ELV Directive Status Update on Annex II Revisions

ELV Directive Status Update on Annex II Revisions 4 th adaptation(Solder Review) + 5 th adaptation CLEPA IMDS Suppliers Group Meeting November 5 th 2009 Harald F. Schenk Stuttgart

4 th adaptation Steps of OEKO-Inst. /DG-ENV and Industry • First consultant assessment (tendency draft report) was presented in the May 11 th TAC meeting • Final report by OEKO was available by mid June • Draft proposal of DG-ENV to MS beginning of July • ACEA/JAMA/KAMA/CLEPA meeting with DG-ENV and DGENTR on July 10 th • No support for carry over parts • More detailed input regarding solder on Glazing has been requested CLEPA Update on ELV-Annex II 2

4 th adaptation Steps of DG-ENV and Industry • Common letter sent to Falkenberg • DG-ENV new draft Proposal for interservice consultation ready by July 23 rd • Agreement between DG´s to shorten the inter-service consultation to 5 days only • Inter-service consultation ended Aug 2 nd • Legal service required some (formal) changes • DG-ENV decision to initiate a “written procedure” for voting rather than a F 2 F TAC meeting CLEPA Update on ELV-Annex II 3

4 th adaptation -- Lobbying Activities • COMM proposal has been sent to the MS for voting until Sept. 11 th on August (in all languages) • ACEA/JAMA/KAMA/CLEPA letters has been sent to all TAC members asking for a positive decision for the solder exemption • Lobbying was done according to an updated ACEA lobbying matrix • Mainly via the nat. associations with support from OEM/suppliers • via F 2 F meetings • via phone /e-mail CLEPA Update on ELV-Annex II 4

4 th adaptation -- Lobbying Activities • Decision in the TAC was positive • Qualified majority had been reached • 341 votes in favor and 4 abstentions (EST) • COMM sent the required documents out to EP and Council on Sept 23 rd for “scrutiny” process • 90 days period will end on Dec 23 rd 2009 • “The EU Council of Ministers decided, on 26 October, not to oppose the European Commission’s decision to amend Annex II of Directive 2000/53 on end-of-life vehicles. ” • EP response is still pending; no risk seen that they may reject • Final publication in JAN 2010!! CLEPA Update on ELV-Annex II 5

4 th adaptation -- Implementation Strategy • The AI working group (OEM, + supply chain) developed and agreed upon on a common “implementation strategy “ on the basis of the new Annex II (Draft) in order to benefit from the postponements of the phase out dates • Roll-out of the new strategy is ongoing at all OEMs and suppliers • Roll-out need to be well coordinated and improved to ensure cost avoidance (we should take advantage of this) • Potential can be 50 to 100 Mio € per OEM (rough est. ) CLEPA Update on ELV-Annex II 6

4 th adaptation -- Implementation Strategy • As there are obviously different interpretations in the industry, the AI working group (OEM, + supply chain) is currently working on an “interpretation guide/guiding principles” for the new exemptions 8 a) to 8 j) incl. a list of examples • what is the definition of an ”electronic circuit board” ? ? • which application/part falls into the basket 8 b) ? ? • Interpretation guide • Prevent different interpretations (e. g. different IMDS application code for the same part) CLEPA Update on ELV-Annex II 7

5 th adaptation is ongoing • Stakeholder consultation for the 5 th adaptation started in June and closed early August • All remaining exemptions of Annex II (except the solder) will be assessed (10 exemptions) plus two new exemption requests (Thermo-electric Generator (TEG), solder for thin wires) • Industry (ACEA/JAMA/KAMA/CLEPA/other Assoc. provided justifications for all exemptions to defend them • Assessment of Justifications by the consultant (Oeko. Institut) is ongoing • Additional questionnaires are coming in weekly/daily CLEPA Update on ELV-Annex II 8

5 th adaptation -- General Process • Questions will be answered in a reasonable timeframe • AUDIO with OEKO, the respective champion, + add. experts, and myself. • OEKO prepares the draft recommendations and the champions +AUDIO industry team and myself can review/comment • Final responses to OEKO via me or the champions • OEKO will sent the draft recommendation to the EU COMM (DG-ENV) • without putting us on cc. CLEPA Update on ELV-Annex II 9

