CASF conference, Vaughan, Canada 18 November 2015

CASF conference, Vaughan, Canada 18 November 2015
Potential Banned Substances of Concern for the Metal Finishing Industry CASF conference, Vaughan, Canada 18 November 2015 Werner Richtering – Atotech, Berlin, Germany – 18/11/2015

... seen from Europe: REACH and other directives
... an update Werner Richtering – Atotech, Berlin, Germany – 18/11/2015

Substance inventories
KECI AREC DSL REACH TSCA IECSC ENCS RICCS PICCS CLASS TCSI AICS W. Richtering – CASF, Vaughan, Canada – 18/11/2015

A global trend: environmental awareness towards a sustainable future
REACh and REACh-like legislations worldwide: Restriction of Cr(VI)-compounds (Chromates, Dichromates, CrO3) Restriction of Co-salts Restriction of hazardous substances (RoHS) End of Life Vehicles Directive (ELV) Biocide Directive K-Reach: South Korea Taiwan-Reach Nickel-salts ??? Borates and boric acid NPE: Nonylphenolethoxylates W. Richtering – CASF, Vaughan, Canada – 18/11/2015

Local restrictions for specific chemicals: Boron-based chemicals in Europe (fish toxin) More than local restrictions for specific chemicals, (China Catalog of Hazardous Chemicals, rev. 2015) W. Richtering – CASF, Vaughan, Canada – 18/11/2015

Industry or company restrictions: Formaldehyde: by Samsung, semiconductor industry Nickel: by cell phone manufacturers ... Cr(VI): Hyundai, Toyota, ... More than industry or company restrictions (substances restricted by OEM, e.g. On-Semiconductor, Sony, HP, Hitachi, Seagate, Intel, Panasonic, Ford, GM, VW...) *SVHC: Substance of Very High Concern W. Richtering – CASF, Vaughan, Canada – 18/11/2015

Paris, 06/01/2014 Restrictions on chemical substances are increasing on a world-wide level. Today 12 chemical inventories, including REACH E.g. REACH Today, 31 chemical substances of very high concern (SVHC) are listed in ANNEX XIV and require authorization, including hexavalent chromium (Cr(VI)) By 2020: > 450 SVHC candidates will be reviewed and presumably included Other Chemical Legislations e.g. China Catalog of Hazardous Chemicals rev (update after Tianjin accident) In 2015: Major revision to broaden the scope and include substance groups With chemical regulations like REACH, the use of chemical substances is limited to certain applications, requires protection equipment and oftentimes is also only allowed for a certain period of time before the substance will be outlawed. W. Richtering – CASF, Vaughan, Canada – 18/11/2015 Cr6-elimination-case-and-timeline_v5.8_ pdf

R E A Ch egistration, valuation, uthorization and restriction of
emicals W. Richtering – CASF, Vaughan, Canada – 18/11/2015

Timeline of REACH in effect since 1 June 2007
Nov. 2015 High volume deadlines passed – all other due before 2018 Source: BTC Specialty Chemical Distribution, REACH Flyer W. Richtering – CASF, Vaughan, Canada – 18/11/2015

REACh: Substances of Very High Concern (SVHC)
„Substances of very high concern pose an unacceptable risk to human health / the environment” It is the aim of REACH to replace SVHC progressively (where economically and technically viable) Authorization and restriction are the mechanisms to minimize the risks coming from SVHC by restricting the use to specific applications imposing strict measures for handling the substance eventually banning the use of the substance from the market EU authorities repeatedly announced intention to fulfil the target of reviewing >450 substances for the SVHC candidate list by 2020 Any substance on the SVHC candidate list might be banned within 5 years *SVHC: Substance of Very High Concern W. Richtering – CASF, Vaughan, Canada – 18/11/2015

Annex XIV Proposals for SVHC Candidate list Priority list Reach Annex XIV 31 substances included in Annex XIV with sunset dates from Aug until 22. Jan. 2019 Additional 35 substances recommended as priority substances for inclusion into Annex XIV have been published between 01. Jun (1st) until 01. Jul (6th recommendation) Number of substances on the Candidate List: (published in accordance with Article 59(10) of the REACH Regulation, last updated: 15 Jun. 2015) If customers require information about SVHC in ATOTECH‘S products, local HSE can check with the data in Atotech products containing SVHC xls W. Richtering – CASF, Vaughan, Canada – 18/11/2015

