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Expert Opinion on the Prohibition of Hazardous

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Expert Opinion on the Prohibition of Hazardous EXPERT OPINION CONCERNING PROHIBITION OF HAZARDOUS SUBSTANCES IN CERTAIN VEHICLE MATERIALS AND COMPONENTS PB/22875bis PART 1: Regarding entry 2, 8 and 21 in Annex II of the ELV Directive Cd Cr6+ Hg B- ns\P a Lever V\7_ nion EL opi Pb 938 Expert 05 1 el\10 Bryss 1.0 t, ot ver d c do 03. 1. 20 T - t October 11, 2004, U Liljenroth 04\Miljöministerie PAR ppor 20 s \ a 5bi R : 7 501 l l a L:\3 228 M WSP Environmental 2 (23) Content 1. Introduction 1.2 Summary 2. Entry 2 2.1. Summary from relevant stakeholders 2.2. Reflections and comments from other industries and relevant sources 2.3. Conclusions and comments 2.4. Expert opinion 3. Entry 8 3.1. Summary from relevant stakeholders 3.2. Reflections and comments from other industries and relevant sources 3.3. Conclusions and comments 3.4. Expert opinion 4. Entry 21 4.1. Summary from relevant stakeholders 4.2. Reflections and comments from other industries and relevant sources 4.3. Conclusions and comments 4.4. Expert opinion Attachment 1-3 1. Introduction The purpose of this report is to offer support to the judgement of the authorities in EU member states about the possible review of three entries (2, 8 and 21) of annex II of the ELV Directive by means of an independent expert opinion. In addition an independent assessment of industry opinion regarding the other B- entries of the same annex is also offered in a second report. ns\P a Lever Basically the procedure to formulate the independent expert opinion has V\7_ included the following steps: nion EL 1) Read input, comments and position from the concerned industry and opi independent studies on the subject. 938 Expert 2) Contact relevant Universities, Research Institutes, manufacturers and 05 1 suppliers in relevant branches to discuss the latest state of research el\10 activities, trends and future development. Bryss 1.0 t, 3) Based on input, in combination with own experience in the field, make ot ver d c an assessment of available information and input and formulate the do 03. 1. 20 T expert opinion. - t 04\Miljöministerie PAR ppor 20 s \ a 5bi Received answers and input have been kept anonymous in most cases. This is R : 7 501 l l a done to protect the individual in the case the statement is not fully in line with L:\3 228 M the common industry opinion. 3 (23) 1.2. Summary Entry 2 allows the use of lead as an alloying element in aluminium for machining purposes (2% until July 2005 and 1% until July 2008). Most stakeholders acknowledge a reduction and phase out of lead as an alloying element in aluminium. The long-term goal should be that no lead is intentionally added. It should also be acknowledged that material changes in car industry are a complex issue. Extensive testing is needed. The car industry supply chain is complex with several supplier levels. An additional issue is also the availability of alternative aluminium qualities on a worldwide scale Meeting the 1% Pb limit July 2005 is to optimistic. With the reason above as a background the lead content limit of 2% (or reduced to 1,5%) ought to extended until July 2008 and be reviewed before the phase-out date. A threshold level up to 0.4% by weight of lead, unlimited in time, is necessary to allow future recycling of aluminium. Entry 8 allows the use of lead and lead compounds in vulcanising agents and stabilisers for elastomers in fluid handling and power train applications until July 2005. Lead-stabilisers are already replaced in elastomer types. For vulcanising agents including the bonding agents however, some issues still need to be resolved. There is no long-term reason why lead should be added to rubber. Alternatives are available. Taking these opinions and factors into account there are no reasons to change the current wording in entry 8. B- Entry 21 allows the use of cadmium in batteries of electrical vehicles until ns\P a December 2005. Lever V\7_ The environmental impact of cadmium is high. Substitution of cadmium containing batteries in vehicles as well as in other applications should be a nion EL priority item. Replacing NiCd batteries by NiMH batteries (or Pb batteries) in opi EVs (electric vehicle) is not a technology problem. However phase out of NiCd batteries by 2005 will require organisational and major economic efforts for the 938 Expert companies concerned. 05 1 el\10 Weighting advantages and disadvantages with a phase out of NiCd is difficult. Bryss From an environmental point of view cadmium should be phased out as soon 1.0 t, as possible. Maintaining the ban of cadmium in batteries in electrical vehicles ot ver d c from December 2005 will in the short-term lead to a reduction of EVs offered on do 03. 