Automotive Supply Chain impacts of CSS - Chemicals Strategy for Sustainability Marco Buczilowski / CLEPA Faurecia Innenraum Systeme GmbH - AIAG.org
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Automotive Supply Chain impacts of CSS
Chemicals Strategy for Sustainability
Marco Buczilowski / CLEPA
Faurecia Innenraum Systeme GmbH
CLEPA EG Materials & Substances How we are organized!
European Green Deal
The president of the European Commission, Ursula von der
Leyen, stated that the European Green Deal would be
Europe’s “Man on the Moon moment", as the plan would
make Europe the first climate-neutral continent by 2050!
The European Green Deal is also the lifeline out of the COVID-19 pandemic.
One third of the 1.8 trillions euro investments from the NextGenerationEU Recovery Plan, and the EU’s
seven-year budget will finance the European Green Deal.
Today´s subject-matter is about what´s worth to be considered and funded as ´green technologies´!
Taxonomy
European Green Deal Source: Survey in support of the Commission services' work on the definition of Safe and Sustainable by Design criteria for chemicals and materials With the European Green Deal (COM 2019/640), the European Commission outlines its vision to make the European economy and society more sustainable. Great attention is paid on how to achieve climate neutrality, circular economy, biodiversity protection, and a zero-pollution ambition for a toxic-free environment. One of the priorities is to protect citizens and the environment against the negative impact of hazardous chemicals, materials and products and to encourage safe and sustainable alternatives. In October 2020, the Commission adopted the Chemicals Strategy for Sustainability (COM 2020/667), one of the steps towards a zero-pollution ambition for a toxic-free environment announced in the European Green Deal. The Zero Pollution action plan (COM 2021/400) was published in May 20021.
European Green Deal→ CSS
• The Chemicals Strategy for Sustainability (CSS) is an integral part of
the Green Deal
• CSS is mainly linked to “A
zero pollution ambition
for a toxic-free
environment”
– EU REACH relevance
– …
• Some aspects also related
to circular economy
– EU ELV
– Battery Regulation
– …
CSS - EU COM’s objectives • The European Commission presented its main objectives in 2020… • … and a plan with 56 actions!
CSS – 4 key initiatives • Revision of REACH (Regulation No 1907/2006 on Registration, Evaluation, Authorisation and Restriction of Chemicals) • PFAS Action plan • Safe-and-Sustainable by Design Criteria • Sustainable Product Initiative
REACH (1) – Revision process
• Timeline
Today CSS changes
Risk based regulation Hazard based regulation
– Consultation on initial roadmap – June 2021 (Restriction only if risk is
proven)
(Restriction without proven
risk)
– Public consultation – Q1-2022 Subsitution with sufficient lead
time
Subsitution within month
– Planned adoption – Q4-2022 Substance by substance Thousands of substance
restrictions restrictions at once
Several hundred substances Additionally up to 8000+
restricted in vehicles substances to be restricted
• Main changes under discussion Exemptions based on soft Exemptions only if use is
criteria essential
– Definition of Essential Use No requirements on substance Limitation in substance /
– Group restrictions / material selection material selections
– … No product design
requirements
Sustainablility product design
requirements
Protection of confidential Less protection of confidential
Business Information (CBI) Business Information (CBI)REACH (2) - Group restriction
• Some stakeholders would like that Restriction of substances is not done for
each single substance but for full Substances Groups
– Example: 5 MS shared the evaluation of >4000 PFAS´s
– 100-1000s of substances to be assessed in a single procedure
– Same duration as for single substances…
– …critical to industry to evaluate its impact, to report and substitute, if
possible
• Substances are planned to be restricted or regulated based on hazard
properties only instead of current risk-based approach
– Restriction without proven riskREACH (3) - Essential use
• Discussion started in different circles
– Criteria !?
– Should it be applied to Substances and/or Products, as well !?
• DG Growth tend to substances whereas DG Env may focus on article and substances
• Auto Industry’s position
– Essential use should be applied/evaluated on substances level
– Take into account the actual availability of substitutes
– Criteria should be transparent and unambiguous, as well as change management
– General exemption for spare parts and remanufacturingPFAS action plan (1)
• Initial built on a hazard-based approach
• Group of 4700 substances to be assessed
– Many automotive applications
– Precise nature and concentration not always known
– No exhaustive list of Substances
– Not all CAS-No. knownPFAS action plan (2)
• Process led by five EU Member States
– REACH Annex XV Restriction Dossier
– Second call for evidence closed on 17/10/2021
– Questionnaire: 150 pages!
• Topics: transportation, lubricants, TULAC, F-Gas, electronics/energy,
metal plating…
• Outcome expected in 2023Safe-and-Sustainable by Design (1)
• Presented as an approach to the design, development and use of
substances, materials and/or products that focuses on providing a
function (or service), while reducing harmful impacts to human
health and the environment.
– Main expected impact = future regulation(s) or basis for them
– The initiative is piloted by DG Research and InnovationSafe-and-Sustainable by Design (2)
• Idea´s on Safe & Sustainable by Design Criteria / Principals
– Maximize renewables
– Efficient design
– Minimize toxicity
– Safe production
– Minimize waste
– …Safe-and-Sustainable by Design (3)
• First mapping of criteria
• Chemicals and materials are in
general addressed as part of the
final product
• Chemicals are addressed in
terms of the level of hazard to
human health or to the
environment
CLEPA will monitor developmentsSustainable Product Initiative
• Major part of the Sustainable Product Initiative (SPI) = revision of the EU Eco-design Directive
• Although automotive applications are not in the focus, there may be indirect impacts
− Legal or regulatory provisions introduced here could then be extended to the
automotive sector
▪ Labelling based on carbon footprint
▪ Digital product passport
▪ Wider scope of information sharing along the supply chain
• Initiative to be monitored
• Commission’s adoption expected by end of 2021…and the Member States ?
• Germany has applied its Supply Chain Due Diligence Law
– Hugh impact on reporting & tracking for industry
• French Circular Economy Law to inform Comes into force on January 1st 2022
consumers, producers and importers on product Obligation to make available information allowing the ED
environmental content, including identification in a product (substance, mixture or article according to
• Recycled content REACH definitions) placed on the market
• Durability
• Use of sustainable materials
• Reuse Comes into force on January 1st 2022
preventing lost of plastic pellets in industrial environment
• Dangerous substances
Target industrial sites where pellets are produced and used above
• Strategic materials, including Rare earth quantities above 5 tons.
• Electronic information possible Audit by certified body every 3 yearsConclusion • The Chemicals Strategy for Sustainability is a game-changer for Industry • Main consultation activities will happen until 2022 • Huge work in terms of assessment and formal documents to be submitted • Collaboration across the value chain is imperative at worldwide level
The End !? Thank you very much ! marco.buczilowski@faurecia.com
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