thyssenkrupp Bilstein WNB-880-E

Materials and Substances of Content (Automotive Environment Compatibility) (EN)

1. Aim and task The company standard WNB 880 refers to the harmful environmental impact of
parts in vehicles. The aim is to minimise possible harmful environmental impact
to the greatest extent as defined by a holistic consideration and to apply it
during the product development within ThyssenKrupp Bilstein and its suppliers.

2. Scope WNB applies to materials and substances of content of parts, fuels and spare
parts, used within the automotive industry. It does not matter whether the
substances enter the parts during manufacturing, maintenance, repair or use.
The REACH Regulation, Waste Framework Directive (WFD) and California
Proposition CP65 apply generally to all components including packaging
materials.

For substances requiring declaration of their substances of content according to

the current state of knowledge, or whose use is restricted by legal provisions,
this WNB specifies the manner in which they may be used.
The content of this standard does not release the user from his duty to inform
himself about deviating legislation outside the EU and the national
implementation of laws, directives and regulations across the EU, and to take
these into account.

3. Legal Unless no further requirements are specified in the following, at least all
requirements and applicable laws and regulations with regard to materials and substances of
rules content must be observed without exception, especially:

- VDA 232-101 Declarable substances

- EU-RL 2000/53/EC
- GefStoffV
- REACh 1907/2006(EC)
- TRGS 552
- Dodd-Frank Act
- DIRECTIVE 2018/851/EC
- California Proposition CP65 The Safe Drinking Water and Toxic
End-of-life Vehicles Directive (European
Directive for End-of-life Vehicles)
Regulations for handling hazardous substances
Registration, Evaluation, Authorisation and
Restriction of Chemicals
Technical Rules for Hazardous Substances,
N-nitrosamines
Regulations for companies dealing with conflict
minerals, Federal Law USA
Revised Waste Framework Directive (WFD)
(2008/98/EC)
Enforcement Act

3.1 Substances of The use of the substances mentioned in VDA 232-101 is prohibited, restricted
VDA 232-101 / or subject to other conditions. The list must be observed and is only valid in
GADSL List conjunction with the corresponding explanations.

A current GADSL list can also be accessed via https:/www.gadsl.org/.

GADSL = Global Automotive Declarable Substance List

Index 8 Originator: MPP Quality Management Technology & Innovation

First edition: Kusche 2005-07-22 OK: Luczak, Hanno OK: May, Patrick (11/11/2020 08:45)
(11/27/2020 19:31) OK: Müller, Jochen (11/19/2020 14:35)
Updated: Ziemann, Stefan
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Materials and Substances of Content (Automotive Environment Compatibility) (EN)

3.2 Substances with
regard to the End-
of-life Vehicles
Directive
According to EU-RL 2000/53/EC, for new vehicles and their spare parts
prohibitions apply as of 01 July 2003 regarding the use of lead, mercury,
cadmium and hexavalent chromium (chromium(VI)). Exceptions are only
admissible if they are explicitly specified in Annex II of the directive. Especially
chromium(VI) and lead, which is why they are emphasised here:

- Hexavalent chromium (Cr(VI))

Basically, the use of Cr(VI) is prohibited since 01 July 2007. Alternative
coatings, which are to be used as a corrosion protection on surfaces, are
specified in WNB 879-D (chromium (VI)-free coatings on ferrous material).

- Lead
In the EU End-of-Life Vehicles Directive (Annex II of Directive 2000/53/EC),
an exemption regulation permits the use of lead in aluminum up to a
proportion of 0.4 percent by weight. In the revision of Annex II of Directive
2000/53/EC planned for year 2021, this exemption for lead in aluminium is
due for review. Suppliers are therefore urged to use materials with a lead
content of < 0.1 percent by weight wherever possible in consultation with tk
Bilstein.
All materials mentioned in Annex II of Directive 2000/53/EC are excluded
from general prohibition (to be mentioned is the field of application and the
target date of the exception)

Lead as an alloy component in steel and aluminium for machining purposes, is

excluded from general prohibition. For the respective applicable maximum
content, refer to Annex II in the most current version.
Annex II controls the max. lead content by weight, which must not be exceeded.
Falling short of the min. lead content by weight specified in the technical
documentation by ThyssenKrupp Bilstein is inadmissible without previous
announcement by the suppliers and approval by ThyssenKrupp Bilstein.
The aluminium materials currently used at ThyssenKrupp Bilstein are provided
with various lead contents and are specified as listed in Chapter 4, effective
immediately.

In particular, it is stated that since 01 July 2005, no lead may be contained in

vulcanising agents and stabilisers for elastomers. This requirement includes
among others rubber-metal bonded components, which thus must be
manufactured with lead-free bonds.

