The German plastic electroplating companies have actively participated on the approval process of several international and national consortia (CTAC, Vecco e. V. and FGK), because substances containing Cr(VI) are used during two process steps during electroplating on plastic. These steps are the pre-treatment of the plastic surface to make it electrically conductive and the actual chrome plating, which is the application of the final metal layer on the part. It is important to note that the final product does not contain any Cr(VI) substances but they are only used during the plating process itself.
The CTAC application was compliled by the importers of chromium trioxide and includes all applications of surface technology in Europe (i.e. formulators, hard chrome plating, decorative coatings, passivation surfaces), where chromium trioxide is used today. The plastic electroplating companies that are organised in the FGK submitted a standalone application for authorisation which is specifically focused on the decorative coating for interior and exterior automotive applications.
After the FGK application had been assessed by the relevant committees of ECHA a decision by the European Commission was expected in spring 2019. However, this decision has not been made because the European Court of Justice (ECJ) has classified an authorisation of a substance as unlawful in another case, which is not directly related to the FGK application. The court claimed that the assessment of the availability of potential alternatives would not have been carried out in accordance with the EU guidelines.
As a consequence of the ECJ judgment, the EU Commission has now requested the subsequent submission of a substitution plan for various authorisation applications (not only for chromium trioxide). This is a timing/project plan that shows the path to the potential replacement of the substance to be authorised. In May 2020, the FGK consortium received the official request to draw up such a substitution plan by November 2020 and to submit it to ECHA. A working group within the FGK started to develop this plan already. The same is done by the other applicants concerned.
The FGK companies are actively engaged in evaluating alternatives to chromium trioxide within the two relevant process steps. The FGK participated in the benchmarking and testing of trivalent chrome plating at an early stage and, with the knowledge gained thereby, significantly influenced the development of the processes. In the meantime, first FGK companies are offering surfaces from trivalent chrome plating to their customers. The others are planning the extensive plant modifications required and will implement them within the expected authorisation period.
Likewise, the FGK examined the suitability of alternative pre-treatment respectively conditioning processes for the commonly used plastic substrates, material combinations and part geometries in-house and together with formulators. So far, the results of the extensive series tests have not been satisfactory and the feasibility in a reliable industrial production scale is not yet foreseeable. As soon as alternatives have proven to be suitable for large-scale use, the necessary plant modifications will be planned and implemented here. Accordingly, the required steps and timelines for this will be taken into account in the substitution plan.
By mid-2021, once the ECHA has assessed the plan submitted by the FGK consortium, the EU Commission will then deal with the application for authorisation again. The expectation that the FGK application will be approved finally remains unchanged, as the many delays within the authorisation process are not related to the content of the application, but are essentially based on procedural formal reasons.
The application for authorisation has already been positively assessed by the committees of ECHA and by submission of the substitution plan, the applicants give an additional commitment to eliminate chromium trioxide from their production processes as soon as suitable alternatives are available on the market. Within the same timeframe final decisions on the other applications for authorisation (i.e. CTAC, Vecco e.V. and others) are expected.
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