Authorisation for

Chromium Trioxide
Automotive Industry
Challenges
27 March 2014
Dr. Wolfgang Marquardt
BMW Group

REACH

The engine of Europe

ACEA represents the whole European auto industry
15 major international companies

An industry crucial for economy

16.2 million
vehicles
produced in
2012

Over 32 billion
in R&D spending,
largest private
investor

92 billion
of net trade
contribution

and employment
12.9 million direct and indirect jobs

385 billion
of tax revenues
(EU 14)

Topics
Introduction: Automotive Industry and REACH
Authorisation
Importance of CrO3 in the Automotive Industry
Strategic Aspects on Chrome plating from
2017 onwards
Summary
Recommendation: Strategic Aspects on Timing
and Submission

Actors in the Authorisation process?

Compliance is the main role of the Automotive

Industry in the Authorisation process (e.g. CrO3)

CrO3/Cr(VI) in cars?
End-of-Life Vehicles (ELV) Directive
(2000/53/EC)
Ban of Cr(VI) since 2003
No potential risk in passenger cars with Cr(VI)

However, repair-as-produced principle

Exemptions for materials and components
containing Cr(VI) - ELV Directive, Annex II
Only very specific applications
Only for spare parts for vehicles already put on the
market -> repair-as-produced principle

Importance of CrO3 in the Automotive

Industry?

Importance of chrome-plated parts

Use of chrome-plated parts :
CrO3 used in the supply-chain to manufacture Chromeplated parts
Different applications (hard chrome-plating, functional
chrome-plating with durable decorative character)
Different specifications for chrome-plated parts are
required e.g. for interior, exterior, specific parts: injector
valve, piston rod, safety belt lock
Estimate: On average 10,000 chrome-plated parts per car
manufacturer are in use

Example: Fuel-Injection-Technology
Current Product Situation
No alternatives for use of chromium
trioxide known, for comparable
function and life-endurance
No Cr(VI) in the end product
Current Situation on Worker Safety and Environment
Electro-plating sites with high standards
Skilled workers
Emission-free production
Conflict with European goal on CO2-Emissions
Hard-chrome plating is irreplaceable to meet current and
future CO2 emission
targets

Strategic Aspects
Mingle-Mangle from Supply chain
an unlimited authorisation for chromium
trioxide is guaranteed
we will not apply for authorisation because an
alternative is available for our specific use
we will relocate our production outside of
Europe
a technical alternative to chromium trioxide is
unknown
slowly, ECHA realises that they made a
mistake
What is fact, what is fiction?

Current Facts
In REACH Annex XIV since April 2013

Strategic Aspects
5 Ways to go?

Now

2017
2018

Strategic Aspects
5 Ways to go?
Change the law?

Now

2017
2018

Change the law?

Action: VECCO e.V. and Others v
Commission

Still other options than Annex XIV?

Chrome plating: main issue is workers safety
closed systems to guarantee workers safety?

Strategic Aspects
5 Ways to go?
Change the law?
Non-EU Production?

Now

2017
2018

Non-EU Production?
Relocation of production sites
outside the EU can be foreseen
Unproblematic under REACH because
imported chrome-plated parts without Cr(VI)
Critical for EU labour market (once dislocated
always dislocated)
Loss of competence in the EU
The automotive industry acts global, but
Additional logistics
Level of workers safety the same in other
countries?
Critical step from a sustainable perspective
An early authorisation would send a signal

Strategic Aspects
5 Ways to go?
Change the law?
Non-EU Production?

Now

On stock production?

2017
2018

On stock production?
Production of chrome plated parts on stock
before sunset date in 2017
High storage cost and low resource efficiency
Very limited (some models, some spare parts)
Only temporary
Not a solution for spare parts issue (>12
years spare part guarantee):
Unlike ELV and other directives, REACH does
not offer the repair-as-produced-principle
(yet)

Strategic Aspects
5 Ways to go?
Change the law?
Non-EU Production?

Now

On stock production?
Substitution?

2017
2018

Substitution?
Aim of REACH Annex XIV is Substitution
Where to start? Which parts?
Average of 500,000 parts to search
No search for CAS-No CrO3
Instead search via complex supply chain with
1,500 to 4,500 suppliers (Tier 1)

Substitution?

Find appropriate alternatives for different

specifications
4 different applications (CTAC) with up to 30 alternative
methods in literature (without prove on large scale production)

Many automotive requirements (~80)

E.g. Corrosion resistance:Exterior: with/without stone-chipping,
min. DIN EN ISO 9227 CASS 48h/80h, DIN EN ISO 9227 NSS
480h, PPV 4017 Var. 2, 2 cycles, VDA 233-102: 6 cycles.
Interior: min. DIN EN ISO 9227 CASS 24h, DIN EN ISO 9227
NSS 240h, substrate unchanged
Beside corrosion resistance: hardness, layer thickness,
adhesive strength, coefficient of friction, abrasion resistance
and, long-term-compliance of alternative..?

