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 Cr 6+ 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, Cr 6+. 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 Cr 6+ 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, Cr 6+, 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 Cr 6+ limits on galvanizing post-treatment Cr 6+ 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% Cr 6+ at surface Practical experience: Suppliers have switched to non- Cr 6+ alternatives for passivation for products covered by WEEE (and ELV). Cr 6+ limits are more problematic for other zinc coatings.

15. RoHS and ELV Requirements: Important differences Concentration limits for Pb, Cr 6+, 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.