Authorisation Reviews: The Overlooked UK REACH Risk

While PFAS dominates the headlines, many businesses still overlook a quieter, longer-running obligation: existing UK REACH authorisation requirements. The latest Government update to UK authorisation decisions was published on 17 June 2026, including a further decision relating to chromium trioxide use — a timely reminder that authorisation doesn’t stop being relevant once a substance is already on the list.

Why authorisation gets overlooked

SVHC identification and Candidate List additions tend to get the attention, because they’re the first step and the most visible. Authorisation is quieter by comparison — it applies to a smaller number of substances, moves on longer timelines, and often feels like “someone else’s problem” once a business assumes its supplier has already dealt with it. In practice, authorisation obligations can sit directly with downstream users too, depending on how a substance is used, not just how it’s supplied.

Chromium trioxide: a case in point

Chromium trioxide is one of the longest-standing authorised substances under the REACH framework, widely used in hard chrome plating and surface treatment processes across manufacturing, automotive, aerospace and defence supply chains. The 17 June update included a further authorisation decision relating to chromium trioxide use — a reminder that decisions in this area continue to evolve, and that businesses relying on plated or surface-treated components can’t assume the position they checked two or three years ago still holds today.

If chromium trioxide (or another authorised substance) appears anywhere in your supply chain — even several tiers removed, in a plated fastener or treated component rather than a substance you handle directly — it’s worth confirming that the specific use is actually covered by a current authorisation, rather than assuming it is.

What to check

• Whether any substances you manufacture, use or purchase components containing are on the UK REACH Authorisation List, not just the Candidate List.
• Whether your specific use — or your supplier’s — is covered by an existing authorisation, and what conditions or sunset dates apply to it.
• Whether recent authorisation decisions, like the 17 June update, affect a substance already in your supply chain.
• Whether you’re relying on a supplier’s authorisation status without having confirmed it recently.

How we can help

We help clients work out where authorisation obligations actually sit in their supply chain — including cases several tiers removed from the substance itself — and keep that position current as new decisions are published. If you’re not confident your authorisation exposure has been properly mapped, that’s a good place to start.

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