SVHC

Plating processes use a wide variety of substances, some of which have already been classified as SVHCs (Substances of Very High Concern) and many more that meet the criteria set out in Article 57 and will probably, at some point in the future, be classified as SVHCs. REACH Article 33 (1) requires manufacturers and distributors who supply an article which contains more than 0.1% weight by weight (w/w) of any Candidate List Substance of Very High Concern (SVHC) to provide their industrial customers with sufficient information. The Ronuk group is a supplier of preparations. Therefore, there is strictly speaking no duty of notification according to Article 33 for us. Nonetheless, we regard it as important to inform our customers on the use of SVHCs in our additives. We generally include a note on the classification of substances as SVHC in paragraph 15 of our Material Safety Data Sheets. We are aware of our duties under REACH and we will continue to monitor the SVHC situation via the European Chemicals Agency (ECHA) website and will proactively notify you should the situation arise where any article processed by us contain SVHCs above the stated threshold. The development of new alternative processes which allows us to replace SVHCs with less hazardous substances will remain one of  the key objectives of our R&D department. The authorisation process for substances which have been included to the candidate list by the European Chemicals Agency (ECHA) consists of several steps. In the outcome of this process, it will be determined whether a given substance will be subject to authorisation, which uses of the included substances will not need authorisation and the “sunset date” by when a substance can no more be used without authorisation. To date following substances currently used in Ronuk additives have been included to the candidate list. However, it is extremely unlikely that any of these SVHCs will be present on he finished component in a concentration above 0.1% on a weight for weight basis. The reason for this statement is explained below.

listed as SVHC candidate since 18.06.2010 Boric acid is used as a buffer substance in nickel electrolytes, weakly acidic zinc electrolytes and chrome electrolytes based on chromium(III) compounds. The concentration of boric acid in the electrolyte is below 5.5 % weight by weight and therefore does not reach the limit value according to Directive 1272/2008/EC (GHS), Annex VI, Table 3.2. There is no co-deposition of boric acid in the electrodeposited layer, and so there is no duty of notification according to Article 33 of Directive 1907/2006/EC (REACH).

listed as SVHC-candidate since 18.06.2012 Lead(II) bis(methanesulfonate) is used in Ronuk tin-lead electrolytes. However, there is no deposition of lead(II) bis(methanesulfonate) in the electrodeposited alloy layer, and so there is no duty of notification according to Article 33 of Directive 1907/2006/EC (REACH).

listed as SVHC candidates since 15.12.2010 Chromic acid, dichromic acid and chromium trioxide can be considered together. Both chromic acid and dichromic acid do not exist as pure substances. Both substances are formed when chromium trioxide is diluted in water. Chromium trioxide (chromic acid, dichromic acid) is used in chrome electrolytes based on chromium(VI) compounds. The electrodeposited layer consists of metallic chromium, there is no co-deposition of Cr(VI). Therefore, there is no duty of notification according to Article 33 of Directive 1907/2006/EC (REACH). Chromium trioxide (chromic acid, dichromic acid) is also used for the manufacture of chromating solutions. The addition of potassium hydroxide or sodium hydroxide leads to a partial neutralization of the solution, during which sodium chromate and potassium chromate are formed. 20 December 2011– ECHA recommendation  ECHA has submitted to the European Commission a recommendation to include chromic acid, dichromic acid and chromium trioxide in the Authorisation List (Annex XIV). According to ECHA’s planning, the European Commission should enter these substances into Annex XIV by February 2013.

listed as SVHC candidates since 18.06.2010 / 18.06.2010 / 15.12.2010 Potassium dichromate, sodium chromate and sodium dichromate can be considered together. In the solution there is a balance between chromates and dichromates depending on the pH value. The potassium or sodium ions are not relevant to the safety assessment of these substances. Chromates are used for chromating solutions. They react with the zinc or zinc alloy surface and form conversion layers. The initial compounds are not deposited in the layer. However, chromate layers contain small amounts of chromium(VI) compounds. According to IMDS Data Entry 899343, the value of Cr(VI) reaches 10.6% by weight in yellow chromate layers with a weight of 0.9 g/m². The value of 0.1% by weight of SVHC refers to the total value of a manufactured item. The chromate layer makes up only a small part of the total weight; thus the limit value of 0.1% by weight is not reached. Therefore, there is no duty of notification according to Article 33 of Directive 1907/2006/EC (REACH). Sodium dichromate, sodium chromate and potassium dichromate have only been registered as intermediate substances in REACH by the manufacturers and importers. They are no longer available for the manufacture of chromating concentrates. All chromating processes, containing sodium dichromate, sodium chromate or potassium dichromate have been withdrawn from our sales programme in March 2011 and been replaced with alternative products. Chromium trioxide has been registered by the manufacturers or importers and can be used for the make-up of chromating processes. Adjusting the pH value with sodium hydroxide or potassium hydroxide solution generates the same chemical compounds as in make-ups with the stated chromates. There is no duty of notification according to Article 33 of Directive 1907/2006/EC (REACH).

listed as SVHC candidate since 15.12.2010 Cobalt sulphate is used in passivating processes based on Cr(III) to improve the corrosion resistance of the layers. Cobalt sulphate is not integrated into the passivation layer. During the conversion reaction, it is transformed into hydroxide compounds. Therefore, there is no duty of notification according to Article 33 of Directive 1907/2006/EC (REACH). 20 December 2011– ECHA recommendation  ECHA has submitted to the European Commission a recommendation to include cobalt sulphate in the Authorisation List (Annex XIV). According to ECHA’s planning, the European Commission should enter cobalt sulphate into Annex XIV by February 2013.

listed as SVHC candidate since 18.06.2010 Disodium tetraborate is used in alkaline degreasers in order to strengthen their cleaning power. The degreaser solution will be rinsed off completely, leaving no residues of disodium tetraborate on the manufactured item. Therefore, there is no duty of notification according to Article 33 of Directive 1907/2006/EC (REACH).

listed as SVHC candidate since 19.12.2011 Phenolphthalein is mainly used as laboratory agent (in pH indicator solutions), eg. for the alkalimetric titration of degreasers. Phenolphthalein is not contained in Ronuk additives. Therefore, there is no duty of notification according to Article 33 of Directive 1907/2006/EC (REACH).

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