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 request was made 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 request for approval which is specifically focused on the decorative coating for interior and exterior automotive applications.
During the meeting of the Regulating Committee of the European Commission on February 15th, 2019 two authorisation requests of importance for the further use of hexavalent chromium compounds during chrome plating of plastic components were assessed and finally approved:
For the CTAC application the committee set a review period of four years. Because of the far delayed decision the deadline for the review period shall not be from the "sunset date" 21 September 2017, but from the date of publication of the approval.
The Gerhardi joint application (FGK application), which most members of FGK participated, received a review period of seven years from the "sunset date", so until September 2024 although ECHA recommended a period of twelve years. The applicants will have implemented alternative solutions by then or file a subsequent application for a new review period. The publication of both authorisations in the EU official journal is expected until autumn 2019.
The FGK was engaged in the evaluation of trivalent chrome plating systems (Cr(III)-systems) since a very early stage. The new systems available on the market have been tested extensively over several years. The outcome of these tests gave important indications for the further development of the new plating systems. Single FGK companies already employed trivalent chromium processes in series production or have installed test procedures.
Now it is to plan the partly extensive modifications of the plating lines and to schedule them. This will take some years to complete depending on the company and the individual complexity and size of the machinery, but will be completed until 2024. If in addition a subsequent application for a further review period needs to be submitted, will be decided in a timely manner. In parallel it is to coordinate the changeover scenario form Cr(VI)- to Cr(III)-systems together with the automotive customers. Some OEM have already laid the foundations for a change towards the trivalent chrome plating.
Cr(VI)-free conditioning processes can be implemented into mass production only once the process is stable and established for the common plastic grades as well as their combinations in multiple component parts. At this moment there are running several intense tests at the formulators as well as within FGK member facilities. Once the suitability of alternatives is proven in an industrial scale, the companies will subsequently plan and implement the necessary modification of their plating lines. This will be quite a complex and expensive task and can take place during short available time slots only.
In case the operational robustness of the alternative conditioning systems cannot be assured by 100% until the end of the review period, the FGK members will file a subsequent application for a further review period. Again the FGK will coordinate the process change and initial sampling scenario closely with the OEMs.
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