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An important Cadmium and REACH update – ‘planning ahead’ workshop held in Brussels

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24 May 2017

The SEA’s Chief Executive, Dave Elliott, recently attended a workshop in Brussels held by the Cadmium REACH Consortium and the International Cadmium Association. The purpose of this summit was to present and discuss the likelihood of upcoming legislative changes that govern the way in which Cadmium can be used within the manufacturing sector.

 The title of the workshop was “Planning ahead for a possible future REACH Authorisation dossier for Cadmium, Cadmium Oxide (and other cadmium compounds)”, and outlined the upcoming changes in regards to REACH and how this could affect companies within the surface engineering sector.

Both Cadmium and Cadmium Oxide are on the Candidate List for Authorisation currently listed 9th and 13th respectively, in terms of priority.  This indicates that change is on the horizon.

There is a distinct possibility that Cadmium and Cadmium Oxide will be included in the 9th recommendation for authorisation, which will be published at the end of this year – December 2017.  

If this happens, the timetable will be as follows -

  • April 2018 – Discussion on prioritisation of ECHA recommendations at 59th Member State Committee meeting.
  • June 2018 – Final decision on 9th recommendation at 60th Member State Committee meeting.
  • September 2018 – Public consultation.
  • September 2019 – Final recommendations to European Commission.
  • Summer 2020 – Final European Commission decision.
  • Summer 2022 – Last application date (LAD) for applications for authorisation.
  • End of 2023 – Sunset date.


How does this affect UK companies working with Cadmium?

Although nothing has been confirmed officially, this report should outline what the timetable will look like if Cadmium, Cadmium Oxide and other Cadmium compounds go forward for authorisation.

It is important to note, that with Brexit scheduled for completion in 2019, it is unlikely that there will be a flood of UK applications for authorisation.  Companies within the aerospace sector, using Cadmium and its compounds in their manufacturing processes, will likely wait until Brexit is completed before applying for authorisation if it is still required.

It has been made clear that it is very unlikely that the manufacturers and importers of Cadmium and Cadmium Oxide will apply for “whole supply chain” authorisation.  Dave Elliott says “we suspect that a number of aerospace OEMs will make the application for authorisation, or they will ‘suggest’ that those within their supply chain do so”.

Mr Elliott goes on to say, “Given the amount of Cadmium plating carried out in the UK, and the high costs of authorisation application, it does not make economic sense for an electroplating company, or group of electroplating companies to apply for authorisation”.  It would therefore make more sense for the aerospace OEMs to apply for their supply chain as a whole, which if granted, would cover their suppliers using Cadmium.

However, the European Commission is discussing new EU wide Cadmium change.

It is also expected that the European Commission will finally issue an EU wide Occupational Exposure Limit (OEL) and Biological Limit Value (BLV) for Cadmium over the next few months.  If this happens, it is unlikely that Cadmium and its compounds will go forward for authorisation, as this will monitor and restrict the use of Cadmium to a satisfactory level. 

However, it’s important to remember that it’s  it has taken the European Commission at least 7 years to get this far, so there is no guarantee that this will progress any time soon, meaning REACH application requirements could still be on the horizon.

If the OEL and BLV does go ahead, electroplating companies would have to carry out regular personal air monitoring and enter a biological monitoring programme for Cadmium.  This would increase costs further – so expect changes over the coming months, and prepare your customers for an increase in price.

If you work with Cadmium, talk to us about the implications of this change on your business.

If you’re already a member of the SEA, then the benefits of membership are apparent, especially during periods of change – we will keep you up to date with all of the latest legislative changes, and guide you through any alterations needed within your company.

If you are not already a member, please click here to discover more benefits of membership.  Alternatively, please email Michaella Mais (Michaella.Mais@Sea.org.uk) who will be happy to discuss how membership could benefit you and your company.

 

 

Cadmium REACH Consortium
International Cadmium Association 

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