New EU regulations that may restrict Gum printing

Writer / Udo Schnitzbauer

This is an important issue to spread, and to find a solution for. Please comment below if you have any more info.

For people in the EU there will be a big impact from this two issues of the above subjects:

The EU-Regulation 98/2013 on the marketing and use of explosives precursors which is in force since September 2014, will target members of the general public and at the grace period will expire at 02.03.2016. After that date members of the general public will need a permit to obtain, use and handle some chemicals e.g. hydrogen peroxide with more then 12% and nitric acid with more then 3%. If you have a business you are not involved, but it can be that you need permits and some documentation. For private persons it will be more complicated, because even if the regulation suggests that should be permits for private people to get higher concentrations, many governments decided that there is no need for permits. As a result of this decision the use and even the possession of this chemicals are illegal and can be fined (e.g. in Austria with 500 Euro).

The second issue will be REACH and this will target all people, but mostly people with a own business and/or people who make workshops specially gum printing.
The reason for that is that the dichromates (sodium and potassium) are classified as SVHC (substance of very high concern) and the use of it will be forbidden or strongly regulated and only approved after authorization from ECHA (European Chemicals Agency).
The sunset date for potassium dichromate is 21/09/2017. After this date “the placing on the market and the use of the substance shall be prohibited unless an authorisation is granted”.

Additionally there is a other issue what will affect mostly the private end user: The “COMMISSION REGULATION (EC) No 552/2009” determined that Carcinogenic, mutagenic, reprotoxic (CMR) substances should not be be placed on the market, or used, as substances, as constituents of other substances, or in mixtures for supply to the general public and should be restricted to professional users see page 20 at

There are more and more chemicals which will be categorised as CMR and regulated through this regulation. This will have the effect, that some kind mixtures e.g. developer can not be sold or shipped to private endusers anymore.

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Recommended reading - Learn more about Gum bichromates
Gum Printing: A Step-by-Step Manual, Highlighting Artists and Their Creative Practice

Gum Printing: A Step-by-Step Manual, Highlighting Artists and Their Creative Practice

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8 thoughts on “New EU regulations that may restrict Gum printing”

  1. Further experiments with making images with ultraviolet light c and uv-b indicate both types of uv can render a gelatin glucose mixture insoluble on exposure to uv without chromates. The uv-c light at 254 nanometers wavelength is very harsh and produces images with very high contrast in 10 minutes exposure to 2- 34 watt uv-c bulbs. Uv-b wich is at a wavelength of around 290-310 nanometers produces much better images rivaling dichromate chemistry images. The main difficulty in this type of photography is finding inexpensive uv transparent plastics for the vaccume frame cover as well as the negative substrate. I am glad to announce that polyethylene is a good vaccume frame cover as it readily transmits uv-b and uv-c readily with low loss. Kynar is a readily available uv-b and c transparent plastic film good for negative substrate. Glass will not worrk on uv-b or c as it has near 100% absorbtion. Fused quartz will work but the cost is very high. Kynar plastic 5 mm thick is the absolute minimum thickness because the plastic is just too flexible. 8 to 10 mm would be much better. The plastic must be coated with a inkjet receptive coating to recieve the inkjet printed negative. Art stores have the coatings available. Coating materials are composed of polyvinal alcohol (pva) mixed with a small amount of colloidal silica and a wetting agent to reduce surface tension. Pva is completely transparent to uv-c and uv-b as well. Homemade sheets of pva might be used to print negatives on in a inkjet printer.

  2. The problem with REACH and the respective EU agency is that these people have become used to their very well payed jobs in a remote area in Finnland where hardly other jobs can be found.
    They will continue to forbidd chemicals until finally water is made illegal as well and not stop one day earlier because this is what they live from.
    Don´t expect common sense or thoughtfull acting from them.
    The solution would be to limit any regulations in time so that already forbidden substances become legal again after 10 years just like trademarks. Then they could re-forbidd those and thus justify their existance. Kind of an illusion though.

  3. Good news I tried the ascorbic acid method and it seems there is no need to acidify the waste water; here is the experimental part with pictures (in German):

    Short translation:

    For 3 g dichromate (dry weight) you use minimum 10 g Ascorbic acid, that will convert all Cr(VI) to Cr(III), which is much less toxic.
    Additionally you can treat all solutions e.g. water where you clean the brush or the mixing bowl and the second wash water with Ascorbic acid, so even traces of Cr(VI) will be detoxified.


  4. @ Bolkey:

    I had a tip (hint) from the book of Christina Anderson, she reuses the fist washing bath over and over and even the liquid looks very nasty, neither the print will not stained from the liquid nor the dichromate is not washed right out.

    My solution: I have taken about 2 L water what I pour back after washing the print(s) in a 5 L plastic canister. The next time I reuse it and if it is after a while really dirty you have a few possibilities to handle it:

    a) Put it in a try and let it evaporate to a small volume, then you can give it to a public hazardous waste collection point, if there are some at your place.

    b) Same as above but the dichromate is reduced to a less toxic form. Look at page 6 at or this PDF
    Even sugar works:
    […]250 g of sodium dichromate were mixed with 625 g water in a beaker; 230 g of concentrated sulphuric acid (Sp. Gr. 1.84) were added carefully and stirred well. The beaker was placed in a reactor under cooling with continuous stirring while 62.5 g of sugar were added slowly in 10 lots over three hours. During the reaction the colour of the liquor changed gradually from orange to green and finally to bluish green indicating the completion of the reduction

    So what you can do: Acidify your waste liquid with sulfuric acid to pH 1, then add sodium thiosulfate (Fixer), iron powder or sugar and let it sit for a while and look for a color change. Make it basic, some precipitate should came out. Let it stand for a while, the supernatant can go to the drain and the sediment can be dried and got to the solid chemical hazardous waste, like above.

    Found another method which is working even at neutral or light alkaline pH:

    Ascorbic acid is Vitamin C. In that case according to the paper you can use only a few ml of diluted sulfuric acid to adjust the pH (Figure 3) and then add Vitamin C and wait a few days…. I think the residue can than got to the heavy metal waste….

    So I thin there is really no need to put bichromate down the drain, even if the amounts are very small…..


  5. Well, I am in two minds about this. On the one hand i think: let’s buy a ton of the stuff while I still can do so. On the other hand, it worries me every time I wash my materials and see the bichromate running down the drain, while it is said to be very toxic to aquatic life. Am I overly concerned about this?

  6. O.K. then we have to supply us and work in Turkey, Marokko, Guatemala …
    As a European I am fed up with their silly regulations. Europe will end up like the late socialist/communist states by extreme regulation not taking in account that people are NOT in general ill minded. Which photographer blew up or killed himself in the last 50 years by using these chimicals?

  7. I think the REACH issue with the sunset dates will be the most important thing to solve….from the other both, the impact will be less, because there will be workarounds…


  8. I have just posted to the yahoo group, carbon printing, the results of my experiments in non dichromate gum printing using ultraviolet light-c to harden and render insoluble the tissue of a print. With some further development this technique will allow 10 minute exposures and a completely non toxic ingredient list of chemicals that could be ingested without harm. The print tissue is composed of gelatin, glucose and a watercolor pigment. This tissue is exposed with uv-c, under a uv-c transparent negative. An exposure of 10 minutes with two uv-c lamps producing 64 watt hours of uv produces an image.

    Best Regards


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