VDA_232-101

July 2004 List of Declarable Materials in Automobile Manufacturing Substances in Components and Construction Materials VDA 232 – 101 1 Objective In automotive manufacturing a large number of construction, operational and processing materials are used whose selection and proper use affect the vehicles’ quality, safety and environmental friendliness through their entire life. In order to optimise these characteristics, it is necessary to cultivate the exchange of information, as well as the dialogue within the value-creation chain – starting with raw material extraction, continuing with the manufacturing of pre-products, components, the construction of motor vehicles up to their usage, and finally re-utilisation or waste disposal. Legal requirements, which provide the basis for passing along information within the supplier-customer chain, are already in place. Looking ahead at future development, information will be constantly expanded and a dialogue about all possible risks for humans and the environment will be introduced. Co-operation based on mutual trust is imperative for reaching goal-oriented solutions. Thus, joint evaluation procedures, which have the ability to weigh out benefits and potential risks involved in the application of materials, need to be introduced. As the result of this co-operation the List of Declarable Materials in Automobile Manufacturing - Substances in Components and Construction Materials has been attached. 2 Bases In this List of Declarable Materials in Automobile Manufacturing – Substances in Components and Construction Materials publication, substances and substance categories are listed, which may be present in automotive construction materials, and which, based on current knowledge, present potential risks for humans and the environment during the vehicle’s usage, as well as during the recycling and disposal processes. The composition of the list is based on: • Legal requirements • Environmental protection and occupational safety requirements, which take precautionary measures in order to help prevent possible risks to humans and the environment, which may be caused by construction, operational and processing materials. • Our responsibility to humans and the environment based on the motto: We act in an environmentally conscious manner. Particular consideration was given to substances which may cause higher risks, such as: continued page 2 to 11 VERBAND DER AUTOMOBILINDUSTRIE E. V. (VDA) Westendstraße 61 60325 Frankfurt Distribution: DOKUMENTATION KRAFTFAHRWESEN e.V. (DKF) - Ulrichstr. 14 - D-74321 Bietigheim-Bissingen, Germany Page 2 VDA 232 - 101 (July 2004) • Carcinogenic substances • Substances which affect fertility • Mutagenic substances • Sensibilizing substances • Slightly and highly poisonous substances • Environmentally damaging substances 3 Application and explanations All the substances and substance groups listed in the List of Declarable Materials in Automobile Manufacturing - Substances in Components and Construction Materials must be recorded with the Initial Sample Test Report VDA - Constituents in Purchased Parts (Material Data Sheet), if they are present in the products, or if they run the risk of being released. Mass limitations i.e. content limitations for individual substances have been specified. If the content level falls below these limitations, it does not have to be declared. These limitations are 0.1g/100g (weight %), unless otherwise indicated. Substances on the list marked with “D” must be declared if their amount exceeds the set limitation. These specifications form the basis for dialogue between the supplier and the customer, in order to provide a safe and environmentally friendly operation. The declared substances should not be automatically substituted, but a joint effort should be made to carefully weigh out advantages/benefits as well as potential risks, while taking the specific use of the substance into consideration. After this has been done, a final decision concerning the substance of choice will be made. This procedure may also make it necessary to test alternative substances. In doing so, one must make sure that all of the possible substances are tested in the same way, taking all technical, economic and ecological aspects into consideration. The substances on the list marked with “P” are prohibited for certain application purposes by law. They may not be contained in amounts, which exceed the set limitations. Impurities caused by these substances must be recorded qualitatively and risk estimates should be discussed in a dialogue. 