CLEPA Materials Regulations Event 2018 Stuttgart, 18 & 19 April 2018
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CLEPA Materials Regulations Event 2018 Stuttgart, 18 & 19 April 2018
Marco Buczilowski - FAURECIA
Oliver Schmid - HELLA
Hannes Stradner - MAGNA
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 2
Marco Buczilowski - FAURECIA
CLEPA Materials & Substances WG
ELV Annex II exemptions 8 & 10
GADSL + n
Chemistry Manager
Where-used-analysis
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 3
WG EE Materials & Substances
Chair: M. Buczilowski - FAURECIA
Co-chair: F. Coene - AISIN
Inputs
topics/Regulations
Declaration
Regulations
(tools)
M. Buczilowski - REACH like Material L. Käseberg -
FAURECIA Regulations Reporting Lumileds
S. Assmann - BOSCH ELV GADSL S. Dully - DuPont
Conflict
D. Eggeling - HUF
Minerals
Other monitoring
topics
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 4
REACH like Regulations:
REACH EU TSCA Other monitoring topics:
REACH non- Circular
POP - EU
EU Economy
(Critical LCA VIAQ
Raw
International
BPR Materials)
Conventions
California
ELV Basel
proposition
Convention
65
Minamata
Non-EU ELV
(monitoring)
Conflict Minerals
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 5
Material Reporting
IMDS - Where Used IMDS - Chemistry
Analysis Manager
Recommendation
New Release
Rev.
CAMDS GADSL +n
GADSL GLAPS
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 6
Steering Committee
Sylvia Assmann Lutz Käseberg
Hugues Boucher FIEV
BOSCH LUMILEDS
Michael Jeppe
Dennis Eggeling HUF Frederic Coene AISIN
ZF
Marco Buczilowski Hannes Stradner
Stefan Dully DUPONT
FAURECIA MAGNA
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 7
ELV Annex II exemptions 8 & 10 Result of the 8th revision: Revised Annex II has been published and became effective December 6th 2017: link Exemption 3: “Copper alloys containing up to 4% lead by weight” review 2021 Exemption 2(c)(i): “Aluminum alloys for machining purposes with a lead content up to 0.4% by weight” review 2021 Exemption 2(c)(ii): “Aluminum alloys not included in entry 2(c)(i) with a lead content up to 0.4% by weight” review 2024 Exemption 5(a): “Lead in batteries in high voltage systems (2a) that are used only for propulsion in M1 and N1 vehicles ” expires for vehicles type approved after January 1st, 2019 Exemption 5(b): “Lead in batteries for battery applications not included in entry 5(a)” review 2021 Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 8
Getting prepared for 9th revision of ELV
There are 3 ELV exemptions which are subject to revision in 2019:
Exemption
Pb “high melting solder” (8e)
Pb “connectors” (8f (b))
Pb “flip chip” (8g)
General statements:
• Task of the WG is to prepare an application document for the revision of EU ELV exemptions
on behalf of the Automotive Industry WG (ACEA, JAMA, KAMA, CLEPA)
• The document will have to be aligned and approved by the above mentioned Associations
Goal is:
• to reach a mutual understanding and a common document for all participants
• to have a document ready by July 2018 latest
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 9The ELV evolution – what is coming up next
•Priority waste stream strategy of EU Commission •5th revision of Annex II (2011/37/EC)
✓„…. both the quantity and the toxicity of waste for landfill should be ✓36 exemptions listed in „Annex II“
reduced …”
1990 ✓ELV one of the prioritized waste streams
2011 ✓Glass & Ceramic „split off“ and expiry dates
•Treaty of the European Union (amended in 1997) •6th revision of Annex II (2013/28/EC)
✓ Union policy on the environment shall contribute to …
▪protecting human health, 2013 36 exemptions listed in „Annex II“
1997 ▪prudent and rational utilization of natural resources
▪available scientific and technical data to be taken into account
•ELV Directive (2000/53/EC) •7th revision of Annex II (2016/774/EC)
✓Ban of Pb, Cd, Hg & Cr6+ ✓Revision of exemptions 8e, f, g, h, j (solder), 10d
✓13 exemptions listed in „Annex II“ 2016 (ceramic)
2000 ✓Recycling & Recovery Quota per vehicle
•8th revision of Annex II
•1st revision of Annex II (2002/525/EC)
✓22 exemptions listed in „Annex II“
Revision of exemptions 2c (Aluminum), 3 (Copper), 5
▪Improvements to 2000 version 2017 (Batteries)
2002 ▪Expiry date for e.g. Pb in Carbon Brushes (2003), Cr6+ (2007)
•2nd revision of Annex II (2005/673/EC)
✓21 exemptions listed in „Annex II“
•9th revision (8e, 8f, 8g)
•Commission Decision 2005/438/EC 2019
2005 ✓„Repair as Produced“ principle for spare parts
