OpenLobby.EU
Explore

Asociación Española de Proveedores de Automoción

SERNAUTO

La Asociación Española de Equipos y Componentes para Automoción, fundada en 1967, reúne más del 85% de la facturación del sector a través de sus empresas asociadas.

Lobbying Activity

Response to Commission Regulation amending Annex XIV to REACH

22 May 2019

SERNAUTO is the Spanish Association of Automotive Suppliers. Among our members, there are several European battery manufacturers. Spain is the first lead-acid battery manufacturer in Europe, with 5 manufacturing plants and several foundries for lead recycling, and exports 70% of the batteries produced. This industrial activity generates 3.000 direct jobs in Spain. To make sure that the European battery industry will be able to contribute to the fight against climate change, delivering at the same time jobs and growth, an integrated strategy on batteries is needed. Chemicals management is an essential part of this strategy: Europe’s chemicals policy must find the right balance to support the growing demand of batteries while ensuring there is no risk to human health or the environment from battery materials. A Risk Management strategy based only on REACH Candidate Listing and Authorisation would be detrimental of industrial growth and investment in battery manufacturing in the EU and could hinder the further development of a globally competitive EU batteries value chain, while not providing an effective higher level of environmental and human health protection. Scientifically robust Occupational Exposure Limit Values under OSH for SVHC metals used in batteries will be a more effective alternative to REACH authorisation. Lead compounds- In the EU, Tetralead trioxide sulphate; pentalead tetraoxide sulphate; orange lead (lead tetroxide) and lead monoxide (lead oxide) are used almost exclusively in the manufacturing of lead based batteries. They are not present in the batteries placed on the market and hence exposure is restricted to industrial uses that are already covered by lead specific provisions in Council Directive 98/24/EC7, Directive 92/85/EEC and Directive 2010/75/EU of the European Parliament and of the Council and its implementing measures establishing Best Available Techniques (BAT) conclusions. We support the Commission's observation that through implementation of Directive 2010/75/EU and its predecessors, emissions of lead and its compounds to the environment have decreased and continue to decrease as shown by the European Pollutant Release and Transfer Register (E-PRTR) reporting. SERNAUTO therefore welcomes the decision of the European Commission to postpone further decisions regarding the inclusion of the four lead compounds in Annex XIV to REACH Regulation (EC) No 1907/2006 until the current Union binding occupational limit value and binding biological limit value for lead compounds under Directive 98/24/EC will be reviewed. These binding limit values no longer represent the technical measures now adopted by Industry to control lead exposure in the workplace nor the latest science on health effects of exposure to inorganic lead compounds. A revision of the current EU workplace binding limit values is a more proportionate risk management option at this stage as it will benefit a far higher number of EU workers than including the four lead compounds in Annex XIV to Regulation (EC) No 1907/2006. A review of the workplace binding limit values will cover all potential workplace exposures to the listed lead compounds, and additionally other lead compounds and lead metal. NMP – Battery manufacturing processes are using NMP in casting processes. NMP content in batteries is lower than 0.1%. Where visible, NMP is collected after the drying process, reused for cleaning of equipment and finally sent for proper recycling. All potential risks connected to the use of NMP are already addressed by the restriction (Annex XVII - entry 71), which is the most appropriate risk reduction measure for NMP. Therefore, we remark our opposition to the inclusion of NMP in Annex XIV to Regulation (EC) No 1907/2006, and invite the Commission to close the process of inclusion in Annex XIV to ensure business certainty regarding its use as flux melting agent.
Read full response

Meeting with Miguel Arias Cañete (Commissioner)

10 Jan 2018 · Mobility Package

Meeting with Miguel Arias Cañete (Commissioner) and CEOE - Confederación Española de Organizaciones Empresariales and

27 Apr 2015 · Energy Policy for Climate Change and Working programme of the EU 2015, and Action Plan

Meeting with Daniel Calleja Crespo (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

25 Mar 2015 · The automotive equipment and sector components in Spain