In the following, we have provided you with information on frequently asked questions about REACH, the ban on chromium trioxide and our application for authorisation. Please click on the plus sign next to the question to display the detailed information. Your question is not listed? Please feel free to contact us!
What is REACH?
REACH – Regulation (EC) 1907/2006 is the European Chemicals Regulation concerning the Registration, Evaluation, Authorisation and Restriction of CHemicals. The aim of REACH is to ensure a high level of protection for human health and the environment. The principle is that manufacturers, importers and downstream users take responsibility for their chemicals, i.e. that they use the chemicals placed on the market safely. The REACH Regulation has been in force since 2007 and is considered one of the strictest chemicals laws in the world. Further information on REACH.
How is chromium plating affected by REACH?
The chromic acid required for chrome plating consists of aqueous chromium trioxide. Chromium trioxide is a hexavalent chromium compound, which is why it is also referred to as chromium(VI). Chromium trioxide is classified as mutagenic and carcinogenic, which is why it was included in the list of substances of very high concern (SVHC) in 2010. With the listing in Annex XIV of the REACH Regulation, chromium trioxide may only be used after the sunset date (21 September 2017) if an authorisation has been granted by the EU Commission and the user has taken appropriate and effective measures to protect employees, the environment and the population.
Are chromium-plated components dangerous to health or the environment?
No. The chromium layer deposited in the galvanic process is present as a metal in neutral form – chromium(0) – and is not toxic. Chromium-plated components are completely harmless.
How long is it guaranteed that Betz-Chrom is our legally secure chrome plater?
Through the application of the CTACSub consortium, Betz-Chrom is covered as a downstream user until September 2024. Downstream users must also comply with certain conditions within the scope of this authorisation (exposure measurements, emission measurements, etc.). Betz-Chrom has been dealing with these issues for some time and has suitable partner companies, such as an accredited measuring institute, to fulfil these requirements. Betz-Chrom completely complies with the conditions for authorisation that apply to downstream users of the CTACSub supply chain.
Betz-Chrom has prepared itself for the period after September 2024 and submitted an individual application for the use of chromium trioxide to the ECHA (European Chemicals Agency) in February 2021. Our application for authorisation is fully supported by the reputable engineering and management consultancy Ramboll. Ramboll is very experienced in the field of REACH authorisations, maintains excellent contacts with authorities (especially ECHA) and has successfully implemented more than 50 similar projects.
With the opinion of the Committee for Risk Assessment (RAC) and the Committee for Socio-economic Analysis (SEAC), an important milestone was reached in our authorisation procedure. The opinion recommended an authorisation for 12 years (proposed review period: long). The opinion was sent to the European Commission in March 2022. In addition, the RAC and SEAC opinion on our application was published on the ECHA website. The EU Commission’s decision on Betz-Chrom’s application for authorisation is expected well before September 2024. The EU Commission’s decision on Betz-Chrom’s application for authorisation is expected well before September 2024.
Why did Betz-Chrom decide to submit an individual application instead of joining the follow-up CTACSub application?
Originally, it was explicitly intended by the authorities that users join together in consortia and submit joint applications for authorisation. In theory, a consortium application has the advantage that it relies on a broad base of knowledge to establish a secure data situation. In practice, it has proven to be very complex and time-consuming to share and process this knowledge. Moreover, in the past many companies were not willing to make sufficient data available. The biggest point of criticism, however, is that the components and corresponding industrial applications as well as the risk minimisation measures differ widely between the companies in the consortium. This made the assessment of the data situation on the regulatory side a difficult undertaking and uncertainties (e.g. availability of alternatives) could not be sufficiently reduced. As a result, the CTACSub application became the focus of political attention and ultimately the decision on approval dragged on for several years.
Betz-Chrom submitted an individual application for the use of chromium trioxide to ECHA in February 2021. The individual application allows Betz-Chrom to demonstrate the use of chromium(VI) in the specific application as well as the high standard of risk minimisation measures and to support this with exposure and emission measurements. This increases the chances for a longer review period compared to a consortium application. Currently, we have to assume that a complete substitution of chromium trioxide will not be possible within the requested review period. In this case, it is also possible to extend the authorisation in the individual application by submitting a follow-up application (review report).
