Insights from an Automotive Industry perspective Timo Unger

Insights from an Automotive Industry perspective Timo Unger Substances in Articles Challenges & Tools

2 Numbers and Challenges ? 2. 848 9. 000 500. 000 7 100 187 Bn Hyundai Motor Europe Tech. Center Gmb. H 900 12 4, 3

REACH Art 31 – SDS Obligations 3 Hyundai Motor Europe Tech. Center Gmb. H For dangerous substances you get Safety Data Sheets: • Upon receipt of a SDS, the DU should : – Check the SDS content for errors and shortcomings (plausibility check) – Check whethere is for each substances classified as hazardous a SDS available (provided by the supplier) – Check whether the SDS is supplied in the official language of the Member State(s) where the substance or mixture is placed on the market. – Check whether the information mentioned in the SDS is sufficient for workplace and environmental risk assessment. – Make a risk assessment for the workplace – Inform the substance/mixture supplier about new findings with f but er o new umb hing the n ase Not CH Needed is: incre REA DS will and their A complete inventory of all S substances uses A systematic content check of the SDS A documentation of your decisions and the

If I receive an e. SDS… 4 Hyundai Motor Europe Tech. Center Gmb. H For dangerous substances >10 t/a you get extended Safety Data Sheets (e. SDS = SDS + Exposure Scenarios): e. SDS: • Checklist for – – Is the substance registered under REACH ? Is the substance classified as hazardous? Have sections of the main part of the SDS been modified ? Is your use covered? See ES title and check use description for the relevant ERCs, PROCs, ACs, SUs, … – If use is covered/identified, make a Risk Assessment to check if OCs and RMMs are appropriate for environment and human health? ges !!! o 900 pa Up t Needed is: Expertise in chemical language and capacity…

5 The Challenge ECETOC TRA Cs PCs SUs RO P PN ECs ERC Cs. OCs A s Hyundai Motor Europe Tech. Center Gmb. H ? ? ? RCRs Ls NE D REACH Annex II: 0. 2 General requirements for compiling a safety data sheet – 0. 2. 3. “The information in the safety data sheet shall be written in a clear and concise manner…” – 0. 2. 4. “The language used in the safety data sheet shall be simple, clear and precise, avoiding jargon, acronyms and abbreviations…” DU Industry (especially SMEs) need a solution which enables non chemical experts to understand their chemical suppliers, and to fulfill their legal obligations! Preferred solution: End users shall not receive e. SDS but “only” consolidated SDS incl. the for the customer relevant content from the Exposure Scenarios & written in an easy understandable language.

6 Sector recommendation to process SDSs Hyundai Motor Europe Tech. Center Gmb. H SDS Transfer Current standard Process: S/P*Supplier 1 S/P Supplier 2 S/P Supplier 3 S/P Supplier 4 PDF (SDS Format 2006) Excel (SDS Format 2009) Agreed future Process: e. SDSCom. XML +Eu. Phra. C S/P*Supplier 1 S/P Supplier 2 S/P Supplier 3 S/P Supplier 4 Semi Automatic SDS Creation -> In House Tool or e. SDB (e. g. OEM) Print out (SDS Format Korea) Manual SDS Creation *S/P: Substances / Preparations Customer Word (SDS Format 2010) Manual SDS Processing (Analyzing, Checking, Implementing, …) e. SDSCom. XML Customer (e. g. OEM) e. SDSCom. XML Semi Automatic SDS Processing (Analyzing, Checking, Implementing, …) -> In House Tool (e. g VW, BMW, Daimler) -> Already existing IHTs can be adjusted with low internal effort.

Position paper on electronic data exchange format • • 7 Hyundai Motor Europe Tech. Center Gmb. H The Automotive Industry has agreed on a common communication paper to implement a xml based electronic data exchange format for Safety Data Sheets on a long term. Other sectors are also considering to joined (e. g. Construction machines, Aerospace (under consideration)) • A common project with CEFIC has started • • Harmonization of their xml project for Exposure Scenarios with the EDAS approach Also ECHA & COM have shown interests Outlook & Recommendation: • An electronic exchange of SDS will become a cross industry standard

How many parts a vehicle contains? 8 Hyundai Motor Europe Tech. Center Gmb. H • Depending on the complexity, there are between 4. 000 & 9. 000 different main components contained in a vehicle platform (without multiple entries for one specific part). – e. g. The vehicle platform of one OEM contains 8. 400 components (=28. 000 incl. common parts) from 1. 800 suppliers! – Up to 75% of a car are pre-manufactured by supply chain Total number of components assembled to one vehicle: up to 28. 000 (example: 1 tire = 1 part reference number; number of tires per vehicle = 4) Products from other industries may be even more complex! (e. g. aerospace, engineering industry)

How many parts a vehicle contains? 9 Hyundai Motor Europe Tech. Center Gmb. H • A car radio is counted as one main component… Considering all parts contained in all components and sub-components, we come to many tens/hundreds of thousands of articles per vehicle!