Chromium-VI among the first SVHCs nominated
Paris, 06/01/2014 REACH provides strict guidelines for the authorization of substances of very high concern (SVHC) EU Member state proposal for SVHC 18 months or more for preparation of application per uses 18 months or more for decision whether authorization is granted If authorization is granted It specifies: The allowed use / time frame / HSE measures Authorization can be taken back any time if a business solution is found Formation of a consortium for authorization of specific uses 2013 Latest date of application 2016 Sunset date: Any use without authorization banned Expected expiry date authorization 2017 2025 2011 The process for authorization of substances of very high concern (SVHC, as specified in Annex XIV) is clearly defined: EU member states may propose substances for SVHC at any time. The European Commission decides whether these substances will effectively become subject to authorization. These substances will then move into the Annex XIV and are published. Then companies are given a minimum 18 months for preparing applications for specific uses of the listed substances. Earliest 18 months after the latest date for application, any use without authorization is banned, the so-called „sunset date“. If authorization is granted, it specifies the allowed use, time frame and HSE measures. However, the important thing is: Authorization can be taken back ANY TIME, if a feasible alternative economic solution is found. Chromium-VI among the first SVHCs nominated W. Richtering – CASF, Vaughan, Canada – 18/11/2015 Cr6-elimination-case-and-timeline_v5.8_ pdf

Paris, 06/01/2014 Chromium-VI is used in various industries. Many applications have already been stopped. Worldwide consumption: Applications (partly stopped already) Paints Textile and leather Wood preservation Anti-corrosion and conversion coatings ELECTROPLATING 2002: 184,000t 2011: 90,000t of which 45,000t by the metal finishing industry W. Richtering – CASF, Vaughan, Canada – 18/11/2015 Cr6-elimination-case-and-timeline_v5.8_ pdf

Expected 12 years with restrictions, then no more Chromium-VI
Paris, 06/01/2014 It is expected that usage for Chromium-VI is granted with restrictions but... Example Chromium-VI Expected 12 years with restrictions, then no more Chromium-VI EU Member state proposal for SVHC 18 months or more for preparation of application per uses 18 months or more for decision whether authorization is granted If authorization is granted It specifies: The allowed use / time frame / HSE measures Authorization can be taken back any time if a business solution is found Formation of a consortium for authorization of specific uses / Atotech is a member of the consortium Latest date of application Sunset date: Any use without authorization banned Expected expiry date authorization 2011 The process for authorization of substances of very high concern (SVHC, as specified in Annex XIV) is clearly defined: EU member states may propose substances for SVHC at any time. The European Commission decides whether these substances will effectively become subject to authorization. These substances will then move into the Annex XIV and are published. Then companies are given a minimum 18 months for preparing applications for specific uses of the listed substances. Earliest 18 months after the latest date for application, any use without authorization is banned, the so-called „sunset date“. If authorization is granted, it specifies the allowed use, time frame and HSE measures. However, the important thing is: Authorization can be taken back ANY TIME, if a feasible alternative economic solution is found. 2013 2016 2017 2025 The EU has already now published strict standards for specified Chromium-VI usage after sunset days. W. Richtering – CASF, Vaughan, Canada – 18/11/2015 Cr6-elimination-case-and-timeline_v5.8_ pdf

Expected 12 years with restrictions, then no more Chromium-VI
Paris, 06/01/2014 It is expected that usage for Chromium-VI is granted with restrictions but... Example Chromium-VI Expected 12 years with restrictions, then no more Chromium-VI EU Member state proposal for SVHC 18 months or more for preparation of application per uses 18 months or more for decision whether authorization is granted If authorization is granted It specifies: The allowed use / time frame / HSE measures Authorization can be taken back any time if a business solution is found If an economically feasible alternative exists, authorization is not granted. If an economically feasible alternative appears, application may lose authorization. Formation of a consortium for authorization of specific uses / Atotech is a member of the consortium Latest date of application Sunset date: Any use without authorization banned Expected expiry date authorization 2011 The process for authorization of substances of very high concern (SVHC, as specified in Annex XIV) is clearly defined: EU member states may propose substances for SVHC at any time. The European Commission decides whether these substances will effectively become subject to authorization. These substances will then move into the Annex XIV and are published. Then companies are given a minimum 18 months for preparing applications for specific uses of the listed substances. Earliest 18 months after the latest date for application, any use without authorization is banned, the so-called „sunset date“. If authorization is granted, it specifies the allowed use, time frame and HSE measures. However, the important thing is: Authorization can be taken back ANY TIME, if a feasible alternative economic solution is found. 2013 2016 2017 2025 The EU has already now published strict standards for specified Chromium-VI usage after sunset days. W. Richtering – CASF, Vaughan, Canada – 18/11/2015 Cr6-elimination-case-and-timeline_v5.8_ pdf