4 Extent of validity Should the content of the English, French, Spanish and Italian versions of the List of Declarable Materials in Automobile Manufacturing - Substances in Components and Construction Materials interpreted differently from the German text, the German original issue is authoritative! The contents of the List of Declarable Materials in Automobile Manufacturing - Substances in Components and Construction Materials and its application does not relieve any of the parties involved in process chain from their obligation to comply with all the government regulations regarding hazardous materials and any resulting additional prohibitions or application limitations. It is intended that this List of Declarable Materials replaces the company specific declaration lists (specifications, regulations etc.) Page 3 VDA 232 - 101 (July 2004) 5 Further Development The List of Declarable Materials in Automobile Manufacturing - Substances in Components and Construction Materials - was drawn up on behalf of the VDA Materials Committee (VDA- Werkstoffausschuss) by the VDA-Material Contents Working Group (VDA AK Inhaltsstoffe) and completed in co-operation with the Chemical Industry Association VCI (Verband der Chemischen Industrie). It will be updated annually (January 31st) according to increasing knowledge and developing requirements in order to continuously improve product safety and environmental protection. This work will - as with the preparation of the list- continue in co- operation with all partners. For any comments and questions please contact directly: Verband der Automobilindustrie e.V. (VDA) Technical Department Westendstr. 61 D-60325 Frankfurt Germany taeubl@vda.de 6 General Definitions Products Substances or preparations, which during production, have taken on a specific shape, surface or form, which has a greater influence on their function than their chemical composition does. Substances Chemical elements or chemical compounds as they exist naturally or are produced, including stabilising agents and production-related impurities, with the exception of solvents, which can be separated without any effects on stability or change in composition. Preparations Mixture or solutions, composed of two or more substances Page 4 VDA 232 - 101 (July 2004) 7 Abbreviations Used ChemG Chemicals Act - law for protection against dangerous substances ChemVerbotsV Chemical Prohibition Regulation – regulation on bans and restrictions regarding hazardous substances, preparations and products being brought into service EU-D European Directive including amendment and adaptation directives: EU-D 67/548/EEC: Directive on the approximation of laws, regulations and administrative provisions relating to the classification, packaging and labelling of preparations made from dangerous substances EU-D 76/769/EEC: Directive on the approximation of the laws, regu- lations and administrative provisions of the Member States relating to restrictions on the marketing and use of certain dangerous substances and preparations EU-D 2000/53/EG: Directive on end-of life vehicles EU-R EU Regulation including amendment and adaptation regulations: EU-R 594/91/EEC: Council Regulation on substances that cause the depletion of the ozone layer GefStoffV Regulation on Dangerous Substances – regulation on the protection from dangerous substances StrlSchV Regulation on Radiation Protection CX*) Carcinogenic, classification according to EU-D 67/548/EEC or TRGS 905 MX*) Mutagenic, classification according to EU-D 67/548/EEC or TRGS 905 REX*) Substances which are embryotoxic (EU-D 67/548/EEC or TRGS 905) RFX*) Substances which affect the fertility (EU-D 67/548/EEC or TRGS 905) T Toxic (according to ChemG and GefStoffV; EU-D 67/548/EEC) T+ Very toxic (according to ChemG and GefStoffV; EU-D 67/548/EEC) TRGS Technical rules for hazardous substances *) X = 1: proven to affect humans; effects known *) X = 2: proven to affect animals; effects apply to humans as well. *) X = 3: supposed effects of the substances on man Page 5 VDA 232 - 101 (July 2004) 8 Notes for the user on the information in the table’s columns Substance The column contains chemical compounds or substance groups, respectively. Substance groups are normally referred to by their root substance. CAS No. Chemical Abstracts Services, numbering system for chemicals. For the groups of chemical compounds (e.g. benzidine or its salts) the CAS No. of the root chemical is noted and put into parentheses. Declaration Limit * For “prohibited substances” the maximum concentration of the specified substance allowed to be present in a material is noted. “Declarable substances” have to be reported if their concentration exceeds the specifications above. The actual concentrations have to be reported in each case. VDA classification D: duty-to-declare substances - with dialogue P: prohibited substances; valid for specific usage Type * This row contains information concerning usage or material classification Source Listed here are laws, regulations and rules containing usage prohibitions or restrictions. Supplementary and amendment