Materials Regulations Event
Suppliers’ presentaion
17 May 2017
Reutlingen, Germany
Messages from the Automotive
Supply Chain
-
Cooperation with and contribution to
Material Regulations & IMDS
•
•
•
•
Mariola Hauke – CLEPA
Dennis Eggeling – HUF
Sylvia Assmann – BOSCH
Marco Buczilowski – FAURECIA
Copyright © 2017 CLEPA. All rights reserved. www.clepa.eu
2
CLEPA Secretariat – new structure (from 10.03.2016)
Secretary General
Sigrid de Vries
HR (Attentia)
Budget (Deloitte/Mazars)
Reception, Travels
Meeting Coordination
B. Coen
Chief Global Governmental
Affairs & Communication
Amalia Di Stefano
Chief Technology Officer
Alessandro Coda
Director TR
P. Alburno
Manager TR
(Safety)
T. Crauwels
R&I
Manager
K. Doraczynska
Manager GA&C
P. Thibaudat
Manager GA&C
S. Mc Millen
Manager TR
(Environment)
Manager
Communication &
Events
B. Tomassini
Chief Operating Officer
Frank Schlehuber
Director Trade &
Legal Affairs
E. Wessman
Policy Officer
Afterm. & Trade
J. van der Werff
Director
Membership
Development
E. Vandervreken
Project Officer
Invoicing
C. Cote
M. Hauke
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Organization of REACH Group
• Meetings
 15 per year by phone
 5 f2f
• Strong cooperation with




ACEA
JAMA
KAMA
JAPIA
 AIAG
 Plastics Europe
 Cefic
• Scope of the WG
 monitoring, clarifying, providing interpretation and position papers
Copyright © 2017 CLEPA. All rights reserved. www.clepa.eu
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Organization of Materials Expert Group
• Meetings
 8 by phone
 1 big event f2f
• Strong cooperation with
 ACEA
 JAPIA / AIAG
 RoHS WG of the EE industry
• Scope of the WG
 monitoring, clarifying, providing interpretation and position papers
Copyright © 2017 CLEPA. All rights reserved. www.clepa.eu
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CLEPA Organisation - Substances
Regulations & Declaration
E/E
Fueling… 
(topics/Regulations)
Regulations
Declaration (tools)
REACH / BPR /
POP
IMDS
Chairperson
REACH
BPR
POP
ELV
Chairperson
Topic “Pilots”
Conflict Minerals
Chairperson
VIAQ
Chairperson
CAMDS
Chairperson
GADSL
working groups…
working groups…
working groups…
Topic “Pilots”
Chairperson
Others…
Chairperson
Others …
Copyright © 2017 CLEPA. All rights reserved. www.clepa.eu
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CLEPA Conflict Minerals Taskforce
Initial Situation
•
•
•
Establishment of Conflict Minerals Taskforce in March 2015 (currently 12 companies and 2
associations are members)
Increasing customer requirements on Dodd Franck Act at that time
Requirements of other Conflict Minerals legislation around the globe were unclear.
CLEPA Activities
•
•
•
•
Best practice share on US Dodd Franck Act
Monitoring of other Conflict Minerals requirements around the world (Europe, China, Cobalt,
Mica,…)
Close communication with VDA / ACEA
Close monitoring of the legislative process in the EU (law enters into application in January 2021).
Results
•
•
Joint Position paper of ACEA / CLEPA during the legislative process in the EU
EU law establishes mandatory due diligence requirements for importers, not for article producers
such as in the US law.
Next steps
•
Focus on missing Conflict Country definition in the EU legislation  that should be defined in due
time by the legislator!!  The commission intends to publish respective guidelines until the end of
2017.
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„GADSL + x“ taskforce (1/3)
Initial Situation
Selected activities from single suppliers
•
•
•
•
Review of respective customer specifications, in order to identify the differences between GADSL
and the customer specification (very difficult work!)
Development of software tools, in order to track the customer specific substances
Establishment of paper work in addition to IMDS with conformity declarations for all products related
to each customer (nightmare!)
Making (difficult!) risk assessments, which products could contain the additional substances and
establish paper work in addition to IMDS with conformity declarations for the risky products related
to each customer.
