Hazardous Substances in Vehicles (ELV)

The use of certain heavy metals in vehicles is restricted. The End-of-Life Vehicles (ELV) legislation aims to reduce waste from vehicles and make the reuse, recycling, and other recovery of end-of-life vehicles more environmentally friendly.

The Finnish Safety and Chemicals Agency (Tukes) monitors compliance with the restrictions of certain hazardous substances in vehicles placed on the market and related materials and components. “Placing on the market” refers to the first time a product is made available on the EU market.

Tukes also monitors compliance with the obligation to use coding standards for vehicle components and materials and the obligation to prepare and publish dismantling data for new vehicle types

Scope of ELV

Vehicles, their components, and materials fall within the scope of the ELV legislation.

The ELV legislation defines vehicles as:

Motor vehicles and their trailers, as well as systems, components and separate technical units intended for such vehicles (vehicles in category M1 or N1)
- Passenger cars with no more than eight seats in addition to the driver’s seat
- Motor vehicles with a total mass of not more than 3.5 tonnes
Powered three-wheel vehicles (vehicles of category L5e)
- Three-wheel vehicles weighing less than 1,000 kg powered by any of the following:
  - an internal combustion engine
  - an external combustion engine, a turbine engine or rotary combustion engine
  - a compressed air engine
  - an electric motor
  - a combination of any of the propulsion systems listed above

Examples of vehicles:

Passenger cars
Vans (weight max. 3.5 tonnes, at most driver’s seat + 8 seats)

ELV legislation does not apply to the following:

E-bikes
E-scooters

Restricted Substances

The restrictions apply to the use of the following substances in vehicles, their materials and parts:

Lead
Cadmium
Hexavalent chromium
Mercury

Allowed maximum concentrations:

Cadmium 0.01% by weight
All other substances 0.1% by weight

The maximum concentrations are the maximum permissible concentrations of the hazardous substances in homogeneous materials.

Points to note regarding the substance restrictions:
- The restriction on hazardous substances does not apply to spare parts placed on the market after 1 July 2003 which are used in vehicles placed on the market before 1 July 2003. This does not apply to wheel balancing weights, carbon brushes for electric motors or brake linings, however.

Exemptions and Labelling Requirements

The Commission permits the use of the restricted substances for certain applications. The exemptions are listed in Annex 1 to the Government Decree on End-of-Life Vehicles and Restrictions on the Use of Hazardous Substances in Vehicles (123/2015). Annex 1 also sets out when such materials and parts must be labelled or otherwise made identifiable.

Examples of labelling requirements for lead:

Materials and components	Scope and expiry date of the exception	To be labelled or made otherwise identifiable
Lead in batteries in high-voltage systems that are used only for propulsion in M1 and N1 vehicles	Vehicles type-approved before 1 January 2019 and spare parts for these vehicles
Lead in batteries for battery applications not included in the above paragraph	n/a
Vibration dampers	Vehicles type-approved before 1 January 2016 and spare parts for these vehicles

Coding Standards and Dismantling Information

Producers as well as material and equipment manufacturers must use the coding standards specified below to label vehicle components and materials. The coding standards facilitate the identification of vehicle components and materials suitable for reuse and recovery.

“Producer” refers to the manufacturer, the importer or the party that delivers vehicles to Finland on behalf of a Finnish user. “Importer” refers to a natural or legal person who places the product on the market in the EU.

Coding Standards

1. The labelling and identification according to the standard for components and materials weighing more than 100 grams:

ISO 1043-1 Plastics — Symbols and abbreviated terms Part 1: Basic polymers and their special characteristics
ISO 1043-2 Plastics — Symbols and abbreviated terms. Part 2: Fillers and reinforcing materials
ISO 11469 Plastics — Generic identification and marking of plastics products

2. Labelling and identification according to the standard for elastomer components and materials having a weight of more than 200 grams:

ISO 1629 Rubber and latices — Nomenclature. However, this nomenclature does not apply to the labelling of tyres

Producer’s Duties with Regard to Dismantling Data

A producer must prepare and publish the dismantling information for each type of new vehicle within six months after the vehicle was placed on the market for the first time.
The producer must make the dismantling information available to the pretreatment facility in the form of manuals or by means of electronic media. The information must identify the vehicle components and materials, and the location of all hazardous substances in the vehicle.
The producer must make available to pretreatment facilities information concerning the dismantling, storage and testing of components which can be re-used. The obligation does not, however, apply to information covered by commercial or industrial confidentiality.

Extended Producer Responsibility

Extended producer responsibility applies to end-of-life vehicles. It means that the manufacturers, importers, distance sellers and packagers of products are responsible for arranging waste management for their products and for the associated costs. Matters related to extended producer responsibility in Finland have been centralised under the supervision of the Centre for Economic Development, Transport and the Environment in Pirkanmaa (PIR-ELY).