directives should also be observed. Danger/risks Remarks on classification according to chemical legislation or concerning usage in materials of cars and/or car manufacturing Examples of use and presence of a substance The examples show typical automotive related usage for environmentally relevant hazardous substances. Substances contained in construction materials and substances used during production, which can be present as residues, are listed as well. Remarks / comments This column contains information on detailed usage prohibitions and specific details, including industry specific restrictions. * This information is currently being revised for the next edition List of Declarable Materials in Automobile Manufacturing Substances in Components and Construction Materials Valid only with explanation VDA 232-101 (July 2004) VDA AK Inhaltsstoffe taeubl@vda.de 1 Substance CAS-No. VDA- Classi-fication Source (Legal requirements, regulations) Danger/ Risk Examples for usage / existence Remarks and Comments (contents, deviation from 0,1%) 2 Acetaldehyde 75-07-0 D EU-D 67/548/EEC C3 Emitted substances from auto components 3 Acetamide 60-35-5 D EU-D 67/548/EEC C3 Solvent additive, stabilizer for softening agents 4 Acrylamide 79-06-1 D EU-D 67/548/EEC C2,M2 Production of polyacrylamide (residual monomer) 5 Acrylonitrile 107-13-1 D EU-D 67/548/EEC C2 Production of plastics, resins and rubbers eg. ABS (residual monomer) 6 Aliphatic chlorohydrocarbons refer to Chlorinated hydrocarbons 7 4-Aminobiphenyl and its salts (92-67-1) D P EU-D 76/769/EEC EU-D 67/548/EEC, ChemVerbotsV. GefStoffV incl. Annex IV No. 2 C1 Impurities in textile and leather paints, antioxidants in lubricants, rubber/latex, plastics Restriction for substances and preparations according to German ChemVerbotsV 8 Ammonia emitting substances (7664-41-7) D Emitted substances from auto components Odour problem in car interior, refer to introduction 9 Aniline and its salts (62-53-3) D EU-D 67/548/EEC ( C3 ) Pigments, sulfonamides, isocyanate - plastics 10 Antifouling dyes components; refer to: Arsenic Hexachlorocyclohexane Mercury Organo-tin-compounds D GefStoffV incl. Annex IV Nr. 5 Mainly used as protective coating - contained in collophony, resin esters or modified vulcanized resins in combination with tar or bitumen, small amounts chlorine latex, chlorinated Polypropylenes and Vinyl resins Restriction for substances and preparations according to German ChemVerbotsV 11 Antimonytrioxide (Diantimonytrioxide) 1309-64-4 D EU Annex 67/548/EEC C3 Flame retardant for plastics and rubber/latex, opacifier in smelting coverings, friction lining in vehicle assembly 12 Aromatic amines or their salts: 4-Aminobiphenyl or its salts Benzidine or its salts 2-Naphthylamine or its salts 4-Nitrobiphenyl or its salts (92-67-1) (92-87-5) (91-59-8) 92-93-3 D P EU-D 67/548/EEC EU-D 76/769/EEC ChemVerbotsV GefStoffV incl. Annex IV Nr. 2 C1 Possible impurities in certain colours for natural textiles (production prohibited in Europe) Restriction for substances and preparations according to German ChemVerbotsV 13 Arsenic or its compounds (7440-38-2) D P EU-D 67/548/EEC EU-D 76/769/EEC ChemVerbotsV GefStoffV incl. Annex IV Nr. 3 T Paints and smelting coverings, wood preservative, leather and textile finishes, water treatment, plane glass, metal glue, pyrotechnic objects, metal finishes, wood impregnation If used as a component in metals the declaration limit is 500 ppm. Restriction for substances and preparations according to German ChemVerbotsV 14 Asbestos 1332-21-4 P EU-D 76/769/EEC, ChemVerbotsV GefStoffV incl. Appendix IV Nr. 1 C1 Friction pads, gaskets, insulations Restriction for substances and preparations according to German ChemVerbotsV 15 Azo-dyes as defined by TRGS 614 containing carcinogenic amine components D P EU-D 67/548/EEC C 1 - 2 In dyes Restricted for use in textiles 16 Barium compounds (organic or water soluble) except Ba-carboxylate (7440-39-3) D EU-D 67/548/EEC TRGS 614, 905 Xn Colour pigments, stabilizers for PVC, lubricant additives Declaration-limit: 1 % 17 Benzidine or its salts (92-87-5) D P EU-D 67/548/EEC EU- D 76/769/EEC ChemVerbotsV GefStoffV incl. Annexx IV No. 2 C1 Kongo dyes (benzidine dyes: mainly azo dyes) textile and leather dyes, antioxidants in rubber and elastomers Substitute materials TRgA 603 Declaration limit: 0,01 % Restriction for substances and preparations according to German ChemVerbotsV D = duty to declare- commence dialogue; P = legally prohibited for certain application purposes (version: 034e) page 6 of 11 List of Declarable Materials in Automobile Manufacturing Substances in Components and Construction Materials Valid only with explanation VDA 232-101 (July 2004) VDA AK Inhaltsstoffe taeubl@vda.de 1 Substance CAS-No. VDA- Classi-fication Source (Legal requirements, regulations) Danger/ Risk