1. 20 T the market. In the longer term more cost efficiently produced NiMH batteries for - t 04\Miljöministerie EVs will be offered and the number of HVs (hybrid electric vehicle) will increase PAR ppor 20 s \ a 5bi levering the short-term effect. R : 7 501 l l a L:\3 228 M 4 (23) 2. Entry 2 allows the use of lead as an alloying element in aluminium for machining purposes 2.1. Summary from relevant stakeholders, i.e. their answers to questions 1-4 in the a consultation round on the revision of certain entries of Annex II of the ELV Directive (see also attachment 1) Some aluminium grades according to international standards have Pb content up to 2% by weight added for machining purposes. Currently substantial quantities (50,000 t/year estimated) of aluminium alloys with lead contents of between 1% and 2% by mass are placed on the market. A major part (35,000 t/year estimated) is used by the automotive industry. These grades are still required within the automotive industry for several safety related parts e.g. brake system, steering system, chassis and power train parts. These relatively small aluminium parts can only be machined if the chips are small enough and break away during machine operation, this is achieved by adding lead. The metal producing industry considers tin, zinc and bismuth as possible substitutes for lead in some applications. Pilot runs and components tests at suppliers confirmed that some lead free alternative alloys are more difficult from a machining point of view. In addition the fatigue strength is lower and problems are suspected with creep behaviour. Aluminium alloys with Sn (tin) in contact with brake fluid and fuel with ethanol did not meet all corrosion and durability requirements for concerned applications. It is argued that alloys with less than 1% lead cannot be machined into products of the required quality and to the desired cost. Comments related to possible phase out of lead vary. Some stakeholders argue it is not possible at all, i.e. the limit of 2% Pb needs to be unlimited. Some argues problems with the 1% limit after July 2005. A major component supplier also proposes July 2012 as the final phase out limit. 4 5 (23) 2.2. Reflections and comments from other industries and relevant sources Opinion 1: Air and Space industry Lead in cast aluminium alloys is not an issue in their applications. Other added materials such as bismuth solve the machinability issue. However the demands for high speed mass volume production of components are quite different in their industry compared to the car industry. This could be one reason why it is not necessary to use aluminium alloys with lead in the air and space industry. Opinion 2: Scandinavian Research institute Lead not present in alloys used by airplane manufacturing industry, except for some few exemptions where lead is present up to 0,5%. Opinion 3: European car manufacturer European car manufacturers should not experience any difficulties with the current entries in Annex 2. The use of aluminium alloys with lead is more widely spread in countries outside of the EU where fulfilling the 2008 limit might be more difficult. The recycling aspects are very important. As Pb accumulates in recycled aluminium remnants of Pb must be allowed up to 0,4% to make it possible to recycle aluminium in the long run. Due to this aluminium alloys with 1-2% Pb are not welcome in the recycling industry. Opinion 4: Aluminium material supplier Replacing Pb as alloying element in aluminium is not a real technology problem. It is more a question of modifying and retuning present production lines to alternative materials. However considering the high volume production in the car industry this is an expensive and time- consuming matter for them. The worldwide availability of alloys with alternatives to Pb could also be an issue that will take some time to solve. Opinion 5: Aluminium material supplier/component supplier No lead is present in their cast aluminium materials offered on the market of today. Opinion 6: Swedish Standards Institute, SIS Very few standard alloys are present with Pb added in volumes 1-2%. Some EU and American standards are available. Availability of these alloys will be difficult in the future due to decreased demand. Opinion 7: European truck manufacturer Lead in an unwanted substance in their aluminium components. Their standards do not allow Pb to more than some tenths of a percent. They experience difficulties to get aluminium qualities with really low content of Pb, less than 0,1-0,2 %. Opinion 8: Aluminium Magazine Lead has an improving role in relation to mashinability.
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