Updated Environmental Statement 2019 EvoBus GmbH Mannheim plant 2 Updated Environmental Statement 2019
Inhalt
3 Preface 4 The EvoBus plant in Mannheim 6 Energy and environmental program 12 Figures, data, facts 26 Validation
Imprint
Responsible environmental protection officer: Randolf Troche BUS/OPT-UWS
Responsible editor: Stephan Schmitt BUS/OPT-UWS Environmental protection department Phone: +49 621 740-2127 Telefax: +49 711 17-790 30453 [email protected]
Head of Production Daimler Buses: Dr. Marcus Nicolai
Layout and implementation: Daimler AG, CBS/M
Imprint allowed with exact source. Updated Environmental Statement 2019 3
Preface
The Mannheim location stands for the development and production of city buses and thus makes a significant contribution to environmentally friendly urban mobility concepts. Apart from the classic diesel-fueled Citaro, these also include gas-fueled buses, hybrid vehicles and, as of this year, our eCitaro as a fully battery-electric vehicle, which is thus free of local emissions. On the production side, we are currently implementing our production vision, based on which we will build city buses in Mannheim efficiently and in alignment with the basic idea of Industry 4.0.
Since the start of 2019, environmental protection has been assigned to technical service at the Mannheim and Neu-Ulm locations.
The environmental management system has a long tradition at the location though. Since 1997, annual external validation has been taking place – especially of the Environmental Statement in accordance with the European Directive EMAS. In the EMAS register, EvoBus Mannheim can be found with the registration number DE-153-00022. The registration certificate is updated by the Chamber of Industry and Commerce every three years. This took place most recently in 2018. This is done by submitting the Environmental Statement, including the topics of environmental policy and environmental impacts. The Environmental Statement is updated in the intervening years but only for updated topics. The certification of the international environmental management standard ISO 14001 has been integrated into the matrix certification of our production locations since 2015.
Mannheim, May 2019
Dr. Marcus Nicolai Randolf Troche Head of Production Daimler Buses Head of environmental protection Mannheim plant 4 Updated Environmental Statement 2019
The EvoBus plant in Mannheim Updated Environmental Statement 2019 5
Tradition meets modernity
Apart from city bus construction, bodies-in-white for touring coaches At the end of 2018, 3,436 employees were employed. This number and inter-city buses are also manufactured at the EvoBus GmbH location includes interns, diploma students and trainees. in Mannheim. The portfolio of the Citaro city bus family covers a large product range of non-articulated and articulated buses that are fueled Compliance with legal provisions, official requirements and other by diesel, gas and electricity. The first battery-electric buses were mandatory requirements is a matter of course for our company. For handed over to customers at the end of 2018. this purpose, the required information and resources for reviewing and achieving the requirements are ensured. The entire plant floor space comprises 305,656 m2, of which 130,100 m2 is sealed as development space and 128.603 m2 is sealed as a traffic area. On the location premises, 16,591 m2 is left in a semi-natural state. Outside the location, no semi-natural spaces are managed by EvoBus. The display of the core indicator “land consumption in relation to biological diversity” is depicted on page 21; this is limited to sealed spaces from development and asphalting.
Plan of the EvoBus plant in Mannheim in 2018
EMR Verwaltung Montage EMR BR Logistik EMR PKW - Tausch PKW - Tausch GF OAL Plaanung Vertieb WD VBE
WS WS LKW- LKW- Leitstelle Wareneingang
Bänder Bemi Werkstatt T Lack- Finish
D
Ausliefercheck
/ KTL / OLA / KTZ
EG. FertigmontageOG. Teilefertigung
GLZ koppeln
KSW Inbetriebnahme
Logistik
Technische
Fertigstellung
Rohbau Reisebusse Teilefertigung Rohmontage alle Typen
PAOB
Dach
Teilefertigung SW EG. Logistik
Rohbau Stadtbuslinie 1 und 2 OG. IH - Werkstatt Wzg - Lager ET Lager - Fertigung Prototyp Klappenfertigung Vorrichtung Stadtbus LOG
Bekleidungsst
Rohmontage Versuch Logistik Musterbau / SLT
EZ ONC 6 Updated Environmental Statement 2019
Energy and environmental program Updated Environmental Statement 2019 7
In our energy and environmental program for the Mannheim plant, the On the following pages, you can find the current energy and most important targets of the individual units are taken from their energy environmental program, including selected targets of our plant, with and environmental program and summarized. On this page, the location’s the respective responsibilities and the target completion date. environmental program for 2019 is presented with the completion Status.
