To: European Commission, DG Environment, Unit A2 – ELV...

GM-OPEL Introduction.doc

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To: European Commission,

DG Environment, Unit A2 – ELV – Annex II Consultation, B-1049 Brussels

Belgium Email: [email protected]


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INTRODUCTION TO THE STAKEHOLDER CONSULTATION ON THE PREPARATIONS OF A REVISION OF

CERTAIN ENTRIES OF ANNEX II OF DIRECTIVE 2000/53/EC General Motors (GM) actively supports environmental policy efforts to design products free of hazardous substances and as environmentally sound as possible. We have set up internal goals and environmental guidelines regarding the product as well as the production processes even prior to the publication of the ELV directive General Motors agrees upon the minimization of negative environmental impacts during all phases of a vehicle life. In order to reach this common goal to manufacture, market, operate service and recover a product with as little as possible impact to environment or human health, the exact environmental impact, the relevance of certain substances and their technical and economical implications need to be understood prior to mandating substance restrictions. This is the reason why the definition of balanced policy measures needs to be based on a thorough risk assessment as well as on a thorough business impact assessment. Since July 01, 2003 the substance restrictions on heavy metals, based on the “precautionary principle”, are in effect and General Motors together with their global supply base could meet the Heavy Metal Ban so far. As self-responsible partners to GM, our suppliers are affected in a special way, having to deal with their global supply chain, sometimes down to the raw material basis. The challenge for the supplying industry is to inform their lower tier suppliers as well as changing well proven, quality optimised designs according to the new requirements. During this process some unclear definitions of exemptions in Annex II are the reason for different interpretations and have caused a situation of legal uncertainty in some areas. Many negotiations and action plans to change the affected parts have could only be done with support of the legal staff. During the identification phase of Heavy Metal affected components, parts and materials the automobile manufactures and the supply base worked closely together to achieve compliance in time. Within this phase we all learned from each other and exchanged knowledge what the substitute or alternative would be. Continuing the process of implementing the provisions of Article 4(2)(a) of the directive 2000/53/EC, the upcoming phase out dates of exemptions mentioned in Annex II of the directive have been assessed again in depth. Even though we have been already successful in developing some substitutes (e.g. Lead in PVC, wheel balance weights) or is confident to have them developed in time (e.g. valve seats, stabilizer in protective paints) we are still facing a number of problems to get substitutes or alternatives ready for implementation in our vehicles without risks for safety and reliability of our products. The continued improvement of the overall environmental performance of products and production processes requires that we are assessing as well the environmental performance of substitute materials to allow long lasting decisions for optimized


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materials in each application. Not only GM, the entire industry, however, need a reliable planning basis for these substitute materials for at least one development cycle of a cars regarding the future plans and commission decisions. As a result of the internal assessments there are some indications, that for a number of exemptions the phase-out of heavy metals will need a longer period of time than currently foreseen. Attached you will find a proposal of General Motors, based on our current knowledge, for a revision of the Annex II by end of 2004. It is our aim to improve the definitions of exemptions and phase-out dates in order to achieve a high level of legal certainty and to guarantee a continued production of safe and reliable vehicles for the European market. GM would welcome to have open discussions with the commission and to provide further information on the subjects mentioned above. As stated in the introduction of the stakeholder consultation document, the directive 2000/53/EC on end-of life vehicles is based on the prevention of waste from vehicles. This clearly states that the focus is on the conception of new vehicles and the possible release of heavy metals to the environment this means causing negative impact to the environment. This position is at our opinion in line with parliament and council decisions. General Motors and all its Brands take the challenge to transfer the material restrictions into all new products. It is up to the commission to resume and to ask for the overall environmental and socio-economic benefit achieved for each application.

With the document below GM participates also on the EU Commission (DG-ENV) stakeholder-consultation. GM strongly believes, based on the experience with the Heavy Metal Ban so far, that a revision of all entries at this point in time will result in a more workable future oriented Annex II. Detailed reasons for this are described in separate attachments. Especially the availability of new spare parts for the car stock will be addressed again. Best regards Harald F. Schenk Rüsselsheim, March 24, 2004

Attachment 10 According to Directive 76/769/EC and based on scientific risk assessment some acceptable and useful threshold values have already been established for all listed hazardous materials. These values are incorporated in producer internal standards or e.g the VDA-list 232-101 or similar lists (automotive substance negative list). Below this concentrations, risks for environment and human health are not known and can be considered as not evident according to existing scientific knowledge. More stringent regulations are currently not necessary. A distinction between substances intentionally or not intentionally added below this threshold values are therefore insignificant. The remark 1 in Annex II should be revised accordingly. A policy of consistent threshold values should be considered within the EC, also with regard to the EU-chemical policy.

GM-OPEL answers to consultation document.doc

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GM Proposal for Annex II Revision 4.1. Review of entries 2 (a) and (b): exemption for the use of lead as an alloying element in aluminium for machining purposes with a lead content up to 2% by weight until 1 July 2005 and with a lead content up to 1% by weight until 1 July 2008.

Question 1: Are there currently leaded aluminium alloys with more than 1% lead by weight put on the market? If so, in which applications? What are the predicted market evolutions for the next 5-10 years? Answer 1: Yes.

Some aluminium grades acc. to international, regional or national standards (e.g. AA, EN 573-3, DIN) have an Al content up to 2% lead by weight for machining purposes. These grades are still required within the automotive industry for several safety related parts e.g. brake system, steering system, chassis and powertrain parts. These grades are also used in other industries and a phase out for only one industry sector is not possible in a short time frame. These Al-grades are needed also for the next 5 to 10 years. However, the application patterns of these alloys are predicted not to increase. Most of the casting alloys, or Al sheet metal are already below the 1% limit. Compared to the total lead content in Al we are talking here about a few % of affected parts.

Question 2: Are there any technical impediments to phase-out the use of leaded aluminium alloys? If so, for which applications? Answer 2: Yes.

