EUR: EU, gun makers clash on carcinogenic chrome

Presented by FTI Consulting

BLUF: The European Chemicals Agency (ECHA) wants to tighten the rules on chromium VI, a carcinogenic family of substances prized for its role in heat shielding and corrosion protection. While substitutes have been found for some industrial uses, arms manufacturers which use it to coat gun and rifle barrels are struggling to find alternatives.

ECHA and the European Commission also want to clamp down on lead bullets used in hunting. Although military supplies would be exempt, the higher price of copper may force manufacturers to operate parallel lead and copper production lines to stay competitive. 

Europe needs TNT for large-caliber ammunition, such as artillery shells. But it allowed TNT production to collapse after the Cold War, leaving only one state-owned factory in Poland still operating. The Arsenal talked to SWEBAL, a Swedish startup planning to open a new TNT plant in 2028.

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Arms manufacturers prize hexavalent chromium, also known as chromium VI or chrome VI, for the role it plays in protecting gun and rifle barrels from heat and wear. It also prevents corrosion in aircraft, among other uses. But chromium VI is carcinogenic, posing a cancer risk to factory workers who can breathe in particles when applying it. EU policymakers are trying to decide what to do about it.

Chromium VI substances are regulated under REACH, which governs the registration, evaluation, authorization and restriction of all chemicals used in EU industries, from bomb-making to lipstick. 

Currently, the cancer-causing group of compounds falls under the ‘authorization’ regime, which means companies must negotiate with the European Commission for specific, time-limited permission to use it. The bureaucratic process for obtaining authorization is stringent, complicated and time-consuming, sometimes lasting up to two years.

In April last year, the European Chemicals Agency (ECHA) proposed replacing all chromium VI authorizations with a single ‘restriction.’ The restriction would provide an exclusive list of permissible uses and set limits for worker exposure and environmental emissions.

The ECHA proposal on restricting chromium VI is now being considered by the Helsinki-based agency’s committees for Risk Assessment (RAC) and Socio-Economic Analysis (SEAC), which are made up of experts appointed by national governments.

They will eventually submit an opinion to the European Commission, which then makes a formal legal proposal. That, in turn, is scrutinized by the REACH committee in Brussels, also made up of national appointees.

An EU official said that many uses of chromium VI in the defense sector had already been substituted. But for gun barrel coatings and some other applications, there remains “a very tough walk ahead in order to have a complete substitution.”

“There are many companies working on substitutes,” an executive at a major European small arms manufacturer told The Arsenal. “There are indeed companies that pretend they have found a solution.”

Whether they bear out remains to be seen.

“Nobody knows yet if this solution, this technical solution, enables them to have barrels that reach a certain threshold in terms of the amount of shots they can shoot with the same barrel before replacing it,” the executive said.

When procuring weapons, ministries of defense set minimum standards for barrel durability and accuracy over time. If European-made weapons start failing those tests due to inadequate barrel coatings, “then we will be replaced by non-European companies—American companies, Turkish companies, Israeli, South African, whatever.”

As Europe rearms, the small arms source told The Arsenal that its defense industry confronts contradictory policy priorities. DGs, or directorates-general, are departments of the European Commission. DG GROW is responsible for industrial policy.

“On one side, you have people from the DG Environment who are telling you, ‘You have to stop this.’ And on the other side, we have DG GROW and our governments who are telling us, ‘You have to increase your production.’” 

Delegates to the REACH committee tend to be picked by national environment ministries, the source added, and don’t communicate with their defense ministries.

The bureaucratic complexity of REACH—especially its authorization regime, which currently governs chromium VI—is partly intentional, said Tony Musu, a chemicals specialist at the European Trade Union Institute (ETUI), which advises the European Trade Union Confederation (ETUC). He said the idea is to push industry to find alternative substances with less stringent requirements. 

But the arms company source said that the speed with which the rules on new chemicals get tightened outpaces the industry’s capacity to replace them.

“Every year you have a new layer of things that are not authorized anymore,” the source told The Arsenal. “Honestly, I don’t know how we’re going to manage this in the coming years.”

“It’s like they don’t get that political time is not industrial time.”

ECHA’s proposed chromium VI restriction will include limits on worker exposure. REACH has never been used for that purpose, Musu said. 

Worker exposure limits for chromium VI already exist under the Carcinogens, Mutagens, or Reprotoxic substances Directive (CMRD). These limits are also under review and likely to be lowered in the coming months, Musu told The Arsenal.

The REACH restriction will only cover deliberate applications of chromium VI, whereas the CMRD covers all circumstances where exposure can occur.

Musu said that if the setting of the limits under the REACH restriction and the CMRD aren’t coordinated, “it will be a mess.”

The current exposure limit under the CMRD is five micrograms of chromium VI particles per cubic meter of air, although any level of exposure is a cancer risk, he said.

