Hatched in Europe, REACH Regulations Impact U.S. Auto Manufacturers

U.S. auto makers are not obligated to comply with REACH, but a gradual or phased-in global solution is a practical approach.

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The aim of REACH is well known, but its effect on automotive manufacturers with headquarters outside of Europe is less known. As U.S. companies scrutinize and study the response of the European-based OEMs, they are confronted with two questions: First, are U.S.-based OEMs required to conform to REACH? Second, how can U.S.-based OEMs be ready if future U.S. legislation or the EPA dictates a similar regulation? All major automotive OEMs view their business as global, and will likely seek a global solution. A few technical options have been offered to the OEMs as alternatives to decorative hexavalent chrome. But the emergence of decorative trivalent chrome with chrome-free post treatment is gaining wide acceptance. This technology is a practical consideration when addressing industry concerns in response to REACH.

Overview and Key points of REACH

Automotive manufacturers and their suppliers are well acquainted with the European Union’s REACH regulation. Its primary objective is the protection of human health and the environment from the risks that can be posed by chemicals. The burden of proof regarding a particular substance’s risk is on the companies, which may include the chemical manufacturer, an importer of chemicals or mixtures of chemicals, or a downstream user.

Specific to automotive manufacturers and their suppliers of electroplated products, alternatives to the banned hazardous substance must be employed in the future according to the regulation’s enforcement date. Particularly in the case of decorative hexavalent chrome, there is clearly an industry movement to identify viable replacement options. Among the choices are paint or a tinted clearcoat, PVD, or trivalent chrome. The latter approach is favored by most automotive OEMs and their suppliers.

Challenges for U.S. Automotive Manufacturers

For clarity, reference to U.S. automotive manufacturers includes Ford, General Motors, and Fiat Chrysler Automobiles’ Chrysler Group. Since these companies are established outside of the EU, they are not bound by the REACH regulation even though they export to Europe. However, all have a manufacturing footprint in the EU. Consequently one of the early challenges for the OEMs is to address the replacement of decorative hexavalent chrome regionally or globally. A global solution is the common response since all utilize suppliers from different geographical regions across the globe. But is this achievable?

Other considerations include:

  • Development of new materials and performance specifications and standards
  • Identification of capable supply base for the hexavalent chrome alternative
  • Cost impact per vehicle
  • Transition from decorative hexavalent chrome to its replacement

While these concerns and others are addressed in the U.S., a leading question is “How are the European OEMs responding to REACH on this matter?”

U.S. Automotive Manufacturers Study EU Response

Most European OEMs and their suppliers began investigating substitutions to decorative hexavalent chrome prior to 2010, when chromium trioxide was added to the candidate list of Substance of Very High Concern (SVHC). In 2012, the FGK (Association of Electroplated Plastics) organized an extensive evaluation that scrutinized the physical properties—and performance—of decorative trivalent chrome systems. To eliminate any bias, standard molded ABS specimens, as shown in Figure 1, were used by all of the participating companies.

 

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Figure: 1:   FGK Standard Test Part

 

Typical laboratory CASS and NSS performance of decorative hexavalent chrome-free finishes were conducted and are given in Figure 2 and Figure 3. The totally chrome-free post treatments were shown to improve performance of decorative trivalent chrome finishes to a point where functionality was comparable to decorative hexavalent chrome.

 

 Chrome (VI)-Free Post Treatment - Effect on CASS Performance

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Figure 2:  Comparison of CASS Performance for Hexavalent Chrome and TRILYTE Trivalent Chrome with Chrome (VI)-free Post Treatment

 

Chrome (VI)-Free Post Treatment Effect on NSS Performance

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Figure 3:  Comparison of NSS Performance for Hexavalent Chrome and TRILYTE Trivalent Chrome  with Chrome (VI)-free Post Treatment

 

Additional tests addressed chemical contact and chemical resistance of the decorative trivalent chrome finish. Hydrolysis resistance tests, cream resistance tests, and chemistry resistance tests were conducted by a major OEM and included surface care resistance tests undertaken by a second OEM. Evaluations consisted of exposure to window cleaner, stain remover, and plastic cleaner. The decorative trivalent chrome finish with the chrome-free post treatment passed both OEMs’ test requirements.

U.S. OEMs Add Trivalent Chromium to Materials Standards

Leading U.S. automotive OEMs have adopted decorative trivalent chrome as part of their standards. The inclusion of decorative trivalent chrome is for several reasons: First, to introduce a decorative dark metallic-like finish achievable only with trivalent chrome for styling and branding. Second, to offer an electroplated chrome alternative for vehicles designated for the Russian market in order to withstand specific corrosive environmental exposure. Third, to develop a light decorative trivalent chrome which mirrors the hue, brightness, and reflectance of traditional hexavalent chrome. The further benefit for these automotive manufacturers is laying the groundwork for a complete transition to trivalent chrome in the future.

Summary

U.S. automotive manufacturers are not obligated to comply with REACH, but because of their global business, a gradual or phased-in global solution is a practical approach. Whether driven by styling or harsh, regional corrosive field exposure, the totally hexavalent chrome-free decorative system would be the preferred replacement.

The execution of a massive changeover from a long standing or traditional surface finish is an exceptional challenge for the automotive industry. A deliberate, gradual transition is a reasonable strategy, particularly when OEMs are sourcing these finishes from suppliers across the globe. A viable solution is the utilization of commercialized, totally hexavalent chrome-free decorative trivalent systems as the replacement for decorative hexavalent chrome.