The Drive to Develop Innovative Products: the Case of Cobalt-Free Passivation
Since the dawn of the REACH Regulation, its primary objective has been to increase control over the use of chemicals in the European market and secondarily, with the aid of technology and time, to gradually replace substances that may be harmful to human health and the environment, thus protecting both end-users and operators in the waste management field.
Under the REACH regulation, these objectives are pursued by including these substances of concern in the SVHC list, among which we find, for example, cobalt nitrate, cobalt sulphate and cobalt carbonate. From the moment a substance is placed under the magnifying glass by the European Chemicals Agency (ECHA), although its use may still be permitted, users of that substance should be aware of the need to explore alternatives, in the event of a future prohibition of use.
The state of a SVHC substance could therefore be defined as a limbo, where substances of particular concern for human health or the environment await a decision regarding their possible use or prohibition. Whatever the verdict, as these substances have been identified as potentially harmful, a set of norms for controlling their use throughout their entire life cycle (including the final phase, where they become waste) has been deemed necessary.
And this is where the SCIP ("Substances of Concern In articles as such or in complex Products") database comes into play, providing a unique source of information about substances of concern in articles or complex objects, established to comply with the Directive on waste (WFD - Waste Framework Directive).
The SCIP database, therefore, aims to increase the knowledge of chemicals from the SVHC list that may be found in articles and products along the entire production chain, until they become waste.
In light of this complex and constantly evolving regulatory context, Technic’s goal is to be proactive by creating a new generation of specialty chemicals that offer excellent performance, while improving the sustainability of electroplating processes and eliminating issues related to SCIP notifications and the use of SVHC substances, to save time and resources.
For example, as mentioned above, cobalt salts are included in the SVHC list. These substances are typically found in post-treatments such as passivation, which are utilized to improve the properties of the deposit and enhance corrosion resistance. Technic provides several types of cobalt-free passivation, such as Wonder TR 36, a blue passivation for acid and alkaline zinc with good tolerance to iron contamination. Wonder CF 150, on the other hand, provides an iridescent color on alkaline and acid zinc deposits. If a passivation process providing a transparent finish is required, Wonder Clear 74 is suitable for both rack and barrel zinc/ nickel applications. Finally, Wonder CFY 1 is a blue passivation for acid and alkaline zinc, completely free of both hexavalent chromium and cobalt, which provides excellent corrosion resistance.
Going back to the SCIP regulation, some of its main objectives are:
- Reduce the generation of waste containing dangerous substances, aiming to replace them with non-dangerous ones
- Encourage the replacement of these substances with safer alternatives
- Make information available to support waste treatment operations
- Monitor the use of SVHC substances in articles and initiate appropriate actions during the disposal of these articles
Before going into more detail about this new regulation, it is useful to explain what is identified as an 'ARTICLE':
"An article is an object that is given a particular shape, surface or design during production, which determines its function to a greater extent than its chemical composition."
Let’s analyze the meaning of some of these terms:
- Shape: refers to the three-dimensionality of the object, i.e. its depth, width, and height.
- Surface: the outermost layer of the object.
- Design: the arrangement of the design elements used to achieve a specific purpose in the best possible way.
Shape, surface, or design must be more important than the chemical composition in determining the function of the Article.
The term "function" in the definition of an article must be interpreted in the sense of the basic principle that determines the use of the object, not the level of technical sophistication that determines the quality of the result.
An Article can be "simple", i.e. meant for direct use, or assembled in a "complex article" consisting of several Articles. Taking a car as an example, we could define the tire as a simple article, the seat as a complex article, and the car in all its parts as a very complex article.
The 2018/851 Directive (EU) states that starting from January 5th 2021, all companies that supply articles containing SVHC substances on the Candidate list in a concentration higher than 0.1% w/w must provide information on these articles to ECHA. By facilitating access to information, the SCIP database aims to support informed purchasing decisions by consumers as well as recovery activities.
As mentioned above, the obligation to submit a SCIP notification concerns all articles on the EU market which contain a substance of very high concern on the Candidate List in a concentration above 0.1% w/w and applies to:
- EU manufacturers and assemblers
- Importers from the EU
- EU distributors of articles and other players in the supply chain who market these articles
Retailers and other players in the supply chain who directly and exclusively supply items to consumers are exempted from the obligation to submit information to the SCIP database.
Article suppliers must provide ECHA with the following technical information:
- The Article’s unique identifier (primary article ID)
- Instructions for safe use (toxicological and eco-toxicological information)
- Which SVHC is included and in what concentration range
- The category of material of which the Article is made (material category / TARIC CODE)
- The category of mixture containing the substance of concern (EuPCS)
The information transmitted to the SCIP database will be publicly accessible and therefore readily available to waste operators, with a view to filling current gaps in the flow of information. ECHA will publish the information as received on its website, however, the quality of the data relies on the responsibility of each entity involved. At the same time, ECHA will ensure the confidentiality of sensitive business information, where justified.
The information-gathering process can be extremely complex, especially taking into account that often players in the supply chain utilize an Article from an upstream supplier and thus do not have the complete picture of the Article’s chemical composition.
Furthermore, it is necessary to specify that in most electroplating treatments, the substances used during the processes are not the same as those found in the finished article. In processes that involve the use of SVHC substances, such as cobalt salts, the final deposit is mainly made of cobalt metal, which is not listed on the SVHC list. In this case, therefore, the problem may arise if some traces of cobalt salts remained on the deposited layer.
Given the complexity of this matter and the substantial amount of work that a notification to the SCIP database would require, Technic is constantly engaging in R&D activities to provide alternatives to the use of SVHC substances, since the absence of such substances in the electroplating processes used to treat the 'articles' would exclude the need for further investigations on the possible presence of the same substances on the finished products.
In addition to the solutions previously highlighted in this article, Technic also offers other types of passivation for alkaline, acid, and zinc alloys in a variety of colors, depending on the level of corrosion resistance required. Our R&D team will be happy to guide you in selecting or developing the most suitable post-treatment for your specific application.
ECHA – European Chemical Agency (https://echa.europa.eu/authorisation-process)
REACH Helpdesk https://reach.mise.gov.it/
Author: Tiziano Laficara, Health and Safety Officer at Technic Italgalvano
About Technic Italgalvano
Technic Italgalvano supplies surface finishing process chemistry for industrial, functional and decorative applications. Our markets include Electronics, Aerospace, Solar, Automotive, Fashion, Furnishings and Decorative applications. Technic Italgalvano provides regional service and support to Europe, Russia and the Middle East. This ISO 9001:2015 facility offers sales and technical assistance for Technic products as well as equipment sales and service.