To reduce exposure, the law dictates “a hierarchy of measures to be used in the workplace,” Musu said. The first is not to use the substance at all, and the second is to use a “closed system,” such as a sealed tank, that separates workers from the hazard. 

If that’s impossible, then employers must reduce exposure as much as possible using exhaust ventilation. The use of personal protective equipment, such as respirators, is a “last resort,” he added.

Industry sources told The Arsenal that as manufacturers abandon or find alternatives to a restricted chemical, European suppliers may start to exit the market. That could leave defense firms that haven’t found alternatives dependent on foreign suppliers.

Musu said the ECHA committees are expected to submit their opinion on chromium VI by the end of this year. The Commission’s decision will probably follow in 2027.

The Commission is due to propose what it calls a “targeted revision” of REACH this year, with the goal of simplifying procedures. 

“That's the new model in Brussels: They say, ‘Yeah, we're going to make the life of manufacturers easy’—they're going to make the reporting procedure much lighter,” said the small arms executive. “I don’t believe them.” 

Amid all the talk of boosting European defense production and all the money pouring into new technologies, one startup founder told The Arsenal there’s a critical resource being overlooked: trinitrotoluene—good old-fashioned TNT.

“TNT is an essential ingredient” for large-caliber ammunition, such as artillery shells, said Joakim Sjöblom, CEO and co-founder of Swedish startup SWEBAL, in an interview with The Arsenal.

“Western countries are now looking to triple, quadruple—or increase even more than that—their [TNT] production capacity,” he said.

SWEBAL is building a new TNT factory in Nora, roughly 210 kilometers (130 miles) west of Stockholm. 

Its investors include Thomas von Koch, ex-CEO and founder of private equity firm EQT; Pär Svärdson, founder of online pharmacy Apotea and online bookstore Adlibris, and Major General Karl Engelbrektson (ret.)—the former chief of staff of the Swedish Army.

Unlike defense tech, “the financing of manufacturing is not venture-driven,” Sjöblom told The Arsenal. “You're not looking at a series A or series B model, because we don't have any scalability,” he said. “Our machines can only produce so much, meaning that we are much more of a family office or private equity case.”

“Defense tech is a crowded space,” he said. “But we are way too few entrepreneurs doing defense manufacturing. Whenever it comes to large-scale production, we’re heavily reliant on the primes—the BAEs, the Rheinmetalls of the world.”

But even those companies don’t make their own TNT—Nitro-Chem is the only company left in Europe doing that. It wasn’t always so. 

“We had at least seven plants, post the Cold War,” Sjöblom told The Arsenal. “We had TNT production in Sweden until 1998, and we had TNT production in Finland until 2003.”

The defense downsizing that followed the end of the Cold War brought about large-scale recycling of stockpiled ammunition. That unleashed vast quantities of TNT onto the market at rock-bottom prices. 

A pending EU ban on lead hunting rounds could have knock-on effects for military supplies by forcing manufacturers to create separate copper production lines.  

Lead is highly toxic. Lead bullets pollute the environment and poison wildlife. That’s why the European Chemicals Agency (ECHA) and the European Commission want to ban the use of lead bullets in hunting and outdoor sports shooting.

The ban would not apply to the military, the police, or indoor gun clubs. 

National delegates on the REACH committee, which scrutinizes proposed restrictions under the REACH legislation, have long been deadlocked over the ECHA proposal. 

Only one large country needs to change its position for the ban to go through, said Seppo Puustinen, REACH advisor to the European Federation for Hunting and Conservation (FACE), a lobby group representing hunters.

The Commission is “wheeling and dealing and horse-trading” to get the measure through, said Puustinen, speaking to The Arsenal after a hunting trip in Lapland, in northern Finland. 

The original proposal was that all lead hunting rounds would have to be replaced with copper rounds within 18 months. Puustinen said ammunition manufacturers can’t scale up their non-lead production lines that fast.

The Commission has extended that timeframe to five years. If that sways one of the larger holdouts, such as Germany or Italy, the ban would clear the committee. 

Running a separate copper production line for hunters could reduce manufacturers’ headroom to meet a surge in military demand for lead rounds, Puustinen said. The indoor sports shooting market, which is bigger than the hunting market, would be the first to get cannibalized by the military, he added.

NATO standards do allow copper bullets, and some NATO armies already buy them. The Swedish Army, for example, began procuring lead-free bullets in the 1990s, according to the BBC. The large Norwegian-Finnish ammunition manufacturer NAMMO says on its website that Scandinavian demand is what prompted it to begin producing lead-free bullets.

But copper rounds are several times the price of lead rounds, Puustinen said.

Ammunition manufacturers already make a variety of bullets for different purposes. Copper production lines are separate from those making different types of lead bullets, Puustinen told The Arsenal.

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