The Problem
RoHs REACH restrictions will soon forbid the use of “black chromium” coatings in a broad range of products – which will incrementally further expand over the next few years. Since these coatings are presently widely used in optics this raises a problem for manufacturers – the need for an alternative.
The Solution
Luckily an excellent alternative is readably available. Acktar coatings are accepted as the “gold standard” for black coatings in high performance optical systems.
Acktar Ltd. is a globally recognised leading provider of deep-black inorganic, non-toxic and non-outgassing coatings and foils. Both at the headquarters and at the German subsidiary ACM Coatings GmbH in Bad Kösen – only 25 km away from Optical Valley Jena – the EU directive RoHS 2011/65/EU and the Regulation (EC) 1907/2006 REACH are implemented consistently. AcktarBlackTM coatings and foils thus offer an outstanding RoHS and REACH compliant alternative to black chromium coatings, which, additionally, possess better optical properties and are applicable to a large number of substrates. ACKTAR coatings have a high level of heat stability (-269°C to +350°C) and are applicable in a wide spectral range (UV to IR). They fulfil the toughest requirements with regard to light absorption and residual reflection, for example in aerospace technology, industrial optics and sensors, laser technology, medical technology, semiconductor technology as well as other high-tech applications, including under 1st class vacuum and cleanroom conditions.
Alexander Telle, Managing Director of ACM Coatings GmbH – Acktar’s subsidiary in Germany – says: “Many users of black chromium are currently not yet very aware of the problem and possible alternatives are rare. We help our customers to make the conversion as simple as possible – forward-looking, careful and smooth. Now is a good time to allow for the recent extension of the area of application of the RoHS and to prepare oneself for the next one in 2017. RoHS and REACH are far from being a topic only for large companies; the legal provisions are no less strict for SMEs either. Apart from the costs that would be incurred in the event of an infringement upon the provisions, it is also a monetisable image gain and a competitive advantage for companies when they commit to the protection of the environment and the health of their employees by reducing cancer-inducing chemical agents at the workplace. Moreover, preserving employee health ensures work productivity and the retention of specialist workers in the long term.”
What restrictions to the use of black chromium are currently under consideration?
The RoHS = Restriction of (the use of certain) Hazardous Substances in electrical and electronical devices prescribes a maximum value of 0.01% for hexavalent chromium for all elements and components used.
Due to the critical material hexavalent chromium, the galvanic coating “black chromium”, which is frequently used in optics, is not RoHS compliant.
For vacuum-metallised black chromium coatings, the legal situation is at best insecure.
Do my products come into the area of application?
The area of application is gradually being extended to practically all electrical products – approximately two years ago for medical devices and non-industrial monitoring and control instruments (since 22 July 2014), currently for in-vitro diagnostics (on 22 July 2016), in approximately one year also for industrial monitoring and control instruments (on 22 July 2017) and finally in 3 years also for other electrical and electronical devices not covered by any of the other categories (from 22 July 2019).
Do I need to think about RoHS compliance if I do not deliver to the EU?
If you sell electrical or electronical devices within the EU or parts and/or material that, in turn, are integrated into other products subject to the RoHS, your products must be RoHS compliant. However, even if you sell your products beyond the EU borders, the RoHS topic is relevant. There are or will be similar provisions on the reduction of hazardous substances with other important trading partners of the EU as well.
What is the significance of the REACH regulation?
The REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) regulation, issued by the EU, serves to protect human health and the environment from the risks that can emerge due to chemicals. Certain hexavalent chromium combinations were determined as particularly alarming substances, as they fulfil the criteria for a classification as a carcinogenic substance (category 1A or 1B) according to Regulation (EC) No. 1272/2008 and are therefore carcinogenic substances within the meaning of directive 2004/37/EC.
Area of application
1. Large household appliances
2. Small household appliances
3. IT and telecommunications equipment
4. Consumer equipment
5. Lighting equipment
6. Electrical and electronic tools
7. Toys, leisure and sports equipment
8. Medical devices
9. Monitoring and control instruments including industrial monitoring and control instruments
10. Automatic dispensers
11. Other EEE not covered by any of the categories above
2. Small household appliances
3. IT and telecommunications equipment
4. Consumer equipment
5. Lighting equipment
6. Electrical and electronic tools
7. Toys, leisure and sports equipment
8. Medical devices
9. Monitoring and control instruments including industrial monitoring and control instruments
10. Automatic dispensers
11. Other EEE not covered by any of the categories above
This Directive does not apply to:
(a) Equipment which is necessary for the protection of the essential interests of the security of Member States, including arms, munitions and war material intended for specifically military purposes.
(b) Equipment designed to be sent into space.
(c) Equipment which is specifically designed, and is to be installed, as part of another type of equipment that is excluded or does not fall within the scope of this Directive, which can fulfil its function only if it is part of that equipment, and which can be replaced only by the same specifically designed equipment.
(d) Large-scale stationary industrial tools.
(e) Large-scale fixed installations.
(f) Means of transport for persons or goods, excluding electric two-wheel vehicles which are not type-approved.
(g) Non-road mobile machinery made available exclusively for professional use.
(h) Active implantable medical devices.
(i) Photovoltaic panels intended to be used in a system that is designed, assembled and installed by professionals for permanent use at a defined location to produce energy from solar light for public, commercial, industrial and residential applications.
(j) Equipment specifically designed solely for the purposes of research and development only made available on a business-to-business basis.
(a) Equipment which is necessary for the protection of the essential interests of the security of Member States, including arms, munitions and war material intended for specifically military purposes.
(b) Equipment designed to be sent into space.
(c) Equipment which is specifically designed, and is to be installed, as part of another type of equipment that is excluded or does not fall within the scope of this Directive, which can fulfil its function only if it is part of that equipment, and which can be replaced only by the same specifically designed equipment.
(d) Large-scale stationary industrial tools.
(e) Large-scale fixed installations.
(f) Means of transport for persons or goods, excluding electric two-wheel vehicles which are not type-approved.
(g) Non-road mobile machinery made available exclusively for professional use.
(h) Active implantable medical devices.
(i) Photovoltaic panels intended to be used in a system that is designed, assembled and installed by professionals for permanent use at a defined location to produce energy from solar light for public, commercial, industrial and residential applications.
(j) Equipment specifically designed solely for the purposes of research and development only made available on a business-to-business basis.
