December 3, 2024 | Compliance
A few years ago chromate-free passivation was a negotiable option on a quotation. For appliance exports it is now an entry requirement. The reason is simple: regulation is tightening and OEMs pass the pressure upstream.
RoHS restricts hexavalent chromium in electrical and electronic equipment at 0.1%. Finished appliances fall in scope, so the steel supplier is asked for a declaration.
REACH works differently — through the SVHC list and notification duties. Buyers typically ask for SVHC screening results.
Together they mean one thing: a passivation film containing hexavalent chromium is increasingly hard to move through an export chain.
| Type | Character | Where it fits |
|---|---|---|
| Inorganic (silicate / Ti-Zr) | Good heat resistance, moderate cost, slightly lower initial corrosion resistance than chromate | Standard appliance parts, over-painting |
| Organic (resin) | Good adhesion, can combine with anti-fingerprint in one film | Anti-fingerprint and lubricity requirements |
| Hybrid | Inorganic backbone with organic sealing — a compromise | Most appliance exterior parts |
The usual concern is whether chromate-free is less corrosion resistant. Fairly put: on a bare film, some chromate-free systems do start lower. But appliance sheet rarely ships bare — an anti-fingerprint film or paint goes on top, and after that the gap is small.
What actually matters is not chromate versus chromate-free but whether film weight is stable. A passivation film that runs thin loses corrosion resistance faster than switching systems ever would.
Usually three things: a material declaration, third-party test reports, and batch traceability. The first two are documents. The third tests the factory — can you tie a specific shipment to a specific report. Many suppliers cannot answer that one.
Attach the compliance requirement to the contract and collect the declarations at first-article approval. Chasing your supplier after a finished appliance is held at customs is too late — what gets replaced at that point is not the supplier but the shipment.
