In this context, a review period of 4 years was decided for the CTAC application – an upstream application by formulators and importers that provides for all forms of electroplating that satisfy the criteria of Use Group 3. The Commission’s decision was delayed significantly, so this period does not apply from the sunset date (21 September 2017), but rather the date that the authorisation decision will be announced. This will most likely be released on 1 April 2019.
As a matter of principle, it is important to note that the authorisation is not time-limited. This means that all plastics electroplaters in Europe will be allowed to continue using hexavalent chromium compounds until around March 2023, provided they comply with certain conditions. After that they will be required to apply for an extension of authorisation or adapt the affected process stages so that they are chromium VI-free.
Despite the ECHA recommendation of twelve years, the Gerhardi Joint Application (FGK application), which was submitted by virtually all FGK members, received a review period of only seven years from the sunset date, i.e. until September 2024. This means that by then, applicants will be required to have implemented alternative solutions or have placed a follow-on application.
FGK companies are planning a switch to trivalent chromium
FGK addressed the issue of evaluating trivalent chromium plating at an early date. The systems available on the market were thoroughly reviewed over a period of several years. Insight acquired in this way significantly influenced the development of methods. Individual FGK member companies are already using trivalent chromium processes in series production or have rolled out test procedures.
Now it is important to plan and schedule the necessary system switches that are, in places at least, quite considerable. Depending on the specific company, this will take several years, but will certainly be manageable by 2024. It will be important to make a decision in good time on whether a follow-on application will need to be submitted.
The switch scenario must be coordinated with automotive customers at the same time. Some OEMs have already done the legwork for switching to trivalent chromium plating.
Chromium VI-free pre-treatment requires more testing and development
A switch to chromium VI-free processes in pre-treatment cannot be implemented in series production until process reliability for all standard plastics in use has been assured. A variety of tests are currently under way in this respect. But some companies would find it extremely difficult to implement the switch during ongoing operations.
The FGK members will place a follow-on application for another review period if the operational readiness of the alternative pre-treatment is not 100 percent certain by the end of this review period. Here as well, FGK will coordinate the switch and sampling scenario with the OEMs.