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EU Initiates Proposal for Restriction of Chromium Electroplating Process

Time：

2023-11-14

EU Initiates Proposal for Restriction of Chromium Electroplating Process

Recently, the European Chemicals Administration (ECHA) has received authorization from the European Commission to prepare an Annex XV report that may impose possible restrictions on chromium (VI) substances in items 16 (chromium trioxide) and 17 (chromic acid) of the current REACH authorization list XIV (Annex XIV). According to the authorization requirements of the European Commission, ECHA will submit a restriction proposal before October 4, 2024.

1、 The proposal for a chromium ban has increased, and ECHA is preparing to cut it all

According to ECHA reports, the proposed restriction aims to address the challenges posed by the current and potential future workload of ECHA and the European Commission. This workload stems from a large number of applications for authorization to use these substances, which have been submitted or may come from hundreds of companies. For ECHA, evaluating applications and drawing conclusions will exceed the available resources of the Risk Assessment Committee (RAC) and the Socio Economic Analysis Committee (SEAC), and will affect its work in regulating other hazardous chemicals.

If ECHA discovers potential risks of regrettably replacing other chromium (VI) substances during the preparation process of the restriction proposal, the scope of authorization can be extended to cover other chromium (VI) substances. However, this requires discussion and agreement with the committee.

The preparation of restriction proposals and the evaluation of RAC and SEAC will follow the standard REACH restriction process. When preparing the proposal, ECHA will consider the knowledge and experience gained from the authorization application for handling these substances. Once the committee approves the restrictions, the substances within the scope will be removed from the authorization list. This will mark the first time in REACH's history that such action has been taken.

2、 What is the expected timeline for implementing restrictions?

The European Commission issued an authorization to ECHA on September 27, 2023, which was issued for intention registration on October 11, 2023, giving ECHA 12 months to complete the Annex XV file, in accordance with Article 69 (4) of REACH. Once the qualification check is opened, the files will be completed by RAC and SEAC, with the committee having 9 and 12 months respectively to finalize their opinions. The final opinion will be submitted to the European Commission, which will draft revised regulations and submit them to the REACH Committee on behalf of member states. After the REACH committee submitted its opinion, the European Parliament and Council had a three-month review period before implementing the restrictions, which was ultimately approved by the committee. In the best case scenario, the European Commission is expected to take restrictive measures approximately 3 years after receiving ECHA authorization.

3、 What is the scope of the restriction in the proposal?

In the task of the European Commission, ECHA is required to prepare an Annex XV dossier containing information aimed at limiting at least two Cr (VI) substances, namely chromium trioxide and chromic acid (items 16 and 17 in Annex XIV). As part of the preparation of the restricted dossier, ECHA requires that the evaluation be limited to these two substances and replaced with other unrestricted Cr (VI) substances. The scope of the attachment XV file can be extended to other Cr (VI) substances if ECHA deems it necessary to do so to prevent regrettable substitution. The evaluation scope will cover all uses of the substance, similar to the use. When the substance is listed in Annex XIV, it is subject to authorization obligations. ECHA has been requested to establish several limiting options in the attachment XV dossier in order to find the most suitable method to control the risks of these substances, while encouraging alternative alternatives.

4、 Hexavalent chromium has a wide impact, and the EU has widely recommended it

The European Commission has issued a Q&A document clarifying the situation of the affected companies. This document also covers the main issue regarding the revocation of consortium authorizations covering many downstream users of chromium trioxide by the European Court of Justice ruling (Chemservice ruling).

Encourage companies dealing with hexavalent chromium compounds to consult this document for more information. If your question is not answered in the document, it can be collected and sent to the European Commission by Akerson Environmental Technology Agency. The EU invites stakeholders to provide relevant information to the file submitter. If justified based on reliable risk and socio-economic information, the submitter of the record may suggest derogation from the proposed restrictions. If the submitter of the record does not propose any reduction, it is the responsibility of relevant stakeholders to propose the reduction in any consultation process, accompanied by sufficient risk and socio-economic reasons.

5、 Significant impact in the automotive manufacturing sector

In April 2013 and August 2014, a total of 11 hexavalent chromium substances were added to the authorization list. They may cause cancer, genetic mutations, and harm reproduction. Some of them are also skin and respiratory allergens. One of the main uses of the substances covered in the restriction proposal is electroplating, which is a common material coating surface treatment process.

Hexavalent chromium electroplating is a widely used chromium plating method in industry and is widely used in high-end automobile manufacturing. Hexavalent chromium coating is bright, with high hardness, good wear and corrosion resistance, simple process, and convenient maintenance. However, hexavalent chromium electroplating is one of the most serious and difficult to treat pollution sources in the electroplating industry. Chromium is one of the essential elements in the normal metabolic process of organisms. Chromium deficiency can cause metabolic disorders such as sugar and fat, but excessive levels can cause serious harm to organisms and the human body. The US Environmental Protection Agency (EPA) has identified hexavalent chromium as one of the 17 highly hazardous toxic substances. Chromium exists in trivalent and hexavalent forms in water, with hexavalent chromium being highly toxic, approximately 100 times that of trivalent chromium. If the concentration of hexavalent chromium in water exceeds 0.1mg/L, it will have toxic effects on the human body. Chromium (V) has serious irritation to the skin and can cause skin ulcers. Long term intake can cause diseases such as squamous cell carcinoma, sarcoma, and adenocarcinoma. Hexavalent chromium wastewater and waste cannot be naturally degraded in nature like cyanide.

Many developed countries are gradually replacing hexavalent chromium electroplating with trivalent chromium electroplating. North America has stipulated that hexavalent chromium will gradually decrease, and many domestic manufacturing processes have also switched to trivalent chromium electroplating. However, with the recent REACH authorization proposal, if such substances are also restricted, the use of chromium containing substances in electroplating processes will face significant challenges.