5 th adaptation -- Status • Exemption 14 a): • Draft recommendation will be sent to the COMM by mid November • It is recommended to continue the phase-out of the exemption until 1 July 2012. The current wording can thus be kept as it is. • Exemption 14 b): • Draft recommendation will be sent to the COMM by mid November • The consultants recommend continuing the phase-out of the exemption until 1 July 2012. The current wording can thus be kept as it is. CLEPA Update on ELV-Annex II 10

5 th adaptation -- Status • Exemption 1 and 3): • AUDIOS took place mid October • No recommendation received for review • Draft recommendation will be sent to the COMM by end of November • Exemption 2): • Add answers are not yet answered officially • OEA provided input • OEKO requested answers and proposed dates for an AUDIO (mid/end of November) CLEPA Update on ELV-Annex II 11

5 th adaptation -- Status • Exemption 10): • Add. questions have been answered (draft) • A F 2 F meeting (Deubzer/Huck) took place to prevent several iteration lops and misunderstandings • New wording proposals had been recommended and are under discussion. • Very detailed and application specific with partly phase out dates/no phase out dates • 10 a) i, ii, …to vi • 10 b) • 10 c) CLEPA Update on ELV-Annex II 12

5 th adaptation -- Status 10 a) Lead in i) dielectric ceramic materials of noble metal electrode (NME) capacitors in vehicles type approved before 1 January 2016, and in spare parts for these vehicles ii) dielectric ceramic material of capacitors with a minimum rated voltage of 125 V AC or 250 V DC and above iii) dielectric ceramic materials of capacitors integrated into F-RAMS iv) the ceramic of piezoelectric components v) the ceramic of PTC components vi) the PZT ceramic passivation layers of multilayer ceramic varistors 10 b) Lead in the ceramic of other components than those listed under exemption 10 a) in vehicles type approved before 1 January 2013, and in spare parts for these vehicles 10 c) Electrical and electronic components, which contain lead in a glass or a glassceramic material or matrix compound forming a functional layer on a substrate, or a sealing or encapsulation. CLEPA Update on ELV-Annex II 13

5 th adaptation -- Status • Exemption 13): • Add questions have been asked to the two main stakeholders (Dometic and Thetford) • OEKO would obviously appreciated some “help” from the Auto Industry • Exemption 5) • Add. questions received last week • High awareness at some OEMs (Associations) and EUROBAT in the meantime (BOD level) • Some BATT manufactures fear a potential possible phase out date and loss of business • Meeting Auto Industry/EUROBAT/ILA planned CLEPA Update on ELV-Annex II 14

5 th adaptation -- Status • Exemption 4 and 6): No activities so far • New exemptions: • TEG (BMW): • One add. question received by OEKO • Answered by BMW • AUDIO took place mid October (OEKO/BMW) • Soldering of thin wires (DMPSS) • Nothing known so far CLEPA Update on ELV-Annex II 15

5 th adaptation -- possible Timeline • Final report with recommendations are expected ? ? • first priority package (e. g. TEG, exemption 1, 2? , 3, 14 a, 14 b) >>> Q 4/2009 • Second priority package (rest) >>> Q 1/2010 • Next TAC meeting scheduled for February 2010 ? ? • Priority 1 package could be on the Agenda for voting • Contract with OEKO runs until June 15 th, 2010 • Final draft report is due on April 15 th • Priority 2 package could be ready for voting in Q 3/Q 4 2010 CLEPA Update on ELV-Annex II 16

How will this story go on? • Solder on glazings review (6 th adaptation) • Industry WG kick off latest in Q 2/10 !!! • Stakeholder Consultation (most likely to start in Q 1 2011) • Neutral assessment…. • COMM proposal, Lobbying, …. • TAC Decision, Scrutiny, Publication (latest by Dec. 2011) CLEPA Update on ELV-Annex II 17

How will this story go on? • Review for HT solder, press fit connectors, flip-chip, etc. (7 th adaptation) • Industry WG kick off latest in Q 1/2013 !!! • Stakeholder Consultation (estimated in Q 1 2014) • Neutral assessment • COMM proposal, Lobbying, …. • TAC Decision, Scrutiny, Publication (latest by Dec. 2014) • . . A never-ending story…. …. unless we are not able to stop it !! CLEPA Update on ELV-Annex II 18

y r e v u o r y u k o y n a r h o d T ch f n a n u o m nti ! ! e y t h at pat m y s CLEPA Update on ELV-Annex II 19