cd EPM, 07/01/02 Product Management Material Controlling MCT 1 Heavy Metal Ban, Annex II Implementation Status 1 st July 2002 Directive 2000/53/EC

cd EPM, 07/01/02 Product Management Material Controlling MCT 2 Heavy Metal Ban Agenda Legislation overview Implementation of legal requirements Heavy metal ban - overview Amended Annex II Exemptions listed in amended Annex II Realization following priority lists Cr(VI)-Applications for heavy metals Possible substitutions for heavy metals

cd EPM, 07/01/02 Product Management Material Controlling MCT 3 Directive 2000/53/EC was passed on 18 th September 2000 integration with national law within 18 months Time frame: vehicles for passenger transport with 4 wheels (minimum), with maximum capacity of 8 passengers plus driver light commercial vehicles / light goods vehicles up to 3,5 t maximum permissible weight Vehicles concerned: Heavy Metal Ban Legislation Overview

cd EPM, 07/01/02 Product Management Material Controlling MCT 4 Time schedule of Directive 2000/53/EC Take back of ELV´s / Recycling / Heavy Metal Ban free take back of new vehicles free take back of all vehicles type approval: proof of 95% recyclability recycling of ELVs: 80 % re-use and recycling 5 % energetically 15 % disposal recycling of ELVs: 85 % re-use and recycling 10% energetically 5 % disposal ban on heavy metals: Cd, Cr(VI), Hg, Pb exemptions listed in Annex II ELV: End of Life Vehicles

cd EPM, 07/01/02 Product Management Material Controlling MCT 5 Directive 2000/53/EC Heavy Metal Ban Article 4 (2): materials and components of vehicles put on the market after 1 st July 2003 must not contain lead (Pb), mercury (Hg), cadmium (Cd) or hexavalent chromium (Cr(VI)) exemptions are listed in Annex II Annex II: an amended Annex II was passed by the Commission on 22 nd May 2002 Annex II will be amended on a regular basis in future, according to technical and scientific progress manufacturers are integrated with the revision process

cd EPM, 07/01/02 Product Management Material Controlling MCT 6 Realization of heavy metal ban following priority lists according to VW Executive Board decision, 15 th June 2001 identification of critical materials, analysis of components, adaptation of legal requirements of the heavy metal ban into: VW standards, technical specifications, inquiry documents, guidelines for sample testing identification of components concerned (part no./vehicle class) by technical development departments commitment within VW group, development of strategies exchange of components concerned by CW 18/2003 by technical development departments, coordination by product management joint strategy of all manufacturers for the European market concerning the implementation of alternative processes Heavy Metal Ban Implementation of Legal Requirements

cd EPM, 07/01/02 Product Management Material Controlling MCT 7 Heavy Metal Ban Overview - Most Important Examples Cd with ban of cadmium in Sweden from 1985, vehicles containing less than 75 ppm of cadmium are considered to be Cd-free demanded in standard VW applications (discharge lamps, displays) exempted to be labelled or made identifiable, to be dismantled Hg Cr(VI) exemption only for Cr(VI) in corrosion preventive coatings enormous number of parts concerned (e.g. screws, fasteners) alternatives offering sufficient safety are not available for all applications lack of analytical determination method Pb wheel balance weights only exempted until 2005 polymers: lead as stabilizer for PVC in wiring harness or exterior trim components or as vulcanizing agent in elastomers (e.g. ECO or CSM) black ceramic paint on windows electronic components (solder, lead in ceramic or glass matrix) for a fuller list see priority lists on Intranet heavy metal homepage

cd EPM, 07/01/02 Product Management Material Controlling MCT 8 Amended Annex II Commission Decision of 27 th June Examples hexavalent chromium – 2g-limit per vehicle was dropped – exemption for Cr(VI) in corrosion preventive coatings until 1 st July 2007 – exemption for absorption refridgerators in motorcaravans, dismantling compulsory lead for wheel balance weights until 1 st July 2005 in case of type-approval before 1 st July 2003 lead in elastomers in fluid handling and powertrain applications – exemption until 1 st July 2005 – revisal at beginning of 2005, if prolongation necessary lead in aluminium for machining purposes – exemption up to 0,4 % unlimited lead in solders in electric applications – exemption unlimited

cd EPM, 07/01/02 Product Management Material Controlling MCT 9 Exemptions listed in Annex II Lead in: copper in brake linings carbon brushes for electr. motors glass in bulbs and glaze of spark plugs wheel balance weights elastomers as vulcanizing agents and stabilizers for elastomers in fluid handling and powertrain applications stabilizer in protective paints valve seats pyrotechnic initiators steel for machininig purposes and galvanized steel Al for machining purposes copper alloys batteries if type-approved before servicing of these vehicles DISMANTLING COMPULSORY!!! if type-approved before engines developed before ,4% >0,5%, up to 2,00% until up to1,00% until up to 0,35% unlimited up to 4,00% unlimited unlimited - but DISMANTLING COMPULSORY!!! if type-approved before servicing of these vehicles DISMANTLING COMPULSORY!!!

