ZVO: Second class-action lawsuit regarding chromium trioxide successful
The second model lawsuit initiated by the ZVO seeking recognition of chromium trioxide as an intermediate within the meaning of the REACH Regulation was successful before the Administrative Court of Hanover.
In its (not yet final) judgment of April 24, 2026 (Case No. 11 A 2877/21), the Administrative Court of Hanover also found that chromium trioxide, a substance used in electroplating, constitutes an intermediate within the meaning of Article 3(15) of the REACH Regulation and is therefore not subject to an authorization requirement. The court expressly bases its decision on the ruling of the Mannheim Higher Administrative Court of April 9, 2025 (Case No. VGH 10 S 1332/23), which was secured by the ZVO.
Model lawsuits regarding chromium trioxide as an intermediate
In 2018, the ZVO decided to finance five model lawsuits in five federal states to resolve in court the issue in dispute between the European Chemicals Agency (ECHA), the Federal Institute for Occupational Safety and Health (BAUA), and the ZVO, regarding whether chromium trioxide, as used in surface technology, constitutes an intermediate within the meaning of REACH. For years, the ZVO has maintained the position that chromium trioxide should be classified as an intermediate in the REACH process and therefore does not require authorization. Following Baden-Württemberg, the second model lawsuit in Lower Saxony has now also been successful. This suggests a trend in which the ruling of the Mannheim Higher Administrative Court ( as reported bySurface Technology Online) could become a landmark decision recognized by courts in other federal states as well. This development is encouraging and is being actively promoted by the ZVO.
Contact details and information on the companies and institutions presented here can be found in our interactive surface technology industry directory.