The metal producing industry considers still Tin (Sn), Antimony (Sb) or Bismuth (Bi) as possible substitutes, where the focus is on Sn, for some applications, but it is not clear if AlSn alloys can substitute AlPb alloys for all intended applications. Pilot runs and components tests at suppliers confirmed this and reported that those AlSn alloys did not meet all corrosion and durability requirements for applications as listed in answer 1. E.g. in the brake systems and fuel system especially when alternative fuels are added or used (e.g. ethanol). Only if all requirements of substitute alloys can be met, we can apply these. We should not restrict ourselves in the future use of more alternative additives to fuel.

Question 3: Is the scheduled phase-out date (1 July 2008) feasible? If not, please give detailed reasons and specify for which applications this is not feasible. Answer 3: No.

At this point in time it seems not feasible to phase out Al-alloys for safety related parts e.g. brake system, steering system, chassis and powertrain parts. A detailed analysis should be made what the implications are to the total supply chain, especially to small enterprises. The global availability of alternative alloys meeting all requirements is still not ensured.


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Question 4: If the scheduled phase-out date is not feasible (for certain applications), which phase-out date would be appropriate? Answer 4: No phase out date at all is recommended at this point in time. Lead is fully inert in the Al-

matrix, is not water-soluble, cannot be released into the environment and is finally going with the non-iron metal fraction to the Al-mills and to the remelting process. A review date for this entry is recommended again for 2008. After a re-assessment in 2008 a reduction to 1.5% might be possible.

4.2. Review of entry 7: exemption for the use of lead and lead compounds in wheel balance weights used in vehicles type-approved before 1 July 2003 and wheel balance weights intended for the servicing of these vehicles until 1 July 2005

Entry 7, which was inserted by Commission decision 2002/525/EC in 2002, allows the use of lead and lead compounds in wheel balance weights until 1 July 2005 for vehicles type-approved before 1 July 2003 and wheel balance weights intended for the services of those vehicles. By 1 January 2005, this exemption should be assessed in relation to road safety aspects. Question 5: Did the alternative market for non-leaded wheel balance weights develop and are the necessary adaptations made in order to ensure the road safety? What are the predicted market evolutions for the next 5-10 years? Answer 5: Yes.

The markets and production capacities for substitute materials are established and continuously increasing. Main reason for this success was the gradual phase in due to the link to type-approval date. For vehicles, type approved after the 1.7.2003 alternative materials are in use for balancing. The influence of the substitutes on road safety for servicing tyres done by small independent companies cannot yet be judged finally, because of missing field data. For the next years the recycling of balancing weights in Europe will be challenged because of the evolving material mix (lead, tin, zinc, steel etc.) and material separation expenses.

Question 6: Is the scheduled phase-out date (1 July 2005) feasible and would this not endanger road safety? Answer 6: The scheduled phase out is feasible for new vehicles. Safety issues have been solved

during their release phase. GM applies the alternatives, Zinc, to all new launched models and is changing production plant by production plant. By this, some carlines already benefit from this when produced in the same plant as a new launched carlines. Even we instructed all our contracted dealers to service the vehicles with the alternatives acc. to the phase out dates of the exemption, we cannot rest assure that all service stations, especially the independent ones are following the rules and can ensure the road safety. This business is not under our control.


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4.3. Review of entry 8: exemption for the use of lead and lead compounds in vulcanising agents and stabilisers for elastomers in fluid handling and powertrain applications until 1 July 2005 The scheduled phase-out date of this exemption should be reviewed by 1 January 2005, in relation to the availability of substitutes of lead. Question 7: Which substitutes have been developed and are currently in use? What are the predicted market evolutions for the next 5-10 years? Answer 7: Lead-stabilisers are already replaced in elastomer types (e.g. ECO). The total replacement

will be finished in time by July 2005 for all new vehicles. The future development of parts will be based on lead free products from the beginning on and zinc/zinc-oxide based products will mainly be used. The amount of lead in elastomers has been replaced almost completely by this approach. (<98%) There are no detrimental results know, and we will continue to use the substitutes. For vulcanising agents including the bonding agents however, some issues still need to be resolved.

Question 8: Are there other substitutes still being developed and tested? Answer 8: There are already low lead-containing alternatives available. These are containing up to 0.4%

lead being intentionally added. Because of the very unfortunate wording of the impurities (0%for intentionally added lead), this residual lead content needs to be completely eliminated. Considerable efforts were made to finally develop complete lead free vulcanising agents. However long-term risks regarding safety-related aspects are not assessable at this moment. Some substitutes failed, others provided positive results. This implies that probably the performance levels have to be adjusted. The long-term performance of lead free developments has a very high importance to road safety aspects because a breakdown of the affected parts can put other traffic participants at risk. Only long-term tests, which are currently in progress, can ensure the reliability of new products in respect to material interactions, component position/function, temperature profiles and influence of fluids. These requirements are all in a complex relation. Substitutes are based on zinc or magnesium. Here we are talking again about a very small amount of lead in the bonding agents. They are applied in a thin layer of 1-2 µm on the metal surface prior to vulcanisation.

Question 9: Is the scheduled phase-out date (1 July 2005) feasible? If not, please give detailed reasons. Answer 9: A final assessment about the results of the current vehicle tests is not possible. The test

series are still ongoing and we are confident to more reliable test results by end of this year if everything is going well.


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Question 10: If the scheduled phase-out date is not feasible, which phase-out date would be feasible and why? Answer 10: If these tests do not provide reliable products, new long-term tests with improved

vulcanising/bonding agents are necessary. In that case and taking the supply chain and distribution aspects into consideration, an extension of the entry until 1. Sept. 2006 is required. If long-term tests show satisfying results, a phase out by 1. July 2005 is possible.

4.4. Review of entry 21: exemption for the use of cadmium in batteries for electrical vehicles until 31 December 2005 Pursuant to Article 2 of this Commission Decision, this exemption should be reviewed by 31 December 2004. This review should include an analysis of the progressive substitution of cadmium and the availability of electrical vehicles. Pursuant to Article 2 of this Commission Decision, this exemption should be reviewed by 31 December 2004. This review should include an analysis of the progressive substitution of cadmium and the availability of electrical vehicles. Question 11: How many electrical vehicles are currently registered and in circulation in the EU? What are the predicted market evolutions for the next 5-10 years? Answer 11: GM has not been producing such type of vehicles in a large scale. There has been some

countable numbers sold in the US, and may be handful in Europe. These types of vehicles are not in the product portfolio anymore and we consider electrical vehicles as a niche market. Such a niche market can only grow within the framework of International, European and National policies promoting the development of clean transportation. Such policies are not mature enough today to give a mid term perspective us vehicle manufacturers. This situation does not allow to commit additional research and manufacturing resources.

