The Alliance of PVD Providers (the APP) lead and managed by Fipra International Ltd. includes IHI Hauzer Techno Coating B.V., Ionbond Netherlands, B.V., Kolzer SRL, Oerlikon Balzers Coating Germany GmbH and Vergason Technology, Inc. The APP calls on the EU institutions to replace a hazardous chemical substance inclused in the REACH Regulation, the hexavalent chromium (CrVI), with the sustainable alternative of PVD, the physical vapor deposition technology.
CrVI is a carcinogenic substance: in the European market it has been banned since 2011. However, despite this and despite the existence of sustainable alternative technologies, it is still used on an industrial scale without providing a precise date for its final replacement. Indeed, the European Commission is planning to extend various pending CrVI authorisations for a very long time (12 years).
The Committee for Socio-economic Analysis (SEAC) and the Committee for Risk Assessment (RAC) within ECHA - European Chemicals Agency have recommended the European Commission to grant the following authorisations, among other ones:
- Lanxess: 4-year authorisation for functional plating with decorative character (see Note 1), whilst maintaining a 7-year authorisation for other applications (see Note 2);
- Gerhardi: 12-year authorisation (see Note 3) although there were 2 minority positions in RAC and SEAC in favour of a shorter review period;
- Hapoc: RAC and SEAC have not yet issued a recommendation on this application.
The APP requests the EU institutions to:
- Clarify and speed-up the decision-making process on the pending authorisations of the CrVI applications, included the Gerhardi, Lanxess and Hapoc applications, by December 2018.
- Reduce authorisation for Gerhardi application to maximum 7 years. This would be in line with the opinions of some ECHA - European Chemicals Agency's members.
On the basis of the above considerations, the APP has written the Manifest intitled "A sustainable alternative to CrVI" , which has the aim to show that the current draft decisions approving the CrVI's continued use are not based on the latest available information, but on the opinion submitted to the European Commission by the European Chemicals Agency in 2005-2006 (RAC and SEAC). During this period the PVD technology was still in rapid development and has been greatly developed since then.
Nowadays the CrVI can be easily replaced with the PVD technologies, that provide the same quality, they are cost-effective and available to meet the market demand and they were approved by the automotive industry.
The replacement with more environmentally friendly products must be the main aim of REACH.
The current status quo means the maintenance of a situation that represents a defeat for the society, since it is a missed opportunity for a more sustainable Europe. Indeed, both the companies and the NGOs know that the CrVI's replacement with the PVD technology is the only possible solution. Inspired by what Erin Brockovich achieved with the CrVI's elimination in the United States, the APP was created to achieve a better result.
The APP urges the EU institutions to say yes to the investments in a sustainable and recyclable product, that is suitable to the EU's ambition to create a non-toxic environment; to say yes to a climate-friendly production process and in line with the Paris Conference's objectives; lastly, to say yes to a competitive EU that has the know-how and the capacities to compete with technological giants in United States, China and elsewhere, rather than to leave room to other Countries in order to be the first continent to develop new greener technologies.
For any question, please contact Willem Vriesendorp (+32 2 613 2828), Fipra International's partner on behalf of the Alliance of PVD Providers.
Note 1: Opinion of RAC and SEAC (16 September 2016) on an Application for Authorisation for Chromium trioxide use: Functional chrome plating with decorative character.
Note 2: Opinion of RAC and SEAC (16 September 2016) on an Application for Authorisation for Chromium trioxide use: Functional chrome plating.
Note 3: Opinion of RAC and SEAC (13 March 2017) on an Application for Authorisation for Chromium trioxide, use: Plating on Plastics for Automotive
Applications (PoPAA). ECHA/RAC/SEAC: AFA-O-0000006558-63-02/F.
Note 4: The manifest can be downloaded at this link