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SVHC Chromating

The European Chemicals Agency (ECHA) has included Sodium chromate, Sodium dichromate, Potassium chromate and Potassium dichromate in the candidate list of Substances of Very High Concern (SVHC), Sunset date has been set for all chromates at 21st Sept 2017, after which it will be illegal to use them without authorisation.

Chromates were present in the following products of our delivery program all of which have now been withdrawn: 060601 SIL AFT Salt , 090303 METAPAS Concentrate olive 090301 METAPAS Salt yellow 065328, Umicore ANTITARNISH 328 make-up salt. Any  residual products at our customers can be used legally up to the sunset date, but not beyond.

060601 has been replaced by Sil Aft Salt CF, which is chromate free. Other passivates are now available in trivalent versions.

The stated substances are used for the manufacture of chromating solutions for post treatment of Silver, Zinc or Zinc alloy coatings.  During the chromating reaction chromates are integrated in the chromate layer.  It is therefore necessary to check whether there is a duty of notification according to article 33 of Directive 1907/2006/EC (REACH Directive) .  We must point out there are a variety of Cr(VI) free post treatment processes which are available, and in most cases are substitutes for the Cr(VI) containing processes.

There is the duty of notification when the manufactured item contains 0.1% by weight or more of a SVHC product.  Chromated layers can have a layer of weight  up to 2 g/m² and contain up to 20% by weight of chromate, calculated as Chrome trioxide.  As the limit value of 0.1% by weight refers to the whole manufacture item and not to the chromate layer on its own, it is difficult to predict whether the limit value of 0.1% by weight is reached or exceeded.

A sheet plate of steel with a dimension of 1000 x 1000 x 2 mm has a volume of 2000 cm³ and thus a mass of 15,720 g and a surface of 2.008 m².  The weight per unit area of the chromating layer is therefore approx. 4 g and the proportional chromate is 0.8 g.  Calculating to the total weight this corresponds to a share of 0.005% by weight.  The limit value of 0.1% by weight is not reached.  It would only be reached when the sheet thickness was only 0.1 mm instead of 2 mm and all other dimensions remain unchanged.

The inclusion of these substances will not create any new obligations for the Schloetter group. These substances were already classified before in Directive 67/548/EWG, Annex 1 with T+, R 45, R 46 and R 60-61. Their inclusion in the SVHC list will not demand any change in the Material Safety Data Sheet.

T+ = Very Toxic
R 45 = May cause cancer
R 46 = May cause heritable genetic damage
R 60 = May impair fertility
R 61 = May cause harm to the unborn child

 

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Schloetter Co Ltd
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