In this bulletin:
- New ESTAL President 2020-2023
- Preparing for the revision of BREF STM
- Surface treatment and recycled aluminium
- ADAL, full member of ESTAL
- ESTAL Congress 2021 in Budapest
- CrO3: Individual Applications for authorisations?
- Titanium dioxide classification
- PFOA and PFAS ban
New ESTAL President 2020-2023
On 3rd November 2020, ESTAL General Assembly elected a new Executive Committee and appointed Ivo Vermeeren from Belgium as President and Dr. Metin Yilmaz from Turkey as Vice-President of the European association.
They will be in charge of the association for the next 3 years. Ivo Vermeeren succeeds José Almeida from Portugal who leaves the task of directing the European Association to his Belgian colleague who has previously already led ESTAL for 6 years from 2011 onwards. Dr. Metin Yilmaz has been the vice-president of ESTAL for the past 3 years and accepted to continue his mandate for another term.
Preparing for the revision of BREF STM
Both Ivo Vermeeren and Dr. Metin Yilmaz want to focus the immediate efforts of the European association on the forthcoming revision of the BREF STM (Reference document on Best Available Techniques for Surface Treatment on Metals and Plastics). The revision will be crucial for the surface finishing industry: in future the Best Available Techniques defined in the revised document will be compulsory for all plants in Europe.
The revision of the document should start in the second half of 2021 and ESTAL will probably need updated information from the anodisers and coaters about the technology used in the surface finishing companies. Without this information, the EU Commission may impose drastic permit conditions for the plants that could force anodizers and coaters to invest heavily.
In this respect the ESTAL board is looking for experts in the industry to reinforce the ESTAL task force that handles this crucial topic. All interested parties, please contact the ESTAL-secretariat at firstname.lastname@example.org
Surface treatment and recycled aluminium
Ivo Vermeeren will also be chairing the working group “Secondary / Circular Aluminium”. In this task force, Extruders together with Powder Coaters, Anodizers, Academics, Quality Labels, Powder and Chemical Suppliers from all over Europe are investigating the interaction between Recycled Aluminium and the current Surface Treatment Processes. This is a unique project as it is the very first time that all players in the value chain are bringing their expertise to the table on a specific topic. This clearly underlines the importance of the research done by this task force.
ADAL, full member of ESTAL
On 1st July 2020, the French Association of Aluminium surface treatment, ADAL rejoined ESTAL as a full member, after an absence of a few years. ESTAL is pleased to welcome the 46 French finishing plants.
ESTAL Full members presently encompass 85 anodising companies, 138 coating companies and 88 companies with anodising and coating facilities. Together with the 6 associated members (4 anodising plants and 2 plants with anodising and coating facilities) and 9 sustaining members, ESTAL membership represents 326 companies.
ESTAL Congress 2021 in Budapest
ESTAL will hold its congress 2021 from 29 September to 1st October 2021 in Budapest, under the slogan: Taking aluminium to new horizons. ESTAL plans to hold the congress as in the past, provided the covid-19 pandemic makes it possible. In case the situation remains too unpredictable, Estal may decide to hold a virtual congress or a hybrid congress with online-presentations for the participants. More information to be given in the first months of 2021. In the meantime, please reserve the date.
CrO3: Individual Applications for authorisations?
Since the sunset date of 21 September 2017, CrO3 can no longer be used in the EU - that is, unless an authorisation has been granted or at least applied for. The importers of CrO3, Chemservice (formerly Lanxess) et al., have formed the CTAC Sub consortium that filed an AfA (application for authorisation) before the LAD (latest application date) of March 2016. That 'upstream' AfA covers a multitude of 'uses' at a downstream level. It includes, under its 'use 5', the use of a conversion layer before powder coating of aluminium for architectural applications.
Until now, no decision has been taken by the EU Commission on the CTAC Sub AfA. Until such a decision is taken, coaters can continue to use CrO3 that originates from one of the CTAC Sub applicants.
An upstream authorisation such as the CTAC Sub AfA covers multiple 'uses', and would allow downstream users, even 'far away down' downstream users such as powder coaters of aluminium, to continue the use of the substance under conditions specified in the Commission's granting decision.