Under these circumstances, it is quite impossible to generate any market forecast.

Question 12: How many electrical vehicles are currently being equipped with substitutes for NiCd batteries? What are the predicted market evolutions for the next 5-10 years? Answer: There are currently no substitutes to Ni-Cd batteries on vehicles in Europe (and elsewhere).

The few vehicles using other technologies are not mass-produced vehicles but pilot-project or prototypes. Regarding market evolutions for technologies other than Ni-Cd, it is even more difficult to create market forecasts than for the whole electric vehicle market (see answer to question 11), since such technologies need to go through substantial investments in manufacturing facilities


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Question 13: Are other substitutes than NiMH and Li-ion still being developed and tested? Answer 13: As GM is not the leader in this type of developments, the knowledge is very limited.

As of our knowledge many different technologies are currently under development and test at various stages, such as sodium-nickel chloride, lithium-polymer as well as others. At this time, these technologies are far from being certified for automotive traction power by vehicle manufacturers, and there currently are no manufacturing infrastructure that can produce the 10,000 units per year which are required for a commercial launch.

Question 14: Is the scheduled phase-out date (31 December 2005, with an exemption for replacement parts) feasible? If not, please give detailed reasons. Answer 14: No.

A revised draft battery directive is currently undergoing the codecision procedure within the European Parliament and Council. According to the extended impact assessment procedure, this revised directive authorizes the placing on the market of industrial (motive power) NiCd batteries when conforming to the specific and mandatory collection and recycling targets. It specifically forbids any ban or specific and mandatory collection and recycling targets. It specifically forbids any ban or marketing restrictions on NiCd batteries fulfilling the requirements of the directive. These NiCd batteries have to be dismantled and recycled separately acc. to the obligation from the ELV directive.

Question 15: If the scheduled phase-out date is not feasible, which phase-out date would be feasible and why? Answer 15: No phase out date at all.

As stated under answer 14 and for the sake of legal consistency, NiCd batteries for electric vehicles have to be exempted without any expiry date.


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Replacement parts and other entries, not part of the internet-consultation.

Replacement parts Spare parts for vehicles put on the market before 1 July 2003 are exempted from the

provisions of article 4.2 in order to ensure proper servicing and maintaining of these vehicles. For exemptions expiring after 1 July 2003 the same logic should apply. The reference needs to be made to the vehicle. Proposed wording: “Vehicles put on the market prior to 1 July 2003 or prior to the respective expiry date of the exemptions listed in Annex II and parts intended for repair or servicing of these vehicles are not affected by the restrictions (of Article 4(2)(a)).” GM is producing spare parts on the same production line than the original equipped vehicles, during the same time period and using the same materials and manufacturing processes. At the end of a production phase of a vehicle we or our suppliers are producing the estimated amount of spare parts “for lifetime” of this vehicle, having in mind that in 15 years time from that very day still some vehicles may be around and might be repaired by “original spare parts”. Therefore, the phase out of heavy metals in the production of “spare parts” is planned according to the same time-schedule as the parts for the original equipment. It is only feasible to develop new spare parts with proper confirmation of safety features accompanied with original vehicles. In cases where the original vehicle is not in production anymore (and therefore the spare parts), it must be possible to reproduce new spare parts under the same conditions as the production of the vehicle itself was done. In cases were we produced to less spare parts we need to reproduce new spare parts even 15 years after stopping production. Otherwise the repair or servicing of vehicles is not possible anymore.

1. Steel for machining purposes and galvanised steel containing up to 0,35 % lead by weight Exemption is still necessary, without any time limitation. Some ISO standards for fasteners

or other parts to be machined are in this range. Lead is still needed for parts where a high machinability is required. Investigations with substitute materials (e.g. Calcium) showed still detrimental results.


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3. Copper alloy containing up to 4 % lead by weight Exemption is still necessary without any time limitation.

Typically the brass is an alloy that contains between 0.2 and 4.2 % lead with the most important alloys being in the 2.5-3.5% range (industry wide standards). Main reason for the lead content is the machinability. No other metal or alloy can be machined faster, longer or more consistently than these brass types that are being used in various applications such as nozzles or inserts. The vast majority of all lead containing copper alloy is used for essential safety, comfort and reliability features. Collection and recycling are performed as a regular activity of the affected industries. However, there are already for years some lead-free copper alloys in use, an also some new developments introduced to the market. This alloys are not suitable to replace the current alloys in all applications.

4 Lead-bronze bearing shells and bushes Exemption is still necessary, however needs to be reworded. There are various

translations out there and interpretations possible regarding the lead content; in the bronze as an alloying element, as a functional layer, as constituent in the functional layer and many more. As it currently stands is a lead-bronze bearing containing 20 to 25% lead exempted and a bearing using no lead-bronze at all but using a PTFE (Teflon) functional layer containing 5 % lead not exempted. This makes no sense at all. The interpretations also differ between vehicle manufacturers and the supply base. There are new developed lead-free bearings and bushes available and in use for some applications.

See: Attachment 2.doc

5. Battery Exemption is still necessary. There is still no practicable alternative for lead

acid starter batteries. No practicable alternatives are expected to be available for mass production in the foreseeable future. Efficient collection and recycling system in place. Statements made in the Ökopol-Report from July 2001 are still valid. See also statement from EUROBAT.

See: Attachment 3A-Eurobat position.pdf


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6. Vibration dampers The entry will also be required in future, without any time limitations.

