COD Test Kit Manufacturers found German Consortium 

Three German manufacturers of COD (chemical oxygen demand) test kits (MACHEREY NAGEL
GmbH & Co. KG, Merck KGaA and Tintometer GmbH) in mid 2013 founded a consortium (COD2
Consortium), to jointly elaborate the dossier parts for application for REACH authorisation for the use
of potassium dichromate for manufacturing of these test kits.

The works are progressing well and are expected to be concluded by the end of 2014. Thereafter the
three companies may file their applications for authorisation with ECHA (European Chemicals Agency
in Helsinki). The European Commission is responsible for granting the authorisations. The decision
making procedure normally is scheduled to take about 1.5 to 2 years.

The determination of COD for the analysis of waste water is obligatory under the EU Urban Waste Water Directive 91/271. This can be conducted either via standardised methods (e.g. decomposition and titration) or by the user friendly COD cell tests according to EN ISO 15705.

Potassium dichromate is a substance listed in Annex XIV of the REACH Regulation. The use of
substances listed in this Annex requires REACH authorization. However, authorisation is only
required for the manufacturing of the COD cell tests, not for their subsequent use by the water
treatment companies and communes (Article 56(3) REACH in conjunction with Article 3(23) REACH:
exemption for laboratory uses, which includes routine analysis).

Manufacturers of COD cell tests who will not have applied for authorisation by March 21, 2016, may
no longer produce those test kits in the European Union as of September 21, 2017 (“sunset date”).
The three members of the COD2 Consortium are confident that their applications for authorisation will
be successful. Operators of waste water treatment plants should therefore not worry. The members
of the Consortium expect continuous availability of COD cell tests.