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REACH, RoHS and Chromates

We have carried out a detailed analyses of its impact on the Aerospace & Defense industry, and we are assisting a number of multinational companies with eliminating chromates and other REACH and RoHS-impacted materials from the product line.

  • The European RoHS regulations (Restriction of Hazardous Substances) were introduced in January 2003.  Under these regulations electrical equipment containing more than 0.1% of Pb, Cd, or Cr6+, or more than 0.01% Cd cannot be sold in Europe.
  • The European REACH regulations (Registration, Evaluation, Authorization, and restriction of CHemicals) were put into force in 2007 and Preregistration of chemicals in Europe began in June 2008.  The aim of REACH is to eliminate from the market SVHCs (Substances of Very High Concern), the list of which is continuously growing.
  • February 2008, we released our first REACH report “Potential Impact of European REACH Regulations DoD and Military Equipment Manufacturers and Suppliers“ Ralph Alexander and Keith Legg.
  • Keith Legg provided his expertise to the DoD REACH Working Group, helping to improve DoD’s understanding of how REACH affects military equipment.
  • December 2015, we released “Impact of European Reach Regulations on DoD and Military Equipment Manufacturers and Suppliers, Version 7[KL1] ” Keith Legg and Ralph Alexander.

Initially many manufacturers thought that REACH would not be a serious issue for them because it affected primarily chemicals, and did not cover end products (Articles in REACH-speak), which are explicitly excluded from the regulation.  Besides, they thought of it as a competitive issue for European companies – a European producer would not be able to use chromated zinc in Europe, but the same product could be manufactured elsewhere and sold in Europe no matter how much cadmium, chromate, or other toxic material it contained.  That is true in principle, but manufacturers have quickly found that all it takes is to add an electrical control or sensor to a product to change it from a product can be sold in Europe into electronic equipment subject to RoHS, which cannot be sold in Europe at all.  They have also come under a great deal of pressure from the customers to eliminate these materials because of regulatory and legal risks.

As a result of all this, the costs of these regulations are enormous, not only for European companies, but for companies across the world who must find alternatives for any product sold in Europe (and increasingly elsewhere in the world) without reducing performance.  And when those alternatives are classified as SVHCs (which under Legg’s Law they probably will be), they will have to be replaced again.

Corrdesa works with companies to identify where they are risk, suggest alternatives, and ensure that those alternatives will not rapidly become SVHCs themselves, requiring them to be replaced in short order.