How does the approval procedure for Betz-Chrom work?
The application is structured in four parts. The Chemical Safety Report (CSR) contains the risks and risk minimisation measures associated with the use of the substance. The Analysis of Alternatives (AoA) examines the technical and economic feasibility, availability and risk reduction potential of alternative substances and technologies. The Socio-Economic Analysis (SEA) weighs the benefits against the costs to society if authorisation for the use of the substance were not granted. The Substitution Plan (SP) contains a concept including a timetable for replacing the substance with an alternative. More on how to prepare an application for authorisation.
After almost two years of preparation, Betz-Chrom submitted the individual application to ECHA in February 2021. ECHA then published the application on its website and invited the public to give information on possible alternative substances or technologies for these uses. The consultation period lasted a total of eight weeks and ended on 14 July 2021.
The Risk Assessment Committee (RAC) and the Committee for Socio-economic Analysis (SEAC) prepare their draft opinions within 10 months of receiving the application. The opinions of the Committees are based on the application as well as on all information received during the consultation on possible alternatives. More general information on the opinion development of RAC and SEAC.
In their opinion on our application, RAC and SEAC recommended an authorisation for 12 years (proposed review period: long). In March 2022, the Secretariat sent the opinion to the European Commission. In addition, the RAC and SEAC opinion on our application was published on the ECHA website.
Based on the opinion of the RAC/SEAC, the European Commission prepares a draft authorisation decision – ideally – within three months after receiving the opinion from ECHA. Following the draft decision, at least three months are needed for the vote in the REACH Committee and the subsequent adoption procedure in the Commission. The entire decision-making process of the Commission therefore usually takes much longer than six months. If the authorisation is granted by the European Commission, it is subject to the conditions of the Chemical Safety Report submitted with the application. Additional conditions may be specified in the Commission’s authorisation decision. More on the decision-making process of the European Commission.
Due to the complexity and the importance of the application for authorisation, Betz-Chrom is being supported throughout the entire process by the reputable engineering and management consultancy Ramboll, which has already successfully handled more than 50 similar projects.
Our application is publicly available at: application for authorisation of Betz-Chrom.
Are you confident that an authorisation for Betz-Chrom will be issued?
Due to the timely submission, we assume a positive decision on our individual application within the existing authorisation period of CTACSub.
With the opinion of the Committee for Risk Assessment (RAC) and the Committee for Socio-economic Analysis (SEAC), an important milestone in the authorisation procedure was reached. The opinion recommended an authorisation for 12 years (proposed review period: long). The opinion was sent to the European Commission in March 2022. In addition, the RAC and SEAC opinion on our application was published on the ECHA website. Through the application of the CTACSub consortium, Betz-Chrom is covered as a downstream user until September 2024. The EU Commission’s decision on Betz-Chrom’s individual application for authorisation is expected well before September 2024.
Are you working on alternative coatings to hard chrome or are there ongoing developments?
Yes! In a joint research cooperation, the chemical supplier Coventya and Betz-Chrom have developed a pilot process for functional coating with chromium(III). The BeGreen Chrome process deposits a functional hard chrome layer based on trivalent chrome compounds from the DURATRI 240 electrolyte. We currently offer the coating as part of R&D projects. For more information, please visit our BeGreen Chrome website.
In addition, we have built up a network of research institutes, chemical suppliers, plant manufacturers and market participants with whom we regularly exchange information on innovations and ongoing developments.
Based on our expertise in electroplating technology acquired over decades, we focus on an alternative electroplating process. However, Betz-Chrom also considers possible alternatives in other areas of technology.
We strive to offer our customers a technologically and economically feasible alternative to chromium trioxide and, in the meantime, continue to carry out legally secure hard chrome plating with chromium(VI).
What measures can we take as a customer?
Ideally, you support us in the research and development of an alternative for chromium trioxide in hard chrome plating. Only through the feedback of our customers can we further develop chromium plating on the basis of trivalent chromium compounds so that it becomes a technically and economically feasible alternative to chromium(VI). We are therefore looking for further interested pioneers who want to test a functional chrome plating with chromium(III) on their components and in their specific application. For more information, please visit the BeGreen Chrome website or contact us directly via email@example.com.