ClientEarth comments to SEAC draft opinion for Cr(VI) restriction

ClientEarth argues that the SEAC draft opinion on Cr(VI) restriction is based on systemic information gaps and biased evidence, failing to prove that a restriction would better promote substitution or reduce risks than the current authorisation process. The organization urges SEAC to stay its opinion until a robust dossier is provided, suggesting that a ban with transition periods would be a more proportionate and effective risk management measure.

• ClientEarth asserts that the SEAC draft opinion contains systemic information gaps that prevent a meaningful assessment of whether the proposed restriction is the most appropriate Union-wide risk management measure. These gaps include insufficient data on the availability and feasibility of alternatives, substitution potential across sectors, and the costs and benefits of the restriction.
• The evidence base used for the assessment is criticized for being methodologically biased, as it relies heavily on calls for evidence from current Cr(VI) users, with only about one-third of identified users responding. ClientEarth argues this prioritizes industry perceptions over objective evidence and suggests consulting companies that have already successfully substituted Cr(VI).
• ClientEarth claims the SEAC assessment focuses on the costs of compliance for industry rather than the goal of substitution. It notes a contradiction where SEAC acknowledges that alternative technologies exist but admits it cannot conclude on their technical or economic feasibility based on the provided information.

APA

ClientEarth (2026). ClientEarth comments to SEAC draft opinion for Cr(VI) restriction. https://www.clientearth.org/media/uktnzmxl/clientearth-comments-to-seac-draft-opinion-for-cr-vi-v2.pdf

Chicago

ClientEarth. ClientEarth comments to SEAC draft opinion for Cr(VI) restriction. 2026. https://www.clientearth.org/media/uktnzmxl/clientearth-comments-to-seac-draft-opinion-for-cr-vi-v2.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=ClientEarth comments to SEAC draft opinion for Cr(VI) restriction |date=August 2026 |url=https://www.clientearth.org/media/uktnzmxl/clientearth-comments-to-seac-draft-opinion-for-cr-vi-v2.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2026clientearth, author = {{ClientEarth}}, title = {{ClientEarth comments to SEAC draft opinion for Cr(VI) restriction}}, publisher = {ClientEarth}, year = {2026}, month = aug, url = {https://www.clientearth.org/media/uktnzmxl/clientearth-comments-to-seac-draft-opinion-for-cr-vi-v2.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }