6. Why it becomes an issue

Germany: the German TRGS 561

Since 4 May 2026, the German TRGS 561 has applied in a new version. Section 3.3.4 describes the subject matter, and section 5.9.3 names alkali/alkaline earth metal oxides from insulation materials or assembly pastes as an influencing factor. Protective measures under sections 4.1 and 4.2, including personal protective equipment, low-dust working and the substitution check, already apply where chromium(VI) exposure cannot be ruled out. For employers in Germany, the question is thus part of the risk assessment and not merely a consequence of a positive finding (section 19). [19]

EU: routes of exposure, restriction and concept of use

The European Directive 2004/37/EC requires the assessment of all possible exposures, including absorption through the skin (section 24). In April 2025, the European Chemicals Agency ECHA proposed a restriction on chromium(VI) substances under which only certain uses would remain permitted under strict conditions. [18, 59]

The broad concept of use in the European REACH Regulation is decisive, covering, among other things, storage, keeping and treatment. If a component contaminated with chromates is removed for maintenance, stored and reinstalled, or if contaminated insulation is stored or reused, this may constitute a use. If it does not fall under the uses permitted in future, it would be prohibited. For today’s insulation systems on chromium-alloyed hot components, this may amount to a de facto ban. The final legal text is decisive (section 25). [59, 60]

Australia as a forerunner

From 1 December 2026, the Australian authority Safe Work Australia will no longer set a workplace exposure limit for chromium(VI) compounds. It is replaced by the obligation to eliminate exposure or to minimise it so far as is reasonably practicable (section 25). [58]

Vehicles and combustion residues

For vehicles, European consumer sales law and Vehicle Regulation 2018/858 open up separate lines of enquiry where a vehicle is demonstrably contaminated with Cr(VI) (section 20). For combustion residues, occupational safety and health during overhaul and cleaning applies independently of the environmental assessment of the ash (sections 21 and 22). [46, 47]