Public consultation on the ECHA Restriction proposal on the manufacture and use of the 5 cobalt salts

The European Chemicals Agency (ECHA) is proposing a REACH Restriction on the manufacture and use of the 5 cobalt salts (cobalt diacetate, cobalt dinitrate, cobalt carbonate, cobalt sulphate and cobalt carbonate). The six-month public consultation (PC) on the ECHA Restriction proposal for the 5 Co salts started on 19th Dec 2018 and will last for 6 months (closes 19th June 2019). The Cobalt REACH Consortium (CoRC) has formed a Restriction Project Team (RPT) to closely monitor this regulatory process.

The Cobalt Secretariat (CoRC-CI) have consulted with many industry stakeholders and conducted activities such as information webinars, an industry workshop, and technical surveys. Feedback and responses from these activities have shown that many companies, sector groups and associations are aligned with CoRC-CI views. The survey responses and feedback from companies, industry associations and sector groups have contributed to the CoRC-CI joint response comments for the restriction consultation.

The Cobalt Secretariat and Consultants (EBRC/eftec) have conducted detailed reviews of the ECHA restriction proposal (which is called an Annex XV dossier) and have noted key issues with the restriction proposal for a REV (reference exposure value) and many key messages which are being relayed through the responses to the ECHA’s specific information requests for this PC. In summary the CoRC-CI response into the PC involves: challenging the technical basis of the REV (Reference Exposure value) approach and the non-feasibility of complying with the very low number being proposed; and also emphasising the issues with the non-proportionality, and lack of regulatory efficiency with this proposal. The agreed strategy is to advocate for an alternative risk management option (RMO) based on a Binding EU wide OEL (B-OEL) for Co and Co-compounds, in addition to challenging the proposed REV value (RO1) as well as the other restriction option (RO2).

The Cobalt Secretariat, Consultants and Eurometaux held a full-day workshop with industry stakeholders in Brussels (30th Jan 2019) where the CoRC-CI strategy was relayed. During the workshop, the sector representatives were interviewed on the possible impacts of the restriction proposal on their sectors. The workshop participants and sector representatives supported the CoRC-CI strategy of advocating for the implementation of the BOEL as a more appropriate risk management measure (RMM) to control occupational exposures to the 5 Co salts.

Industry stakeholders for the 5 cobalt salts, and other cobalt compounds, are welcome to contact the Secretariat ( ) to discuss any questions regarding this activity.


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