No new evidence is available that we could entirely life without this. Typically design flaws are being reworked as soon as possible but are not at all unavoidable. Even the latest computer aided solutions cannot avoid the detection of unexpected vibrations at late design or release stages. Therefore, safety issues are predominately the driver behind such solutions, to e.g. prevent from vibrations in the steering column. In many cases the problem can be resolved with steel dampers, but occasionally the mass needed in one spot or the available space, limit the material selection to lead. Also the documentation of the unavoidable vibration dampers made from lead has significantly improved by making these data available to the dismantlers thus avoiding that these lead applications enter in the waste stream.

9. Stabiliser in protective paints No extention of this entry needed.

Alternatives for the vast majority of applications are available. GM is is changing to lead-free stabilisers step by step plant by plant. Our suppliers are requested to do the same in their paint shops. For some special applications (e.g. primers for pre-treatment of plastic/composite bodies prior to paint application) however, new developments failed so far. We try hard that this can be resolved in time.

10. Carbon brushes for electric motors Extention for vehicles type approved before 1 July 2003 without any

time limitation necessary. There are no replacement options for the carbon brushes itself. The complete component needs to be exchanged. Lifetime design and reliability issues of components are the reasons to apply for an extended use of lead containing carbon brushes.

See: Attachment5_vers4.doc


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11. Solder in electronic circuit boards and other electric applications Exemption is still necessary without any time limitations but needs to

be reworded. GM not yet there to use lead-free applications cross board. We proactively are addressing this requirement to our supply base and are trying to implement lead-free solder solutions where is it possible step by step. Due to safety-related reasons for e.g. chassis control, ABS, airbags, etc. lead containing solders are still required. Wording of footnote shall be changed and read as follows: Dismantling of lead amounts from entry 11 and 14 exceeding an average threshold of 60g per car only, if lead concentrations after shredding processes do not allow further treatment according to existing regulations. A reassessment of this entry by end of 2007 is recommended.


12. Copper in brake linings containing more than 0,5 % lead by weight Extention for vehicles type approved before 1 July 2003 without any time limitation

necessary. The gradual phase out of lead containing brake linings with new type approved vehicles will minimize the risk of road safety, limit the number of variances in the market and will be more successful in the servicing area, because of a clear break point. Safety related risks after servicing of vehicles which had been placed on the market by the OEM´s not fulfilling this requirement, cannot be excluded. The note: - a max. concentration value up to 0,4 % by weight of lead in copper intended for friction materials in brake linings shall be tolerated without any time limitations, provided it is not intentionally introduced, is also still needed.

13. Valve seats Extention for engine types developed before 1 July 2003 without any time limitation

necessary. New developments are already lead-free Changing of running series requires intensive durability tests engine type by engine type. Test results from one engine cannot be transferred to another one. In case of unsuccessful tests, the total engine needs to be redeveloped. Time limitation until 2006 seems to be to short. This is also an important issue for the current replacement part requirement. Engines cannot be repaired with the current wording.


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14. Electrical components which contain lead in a glass or ceramic matrix compound except glass in bulbs and glaze of spark plugs. Exemption is still necessary without any time limitations but needs to be

reworded. During the last three years in research and development there were no practical alternatives found for piezo-electronic based car components, sensors and highly precise passive electronic components. Lead is still essential in these applications. The further reduction of fuel consumption to fulfil the CO2 targets and to reduce the environmental implications during the use phase of a vehicle is not possible with these components. Wording of footnote shall be changed and read as follows: Dismantling of lead amounts from entry 14 and 11 exceeding an average threshold of 60g per car only, if lead concentrations after shredding processes do not allow further treatment according to existing regulations.

See: Attachment7_vers4 .doc

15. Glass in bulbs and glaze of spark plugs No extention of this entry needed. Mass production of lead-free glazing and bulbs started in

2003. Industry is changing to lead-free step by step. As expected for both, glass in bulbs and glaze of spark plugs, the supplier industry managed to deliver lead-free substitutes. The vehicle manufacturers can implement the substitutes in time for the running series and for all new developments.

Thus the exemption is not longer needed and a successful contribution to the overall aim of reduction and control of lead in vehicles has been achieved. Parts and components already put on the market must be accepted to be used for repair and servicing without any time limitation.

16. Pyrotechnic initiators Extention for vehicles type approved before 1 July 2006 without any time limitation

necessary. We see mayor safety-related problems and risks for human health by changing of running series. Presently lead free ignition systems for future models are in the development process for these safety sensitive applications. Different ignition systems (low and high energy) must be validated and large tests are needed for qualification considering technical periphery.


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17. Corrosion preventive coatings Entry shall be reviewed in 2006 and feasible phase out date shall be

reassessed. This entry shall be linked to a date of type approval as well. GM is on one hand confident that some Cr (VI) free applications can be successfully introduced within the next few years, (e.g. coating for fasteners is almost done) but is on the other hand also facing major challenges: First of all a long range planning “trust level” regarding the substitutes is needed from the commission. Industry does not want to develop and apply substitutes with higher risk potential to the environment and human health. Since the beginning of the discussion to ban Cr (VI) the need of a stability of the planning procedure was to be seen. Due to the fact that the substitutes for Cr (VI) are Ni and Zn is to be classified that

1. these substitutes force a lower performance / functionality out of the higher thickness,

2. if at any time Ni and Zn will be banned, a further switch to substitutes

might provoke a fall back to Cr (VI),

subsequently any discussion for a ban of Ni and Zn should include a general exemption for corrosion prevention. Second: For several applications neither substitutes nor alternatives are available at this point in time (e.g. Mg, Al, black chromate) Regarding galvanic platings see report from VDA-WG-Cr (VI) Substitutes: a) Process is still not under control at the job-coaters. b) Major variation in quality c) High temperature resistance (>120°) not yet achievable. There are still not all safety risks known. Pretreatment of weatherstrips is still not solved Outcome of the CHROMATEX study need to be considered. The automotive industry is not the market leader in use of Hex Chrome. The vast majority is used for the construction industry, household/electronic industry.

See: Attachment 8_vers2.ppt

18. Absorption refrigerators in motorcaravans Entry is still needed


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19. Discharge lamps and instrument panel displays Entry still needed.

