In April, we were present with a booth at the CLEPA Materials Regulations Event in Kurhaus Bad Homburg as a Hewlett Packard Enterprise (HPE) partner. We enjoyed the many interesting talks with customers and other visitors. Among other things, we were able to make a presentation showing how the IMDS a2 tool of HPE can be used to enter parts lists automatically in IMDS. We had lively discussions on the time saved as compared to manual entry, besides other advantages and problem-solving options. You can download the presentation as a pdf document.
The papers presented at the conference were equally interesting. We have come away with much information that is relevant for you and which we would like to pass on to you now.
Thus, for instance, the new release 11 will go live in November this year. It will incorporate the so-called Chemistry Manager, which is meant to make it easier for companies to provide substance declarations and share information on the chemicals used. From summer onwards, we will offer you information webinars and, from autumn onwards, trainings in the new release in the form of both webinars and live seminars. You will find the dates in the current training plans.
The Stockholm Convention and the EU POP regulation were an important topic at the event. Both have been in force since 2001 or 2004, but the automotive industry had not been affected by them so far. The agreements regulate the handling and/or prohibition of persistent organic pollutants, which are not easily bio-degradable and can have carcinogenic and reprotoxic effects. Since 2014, the flame retardant Hexabromocyclododecane (HBCD or HBCDD) has been added to the list of POPs. A ban on the flame retardant Decabromodiphenylether (DecaBDE) used, among other things, in vehicles, is currently being discussed and will be decided in 2017. We will soon offer webinars on this topic as well.
- In February, 157 substances on the list were either revised, added or deleted.
- The three documents ("GADSL Document", "Reference List" and "Guidance Document") were consolidated into two documents ("GADSL Guidance Document" and "GADSL Reference List").
- In August, there will be another update of REACH where it will be decided whether all the biocides from the EU Ordinance 528/2012 are reflected in it.
- A Global List of Automotive Process Substances is being developed, since currently every OEM maintains its own list; the aim is to develop a harmonised list.
- The list focuses on production parts that are still present in the final product, production equipment, prototypes, the maintenance and repair of production parts as well as chemical products for the accessories market.
- The composition of the list will be similar to that of GADSL and shall have four classifications: P for prohibited, R for reportable, U for unknown, and N for not reportable.
- Members of the Steering Committee and the regional teams are still being selected.
- Initially, the list will not be incorporated in IMDS.
Current developments in ELV
- The 7th revision of Annex II is scheduled in 2016, during which the focus will be on: prohibition of heavy metals. This revision will affect the exceptions 8e, 8f, 8g, 8h, 8j and 10d.
ELV developments in Asian countries
- Japan: JAMA Gentleman’s Agreement: in force since January 2005; applies to all L, M and N classes; prohibits lead, mercury, cadmium, chromium VI.
- Korea: Korea ELV Recycling Regulations: in force since January 2008; apply to class M1 and N1 vehicles; prohibit lead, mercury, cadmium, chromium VI; recycling- and recovery rates of 85 or 95 percent.
- China: China ELV Management Requirements: in force since January 2016 for all new types, and since January 2018 for all new vehicles; apply to class M1 domestic production vehicles; prohibit lead, mercury, cadmium, chromium VI, polybrominated biphenyls (PBB) and polybrominated diphenylethers (PBDE). The China Compulsory Certification for class M1 and N1 imported vehicles has also been in force since 2010 (new types) or 2012 (new vehicles), under which the above mentioned substances will be prohibited from January 2015 (new types) or from June 2016 (new vehicles).
- India: Indian ELV: expected in 2017; meant for class M1, L1 and L2 vehicles; recovery rate of 85 percent; recycling rate of 80 percent; ban on lead, mercury, cadmium, chromium VI.
- Malaysia: Malaysian standard: expected in 2022; meant for class M1 and N1 vehicles; recovery rate of 95 percent; recycling rate of 85 percent; ban on lead, mercury, cadmium, chromium VI.
- The sunset date for chromium trioxide is due in 2017, however it has not yet been decided how this substance should be handled in future or how it should be reported.
- There is a new article definition (O5A) Once an article, always an article. More information on this can be found at http://www.acea.be/publications/article/reach-automotive-industry-factsheets.
- Ban on phthalates: these substances will be banned latest by 2023.
- In June 2015, the Annex “Safety Data Sheet Compliance Checks” was added to “REACH: Automotive Industry Guideline”. Meanwhile, these checks are mandatory for compliance with statutory obligations. More information on this can be found at http://www.acea.be/publications/article/reach-safety-data-sheet-compliance-checks.
Ordinance on Biocidal Products (BPR, Ordinance No. 528/2012)
- Has been in force since September 2013 and regulates products that fight harmful organisms (e.g. pests or bacteria).
- Upcoming deadlines are in September 2016 and March 2017.
All the presentations from the CLEPA event can be downloaded from this link http://clepa.eu/events/201604-materials-regulations-event/.
If you have any questions, please call us on +49 6083 / 913030 or send us an email any time to email@example.com.