This is a joint submission by DUCC representing 11 European trade associations in “downstream” industries, Vecco e.V, an association of 120 downstream users and vecco:net, network of 38 companies, research institutions offering a platform for the substitution of Cr(VI)-based processes in hard chrome plating and other functional coatings. (Vecco:net is managed and represented by eiffo eG, and active in Austria, Germany and the Netherlands in collaboration with Vecco eV as well as Austrian and Dutch industry associations.) Topic 3 of the transition pathway for chemicals considers a variety of actions in relation to moving towards targets of safety and sustainability, including: i) for EU/MS to “Maintain an EU-wide SSbD support network to promote cooperation and the sharing of information across sectors and the value chain and provide technical expertise on alternatives;” ii) Industry to be involved in the "testing phase of the SSbD framework".

With respect to chemical products, an important element is that ‘regrettable substitution’ must be avoided; but as a concept this should be interpreted more broadly than just replacing one hazardous substance with another that subsequently turns out to be just as hazardous. For example, considering also the impact that substituting a substance could have on climate or resource use (e.g. as presented in the SSbD framework). DUCC has thus actively engaged in discussions, bringing different stakeholders together though workshops, to build and test a future system for "assessing alternative substances in chemical products".https://www.ducc.eu/ducc-workshop-on-assessment-of-alternative-substances-in-mixtures.

Engagement with different stakeholders led to a collaboration between DUCC, Vecco e.V. and eiffo eG. To learn from the experience of the latter two organisation in launching the project “vecco:net”. The aforementioned project started in 2021 with 35 companies, research institutions and funding from the Federal Ministry for Economic Affairs and Energy in Germany. The company network offers a platform for the companies concerned to develop strategies and solutions for the substitution of Cr(VI)-based processes in hard chrome plating and other functional coatings and to bring them to application maturity. This submission presents the cumulative learning retained from the joint DUCC and Vecco work in relation to different topics of the transition pathway.