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The Society of Motor Manufacturers and Traders Ltd.

SMMT

The Society of Motor Manufacturers and Traders (SMMT) exists to support and promote the interests of the UK automotive industry at home and abroad.

Lobbying Activity

Response to 8th Amendment to Annex II to Directive 2000/53/EC on end-of life vehicles

18 Apr 2017

SMMT welcomes the opportunity to provide input the consultation on the Commission Draft “8th Amendment to Annex II to Directive 2000/53/EC on end-of life vehicles”, (ID Ares(2017)1520534), which the industry welcomes. Since the entry into force of the heavy metal restrictions in July 2003, the automotive industry has continuously decreased the amount of Cr(VI), Cd, Hg and lead used. Cr(VI) and Cadmium have no longer been in use for years and all new type approved vehicles in the EU have been mercury free, since July 2012. The life cycle related lead emissions have been reduced by more than 99.5% and today most lead in vehicles originates from the use of recycled materials in metals, mainly aluminum. Low voltage lead batteries need to be considered separately. They are still essential components of the automotive manufacturing however safe substitutes for mass production are not available today. Lead batteries for vehicle applications in Europe are used in an almost closed loop, so that today more than 80% of lead used in the current battery production originates from its recycling. This is based on the fact that more than 99% lead-batteries for automotive applications in the EU are collected and recycled at end-of-life and then used to manufacture new batteries. Please see attached the industry statement on automotive batteries attached, which includes further details. The European Automotive Industry believes that all current significant potentials for phasing out lead have been exploited. For the minimal amount still required for technical reasons, the automotive industry is working on future R&D projects to enable sustainable substitution. The review periods suggested by the EU for entries 2c(i) and 2c(ii), 3 and 5b are the minimum periods to generate significant new scientific results. To avoid potential timings conflicts, between publication and the entry into force dates – as already experienced in the past - we would like to suggest a slight re-phrasing of the review periods for entries 2(c) (i), 3 and 5 (b) into four years, after publication of the new annex II and for entry 2 (c) (ii) into 7 years after publication of the new annex II. Furthermore, this would ensure a sufficient timescale for the further research and scrutiny of test results to enable the potential future volume production with focus on safety, endurance and sustainability. Proposed wording: (1) This exemption shall be reviewed in 2021 4 years after publication in the Official Journal. (2) This exemption shall be reviewed in 2024 7 years after publication in the Official Journal. For entry 2 (c) resp. 2(c)(i) and 2(c)(ii) the new terminology “alloys” have been introduced. Because line 2 of the already existing title of the related column already reads “Lead as an alloying element” the extra term alloy is considered to be obsolete, might cause confusion and should therefore be deleted. Instead of the proposed new wording: 2(c)(i) Aluminum alloys [for machining purposes] with a lead content up to 0.4% by weight. we recommend maintaining the current wording: 2(c) Aluminum with a lead content up to 0.4% by weight. In the current draft, different formulations are used for similar purposes in the column for “Scope and expiry date of the exemption”. We suggest the following format “Vehicles type approved before dd / mm / yyyy and spare parts for these vehicles “ to be used consistently (as for example used in exemption 12) throughout. The additional term (“after that date as”) used in some entries is not needed (e.g exemption 8 h).
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Response to Real-Driving Emissions in the EURO 6 regulation on emissions from light passenger and commercial vehicles (RDE3)

8 Dec 2016

SMMT fully supports the introduction of Real Driving Emissions, including those elements within the Package 3 amendments. However, it is important to understand that the full benefits will only be achieved by allowing the automotive industry, supply chain, equipment manufacturers and test houses adequate time to implement the required measures. SMMT understands the current political pressure to implement the requirements as soon as possible but industry needs to be able to plan for the necessary changes resulting from this new legislation. Implementation of the new measures from 1 September 2019 for all vehicles would not be unreasonable in this regard. However, even this is still a very short lead-time which still presents a huge challenge and should be viewed as an exception in terms of any future regulatory process. The stepped approach for the introduction of RDE has presented an already significant challenge to the Industry in terms of product planning and development. Package 1 and 2 have already necessitated major investment and accelerated or amended product launches in order to be able to introduce the provisions from 1 September 2017. Package 3 includes two additional technical requirements (particle number and cold start) which will require further substantial developments. These are still due to be introduced in the same timeframe despite being presented for agreement within the member states in December 2016 only 9 months before they come into effect. Once agreed, the regulations will have to go through scrutiny by the European Parliament which means the earliest that the regulation will be published is April / May 2017. Only at that point can industry be certain of the exact contents of the regulation. This allows an absolute maximum of 5 months for industry to comply with requirements necessitating changes to product design and manufacturing processes. In some cases, it will simply not be possible within that timeframe. The portable equipment required for particle number measurement has only become available within the past few months. Supply of this equipment is not yet widespread and any existing equipment is unlikely to be to the latest specification. This should be taken into account in setting the acceptable error margin. The equipment should be subject to an approval process to ensure that it is of a level to provide robust results during RDE tests. SMMT supports the inclusion of text in the proposal to separate the introduction of the WLTP regulation (due in 2017 / 2018) from the RDE regulation to allow the introduction dates for RDE NOx contained within Packages 1 and 2 to remain in place (2017 / 2019). Having been previously agreed and published, it is essential that this timing is maintained to avoid further disruption to product and manufacturing developments, both within the vehicle manufacturers and the supply chain. Similar concerns exist around the introduction of the new evaporative emissions testing procedure where the current regulatory text would undermine the introduction date of September 2019 previously agreed by member states in May 2016. SMMT also supports the inclusion of provisions for small volume manufacturers. However, the current regulatory text in the proposal does not achieve the intent shown within the recitals and should be amended. It is vital that Package 3 is agreed by the end of 2016 so that the regulation can be published as soon as possible. Industry cannot make decisions based on unpublished legislation. No additional requirements should be included after this and any further amendments should be avoided except if necessary to improve the robustness of the existing regulation; for example, the inclusion of consideration of the quality of market fuels which should be taken into account and improved in order to achieve a reduction in real driving emissions. Such amendments should be addressed as quickly as possible within the Package 4 discussions.
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