•3rd revision of Annex II (2008/689/EC) •10th revision (2c(i), 3, 5b)
2008
✓23 exemptions listed in „Annex II“
✓Solder „split off“ and expiry dates
2021
•4th revision of Annex II (2010/115/EC)
✓31 exemptions listed in „Annex II“ •11th revision (2c(ii))
2010 ✓Further Solder „split off“ and expiry dates 2024
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 10GADSL+n ✓ GADSL is overall accepted and fully integrated in IMDS ✓ GADSL reflects all substance regulations relevant for automotive components ✓ GADSL is regularly maintained and updated ✓ IMDS rules clearly refer to GADSL ➢ CLEPA members observe many cases of restricted substance lists in addition to the GADSL (“GADSL+n”) ➢ These requirements are very difficult to handle (not possible in IMDS) ➢ This leads to reporting obligations outside of IMDS > higher burden, not manageable for entire supply chain Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 11
GADSL+n
- CLEPA and JAPIA members unanimously support the use of
the GADSL and IMDS
- Automotive companies should refer to the GADSL only
- Any substance which is considered declarable should be
added to the GADSL
- Automotive companies should use the official application
via a dossier to Global Automotive Stakeholders Group
(GASG) to have substances added to the GADSL
Link to official CLEPA/JAPIA position paper:
https://clepa.eu/mediaroom/company-specific-substance-restrictions-addition-gadsl/
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 12Chemistry Manager I
Misunderstanding of IMDS and Chemistry Manager:
Suppliers were asked to provide:
Documentation that all biocides are Information on biocidal active
approved to the EU Regulation by substances via IMDS and the new
filling out the attached form. Chemistry Manager tool.
Additional paper work “IMDS+n-request”
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 13Chemistry Manager II
☺
Chemistry Manager is available for all IMDS users (along the supply chain),
so there is no need to ask for biocide information separately via
e-mail
☺
Information can be obtained via IMDS - Chemistry Manager tool directly by
requestor
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 14Chemistry Manager III Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 15
Enhanced Where-Used Analysis
Proposed enhancements for the Where-Used Analysis:
• Adjustable threshold (26th October 2017: first presentation of this proposal to IMDS SC; F2F in
Bad Homburg/Germany)
• threshold settings (like application codes)
• Inbox/Outbox
✓ reports should be possible for both received (per Org.-Unit) and sent/own MDS
✓ additional functionality
• no limitation to 500 hits (both online and export file)
• merge/rearrange “REACH like” analysis types
✓ substances group REACH shows Annex XVII search
✓ substance list allows Annex XIV search
✓ SVHC list under GADSL category
Improve legal compliance in the supply chain and on the customer side!
To ease analysis, shorten answering time and to improve data quality/ maintenance!
Majority of the supply chain (SMEs up to Tier1) uses and relies on the IMDS online system and
its functionalities!
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 16Enhanced Where-Used Analysis
Adjustable threshold settings in IMDS legacy
(like application codes)
Today
Proposal
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 17Enhanced Where-Used Analysis
Merge/rearrange “REACH like” analysis
Analysis Type Additional Parameter comment
Basic Substance Biocides (GADSL) In total 40 options given
REACH Annex XIV
REACH Annex XVII (Automotive)
REACH SVHC
Basic Substance List Biocides (GADSL) In total 9 options given
REACH Annex XIV
Basic Substance Group REACH Annex XVII (Automotive) In total 32 options given
GADSL Category REACH SVHC
Confidential Substance REACH SVHC
Multiple options given, lot of overlap
(analysis evolved over time based on additional requirements)
It´s time to review and to streamline and simplify!
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 18Actual Status
Proposal of the CLEPA IMDS Experts Group well received by the IMDS SC
• Assessment / evaluation done by DXC
• Feedback from DXC from February 2018 overall positive
✓ Proposed changes are possible from a technical perspective
✓ Implementation would need design, programming and testing
✓ Possible changes will have to be implemented in IMDS enhancements for
release 12.x
• CLEPA IMDS Experts Group re-emphasizes proposals to IMDS SC in April 2018
IMDS SC decision needed!