Some alternatives are under development. Statements made in the Ökopol-Report from July 2001 are still valid. A phase out date for discharge lamps seems currently not to be possible. A reassessment by end of 2007 is recommended.


20. Thick film pastes Entry is still needed. There is still no substitute available. An extended phase out date, at

least a review date in 2006 seems to be appropriate. Some applications e. g. for optical sensors are still not yet solved

Impurities The last part of the sentence “provided these substances are not intentionally

introduced” should be deleted. There is no difference regarding the environmental impact if the metals are intentionally added or part of the materials as “normal” impurity as far as the upper limits are met. The threshold values for impurities shall be set in accordance with the maximum concentration values already fixed in other directives (e.g. ROHS), and periodically revised, or an orientation on CEN and other international or national standards should be considered.

See: Attachement 10-vers2.doc

Attachment 2

Entry 4: Lead-bronze bearing shells and bushes In vehicles there is a large variety of bearing shells and bushes which are in sliding contact to moving parts. The group of bearing shells and bushes which is described by the current wording of exemption #4 represents a large fraction, but not all of those bearing shells and bushes. The supplying industry in cooperation with the vehicle producers has started intensive and partially successful work to develop and produce bearing shells and bushes completely free of lead. For single applications a number of lead-free bearing shells and bushes is available already. In the next couple of years the number of bearing shells and bushes which are free of lead will continuously increase in vehicles. However an appropriate time for evaluations and testing has to be taken into account. For new developments those evaluations and testing can be done in the course of the regular development procedures. Due to the large variety of bearing shells and bushes and the corresponding technical requirements it can not be predicted whether lead-free bearing shells and bushes will be available in all cases within the next 5-10 years, but in the long run this might be possible. In the study “Heavy Metals in Vehicles II” Ökopol used the method to look at the ways of recovery or discarding of parts of vehicles which contain lead. On the basis of these processes Ökopol judged the impact of lead on the material processing chains and evaluated the necessary measures for the corresponding materials or parts of vehicles. Using this approach there is no difference between those lead-bronze bearing shells and bushes which are covered by the current wording of exemption #4 and other bearing shells and bushes. For the reasons mentioned above and due to the fact that there is no difference in the relevance and amount of lead in lead-bronze bearing shells and bushes and other bearing shells and bushes the involved industries propose to change the wording of exemption #4 in the following way:

New exemption #4: „Lead in bearing shells and bushes.”

We would like to add that extensive efforts for the development and introduction of lead-free bearing shells and bushes are on their way including the replacement of lead-bronze bearing shells and bushes. We are confident that the total amount of lead in bearing shells and bushes in vehicles or motors which are newly developed will be reduced significantly in the next couple of years. These efforts will not be influenced in a negative way by the proposed new wording. In the case of bearing shells and bushes the industry is on a good way for the purpose of reducing and controlling hazardous substances. Nevertheless an understandable and technically justified revision of the wording for exemption #4 is necessary in order to take into account the large variety of bearing shells and bushes. The transition to lead-free alternatives should not be done without sufficient development and testing.

GM-OPEL on entry 10.doc04.06.2004

Attachment 5

Carbon brushes for electric motors A lot of research work and modifications in production processes happened during the last years. From major producers of carbon brushes it was stated that for new products a phase out of lead containing carbon brushes by Jan 1. 2005 is feasible and on the track. Production processes have been modified and adopted. But the effect of lead-free carbon brushes on lifetime and reliability of components may in the meantime be a topic of testing and research work. In some cases redesigns still can be necessary. After 1.7.2003 new type approved vehicles are equipped with lead-free carbon brushes. As far as possible, new produced spare parts will get lead-free carbon-brushes. A modification of spare parts needed for older vehicles and which often are ordered in very limited volumes only is not feasible and useful. In many cases because of high labour costs or not given replacement options (lifetime construction principle) consumed carbon brushes are not replaced separately, so that complete components have to be exchanged. In the storehouses of suppliers, dealers and car companies complete components wait for their use in vehicles. Because of the need to exchange complete components and a missing exemption after 1.1.2005 all these ”virgin” parts would have to scrapped and replaced by new parts, if available. For that reason the automotive industry applies to revise the exemption for the use of lead containing carbon brushes as following: - Vehicles type approved before 1.7.2003

GM-OPEL on entry 11.doc 22.04.2004 1:20

Attachment 6

Entry 11: Solder in electronic circuit boards and other electric applications

Proposal for 2005 During the last years joint working groups of car producers, electric and electronic components suppliers and electronic devices producers were involved in depth in lead free soldering processes for automotive electronics. Because of higher temperatures of lead free soldering processes new electronic parts with a high temperature resistance had to developed at first. Some sensors with leadfree soldering could be brought into volume production. But a control unit e.g. may consist of several 100 elements which all must be suitable for leadfree processes There is still the open question, if lead free soldering processes of complex automotive electric and electronics can achieve the same ratio of life time and reliability as the high sophisticated actual processes. After the availability of the appropriate electric and electronic elements now more and more the production processes are in the scope of research. In the next years the reliability of lead free soldering processes for the complex automotive electronics has to be developed and examined. The situation is comparable to the problems of the industrial electronic automation devices and military electronics applications. Because of the high importance of reliable electric and electronics for car safety over a long period of time there is no way to go in volume production without sufficient experiences and tests. For that reason we apply to continue the existing unlimited exemption in entry 11 and to set a review/ reassessment date by 2007. For practical reasons in the exemption the following rewording is recommended Dismantling, if lead concentrations after shredding process would not allow further treatment according to existing regulations Entry Expire date Dismantling 11. Solder in electronic circuit boards and other electric applications

Dismantling, if lead concentrations after shredding process would not allow further treatment according to existing regulations

