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ELV (EU)


The ELV Directive and Your Business

Successful compliance with the European Union’s End-of-Life Vehicle Directive (Directive 2000/53/EC) requires coordination of data collection and consolidation along the entire supply chain as well as constant attention to the ever-increasing of declarable and prohibited substances list (aka the GADSL) that must be tracked across all vehicle components.

Need background?

Click here for basic information about the ELV regulation:

  • Requirements

  • Risks (Business, market, competitor, legal)

  • Solutions

Looking for Updates and Alerts? July, 2015: 3 recent Items of interest

1

What Happened

A company that only uses IMDS (the automotive industry’s ELV data collection mechanism) occasionally recently contacted RSJ in a panic because a PPAP deadline was only a day away and they had lost access to their IMDS account when their only Company Administrator left the company.

What Impact It Might Have

Failure to meet PPAP submittal deadlines might trigger contract penalty provisions for failure to supply required documentation. Such penalties can be significant and will impact the profitability of the sale for which the PPAP is required.

What We Recommend

Make sure that when a person with a Company Administrator user designation in IMDS transfers to a new position or leaves the company that transfer of Company Administrator duties to another staff is part of the transfer/exit process.

2

What Happened

The EU Regulation (EU) No 528/2012 concerning the making available on the market and use of biocidal products entered into force on September 1, 2013. Three of the nine product categories included in the regulation are likely to be found in vehicles. As a result new substances were added to the GADSL in 2014.

What Impact It Might Have

Materials and components in vehicles that were previously compliant may now be non-compliant. The determination of compliance rests on whether or not the substance(s) in question were added to a material for their biocidal properties or for some other purposes. If for biocidal purposes, the product may now by non-compliant.

What We Recommend

Review your products for these recently added substances and determine the purpose for which the substances were included in material formulations. For any found to be added for biocidal purposes, determine if the requirements for use have been met or if action is required to bring the identified products into compliance.

3

What Happened

Under the REACH regulation glass is a UVCB substance (unknown or variable composition, complex reaction products or biological materials). It is virtually considered as a single substance and does not contain individual elements or oxides anymore. IMDS data used to support ELV documentation has traditionally shown the individual elements and oxides in glass, ceramic and enamel materials. The REACH approach to showing such materials as UVCBs has been implemented in IMDS.

What Impact It Might Have

Glass and ceramic materials in IMDS may include declarable or prohibited substances as part of the material formulation that are not actually present in the finished glass or ceramic material. This means that all the requirements regarding tracking and managing such substances are not actually applicable.

What We Recommend

Review and update any glass, ceramic, or enamel materials in your IMDS data to meet the new standards for reporting these materials. This may require working with suppliers to obtain updated IMDS submissions.