Energy and environmental goals for 2018
Goals for 2018 Measure Assessment criterion Planned Completion date status* Process optimization Reduction of environ- Contribution to Daimler target 70 % of the supplier Evaluation criterion of at least 70 % 04/19 Done, mental impact revenue (purchased parts) is covered by certificates has been met ongoing issue for environmental management Reduction of Conversion relocation of the raised floor Floor Implemented 06/18 Done hazardous material coating to Neu-Ulm use and emissions Energy saving Reduction of energy Implementation of the “Switching off machines The machines that may be switched 06/18 Postponed consumption outside working hours” project off have been defined and labeled until decem- ber 2020 Reduction of energy Replacement of the CDP dryer’s thermal Planning, notification/approval, 02/18 Done consumption afterburning and installation of the CDP dryer’s new thermal afterburning. Energy conservation Reduction of energy Renewal of the ultrafiltration in CDP Proof of energy conservation 06/18 Done consumption Efficient processes Reduction of energy The tube washing unit was replaced with a tube The tube washing unit is no longer 10/18 Done consumption and cleaning unit. The cleaning is done by means of a in service chemicals foam plug that is shot through the tube with compressed air Using substitutes for Conversion of the floor coating to black for the Converted 01/18 Done hazardous materials Citaro Using substitutes for Substitution of black (zinc-free) for CDP paint Substitution started after authori- 06/18 Done hazardous materials zation by the Regierungspräsidium (regional administrative council) Reduction of noise Expansion of natural gas filling station Reduction of compressor run times 06/18 Done development per vehicle Reduction of Changing the assembly process in order to reduce Changed assembly sequence for 12/19 Taken over environmental impact reworking due to damage glazing and painted external parts in 2019 Avoidance of Incorporation of Mercedes-Benz Turkey in Use of standard load carriers and 06/19 Taken over packaging materials production network with standard load carriers gradual elimination of one-way in 2019 wood and cardboard packaging
* Status: April 15, 2019 8 Updated Environmental Statement 2019
Energy and environmental goals for 2019
Goals for 2019 Measure Assessment criterion Planned Primary res- date ponsibility Process optimization Reduction of CO₂ Derivation from green production for the location: By 40 % by 2030 12/30 BUS / OM emissions Reduction of absolute CO₂ emissions in Europe (base year 1992–94) Reduction of environ- Contribution to Daimler target of having 70 % of Annual pursuit of measures 04/19 TP / G52 mental impact supplier revenue (purchased parts) be covered by certificates for environmental management Reduction of environ- Reduction of wax application of the materials cur- Specification created in accordance 07/19 CQW mental impact rently used in B32 as a consequence of the use of with the floor coating changeover black floor coating and implementation coordinated with the unit. Reduction of the kg/vehicle is to be taken from the guideline values Energy saving Reduction of energy Derivation from green production for the location: By 2.5 % per vehicle per year by 12/30 BUS / OM consumption Reduction of global energy demand 2030 (base year 2013–14) Reduction of energy Reduction of the combustion chamber temperature Reduction of the combustion 05/19 OMB consumption of CDP-TNV following documentation of compliance chamber temperature from with limit values through measurement and public 745 °C to 725 °C authority confirmation Reduction of energy Implementation of the “Switching off machines Machines that can be switched off 12/20 OPT consumption outside working hours” project are defined and marked Reduction of energy Conversion of office lighting to LED in Building 135, Calculated saving Approx. 03/19 OMB consumption Rooms 101–103, and Building 45, Rooms 201–205 4,000 kWh/a Updated Environmental Statement 2019 9
Continuation energy and environmental goals for 2019
Goals for 2019 Measure Assessment criterion Planned Primary res- date ponsibility Efficient processes Increasing Derivation from green production for the location: To 90 - 95 %; -2.5 % per vehicle per 12/30 BUS / OM recycling rate Increasing the global recycling rate and objective: year by 2030 Waste for disposal „Zero waste to landfill“ (base year 2013–14) Conservation of Reduction of grab bar waste parts, waste optimiza- Assessment as to whether there 06/19 OMM resources tion, and fewer mistakes when making cutouts by are fewer complaints and duplicate using a new laser system productions Conservation of Use of smart repair in the finish area Reduced use of solvents 12/19 OMM resources Reduction of paper use Reduction of accompanying vehicle papers by using Using PDA yes/no 10/19 OMM PDA Avoiding packaging Incorporation of Mercedes-Benz Turkey into the Implementation of standard load 06/19 OSL production networkrnwith standard load carriers carriers and gradual elimination of single-use wood and cardboard packaging Reduction of environ- Changing the assembly process to reduce Changed assembly sequence for 12/19 OPL mental impact reworking due to damage glazing and painted external parts Reduction of masking Reduction of masking scopes in the work schedules Documentation of eliminated 04/19 OMB scopes in the floor masking scopes coating area on the front + rear 10 Updated Environmental Statement 2019 Updated Environmental Statement 2019 11 12 Updated Environmental Statement 2019
Figures, data, facts Updated Environmental Statement 2019 13
Production
Mannheim is the main production location of the Mercedes-Benz Citaro The calculation of production unit [PU] equivalents takes into account city bus fleet for public transportation. In addition, all bodies-in-white the amount of work done in all plants participating in the production of the Mercedes-Benz and Setra brands are produced here for assembly network. Since the introduction of this key figure in 2012, the value has at sister plants in Neu-Ulm and Ligny-en-Barrois (France). leveled out at between 2,000 and 3,000 PU equivalents.