Other interesting figures… • 10 Hyundai Motor Europe Tech. Center Gmb. H How many different part numbers a vehicle manufacturer has in its warehouse? up to 500. 000 • How many parts supplier (Tier 1) does a vehicle manufacturer have? 1. 500 to 4. 500 • and how many Tier 2 suppliers the Tier 1 has in average? 500 to 1. 500 • How many Tier 1 suppliers are coming from outside Europe? 20% to 30% (from European Vehicle Manufacturers) 50% to 80% (from non-EU Vehicle Manufacturers) • How many levels the supply chain in the Automotive Industry has? 3 -7 levels

The Challenge of Supply Chain Communication 11 Hyundai Motor Europe Tech. Center Gmb. H 1 Levels (OEM) Tier 1 1. 500 3. 500 (Tier 1 s) X 500 Tier 2 Tier 3 X 500 750. 000 X 100 1, 75 Mio 75100 X Mio X 50 Tier 4 Tier 5 175 Mio 3, 75 Bn X 50 8, 75 Bn 187 Bn Using this data and adding some conservative assumptions a number of several billion possible substance communications for the tens of thousands of parts per vehicle are generated.

GADSL – Global Automotive Declarable Substance List European- Requirements collected by European members Japanese- Requirements collected by Japanese members 12 Hyundai Motor Europe Tech. Center Gmb. H Korean- Requirements collected by Korean members www. gadsl. org US- Requirements collected by US members Considering the following criteria: • Substance is to be expected in automobile part or vehicle (NOT in the production process and not outside the Automotive Industry!) • • Substance is regulated or projected to be regulated Reportable threshold levels will be based on the lowest level required by regulation or scientific evaluation.

GADSL – A short insight • The sources to analyze, evaluate and finally decide are – The know how of the GASG Group (Decades of experiences!!!) – In addition and with minor impact, information from IMDS (has this substance already been used within a vehicle) GADSL today includes: • • 2848 Substances (CAS numbers) in 141 Substance Groups 13 Hyundai Motor Europe Tech. Center Gmb. H

How Automotive is collecting substance information 14 Hyundai Motor Europe Tech. Center Gmb. H Raw Material Manufacturer Since IMDS GADSL 12 years Communication of substance information One reference list for declarable substances a standard Supply Chain (Tier 4, 3, 2, 1) process within the Automotive Industry IMDS GADSL Communication of substance information One reference list for declarable substances Car Manufacturer • For reasons of know how protection, the systems allows the usage of „Jokers“ (max 10%) BUT ONLY… …if the relevant Joker is not “hiding” a substance listed on GADSL

15 IMDS History 2000 2001/02 Hyundai Motor Europe Tech. Center Gmb. H 2003 2010 2011 2012 2008 2009 2007 2005 2006 2004

IMDS – International Material Data System A unique success story 16 Hyundai Motor Europe Tech. Center Gmb. H U S E R M D S Source: HP

Helpdesk per Region since 2008 Source: HP / IMDS SC 17 Hyundai Motor Europe Tech. Center Gmb. H

18 How the IMDS is managed? Hyundai Motor Europe Tech. Center Gmb. H Tasks: EDS Sponsors Groupe Definition of Responsibles (Spokesman) Ø Strategy & Costs (Managers) Speaker EDS Steering Committee Order Implementation and Operation (Experts) EDS North American Steering Committee Speaker Japanese Steering Committee Suppliers Requests, Remarks Ø Operational Execution

19 A data flow throughout the full supply-chain Hyundai Motor Europe Tech. Center Gmb. H Example: IMDS Address of Raw Material supplier PP Send Material Data Sheets (MDS) to: IMDS Address of Tier n supplier Insert MDS Proofing, Linking with own data and Sending new Material Data Sheets to: IMDS Address of Tier 2 supplier Doortrim Carrier IMDS Address of Tier 1 supplier Doortrim IMDS Address of the Car Manufacturer Complete Car Proofing, Linking with own data and Sending new Material Data Sheets to: Proofing of MDS and using Data for internal benefit Time (1 -5 month*) * Estimate of a real data collection. Depending on the complexity of the part & the strategy of the vehicle manufacturer (PPAP).

20 Not included in IMDS In IMDS, only substances have to be reported that are contained in the final part and that exceed the impurity threshold of 0, 1%/(0, 01%). Hyundai Motor Europe Tech. Center Gmb. H IMPORTANT: No other substances, e. g. used for: • Production • Packaging • Transport e. g. : No Polyol and no Isocyanate but only Polyurethane (PUR) e. g. : Release Agents, Cleaning Agents e. g. : Transport Boxes, Paper, Plastic Foil e. g. : Fuel, Containers …have to be entered into the IMDS ( except they are still available on the final part)

21 Hyundai Motor Europe Tech. Center Gmb. H Challenges on investigations of substances in articles • • • Complexity (of product and supply chain) Frequency (of legislative updates) Availability (of spare parts & information on spare parts) Harmony (of global legal requirements) Impossibility (of legal compliance)

Data collection obligations & complex articles 22 Hyundai Motor Europe Tech. Center Gmb. H Complex products Complex supply chain ty i x le p Complex data collection m o C 100% data completeness is almost impossible? It is almost impossible to fulfill e. g. REACH Art 33, even with • an experience of >12 years in the collection of substance information throughout the supply chain.