3.3 Regulations for The German Regulations for handling hazardous substances (GefStoffV) govern
handling comprehensively the protective measures applying to employees handling
hazardous hazardous substances. Hazardous substances are substances, preparations
substances and products with certain physical or chemical properties, such as being
extremely flammable, toxic, corrosive, carcinogenic to mention only the most
dangerous ones. The respective current version of the GefStoffV can be
accessed via the website of the Bundesanstalt für Arbeitsschutz und
Arbeitsmedizin (BAuA - Federal Institute for Occupational Safety and Health)
http://www.baua.de.

Index 8 Originator: MPP Quality Management Technology & Innovation

First edition: Kusche 2005-07-22 OK: Luczak, Hanno OK: May, Patrick (11/11/2020 08:45)
(11/27/2020 19:31) OK: Müller, Jochen (11/19/2020 14:35)
Updated: Ziemann, Stefan
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Materials and Substances of Content (Automotive Environment Compatibility) (EN)

3.4 REACh A relevant aim of the European Chemicals Regulation REACh 1907/2006 is the
Regulation replacement of substances of very high concern by less dangerous substances
or technologies.

- Substances requiring approval (SVHC) according to REACh regulation

Substances, listed in REACh Annex XIV, are basically prohibited for new
constructions. Even if it requires approval (Sunset Date) only after the use in
series takes effect.
An up-to-date list of all substances subject to authorisation is available at
https://echa.europa.eu/authorisation-list.

- Especially substances of very high concern (SVHC) according to the

REACh regulation
The use of SVHC substances of the REACh list of candidates for new
constructions must always be avoided if technically and economically viable
alternatives are available. If a use on technical and economic grounds is
required, the component specialist1 / technical project manager must be
notified actively and accordingly by the suppliers. A current list of
candidates is available at https://echa.europa.eu/candidate-list-table.

The SVHC list of candidates and the REACh Annex XIV are updated by the
European Chemicals Agency (ECHA) in regular intervals. The supplier is
obligated to check the use of the newly added substances or SVHC candidates
requiring approval in its products within 6 weeks after the update of the list. If
substances in the lists of newly added substances are used in products
supplied to ThyssenKrupp Bilstein, the component specialist1 must be notified
immediately.

In this case please send an e-mail to: imds.bilstein@thyssenkrupp.com

Ref. to 1) The component specialist is listed in the title block of the drawing as "Standards checked".

3.4.1 Waste Framework As part of the implementation of the EU Action Plan (2015) for the recycling
Directive (WFD) industry, the amended Waste Framework Directive - WFD 2018/851/EC came
into force in July 2018.

Companies that sell on the EU market articles containing substances of very

high concern (SVHC) from the candidate list in a concentration > 0.1% by
mass, must provide ECHA with information on these articles from January 5,
2021 onwards.

If a delivered article, component or packaging or packaging material (e.g.

paperboard boxes, transport protection caps, foils, labels, adhesives, PE/VCI
bags, printing inks, etc.) contains a SVHC substance of the REACH candidate
list, this article / component or the packaging or packaging material must be
reported by the respective supplier to the SCIP database (Substances of
Concern In articles as such or in complex objects (Products) of the ECHA
(European Chemicals Agency).

Index 8 Originator: MPP Quality Management Technology & Innovation

First edition: Kusche 2005-07-22 OK: Luczak, Hanno OK: May, Patrick (11/11/2020 08:45)
(11/27/2020 19:31) OK: Müller, Jochen (11/19/2020 14:35)
Updated: Ziemann, Stefan
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Materials and Substances of Content (Automotive Environment Compatibility) (EN)

In such cases, the supplier has to carry out a SCIP notification for all articles
concerned and has to inform tk Bilstein about the SCIP ID / UUID number and
Snapshot UUID / Submission No. of the dossier, if applicable, because complex
product structures have to be mapped in SCIP and referenced to SVHC
substances in articles, components or sub-assemblies.

The SCIP database supplements the existing reporting and notification

obligations for substances on the candidate list. It should be noted that new
substances are regularly added to the REACH Candidate List, usually twice a
year (December/January & June/July). Supplier shall check without being
asked whether the newly added substances are contained in articles,
components or packaging delivered to tk Bilstein. If this is the case, the affected
products, article or part numbers have to be reported immediately to tk Bilstein
and the above mentioned SCIP notification has to be carried out (if the supplier /
manufacturer or importer is located within the EU).
Non EU suppliers are NOT allowed to create reports in SCIP, in this case send
an email to the email address below, stating the tk Bilstein article or part
number and information about the contained SVHC substance.

