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ELV Overview

A thorough understanding of the requirements the European Union’s End-of-Life Vehicle Directive (Directive 2000/53/EC) is critical to successfully collecting the necessary data and meeting the requirements of the automotive Production Part Approval Process (PPAP).

IMPACT OF THE EU’S ELV DIRECTIVE ON:

  • Automotive manufacturers who place product on the EU market

  • All-sized suppliers who provide materials, components and/or assemblies to the automotive manufacturers who place product on the EU market

What you need to know

What you need to watch for

Legislative History

Geography/Markets

Liability

How ELV impacts companies

ELV Requirements

ELV Risks

ELV Enforcement and Penalties

What you need to know

  • Adopted to reduce automotive scrap in the waste stream in Europe and reduce the environmental impact of scrap vehicles.

  • Directs automotive OEMS to design and produce vehicles in a manner that takes into account and facilitates the efficient dismantling, reuse and recovery of the vehicle, its components and materials at the end of the vehicles life

  • Primary requirements of ELV can be divided into two parts

    • The establishment of recycling targets and

    • The implementation of requirements eliminating four substances from vehicles.

  • Establishes reuse and recovery targets for vehicles being dismantled at the end of their useful life

    • 85% target as of 2006 of which only 5% could be energy recovery (incineration to generate steam and electricity)

    • 2015 this target moved to 95% of which only 10% could be energy recovery

    • Manufacturers are required to prove their vehicles can meet these recycling targets through a calculation performed according to the ISO 22628 Standard

    • Under the later released Reusability, Recyclability and Recoverability of Vehicles (RRR) Directive vehicle manufacturers are required to submit a report with calculations proving their vehicles can meet these standards at the time vehicles are going through type-approval for the European Market

  • Establishes substance elimination requirements

    • Reduction of lead, mercury and hexavalent chromium in each homogeneous material in a vehicle to less than 0.1% by weight per homogenous material

    • Reduction of cadmium in each homogeneous material in a vehicle to less than 0.01% by weight per homogenous material

    • Includes permissible exemption to these limits (documented in Annex II of the directive)

      • Some exemptions do not have an expiration date, e.g. the exemption for up to 0.35% lead in steel

      • Some exemptions have a sunset data after which the exemption will no longer be allowable, e.g. lead in the dielectric ceramic material of capacitors with a voltage of less than 125 volts AC or 250 volts DC which is allowable only on vehicles that are type approved prior to January 1, 2016.

    • Annex II has been updated several times since the directive’s initial release, most recently May 17 2013 (2013/28/EU).

  • In response to ELV the automotive OEMS created the International Material Data System in order to collect and consolidate the data from all tiers in their supply chains

  • The data collected via IMDS is used to

    • Identify where banned or regulated substance are found in vehicles; and

    • To classify vehicle materials in order to perform recyclability calculations

  • IMDS tracks all declarable and prohibited substances in the regulations and laws that affect the automotive industry

    • Declarable and prohibited substances are listed on the Global Automotive Declarable Substances List (GADSL)

    • GADSL is updated on an irregular basis depending on changes in the underlying regulations

  • IMDS includes provisions for maintaining the confidentiality of proprietary information while still making the required declarations regarding material substance content

  • Vehicle disposal is impacted by more than the ELV Directive and this means that regulatory requirements that go beyond those in the ELV Directive are inextricably tied to it. Because a vehicle is such a complex product which includes among other things electronic equipment and hazardous operating fluids the following EU directives and regulations also impact ELV and IMDS:

    • The Waste Electrical and Electronic Equipment (WEEE) Directive provides guidelines for electronics waste disposal.

    • The Directive on Restriction of Use of Certain Hazardous Substances (RoHS) bars use of materials like lead, mercury, and cadmium in the production of electrical and electronic equipment.

    • The REACH regulation dictates the proper handling and disposal of certain chemical substances as well as banning or restricting the use of certain substances in materials.

What you need to watch for

  • Customers requiring suppliers to provide quality data along with quality materials and products, in order to help them comply with ELV. This requirement is and will continue to be a condition of winning business and/or receiving payment.

  • Updates in the substances listed on the GADSL can change the compliance status of products overnight. It is critical that all substances in your product be included in your IMDS data to facilitate identification and modification of products which contain newly declarable or prohibited substances.

  • Products going to OEM participants in IMDS will likely be required to comply with ELV even for vehicles that are not sold in the EU. Exceptions for non-ELV-compliant products are rarely granted by OEMS.

  • Companies entering the automotive supply chains for the first time must quickly master the intricacies of IMDS and the requirements of collecting data for their suppliers, consolidating it and passing it along to their customers.

LEGISLATIVE HISTORY

• Enacted: September, 2000

• Most Recent Amendment: May, 2013 update of Annex II

GEOGRAPHY/MARKETS

  • Primarily: European Union + 3 other nations (Iceland, Lichtenstein and Norway) that comprise the European Economic Area

    • Commonly referred to as the “EU”

LIABILITY

  • Legal liability: Companies placing vehicles on the market in the EU, as defined above

  • Business liability: Regardless of location and supply chain tier, all companies who supply products to automotive OEMS including spare parts

HOW ELV IMPACTS COMPANIES

  • ELV requires automotive manufacturers to identify all the substances in each material used in every component of each vehicle model they produce in order to make the required declarations regarding vehicle substance content

  • The evolving and expanding GADSL requires sophisticated tracking and monitoring to ensure that products are and remain in compliance and to update compliance data and supporting documentation at all tiers in the supply chain

ELV REQUIREMENTS

Because ELV and its data collection mechanism, IMDS, are so inextricably tied together and because IMDS is driven by the GADSL which goes beyond the requirements of ELV (REACH, RoHS, EU Biocide Regulation, etc.), the table below is a compendium of requirements regarding automotive products that goes beyond those outlined in ELV.

