End-of-Life Vehicle Regulations

With End-of-Life vehicle (ELV) regulations existing in all major markets worldwide, vehicle manufacturers have to prove compliance for their products before they can obtain type approval (homologation). Besides the restriction of substances like lead, mercury, cadmium, chromium (VI) and bromated flame retardants like PBDE and PBB increasing demands for the recyclability have to be fulfilled. The whole automotive supply chain has to follow the national and international legislation regarding the restriction of substances.

In the following important ELV-directives:

• 2000/53/EC EU-ELV-Directive
  • 2002/525/EC Annex II (Exemption list) update
  • 2005/673/EC Spare parts decision
  • 2008/33/EC Annex II (Exemption list) update
  • 2008/112/EC Clarifications
  • 2008/689/EC Annex II (Exemption list) update
  • 2003/138/EC Coding standards for materials and components (ISO 11469, ISO 1043, ISO 1629)
  • 2005/64/EC ELV and type approval. RRR (Reuse, Recycling, Recovery; calculation following ISO 22628)
  • 2009/1/EC Addendum for supply  chain management procedures
• China-ELV with Appendix A (Exemption list)
• Japan’s Law for the Recycling of End-of-Life Vehicles (Automobile Recycling Law)
• Korea RoHS (incorporating aspects of comparable WEEE and ELV regulations) Act for Resource Recycling of Electrical and Electronic Equipment and Vehicles

Additionally the general chemical legislation for products and materials has an impact on the automotive industry, notably the 1907/2006/EC (REACH) with its substance of very high concern (SVHC) definition and the restricted substance list in Annex XVII.

The plethora of national regulations necessitates a comprehensive approach for a global restricted substance management, which has led the automotive industry to the development of the global automotive list of declarable substances (GADSL), which contains more than 2000 individual substances.

Databases for Self-Declarations

In order to be able to cope with the increasing regulatory demands for their products, the automotive industry has developed self-declaratory procedures supported by electronic databases. The first database system implemented as a joint venture is the International Material Database System (IMDS) with 16 OEM as partners, while a recent initiative in China has resulted in the China Automotive Material Database System (CAMDS). Yet, some OEM rely on proprietary procedures to track supplier data regarding restricted substances and material classifications for the calculation of the recyclable content.

Find a list of OEM and tier-1 specific standards for restricted substance management (PDF 10 KB).

Our specialists can advise you on the consequences of the international regulations relevant for the automotive industry. They are aware of the special procedures and demands of the automotive industry and provide you with customer-tailored solutions in the fields of chemical analytics, data management and consultations. Our services in detail:

Chemical Compliance Consulting

• International ELV-directives, e.g. the new China-ELV and Appendix A, EU-ELV and updated Annex II
• Implementation of REACH for automotive customers
• Database solutions and implementation strategies
• Best practices and practical advice on how to set up the processes for a reliable documentation required for global business and demanded by legislation and OEM (due diligence)

Consulting for IMDS / CAMDS

Trained specialists are the key resource for successfully mastering the obligations for chemical compliance in the automotive supply chain. The complexity of the databases IMDS and CAMDS, frequent changes of the legal frameworks and the internal recommendations require a constant training on the job. Rejections by customers caused by insufficient data quality cost time and can damage your reputation.

• We will empower your personnel to cope with the current and future demands of the portals IMDS and CAMDS.
• We support you in case of rejections by customers and help you to understand the rejection codes, warnings and errors. Together we analyze the underlying problems and develop a persistent solution for the future.
• We work out standard process and checklists with you, as checked supplier data, the usage of standard materials and a thorough understanding of all data fields is crucial for the successful generation of material data sheet (MDS) in IMDS.
• Our services are based on the latest OEM recommendations, standards and laws, also taking into account foreseeable fture changes.

Outsourcing Solutions for IMDS and CAMDS

Database submissions can be a cumbersome and tedious process, necessitating well-trained personnel and absorbing precious resources. SGS as a service provider can ease this burden by offering you a customer-tailored outsourcing solution. Our specialists perform an analysis of the current situation, followed by the necessary steps for implementation: Company registration, supplier information, requests for data, progress monitoring, quality checks of supplier data, creation of material data sheets and communication with the customers. You can choose the scope of the service – also project-oriented approaches are possible.

End-of-Life Vehicle Directive: Chemical Analytical Services

• Chemical analytics and screenings for the heavy metals Pb, Hg, Cd, Cr(VI) and for the flame retardants PBB and PBDE based on international standards in our certified laboratories
• Detailed analysis results combined with explanation including exemption evaluation
• Competent evaluation of borderline cases in chemical analytics
• Crosscheck of analytical results against the self-declarations in IMDS and CAMDS

GADSL Risk-Based Substance Testing and Evaluation

The automotive industry demands in their delivery specifications the declaration of all substances contained in the GADSL list depending on individual thresholds.

• Depending on your material category and internal manufacturing processes, we define candidates for analytical testing
• Based on the list of potentially contained declarable or prohibited substances we perform the chemical analytical services.
• With this verification method you obtain an additional layer of product safety. We can compare the analytical results directly with the self-declarations of your sub-suppliers in IMDS or CAMDS.