EU RoHS Regulations: Interpretation Impact for the General Galvanizing Industry

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Structure. More extensive picture and starting point of focus limitsKey Issues for GalvanizersScope of the WEEE Directive Natural vicinity of Pb and Cd Definition of

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Slide 1

EU RoHS Regulations: Interpretation & Impact for the General Galvanizing Industry ASTM A05 Workshop, May 23 2007, Norfolk Murray Cook, Director, European General Galvanizers Association Tom Langill, Technical Director, American Galvanizers Association

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Structure Wider picture and birthplace of fixation cutoff points Key Issues for Galvanizers Scope of the WEEE Directive Natural nearness of Pb and Cd Definition of "homogeneous part" Use of Cr 6+ in post-treatment Consistency with the ELV Directive

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The more extensive EU picture and US roots of RoHS Regulations! Mid 1990s : USA CONEG activities for bundling waste – focus restricts on Cd, Hg, and so forth 1999 : EU Packaging Waste Directive 2000 : EU End of Life Vehicle Directive (ELV) 2003 : EU Waste Electronic & Electrical Equipment (WEEE) and RoHS Directives 2007 : REACH… …

Slide 4

EU Product-based Waste Regulation WEEE, ELV and Packaging Directives fundamentally for waste lessening and reusing. Limitations on risky substances a minor piece of the enactment - with a major effect on industry.

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Origin of Concentration Limits for Hazardous Substances Original ELV and WEEE Directives – zero breaking points for Pb, Cd, Hg, Cr 6+ . Vehicle industry campaigns for 2003 ELV Directive change - limits at 0.1% (0.01% for Cd) These cutoff points then transposed to WEEE/RoHS in 2005 revision Practical Experience : The first (2003) Directive content must be perused in conjunction with the later (2005) Commission Decision 2005/618/EC – generally clients accept zero fixation.

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Key Issues for Galvanizers Scope of the WEEE Directive – which items/applications are secured? Common nearness of Pb and Cd in zinc and meaning of "homogeneous segment" Use of Cr 6+ in post-treatment Consistency with the ELV Directive

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Scope of the WEEE (and along these lines RoHS) Directive Need electric present or attractive field to work < 1000V AC or 1500V DC Used in: Large/little family unit machines IT & Telecoms hardware Consumer gear Lighting gear Electrical and electronic apparatuses Toys, recreation and games hardware Automatic allocators

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Scope of the WEEE (and consequently RoHS) Directive most by far of general excited items are unquestionably outside the extension: Electrical designing items, for example, link plate, electrical cupboards, transmission towers Practical experience : Manufacturers in these fields look for RoHS consistence paying little mind to extent of WEEE.

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Concentration Limits Pb, Cr 6+ , Hg, polybrominated biphenyls, polybrominated diphenyl ethers – 0.1% every; Cd – 0.01% Applied per homogeneous material Pb and Cd actually display in zinc coatings No application-particular exceptions for Pb or Cd in excited steel Applies to the last item; not handle

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Concentration Limits Typical scope of Pb and Cd when all is said in done stirred coatings Cd << 0.005%  Pb 0.05% - 0.4% x Is an aroused steel segment the homogeneous material or the covering itself?

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European Commission Interpretative Guidance on RoHS, August 2006 " Homogeneous material means a material that can't be mechanically incoherent into various materials " Mechanically disconnected means ..the materials can be isolated by mechanical activities e.g., ..smashing, granulating and grating procedures " Examples of homogeneous materials are … ..metals, amalgams, paper, board, saps and coatings. "

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Averaging the lead content over the steel segment? Commission Guidance seems to block it Not yet "tried in courts" Practical experience: Customers (and experts) are utilizing "surface-level" testing systems and require consistence at surface paying little respect to this averaging contention.

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Exemption for lead in electrifies steel ELV Directive – exempts "lead in aroused steel up to 0.35% by weight" Similar exception for RoHS rejected – item illustrations refered to by industry (link plate, cupboards) regarded outside extent of WEEE! Industry has not resubmitted exception ask for

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Impact of Cr 6+ restrains on arousing post-treatment Cr 6+ restrict exclusion for consumption insurance of "unpainted metal sheets and clasp" to 1 July 2007. General electrifying post-treatment (0.3% sodium dichromate) yields <0.1% Cr 6+ at surface Practical experience : Suppliers have changed to non-Cr 6+ choices for passivation for items secured by WEEE (and ELV). Cr 6+ points of confinement are more dangerous for other zinc coatings.

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RoHS and ELV Requirements: Important contrasts Concentration limits for Pb, Cr 6+ , Cd, Hg are indistinguishable ELV : Limits just apply when substances are non-deliberate or because of utilization of reused feedstock. RoHS : Substances can be purposeful/non-deliberate ELV : Exemption for <0.35% Pb in stirred coatings and suggestion this utmost applies over the entire steel segment (cf. free-machining steels)

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Summary Most broad stirring applications are outside extent of WEEE/RoHS. Limitation on lead substance may demonstrate hazardous if covering considered the homogeneous part. EGGA not mindful of any loss of market for any item inside extension and surpassing as far as possible. In the event that illustrations are discovered – EGGA will reintroduce a demand for exclusion for Pb <0.35% according to ELV Directive.