Request for a continued exemption pursuant to Article 4(2)(b)(ii) of 2000/53 EC resp. Annex II from 20.09.2005 (2005/673/EC)

Entry 11.

Electrical components which contain lead in a glass or ceramic matrix compound exempt glass in bulbs and glazing of spark plugs

This report is an industry contribution concerning entry 11 of Annex II in the form of 20.09.2005 and it is an application for an unlimited exemption for the use of lead in a glass or ceramic matrix compound.

Thesis

The aim of the material ban is to minimize the overall negative impact of heavy metals, used in vehicles, on beings and the environment. Therefore the scope of the impact should be on bioavailability of heavy metals used. Closed loop use with missing significant release into the environment should be considered specifically.

Summary:

Lead is today still an essential material for some long-term highly precise passive and active electric/ electronic components as well as for piezo-ceramic based sensors and actuators. These components are often used in automotive applications resulting in a reduction of emissions, noise, weight, less fuel consumption or improved safety systems. From end of life vehicles they will end up in the material recycling processes or on special waste disposal. Amount of lead compared with positive effects for the environment or risk of release is low [12]. For some applications they are the basis to achieve further advanced environmental performance of a car (e.g. to meet emission standards beyond Euro IV etc.), which is not possible with conventional systems.

Although intensive research materials with suitable material characteristicsfor automotive applications like long term temperature stability and sufficient strong piezo effects, necessary for advanced industrial serial products are only feasible with piezo-material still containing lead. Environmental advantages of these articles(e.g. emission reduction or fuel reduction by piezo injection systems) compensate marginal lead-content by far.

In addition volume production of glass frits forVFD (vacuum fluorescence displays) still requires the use of lead[14].

Meanwhile efforts in research and development of the supplying industry in cooperation with public institutes will be continued to find lead-free alternatives, but these alternatives are not available today [3].

Therefore the automotive industry applies for continuing the existing exemption without any limitation and proposes a review after 2011.

Detailed Justification and supporting information regarding applications covered under entry 11.

It is our intention to provide all necessary information to enable an assessment based on facts of the environmental aspect / impact / benefit of lead containing electrical components within automotive applications.

Requirements for Electric Components Containing Lead / Annex II 2005/673/EC

With the amendment of the Annex II 2005/673/EC, electrical components containing lead in a glass or ceramic matrix are exempted from the heavy metal restriction of the End of Life Vehicle Directive 2000/53/EC, without fixed expire date.

For components other than piezo in engines there is the obligation of dismantling, if together with lead form solder applications an average threshold of 60g per vehicle is exceeded.

The Ökopol study on Heavy Metals in Vehicles II [1]to last stakeholder consultation on Annex II confirms environment advantage of PZT connected to engine and the necessity of further information

More information was provided by the automotive industry on detail within the last stakeholder consultation on Annex II.

Electrical Components containing Lead:

* The piezo effect / piezoelectric materials:

Piezoelectricity is based on the ability of certain crystals to emit an electrical charge when mechanically loaded by pressure or tension (direct piezo effect). Conversely, these crystals undergo a controlled deformation when exposed to an electric field - a behaviour referred to as the inverse piezo effect. The polarity of the charge depends on the orientation of the crystal relative to the direction of the pressure.

For automotive applications especially within the engine area piezo-materials with a high Curie temperature and a high level of polarisation saturation are necessary. The best known performance have PZT ceramics, which are a mixture of PbTiO3 and PbZrO3 .

Direct piezoelectric effect means the converting of mechanical quantities such as pressure and deceleration (during an accident) into electrical quantities.

Inverse piezoelectric effect means an electric field which induces a mechanical deformation of a piezoelectric crystal.

Applications of Piezoceramic within Vehicles

Apart from electric / electronic circuits which contain small components with a low lead content (total amount per vehicle < 2g) there are various applications, either already existing or lying in the future, where piezoceramic actuators and sensors are the basis for advanced technology.

Some of these applications are directly used to optimise the engine performance and so saving fuel and reducing emissions.

Even if they serve at first sight only for convenience reasons, they might also generate additional environmental benefit e.g.

  • active noise killing systems may substitute weight intensive sound insulation materials
  • wheel tyre guards will positively influence running characteristics of a car because they inform the driver about the proper tire pressure and such also reduce fuel consumption
  • park distance control sensors may prevent driving around searching for bigger parking spots.

Piezo Ceramic Injection Systems

The automotive industry has developed a high pressure diesel (gasoline) injection system with piezo technology, the Piezo Common Rail System.

A common rail system is an injection system which offers high pressure fuel for injection at any given moment. To reduce engine noise and emissions, it is necessary to add several small pilot- and post-injections to the main injection during a working cycle of a diesel engine. The essential component of the common rail system is the injector.

Piezo Ceramic Injection System / The Injector

The injector of the common rail system is designed to reach very low injection quantities. That can be realized exclusively due to a piezo actuated valve which controls the amount of diesel injected.

The piezo actuated valve offers the following advantages:

  • The valve switches 30 times faster than a conventional solenoid valve, because it requires no time for a magnetic field to be generated and omitted with each reaction.

Result: Very low injection quantities and several single injections possible.

  • The piezo actuated valve offers a better reproducibility of the injection quantities than a valve actuated with solenoid technology.

Result: Precise injection quantities over the lifetime of a diesel engine which ensures a continuous low level of emission.

