REACH affects vehicle production
REACH is a regulation of the European Union, which governs the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH). The regulation has been in effect for almost ten years. The authorization or approval procedure for substances of very high concern (SVHC) was established by REACH. This procedure provides that substances that are included in the regulation require authorization for a transitional period. If such approval is not obtained for an affected material, its use is banned within the EU after the end of the period. Experience with REACH has shown that the regulation also has great influence on vehicle production, because substances previously used have had to be substituted.
However, a use ban applies only within the EU, and only for the substances themselves. Products that are manufactured outside the EU with substances that are no longer approved may continue to be imported into the EU. This compromise is made clearly manifest by the authorization procedure for chromium (VI) compounds. Chromium (VI) compounds, which are used in the production of chromiumplated components – in the car, as well as in the sanitary sector – were added to the REACH Regulation Annex, and require approval as of September 2017. In finished, chrome components, only harmless, elemental chromium is included. A potential risk arises only in the factory chromium plating process. However, here the protection of workers is consistently regulated at a high level by EU directives and national regulations. Long periods should be granted for the use of chromium (VI) compounds, in order to allow alternatives to be developed in Europe. Otherwise, businesses and jobs in the EU would be jeopardized. At the same time, it is expected that production would migrate to regions with lower labor and environmental standards. Since the affected components can be produced without any restrictions outside Europe and then imported.
In addition, REACH also increasingly endangers the production and availability of spare parts. The EU Vehicle End-of-Life (ELV) Directive does allow that replacement parts with the same materials as the original parts may be produced (repair-as-produced principle), so that older vehicles could still be repaired. However, the REACH regulation does not provide for similar treatment. Replacements parts should therefore be exempted from the prohibited substances and be guaranteed over the entire period of use of a vehicle. Such an exemption should be part of the REACH regulation. Otherwise, older vehicles could not be repaired in a few years. The previously discussed approaches are not sufficient from the viewpoint of the automotive industry.