End of life vehicles (ELV) European directive on lead, mercury, cadmium and hexavalent chromium
The European directive 2000/53/EC was published 18th September 2000 and came into force on 21st October 2000. It requires EC member states to transpose the directive into their national law by 21st April 2002.
A UK government consultation paper was published August 2001 outlining the issues, including the restriction on the use of ‘heavy metals’ in new vehicles from July 2003.
Copies of the EC directive are available on the Department of Trade and Industry web site www.dti.gov.uk
The UK government consultation paper notes that article 4 of the EC directive states that vehicles put on the market after 1st July 2003 must not contain any of the ‘heavy metals’ lead, mercury, cadmium and hexavalent chromium, unless exempted in Annex II of the directive. This may also apply to replacement components for new AND existing vehicles, where the components are sold after July 2003, but this is still subject to some debate.
The original version of the EC directive only had steels containing lead up to 0.35% as an exemption in Annex II , although there are mechanisms in the directive for reviewing the Annex II exemptions.
How the EC directive applies to stainless steels
The original list of Annex II exemptions does not apply to stainless steels as lead is not added, as it is in some other alloy steels, to improve their machinability. Limits of 0.1% maximum for lead, mercury and hexavalent chromium and 0.01% for cadmium are reported to have now have been accepted as applicable to stainless steels, provided these elements are not been deliberately added during steelmaking.
Eurofer, (the European trade association of steel producers), has been working with European automobile manufacturers during 2002 to produce a list of standardised steel grades for inclusion on the automobile manufacturers ‘International Materials Data System’. The steel producers should then provide a statement to show that each of the grades appearing in European standards supplied for automobile applications meet the ‘ELV’ directive, Annex II requirements. This has to be based on analytical evidence of lead, mercury and cadmium in the relevant steels.
These elements are not usually deliberately added to any stainless steel grades and so routine analysis, cast by cast, is not done. Consequently no values for these elements can be expected on material test certificates.
Progress on heavy metal element levels
Some analysis work has been done by the Scandinavian stainless steel producers AvestaPolarit, (now Outokumpu Stainless), and Sandvik Steel. This indicates that the steels tested have values for lead, mercury and cadmium well within the known maximum level restrictions. Chromium in the hexavalent valency-state is not present in stainless steels and so cannot be analysed and declared. This is quite different from chromium in the metallic state, which is always present in stainless steels, by their definition, (10.5% minimum).
This metallic chromium is analysed on a routine basis and reported on stainless steel material test certificates. Metallic chromium, as an alloying element in stainless steels, is NOT restricted in the ‘ELV’ directive.
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