GLOBAL TRENDS IN REGULATIONS ON LEAD - OVERVIEW. Steve Binks, Regulatory Affairs Director INTERNATIONAL LEAD ASSOCIATION JUNE 2017

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1 GLOBAL TRENDS IN REGULATIONS ON LEAD - OVERVIEW Steve Binks, Regulatory Affairs Director INTERNATIONAL LEAD ASSOCIATION JUNE 2017

2 CHALLENGES FACING THE GLOBAL LEAD INDUSTRY SUBSTITUTION OF LEAD BATTERIES Regulatory Eliminating hazardous substances REACH, ELV, California Green Chemistry Market Changing markets Increased competition Increasing vehicle hybridisation Increasing performance and reducing cost of Li-ion and other technologies LICENSE TO OPERATE Regulatory Disproportionate operating costs Precautionary lead OELs, emissions limits, ambient limits Highly variable standards and enforcement worldwide

3 REGULATORY DRIVERS FOR SUBSTITUTION - EUROPE EU Circular Economy Strategy Promotion of non-toxic material cycles and better tracking of chemicals of concern in products will facilitate recycling EU REACH Authorisation To progressively replaced SVHC s by suitable alternative substances or technologies where economically and technically viable EU REACH Restriction To protect human health and the environment from unacceptable risks posed by chemicals. Restrictions may limit or ban the manufacture, placing on the market or use of a substance EU ELV Directive Bans on the use of hazardous substances / materials - lead; mercury; cadmium; hexavalent chromium - in new vehicles post 1 July 2003 Battery Directive Requires Member States to promote research and encourage improvements in the environmental performance of batteries through their life-cycle, and encourage the marketing of batteries which contain less polluting substances (in particular substitutes for mercury, cadmium and lead)

4 REGULATORY DRIVERS FOR SUBSTITUTION - A REALITY CHECK ELV and REACH Authorisation will result in direct comparison of lead-based batteries with non-lead alternatives REACH authorisation covers both automotive and Industrial ELV restricted to automotive For REACH authorisation application applicants must produce an analysis of alternatives that considers: risks from alternatives, technical feasibility of substitution, and economic feasibility of substitution. For ELV the Commission assess whether the use of lead based batteries can be avoided.(as an alternative lead-free technology exists) does not give grounds for a lead-use exemption to be based on economic arguments but on basis of the unavoidability of the use of lead the existing unlimited exemption for the use of lead in automotive batteries may be coming to an end as there is evidence about the forthcoming market availability of automotive batteries without lead. - TAC 30 th Nov 2015

5 REGULATORY DRIVERS FOR SUBSTITUTION - NOT RESTRICTED TO EUROPE California Dept of Toxic Substance Control Safer Consumer Products Regulations aim to create safer substitutes for hazardous ingredients in consumer products sold in California. DTSC evaluates and prioritizes product-candidate Chemical combinations to develop a list of Priority Products for which a safer alternative should be sought. TSCA Goal to promote the use of safer alternatives and other actions that reduce use of and exposure to hazardous chemical substances and reward innovation toward safer chemicals, processes, and products

6 ECONOMIC DRIVERS FOR SUBSTITUTION - EUROPE 3.6 million To stimulate the competitiveness of eco-innovative SME s looking to launch their product in global markets

7 ARE SUBSTITUTES AVAILABLE? Olife has developed a new car battery that is a milestone in the evolution of the automotive industry. It is the first full substitute for lead-acid batteries and offers many advantages, such as: superb performance, light weight, high range of operating temperatures, ideally suited to start-stop systems, superior reliability and durability, resistance to extreme vibration, starting ability up to 90% DOD (depth of discharge), lead and acid free, non-hazardous and ecofriendly. 12V Li-ion batteries are ready for mainstream adoption. Barriers to mass market adoption have now been addressed: Total value exceeds cost Cold crank performance gaps closed Crash safety proven Under hood positioning possible Battery assembly plant opened in Czech Republic with annual volumes expected to reach 1M units by 2020 A123 AABC Conference Jan 2017

8 The strongest driver for substitution of hazardous chemicals is obviously regulation, or rather anticipation of regulation

9 DISPROPORTIONATE OPERATING COSTS AMBIENT AIR LEVELS/FACTORY EMISSIONS New Paradigm: There is no known threshold for the effects of lead. How low do lead levels in children have to be to be acceptable? EU RAC concluded that 0.05 µg/kg bw/day represents no appreciable risk for children - ECHA This is equivalent to loss of 0.1 IQ points or blood lead level of 0.12µg/dL Current mean blood lead levels in US children (age 1-5) is approx. 0.8µg/dL Level that represents no appreciable risk << current blood lead levels so public health policy pressure likely to continue to effect further reductions Lead in air, drinking water, contaminated land, indoor environments etc will continue to be under spotlight minimising emissions from point sources (including lead battery manufacturing and recycling facilities)

10 DISPROPORTIONATE OPERATING COSTS OCCUPATIONAL EXPOSURE LIMITS New Paradigm: Current workplace exposure limits are not protective of health. How low do lead levels in workers have to be to be acceptable? US ACGIH (2017) PbB of 20mcg/dL Germany AK Metalle (2016) PbB of 15mcg/dL CalOSHA (2015) PbB of <10mcg/dL RAC (2014, Lead chromate sulfochromate yellow authorisation opinion) PbB of 1.2mcg/dL and DNEL of 3.5mcg/m3 (8hr TWA) Proposed health-based limits < current industry performance so occupational health policy pressure likely to continue to effect further reductions

11 Summary We are reaching a critical point in the 150 year old history of lead batteries as mass-market alternatives become a real possibility Direct comparisons of technologies are being made by Regulators with aim of increasing pace of substitution.. Li Additional Regulatory pressure is also being applied in form of significant reductions in workplace and environmental emission limits Pb We need to get much better at making the case as to why lead batteries remain essential, are the most cost effective energy storage solution and are sustainable as all players in the value chain are driving continuous improvement and achieve excellence in environmental, health and safety.

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