REQUIREMENTS SUMMARY

TYPE OF REQUIREMENT

COMPANIES WITHIN SCOPE MUST:

Substance Bans

 

Not incorporate any prohibited substances in any vehicle or spare part that is manufactured or imported into the EU

Substance Limitations

Not incorporate identified substances whose concentration in any given material exceeds a legally-allowable limit

Material Coding and Marking

Mark components with the appropriate material codes to facilitate identification of those components and materials which are suitable for

reuse and recovery

Type Approval Process Documentation

OEMSs must provide relevant technical information regarding constituent materials and their respective masses in order to permit verification of the manufacturer's calculations regarding reusability of component parts, recyclability and

recoverability of materials

Dismantler Documentation

(OEM)

OEMSs must provide dismantling information for each type of new vehicle put on the market within six months after the vehicle is put on the

market

Authorized Treatment Facility Documentation

(OEM)

OEMSs must make available to authorized treatment facilities, when requested, information concerning dismantling, storage and testing of components which can be reused

Vehicle Design

(OEM)

OEMSs must design to meet the designated reuse and recovery targets for vehicles being dismantled at the end of their useful life

Required Information for Prospective Buyers Promotional Literature for Marketing a New Vehicle

(OEM)

OEMSs must include in promotional literature for marketing a new vehicle the following information

  • The design of vehicles and their components with a view to their recoverability and recyclability;
  • The environmentally sound treatment of end-of life vehicles, in particular the removal of all fluids and dismantling,
  • The development and optimization of ways to reuse, recycle and
  • recover end-of life vehicles and their components; and
  • The progress achieved with regard to recovery and recycling to reduce the waste to be disposed of and to increase the recovery and recycling rates.

ELV RISKS

ELV entails a wide variety of legal and business risks for all companies within a supply chain. While attention is typically focused on legal risks, the greatest non-compliance impact on companies may very well result from business risks, e.g.:

  • A customer delays payment for products until you provide substance documentation

  • A competitor provides substance documentation earlier than your company does, and it uses that documentation to win new customers and to take away your existing customers

ELV ENFORCEMENT

While the ELV directive does not include enforcement provisions targeted specifically at manufacturers there are, nonetheless, mechanisms in place to effectively enforce its requirements regarding product substance content.

Enforcement of ELV requirements is mostly done through the new type approval process. This takes place before a single model of a vehicle is placed on the market in the EU. Failure to obtain type approval due to non-compliance with product substance requirements or insufficient documentation puts at risk the recovery of all vehicle development costs to that point. As such the new type approval process is an enforcement barrier that must be successfully negotiated.

After a vehicle is on the market in the EU the possibility of recall for non-compliance still exists along with its associated costs.

The End of Life Vehicle (ELV) Directive 2000/53/EC was adopted by the European Union in 2000 in order to reduce the contribution of automotive scrap to the waste stream in Europe and reduce the environmental impact of scrap vehicles. The primary requirements of ELV can be divided into two parts the establishment of recycling targets and the implementation of requirements eliminating four substances from vehicles.

Recyclability and Recoverability Requirements

ELV required that the reuse and recovery of vehicles at the end of their useful life meet an 85% target as of 2006 of which only 5% could be energy recovery (incineration to generate steam and electricity). In 2015 this target moved to 95% of which only 10% could be energy recovery. The automotive manufacturers are directed by ELV to design in produce vehicles in such a manner that takes into account and facilitates the efficient dismantling, reuse and recovery of the vehicle, its components and materials at the end of the vehicles life. Vehicle manufacturers are required to prove their vehicles can meet these recycling targets through a calculation performed according to the ISO 22628 Standard. Under the later released Reusability, Recyclability and Recoverability of Vehicles (RRR) Directive vehicle manufacturers are required to submit a report with calculations proving their vehicles can meet these standards at the time vehicles are going through type-approval for the European Market.

Substance Elimination Requirements

ELV requires the elimination of lead, mercury and hexavalent chromium from vehicles to a level under 0.1% by weight per homogenous material and elimination of cadmium from vehicles to a level under 0.01% by weight per homogenous material. These elimination came into force on July 1, 2003. There are permissible exemption which are documented in Annex II of the directive. In Annex II some of the exemptions are specified without an end date such the exemption for up to 0.35% lead in steel others have a sunset data after which the exemption will no longer be allowable such as lead in the dielectric ceramic material of capacitors with a voltage of less than 125 volts AC or 250 volts DC which is allowable only on vehicles type approved prior to January 1, 2016.

Annex II of ELV has been updated several times since the directive’s release in 2000. The most recent update was enacted on May 17 2013 (2013/28/EU).

Vehicle Manufacturers Response to ELV

In response to ELV the vehicle manufacturers recognized that they needed data to identify where banned or regulated substance were found in their vehicles and also to have the materials in their vehicles classified in order to perform recyclability calculations. Previous to 2000 several of the vehicle manufacturers or automotive original equipment manufacturers (OEMs) had programs in place to collect restricted substance content however this programs had limited success and almost none of them required the level of disclosure required to ensure compliance with ELV. In recognition of this eight of the vehicle manufacturers contracted with EDS (now HP) to build an online system for the collection of the data. This system, the International Material Data System or IMDS was put in place in 2000 and 2001 since its release more vehicle manufacturers have joined it requiring material disclosure from their suppliers. For more information on IMDS click here

The ELV Directive and be accessed at http://eur-lex.europa.eu/resource.html?uri=cellar:02fa83cf-bf28-4afc-8f9f-eb201bd61813.0005.02/DOC_1&format=PDF

The May 17, 2013 update of Annex II of the ELV Directive can be found at http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2013:135:0014:0018:EN:PDF