German electroplating companies have played an active role in the approval process by means of their involvement in number of different international and national consortia (CTAC, Vecco e.V. and FGK).
The CTAC application was created by chromium trioxide importers and covers all of the surface technology applications throughout Europe (from formulators to hard-chromium plating, and from decorative coatings to passivation coatings) where chromium trioxide is used.
The approval application by Vecco e.V. takes a different approach, placing the focus on the risk potential of the particular application.
The electroplating companies in the FGK have created their own approval application, which is oriented very specifically towards automotive applications for decorative coatings in vehicle interiors and exteriors.
What exactly is meant by an authorisation period or review period?
The use of chromium trioxide (in accordance with the referenced approval application) is permitted without any further testing during this period.
For example, a QM certificate can be consulted, which is also verified every year by way of a monitoring audit. This example would be referred to as a review period of 1 year.
What happens once the authorisation period has expired?
Once the review period has expired, this is followed by the next review period, and so on. To this end, once the review period has expired, the applicants create a new but reduced approval application, which takes into account the alternatives and conditions that exist at this point in time. The application is once again checked and evaluated by the ECHA and is given a new review period, i.e. the remaining time until a new check needs to be performed. It may be possible to reduce these review periods or it may also not be possible to change them, depending on the state of the alternatives.
How is the use of chromium trioxide (Cr-VI) guaranteed after the sunset date (21.09.17)?
There is a final recommendation from the ECHA for the approval application from CTAC. This proposes an authorisation period of 4 years for use in decorative applications. A final decision by the EU Commission has not yet been made. With this application, the use of chromium trioxide would therefore be permitted until 2021 without having to perform any re-testing or re-submit an updated application.
On 17.03.17, the SEAC (Committee for Socio-economic Analysis) gave the ECHA its final recommendation of 12 years for the authorisation period for the FGK approval application. The described application (Plating on Plastics for Automotive Applications – PoPAA) would therefore be permitted until 2029. A final decision by the EU Commission is still outstanding, but the recommendations of the ECHA have always been followed for applications that have already been responded to.
What happens if the EU Commission has not made a decision by the sunset date?
In the event of a delay, Article 58(1)(c)(ii) REACH stipulates that those downstream users who submitted their approval application at least 18 months before the sunset date (= "latest application date") are permitted to continue use beyond the expiration date until the EU Commission has reached a decision.
In this case, however, it must be considered that continued use is only permitted if this use falls within the application area specified in the approval application.
Are there available and feasible alternatives to the use of chromium trioxide (Cr-VI) in the electroplating process?
Chromium trioxide is used in two process steps within the electroplating process; once right at the start when conditioning the plastic surface (previously pickling) and once right at the end of the process when carrying out the final chrome-plating.
For the first process step, there is currently no chromium-trioxide-free alternative available on the market. Many chemical manufacturers do offer alternatives, but these have not been sufficiently tested either on a pilot-plant scale or a large industrial scale. Therefore, no reliable statements are available with regard to the process stability, the selectivity of multi-component products or the integration into existing systems technology etc. We are undoubtedly still in the preliminary stages of this area of technology. Further research and development is crucial.
For the final chrome layer, the available Cr-III procedure provides a perfectly respectable technical alternative. However, this procedure also involves particular requirements (technical, procedural, analytical, personnel-related) that the electroplating companies need to be able to meet. For example, most electroplating plants simply don't have enough space within the building or facilities to implement this procedure. There are also a number of questions relating to the specification of the layer (e.g. colour values, layer thicknesses, additional testing requirements etc.) that have not yet been clarified by the OEMs.
When can the alternatives be used?
There is still a distinct lack of basic knowledge relating to chromium-trioxide-free conditioning, meaning that no reliable statements can be made in this regard.
The Cr-III procedure is almost completely developed in terms of the technology, but there is still a lack of empirical values from series production. Companies will also not convert their electroplating plants if there are not sufficient orders to cover these high investments.
This can be summed up in a few simple words: Without an order from the customer, there will be no conversion to the Cr-III procedure, even though the technology would be operational throughout the company within approx. 5-7 years (plus the release periods set by the OEMs).
What do the OEMs need to do in order for alternatives to be used?
The OEMs have a variety of tasks to perform for the conversion to the Cr-VI-free procedure.
- There must be a consensus on the specification of the Cr-III surfaces, as only then will it be possible to carry out mixed assembly (Cr-III surfaces with Cr-VI surfaces and different electroplating companies).
- Series orders must be placed for Cr-III surfaces.
- The release/conversion scenario must be defined and agreed upon (e.g. only new projects during current series production for each component, for each electroplating company and OEM, scope of testing etc.).
Only when these issues have been clarified by the OEMs will it be possible for the electroplating companies to plan and implement the conversion to Cr-VI-free technologies.
In collaboration with a work group for occupational safety made up of experts from several different member companies, the FGK is working on improving occupational safety standards, which have already been at a very high level for many years. For example, there are plans to define cross-company standards for comparable measurements of any Cr VI contamination.