Chromium trioxide (“Chromic Acid”) Authorization
Chromium trioxide is listed on Annex XIV or REACh The substance is labelled a “Substance of Very High Concern (SVHC)” Any use that is not explicitly authorized is banned after the sunset date: September 21, 2017 April 17, 2013 Inclusion in Annex XIV REACH Dec. 2014 Conclusion of consortium works Q1 2015 Start of application consortium Q3 2015 Submission of applications March 21, 2016 Latest application date Sept. 21, 2017 Sunset date a a a a W. Richtering – CASF, Vaughan, Canada – 18/11/2015

EACH authorization Chromium Trioxide Current status
Atotech filed an application for authorization for inter alia decorative plating together with the members of CTACSub (Chromium Trioxide Authorization Consortium for Submission) Submission was done in May 2015, ECHA confirmed conformity and receipt The consortium is the successor of CTAC Managed by Jones Day Consultancy support by Ramboll-Environ Expected review period for the authorization: 7 years The review period starts with the sunset date The public consultation ended on October 7, and was re-started Nov. 11 until January 7, 2016 for 3 applications The next steps will not be visible to the public The decision by the EU Commission is expected at the very earliest end of 2015, more likely by mid of 2016 W. Richtering – CASF, Vaughan, Canada – 18/11/2015

EACH authorization Chromium Trioxide ... Latest update
W. Richtering – CASF, Vaughan, Canada – 18/11/2015

REACH authorization Chromium Trioxide Current status & recent developments [2014]
ACEA (European car manufacturer association) has finally taken a position: they are asking for a more time (9-12 years) to use CrO3 for the authorized applications in order to substitute Cr(VI) by other alternatives They support the substitution! EU authority expert groups proposed a duration for the authorization of another Annex XIV-substance of 7 years We expect something similar for Cr(VI) ECHA expectation is this 7 year period has to be used to for the phase-out of Cr(VI) W. Richtering – CASF, Vaughan, Canada – 18/11/2015

REACH authorization Chromium Trioxide Current status & recent developments [2014]
2nd independent consortium VECCO is active Consists of appr. 185 SME’s from the European surface finishing industry with a majority share from Germany (28 from Italy) VECCO started a lawsuit against EU Commission First hearing in German administrative court on Hearing at European Court of Justice in early 2015 Based on doubt for correct methodology to obtain exposure data and hazardousness of chromic acid in plating operations It is the aim of the lawsuit to get exemptions from authorization for plating applications A decision can be expected in late 2015: The case was dismissed on Sept. 25, 2015 *VECCO = Verein zur Wahrung von Einsatz und Nutzung von Chromtrioxid und anderen Chrom-(VI)-Verbindungen in der Oberflächentechnik (Association for the protection of the use of CrO3 and other Cr(VI)-compounds in surface finishing) W. Richtering – CASF, Vaughan, Canada – 18/11/2015

Questions on Cr(VI) authorization procedure
Does Atotech apply for authorization? Yes, application is already filed, decision outstanding. W. Richtering – CASF, Vaughan, Canada – 18/11/2015

Does Atotech apply for authorization? Yes, application is already filed, decision outstanding. Atotech has applied for authorization for all uses of CTAC Formulation decorative and functional plating aerospace and aeronautics corrosion resistant coatings passivation of tin plated steel Next steps Public consultation started Aug. 12 and ended on Oct. 7, 2015 NGOs as well as suppliers of alternatives will challenge the application Decision on authorization is expected not before beginning of 2016, more likely around mid of 2016 Use CTAC Proposed review period Formulation of mixtures 12 years+ Functional chrome plating 12 years Decorative chrome plating 7 years Aerospace Corrosion resistant coatings Passivation of tin-plated steel (ETP) 4 years (bridging) NGO – Non Government Organization CTAC = Chromium Trioxide Authorization Consortium W. Richtering – CASF, Vaughan, Canada – 18/11/2015

Atotech is frequently updating customer information letters – latest version August 19, 2015: W. Richtering – CASF, Vaughan, Canada – 18/11/2015