Examples for usage / existence Remarks and Comments (contents, deviation from 0,1%) 18 Benzo(a)pyrene or other corresponding PAH´s (50-32-8) D P EU-D 67/548/EEC EU-D 76/769/EEC ChemVerbotsV GefStoffV incl. Annex IV No. 13 (C2, M2), RF2, RE2 Mineral oils, soot, tar Incomplete burning of organic substances. Differing declaration limits: in wood preservatives: 50 ppm in lubricants: 10 ppm (16 PAHs to EPA) i.e. 1 ppm for Benzo(a)pyren. Restriction for substances and preparations according to German ChemVerbotsV 19 Benzene 71-43-2 D P EU-D 76/769/EEC ChemVerbotsV GefStoffV incl. Appendix IV Nr. 4 C1, M2 Fuel, solvent for latex enamels, raw material for other chemicals declaration deviation limit: 0,01%; Restriction for substances and preparations acc. to ChemVerbotsV. 20 Beryllium or Beryllium alloys (7440-41-7) D EU-D 67/548/EEC C2 Electric contacts, relays and switches must be declared if used as component in metal 21 Beryllium salts or -oxides (7440-41-7) D EU-D 67/548/EEC C2 Ceramic materials in electric insulators 25 Butadiene ( 1,3 - Butadiene ) 106-99-0 D EU-D 67/548/EEC C1, M2 manufacturing of synthetic rubber for tyres, as homopolymerisate (BR), as copolymerisate with Styrene (SBR) or Acrylonitrile (NR), starting product of Sulfolane, Chloroprene, Hexadiamine, softeners, Tetrahydrophthalic acid anhydride, residual monomer in ABS 26 Butylbenzylphthalate (BBP) 65-68-7 D EU-D 67/548/EEC RE2 Softening agent in plastics e.g. PVC 27 Cadmium or it's compounds (7440-43-9) D P EU-D 2000/53/EEC EU-D 67/548/EEC EU-D 76/769/EEC (C2) Surface protection of metals, stabilizers in polymers, pigments, in paints and plastics Cd-impurities up to 75 ppm are tolerated. Cd in alloys and warnings signs are excluded from ban; observe exception pertaining to EU End-of-life-vehicle directive in Annex II! Restriction for substances and preparations according to German ChemVerbotsV 57 Carbondisulfide emitting substances 75-15-0 P EU-D 67/548/EEC RF3, RE3 Emitted substances from vulcanized elastomers Restriction for substances and preparations according to German ChemVerbotsV 56 Ceramic Fibers D EU-D 67/548/EEC C2 Friction lining, screens, re-enforcement, insulation, cables Danger caused by dusts, KI-values in TRGS 90; mind WHO criteria 28 Chloroaniline 106-47-8 D EU-D 67/548/EEC (C2) Hardener or cross linking agent for polymers and epoxy resins 29 Chlorepoxypropane (Epichlorhydrine) see: 1-Chloro-2,3-epoxy-propane 30 1-Chloro-2,3-epoxy-propane 106-89-8 D EU-D 67/548/EEC C2 residual monomers in epoxy resins 49 Chloro-fluoro-carbons (CFC) or other Ozone depleting substances - D P EU-R 594/91/EEC Coolants, propellants, cleaners, solvents, impregnating agents, blowing agents (PU production) prohibited substances: see CFC-Halone- Prohibition Regulation, all others: D 31 Chlorinated Biphenyls see: Polychlorinated Biphenyls (PCB) 32 Chlorinated or brominated Dioxines or Furanes P ChemVerbotsV T Impurities in products Possible formation of Dioxines and Furanes during recycling processes, in cases of fires or re-use 1 ppb, 5 ppb, 100 ppb - up to the grade of halogenation D = duty to declare- commence dialogue; P = legally prohibited for certain application purposes (version: 034e) page 7 of 11 nre Highlight List of Declarable Materials in Automobile Manufacturing Substances in Components and Construction Materials Valid only with explanation VDA 232-101 (July 2004) VDA AK Inhaltsstoffe taeubl@vda.de 1 Substance CAS-No. VDA- Classi-fication Source (Legal requirements, regulations) Danger/ Risk Examples for usage / existence Remarks and Comments (contents, deviation from 0,1%) 33 Chlorinated hydrocarbons: Tetrachloromethane (Tetrachlorocarbon) 1,1,2,2 - Tetrachloroethane 1,1,1,2 - Tetrachloroethane Pentachloroethane Trichloromethane (Chloroform) 1,1,2 - Trichloroethane 1,1 - Dichloroethylene 1,1,1 - Trichloroethane 56-23-5 79-34-5 630-20-6 76-01-7 67-66-3 79-00-5 75-35-4 71-55-6 D P EU-D 67/548/EEC EU-D 76/769/EEC, ChemVerbotsV GefStoffV incl. Annex IV Nr. 11 C3 Cleaners, solvents impregnating/proofing agents, fungicides, pesticides Restriction for substances and preparations according to German ChemVerbotsV 34 Chlorinated hydrocarbons (CHC), see as well: Chloroparaffines, unbranched 35 Chloroparaffines, unbranched (C10-H22nCln to C30-H62nCln; n = 1-28) D P EU-D 76/769/EEC Flame retarding substances Chlorine paraffine with a chain length of C10-C13 are prohibited (P) 36 Chromium(VI)-compounds (14977-61-8) D EU-D 67/548/EECEU-D 2000/53/EEC C2 Chromium pigments (Lead chromate: Chromium Yellow, Barium chromate, Baryte Yellow), chromated surfaces e.g. Chromium Yellow, corrosion inhibitors, residues from dying and tanning. Observe EU End-of-life-vehicle directive with Annex II! Impurities tolerated up to 0,1% 37 Cobalt or Cobalt compounds; Co alloys (7440-48-4) D EU-D 67/548/EEC C3 Hard metal Galvanic Zn-Co-pl