Chromium-VI and Chromium-III

The so-called REACH Regulation was adopted in 2006. REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. It stipulates that approval permits are required for the use of substances of very high concern (SVHC).

At the instigation of Germany, chromium trioxide was listed as a SVHC. Since then, the clock has been ticking for the free use of chromium trioxide in the EU. The so-called "sunset date" is the date from which a chemical substance - without having the corresponding approval - may no longer be used or placed on the market under REACH. In the case of chromium trioxide, this date was 21 September 2017. This also applies to warehouse stock and to the aqueous solution of chromium trioxide, which is often referred to as chromic acid.

In order to maintain the possibility of continuous further use within the framework of the REACH Regulation, numerous manufacturer and user consortia have submitted approval applications for chromium trioxide.

The European Chemicals Agency (ECHA), based in Helsinki, is responsible for evaluating these applications. Two committees have been dealing with the topic of chromium trioxide there: the Risk Assessment Committee (RAC) and the Socio-economic Analysis Committee (SEAC). In the meantime, they have recommended that the EU Commission approve six applications. According to their final recommendations, if chromium trioxide is further used in the EU, the risks to human health are significantly lower than the overall benefits of further use. Normally, the EU Commission follows ECHA's recommendations.

However, the Zentralverband Oberflächentechnik e.V. currently does not expect the EU Commission to issue this approval before the sunset date. In this case, special regulations apply for the interim periods.

If the EU Commission, as expected, follows the recommendations of the ECHA committees, nothing will change for buyers of chromic acid-based surfaces: they can still obtain chromed surfaces for the approved applications after 21 September 2017 without further restrictions. This pertains to the duration of the specified review period, which is four years for "functional chrome plating with decorative character".

Within this time window, coaters must have implemented a chromium-VI-free alternative technology or have had an application for authorisation extension approved.

In the electroplating process, chromium is deposited as a metal and lies on the carrier material (e.g. metal, plastic) as an end surface in neutral form, chromium-0, and is therefore non-toxic. Therefore there is no potential danger for users and consumers.

The required properties of this chrome coating are its very good corrosion resistance, abrasion resistance as well as the color stability of this metal, which are currently not fully achieved by alternatives.

Research is currently being carried out into process-reliable and suitable alternatives that can completely replace a chromium-VI coating.

If you have any further questions on this topic, please contact us. We take our role as a downstream user and the associated obligations and tasks with regard to the European chemicals legislation REACH very seriously, and would therefore gladly provide you with detailed information.