EU ELV Annex II Status - Revisions of Annex II STUTTGART - clepa
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EU ELV Annex II Status Revisions of Annex II CLEPA MATERIALS REGULATIONS EVENT 2018 STUTTGART Reinhard Hoock Pilot Expert Group Heavy Metals Tuesday, 17 April 2018
OVERVIEW
EU ELV Annex II Status of Revisions
• Introduction
• ELV Directive
Heavy Metals Ban and Annex II Revisions
o 8. Revision Annex II released
o Upcoming Revisions
9. Revision
10.Revision
• Revision of ELV Directive
• Other Topics
o Material Compliance
o Market Surveillance
o Reach: Metallic Lead Proposed as SVHC
• Summary and Conclusion
2
INTRODUCTION
ELV Directive 2000/53 EC
Article 4.2 Material Restrictions
Mercury in HID bulbs Lead in solder Lead as additive in elastomers Cr(VI) coating
§ 4.2a
… 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.
Annex II is amended on a regular basis according to scientific and technological progress.
…in order to exempt unavoidable uses … or to delete avoidable uses from Annex II.
3
REVIEWS ELV ANNEX II
Development Since Year 2000
Directive 1. Revision 2. Revision 3. Revision 4. Revision 5. Revision 6. Revision 7. Revision 8. Revision 9. Revision 10. Revision
2000/53/ EC 2002/525/ EC 2005/673/ EC 2008/689/ EC 2010/115/ EU 2011/37 EU 2013/28 EU (EU) 2016/774 (EU) 2017/ 2096
Date Sept. June Sept. Aug. Feb. March 2011 May May Nov.
2000 2002 2005 2008 2010 2013 2016 2017 2019 2021 ?
Amount of
13 22 21 23 31 36 36 37 39
Exemptions
background „repair as 8a -> 10 subentries 10 -> 8i exp. date 8f 8f (a) 2c Review
concentration produced“ 8a,c,d,e,f,g,h, 10a,b,c,d revised 8f(b) split scheduled
levels considered principle 8b -> 8i, j 8h end date 5 for entries
8j end date split 8(e)
10d end date 8f(b)
review for 8(g)
entries 8e, 8f(b)
and 8(g)
Trend: Split of entries, more application specific scope
4
TH
8 REVISION OF ELV ANNEX II
Published Autumn 2017.
Source: (EU) 2017 /2096 16.11.2017
Exemption 3: “ Copper alloys containing up to 4% Lead by weight ” review 2021
Old Exemption 2(c) “ Pb in Al < 0,4% ” was split into 2(c)(i) and 2(c)(ii) :
Exemption 2(c)(i): “Aluminium alloys for machining purposes with a Lead review 2021
content up to 0.4% by weight ”
Exemption 2(c)(ii): “Aluminium alloys not included in entry 2(c)(i) with a Lead review 2024
content up to 0.4% by weight ” (1a)
(1a) Applies to aluminium alloys where Lead is not intentionally introduced
but is present due to the use of recycled aluminium.
5
TH
8 REVISION OF ELV ANNEX II
Published Autumn 2017.
Exemption 5: Old exemption “Pb and Pb compounds in batteries”
was split into 5(a) and 5(b)
expires for
Exemption 5(a): “ Lead in batteries in high voltage systems (2a) that are vehicles type
used only for propulsion in M1 and N1 vehicles ” approved after 1
January 2019
Exemption 5(b): “ Lead in batteries for battery applications not included review 2021
in entry 5(a) ”
(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).
6
ANNEX II REVISIONS 9 &10
After revision is before next
revisions…
New revisions are yet
scheduled :
2019
2021
2024
Source: Wikimedia Commons, free media archive
7
9TH REVISION OF ANNEX II
• 3 entries scheduled for review by 2019
8(e). Lead in “high temp. solders” (numerous low amount uses today)
8(g). Lead in flip chips (amount or uses to be clarified)
8f(b). Lead in “compliant pins” (numerous low amount uses today)
It is possible that additional items will be reviewed.
Start of stakeholder consultation is expected for summer 2018.
Three industry experts groups are active under umbrella of CLEPA to be prepared for
the consultation and to work on items addressed in the last consultant report.
The expert group are open for all association members and support is welcomed.
8
9TH REVISION OF ANNEX II
8(e). Lead in high melting temperature type solders
• Required information
- technical / scientific based arguments for need of exemption
- quantities of Lead used for entry 8(e).
typical applications for high melting temperature type solders (source IMDS ELV Annex II Interpretation Guide)
9
9TH REVISION OF ANNEX II
1) Lead in solders to complete a viable
8(g). Lead in solders for “Flip Chips” 1) electrical connection between
semiconductor die and carrier within
integrated circuit flip chip packages
• Required information
- technical / scientific based arguments for need of exemption
- quantities of Lead used for entry 8(g).
typical applications for Lead solder within flip chip packages (source IMDS ELV Annex II Interpretation Guide)
109TH REVISION OF ANNEX II
8(f)(b). Lead in compliant pin connector systems other than the mating area of
vehicle harness connectors
• Required information ”same procedure”
- technical/scientific based arguments for need of exemption
- quantities of Lead used for entry 8(f) (b).