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„GADSL + x“ taskforce (2/3)
CLEPA Activities
•
SUAL (Supplier Alliance) Position paper on GADSL already created in 2010
•
•
New CLEPA Taskforce „GADSL+x“ established in 2017 (10 companies)
BASF held a presentation in the name of CLEPA during last EU GASG (Global Automotive
Stakeholder Group - EU technical team) meeting in March.
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GADSL + x“ taskforce (3/3)
„
Results:
• CLEPA presentation was well recognized by the companies attending the
GASG meeting.
Next steps:
• SUAL agreed to closely follow up on this topic, by considering the respective
boards, such as GASG
• We will come up with proposals.
Copyright © 2017 CLEPA. All rights reserved. www.clepa.eu
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Chemistry Manager
Initial Situation
• Definition & Development of Chemistry Manager by SC/ DXC  add BPR and REACh
related application information
• Rollout as part of IMDS Release 11
SUAL Activities
• IMDS Model Office Testing
• Error Reporting
Results
• Has been rolled out
• CM Data for ZVEI Rec019 Data has been added
• Current and future use?
Next steps
• Rejections of MDSs with missing CM data  has to be avoided!
• Discuss potential improvements with SC & DXC, e.g. BPR request for relevant material
classes only
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Rec019 Revision
Initial Situation
• Is Rec019 suitable to do O5A reporting ?
CLEPA Activities
• Several meetings with IMDS SC members
• Presentation of and discussion on concerns
• Presentation of solutions
Results
• None of the concerns are strong enough to make the Rec019 definitions obsolete
• Rec019 data sheets of ZVEI-Rec019 [102677] to be optimized, including Chemistry
Manager information
• So called „Umbrella Specs“ of ZVEI - Zentralverband E/E-Industrie [77194] to be
deleted
Next steps
•
Discussion & Preparation
– on standard translation guidance between IPC 1752 and IMDS
– options to increase knowledge in the companies of the electronic industry in cooperation with ZVEI
•
IMDS specific Newsletter may be used from special reporting of electronic items
Copyright © 2017 CLEPA. All rights reserved. www.clepa.eu
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ELV Revision
Initial Situation
• 8th revision of ELV (ongoing)
• See detailed information in presentation of Reinhard Hoock
CLEPA Activities
• Input to & Cooperation with Automotive Industry Working Group and related RoHS WG
• Chair of Electronic Exemption WG (8 & 10)
Results
• Automotive Industry Interpretation Guide for ELV Annex II
• Stakeholder input to Consultation
Exemption
EU
ELV
EU
RoHS
Next steps
Pb in Steel (0,35 %)
1(a)
6(a)
• Preparation of 9th revision
• Call for participants – for all Exemption WGs
Pb in Aluminum (0,4 %)
2(c)
6(b)
3
6(c)
Pb in high melting solder
8(e)
7(a)
Pb in Ceramic (partially)
10(a)
7(c)-I
Pb in dielectric ceramic capacitors < 125
V
10(c)
7(c)-III
Pb in flip chip IC
8(g)
15
13
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Pb in Copper (4 %)
CAMDS Activities
Initial Situation
• Concerns with some contents of the CAMDS ToU, raised by CLEPA Legal Advisory
Group
SUAL Activities
• Evaluation of CAMDS ToU with proposal to amend them
• Discussions with CATARC including IMDS SC
Results
• Final draft of CAMDS ToU proposal available, “OK” for CLEPA Legal Advisory Group
• CATARC still in discussion with one other party, minor (uncritical) amendments to be
expected
Next steps
• Amended CAMDS ToU proposal will be sent fo SUAL to finally approve it
• Then be released
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SUAL 2016 / 2017 activities
SUAL 2016 meeting in May 2016:
• Exchange & Positions on:
- Regional legislation
- IMDS / CAMDS related topics
- GADSL topics
• Including JAPIA Product Chemical Compliance Conference
• Address to JAMA related above mentioned topics
Regular exchange as part of Association Meetings and on demand, e.g.
• Chemistry Manager
• ELV, REACH, …
• CAMDS ToU
SUAL 2017 meeting planned to be held in October 2017
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REACH
Current situation
• main focus on REACH
- roundtable on Inspections, Notification, everything
- BPR and POP aside/ to take away
• clear and manageable group of participants
• observers and actors/contributors
- HBCDD
- Cr-VI
- substances forecast / pilots
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REACH
Future situation
• focus on REACH + BPR + POP
• expanded group of participants
- pilots/volunteers for BPR / POP
• actors/contributors
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REACH
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