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.