- assessment of potential substitutes
typical applications for Lead in 8 (f) (b) (source IMDS ELV Annex II Interpretation Guide)
11TH
10 REVISION OF ANNEX II
• Scheduled 10th revision looks similar to 8th revision
o Yet fixed is review for entries
#3 Lead in copper alloys
# 2(c)(i) Lead up to 0,4 % in aluminium for machining purposes
#5 (b) Lead in batteries for battery applications not included in entry 5(a)
o Further revision of entries possible
o Last consultant report addressed a lot different items to be investigated for next revision
o Industry expert groups under umbrella of ACEA, JAMA, KAMA,VDA and well supported by further
associations and as well by material or component producers are active to prepare the answers for the
given tasks.
o If you would like to support the working groups contact your association. Support with technical expertise
is very welcomed.
• Start of stakeholder consultation is expected for summer 2020.
129TH & 10TH REVISION OF ANNEX II
o In case of missing convincing technical, scientific based information,
an exemption will be terminated.
o A big thank you to all who are supporting with their expertise the
drafting of the applications for the stakeholder consultations.
13END NEAR FOR LEAD BASED SOLDERING
source: WIKI commons Sanduhr
In volume production for EU vehicle production supply chain should be aware
that Lead-based soldering of electronic circuit boards is a phase-out model.
Availability of components suitable for Lead-based soldering may also become
challenging.
14REVISION OF ELV DIRECTIVE ANNOUNCED
• In a congress presentation from the EU COMM from March 2018 availability of a
review proposal for the ELV directive was announced for end of 2020.
More details are said to be included in waste package (adoption expected in April
2018).
Further statements:
“ELV directive De facto: an instrument to drive circularity in the automotive sector”
“Reduction of hazardous substances largely achieved”
• It is assumed that beginning of 2020 more information on the scheduled ELV directive
review will be available. Changes in the directive before that time are not very likely.
15MATERIAL COMPLIANCE
Developments:
• More reporting obligations for
material compliance in many
markets
• Disclosure of substance uses
• Intensified market surveillance
e.g. in Asia and Europe
16EU MARKET SURVEILLANCE IN UPDATE
EU WTO Notification of Regulation G/TBT/N/EU/542 16 February 2018
“Article 1 Subject matter
“…rules and procedures for the provision of compliance information about
certain products, …
…harmonising the conditions for the marketing of those products.
…framework for cooperation with economic operators …
This Regulation also provides a framework for controls on such products
Proposed Regulation entering the Union market. ”
((2017/0353 (COD) )
… “Article 3 Definitions
For the purposes of this Regulation, the following definitions shall apply:
(1) ‘making available on the market’ means any supply of a product for
distribution, consumption or use on the Union market in the course of a
commercial activity, whether in return for payment or free of charge;
(2) ‘placing on the market’ means the first making available of a product on
the Union market;
(3) ‘market surveillance’ means the activities carried out and measures taken
by market surveillance authorities to ensure that products comply with the
requirements under Union harmonisation legislation and do not endanger
health, safety or any other aspect of public interest protection;
17METALLIC LEAD PROPOSED AS SVHC UNDER REACH
Metallic Lead is proposed by Swedish authority KEMI to be put on SVHC list of REACH.
Intention: - Knowledge of Lead uses
- Triggering of substitution
Both targets are achieved for vehicles yet today via ELV directive material restrictions.
- Known uses: Look into Annex II is sufficient
- Substitution: Yet ongoing since 15 years
Is there a need for more EU Legislation on Lead in Vehicles ?
How to avoid double regulation ?
This and other questions will be part of an ACEA /Joint Associations statement to
current stakeholder consultation.
18HEAVY METALS EMISSIONS 1990 – 2016 EU
source: https://www.eea.europa.eu/data-and-maps/daviz/emission-trends-of-heavy-metals-6#tab-chart_3
19CONCLUSIONS.
Annex II Revisions will be ongoing. Currently 39 sharp cut exemptions allow limited HM uses.
Without giving evidence in stakeholder contributions for their need, and based on solid and
convincing technical arguments, the exemptions will be deleted.
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 has started.
The joint associations industry expert groups are open to welcome new members.
20Back Up Slides
BACK UP INFORMATION
Sources:
Draft regulation laying down rules and procedures for compliance with and enforcement of Union harmonisation legislation on products
http://ec.europa.eu/transparency/regdoc/rep/1/2017/EN/COM-2017-795-F1-EN-MAIN-PART-1.PDF ; last accessed 03.04.2018
ECHA REPORT REF-4 REACh Annex XVII market surveillance
https://echa.europa.eu/documents/10162/13577/ref_4_report_en.pdf/b53f5cd9-64a4-c120-1953-e9e176b9c282
published 8.2.2018; last accessed 19.2.2018
8 Revision of Annex II
ELI: http://data.europa.eu/eli/dir/2017/2096/oj last accessed 03.04.2018
COMM webpages
http://ec.europa.eu/environment/circular-economy/index_en.htm
http://ec.europa.eu/environment/waste/target_review.htm
http://ec.europa.eu/environment/waste/elv_index.htm
Waste package: http://data.consilium.europa.eu/doc/document/ST-6514-2018-INIT/en/pdf
EUROSTAT webpages
http://ec.europa.eu/eurostat/data/database
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Thank you for your attention www.acea.be @acea_eu
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