Department, date HEAVY METALS RESTRICTIONS OF EU ELV DIRECTIVE. STATUS OF ACTUAL ANNEX II REVISIONS. CLEPA Material Regulation Conference 2017, 17. May 2017, Reutlingen R. Hoock, BMW Group on behalf of ACEA /Joint Associations Industry Expert Groups Heavy Metals
HEAVY METALS RESTRICTIONS OF EU ELV DIRECTIVE. STATUS OF ACTUAL ANNEX II REVISIONS. Contents: Introduction ELV directive Status 8 th Revision of Annex II Next Revisions Conclusion Page 2
EUROPEAN END OF LIFE VEHICLES DIRECTIVE 2000/53 EC. MATERIAL RESTRICTIONS. 4.2 Member States shall ensure that materials and components of vehicles put on the market after 1 July 2003 do not contain lead, hexavalent chromium, cadmium and mercury other than in cases listed in Annex II under the conditions specified therein; Page 3
EUROPEAN END OF LIFE VEHICLES DIRECTIVE 2000/53 EC. ARTICLE 4.2 MATERIAL RESTRICTIONS. 4.2 (b) the Commission shall on a regular basis, according to technical and scientific progress, amend Annex II, in order to: (i) as necessary, establish maximum concentration values up to which the existence of the substances referred to in subparagraph (a) in specific materials and components of vehicles shall be tolerated; (ii) exempt certain materials and components of vehicles from the provisions of subparagraph (a) if the use of these substances is unavoidable; (iii) delete materials and components of vehicles from Annex II if the use of these substances is avoidable; Page 4
REVIEWS ELV ANNEX II. DEVELOPMENT SINCE YEAR 2000. Directive 2000/53/ EC 1. Revision 2002/525/ EC 2. Revision 2005/673/ EC 3. Revision 2008/689/ EC 4. Revision 2010/115/ EU 5. Revision 2011/37 EU 6. Revision 2013/28 EU 7. Revision (EU) 2016/774 8. Revision 9. Revision Date Amount of Exemptions Sept. 2000 13 June 2002 22 Sept. 2005 21 Aug. 2008 23 Feb. 2010 31 March 2011 36 May 2013 36 May 2016 37 Oct 2017?? 2019? background concentration levels considered repair as produced principle 8a -> 10 subentries 8a,c,d,e,f,g,h, 8b -> 8i, j 10 -> 10a,b,c,d 8i exp. date revised 8f 8f (a) 8f(b) 8h end date 8j end date 10d end date review for entries 8e, 8f(b) and 8(g) Draft 21.3 2017 Review scheduled for entries 8e, 8f(b) 8(g) Trend: Split of entries, more application specific scope Page 5
8 TH REVISION OF ELV ANNEX II. LATEST DRAFT VERSION OF MARCH 2017. Source: Ref. Ares(2017)1520534-21/03/2017 Draft Amendment Exemption 3: Copper alloys containing up to 4% lead by weight review 2021 Exemption 2(c) Pb in Al < 0,4% Split in 2(c)(i) and 2(c)(ii) Exemption 2(c)(i): Aluminium alloys for machining purposes with a lead content up to 0.4% by weight review 2021 Exemption 2(c)(ii): Aluminium alloys not included in entry 2(c)(i)with a lead content up to 0.4% by weight (1a) review 2024 (1a) Applies to aluminium alloys where lead is not intentionally introduced but is present due to the use of recycled aluminium. Page 6
8 TH REVISION OF ELV ANNEX II. LATEST DRAFT VERSION OF MARCH 2017. Source: Ref. Ares(2017)1520534-21/03/2017 Draft Amendment Exemption 5: Pb and Pb compounds in batteries Split in 5(a) and 5(b) Exemption 5(a): Lead in batteries in high voltage systems (2a) that are used only for propulsion in M1 and N1 vehicles Exemption 5(b): Lead in batteries for battery applications not included in entry 5(a) expires for vehicles type approved after 1 January 2019 review 2021 (2a) Systems that have a voltage of >75V DC as defined in Directive 2006/95/EC of the European Parliament and of the Council of 12 December 2006 on the harmonisation of the laws of Member States relating to electrical equipment designed for use within certain voltage limits (OJ L 374, 27.12.2006, p. 10). Page 7
UPCOMING ANNEX II REVISIONS. Exemption Pb high melting solder (8e) Pb flip chip (8g) Pb lead in compliant pins other than the mating area of vehicle harness connectors 8(f)(b). Inspection date Review 2019 scheduled Review 2019 scheduled Review 2019 scheduled Pb aluminum alloys 0,4% Pb 2(c)(i) 2021? Pb copper alloys 4% Pb (3) 2021? others? 2021? Expiring exemption Pb laminated glazing (8j) Type aproval before 1.1.2020 Page 8