GM-OPEL on entry 11.doc 22.04.2004 1:20

Background information Entry 11: Solder in electronic circuit boards and other electric applications The footnote prescribing dismantling if an averaged threshold value of 60 grams per vehicle is exceeded should be deleted. In case the footnote is maintained it should read: Proposal for rewording : Dismantling, if lead concentrations after shredding process would not allow further treatment according to existing regulations. ACEA argumentation 2001 Explanation: Sophisticated separation technologies for shredder residues are under development. With these technologies it will be possible, to concentrate lead in a specific fraction, that can be used in metallurgical processes as substitute for primary raw-materials in the same way, or are processed to gain concentrates for smelting processes. As long, as the main goal, the limitation of emission of lead into the environment and the recycling into the lead-production-process is reached, a discrimination of new treatment- and recovery-technologies should not take place. Looking at end-of-life vehicles not only as a waste but rather as a complex source of raw-materials, it is obvious, that sophisticated technologies for the production of specific fractions for different applications will develop. Actual approaches, separating shredder-residues into a plastic- and rubber-granulate for the reduction process in a blast furnace (substituting coal or oil), a fluff-concentrate as draining-agent for sewage sludge and an inert fraction are very promising. A treatment and recovery chain, that is more complex but economically viable, will make a dismantling of lead-containing components, other than batteries and balance-weights, obsolete. Whereas the scope of Article 4 of Directive 2000/53/EC is "Prevention" the "Treatment" of End-of-Life vehicles is in the scope of Article 6 of this directive. Annex I, Item 4 requires theremoval of metal components containing copper, aluminum and magnesium if these metals are not segregated in the shredding process. The same principle which is valid for copper, aluminum and magnesium should be applied also for lead as the necessary pyrometallurgical processes will be available as explained above. Follwing text taken from Oekopol I /II study “Presently extensive investigations to find lead-free alternatives are carried out by several car manufacturers and suppliers, and replacement of lead is already possible in several application fields. But it has to be considered that there is no universal solution that would be suitable for all cases. Unlike consumer electronics like TV or hifi systems, safety requirements in cars, in combination with temperature and mechanical stress and corrosive conditions, make replacement more problematic. Lead-free soldering in the automotive industry can only be implemented stepwise. Experiences from applications with moderate safety demands and ongoing research will lead to transfer of lead-free soldering technology from automotive parts with less adverse conditions (e.g. interior) to those with more demanding requirements. A total ban of lead containing soldering cannot yet be recommended in the present situation.” “Technical progress leads to an increasing use of electronic devices in automobiles, some of them under extreme conditions such as strong vibrations and high temperatures (e.g. when applied directly on the engine block) which require solders with a higher melting point.”

Version 3 überarbeitet von Bosch, EPCOS, Siemens VDO

Entry 14:

Proposal for 2005 Electrical components which contain lead in a glass or ceramic matrix

Information about Electrical Components which contain Lead in a Glass or Ceramic Matrix Compound

Summary: Lead is today still an essential material for some long-term highly precise passive and active electric / electronic components as well as for piezoceramic based sensors and actuators. These components are often used in automotive applications resulting in a reduction of emissions, noise, weight, less fuel consumption or improved safety systems. From end of life vehicles they will end up in the material recycling processes or on special waste desposal. Amount of lead compared with positive effects for the environment or risk of release is low. For some applications they are the basis to achieve further advanced environmental performance of a car (e.g. to meet Emission standards beyond Euro IV etc.), which is not possible with conventional systems. Meanwhile efforts in research and development of the supplying industry in cooperation with public institutes will be continued to find lead-free alternatives, but these alternatives are not available today. Therefore the automotive industry applies for continuing the existing exemption without any limitation and proposes a review in 2007 /2008.


Background information entry 14:

Index of Contents

Ceramics / Annex II

Electrical Components containing Lead

Application within Vehicles

Injection Systems

Reduction of Emission

Application / Amount of Lead

Benefit for theEnvironment

Deposition of Ceramic Components

Lead-free PZT Alternatives

Forecast

Summary

Feb. 04 W. Diertl / B. Reischl Information about PZT

Index of Contents

Index of Contents:

Ceramic Components / Annex II (2002/525/EC) Electrical Components containing LeadApplication within VehiclesTypical Application - Injection SystemsReduction of EmissionApplication / Amount of LeadBenefit for the EnvironmentDiesel Injection System - Amount of Lead / Benefit for the EnvironmentDeposition of Ceramic Components from End of Life VehiclesStatus of Lead-free Piezoceramic AlternativesForecastSummary

It is our intention to provide all necessary information to enable a based on fact assessment of the environmental aspect / impact / benefit of lead containing electrical components within automotive applications. Source : Bosch, Epcos, CeramTec, Siemens VDO automotive, FHG http://www.smart-materials.fhg.de/english/index.html 2003


Requirements for Electric Components Containing Lead / Annex II 2002/525/EC

Index of Contents

Ceramics / Annex II



Injection Systems






Forecast

Summary


Assessment of Ceramic Components (PZT)

Registered on the List of Exemptions for the Heavy Metal Restriction based on the ELV ( Annex II 2002/525/EC):

Entry No. 14: Electrical components containing lead in a ceramic matrixExpire date: noneAdded Obligation: Dismantling for components other than in engines

(60 g rule)

Ökopol Study II: Heavy Metals in Vehicles II (Final Report July 2001):

p. 35: PZT connected to engine have direct environm. advantagesp. 26: Lack of information prevents an overall recommendation

Therefore our intension is to provide more detailedinformation on piezoelectric components

With the amendment of the Annex II 2002/525/EC, Electrical components containing lead in a glass or ceramic matrix are exempted from the heavy metal restriction of the End of Life Vehicle Directive 2000/53/EC, without fixed expire date. For components other than piezo in engines there is the obligation of dismantling, if together with lead form solder applications an average threshold of 60g per vehicle is exceeded. The Ökopol study on Heavy Metals in Vehicles II (July 2001) confirms environment advantage of PTZ connected to engine and the necessity of further information. Heavy Metals in Vehicles II, Ökopol, July 2001: …. Besides technical reasons (mainly electrical properties of lead in certain applications) the lack of information plays an important role here…."


Electrical Components containing Lead:

Index of Contents

Ceramics / Annex II



Injection Systems






Forecast

Summary



Lead compounds are used in a glass Matrix for thick-film materials (Circuitcarrier) and passive components (resistors, condensers, resonators etc.) Theirlead content is mostly below < 5 % and the total amount for a car from thissource is below 2g.

