Stakeholder Consultation Questionnaires
2.1 Proposals for additional exemptions
CCFA cannot support the removal of the current exemptionand request the continued exemption of:
Lead and lead compounds in components: Entry 11: Electrical components which contain lead in a glass or ceramic matrix compound exept glass in bulbs and glaze of spark plugs
No / Criteria / Justification1 / Please describe the material and/or component of a vehicle that contains the
hazardous substance. / Lead compounds in electrical applications are used in a glass matrix for thick-film materials (circuit carrier), passive components (resistors, ceramic capacitors, resonators, positive temperature coefficient (PTC) resistors etc.) and glass frits of VFD displays. For actuators and sensors lead is used as high covalent compound in a ceramic matrix to achieve good ferroelectric properties in a wide temperature range.
2 / Please indicate the type and quantity of the hazardous substance used in the
material and/or component.
Please indicate the quantity of the substance in absolutenumbers and in percentage by weight in homogenous material. / Ceramic capacitors: 0,3 mg lead / piece; Up to 20 capacitors = 6 mg in oxide ceramic /car;
PTC´s over current protector applications and hot wind heater; in average around 1g /car
Glass frits of VFD´s in average 0,7 g lead/ unit [14]. Assuming a take rate of 7% the average content /car is below 0,1 g/car. Piezo sensor applications like gyroscope angular rate, airbag sensors in total around 0.18 g /car; engine applications: piezo anti knocking sensors around 2,2 – 3,5 g lead /car, piezo actuator for fuel injection around 10g / unit or 40g /car 4 cyl. engine. In piezo ceramics lead is part of the perowskite crystal structure of the ceramic and under normal disposal conditions not leachable.
3 / Please indicate the functionality of the substance in the material and/or
component of a vehicle. / Piezoelectricity is based on the ability of certain crystals to emit an electrical charge when mechanically loaded in 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 piezomaterials with a high Curie temperature and a high level of saturation polarisation are necessary. The best known performance have PZT ceramics, which are a mixture of PbTiO3 and PbZrO3. The lead content is between 58% and 68% by weight, depending on the proportion of Zr and Ti).
Direct piezoelectric effect means the converting of mechanical quantities such as pressure and acceleration into electrical quantities. Inverse piezoelectric effect means an electric field which induces a mechanical deformation of a piezoelectric crystal.
Knock sensors require high sensitivity as the sensor head is connected with circuit by means of long cable, which can be easily influenced by external noise. PZT ( = Pb Lead - Zirconium Titanat, PbTiO3 and PbZrO3) ceramics in this application is not possible to be replaced by quartz crystal because of its low piezoelectric constants low electromechanical coupling coefficients. Today, reversing sensors help for example to, register critical movements of the vehicle by gyroscopes
(=driving stabilisation sensors) and thus activate modern stabilizing systems, when parking or manoeuvring or knock sensors sensitively monitor the engine vibrations and inform the engine electronics of the slightest change. Piezoceramic components are used in many other parts also. So important piezo applications are knock-sensors, injection systems, shock–sensors for airbags, driving stabilisation sensors (= gyroscopes), valve control units and parking aid systems.
Capacitor ceramics is oxidized from reducing ceramics. Lead is important agent for oxidizing.
Lead is necessary for PTC Ceramics in order to get following most important electrical characteristics which are requested from market .(1)Withstanding voltage characteristics, (2)Distribution of resistance value. If we cannot use lead, we cannot continue volume -production of PTC products which can be satisfied with the above requirement from market.
In case of PTC Heater, the Curie temperature of PTC ceramics should be designed on around 200°C. Lead is necessary for us to shift the Curie temperature to 200 °C.
4 / Please provide an estimate of the annual quantities of the hazardoussubstance used in this particular application. / Estimated is an current average lead content of 4g embedded in glass and ceramic matrices per car. (incl.2 % cars actually equipped with piezo-injection system) Based on the assumption of 14 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.
5 / Please explain why the elimination or substitution of the hazardous substance is currentlytechnically or scientifically impossible / impracticable. / During the last years in research and development there were no practical alternatives found for piezoelectric based car components and sensors and as well as for long-term highly precise passive and active electric / electronic components. Even lead in glass frits for volume production of VFD´s is required [14]. Lead is still essential in these applications. For piezo ceramic material this is based on desired strong piezoelectric effect for bulk ceramics in a wide temperature range. Therefore the automotive industry applies for continuing the existing exemption without any limitation and proposes a review not before 2011.
6 / Please indicate if the negative environmental, health and/or consumer safety impacts caused by substitution are likely to outweigh the environmental, healthand/or consumer safety benefits.
If existing, please refer to relevant studies on negative impacts caused by
substitution. / Please see 10, respectively the attached file
7 / Please indicate if feasible substitutes currently exist on an industrial and/or
commercial scale.
Please indicate the possibilities and/or the status for the development of
substitutes and indicate if these substitutes will be available by the expiry date
of the exemption or at a later stage. / Due to the variety of application with widespread functions in this field a general substitution of lead in glass and ceramic matrices in components for automotive applications is not expected to be possible. Alternatives have to be proven on a case-by-case basis.
At the moment there is no substitutes known, not on industrial and not on commercial scale. First laboratory studies on KNbO3 piezo ceramic material were presented in 2004 [8], but the achieved material properties even under laboratory conditions are not sufficient for a suitable alternative. Furthermore from laboratory findings to industrial production in articles and qualification of articles at least 7 to 10 years are necessary.
In Europe research projects are run to find suitable material alternatives for PZT ceramics [3].
The research is on a very early stage and at our view far from industrial application.
8 / Please indicate if any current restrictions apply to such substitutes.
If yes, please quote the exact title of the appropriate legislation/regulation. / Not known
9 / Please indicate the costs and benefits and advantages and disadvantages ofsuch substitutes.
If existing, please refer to relevant studies on costs and benefits of such substitutes. / Not known/see 7
10 / Please provide any other relevant information that would support yourapplication for an additional exemption. / See attached file (Justification for Entry 11. doc)
[ ] indicates references/studies which can be found in the attached file.