Substitution?

Additional tests and validation of

components required
Beside lab tests: summer and winter tests,
continuous-operation-tests and validation takes years
In addition: safety relevant parts such as piston rod
and safety belt lock

The automotive industry is continuously

testing new materials/components to
improve new car models, but testing and
validation takes several years

Substitution?

Alternative quantity production

After lab tests and years of validation to find suitable
alternatives for one or several of approx. 10,000 parts:
When are the alternative technologies available for
large-scale production?
Is enough capacity available in Europe to cover all
relevant parts of the more than 10 Million Cars/a
(and other industry sectors)?
Shouldnt we start introducing alternatives step
by step in new type-approved models (similar to
ELV)?

Result: Authorisation is essential!

Strategic Aspects
5 Ways to go?
Change the law?
Non-EU Production?

Now

On stock production?
Substitution?
Authorisation?

2017
2018

Authorisation?
The OEMs cannot apply for CrO3 authorisation
Dependent on authorisation submission by
supply chain
Expected authorisation dossiers with
automotive applications
CTAC Consortium
VECCO e.V.
Planning reliability crucial for strategy
Express request to consortia/applicants: early
submission
Express request to authorities: fast processing
Strategic decisions at OEMs required in 2014

Authorisation?
Authorisation crucial: sunset date vs life time
Example car model 1 (Start of Production
2018)
2013 to 2017 Sunset

> 5 years development

> 7 years production

> 12 years spare part guarantee

Type
approval
Period to introduce changes
> 24 years from concept to recycling

Use of Alternative only after validation and under large scale production

Authorisation?
Authorisation crucial: sunset date vs life time
Example car model 2 (Start of Production
2013)
2013 to 2017 Sunset

> 5 years development

> 7 years production

> 12 years spare part guarantee

Type
approval
Period to introduce changes
> 24 years from concept to recycling

Gain planning certainty with early authorisation and long review periods

Authorisation?
Authorisation crucial: sunset date vs life time
Example car model 3 (Start of Production
2003)
2013 to 2017 Sunset

> 5 years development

> 7 years production

> 12 years spare part guarantee

Type
approval
Period to introduce changes
> 24 years from concept to recycling

Repair as Produced Principle for Spare Parts required

Excursion: Existing EC Solutions:

Repair as Produced

Implementation of heavy metal restrictions of ELV

directive identified the need to address spare parts issues
repair as produced (COM decision 2005/438/EC from 10.06.2005).
As product reuse, refurbishment and extension of lifetime are beneficial, spare parts need
to be available for the repair of vehicles which were already put on the market on 1 July 03.
The use of lead, mercury, cadmium or hexavalent chromium in spare parts put on the
market after 1 July 2003 for the repair of such vehicles should thus be tolerated.

Another Example:
Recast of the Pyrotechnic articles directive (2013/29/EC) :
59) Pyrotechnic articles for vehicles are designed for vehicle life cycles and therefore
require special transitional arrangements. It is necessary for such a pyrotechnic article to
comply with the requirements of the law applicable at the time it is first made available on
the market and for the period of the lifetime of the vehicle in which it is installed.

Repair as Produced Principle for Spare Parts urgently

required under REACH (in the meantime authorisation)

ECHA, 13 September 2013

Strategic Aspects
5 Ways to go?
Change the law?
Non-EU Production?

Now

On stock production?
Substitution?
Authorisation?

2017
2018

Summary
Authorisation is essential
Planning reliability increases by an early
authorisation
Long lead time for substitution and required
large scale production and available
capacities in Europe for all OEMs asks for
long review periods
Substitution of CrO3
Aim should be use of sustainable products
that are environmentally safe and will not
become the next SVHC-Generation
The automotive life-time and complexity
requires appropriate time for substitution

Recommendation: Strategic Aspects on

Timing and Submission
For the applicants
Submit as early as possible, planning certainty is
key for your downstream, decisions made now
Submission in 2014 is a realistic scenario,
otherwise, your market might be gone
somewhere else (avoid shift to non-EU)
Reflect market specifics in the review periods,
less than 7 years seems unrealistic
Dont forget the spare part market, 12 years+
For the authorities
Send a signal by fast processing of the
application and an early decision
Help to keep the competence in technology and
the labour market in Europe by rational decisions

The Automotive Industry Guideline on REACH

(AIG V3.1)

The Automotive Industry has

developed a REACH Guideline
especially for (automotive) EndUsers
>10,000 Downloads since 2008

Free Download of Version 3.1 under:

http://www.acea.be/reach/
Available languages (Released: 05/12)

English
German
Chinese
Japanese
French
Korean

Thank you!

European Automobile Manufacturers Association

www.acea.be