"Ceramic components which contain lead are almost exclusively ferroelectricceramics which belong to the group of piezoelectric materials. In thesematerials, an electrical voltage is induced when the material is mechanicallydeformed ("sensor" mode), or on the other hand they undergo a mechanicaldeformation when an electrical voltage is applied ("actuator" mode)." (Heavy Metals in Vehicles II, Ökopol, July 2001)

The available piezo ceramics are dominated by lead zirconate titanate (PZT). Lead is the main element with a content between 58% and 68% (depending on proportion of Zr to Ti).

Lead is still essential in these applications. Although there is intensive researchon lead-free alternatives there is no practical alternative today.

* The Piezo Effect / Piezoelectric materials: Piezoelectricity is based on the ability of certain crystals to emit an electrical charge when mechanically loaded by pressure or tension (direct piezo effect). Conversely, these crystals undergo a controlled deformation when exposed to an electric field - a behaviour referred to as the inverse piezo effect. The polarity of the charge depends on the orientation of the crystal relative to the direction of the pressure. For automotive applications especially within the engine area piezo-materials with a high Curie temperature and a high level of polarisation saturation are necessary. The best known performance have PZT ceramics, which are a mixture of PbTiO3 and PbZrO3 . Direct piezoelectric effect means the converting of mechanical quantities such as pressure and acceleration into electrical quantities. Inverse piezoelectric effect means an electric field which induces a mechanical deformation of a piezoelectric crystal.


Applications of Piezoceramic within Vehicles

Index of Contents

Ceramics / Annex II



Injection Systems






Forecast

Summary



Engine: Piezo actuator for high pressure direct diesel injection

Engine: Knock sensors for engine control

Chassis: Shock sensor for airbag

Powertrain excl. engine: Rotation rate sensor (gyroscope) for driving

Typical application fields of piezo ceramic componentswithin vehicles

dynamics control system

Existing application:

Future application:

Chassis: Sensors for Active Noise Killing System

Chassis: Reversing sensor for park distance control

Chassis: Sensor for wheel tyre guard (tyre pressure control)

Apart from electric / electronic circuits which contain small components with a low lead content (total amount per vehicle < 2g) there are various applications, either already existing or lying in the future, where Piezoceramic actuators and sensors are the basis for advanced technology. Some of these applications are directly used to optimise the engine performance and so saving fuel and reducing emissions. Even if they serve at first sight only for comfort reasons, they might also generate environmental benefit e.g.

• active noise killing systems may substitute weight intensive sound insulation materials

• wheel tyre guards will positively influence running characteristics of a car because they inform the driver about the proper tire pressure and such also reduce fuel consumption

• park distance control sensors may prevent driving around searching for bigger parking spots.


Piezo Ceramic Injection Systems

Index of Contents

Ceramics / Annex II



Injection Systems






Forecast

Summary


Typical Application - Injection Systems (1/2)

Engine: High pressure diesel injection system (Common Rail)

Injector:Injector head with

Piezo Actuator

Source: Ford

The automotive industry has developed a high pressure diesel injection system with piezo technology, the Piezo Common Rail System. A common rail system is an injection system which offers high pressure fuel for injection at any given moment. To get engine noise and emission down it is necessary to add several small pilot- and post-injections to the main injection during a working cycle of a diesel engine. The essential component of the common rail system is the injector.


Piezo Cermaic Injection System / The Injector

Index of Contents

Ceramics / Annex II



Injection Systems






Forecast

Summary


Typical Application - Injection Systems (2/2)

Structure of Piezo Multi-layer-Actuator

printing pressure

passivearea

Injector head with Piezo Actuator

The actuation of the injector is the most important parameter in a diesel engine combustion process. The actuation is responsiblefor injection quantity and time and therefore affects emission, noise and performance of the engine.

Piezo Actuator

The injector of the common rail system is designed to reach very low injection quantities. That can be realized exclusively due to a piezo actuated valve which controls the amount of diesel injected.


The piezo actuated valve offers the following advantages:

Index of Contents

Ceramics / Annex II



Injection Systems






Forecast

Summary


Injection System - Reduction of Emission (1/3)

By the use of Piezo Actuators an optimized injection control canbe achieved due to

faster actuator switching times

improved response time of the actuation event itself

better reproducibility of injection

ability to perform variable valve lift

The above mentioned characteristics potentiates to perform a multiple injection strategy, which means that several small pilot-and post injections are added to the main injection during a working cycle.

As a result the engine will be better able to meet exhaustemission regulations much more effectively than withconventional actuators.

• The valve switches 30 times faster than a conventional solenoid valve, because it requires no time for a magnetic field to be generated and omitted with each reaction.

Result: Very low injection quantities and several single injections possible.

• The piezo actuated valve offers a better reproducibility of the injection

quantities than a valve actuated with solenoid technology.

Result: Precise injection quantities over the lifetime of a diesel engine which ensures a continuous low level of emission.


In practice that means:

Index of Contents

Ceramics / Annex II



Injection Systems






Forecast

Summary


The use of Piezo ceramic contributes substantially to meet futureemission regulatuons for Diesel and Gasoline engines

Emission

2004 2008 2012

EURO IVEURO IV

EURO VEURO V

EURO VIEURO VI

Year.......

.......


Only feasible withpiezo ceramic !

• The Piezo Common Rail System provides the opportunity to meet Euro IV emission standard without additional hardware components on the engine: No particulate filter, no NOx trap, no knock sensor needed.

• Furthermore Diesel passenger cars equipped with the Piezo Common Rail

Systems fulfil Euro IV, which will be introduced 2005 already in 2003.

• The piezo technology offers further potential to meet future emission standards beyond Euro IV, for diesel as well as for gasoline injection systems.


Injection System – Direct Environmental Advantages

Index of Contents

Ceramics / Annex II



Injection Systems






Forecast

Summary


Results of Siemens VDO Diesel emission research activitieswith Piezo actuated injector and multiple injection strategy(Oct 2003)

For complete EUDC1):

Soot up to -25%

NOx up to -25%

CO up to -37%

HC up to -18%

For urban cycle2) (low load and speed):

CO up to -80%

HC up to -55%

fuel consumption -4,5%

1) Extra Urban Driving Cycle, specification of EU

2) Urban Cycle, specification of EU


Additional:Reduction of noise!

