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Timetable for Lead Exemptions in Car Parts Nears Adoption

Hong Kong sellers of car parts may like to know that the presence of lead in certain vehicle parts will be permitted in the EU over the next two to seven years under European Commission proposals, which are expected to enter into force this coming autumn.

It may be recalled that Directive 2000/53/EC concerning end-of-life vehicles (the ELV Directive) sets clear quantified targets for the reuse, recyclability and recovery of waste vehicles. It also prohibits the use of hazardous substances in the manufacture of new vehicles except in defined exemptions where there are no adequate alternatives. Of particular interest, it provides for a ban on lead, mercury, cadmium or hexavalent chromium for materials and components of vehicles put on the market after 1 July 2003.

The Draft Commission Directive amends Annex II of the ELV Directive which is concerned with exemptions to this ban. A maximum concentration value up to 0.1% by weight in homogeneous material for lead, hexavalent chromium and mercury and up to 0.01% by weight in homogeneous material for cadmium shall be tolerated in general. The draft rules outline higher acceptable concentration values for specific materials and components.

Aluminium alloys with a lead content of up to 0.4% by weight will be exempted from the ban until 2024.

Aluminium alloys which are used for the shaping of car components, otherwise known as ‘machining’, will face an earlier deadline of 2021. The reason behind this seems to be that the Commission expects manufacturers to require less time to find alternatives to lead for such materials.

Copper alloys containing up to 4% lead by weight within vehicles will, furthermore, be exempted from the end-of-life vehicle lead ban until 2021; this is in order for emerging substitutes to be suitably developed.

Additionally, lead in vehicle batteries will generally be allowed until the derogation is reviewed in 2021. The battery exemption is to be phased out by 2019 for a specific group of high-voltage batteries used in smaller motor vehicles, as alternatives to lead for those are felt to already be existing.

Other exemptions, for example for lead in high melting temperature type solders, will be reviewed in 2019.

The Commission’s proposal is currently being reviewed by the European Parliament and the EU Council. If no objections are received by 18 October 2017, the rules will proceed to the formal adoption phase.

The Commission’s proposal and its timetable were supported by the Commission’s consultants’ recommendations last April. These recommendations affirmed the Commission’s intentions to review the exemptions regime contained within the ELV Directive.

The Commission undertook its public consultation to improve the implementation of certain aspects of the ELV Directive. The consultation lasted for twelve weeks, from 22 June 2016 to 14 September 2016.

On 27 February 2017, the Commission released its final report on the implementation of the ELV Directive for the periods 2008-2011 and 2011-2014. It concluded that implementation of the Directive had mainly been positive with the exception of one issue. The Commission found that there was a high number of EU vehicles of unknown whereabouts whose materials and content may be valuable and can potentially cause significant environmental harm without proper treatment.

Member States reported good practices working with manufacturers on the composition of materials and components. Ecodesign is also believed to be constantly improving, while the prohibited hazardous substances used in cars are almost eliminated. In addition, targets for reuse, recycling and recovery are largely met.

Content provided by Picture: HKTDC Research
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