Lead in Onboard Electronics Could Force Large-Scale Automotive Recall

Lead in Onboard Electronics Could Force Large-Scale Automotive Recall

What would be the impact if every bread maker in the world had accidentally baked an ingredient into their products that, although not harmful, made them unsaleable? What if that bread were already in cupboards around the globe? This is the conundrum facing the world’s largest car makers.

Over the past weekend, German suppliers Continental and Bosch — who sell into the largest car manufacturers in the world — admitted that a line of capacitor-outfitted circuit boards marketed as “lead-free” are actually .0003 grams per component above the limit outlined by the European Union (EU) End-of-Life Vehicles (ELV) Directive. As such, it’s speculated that the majority of vehicles on the road today may not be compliant with EU market requirements. 

The components, which were purchased from an electronics supplier in China, can be found in the vehicles of most global car manufacturers. The EU ELV Directive requires automotive companies to limit lead exposure to 1,000 ppm (0.1 weight percentage) at the homogeneous level. Although the exceedance is not considered dangerous to either human health or the environment in this use case, it could expose workers to harm when dismantling vehicles for recycling or recovery of parts. For this reason, the situation could lead to mass recalls and approval delays on new car models.


Leverage Assent’s Product Compliance Suite to acquire data on a broad range of substances regulated in the automotive industry.


Impact on the Automotive Industry

The case shows that no company is immune to risk; both Continental and Bosch maintain high sustainability and supplier standards. Though they discovered the exceedance and reported it to authorities appropriately, more robust due diligence surrounding declarations, testing documentation, and overall age and quality of data for high-risk parts and suppliers could have mitigated a great deal of liability. Companies should be able to identify restricted substances in their supply chains proactively in order to find compliant alternatives prior to manufacture. 

As it stands, both companies (and other manufacturers) may need to implement costly measures related to inventory control, product recall, downstream communication to customers and increased scrutiny from enforcement bodies such as the Federal Motor Transport Authority. 

Assent’s End-of-Life Vehicles solution can help you get an early start by surveying your suppliers for substance concentrations restricted by the EU ELV Directive. Companies with a broad regulatory scope can leverage our GADSL Module to acquire a wide range of automotive-specific substance data. Additionally, our Full Material Disclosure Module can acquire the full composition of your products, so you know if they contain hazardous substances above the regulated threshold for any other regulatory, industry or customer-specific restriction list. 

For more information about how Assent can help you maintain market access and avoid product recalls, contact our experts at info@assentcompliance.com.

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