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Hyundai Environmental Leader Urges Suppliers to Meet June 2018 Low-Volume Chemical Reporting Deadline

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With a deadline fast approaching for registering low-volume chemical substances under the European Union REACH, Hyundai Motor Europe’s Timo Unger urged automotive suppliers to do what they could to meet the June 2018 deadline because without substance registration, the supplier cannot put the product on the European market.

Unger, Hyundai’s manager environmental affairs, gave his remarks at AIAG’s IMDS Conference on October 12, 2017 in Novi, Michigan, which was attended by several hundred automotive professionals who work in corporate responsibility capacities for their organizations.

Unger said while there are many reasons that a company may not make registration by the deadline — including cost, time, or even being unaware of its obligations — he emphasized that low-volume substances are crucial to the industry and are used as additives in numerous tiny applications. The purpose of registering the chemicals is to give legislators are better understanding of whether a substance used in production is toxic or carcinogenic, he said.

“Sometimes companies hold off registering substances because the expected cost to do it is higher than the expected income from that substance,” he said. “But if that substance is playing a high role in a specific product, and it is not registered, then we stop production. That is a worse-case scenario to be avoided at all costs.”

Unger said there is “a tsunami of substances” that need to be observed or even phased out, and that is “a huge challenge to us as an industry.”

“Automakers are relying on their suppliers down the tier to inform their customer and the next tier should alert their customer and so on, until eventually, we have total transparency, and the information reaches the OEM.”

However, Unger reminded attendees that while transparency is good, it is important that shared information be correct information. “If you’re writing letters to your supply chain, make sure you fully understand the issue, otherwise you will make a real mess,” he advised.

“Planning certainty is what we really need for our industry,” he concluded. “We are making a lot of noise about this.”

Unger also spent some time explaining to attendees about the Stockholm Convention and the difference between REACH and POPs (persistent organic pollutants), which are transferred via the food chain. Interestingly, when Unger asked how many members of the audience were familiar with POPs, very few raised their hand. POPs are found in fat cells of the polar bear, he explained.

“The EU is fully committed to effectively implementing the Stockholm Convention and its protocol on POPs,” he said.

The U.S. has not signed on yet to the Stockholm Convention POPs issue and has not ratified the convention. But POPs are a concern for doing business in dozens of countries, including many that U.S. manufacturers sell products to, so it’s important for U.S. companies to understand POPs, he said.

Summing up, Unger said progress is on track for the upcoming substance-reporting deadline. All substances for which there is sufficient information on their hazard properties have already been addressed. The focus now is on getting more data on other substances of potential concern; about 500 substances are currently under investigation for need of further regulation. About half of these substances were identified as substances of very high concern.

”It really is critical that we understand how to avoid substitution of substances because each substitution causes thousands and thousands of Euro,” he said. “It’s an economic and logistical nightmare.”

Unger said that the industry also needs to work toward a process to monitor relevant chemical regulation on a global basis. The benefits, he said, would include efficiency, harmonized activities, planning certainty, process stability, and compliant products.

Carla Kalogeridis is AIAG’s e-news editor.