CLEPA IMDS Expert Group open for further discussions and support!
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 19Oliver Schmid - HELLA
Conflict Minerals
Nickel
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 20Conflict Minerals (EU)
EU regulation No. 821/2017
Obligations come into force by January 2021
Main CLEPA concern: Conflict Countries not explicitly defined in the legislation
European commission drafts a handbook to help the companies to define the conflict
countries by themselves. In addition, a „non-exhaustive list of conflict countries“ will be
provided
Publication date of handbook and „non-exhaustive list of conflict countries“
expected soon
CLEPA Conflict Minerals Expert Group closely follows the further evaluations on this topic.
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu
21Conflict Minerals (USA)
Responsible sourcing of Cobalt
Public discussion driven by NGOs
Pilot phase with new Cobalt Reporting Template (CRT) running untill October
2018. Developed by the Responsible Minerals Initiative (RMI), formerly known as
CFSI
Company Apple conducted first audits in the supply chain regarding Cobalt.
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu
22NICKEL RESTRICTION IN VEHICLE KEYS?
Not in scope anymore
EU REACh legislation 1907/2006, Annex XVII, No. 27
Consequences for vehicle keys according to guidance document
Basic condition for products in scope (ECHA definition):
Continuous (UNDISRUPTED) contact of 30 min. on 1 or more occasions within
2 weeks
Continuous (UNDISRUPTED) contact of 10 min. on 3 or more occasions within
2 weeks
Small CLEPA Adhoc Group was formed
CLEPA created a joint position paper of the automotive industry together with
ACEA
Industry position was submitted to ECHA
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu
23NICKEL RESTRICTION IN VEHICLE KEYS?
Not in scope anymore
CARACAL (Competent Authorities for REACH and CLP) concluded, that KEYS ARE OUT OF SCOPE, but
still discuss if key rings, key chains and key fobs are in scope (final decision expected June 2018)
CLEPA position: KEY RINGS, KEY CHAINS AND KEY FOBS NEED TO BE CONSIDERED OUT OF SCOPE, TOO
Key ring
Key chain Key fob
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu
24Hannes Stradner - MAGNA
REACH declaration
REACH 2018
Brexit in view of REACH
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 25REACH declaration I
Misunderstanding of SVHC development
Supplier was asked for written confirmation, that his products do not
contain a SVHC substance or that the percentage of SVHC substances listed
in the product is less than 0.1% by weight.
There is no legal certainty about substances which will be put on
Candidate List. Any upcoming risk will be on supplier’s shoulder.
Additional paper work “IMDS + n-request”
☺
Legal demand (REACH Article 33)
for SVHC (on Candidate list) > 0.1 % (w/w)
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 26REACH declaration II Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 27
REACH 2018 – Top issues for Automotive Suppliers (I)
Registration Deadline 2018
• Identification of REACH roles
• Awareness letter to supply chain
• Request for proactive information in terms of non-registration
intention to avoid supply chain disruption
Substances without unique identifiers
• Candidate List & Annex XIV substances published on ACEA Website
incl. EC/CAS numbers
• List available under http://www.acea.be/news/article/reach-
substances-without-unique-identifier
Compliance to Restriction & Authorisation
• Substance identification for process chemicals, auxiliary means etc.
via Safety Data Sheets
• Substance identification for articles via IMDS Material Data Sheets
• Compliance checks on authorisation/restriction requirements
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 28REACH 2018 – Top issues for Automotive Suppliers (I)
Substances in articles
• Identification of SVHC and article level
• Identification of communication and notification obligations
• ECHA Guidance on requirements for substances in articles
Management of Safety Data Sheets (SDS)
• REACH enforcements of Downstream User with focus on SDS
management
• Quality, classification and plausibility check of SDS
• AI Guideline on SDS Compliance checks
Automotive Industry Guideline on REACH
• New version 4.0
• Available on ACEA Website
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 29Brexit in view of REACH
CLEPA statement on Brexit in view of REACH
- Uncertainty remains regarding the final exit deal
- Task Force lead by SMMT
- CLEPA statements on Brexit in view of REACH
CLEPA Members support ‘soft’ Brexit by retention the
status quo
Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu 30THANK YOU FOR YOUR ATTENTION CLEPA Materials Regulations Event 2018 Copyright © 2018 CLEPA. All rights reserved. www.clepa.eu
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