Since September 2017, authorisation by the EU Commission has become mandatory for the use of chromium trioxide. German plastics electroplating plants also require such an authorisation, as the substance is used during two process steps in plastic metallisation. These are, firstly, the conditioning (etching) of the plastic surface to make it electrically conductive and, secondly, the actual chrome plating, which is the application of the final metal layer to the part. It is important to note that the end product does not contain any Cr(VI) substances but these are used only during in the plating process itself.
So-called downstream applications were submitted by importers or traders of chromium trioxide. These applications usually cover several uses of chromium trioxide in surface technology, for example formulation, hard chrome plating, decorative coating or passivation. If an authorisation is granted for the corresponding use, the downstream user can refer to it and may use the substance.
More targeted are individual applications or joint applications of several companies with the same use of the substance. The plastics electroplating companies organised in the FGK therefore submitted their own application for authorisation in 2016, which is specifically focused on the chrome plating for interior and exterior automotive applications.
After a positive assessment and a recommended review period of 12 years (until 2029) by the ECHA expert panels, the FGK application was due for a decision by the EU Commission in spring 2019. However, after one of its authorisation decisions was declared invalid by the European Court of Justice (ECJ) in a different case, the EU Commission has requested the subsequent preparation of so-called substitution plans for a larger number of authorisation applications (not only for chromium trioxide) that already had been submitted. All applicants concerned, including the FGK consortium, have followed this request and have drawn up corresponding plans and submitted them to ECHA before the end of 2020. A substitution plan is a project plan that draws the path to the potential replacement of the substance to be authorised by a suitable alternative.
In the course of preparing this substitution plan, the current maturity of possible alternatives to the use of chromium trioxide in plastic conditioning (etching) and the actual metallisation (chromium plating) process was again comprehensively evaluated and also queried with process technology developers and other stakeholders. Taking into account the individual company situations, as well as additional conditions relevant for the transition to alternatives, such as product life cycles and release processes, a corresponding timetable for the substitution was drawn up. For chromium plating, it is expected that all plating lines of the participating companies will be converted to the use of trivalent chromium electrolytes in the course of approximately 8 years. For the conversion of the conditioning step to alternative processes, a period of 13 years is required until complete substitution, due to the significantly lower degree of maturity and the development work that still needs to be done. It is important to note that the consumption of chromium trioxide by the FGK companies will be gradually reduced from as early as 2022, as soon as the first significant production quantities have been moved to trivalent chromium plating and – with a slight time lag – first alternative processes in conditioning are used in series production.
In the meantime, the ECHA authority in charge of the evaluation, the Socio-Economic Analysis Committee (SEAC), has issued its preliminary opinion on the submitted substitution plan. In its assessment, the Committee fully follows the explanations and arguments of the applicants and classifies the plan as "credible". This judgement applies to the assessment of the availability of alternatives, the factors influencing substitution, and the time schedule based on this. In addition, the monitoring concept, which, beside to tracking the progress of the project at the company level, also provides for higher-level tracking at the association level, has been rated positively.
SEAC assessments for the use of chromium trioxide in plastic metallisation are now available for various other applicants (individual companies and consortia). The Committee confirms the review periods applied for, which are generally 12 years.
Only for two downstream authorisation applications the submitted substitution plans were classified as "non-credible". According to the consensus of those involved in the process, this is due to the nature of a complex downstream application with hundreds of downstream users, which makes it very difficult to assess the viability and representativeness of the substitution plan.
The SEAC assessment will now be made available to the EU Commission together with the substitution plans, so that the Commission can finally come to a decision on the pending applications for authorisation. In the opinion of the FGK, the positive assessment by SEAC is an important supporting element for authorisation, in addition to the commitment of the applicants to remove chromium trioxide from their production processes, which is laid down in the substitution plan.
The FGK expects that the Commission will follow the advice of its own EU experts in its forthcoming consultation. A decision is expected in the course of the second half of 2021.
If you want to receive more information about the authorization of chromium trioxide in the plastic plating industry or the Cr(VI)-fee alternatives, please consult our office or our Automotive Manager directly.
Fachverband Galvanisierte Kunststoffe e.V.
P.O. Box 10 10 63
Phone: +49 2103 25 56 10
Fax: +49 2103 25 56 15
Phone: +49 2103 25 56 23
Fax: +49 2103 25 56 43