VIEW TO ROHS. MANY ENTRIES UNDER REVISION - EXAMPLES. Exemption EU ELV EU RoHS Pb in steel (0,35%) 1(a) 6(a) Pb in Al (0,4%) 2(c) 6(b) Pb in Cu (4%) 3 6(c) Pb in high melting solder 8(e) 7(a) Pb in glass /ceramic (partially) 10(a) 7(c)-I Pb in flip chip IC 8(g) 15 Similar exemptions, but Different timing for Due dates / no due date revision Different revision process and different departments at authorities Same parts go to different applications with different waste streams Within current RoHS revisions consultant suggested split of exemptions and early reviews. The affected industry asks to extend review dates and rejects splitting. Page 9
CONCLUSIONS. The draft for the 8 th annex II revision sets again review dates for several entries. As in previous reviews there is a further split of existing exemptions. Without contributions based on solid and convincing technical arguments, the exemptions will end. Careful creation of material data sheets helps to identify the need of exemptions. The support of suppliers, associations, OEMs in the industry expert groups heavy metals is very appreciated and essential to obtain exemptions. Thank you to all for their contribution. For being prepared towards the next revisions the work starts now. The joint associations industry expert groups are open to welcome new members. Page 10
Back Up Slides
NEW ENTRY 8f(b). SCOPE. Why lead is used? Lead is needed to suppress formation and growth of whiskers. Joint Industry Association Experts Heavy Metals Page 12
CURRENT EU LEGISLATION COHERENCE ANALYSIS. The EU Commission is currently analysing the coherence of the legislative approach and procedures regarding hazard identification, generic risk consideration, specific risk assessment or risk management measures. Non exhaustive list below.. 1) Legislation covering hazard identification and classification Classification, labelling and packaging (Regulation No (EC) 1272/2008) Plant protection products (Regulation (EC) No 1107/2009) Biocidal products (Regulation (EU) No 528/2012) REACH, Annex XIII (Regulation (EC) No 1907/2006) Inland transport of dangerous goods (Directive 2008/68/EC) Chemical Agents (Directive 98/24/EC), Asbestos (Directive 2009/148/EC), Carcinogens and mutagens at work (Directive 2004/37/EC) 2) Legislation covering risk management measures Worker safety and transport legislation Inland transport of dangerous goods (Directive 2008/68/EC) Carcinogens and mutagens at work (Directive 2004/37/EC) Young people at work (Directive 1994/33/EC) Pregnant workers (Directive 1992/85/EEC) Signs at work (Directive 92/58/EEC) Chemical Agents (Directive 98/24/EC) Asbestos (Directive 2009/148/EC) Environmental protection legislation Industrial emissions (IPPC) (Directive 2010/75/EU) Waste framework (Directive 2008/98/EC) and List of Waste Waste shipments (Regulation (EC) No 1013/2006) Major-accident hazards involving dangerous substances (Seveso) (Directive 2012/18/EU) Water Framework (Directive 2000/60/EC) Urban Waste Water (Directive 91/271/EEC) Marine Strategy Framework (Directive 2008/56/EC) RoHS in electrical and electronic equipment (Directive 2011/65/EU) End of life vehicles (Directive 2000/53/EC) Batteries (Directive 2006/66/EC) Packaging and Packaging Waste (Directive 94/62/EC) Chemicals control legislation Biocidal products (Regulation (EU) No 528/2012) Plant protection products (Regulation (EC) No 1107/2009) Export and import of hazardous chemicals (Regulation No 649/2012) Persistent organic pollutants (Regulation (EC) 850/2004) Contaminants in food and feed (Regulation (EEC) No 315/93 +Directive 2002/32/EC) Residues of pesticides (Regulation (EC) No 396/2005) Product controls EU Ecolabel (Regulation (EC) 66/2010) Safety of toys (Directive 2009/48/EC) Cosmetic products (Regulation (EC) No 1223/2009) Detergents (Regulation (EC) No 648/2004) Drinking Water (Directive 98/83/EC) Fertilisers (Regulation (EC) No 2003/2003)15 Medical devices (Directives 93/42/EEC, 90/385/EEC 98/79/EC) Aerosol dispensers (Directive 75/324/EEC) Explosives (Directive 93/15/EEC) Pressure equipment (Directive 2014/68/EU) Food contact materials (Regulation (EC) No 10/2011 and Regulation (EC) No 450/2009) General Product Safety (Directive 2001/95/EC) 3) Supporting legislation Test methods (Regulation (EC) No 440/2008) Good Laboratory Practice (Directives 2004/9/EC and 2004/10/EC) Protection of animals used for scientific purposes (Directive 2010/63/EU) Source:http://ec.europa.eu/smart-regulation/roadmaps/docs/2015_grow_050_refit_chemicals_outside_reach_en.pdf last accessed 16.May 2017 Page 13
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