Outlook: Thousands of substance information have to be collected 23 Hyundai Motor Europe Tech. Center Gmb. H • There approx. 2000 substances fulfilling the criteria of REACH, Article 57 for so called Substances of Very High Concern (SVHCs) • In addition, there are several other substances that have an potential unacceptable risks to human health or the environment. • By today, REACH is already targeting around 86 substances. By the end of 2012 there are in total 110 substances scheduled (only for the CL). Challenge: e u q • A small step approach on data collection is very 478 resource consuming ~110 73 (+13) Today re F Update: 2/year Number of regulated dangerous substances End 2012 Possible Solution: 2020 • Preferable is a less frequent requirement 500 (with more substances) 100 2015 2080 potential SVHCs Source: Substances classified as carcinogenic, mutagenic and toxic for reproduction (CMR) and other substances of concern in consumer products Identification of relevant substances and articles, analytical control and consequences for the regulation of chemicals On behalf of the Federal Environment Agency (Germany) - UMWELTBUNDESAMT 300 Today y c n 2018

Substance Substitution vs. Spare Parts Production 24 Hyundai Motor Europe Tech. Center Gmb. H Timeline of the Automotive Production Development 3 - 4 years Vehicle Production 5 - 8 years ty li i b Spare Parts Production 8 - 12 years (after EOP) Spare Parts availability 0 - X years (after EOSP) Substance substitution la i a v A • Spare parts (still produced in very low volumes mostly by SMEs) have to be re-developed & re-validated (several times? ) = Hugh impact on cost side or even impossible to do!!! • Could have negative consequences on service parts strategy Results in: Increasing costs for customers Decrease of the vehicle lifetime or

A possible solution for (still produced) spare parts 25 Hyundai Motor Europe Tech. Center Gmb. H • How to deal with spare parts for long life products? • Will they have to be re-developed after the relevant substance phase out deadline, again and. . ? • Under the ELV (End of Life Vehicles) Directive 2000/53/EC the problem has been understood by EC and solved in the year 2006 by implementing an exemption for spare parts into the ELV Annex II, called the „repair as produced principle“. • One (of many) proposal for a similar exemption under REACH: Add to REACH Annex XIV a clause such as e. g. • Spare parts put on the market after the sunset date which are used for vehicles put on the market before the sunset date shall be exempted from the provisions of Article 56, REACH.

Challenge: Spare parts on stock (for old vehicles) • Name: Volkswagen Beetle • Surname: Taillight • Born: 1970 in Wolfsburg/Germany • Place of residence: Volkswagen-Audi Classic Parts Centre, Wolfsburg • Parents: Defunct • Population: 6 26 Hyundai Motor Europe Tech. Center Gmb. H

Challenge: Used parts & cars 27 Hyundai Motor Europe Tech. Center Gmb. H And it is not only challenging “new” spare parts on stock… • • • The backyard dealer does not know anything about REACH The supply- & communication chain never existed! How to collect the necessary information?

Challenge: Spare & used parts The preferred solution for the future (Lobbying activities) 28 Hyundai Motor Europe Tech. Center Gmb. H Automotive Industry requests that under Art 33 only the substances have to be communicated that were legally required at the time of production Automotive Industry requests 6 month lead time for data collection between the CL update and start of obligations on communication

33 Calculation of the 1 t Notification Threshold Hyundai Motor Europe Tech. Center Gmb. H • REACH Art. 7(2) requires article manufacturers to calculate whether in their manufactured or imported articles the amount of a CL-Substance is exceeding 1 tpa. Start of Notification obligations ty li i b Substance XYZ is placed on the CL 6 Month i s s o p 1. 1. 2009 1. 1. 2010 1. 1. 2011 No communication obligations are existing. My suppliers have no obligation to inform me about the amount and existance of XYZ in my article 1. 1. 2012 I must know, if XYZ is contained in my article 1. 7. 2012 I must know, if XYZ exceeds 1 tpa 1. 1. 2013 Calculation and notify once 1 tpa re-starts with 0 is reached • ECHA recommends in their „Data Submission Manual“ that the tonnage must be calculated as the average of the last year or last 3 years. Im How can we calculate over the last 3 preceding years without having any chance to get the necessary data?

34 Hyundai Motor Europe Tech. Center Gmb. H REACH is a „tour de force“. . . but the Automotive Industry is well prepared!!!

The Automotive Industry Guideline on REACH Since the publication of the last AIG in 2008, the REACH discussions where continuing on both Industry as well as on COM / Authority side. Some of the outcomes are heavily impacting our business. V 3. 1 of the AIG is providing guidance for all critical subjects Free Download of Version 3 under: http: //www. acea. be/reach/ Available languages: • • • English German Chinese Japanese French Korean (Release date: 07/11) (Release date: 03/12) (Release date: 03/12) 35 Hyundai Motor Europe Tech. Center Gmb. H

Our Way Remains Challenging… 36 Hyundai Motor Europe Tech. Center Gmb. H Thank you for your attention ! Timo Unger tunger@hyundai-europe. com