The SCIP notification for articles or components that are part of a

product (damper) must be made via the IMDS system (from Release
13.0 - expected to be available on March 10th, 2021).

IMDS Material Data Sheets already prepared and accepted by tk

Bilstein have to be updated by the required SCIP notification if SVHC
substances > 0.1 % mass percentage are contained.

For articles or packaging that cannot be reported in the IMDS

system, please send an e-mail to imds.bilstein@thyssenkrupp.com

The ECHA submission portal (ECHA Cloud Service) is an online tool for
submitting SCIP notification dossiers according to the IUCLID harmonised
format*. The ECHA cloud service and the ECHA submission portal and further
information can be found at: https://echa.europa.eu/scip

*) IUCLID = International Uniform Chemical Information Database

3.5 Perfluoro- During new construction, the use of PFOA is always prohibited, even to
octanoic-acid manufacture parts within the production process of the supplier. Even if these
(PFOA) substances can no longer be detected in the final product.
For products in series, a prompt change to respective PFOA-free substitutes
must be performed. To this end, the process is to be coordinated with the
component specialist1.
Ref. to 1) The component specialist is listed in the title block of the drawing as "Standards checked".

Index 8 Originator: MPP Quality Management Technology & Innovation

First edition: Kusche 2005-07-22 OK: Luczak, Hanno OK: May, Patrick (11/11/2020 08:45)
(11/27/2020 19:31) OK: Müller, Jochen (11/19/2020 14:35)
Updated: Ziemann, Stefan
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Materials and Substances of Content (Automotive Environment Compatibility) (EN)

3.6 N-nitrosamines
N-nitrosamines are organic nitrogen compounds developing under certain
reaction conditions from nitrosing agents and nitrosable secondary amines. If
technically possible, the development and release must be limited to a
minimum. Especially the recommendations, protective measures and limit
values which are mentioned in the Technical Rules for Hazardous Substances
TRGS 552 must be observed. The respective current version of the TRGS 552
can be called up via the website of the Bundesanstalt für Arbeitsschutz und
Arbeitsmedizin (BAuA - Federal Institute for Occupational Safety and Health)
http://www.baua.de.

3.7 California California Proposition 65 is administered by Cal/EPA's California Office of

Proposition Environmental Health Hazard Assessment (OEHHA) and regulates substances
CP65 that are officially classified as carcinogenic, birth-reducing or reproductively
harmful in the US State of California.
The list of substances covered by CP65 is regularly updated and published.
Based on analyses and current scientific knowledge, chemicals are added or
removed from the list. All substances are listed with their known risk factors, the
date of listing, the unique CAS number and whether they have been removed
from the list, if applicable.

If substances are contained in products from tk Bilstein, the legal regulations of

the US State of California regarding the obligation to label must be observed.
Furthermore, we immediately request the supplier to send a notification of the
substance, stating the tk Biklstein article number, to the e-mail address given
here: imds.bilstein@thyssenkrupp.com

A current list of all CP65 substances can be found at:

https://oehha.ca.gov/proposition-65/proposition-65-list

3.8 Conflict Minerals
With the Dodd Frank Wall Street Reform and Consumer Protection Act (Dodd-
Frank Act), a federal law came into effect in the US in 2010, which contains
regulations for companies dealing with conflict minerals.
The Dodd-Frank Act requires reporting and disclosure requirements for US
listed companies with respect to the use of conflict minerals. Concretely, the
raw materials tin, tantalum, gold and tungsten are referred as conflict
minerals.

As part of the disclosure obligations, companies must show whether the

resources mentioned are used in their production process. The regulations do
not apply if the raw materials are used in the production process but not in the
product itself. If this is the case, it must be proven whether the conflict minerals
originate from the Democratic Republic of Congo (DR Congo) or its neighboring
countries.
If the above criteria are met, companies must comply with the reporting
requirements. These include the preparation of a Conflict Minerals Report for
the US SEC (Securities Exchange Commission), which provides comprehensive
information on the origin and uses of the conflict minerals.

For affected vendors it is required to create a Conflict Minerals Reporting

Index 8 Originator: MPP Quality Management Technology & Innovation

First edition: Kusche 2005-07-22 OK: Luczak, Hanno OK: May, Patrick (11/11/2020 08:45)
(11/27/2020 19:31) OK: Müller, Jochen (11/19/2020 14:35)
Updated: Ziemann, Stefan
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Materials and Substances of Content (Automotive Environment Compatibility) (EN)

Template (CMRT). The creation of the CMRT template obliges suppliers to find
out the origin of the conflict minerals (3TG) along the entire supply chain right
up to the smelter.
The most recent CMRT template at the time of the request by tk Bilstein
has to be used, the sending of older CMRT versions is not allowed. The
currently valid version of the CMRT template and further information are
available under following link: https://www.responsiblemineralsinitiative.org

