EU RoHS Regulations: Interpretation & Impact for the General Galvanizing Industry

1. EU RoHS Regulations: Interpretation & Impact for the General Galvanizing Industry ASTM A05 Workshop, May 23 2007, Norfolk Murray Cook, Director, European General Galvanizers Association Tom Langill, Technical Director, American Galvanizers Association

2. Structure • Wider picture and origin of concentration limits • Key Issues for Galvanizers • Scope of the WEEE Directive • Natural presence of Pb and Cd • Definition of “homogeneous component” • Use of Cr6+ in post-treatment • Consistency with the ELV Directive

3. The wider EU picture and US origins of RoHS Regulations! • Early 1990s: USA CONEG initiatives for packaging waste – concentration limits on Cd, Hg, etc • 1999: EU Packaging Waste Directive • 2000: EU End of Life Vehicle Directive (ELV) • 2003: EU Waste Electronic & Electrical Equipment (WEEE) and RoHS Directives • 2007: REACH……

4. EU Product-based Waste Regulation • WEEE, ELV and Packaging Directives primarily for waste reduction and recycling. • Restrictions on hazardous substances a minor part of the legislation - with a big impact on industry.

5. Origin of Concentration Limits for Hazardous Substances • Original ELV and WEEE Directives –zero limits for Pb, Cd, Hg, Cr6+. • Auto industry lobbies for 2003 ELV Directive amendment - limits at 0.1% (0.01% for Cd) • These limits then transposed to WEEE/RoHS in 2005 amendment Practical Experience: The original (2003) Directive text has to be read in conjunction with the later (2005) Commission Decision 2005/618/EC – otherwise customers assume zero concentration.

6. Key Issues for Galvanizers • Scope of the WEEE Directive – which products/applications are covered? • Natural presence of Pb and Cd in zinc and definition of “homogeneous component” • Use of Cr6+ in post-treatment • Consistency with the ELV Directive

7. Scope of the WEEE (and therefore RoHS) Directive • Need electric current or magnetic field to work • < 1000V AC or 1500V DC • Used in: • Large/small household appliances • IT & Telecoms equipment • Consumer equipment • Lighting equipment • Electrical and electronic tools • Toys, leisure and sports equipment • Automatic dispensers

8. Scope of the WEEE (and therefore RoHS) Directive • The vast majority of general galvanized products are definitely outside the scope: • Electrical engineering products such as cable tray, electrical cabinets, transmission towers Practical experience: Manufacturers in these fields seek RoHS compliance regardless of scope of WEEE.

9. Concentration Limits • Pb, Cr6+, Hg, polybrominated biphenyls, polybrominated diphenyl ethers – 0.1% each; Cd – 0.01% • Applied per homogeneous material • Pb and Cd naturally present in zinc coatings • No application-specific exemptions for Pb or Cd in galvanized steel • Applies to the final product; not process

10. Concentration Limits • Typical range of Pb and Cd in general galvanized coatings • Cd << 0.005%  • Pb 0.05% - 0.4% x • Is a galvanized steel component the homogeneous material or the coating itself?

11. European Commission Interpretative Guidance on RoHS, August 2006 • “Homogeneous material means a material that cannot be mechanically disjointed into different materials” • “Mechanically disjointed means ..the materials can be separated by mechanical actions e.g., ..crushing, grinding and abrasive processes” • “Examples of homogeneous materials are …..metals, alloys, paper, board, resins and coatings.”

12. Averaging the lead content across the steel component? • Commission Guidance appears to preclude it • Not yet “tested in courts” Practical experience: Customers (and authorities) are using “surface-level” testing procedures and require compliance at surface regardless of this averaging argument.

13. Exemption for lead in galvanized steel • ELV Directive – exempts “lead in galvanized steel up to 0.35% by weight” • Similar exemption for RoHS rejected – product examples cited by industry (cable tray, cabinets) deemed outside scope of WEEE! • Industry has not resubmitted exemption request

14. Impact of Cr6+ limits on galvanizing post-treatment • Cr6+ limit exemption for corrosion protection of “unpainted metal sheets and fasteners” to 1 July 2007. • General galvanizing post-treatment (0.3% sodium dichromate) yields <0.1% Cr6+ at surface Practical experience: Suppliers have switched to non- Cr6+ alternatives for passivation for products covered by WEEE (and ELV). Cr6+ limits are more problematic for other zinc coatings.

15. RoHS and ELV Requirements: Important differences • Concentration limits for Pb, Cr6+ , Cd, Hg are identical • ELV: Limits only apply when substances are non-intentional or due to use of recycled feedstock. • RoHS: Substances can be intentional / non-intentional • ELV: Exemption for <0.35% Pb in galvanized coatings and implication this limit applies across the whole steel component (cf. free-machining steels)

16. Summary • Most general galvanizing applications are outside scope of WEEE/RoHS. • Restriction on lead content may prove problematic if coating considered the homogeneous component. • EGGA not aware of any loss of market for any product inside scope and exceeding the Pb limit. • If examples are found – EGGA will reintroduce a request for exemption for Pb <0.35% as per ELV Directive.