In practice that means:

  • The Piezo Common Rail System provides the opportunity to meet Euro IV emission standard without additional hardware components on the engine.
  • Furthermore Diesel passenger cars equipped with the Piezo Common Rail Systems fulfil Euro IV introduced 2005 already in 2003.
  • The piezo technology offers further potential to meet future emission standards beyond Euro IV, for diesel as well as for gasoline injection systems.

Injection System – Direct Environmental Advantages

This slide shows the impressing reduction of emissions which is possible already with piezoceramic injection systems today.

Further research and developments depend also on obligations for dismantling or restriction.

Estimation of total Lead Amount for Electrical Components
Containing Lead in Glass or Ceramic Matrix

Estimated is an current average lead content of 3,3 g in glass and ceramic matrices per car. (incl.2 % cars with piezo-injection system). The calculation do consider actual average take rates and equipment. Based on the assumption of 15 Mio passenger cars put on the market in 2005 within the EC this sums up to around 50 tons for the total EC area. More than 90 % wt are for piezoceramics. The release risk of lead from piezo ceramics is low due to the fact that lead from a perowskite crystal structure is not leachable under normal disposal conditions (inert behaviour). In future by increasing applications of piezo injection systems which improve fuel economy enormously this amount will rise.

Positive Effects of Piezo Ceramics on Safety or Environment

Piezoceramic used in various applications as well as on the engine as on chassis provides benefits for the environment and safety.

Environmental Assessment of a Piezoceramic Injection System

over a total Vehicles Life-time

The amount of lead in vehicles used in a glass or ceramic matrixes is lower than the amount of pollutants that would be emitted from the vehicle over its life without the components containing lead in a glass or ceramic matrix, therefore the use of lead containing piezoceramics has a significant environmental benefit over the life of the vehicle.

Fate of Lead containing Piezoceramics from End of Life Vehicles

A release into the environment of lead from end of life vehicles due to materials containing lead in a glass or ceramic matrix is very unlikely!

Lead-free Piezo Ceramics

Currently it is not possible to substitute materials containing lead in a glass or ceramic matrix and achieve the necessary material properties for current vehicle applications!

Research Efforts

There are intensive research efforts to develop lead free alternatives, carried out as joint public funded projects* [3] as well as from the supplying industry of piezoceramics, but today technical feasibility is not yet achieved.

Exemption for Electrical Components containing Lead in a Glass or Ceramic

Matrix is still necessary!

Therefore the automotive industry applies for continuing the existing exemption without any limitation and proposes next review in 2010 /2011.

Additional remark.

The ban makes it hard to use in future active noise killing systems within a car. These systems use piezoelelectric effects for sensoring and actuatoring and have a high potential to save weight intensive sound insulation materials [10, 11]. The systems have to be matched properly to specific geometries what on the other hand means that a dismantling would be rather difficult.

Sources:

[1]J. Lohse, K. Sander, M. Wirts: Heavy Metals in Vehicles II (Final Report) , p.22 ff ; Ökopol - Institut für Ökologie und Politik GmbH Hamburg July 2001 Report compiled for the Directorate General Environment, Nuclear Safety and Civil Protection of the Commission of the European Communities Contract No B4-3040/2000/300649/MAR/E.3

[2]A.Roosen [chair for technical ceramics; university of Erlangen-Nuernberg material science division]: Substitutes for PZT automotive piezoceramics are missing. personal email communication with R. Hoock, BMW AG Munich 11.08.2000;

[3]N.N.: Project report “Bleifreie Piezokeramiken für die Aktorik (DelLead)” in: Wing, Projektträger Jülich Geschäftsbereich neue Materialien und chemische Technologien; deutsches Bundesministerium für Bildung und Forschung 2006 Förderprojekt 03X4002 Joint partners: Robert Bosch GmbH, Siemens AG, Fraunhofer IKTS, Dresden, IKM,
Universität Karlsruhe, Universität Hamburg-Harburg, Universität des Saarlandes

[4]Ch. Kittel: Einführung in die Festkörperphysik; 6. Auflage 1983 p 443 ff (chapter on ferroelectric crystals) Oldenbourg Verlag München 1983

[5]web pages Argillon piezo products argillon.com Nov. 2006-11-19

[6]web pages ceramics laboratory ecole polytechnique Lausanne http:\ lc.epfl.ch Nov 2006

[7]I. W. Clelland, R.A. Price ITW Pactron leadfree solder study; Lynchburg / Virginia Sept 2005

[8]

[9] company specific input to this report from BMW, Bosch, Epcos, CeramTec, Argillon, Siemens Automotive.

[10]FHG 2003

[11]Konetschny, C.: “Adaptronik: Perspektiven für den kompakten Leichtbau - Aktive Werkstoffe reduzieren den Bedarf an zusätzlichen Sensoren und Aktoren“ Bericht zur Messe Materialica 2004 u. Prototypenstudie Karmann/Osnabrück mit ERAS/Göttingen. in VDI nachrichten 10.09.2004Düsseldorf.

[12]COWI: Heavy metals in waste. Final Report. European Commission DNG ENV E3 Febr. 2002 project ENV.E3/ETU/2000/0058.

[13]cordis database screening done 3.12.2006; cordis.lu

[14]Futaba (company): Request within internet stakeholder consultation for lead in glass frits of VFD´s (vacuum fluorescence displays): 3.12.2006