Anlage 2 zum Schreiben an die EU-Kommission vom 19.12.2006
„Stakeholder Consultation for the purpose of a possible amendment of Annex II“
Entry 4:Bearing shells and bushes
Justification:1 / The need to introduce an exemption from the heavy metal ban for spare partsput on the market after 1 July 2003 which are used for vehicles put on themarket after 1 July 2003 if, at the time when the vehicle was put on themarket, the affected materials or components were covered by one of the sixexemptions according to Annex II; / Main issues are safety requirements and impossible changeson cars in use.
Last year the TAC agreed with a huge majority to the Commission proposal which exempts spare parts for vehicles put on the market prior to 1 July 2003 from the heavy metal ban according to Article 4 (2) a of directive 2000/53 EC.
This decision – which was pretty much appreciated by the automotive industry – has been published under 2005/438/EC in June 2005. The Commission followed with this the principle of Article 4 (2) a, to allow heavy metals only in those cases where they are technically unavoidable. In parts and components for these “old” vehicles the heavy metals were unavoidable. With this decision is – from a technical point of view urgently required – the principle “repaired as produced” applicable for these vehicles and their spare parts without any time limitation.
After 1 July 2003 the unavoidable usage of heavy metal containing parts and components in new produced vehicles and spare parts is regulated by the Annex II of directive 2000/53/EC: heavy metals are allowed for a limited or unlimited period of time or they are not allowed for a unlimited period of time. After the expiry date of the respective exemption it is not allowed to produce a spare part in its heavy metal containing original form according to the current legislation. With this, a vehicle produced after 1 July 2003, can not be repaired with an original spare part, if the respective exemption has been expired.
This may lead to the fact that a relatively new vehicle needs to be scrapped in the worst case, which makes no sense from a macro economical point of view.
Or the vehicle will be repaired and handed back to the customer without any safety guarantee and warranty of the manufactures, which would be clearly irresponsible.
In order to ensure the spare parts availability of vehicles produced between 1 July 2003 and the expiry date of the exemptions the manufacturing of new spare parts in its original design (principle “repair as produced”) must be possible. This affects by far not all spare parts, but only a few most of them out of safety relevant
areas of a vehicle; we are talking about five exemptions out of the current Annex II.
Bearing shells and bushes are used to bear the mechanical load of rotating or moving parts and they are always part of a complex tribological system where the three parameters (friction/wear/lubrication) and therefore all involved components and materials are adjusted to each other.
Lead is used due to its superior lubricating properties as well as dry-run properties (emergency running properties). Lead is also able to embed harmful dirt particles, has a very a high mechanical strength and excellent fatigue properties. It is impossible to replace lead on the same level of performance.
2 / The current (and future, if possible) existence of feasible substitutes on anindustrial and/or commercial scale; / The car manufactures and suppliers have been working hard on lead-free substitutes of bearing shells and bushes for new developments. For entirely new developed engine and transmission generations lead free applications are already in use or under development.The substitutes for lead are mostly Tin, but also Bismuth and Antimony are in use.
At the moment substitutes for all applications of bearing shells and bushes are not available. For many applications substitutes are already in series, some are in the development stage and for some applications, which defer from engine to engine or transmission to transmission, are no substitutes/ alternative materials available at the market.
For “running” series and some heavy loaded bearings and bushings the exemption needs to be prolonged for the production of new vehicles. Lead-free substitutes are not available for all applications, especially not for heavy loaded applications.
3 / Any restrictions that apply to such substitutes, in particular:
whether suchsubstitutes can be used to replace materials and components in vehicle spare
parts in those cars which were originally equipped with parts using heavymetals; / Because of the good material properties lead-containing bearing materials can be loaded with higher surface pressure and higher peripheral velocity than lead-free variants.
The mentioned substitutes do not have the superior properties of lead and therefore for lead-free substitutes major dimensional changes of the counterparts are necessary (diameter, width, thickness of sliding layer, etc.). This requires a very high amount on development and testing time (supplier and car manufacturer for one application of a bearing: 4-6 years). Bearing shells and bushes which are not tested and validated within the tribological system (e.g. grey import) will not have the same properties and therefore not meet the requirements.
The failure of those bearing shells and bushes will cause damages of all other components in the tribological system. This leads to damages of the entire engine until the total blocking. Blocking of the engine in full speed as a consequence of a total failure represents a very high risk for causing accidents.
Such engines can not be used anymore and must be replaced by a new one.
Since the dimensions have been changed a direct interchangeability of the lead-containing original components by lead-free spare parts is not possible. An installation of a lead-free bearing would only be possible, if technically feasible at all, by intensive and not justifiable replacement on the entire engine.
Because of the dimensional changes the current engines and other applications of lead-containing bearing shells and bushes cannot be used without major dimensional changes of the counterparts. In addition to this no “old” engines are available anymore to carry out all necessary tests to fulfill and prove safety requirements. Tests can only be done by using dynamic test stands which is not sufficient for most of the heavy loaded applications, and whose capacities are limited and primarily used for the series developments.
4 / The costs and benefits of such a substitute; / The development time e.g. of an entire new engine including all test at the suppliers, in laboratories, durability tests at test stands and finally durability road tests (on proving grounds) in the vehicle takes a couple of years (4 to 6 years). This depends e.g. of the amount of “carry over parts” from a previous engine (which had been tested and validated in this engine) and the amount of new parts, if the test are successful the first time etc.
The development and implementation of new engines is usually "decoupled" from the development of a new vehicle type. Thus new vehicles will be launched with engines which had been used in previous vehicle types. The new developed engines will be implemented later during the production phase of a vehicle.
Extensive testing needs to be done (e.g. several thousand hour on a test bench for series development), in case of malfunction test needs to be repeated from the beginning on. In addition to this there are intensive long term summer/winter durability and safety tests needed to be done in a vehicle (approx 1.5 Years)
5 / The advantages and disadvantages of such a substitute, in particular anytechnical and safety implications of its application. / Lead-free bearings would not fit into these used engines
Not properly tested and validated bearings,which may fit (dimensionally) into the engine but not having the same properties, will cause damages of all other components in the tribological system and therefore damages of the entire engine > blocking of engine at full speed > safetyrisk by accidents.
Because of our obligation to give guarantee for our products, we need to repair and service with “original” spare parts.
The environmental impact of lead-containing bearing shells and bushings is rather small. During the production of lead-containing bearing shells and bushes is done under existing EC legislation. There is no significant release of lead into the environment.
Lead-containing bearing shells and bushes are part of large metal components of the vehicle, such as engine or transmission. In the recovery process the metal fractions including those bearing shells and bushes end up in the aluminum, steel or copper smelting process. In those processes reliable technologies for the prevention of protraction of heavy metals are in place.