Brass & the E.U. End-of-Life Vehicle (ELV) Directive

We answer and outline the End-of-Life Vehicle (ELV) Directive regulations and how they affect brass and copper manufacturers. 

Updated January 2022

What are the limits for restricted substances?

A maximum concentration value of 0.1% by weight for homogeneous materials is permitted for lead, hexavalent chromium and mercury. The limit for cadmium is 0.01%.

Why is lead added to copper alloys?

Lead acts as a chip breaker and lubricant which provides manufacturing and performance benefits. Advantages include superior machinability required to achieve precise tolerances in tiny components and excellent sliding characteristics which play a vital role in vehicle safety features.

How long will the exemption be granted for copper alloys containing lead?

Under Article 4(2)(b), exemptions covered by Annex II are subject to review on a regular basis to determine if they are still justified. Since the directive was implemented, the European Commission and industry stakeholders have acknowledged that there are no suitable alternative materials that can satisfy the diverse performance requirements of such a wide array of vehicle components. Thus, the use of lead-containing copper alloys cannot be avoided and the exemption is justified. The last review of Exemption 3 was completed in 2016/2017 which concluded that the use of lead in copper alloys was still unavoidable. The reviewers recommended conducting the next review in five years.

The exemption for copper alloys was up for review in 2021. What is the current status?

The European Commission contracts a consortium of independent consultants to provide technical assistance for the evaluation of exemptions. The consortium solicits input from relevant stakeholders during the review and issues a
formal recommendation to the Commission to extend, amend or reject the exemption. The ACEA helped gather feedback from industry for the stakeholder consultation which closed on December 8, 2020.

In November 2021, the final report from the technical consultants was published. In brief, the consultants
concluded that the continuation of Exemption 3 might still be justifiable under Art. 4(2)(b)(II) despite limited evidence provided. An extension for 3 or possibly 4 years was recommended to give manufacturers additional time to substitute leaded alloys where feasible. The EU Commission must now deliberate and decide if the recommendation should be accepted or modified. As such, the final decision published in the Official EU Journal may not arrive until late 2022.

To access the consultants’ full technical report and more information on the ELV exemption evaluation process, visit: http://www.elv.biois.eu/

Content created by the Copper Develpment Assossiation Inc. Download full pdf here.