Does Atotech apply for authorization? Yes, application is already filed, decision outstanding. Should my company apply for authorization? This depends on the company‘s strategy and whether the use is a „standard“ plating application. Non-standard applications might not be included in Atotech’s application for authorization Further information  customer information letter W. Richtering – CASF, Vaughan, Canada – 18/11/2015

Does Atotech apply for authorization? Yes, application is already filed, decision outstanding. Should my company apply for authorization? This depends on the company‘s strategy and whether the use is a „standard“ plating application. Non-standard applications might not be included in Atotech’s application for authorization Further information  customer information letter Will I get the same problems with trivalent chrome in future? No, trivalent chromium compounds do not fulfil the criteria of SVHCs. Trivalent chromium compounds are produced out of chromium trioxide, but this is out of the scope of authorization. *SVHC: Substance of Very High Concern W. Richtering – CASF, Vaughan, Canada – 18/11/2015

Atotech strategy on Cr(VI) Summary
Our first priority is the development of Cr(VI)-free alternative processes for all plating applications In parallel Atotech actively supports the authorization process to secure a sustainable business environment for our customers and end-users until Cr(VI)-alternatives have been qualified W. Richtering – CASF, Vaughan, Canada – 18/11/2015

Borates

Boric acid and sodium tetraborate proposed for authorization
Boric acid and sodium tetraborate were proposed by ECHA for inclusion in Annex XIV, meaning authorization The EU Member States confirmed this approach Currently the decision is in the hands of the EU Commission The industry is currently trying to convince the EU Commission that restriction is the better approach- the outcome is open to date Besides the plating sector, dozens of other industry sectors would be affected by the authorization requirement W. Richtering – CASF, Vaughan, Canada – 18/11/2015

Cobalt

Five Cobalt Salts Proposed for Restriction
Cobaltdichloride, -carbonate, -acetate, -nitrate and -sulfate The cobalt salts are proposed for restriction instead of authorization Under authorization the industry needs to apply for an authorization, prepares a dossier showing the case (industry takes the lead) Under restriction the authorities prepare a dossier that shows why the substance is dangerous and needs to be restricted (authorities take the lead) A cobalt salts restriction might look like Annex II of ELV W. Richtering – CASF, Vaughan, Canada – 18/11/2015

Cobalt Salts Restriction Case in Detail
Restriction instead of authorization proposed Surface treatment is one of the applications of concern In contrary to authorization, authorities take the lead The industry has 6 months for „official input“ The industry has to make authorities aware of substance applications For the cobal salts a decision by EU authorities should already have been taken in 2015 It is not clear why the decision is not yet made- no transparency Rumors say that a decision will be made mid 2016, however the direction of the decision is absolutely unclear W. Richtering – CASF, Vaughan, Canada – 18/11/2015

NPE (Nonylphenolethoxylates)

NPE under REACh News from EU Commission's meeting end of October 2015:
This means that NPE is almost under authorization (law could be issued in Q1 2016). Based on the draft of Annex XIV this would result in a sunset date in Q3/Q4 2019, meaning no usage after that date without authorization. For China: NPE falls under a specific regulation, the Decree 591. This implies that specific import and usage permits are required for NPE. W. Richtering – CASF, Vaughan, Canada – 18/11/2015

Other potential SVHCs Nickel compounds
Today no nickel compound is on the SVHC candidate list In 2015 EU member states may decide on listing nickel compounds (e.g. nickel sulfate) as SVHC* candidates  more in the following talk...... *SVHC: Substance of Very High Concern W. Richtering – CASF, Vaughan, Canada – 18/11/2015

Chemical Legislation outside Europe
K(orea)-REACh came into force 01 Jan 2015 Atotech is in compliance with K-REACH despite a lot of minor and major issues of the law The first list of ~500 substances to be registered until 2018 is available Mainly high volume and highly toxic substances First list of SVHCs still to come Taiwan-REACh The toxical substance control law is giving the outline of substance registration in Taiwan Update came into effect on 11 December 2014 New substance registration already started Start of implementation with pre-registrations (similar to EU-REACh) Authorities will decide on registration based on volumes, hazard criteria, etc. W. Richtering – CASF, Vaughan, Canada – 18/11/2015

