Issue: Application 71 used and part is marked as a Legacy Spare Part
| Application Code Language | Exemption Language including Scope & Expiry Date |
| 2(a),(b),(c)(i) – Alloying element in aluminum for machining purposes | Language: 2(a). Aluminium for machining purposes with a lead content up to 2 % by weight Scope and Expiry Date: As spare parts for vehicles put on the market before 1 July 2005 —————————————- Languate: 2(b). Aluminium with a lead content up to 1,5 % by weight Scope and Expiry Date: As spare parts for vehicles put on the market before 1 July 2008 —————————————- Language: 2(c)(i). Aluminium alloys for machining purposes with a lead content up to 0,4 % by weight |
This application code covers three exemptions for lead (Pb) CAS# 7439-92-1 as an alloying element in aluminum alloys.
Action Required:
This DQR code covers exemption 2(b). The exemption expiry date for 2(b) is earlier than the cut-off date in the review email you received. This means that this application code is not valid for any parts for your customer. Contact your customer to discuss solution to this issue.
If you incorrectly marked this part as a Legacy Spare Part, then it is a new part. Application Code 71 can only be used for new parts containing 0.4% Pb or less. If your alloy contain 0.4% Pb or less, revise the part as appropriate and resubmit to your customer. If your alloy contains more than 0.4% Pb, select another application code. If there is no appropriate application code, contact your customer to discuss a solution to this issue.
If you incorrectly selected Application Code 71, then revise the part as appropriate and resubmit to your customer.
NOTE: Some IMDS Steering Committee published aluminum alloy materials do not conform to current ELV Annex II exemptions regarding Pb in aluminum alloys. For example published MDS 79468908 / 3 for Wrought Aluminium Alloy, Heat Treatable (2011, 2011A) contains 0.2 to 0.6% Pb. If your part is a new part, this material could not be used because it exceeds the 0.4%of Pb allowed under 2(c). While Committee published materials are normally considered acceptable on their face, this is not always the case with aluminum alloys.