As part of the ZVO Surface Technology Days 2023 in Berlin from September 13-15, 2023, the Zentralverband Oberflächentechnik e.V. is offering the consultation hour "Regulatory developments in European and national environmental and chemicals policy - users ask, experts answer" for the first time
The year 2023 seems to have been chosen to raise regulation by the EU Commission and German authorities to unimagined heights. We will not be discussing the German government's legislative capers here. There is not even enough space for the main restrictions imposed on the industry by the EU. First of all, there is the court annulment of the chromium trioxide authorizations granted in 2020. All efforts to produce review reports are suddenly invalidated, as are all notifications, measurements, investments, etc. that were required by the authorizations. Even companies that were prepared to make substitutions or individual authorizations must now fear losing their operating permit, at least temporarily. We will know more in April 2024; the ZVO has informed its members about this in the ZVO online dialog.
The example of chromium trioxide with the chaos surrounding the authorizations should have been a warning to the authorities to try a similar experiment. Instead, they presented an even more extensive work, the PFAS restriction draft. Again, far-reaching regulation, again the preparatory work is - to put it mildly - inadequate and again the reversal of the burden of proof applies; this time to get exemptions - maybe! On June 26/27, 2023, affected industries met in Bonn to discuss the far-reaching consequences of this draft restriction. The attendees must have been terrified. Almost no industry would be able to continue using modern technologies and countless products would disappear. The only thing the representatives of the authorities could think of was that this persistent group of substances absolutely had to be eliminated in its entirety - precisely because of its persistence. Real toxic properties for humans and the environment are only suspected; there are stronger indications for a few representatives, albeit at concentrations far above those that can be observed. Once again, the precautionary principle is being invoked.
A cost-benefit analysis, as required by the EU to apply the precautionary principle, was not carried out. Quote: "They [the industry] have not provided us with sufficient data for this!". There are also no plans to monitor the consequences - apart from regular reports on how much less PFAS has been used.
What can we expect from this type of legislation and regulation in the future? It is staggering to see how easily even the loss of vital components is taken for granted. For example, a representative of the medical technology sector reported on the loss of many minimally invasive surgical techniques, while a textile representative spoke of stents for children no longer being approved in the future. Helicopters will no longer be able to be manufactured on European soil. And no one understands where the planned duration of 6.5 or 13.5 years for exemptions comes from. There is also no justification for this. A purely arbitrary determination.
What can be done to prevent the further massive dismantling of industry and economic output in Europe?
What can be done to prevent the further massive dismantling of industry and economic output in Europe? We will be discussing this at the ZVO Surface Treatment Days 2023. In addition, specific concerns, needs and problems from day-to-day electroplating operations will be heard and solutions found. We look forward to seeing you on Thursday, September 14, 2023, 10:50 a.m. to 12:30 p.m. in the consultation hour of the ZVO Environmental and Chemicals Policy Department. Our experts are ready and waiting. We look forward to seeing you!
Registrations for the ZVO Surface Days 2023 are possible online until September 8, 2023 at