CORAP: COmmunity Rolling Action Plan (update 28. Oct. 2015
Summary Today, CrO3 is 1 of 31 substances on Annex XIV, i.e. subject to authorization 2015 CORAP update draft proposes 138 substances for evaluation in 2013 CORAP update draft proposes 125 substances for evaluation in Atotech No. 1 priority is the development of Cr(VI-free processes for pretreatment and plating Atotech actively supports CTAC for Cr(VI) authorization of decorative and functional applications during transition to Cr(VI)-free Number of specific substance restrictions in China increased from 3800 in 2002 to > 5000 in 2015 EU Goal: > 450 SVHCs reviewed by 2020 Decision onBorate authorization expected in 2015 Sunset date for non-authorized intended uses of CrO3 is 21. Sept. 2017 CORAP: COmmunity Rolling Action Plan (update 28. Oct. 2015

Summary Atotech continues to develop sustainable technologies and processes replacing SVHC 2015 CORAP update draft proposes 138 substances for evaluation in Today, CrO3 is 1 of 31 substances on Annex XIV, i.e. subject to authorization Atotech No. 1 priority is the development of Cr(VI-free processes for pretreatment and plating Atotech actively supports CTAC for Cr(VI) authorization of decorative and functional applications during transition to Cr(VI)-free Number of specific substance restrictions in China increased from 3800 in 2002 to > 5000 in 2015 Sunset date for non-authorized intended uses of CrO3 is 21. Sept. 2017 EU Goal: > 450 SVHCs reviewed by 2020 Decision onBorate authorization expected in 2015 CORAP: COmmunity Rolling Action Plan (update 28. Oct. 2015

Summary 2013 CORAP update draft proposes 125 substances for evaluation in Today, CrO3 is 1 of 31 substances on Annex XIV, i.e. subject to authorization 2015 CORAP update draft proposes 138 substances for evaluation in Atotech No. 1 priority is the development of Cr(VI-free processes for pretreatment and plating Atotech actively supports CTAC for Cr(VI) authorization of decorative and functional applications during transition to Cr(VI)-free Number of specific substance restrictions in China increased from 3800 in 2002 to > 5000 in 2015 EU Goal: > 450 SVHCs reviewed by 2020 Decision onBorate authorization expected in 2015 Sunset date for non-authorized intended uses of CrO3 is 21. Sept. 2017 CORAP: COmmunity Rolling Action Plan (update 28. Oct. 2015

Thank you for your attention!

Back Up

REACH – Authorization Authorization serves to control the use of substances of very high concern (SVHC) CMR substances category 1 and 2 Persistent, bioaccumulative and toxic substances (PBT) Very persistent and very bioaccumulative substances (vPvB) Substances with endocrine disrupting properties Under REACH any use of a substance of very high concern that is not authorized is prohibited Substances are proposed by EU Member States to be included in the candidate list Proposals for SVHC Candidate List Priority List Reach Annex XIV W. Richtering – CASF, Vaughan, Canada – 18/11/2015

REACH – SVHC Consequence of Candidate List Consequence of Annex XIV
Suppliers of substances and preparations have to provide a MSDS specifying these substances >0.1%  Fulfilled for all ATOTECH MSDS Producers or importers of articles have to notify ECHA and the consumer if their article contains a substance of the candidate list >0.1 %  Not relevant for ATOTECH because SVHC are not present in the final surface Consequence of Annex XIV Placing on the market will be prohibited from a sunset date defined for each substance unless an authorization is granted by ECHA Proposals for SVHC Candidate List Priority List Reach Annex XIV A priority list of substances has been published which may subsequently become subject to authorization (Annex XIV). Authorization will be required for each use of such a substance. Authorization will be granted, if the applicant can demonstrate, that the risk to the health or the environment from the use of the substance is adequately controlled or the socio-economic benefits outweigh the risks. Restrictions may apply when the risk to the health or the environment is unacceptable. If a suitable alternative is available, a substitution plan has to be submitted. W. Richtering – CASF, Vaughan, Canada – 18/11/2015

CASF conference, Vaughan, Canada 18 November 2015

Similar presentations

Presentation on theme: "CASF conference, Vaughan, Canada 18 November 2015"— Presentation transcript:

Similar presentations

About project

Feedback

Log in

Auth with social network:

CASF conference, Vaughan, Canada 18 November 2015

Similar presentations

Presentation on theme: "CASF conference, Vaughan, Canada 18 November 2015"— Presentation transcript:

Similar presentations

About project

Feedback