In 2018, 2,107 fully-equipped buses were assembled at the Mannheim location, which corresponds to 2,766 manufacturing units [MUs]. The plant also prepared the bodies-in-white for 7,952 MUs. The number of manufacturing units is higher because an articulated bus consists of two manufacturing units.
Production figures
4000
3500
3000
2500
2000
1500
1000
500
0 2016 2017 2018 Manufacturing units (MU) Body-in-white MU for sister plants PU (production unit) equivalents 14 Updated Environmental Statement 2019
Emissions
Solvent Greenhouse gases The emissions of solvents overwhelmingly occur as a result of surface The greenhouse gases that are emitted by the technical systems at our coatings. The solvent emissions in Mannheim have decreased consid- Mannheim plant are mainly due to the use of natural gas as one of erably since 2011, when the vehicle topcoat painting process was the primary energy sources. In 2018, 2,081 metric tons of greenhouse transferred to the plant in Neu-Ulm. The use of solvents, measured in gases were emitted; this corresponds to a 14.0% increase compared VOC per square meter, is significantly lower than the legally prescribed to the previous year. limit value of 150 g per square meter and is thus at a good level. With the exception of one occasion where the carbon monoxide limit In 2018, the calculation of the VOC value was revised; it was updated value was exceeded, there were no further anomalies in the CDP-TNV on the basis of the sampling of old paints, the efficiency measurement unit in 2018. When the carbon monoxide limit value was exceeded, we and the vehicle surfaces. responded with immediate measures so that compliance with the limit value could be guaranteed again. Noise In 2018, there was a production-related noise complaint by a local The precise figures for greenhouse gas emissions from our plant can resident. Measures were promptly implemented in response to this; be found in the list of core indicators on page 23. compliance with these measures is ensured.
VOC figures
100
90
80
70
60
50
40
30
20
10
0 2014 2015 2016 2017 2018 VOCs in g/m₂ of surface to be painted per vehicle Proportion due to Mannheim plant Proportion due to Neu-Ulm plant Updated Environmental Statement 2019 15
Energy
The following diagrams depict the energy consumption, broken down Natural gas by the main energy sources. The consumption of heating oil is not The natural gas consumption for 2018 amounts to 10.7 GWh and represented here, because it is a negligible energy source, accounting is thus 8.3 % higher than in 2017. However, per manufacturing unit for less than 0.5% of the total energy consumption. The heating oil equivalent, it was reduced by 0.3 % to 3.7 MWh. consumption is taken into account when calculating the total energy consumption. The absolute energy consumption of the last three years at the Mannheim location is shown on page 21.
Electricity The diagram below shows the plant‘s electricity consumption from 2014 to 2018. For 2018, this amounts to 29.3 GWh and is thus higher than the previous year by approx. 7.7 %. This increase can be traced back to increased production figures. Consumption per manufacturing unit equivalent has decreased by 1.5 % to 10.1 MWh.
