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HEAVY METALS RESTRICTIONS OF EU ELV DIRECTIVE. STATUS OF ACTUAL ANNEX II REVISIONS.
Department, date
R. Hoock, BMW Group on behalf of ACEA /Joint Associations Industry Expert Groups Heavy Metals
CLEPA Material Regulation Conference 2017, 17. May 2017, Reutlingen
HEAVY METALS RESTRICTIONS OF EU ELV DIRECTIVE. STATUS OF ACTUAL ANNEX II REVISIONS.
Contents:
Introduction ELV directive
Status 8th Revision of Annex II
Next Revisions
Conclusion
Page 2Joint Industry Association Experts Groups Heavy Metals
Page 3
EUROPEAN END OF LIFE VEHICLES DIRECTIVE 2000/53 EC.MATERIAL RESTRICTIONS.
… 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;
§ 4.2
Joint Industry Association Experts Groups Heavy Metals
Page 4
…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;
…
§ 4.2 (b)
EUROPEAN END OF LIFE VEHICLES DIRECTIVE 2000/53 EC.ARTICLE 4.2 MATERIAL RESTRICTIONS.
Joint Industry Association Experts Groups Heavy Metals
Page 5
REVIEWS ELV ANNEX II.
DEVELOPMENT SINCE YEAR 2000.
3. Revision2008/689/ EC
Aug.
2008
23
Directive 2000/53/ EC
Sept.
2000
13Amount of
Exemptions
Date
4. Revision 2010/115/ EU
Feb.
2010
31
8a -> 10 subentries
8a,c,d,e,f,g,h,
8b -> 8i, j
5. Revision2011/37 EU
March 2011
36
10 ->
10a,b,c,d
2. Revision2005/673/ EC
Sept.
2005
21
„repair as
produced“
principle
1. Revision2002/525/ EC
June
2002
22
background
concentration
levels considered
7. Revision
May
2016
37
8. Revision
Oct
2017 ?
?
2019 ?
9. Revision6. Revision2013/28 EU
May
2013
36
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)
(EU) 2016/774
Draft
21.3
2017
Trend: Split of entries, more application specific scope
Review
scheduled for
entries
8e,
8f(b)
8(g)
Joint Industry Association Experts Groups Heavy Metals
Page 6
8TH REVISION OF ELV ANNEX II.
LATEST DRAFT VERSION OF MARCH 2017.
Source: Ref. Ares(2017)1520534 - 21/03/2017
Joint Industry Association Experts Groups Heavy Metals
Draft Amendment
Exemption 3: “ Copper alloys containing up to 4% lead by weight ” review 2021
(1a) Applies to aluminium alloys where lead is not intentionally introduced
but is present due to the use of recycled aluminium.
Exemption 2(c)(ii): “Aluminium alloys not included in entry 2(c)(i)with a lead
content up to 0.4% by weight ” (1a)
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
review 2024
Page 7
8TH REVISION OF ELV ANNEX II.
LATEST DRAFT VERSION OF MARCH 2017.
Exemption 5: “Pb and Pb compounds in batteries” Split in 5(a) and 5(b)
Draft Amendment
Joint Industry Association Experts Groups Heavy Metals
Source: Ref. Ares(2017)1520534 - 21/03/2017
(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).
Exemption 5(a): “ Lead in batteries in high voltage systems (2a) that are
used only for propulsion in M1 and N1 vehicles ”
review 2021
expires for vehicles
type approved after
1 January 2019
Exemption 5(b): “ Lead in batteries for battery applications not included
in entry 5(a) ”
Page 8
UPCOMING ANNEX II REVISIONS.
Exemption Inspection date
Pb “high melting solder“ (8e) Review
2019 scheduled
Pb “flip chip“ (8g) Review
2019 scheduled
Pb “lead in compliant pins … other than the mating area of
vehicle harness connectors” 8(f)(b).
Review
2019 scheduled
Pb “aluminum alloys 0,4% Pb“ 2(c)(i) 2021 ?
Pb “copper alloys 4% Pb“ (3) 2021 ?
… others ? 2021 ?
Pb „laminated glazing“ (8j) Type aproval before
1.1.2020
Expiring exemption
Joint Industry Association Experts Groups Heavy Metals
Page 9
VIEW TO ROHS.MANY ENTRIES UNDER REVISION - EXAMPLES.
Within current RoHS revisions consultant suggested split of exemptions and early reviews.
The affected industry asks to extend review dates and rejects splitting.
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
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
Similar
exemptions,
but
Joint Industry Association Experts Groups Heavy Metals
Page 10
CONCLUSIONS.
The draft for the 8th 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.
Joint Industry Association Experts Groups Heavy Metals
Back Up Slides
Page 12
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 13
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…..
Source:http://ec.europa.eu/smart-regulation/roadmaps/docs/2015_grow_050_refit_chemicals_outside_reach_en.pdf last accessed 16.May 2017
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)
…
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)
…
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)
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