ZVO & VECCO: Discussion with BAUA on Chromium(VI)

The discussion between the Central Association of Surface Technology (ZVO) (ZVO) and VECCO e.V. with the BAUA was the surface technology industry’s perspective on the currently discussed regulatory tightening within the framework of the European REACH restriction on chromium(VI) substances. ZVO and VECCO made it clear that the reduction of the occupational exposure limit to 0.1 micrograms per cubic meter of exhaust air, as proposed by the Committee for Risk Assessment (RAC), is currently not feasible from a technical and economic standpoint. At the same time, the associations emphasized that companies in the surface treatment industry already operate under very high safety, environmental, and occupational health and safety standards. The existing limit values, as well as the extensive technical protective measures, already ensure a high level of health and consumer protection. From the industry’s perspective, a further drastic reduction of the limit value would therefore not yield any significant additional safety benefits, while simultaneously causing massive burdens for industrial processes and sites in Germany and Europe.

Hard chrome applications are indispensable in technical processes

In discussions with the BAUA, the ZVO and VECCO also made it clear that surface technology is a key technology for numerous industrial value chains—including the automotive industry, mechanical engineering, aerospace, medical technology, and the defense sector. In particular, functional hard chrome applications have so far been indispensable in many technical processes. The associations therefore strongly warned against establishing regulatory requirements that are effectively unachievable in industrial practice. Such regulation would entail significant risks for industrial value creation, investment, and jobs in Europe without providing proportionate additional benefits for health or consumer protection. The ZVO will continue to closely monitor the process together with VECCO and advocate for practical, science-based, and competitive solutions at both the national and European levels.