XV requirements and began drafting their opinions, and a six-month consultation started on 2025-06-18. The final decision rests with the Commission and the Member States.

EU ELV and RoHS

ELV Directive 2000/53/EC, Article 4(2)(a): Materials and components of vehicles put on the market after 2003-07-01 must not contain lead, mercury, cadmium or hexavalent chromium, except as listed in Annex II. Annex II allows up to 0.1 wt% hexavalent chromium in homogeneous materials.
RoHS Directive 2011/65/EU, Annex II: Restricts hexavalent chromium to a maximum of 0.1 % in homogeneous materials of electrical and electronic equipment.

What Anodizing and Chemical Conversion Coating Companies Should Prepare

An inventory of hexavalent chromium chemicals handled (including conversion coating and sealing test solutions), and confirmation of specially controlled substance notification, work environment monitoring and special health examinations
Trivalent chromium and chromium-free processes, with validation data, to meet customer requirements for hexavalent chromium-free coatings (MIL-DTL-5541 Type II, ELV and RoHS declarations of conformity)
For parts exported to the EU, tracking of REACH restriction decisions and use-specific exposure and emission limit requirements
Review of alternative test methods for sealing assessment (ISO 3210 phosphoric-chromic acid method) or use of external test laboratories

EF Technology gives priority to hexavalent chromium-free specifications and continuously monitors and responds to amendments of related laws.

References

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