Electricity consumption Natural gas consumption
35 12
30 10
25 8
20
6
15
4 10
2 5
0 0 2014 2015 2016 2017 2018 2014 2015 2016 2017 2018 Consumption [GWh] Consumption per PU equivalent [MWh] Consumption [GWh] Consuption per PU equivalent [MWh] 16 Updated Environmental Statement 2019
District heating Compared to the previous year, consumption, both in absolute and The heat consumption is displayed for the third energy source. This is relative terns per degree day, increased by around 0.5 % and is approxi- additionally related to the degree days at the location. The relation to mately at the level of 2014 with 27.7 GWh or 10.1 MWh per degree day. the degree days is necessary because the heating requirement depends This can be traced back to the increased production program and the heavily on the weather conditions, and this is the only way to enable resulting increased hall usage time. a meaningful comparison with the previous years.
District heating consumption Total water consumption
30 140
120 25
100 20
80
15
60
10 40
5 20
0 0 2014 2015 2016 2017 2018 2014 2015 2016 2017 2018 Consumption [GWh] Consumption per degree day [MWh] Volume [10³ m₃] Volume per PU equivalent [m₃] Updated Environmental Statement 2019 17
Water
In order to document our water consumption figures, we first calculated The process cannot be broken down further because the monitoring the total consumption of freshwater. Overall, demand has increased system shows only the total consumption of the plant. With the current compared to 2017, both in terms of the total amount consumed and the monitoring system, it is not possible to assign consumption values to amount per production unit equivalent. The total water consumption the individual stages of production. We are planning to improve the trans- of 135,925 m3 in 2018 consists 82 % of well water and 18 % of drinking parency of the monitoring process so that we can assign specific con- water. The consumption of well water and water from public utilities is sumption figures. depicted on the following page. Water from public utilities Well water This representation of water consumption figures refers to the consump- The well water used in the plant is drawn by Daimler AG from wells at tion of drinking water (primarily for the sanitary facilities) provided the location, and it is used exclusively for production. The diagram in by public utilities. In 2018, the drinking water production decreased by the bottom left corner shows that the amount drawn in 2018 increased around 6.1 % to 24,953 m3 compared to the previous year. In terms by 19 % from 93,242 m3 to 110,972 m3 compared to the previous year. of the production unit equivalents, consumption was also reduced by Consequently, the amount per production unit equivalent also increased 13.7 % to 8.62 m3 per PU. by 9.1 % from 35.1 m3 to 38.3 m3. The increased demand for well water is, on the one hand, a consequence of increased production figures and, on the other, a consequence of the high temperatures during the summer months, which meant the cooling systems were used more intensively.
Well water consumption Water from public utilities
120 30
100 25
80 20
60 15
40 10
20 5
0 0 2014 2015 2016 2017 2018 2014 2015 2016 2017 2018 Volume [10³ m₃] Volume per PU equivalent [m₃] Volume [10³ m₃] Volume per PU equivalent [m₃] 18 Updated Environmental Statement 2019
Waste water
Waste water is, on the one hand, dependent on production and, on the The waste water from the cathodic dip painting process (CDP), the portal other, a base load in the production facilities, supplemented with a unit for surface treatment (PUST), the pretreatment for the powder certain amount from the sanitary areas. The total amount is calculated unit and the bus leakage test are tested in accordance with the applicable by taking the freshwater consumption and subtracting the volume self-monitoring guideline for the state of Baden-Württemberg. of water that has been calculated but not discharged. The waste water value in 2018, subject to the increased fresh water consumption In 2018, the limit value was not exceeded at all during external waste compared to 2017, also increased significantly. water investigations.
The waste water discharges occur exclusively into the municipal sew- The plant regularly shares information with the responsible authorities. erage system and are subject to continuous monitoring as an indirect Determined limit value violations are communicated to them, but, discharge. Thus, again in 2018, the discharge points were regularly if necessary, solutions to problems are also striven for, defined and tested by the municipal waste water system of the city of Mannheim. implemented together. Based on this sampling, the city imposed a surcharge based on the parameters of the total nitrogen bound, phosphorus (TP), and the total organic carbon (TOC) in accordance with the waste water regulations.