However, upstream AfA's tend to lack detailed data concerning exposure to the substance of workers and the environment at the 'far away down' downstream level. Also, there can be doubts as to the completeness of the analysis of 'suitable alternatives generally available' for the downstream uses. This is also the case for the CTAC Sub AfA.
NGO's have therefore argued against the planned Commission's granting of an upstream authorisation for CrO3. A motion had been tabled in the European Parliament (EP) which would have led to a review of the Commission's draft implementing decision. In its plenary session mid-July, the EP rejected that motion with the smallest of margins (237 for, 237 against, with some abstentions).
Meanwhile, many authorisations for CrO3, some with the longest possible review periods, have been granted by the Commission to individual users or to small groups of applicants with the same specific and well-documented 'use'.
It is now believed that the Commission's draft granting implementing decision and a possible voting could be on the agenda of the December meeting of the Commission's REACH Committee. A positive vote by the Member States representatives is still expected. If accepted as drafted, a review period of 4 years would apply for 'use 5'. This would mean that powder coaters could continue their use of CrO3 until 2024.
In order to continue after the new sunset date however, it is important to start preparing for a new AfA very soon. ESTAL has warned in the past that it would be safer for coaters not to rely on the upstream chemical suppliers if they want to continue their use of CrO3. A good approach would be for interested coaters to come forward now, together with their immediate upstream chemical supplier.
ESTAL, as an association, cannot file an application for authorisation. And it is neither the role nor the intention of ESTAL to take the lead in an eventual coordinated effort to that effect.
Simon Meirsschaut, ESTAL's Technical Coordinator, is able and willing to facilitate the setting up of a coordinated AfA scheme, which in a first phase would involve bringing in competent REACH consultants to generate dossiers including exposure data at the level of the individual coaters, and later on to take care of the managing of a consortium set-up. Contact email@example.com at Meirsschaut & Associates, Chemin des Soeurs 7, BE 1320 Beauvechain Belgium
Titanium dioxide classification
As mentioned already in the previous Info Bulletin, the European Commission's Delegated Regulation of October 4th, 2019 to classify TiO2 as CMR Cat 2 (by inhalation) was published in the OJEU in February 2020.
The regulation is applicable from 01.10.2021. It implies that powder boxes containing TiO2 will have to be labelled accordingly, including specific hazard symbols. Adapted safety data sheets will have to be provided by the suppliers. Also, there may further be implications for the transport of the materials, as well as for powder wastes.
The manufacturers of titanium dioxide maintain that there are no reliable data that TiO2 causes cancer. Therefore, several member companies of the TDMA (Titanium Dioxide Manufacturers Association) a sector group of CEFIC, have submitted an action in annulment to the EU General Court. They challenge the legality of the classification adopted by the Commission.
The decision of the Court is not expected before another 2 or 3 years. In the meantime, however, the Regulation has to be implemented as of October 1st, 2021.
PFOA and PFAS ban
Under the Stockholm Convention a global ban on POPs (persistent organic pollutants) has been decided. In Europe, substances such as PFOA (PerFluoroOctanic Acid) or PFAS (PerFluoroAlkyl Substances) have been restricted already in the framework of Annex XVII of REACH. With its recast Regulation, effective July 2020, the EU now imposes a more general ban, albeit with still some exceptions.
Powder coaters of aluminium might be affected where the above substances are added to powders for anti-graffiti or anti-bacterial coatings or for fire retardant purposes. Also, within PTFE powders, PFOAs may be added to improve scratch performance or to give textured appearance.
It is important for coaters and powder suppliers to communicate in a transparent way over possible modifications of powder formulations which may lead to complications in the coating process.
For more information, please contact
Simon Meirsschaut, ESTAL Technical Coordinator
Tel +32 473 451 263
Martine Kalmar, Secretary General
Tel. +41 44 772 22 77
Legal disclaimer All information provided by ESTAL and ESTAL Technical Coordinator is given to the best of their knowledge. Neither ESTAL nor the Coordinator personally accept liability for the correctness and completeness of the information contained in this communication, or for the consequences of any action taken on the basis of the information provided. ESTAL advises the information recipient to seek confirmation of the relevant information from the competent authority.