Cobalt Reporting Template

The Cobalt Reporting Template is a free, standardized reporting template
developed by the Responsible Minerals Initiative to identify choke points and
collect due diligence information in the cobalt supply chain. Again, the CRT
template most recent at the time of the request by tk Bilstein must be
used, the sending of older CRT versions is not permitted. The current
version of the CRT Template and further information is available under following
link: https://www.responsiblemineralsinitiative.org

4. Drawing entry The following text must be included in the drawing:

Material und Inhaltsstoffe gemäß WNB 880

Material and substances of content according to WNB 880

Special material requirements apply to the materials mentioned in the following

table:

Use Material Lead Restricted

group content Contents by
(% by weight
weight) (% by weight)
Steel parts Steel max. 0.35
Aluminium parts Aluminium max. 0.4 max. 1.0 Bi

With regard to the lead content, the most recent version of the exemption rule in
Annex II to Directive 2000/53/EC must be observed.

5. Applicable VDA 232-101 Declarable substances; substances of content

documents and EU-RL-2000/53/EC European Directive for End-of-life Vehicles
literature GefStoffV Regulations for handling hazardous substances
REACH (EC) 1907/2006 Registration, Evaluation, Authorisation and
Restriction of Chemicals
WNB 879 Cr(VI)-free coatings on ferrous materials
TRGS 552 Technical Rules for Hazardous Substances
Dodd-Frank Act Regulations for companies dealing with conflict
minerals, Federal Law USA
DIRECTIVE (EC) 2018/851/EC Revised Waste Framework Directive (WFD)
(2008/98/EC)
California Proposition CP65 The Safe Drinking Water and Toxic Enforcement
Act

Index 8 Originator: MPP Quality Management Technology & Innovation

First edition: Kusche 2005-07-22 OK: Luczak, Hanno OK: May, Patrick (11/11/2020 08:45)
(11/27/2020 19:31) OK: Müller, Jochen (11/19/2020 14:35)
Updated: Ziemann, Stefan
Page 6 of 7 2020-11-27
 thyssenkrupp Bilstein
Materials and Substances of Content (Automotive Environment Compatibility) (EN)
Index Chapter
0 New issue
1 5
2 5
3 5
4 5
5 1 to 5
5 3
5 3.3 to 3.6
5 4
5 5
6 -
6 3
6 3.7
6 4
7 -
7 2
7 3
7 3.2
7 3.4.1
7 3.7
7 3.8
7 4
7 5
Index 8 Originator:
First edition: Kusche
Updated: Ziemann, Stefan
Page 7 of 7 2020-11-27
WNB-880-E
Change documentation
Revision
Change of the per cent by weight with the identification numbers 01 and 02 (adapted
to 2000/53/EC version of 20 September 2005)
Material identification number 03 added
Material identification number 04 added
Column title changed. "Restricted contents by weight" into "Other"
Material identification number 00, max. lead content added
Material identification number 04, "max. 1.0 Bi" added
Company standard completely revised
Statutory provisions and rules REACh regulation and TRGS 552 added,
Additional information on GefStoffV, REACh, perfluorooctanoic acid (PFOA) and
N-nitrosamines amended
Table Material requirements revised, identification number 01 and 02 cancelled
Applicable documents: REACh and TRGS 552 regulations added
Revision and transfer to BDMS
Statutory regulations and rules, Dodd-Frank Act added
New chapter on conflict minerals
Table revised, omission of use for guides and bushings of seal packs (03), omission of
identification numbers (00) and (04)
Editorial revisions
Scope updated (REACH Regulation, Waste Framework Directive (WFD) and California
Proposition CP65 included)
Legal requirements and rules Wast Framework Directive (WFD) and California
Proposition CP65 included
Substances related to the End-of-Life Vehicles Regulation, reference to a possible
expiry in year 2021 of the exemption in Annex II to Directive 2000/53/EC regarding the
lead content in aluminium added.
Chapter 3.4.1 Waste Framework Directive - Waste Framework Directive (WFD) newly
added
Chapter 3.7 California Proposition CP65 newly added
Information about the CRT / Cobalt Reporting Template newly added
Text revision in the note concerning the permitted lead content of Annex II to Directive
2000/53/EC
Applicable documents and literature Directive (EU) 2018/851/EC and California
Proposition CP65 added
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MPP Quality Management Technology & Innovation
2005-07-22 OK: Luczak, Hanno OK: May, Patrick (11/11/2020 08:45)
(11/27/2020 19:31) OK: Müller, Jochen (11/19/2020 14:35)