Wastewater development
140
120
100
80
60
40
20
0 2014 2015 2016 2017 2018 Total wastewater [10³ m₃] Treated wastewater [10³ m₃] Evaporated volume [10³ m₃] Wastewater from sanitary facilities [10³ m₃] Wastewater per PU equivalent [m₃] Treated wastewater per PU equivalent [m₃] Updated Environmental Statement 2019 19
Waste
Production waste Recycling/disposal Waste is recycled or disposed of under the waste generator number A positive note is the fact that almost all of the total production waste, of EvoBus GmbH Mannheim. The technical process has been conducted 99.7 %, to be exact, was recycled in 2018, the same proportion as in since 2016 at the disposal center on the premises of EvoBus GmbH. the previous year. A total of 6,336 metric tons were recycled, and 16 metric tons were disposed of. The total volume of production waste was 6,352 metric tons in 2018, which represents an increase compared to the previous year. Because the amount of waste for disposal has been very low since This increase can be traced back to higher body-in-white production, 2014, it is no longer represented in the diagram below. which is associated with a higher occurrence of scrap metal. The high percentage of scrap metal, amounting to 62.3 % or 3,956 metric tons, is characteristic of body-in-white production.
Production waste development Proportion of waste recycled/disposed of
7000 3000
6000 2500
5000 2000
4000
1500
3000
1000 2000
500 1000
0 0 2014 2015 2016 2017 2018 2014 2015 2016 2017 2018 Total [t] Recycled [t] of which, scrap metal [t] Disposed of [t] Waste recycled per PU equivalent [kg] Waste disposed of per PU equivalent [kg] 20 Updated Environmental Statement 2019
Transportation & external companies
Transportation External companies on the plant site and inclusion of suppliers Since 2016, we have been delivering bodies-in-white to our sister The external companies that operate at our location are bound to con- plant in Neu-Ulm exclusively by train. Because of the greatly divergent tractual agreements. In addition, at least once a year, they attend an transportation costs, we are continuing to deliver bodies-in-white informational event at our location, where they recommit themselves to Ligny-en-Barrois (France) by truck. In 2018, 85.6 % of these products to fulfill the requirements of our management system. were transported by train. The current record value of 89.4 % was reached in 2016.
We are continuously optimizing the filling levels of our load carriers for internal and external product deliveries.
The completed buses leave the plant on their own axles.
Body transport (shipping)
100
90
80
70
60
50
40
30
20
10
0 2014 2015 2016 2017 2018 Body shipment by train [%] Updated Environmental Statement 2019 21
Core indicators according to EMAS III
The amended EU directive EMAS III requires us to evaluate our environ- Based on the amendment of appendix IV of the EMAS directive, the pro- mental Performance. duction unit equivalents are selected as a new relationship indicator and thus replace the added vehicle-related and model-related mass of the We are expected to present the core indicators of our energy and vehicle deliveries and bodies-in-white shipped as a relationship indicator. materials efficiency, water consumption, waste generation, land con- A detailed representation of the environmental performance is enabled sumption in relation to biological diversity, and emissions and to using this approach, as is the observance of special characteristics. indicate the relationship between these core indicators and the plant’s The efficiencies of the core indicators for the years 2016 and 2017 were overall output or value creation. also updated with regard to the new production unit equivalent rela- tionship indicator. Energy consumption consists of the figures for electricity, natural gas, hot water and heating oil. The comparative development of the plant‘s environmental performance can be represented by means of the specific key figures and the core indicators we have used. Because of the unique nature of the activities at the location, no cross comparisons or sector comparisons are possible.
The core indicators are represented in a table on the following pages.
