The authorization process lasts many years: An electroplating expert from the Fraunhofer Institute for Manufacturing Engineering and Automation IPA recommends that galvanizers and users of hard chromium coatings apply for a company-specific REACh authorization now, whilst discouraging authorization applications in large consortiums.
In reality, it is a good thing: The EU directive "Registration, Evaluation, Authorisation and Restriction of Chemicals” (REACh) regulates the handling of dangerous substances and aims to protect the environment and workers. For electroplating technology, this means that since September 21st, 2017, the main hexavalent chromium compounds, as a means of production, must be licensed. Since then, individuals may only use chromium VI if they have submitted a licensing application with the European Chemicals Agency (ECHA) in Helsinki or have obtained these substances from a supplier which has submitted such an application.
To this end, manufacturers and end users of hard chromium processes have merged into two consortiums and submitted a collective application to the ECHA. Although the final outcome of this venture still remains to be seen, it is nevertheless conceivable that the period for authorization will be approved until September 2024 at the latest. The follow-up application must be submitted by this time at the latest. Martin Metzner, Head of Department for electroplating at Fraunhofer IPA, warns: "Businesses have no time to lose in submitting applications", adding: "It will take two to three years to collect the data for the chemical safety report, conduct socio-economic analysis and investigate alternative procedures."
Each of these three documents is extensive, can comprise more than 100 pages and, for logical reasons, should be written in legal, watertight English. The documents begin with measurements indicating emissions levels of production processes and how adversely employees are affected by these. However, the Analysis of Alternatives (AoA), a product-specific investigation of the possible alternative substances and procedures to chromium VI as a means of production, is highly time-consuming and must be carried out separately for each use. The IPA team has collected extensive data on this and carried out specific examinations of coating properties.
Metzner says: "Once all that is done, a specialized consultancy firm must formulate and submit the application to the ECHA, a process which, in my experience, takes another year." It can then take another two years for the European Commission to grant REACh registration upon the recommendation of the ECHA. Metzner adds: "Therefore, it is of the utmost importance to start the specific authorization process now, so that everything is ready by the time the presumptive transition period for the current collective applications is due to come to an end."
It is worth the effort: Summarizing his previous experiences with REACh registration applications, Metzner comments: "The more detailed and specific the application, the longer the process for REACh registration lasts".
However, it is unclear whether large-scale collective applications will remain logical in future due to an inevitable lack of company-specific information in this regard. Metzner recommends individual applications, pointing out that "long-term authorizations are market-decisive for companies in the electroplating industry and coating end users."
Fraunhofer Institute for Manufacturing Engineering and Automation IPA