Securing the path to the future

When the prospects for Community applications regarding the authorization of chromium(VI) became increasingly difficult, the hard chrome contract coater Betz-Chrom, based in Gräfelfing, decided to shape its own future - through individual authorization. The process was lengthy, strenuous and cost-intensive. The reward is now a legally compliant use of chromium(VI) for the next twelve years. In this interview, Hannah Betz explains how this challenge was overcome and what she thinks about the restriction of chromium(VI).

mo: Congratulations on another twelve years of coating with chromium trioxide! What does this approval mean to you and your company?
Betz: Thank you very much! Yes, we have received approval from the European Commission for the use of chromium trioxide until February 15, 2033. This approval enables us to continue our core business of hard chrome plating. And an extension is possible, provided we submit a review report by August 2031. I therefore see a good chance that we have created legal certainty for us and our customers for more than just the next twelve years.

mo: An individual authorization for chromium trioxide is not a matter of course. Why did you opt for an individual application instead of remaining part of a consortium application with relative ease?
Betz: We were originally part of the CTAC sub-consortium, but due to the legal uncertainties and insufficient data quality within the consortium, we opted for an individual application in 2019. After an internal strategy workshop, we came to the conclusion that this path was safer for us. Two years of preparation later, we submitted our individual application in February 2021.

mo: Can you give us an insight into how much effort and energy an individual application means for a company?
Betz: The effort was enormous. We commissioned the company Ramboll to help us prepare the application. The application was divided into three sections: the Chemical Safety Report (CSR), the Analysis of Alternatives (AOA) and the Socio-Economic Analysis (SEA). Each area required specialized expertise, which drove the costs into the hundreds of thousands of euros. For a small and medium-sized enterprise (SME) like us, this is a considerable investment. Capital that is then of course initially lost for important investments, for example in production.

mo: A major current topic is the possible restriction of Chrome VI. How do you view this development?
Betz: The proposed restriction on chromium(VI) is indeed a major issue. While our authorization gives us a certain degree of certainty, a restriction could present us with new challenges, depending on how the EU Commission deals with the authorizations that have been granted. It is currently unclear how long it will take for a decision to be made. However, we do not see the restriction proposal in a negative light at all, as it could finally allow fair competition again and, provided it is properly structured from a technical and expert point of view, it would actually be exactly what the industry has been calling for for a long time.

mo: In the discussion about locational disadvantages in Germany, reference is often made to the strict regulations. How do you see this?
Betz: It is true that the regulations in Germany and the EU are very strict, which puts us at a disadvantage in international competition. We often hear of companies moving to countries close to us outside the EU, such as Serbia or Switzerland, in order to avoid the regulations. On the other hand, Germany offers many advantages such as a good education system, an excellent infrastructure and dual vocational training. We must not forget these advantages.

mo: What positive aspects do you see in the licensing and regulatory framework in Europe?
Betz: The strict regulations have led to intensive research and development in the field of alternatives to chromium(VI). We are part of the DigiChrom research project, which is funded by the German Federal Ministry of Education and Research (BMBF) and researches digital tools for improving electroplated coatings. Such projects would probably not have been tackled to this extent without regulatory pressure.

mo: In conclusion, how do you see the future of your company in this highly regulated environment?
Betz: We are convinced that our path was the right one. The investment in the individual application has legally secured our core business. We can offer our customers legally compliant hard chrome plating and are therefore a solution provider for our customers' strategic purchasing. We are also working on alternative processes at the same time. Despite the many challenges in Germany, we are positive about the future and want to continue to act as a reliable partner in the surface coating sector.

Betz-Chrom GmbH

www.betz-chrom.de