RoHS Compliance

The following treatments are RoHS compliant:

The following treatments are not RoHS compliant or may not be RoHS compliant:

REACh Compliance

As part of its surface treatments process, Metal Finishings Ltd use some chemicals that are considered SVHCs under the EU REACH Directive. This page seeks to provide information about which processes use SVHCs and which treatments contain SVHCs in their final form. This article is published for the information of our customers and to satisfy our duties under article 33 of the directive.

This information is based on the SVHC list released on 18/12/2015, gives regard to the judgement in Case C-106/14 at the Court of Justice of the European Union and is based on the ECHA’s Guidance on Requirements for Substances in Articles (version 3.0, published December 2015).

Metal Finishings Ltd is not in a position to determine whether an article is REACH compliant or not. An engineered component is an article before it reaches us and an article when we have coated it. The coating itself is not an article, but a transformation process. Surface treatments are classed as light processing under the ECHA guidance. Nonetheless, our coating may have an impact on the REACH status of the article as a whole and this information seeks to provide you with information to make your own determination on a part by part basis.

SVHCs

SVHCs that are used in our production process are limited to chromium (VI) compounds, which we have sought to list below. As chemists will understand chromic acid, chromates and dichromates are in equilibrium with each other, so it is impossible to say with certainty what form they take when incorporated into the coating:

The following treatments use SVHCs in the production process:

The following treatments do not use SVHCs in the production process (or it is optional):

The following treatments contain or may contain SVHCs in the final coating:

While stainless steel passivation may use SVHCs in the production process, with proper rinsing it is unlikely to be in the end product.

When the base material is porous (such as some castings) or there is another entrapment risk, there is a possibility that chromium (VI) compounds may be present in the article beyond the coating from the production process. This may significantly increase the amount of SVHCs in the article.

However, as the mass of the article is usually much greater than the part as a whole, it is likely that this alone would bring the percentage below the 0.1% threshold for the majority of parts that we process. If customers can supply Metal Finishings Ltd with the total mass of the part and its surface area, we can estimate the maximum mass of SVHC contributed by our processing.

It is our view that no non-exposure argument can be made for SVHCs in our coatings because of the mobility of the chromates in the presence of moisture.

Sunset Dates

If SVHCs are not authorised before their sunset date (and no applications are still being processed under the transitional agreements), then the substances will cease to be available. Within our supply chain, applications have been made for authorisation, but at this stage it is not clear whether they will be successful and what additional restrictions are likely to be applied to their use. Our advice to customers is that they should work with us to design SVHCs out of their parts and their production processes under the assumption that their specific use may not be authorised. It is likely that we will not know more until very close to or even after the sunset date, hence our recommendation for this defensive approach.

The current sunset date for chromic acid/chromium trioxide and sodium dichromate is 21/09/2017. The current sunset date for pentazinc chromate octahydroxide and strontium chromate is 22/01/2019.

Alternative Treatments

For all of our treatments, there are alternatives available that do not use SVHCs in the production process and that do not leave SVHCs in the article after processing. These are suitable for a large number of applications and there are very few applications where these are unsuitable for technical reasons.

Case C-106/14

The ECJ ruled that components that form a larger article can be articles in themselves. However, our interpretation of this is that because the coatings cannot exist without an article to coat, it is impossible for them to be an article on their own (they are merely a substance or a mixture) and they become part of the article itself when processed.

Brexit Impact

The impact of "Brexit" on REACh in the UK is currently unknown. REACh currently applies to the EEA as well as the EU, so depending on the UK's final relationship with the EU, there is a good chance that it will continue to apply in part or in full. Considering the respective timelines of both REACh and Britain leaving the EU, it is likely that the impact of REACh will be felt before Brexit anyway.

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