cd EPM, 07/01/02 Product Management Material Controlling MCT 10 Exemptions listed in Annex II Lead in: vibration dampers lead-bronze bearing shells and bushes solder in electronic circuit boards and other electric applications glass or ceramic matrices in electrical components (except glass in bulbs and glaze of spark plugs) Hexavalent chromium in: corrosion preventive coatings absorption refrigerators in motorcaravans Cadmium in: thick film pastes batteries for electrical vehicles Mercury in: discharge lamps and instrument panel displays unlimited - but DISMANTLING COMPULSORY!!! after only allowed as replacement parts for unlimited - but DISMANTLING COMPULSORY!!! unlimited unlimited - (DISMANTLING if > 60g/vehicle - together with glass or ceramic matrices in electrical components) unlimited - (DISMANTLING if > 60g/vehicle - together with solder in electronic/electric applications) vehicles put on the market before this date. DISMANTLING COMPULSORY!!!

cd EPM, 07/01/02 Product Management Material Controlling MCT 11 Procedure agreed with VDA and ACEA: used spare parts are exempted from the heavy metal ban in general spare parts produced before 1 st July 2003 are exempted legal clarification on spare parts produced after 1 st July 2003 is in process Heavy Metal Ban Spare Parts Source: K. Lüders K-QS-33

cd EPM, 07/01/02 Product Management Material Controlling MCT 12 Exemptions Listed in Annex II Realization Following Priority Lists - e.g. Lead Source: K. Lüders K-QS-33 Entire List Lead List of Parts Concerned for full list see priority lists on intranet heavy metal homepage

cd EPM, 07/01/02 Product Management Material Controlling MCT 13 Heavy Metal Ban Priority List Lead Source: K. Lüders K-QS-33 Components and/or applications without exemptions listed in Annex II need to be exchanged, e.g.: lead stabilizer for PVC (some applications in exterior trim) lead as a pigment or stabilizer in paints lead in black ceramic paint on windows (UV-protection for adhesives) cylinder piston rod protection key slots doors wheel balance weights need to be exchanged ! clarification needed

cd EPM, 07/01/02 Product Management Material Controlling MCT 14 Heavy Metal Ban Priority List Mercury and Cadmium Known applications that are covered by exemptions: mercury in discharge lamps and instrument panel displays (blue LEDs, colour display navigation system, interior lighting T4, discharge lamps in headlights) cadmium is - according to state of information - less than 75 ppm/part limits: 100 ppm for Cd 1000 ppm for Hg, Pb, Cr(VI)

cd EPM, 07/01/02 Product Management Material Controlling MCT 15 Heavy Metal Ban Cr(VI)-Applications (Golf A4) - Overview 1 0,4 0,2 0,8 1,2 1,3 1,5 0,6 00,20,40,60,811,21,41,6 others (Al-parts, Zn-high pressure die casting parts) screws and fasteners retainers, bits and pieces brake calipers Al-disc wheels evaporators (AC) body, pre-treatment condensers (AC) body, Bonazinc Cr(VI)-content in grammes per vehicle Source: G.Laudien K-QS-32

cd EPM, 07/01/02 Product Management Material Controlling MCT 16 Heavy Metal Ban Possible Substitutions for Heavy Metals hexavalent chromium alternatives available for some applications (see TL`s 217, 196, 244) difficulties with surfaces which are in contact with magnesium equivalent substitution for Dacromet estimated to be available for end of 2002 lead bismuth as an alternative for lead in alloys is being developed no substitution for lead in wheel balance weights ready to go into production; due to expensive verification processes, use of alternatives is possible from 09/2004 at the earliest at present no possible substitution for lead as a component of e.g. piezo-ceramics in sensors or actuators of electronic controllers Source: K. Lüders K-QS-33