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Product safety and toxicology

Compliance of steels with EoL Directive 2000/53/EC and with automotive industry requirements

Directive 2000/53/EC requires that  vehicles placed on the market after 1 July 2003 contain no lead, cadmium, mercury or hexavalent chromium, other than in the cases listed in its Annex 2.

It also requires the identification of other dangerous substances (as defined in Directive 67/548/EEC1 and Regulation (EC) No. 1272/2008* and Regulation (EC) No. 1272/2008**) that may be used in the manufacture of vehicles. The amendment of Annex 2 of the Directive, published on 20 September 2005 (Council Decision 2005/673/EC), set 1 July 2007 as the date for a comprehensive ban on the use of hexavalent chromium.

In addition, tolerance thresholds were set for these substances:

  • 0.1% (1,000 ppm) for lead, mercury and hexavalent chromium
  • 0.01% (100 ppm) for cadmium.

Consequently, there is a twofold requirement:

  • Guarantee of compliance of the steel with the Directive, with provision of information on any use of prohibited substances or metals in our products and timetable for implementation of the heavy metal prohibition in the products involved;
  • Provision of information on the composition of our steels, in particular by reporting such information in databases such as IMDS.

* Council Directive 67/548/EEC of 27 June 1967 on the approximation of laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances. The  classification of dangerous substances can be accessed via

** Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008 on classification, labeling and packaging of substances and mixtures, amending and repealing Directives 67/548/EEC and 1999/45/EC, and amending Regulation (EC) No 1907/2006

Characteristics of steels supplied to the automotive sector and their compliance with regulations

Composition of steels

The steels supplied to the automotive sector are often complex, multi-layer products, made up of a substrate with a zinc and/or aluminum based alloy coating, with one or more subsequent surface treatments.


The chemical composition of steel varies from one grade to another. Generally the total concentration of alloying elements does not exceed 3%. The maximum concentration per element may be up to 3% (certain VHS steels contain more than 2% manganese, for example). The most frequently used alloying elements are carbon, manganese, silicon, phosphorous, sulphur, niobium, aluminum, boron, chromium, vanadium, molybdenum and titanium.

Trace lead in steel substrates is not due to deliberate additions during production, but rather to the fact that current processes do not fully eliminate trace elements from raw materials and recycled materials.

Metal coatings

These coatings are obtained either by continuous hot-dip galvanization or by electrodeposition.

Trace lead and cadmium in coatings (dissolved in the metal lattice) are not due to deliberate additions during production, but rather to the fact that current processes do not fully eliminate trace elements from raw materials and recycled materials.

The sum of lead (Pb) and cadmium (Cd) content in spangle-free coating is less than 100 ppm and mercury (Hg) is not detectable.

Surface treatments:


ArcelorMittal has introduced Cr(VI)-free passivation (E-Passivation®), in line with legislation.


This treatment (42% phosphate, 35% Zn, 5% Mn, 1% Ni) complies with regulations.

Thin organic coatings (TOCs)

ArcelorMittal now offers a range of thin organic coatings over hexavalent chromium-free pre-treatment.

Development of environmentally-friendly products

ArcelorMittal has implemented a Cr(VI)-free substitution programme, offering Cr(VI)-free solutions for its entire range of products, including sandwich sheet, in accordance with the timetable set by the Directive and/or vehicle manufacturers' decisions.

Communication of information relating to the composition of steel products

Since 2002, the composition of steels supplied to the automotive sector has been available in the IMDS data base.

ArcelorMittal's steels are reported under their commercial name, with a layer by layer description and ID number.

ArcelorMittal's identification number in IMDS is 5502.

We also work with manufacturers who have not joined the IMDS system.

Certification and reporting of dangerous substances

The ArcelorMittal Technology - Health and Safety - Product Safety Department is responsible for the certification procedure.

The risks that might arise during secondary processing of steels are set out in the Safety Data Sheets (SDSs), which may be downloaded from website under ‘Products & Services > MSDS (Material Safety Data Sheets)'.

Compliance with the REACH Regulation EC 1907/2006

ArcelorMittal is implementing the various aspects of the REACH Regulation according to the regulatory timeframe. In particular, we are making every effort to ensure that the use of our products by our clients is correctly assessed and that all substances present in the products delivered to our clients have been properly registered. Steel coils, slit bands, sheets, blanks and their derivatives are to be considered as articles in the sense of the REACH reglementation. The selection process of substances to be included in the Candidate List of Substances of Very High Concern or in REACH Annex XIV is carefully monitored. We are committed to informing our clients about the presence of any such substances in our products, as provided for in this Regulation. Our Safety Data Sheets have been adapted to the new requirements laid down by REACH and the new CLP (Classification Labelling and Packaging) directive. Further updates may be made as additional information becomes available.

If you have any questions on product safety and toxicology, please ask your usual contact or send an e-mail to:

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