EU ELV Annex II Status

Transcription

1 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

2 OVERVIEW EU ELV Annex II Status of Revisions Introduction ELV Directive Heavy Metals Ban and Annex II Revisions o o 8. Revision Annex II released Upcoming Revisions 9. Revision 10.Revision Revision of ELV Directive Other Topics o o o Material Compliance Market Surveillance Reach: Metallic Lead Proposed as SVHC Summary and Conclusion 2

3 INTRODUCTION ELV Directive 2000/53 EC Article 4.2 Material Restrictions 4.2a Mercury in HID bulbs Lead in solder Lead as additive in elastomers Cr(VI) coating 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

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/ Revision (EU) 2017/ Revision 10. Revision Date Amount of Exemptions Sept June Sept Aug Feb March May May Nov ? 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) 2c split 5 split Review scheduled for entries 8(e) 8f(b) 8(g) Trend: Split of entries, more application specific scope 4

5 8 TH REVISION OF ELV ANNEX II Published Autumn Source: (EU) 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 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. 5

6 8 TH REVISION OF ELV ANNEX II Published Autumn Exemption 5: Old exemption Pb and Pb compounds in batteries was split into 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, , p. 10). 6

7 ANNEX II REVISIONS 9 &10 After revision is before next revisions New revisions are yet scheduled : Source: Wikimedia Commons, free media archive 7

8 9 TH REVISION OF ANNEX II 3 entries scheduled for review by (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 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

9 9 TH 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

10 9 TH REVISION OF ANNEX II 8(g). Lead in solders for Flip Chips 1) Required information 1) Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit flip chip packages - 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) 10

11 9 TH 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) 11

12 10 TH REVISION OF ANNEX II Scheduled 10 th revision looks similar to 8 th revision o o o 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) Further revision of entries possible Last consultant report addressed a lot different items to be investigated for next revision 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

13 9 TH & 10 TH 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. 13

14 END 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. 14

15 REVISION 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 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. 15

16 MATERIAL COMPLIANCE Developments: More reporting obligations for material compliance in many markets Disclosure of substance uses Intensified market surveillance e.g. in Asia and Europe 16

17 EU MARKET SURVEILLANCE IN UPDATE EU WTO Notification of Regulation G/TBT/N/EU/ February 2018 Proposed Regulation ((2017/0353 (COD) ) 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 entering the Union market. 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; 17

18 METALLIC 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. 18

19 HEAVY METALS EMISSIONS EU source: 19

20 CONCLUSIONS. 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. 20

21 Back Up Slides

22 BACK UP INFORMATION Sources: Draft regulation laying down rules and procedures for compliance with and enforcement of Union harmonisation legislation on products ; last accessed ECHA REPORT REF-4 REACh Annex XVII market surveillance published ; last accessed Revision of Annex II ELI: last accessed COMM webpages Waste package: EUROSTAT webpages 22

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