Heavy Metals in Vehicles II

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Executive Summary

Directive 2000/53/EC on End-of-Life Vehicles aims at the prevention of wastes from vehicles and at the reuse, recycling and other forms of recovery so as to reduce the disposal of waste, while at the same time improving the environmental performance of all of the economic operators involved.

More specifically, Art. 4 (1) of the Directive states that “in order to promote the prevention of waste Member States shall encourage, in particular, (a) vehicle manufacturers, in liaison with material and equipment manufacturers, to limit the use of hazardous substances in vehicles and to reduce them as far as possible from the conception of the vehicle onwards, so as to in particular prevent their release into the environment, make recycling easier, and avoid the need to dispose of hazardous waste (...).” Art. 4(2)(a) continues that “Member States shall ensure that materials and components of vehicles put on the market after 1 July 2003 do not contain lead, mercury, cadmium or hexavalent chromium other than in cases listed in Annex II under the conditions specified therein.”

Annex II contains a list of 13 applications of the four substances lead, mercury, cadmium and hexavalent chromium which are exempted from Article 4(2)(a) either generally, or up to a certain concentration or absolute mass limit. For five applications, the exemption is granted only under the condition that they will be “labelled or made identifiable in accordance with Article 4(2)(b)(vi)” with the purpose of stripping them from end-of-life vehicles before further treatment in order to avoid unwanted contamination of the material streams which result from the recycling operations. Annex II further mentions five applications which are to be examined as a matter of priority, three of which refer to potential additions to the list of 13 applications and two of them to potential deletions, in order to establish as soon as possible whether Annex II is to be amended accordingly.

The purpose of this study is to provide the Commission with technical information in view of possible amendments of Annex II of the Directive 2000/53/EC of the European Parliament and the Council of 18 September 2000 on End of Life Vehicles (ELVD). The main results of the study presented herewith show that Art. 4(2)(a) of the ELV Directive has indeed highlighted an area where significant improvements with Heavy Metals in Vehicles II [Final Report July 2001] Institute for Ecology and Political Affair respect to reduced use of hazardous substances can be achieved, thus leading to an
improved recyclability of vehicles and a better environmental performance in the recycling sectors, as well as resulting in "cleaner" waste to be disposed of. Many of today’s applications of the problematic substances can in fact be avoided or substituted, even if this may require a certain period of time in some cases.

The discussions around the evolving ELV Directive have already exerted a strong stimulus on industry to avoid the problematic substances, either by directly substituting them, or at least by taking up research for alternatives which had been neglected in recent years.

In addition to the concepts of general exemption, exemption up to a certain limit, exemption with mandatory labelling and dismantling which are already contained in Annex II, the present report suggests the concepts of

  • mandatory dismantling if a certain maximum allowable amount (of lead per car) is exceeded
  • temporary exemptions until a specified date,
  • stepwise phase-out for complex fields of application where some uses of a substance are easier to avoid than others.

For a number of entries in the list of Annex II, some minor rewording is suggested in order to be technically more precise and avoid misunderstanding, and additional entries are suggested for the two applications of “lead in wheel balance weights” (temporary until 1/7/2004) and “electrical components which contain lead in a glass or ceramics matrix compound”. Among the latter, PZT ceramics around the engine shall not be restricted, but mandatory labelling and dismantling is suggested for applications on the chassis if a maximum amount of 30 g lead from this source is exceeded, because applications on the chassis are likely to reach the shredder light fraction. A similar requirement for labelling and dismantling above a threshold value of 30 g per vehicle is proposed for “solder in electronic circuit boards and other electrical applications”.

A deletion from Annex II is proposed for lead-containing coatings inside fuel tanks. Several new applications were submitted by industry during the course of the study. For some of these, temporary exemptions until a specified date are proposed.

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