Surface technology has always been a key focus of chemical regulation. The EU is currently introducing two comprehensive and groundbreaking regulations: The restriction on Cr(VI) and the restriction PFAS.

Our industry is affected by these in many areas, and in the coming weeks one political meeting follows another. This is precisely our task at present. And we are delighted to be pursuing this path together with the ZVO, the AOT and the Austrian Federal Guild of Metal Technicians.

Last week we had a meeting with the German Federal Ministry on the subject of PFAS. I was particularly surprised by the detailed knowledge of our discussion partners. No half-baked knowledge, no vague wording – instead, clear statements that advocate would support the interests of surface technology within the EU Commission to the best of their ability.

There was one point, however, that surprised me:

They openly admitted that the interactions between the PFAS and Cr(VI) restrictions may not have been sufficiently taken into account at all stages of the political decision-making process.

We were thus able to report that PFAS-free wetting agent alternatives still have limitations regarding the reduction of Cr(VI) aerosols and exhibit a significantly shorter service life. As the current draft, for example, does not provide for any derogations for decorative applications on metal, whilst at the same time drastically lowering the scientific exposure limits in the other restriction, an entire application use segment, together with its downstream supply chains, is coming under pressure.

The current discussion on the future scientific exposure limits for Cr(VI) is based on the existing values from authorisations and the ‘Call for Evidence’. To verify their plausibility, these values were compared with data from the CTACSub-2 consortium. All these measured values were almost certainly obtained using PFAS-containing wetting agents – i.e. with a technology that is unlikely to be available in future, at least in some uses, if the ECHA committees’ draft is to be believed.

At the same time, the RAC is proposing a drastic reduction in the occupational exposure limit as part of the Cr(VI) restriction.

Incidentally, this also has significant implications for the environment. Some members, who for years had well use below the TA-Luft guidelines, are suddenly struggling with exceedances of the limit values.

Among the materials to be banned under the PFAS restriction, PVDF is of fundamental importance for electroplating.

Is it even possible to imagine a world without PVDF here?

Proposed alternatives such as PEEK or ceramics must be examined. Equally crucial for plant engineering is the question of whether, for example, a PVDF liner for a hard chrome bath is classified under Sector 4 or Sector 17.

The differing legal consequences are dramatic.

At least we learnt in our discussion with the Ministry that existing plants are not in the scope of the restriction.

For all these reasons, it is important that you take part in the public consultation on PFAS.

“You have your say”, as the saying in english goes.

That is actually a good approach.

Why comments are then limited to 5,000 characters – even though there is so much to say – is another matter.

Matthias Enseling

Vecco