Cadmium Banned in Europe in November

The European Commission announced May 20 that the European Union will ban cadmium in jewelry, brazing sticks and plastics beginning this November. A Commission press release states that the new legislation, which will be adopted as an amendment under the EU’s Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulation, will prohibit the use of cadmium in all types of jewelry products, except antiques; brazing sticks, which are used to join dissimilar materials; and — in theory — all plastics.  

We say “in theory” in regards to the cadmium ban in “all plastics” because the Commission notice on the updated cadmium restriction appears to have inconsistencies regarding plastics.

The notice on World Trade Interactive suggests that cadmium will be banned in all plastics (with the exception of some recycled PVC).  But an article in British Plastics & Rubber points out semantic oddities in the Commission’s draft document.

The draft references the proposed amendment to Restriction 23 of Annex XVII, which covers cadmium and its compounds.  However, the Commission’s report contained no changes from the 2010 document regarding the list of materials that would be affected.  The wording of the recent statement says “all plastics” would be affected by the ban, but the itemized list of named plastics remains the same.

This leaves the door open for some agents to interpret that plastics not itemized on the list are exempt.

This language snarl is worth being aware of.  In the long view however, while it may delay a revision, it likely won’t stop the fact that cadmium use in virtually “all plastics” will be banned in the EU either in Q4 of this year or shortly thereafter.

And that, of course, is the “heads up.”  (For more on the language snarl, see article, Cadmium — banned or not?)

Cadmium backstory. Cadmium has many uses. It’s used in paint as a pigment, for starters. Or was. EPA and regulatory bodies around the world have been trying to restrict or prohibit cadmium use in paint for years. Often trace amounts of cadmium result in public-perception denigration and expensive product recalls that affect the bottom line; such events are arguably more of a deterrent for industry than the anti-cadmium regulations themselves.

Last summer, for instance, REACH compliance watchdogs found traces of cadmium in Shrek glasses for children. The glasses were manufactured to be sold at McDonald’s as part of the Shrek film promotion. McDonald’s had to recall over 12 million of the glasses that would have retailed for $2 each; that’s a loss of $24 million, plus the operational costs of the recall.

Many think recall events due to substances like cadmium are primarily a supply chain communication failure. While that is true, recalls also point to a regulatory gap and a supply chain that quite naturally tries to cut corners.

The EU appears to be ready to send a clear message:  no cadmium. And to many manufacturers — although probably not to the manufacturers of cadmium pigment — a clear regulation is a welcome regulation. Last year, EPA moved on this item as well when cadmium turned up in kids’ jewelry.

Cadmium alternatives. There’s no reason we need to be using cadmium in this day and age, right?  Problem is, especially for industrial uses, cadmium is very effective as a plating over steel as it’s remarkably resistant to corrosion.

A cadmium alternative for components must be, among other things:

  1. A panacea: act as a general corrosion coating for all seasons
  2. Specific protection: provide good salt spray and scribed corrosion protection
  3. Non-crackable case: cannot succumb to hydrogen embrittlement or stress corrosion cracking.

As a coating, the cadmium alternatives must, among other things:

  1. Retain thread profile/detail underneath, especially in jewelry
  2. Be solderable
  3. Be usable in electrical equipment in terms of conductivity and heat-effect limits.

At minerals.usgs.gov, the government says that coatings of zinc or vapor-deposited aluminum can substitute for cadmium in plating applications.

In 2002, a group published an evaluation of cadmium replacement alternatives for aircraft with notable results. Typically aircraft are exempt from cadmium legislation because of a “no known alternative” clause. In other words, nothing works as well so it is allowed for now.

This still creates a cost and a wrench in manufacturing process, however, due primarily to the problem of disposal of this known-toxic material at end-of-life. Where does cadmium go to die? We’ve all heard of the aircraft boneyard.  Aircraft manufacturers are responsible for end of life disposal of all parts and components (and substances).  The costs associated with end-of-life makes alternatives to cadmium look better and better.  For more on aircraft and replacements, see the Rowan Technology Group 2002 report on cadmium replacements.  It’s an interesting document.  Spoiler alert:  the report concludes that aluminum (Al) is the best cadmium replacement for uses in aerospace, automotive and electronic components in terms of behaving most like cadmium.

The point is that there are alternatives to cadmium — depending on application. For the most part, the replacements are sister- or cousin-metals.

For more on the cadmium ban coming in November under REACH regulation, review the European Commission’s press release.  Also, keep an eye on this blog as we’ll keep you posted on the critical cadmium (and similar) regulatory update status as we go through 2011.

About Kal

Kal Kawar, CIH, PE, has a bachelor's in chemical engineering and a master's in industrial hygiene. His professional experience includes serving as staff industrial hygienist for IBM's New York semiconductor manufacturing facility, and as industrial hygienist for IBM’s US headquarters. Now executive vice president of Actio, Kal taps more than 20 years' worth of chemical engineering, industrial hygiene, and environmental engineering experience. His far-reaching expertise with global regulatory challenges created by EPA, TSCA, REACH, RoHS, WEEE – and hundreds of others – aid in developing Actio software solutions for MSDS management, raw material disclosure compliance, and product stewardship in a supply chain.
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