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End Life Vehicle Directive; 2000/53/EC Demonstrating Compliance through IMDS. Matthew Griffin – Jaguar & Land Rover Materials Engineering June 2004. Introduction. ELV Directive became effective 1/7/03 This Directive severely restricts the use of Pb, Hg, Cd and Cr 6+
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End Life Vehicle Directive; 2000/53/ECDemonstrating Compliance through IMDS. Matthew Griffin – Jaguar & Land Rover Materials Engineering June 2004
Introduction • ELV Directive became effective 1/7/03 • This Directive severely restricts the use of Pb, Hg, Cd and Cr6+ • Annexe II provides a list of exemptions • Interpretations confusing (differ from State to State) • Issues in receiving information from Suppliers • Requirements for Whole Vehicle Recyclability • 85% Re-use and energy recovery in 2006 • 95% Re-use and energy recovery in 2015
OEM Concerns / Issues • Spare Parts • Taking some Member State interpretations, we will not be able to sell spare parts for some applications, from July 2003. • ELV versus WEEE discrepancies • Hg in DVD / entertainment screens vs. instrument panel displays • Instrument panel displays containing Hg are acceptable • DVD screens containing Hg are acceptable according to WEEE • DVD screens according to ELV – confusion. • Vulcanising Agents / Stabilisers in elastomers • Alternatives available have not been validated for all applications
OEM Concerns / Issues • Carbon brushes for electric motors • Alternatives available but lifetime / reliability studies are incomplete • Valve seats • Validation of current production engines incomplete • Impurity levels versus intentionally added amounts • Disparity between impurity and intentionally added amounts • A maximum concentration of up to 0.1% lead, mercury, hexavalent chromium and 0.01% for cadmium will be tolerated providing it is not intentionally introduced • Any levels of these metals added in formulations are prohibited – difficult to assess impact due to insufficient knowledge • Why differentiate?
OEM Concerns / Issues • OEM’s have difficulties introducing the ELV legislation because of: • Inconsistent interpretations • Ad-hoc introduction (e.g. not aligned to Type Approval) • Insufficient time for validation • Conflicts / disparity with other legislation • Annexe II revisions - responses collated and communicated to DG Environment / EU through trade associations such as SMMT and ACEA
International Material Data System (IMDS) • The majority of major OEMs subscribe to IMDS, including Jaguar & Land Rover as part of Ford Motor Company • IMDS facilitates the transfer of basic substance data and material data from the raw material suppliers right through the supply chain, to the OEMs • Tier 1 suppliers send data to the OEMs for each part that they supply. • Ford Motor Company require all parts to be recorded in IMDS, as dictated in the Trustmark standard WSS-M9999-A1 • IMDS is a PPAP requirement
This is the top-level screen in IMDS Various tools / options available to help you search for data, create data sheets, manage data and view recommendations on how to construct data and report typical systems and complex components (e.g. electronics)
For all OEMs using IMDS – ALL SUBSTANCES IDENTIFIED ON THE INTERNATIONAL LIST OF REPORTABLE SUBSTANCES (ILRS) MUST BE DECLARED All materials identified for sub-components Basic substances identified for materials
The material classification is required to assist in calculating the recyclability rate. Therefore ALL materials are required to be reported.
How do we determine ELV Compliance? • Application codes must be assigned for restricted substances by the Tier 1 Supplier • Data sheets are analysed automatically for their quality and for prohibited substance content • Suppliers contacted automatically if their data sheets contain prohibited substance applications. • Vehicle reports / metrics available internally to track status of individual vehicle programmes
All data sheets sent to Ford Motor Company require “application codes” to be selected for all ILRS basic substances.
Example of application codes available for lead. User selects from a pre-defined list.
Activities / Tools to assist Suppliers with IMDS inputs • Publication of universally agreed recommendations • An OEM agreed list of reportable substances (ILRS) • Incorporation of ILI database for a large number of standard materials • Off-line tools available from EDS to speed up input • IMDS-a2 (Advanced Accelerator) • Integrated Corporate Material Management System (icm2) • OEM requirements / guidelines published on IMDS • Ford Requirements found on public pages of IMDS / FAQ’s / OEM specific requirements • Training available from EDS and MDSMap (in the UK) • Publication of expected part numbers on the Ford Supplier Portal
Conclusions IMDS information is used for: • Determining compliance to the substance restrictions of the ELV Directive • Complying with with the Type Approval requirements for recyclability • Assessing the impact of proposed substance prohibitions • E.g. deca – PBDE prohibition proposals for some Nordic countries • U.S and Nordic studies into BFR’s • Complying with JAMA voluntary lead reduction programme • Complying with Non EU substance prohibition legislation • Complying with Non EU recyclability / ASR calculations and requirements • Answering customer queries on allergenic issues
Useful Links • IMDS: http://www.mdsystem.com • EDS off – line tools: http://services.mdsystem.com/index.en.jsp • MDSMap: http://www.mdsmap.com (visit their “Resource Centre”) • Ford Supplier Portal: https://fsp.covisint.com.