This slide shows the impressing reduction of emissions which is possible already with piezoceramic injection systems today. Further research and developments depend also on obligations for dismantling or restriction.


Estimation of total Lead Amount for Electrical Components Containing Lead in Glass or Ceramic Matrix

Index of Contents

Ceramics / Annex II



Injection Systems






Forecast

Summary



Application Component Quantity of ceramic (g)

Lead contentin ceramic (g)

Number per car with ... cylinders

4 6 8

Airbag

Drivingdynamics

control system

Engine Control

High pressurediesel injection

Shocksensor

Rotation rate sensor

Knocksensor

Piezoactuator(injector)

0,2

0,08

5,0

16,6

0,1

0,05

3,4

11,5

2 2 2

1 1 1

1 2 2

4 6 8

Total amount of lead per car (g): 50 76 99

Control units Integratedresistor 10 < 0,1 10 10 10

The total amount of lead for applications for electrical components containing lead in a glass and or ceramic matrix and which are exempted by entry 14 of the Annex II from Heavy Metal Restriction is about 50g up to 100g per vehicle.


Positive Effects of Piezo Ceramics on Safety or Environment

Index of Contents

Ceramics / Annex II



Injection Systems






Forecast

Summary


Fuel injection

Knock sensor

Shock sensor

Rotation rate sensor(gyroscope)

Active noise killing system

Wheel tyre guard

Reduction of emissionReduction of fuel consumption

Better engine control

Safety: activation of airbag

Safety: activation of driving dynamiccontrol system

Saving of weight intensive acousticinsulation

Reduction of fuel consumptionSafety: better vehicle roadholding

Application of PZT Benefit for environment orsafety

Benefit for the Environment

Piezoceramic used in various applications as well as on the engine as on chassis provides benefits for the environment or safety.


Environmental Assessment of a Piezoceramic Diesel Injection System over a total Vehicles Life-time

Index of Contents

Ceramics / Annex II



Injection Systems






Forecast

Summary


Diesel Injection System Amount of Lead / Benefit for the Environment

Reduction of emission ~ 304 g

Application of 50-100g lead per

vehicle in ceramics

Is fixed and ends up on special waste

depositsReduced pollutionof environment

Considering a kilometric performance of 100 000 km and an averagereduction of emission of 30%:

Lead content compared with reduction of emission over a vehicle lifetime. Positive effect of Piezo ceramic outbalance the use of 50 – 100g lead.


Fate of Lead containing Piezoceramics from End of Life Vehicles

Index of Contents

Ceramics / Annex II



Injection Systems






Forecast

Summary


Deposition of Ceramic Components (PZT) from End of Life Vehicles

Way of PZT 1) steel smelter, metallurgical processesassembled to the engine 2) blast furnace slag

3) special waste deposit

Way of PZT 1) shredder light fractionintegrated in the chassis 2) slag of metal recycling or heat recovery

3) special waste deposit

Result:Pb release in the Environment is unlikely, because PZT:

is chemical largely inertwill end up on special waste deposits

A release of lead from end of life vehicles into the environment is very unlikely!


Lead-free Piezo Ceramics

Index of Contents

Ceramics / Annex II



Injection Systems






Forecast

Summary


Status of Lead-free Alternatives

Intensive research on lead-free alternatives, but

Highly, durable stability of electronic units over the entire life cycle of a car(resistance variation < 1%)Low temperature coefficient (< 100 ppm/K)Narrow tolerances, especially for safety-related systems(deviation to set value < 1%)Assurance of function under special conditions of a car(temperatures > 130°C; insensivity for humidity, dust, vibrations etc.)Precise, reproducable positioning travel (xµ-range)Required lift of actuator (fast switching time)Realization of high forces (~kN)High curie temperature (ambient temperature of engine ~ 150°C)

today only possible with lead

Currently it is not possible to substitute lead in piezo ceramic applications!


Resarch Efforts

Index of Contents

Ceramics / Annex II



Injection Systems






Forecast

Summary


Environmental Impact of Ceramic Components (PZT)Forecast

Resarch:BMU (German Environmental Agency) Projecttogether with Industry:

Development of lead-free Alternative PZT:Substitution of Lead by other Metals (see p. 16)

Projects e.g.Siemens CT MM2Long term Substitution and Avoidance of lead containing Materials and Components.Development of lead free or lead reduced Piezo Ceramics useable for technical applications.

There are intensive efforts carried out in the research departments of the supplying industry to develop lead free alternatives. But today technical feasibility is not yet achieved.


Exemption for Electrical Components containing Lead in a Glass or Ceramic Matrix is still necessary!

Index of Contents

Ceramics / Annex II



Injection Systems






Forecast

Summary


In small amounts lead is used in glass or ceramic matrix in advancedapplications with positive effects on the environment (reduction of emission and fuel consumption) and safety (detection and activation of safety systems).

After the lifetime of a vehicle the lead is not released into theenvironment, but will end up in recycling processes or special wastedeposits.

Althoug there is intensive resarch activity lead-free alternatives arenot yet available.

Due to that an exemption for lead in theseapplications is still neccessary.

Summary

Therefore the automotive industry applies for continuing the existing exemption without any limitation and proposes next review in 2007 /2008.

Attachment 9 Entry 19 “Mercury in bulbs and instrumental displays” Some bulbs for headlights are gas discharge bulbs filled with a mixture of sodium, scandium and mercury as an illuminant. To reach the necessary voltage additional devices are necessary. Mercury containing light systems have very strong light intensity and a long life span . Besides their application in headlights mercury containing lamps are used for background illumination of displays in automobiles and sometimes also used for lightening inside the car. A HID bulb usually contains around 0.5 mg of Hg and a display illumination around 1 to 2mg of Hg. Mercury containing gas discharge bulbs have clear advantages especially in terms of light intensity, whiter light and lower power consumption.

To: European Commission, DG Environment, Unit A2 – ELV...

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