Core indicators according to EMAS III – Input
Year Ipsum 2016 2017 2018
Production unit equivalents ¹ 2.572 2.638 2.885 Core indicator Energy consumption Absolute amount [MWh] 62.083 64.667 67.692 Efficiency [MWh/Stk] 24,14 24,51 23,46 Proportion of energy from renewable sources ² Absolute amount [MWh] 0 0 0 Mass flow Input ³,⁴ Absolute amount [t] 42.688 41.863 66.474 Efficiency [t/Stk] 16,60 15,87 23,04 Water consumption ⁵ Absolute amount [m3] 124.763 119.814 135.925 Efficiency 3[m /Stk] 48,51 45,42 47,11 Land consumption in relation to biological diversity ⁶ Absolute amount [m2] 267.808 258.703 258.703 Efficiency 2[m /Stk] 104,12 98,07 89,67
¹ Determined integral bus coordinated production system ² No renewable energy is produced at the plant ³ Sum of tonnage and production waste ⁴ 2018 value using new calculation method ⁵ Total water consumption ⁶ Sealed area due to buildings and asphalting 22 Updated Environmental Statement 2019
Core indicators according to EMAS III – Output Part 1
Year 2016 2017 2018 Equivalent unit of production ¹ 2.572 2.638 2.885 Core indicator Mix of recyclable materials Absolute amount [t] 1.052 986 958 Efficiency [t/Stk] 0,4090 0,3738 0,3321 Emulsions Absolute amount [t] 294 341 268 Efficiency [t/Stk] 0,1143 0,1293 0,0929 Sludges from the plant’s wastewater treatment Absolute amount [t] 258 271 298 Efficiency [t/Stk] 0,1003 0,1027 0,1033 Other waste fractions < 200 t Absolute amount [t] 729 585 873 Efficiency [t/Stk] 0,2834 0,2218 0,3026 Scrap metal Absolute amount [t] 3.549 3.342 3.956 Efficiency [t/Stk] 1,3799 1,2669 1,3712 Total amount of production waste Absolute amount [t] 6.044 5.652 6.352 Efficiency [t/Stk] 2,3499 2,1425 2,2017 Total amount of hazardous production waste Absolute amount [t] 748 719 713 Efficiency [t/Stk] 0,2908 0,2726 0,2471 Total amount of construction waste ⁷ Absolute amount [t] 889 2.239 898
¹ Determined integral bus coordinated production system ⁷ No calculation of efficiency Updated Environmental Statement 2019 23
Core indicators according to EMAS III – Output Part 2
Year 2016 2017 2018 Equivalent unit of production ¹ 2.572 2.638 2.885 Core indicator Greenhouse gas emissions ⁸ Absolute amount [t] 1.933 1.825 2.081 Efficiency [t/Stk] 0,7516 0,6918 0,7213
Pollutant emissions NOX ⁹ Absolute amount [t] 2.190 2.312 2.504 Efficiency [t/Stk] 0,8515 0,8764 0,8679 Pollutant emissions SO₂ ⁹ Absolute amount [t] 310 158 187 Efficiency [t/Stk] 0,1205 0,0599 0,0648 Pollutant emissions PM ⁹ Absolute amount [t] 1.029 1.090 1.428 Efficiency [t/Stk] 0,4001 0,4132 0,4950 Pollutant emissions VOC ¹⁰ Absolute amount [t] 67 72 62 Efficiency [t/Stk] 0,0260 0,0273 0,0215
¹ Determined integral bus coordinated production system ⁸ CO₂ due to gas, heating oil, refills of refrigerants (new GWP conversion factors starting in 2016). Up to 2015, coolant with CH₄, N₂O from personnel and freight transport ⁹ Due to natural gas and heating oil. Calculation according to GEMIS 4.2 ¹⁰ Due to sealing of surface areas 24 Updated Environmental Statement 2019 Updated Environmental Statement 2019 25 26 Updated Environmental Statement 2019
Validation Updated Environmental Statement 2019 27
The undersigned, Dipl.-Geol. Bernhard Schön, EMAS environment expert of TÜV SÜD Umwelt- gutachter GmbH with the registration number DE-V-0321, accredited or authorized for Unit 29 (NACE code) confirms that he has assessed whether the location, as published in the Environ- mental Statement 2019 of the organization EvoBus GmbH, Mannheim plant, with the registra- tion number DE-153-00022, fulfills all the requirements of the directive (EC) No. 1221/2009 of the European Parliament and of the Council of November 25, 2009, and the directive (EU) 2017/1505 from August 28, 2017, concerning the voluntary participation of organizations in a shared system of environmental management and environmental audit measures (EMAS).
By signing this declaration, I confirm that
» the audit and the validation were conducted in full conformity with the requirements of directive (EC) No. 1221/2009 and directive (EU) 2017/1505, » that the result of the audit and the validation confirms that there is no evidence of nonconformity with the applicable environmental regulations, » and that the data and the content of the location‘s Environmental Statement provide a reliable and truthful picture of all of the activities of the location within the unit speci- fied in the Environmental Statement.
This declaration cannot be equated with an EMAS registration. The EMAS registration can be completed only by a competent authority in accordance with directive (EC) No. 1221/2009 and directive (EU) 2017/1505. This declaration must not be used as an independent basis for infor- ming the general public. The present Environmental Statement has been audited and declared valid.
Munich, May 31, 2019
Bernhard Schön Environmental verifier DE-V-0321 Daimler AG Mercedesstraße 137 70327 Stuttgart Germany www.daimler.com