Group standard VW 91102

Issue 2022-02
Class. No.: 97000, 97410

Descriptors: environmental standard, recyclability, recycling, recycling requirements, use of recycled material, vehicle

Environmental Standard for Vehicles

Recycling Requirements, Use of Recycled Material, Recyclability Type
Approval

Preface
The purpose of the Environmental Standard for Vehicles is to provide instructions with regard to
environmental compatibility of vehicles in order to ensure health protection, minimize environmen-
tal impact, and save resources regarding:
– Obtain the recyclability system approval in the type approval
– Fulfill the recoverability rates required by law
– Reduce the amount of waste to be disposed of and the pollutant load to the levels required by
law
– Conserve energy and material resources and to increase the proportion of recycled material
in the vehicle
The requirements of EC Directive 2000/53/EC [1], EC Directive 2005/64/EC [2], and United Na-
tions Economic Commission for Europe Regulation No. 133 (UN ECE R133) [3] are limited to vehi-
cle classes M1 and N1.
This description of the scope of application does not exempt the user of this standard from the obli-
gation to inform themselves of additional laws outside the EU, country-specific legislation within the
EU, and the national implementations of the EU Directives specified in this standard, nor from the
obligation to implement them as required for the target markets for the relevant vehicles and their
components.
Standards do not limit the applicability of legal regulations in any way whatsoever. Before stand-
ards are applied, all applicable legal regulations must be checked and their currently valid versions
applied.
The environmental goals and specifications of the brands must always be implemented.

Previous issues
VW 91102: 1994-02, 1996-03, 2002-09, 2007-02, 2012-03, 2017-02, 2018-01

Always use the latest version of this standard.

This electronically generated standard is authentic and valid without signature. A comma is used as the decimal sign. Page 1 of 9
The English translation is believed to be accurate. In case of discrepancies, the German version controls.

All rights reserved. No part of this document may be provided to third parties or reproduced without the prior consent
of one of the Volkswagen Group’s Standards departments. | internal
© Volkswagen Aktiengesellschaft VWNORM-2021-11
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VW 91102: 2022-02

Changes
The following changes have been made to VW 91102: 2018-01:
a) Standard completely revised

Contents
Page
1 Scope ......................................................................................................................... 2
2 Definitions .................................................................................................................. 2
3 Abbreviations ............................................................................................................. 3
4 Requirements ............................................................................................................. 4
4.1 Recyclability and material documentation .................................................................. 4
4.2 Materials restrictions .................................................................................................. 4
4.3 Removal requirements ............................................................................................... 4
4.4 Design for post shredder technology ......................................................................... 5
4.5 Recovery strategies ................................................................................................... 6
4.6 Marking of materials ................................................................................................... 6
4.7 Use of recycled material ............................................................................................. 6
4.8 Components considered not reusable when manufacturing new vehicles ................ 7
4.9 Reporting obligations for electronic components ....................................................... 7
4.10 Reporting obligations for portable batteries and rechargeable portable batteries ...... 7
5 Applicable documents ................................................................................................ 8
6 Bibliography ............................................................................................................... 8

1 Scope
The specifications in Volkswagen standard VW 91102 apply to
– Vehicle design that is suitable for recovery purposes so as to comply with Directive
2000/53/EC [1]
– The reusability, recyclability, and recoverability of motor vehicles within the scope of type ap-
provals as per Directive 2005/64/EC [2] and Directive 2009/1/EC [4], as well as per
UN ECE R133 [3]
– All materials and substances used in the vehicle, in vehicle parts, and powertrains
– Fuels, coolants, fluids, and lubricants used during the use, repair, and maintenance of the ve-
hicle
– The ban on the use of used parts in new vehicles as per Directive 2005/64/EC [2]
– The registration, marking, reporting, return acceptance, and recycling obligations as a distrib-
utor of electrical/electronic equipment that result from Directive 2012/19/EC [5] and its nation-
al implementations
– The registration, marking, reporting, return acceptance, and recycling obligations as a distrib-
utor of batteries that result from Directive 2006/66/EC [6] and Directive 2013/56/EC [7], as
well as their national implementations

2 Definitions
B-release Procurement release in the Product Emergence Process (PEP)
Battery or rechargeable battery A source of electric power that consists of one or more (non-re-
chargeable) primary cells or one or more (rechargeable) secondary cells,
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where the electric power is generated from the direct conversion of chemi-
cal energy.
Electrical and electronic equipment Equipment that depends on electric currents or electromag-
netic fields in order to work correctly and equipment that is designed to
generate, transmit, and measure such currents and fields and is designed
for operation with a maximum voltage of 1 000 VAC or 1 500 VDC
End-of-life vehicle Vehicles that are considered waste as per article 3, paragraph 1 of Direc-
tive 2008/98/EC [8].
Energy recovery Use of materials for direct energy recovery, excluding thermal treatment
with the main objective of disposal of pollutants
Industrial batteries and rechargeable industrial batteries Batteries intended exclusively for electric
vehicles of any type (e.g., high-voltage battery packs)
Material recovery/recycling The reprocessing of waste materials in a production process for their
original purpose or for other purposes (utilizing the material's properties,
raw material recovery). This does not include energy recovery.
Pollutant elimination Removal of components that contain pollutants
Portable batteries and rechargeable portable batteries Batteries, button cells, battery sets that a)
are encapsulated, b) can be held in the hands, and c) are not industrial bat-
teries, rechargeable industrial batteries, vehicle batteries, or rechargeable
vehicle batteries
Recoverability Recoverability rate for new vehicles calculated as per ISO 22628:2002
Recoverability rate The Recoverability rate (RcovR) is the sum of the recycling rate and the
rate of the energy recovery
Mass of recovered material and energy
(RcovR = ).
Total mass
Recyclability Recycling rate for new vehicles calculated as per ISO 22628:2002
Recycled material Secondary raw materials that are produced by recovery of waste materials
before use (production waste) or after use
Recycling rate Recycled mass
RcycR =
Total mass
Reuse Reuse of components for their original purpose with or without reprocess-
ing.
Vehicle batteries or rechargeable vehicle batteries Batteries for a vehicle's starter, lighting, or ig-
nition system
Vehicle class M1 Vehicles for transporting passengers that have a maximum of eight seats
aside from the driver seat
Vehicle class N1 Vehicles for transporting goods that have a maximum weight of up to
3,5 metric tons

3 Abbreviations
ABS Acrylonitrile-butadiene styrene
CFRP Carbon-fiber-reinforced plastic
EOP End of Production
EOS End of Service
IMDS International Material Data System (internet-based system used to enter
material data)
MISS Material Information Sheet System (Volkswagen intranet-based system for
entering and evaluating material data)
PA6 Polyamide 6
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PA66 Polyamide 66
PE Polyethylene
PET Polyethylene terephtalate
PP polypropylene
PUR polyurethane
PVC Polyvinyl chloride
SOP Start of production
TLD Technical Guideline for Documentation

4 Requirements

4.1 Recyclability and material documentation

As per Directive 2005/64/EC [2] and UN ECE R133 [3], a recyclability rate of at least 85% and a
recoverability rate of at least 95% must be demonstrated during the type approval process (calcu-
lation method as per ISO 22628:2002).
In order to be able to determine these rates, masses and material specifications for all components
must be entered into the systems by B-release (see VW 99000, „Material requirements“ section).

4.2 Materials restrictions

As per Directive 2000/53/EC (article 4, paragraph 2) [1], vehicle materials and components must
not contain any lead, mercury, cadmium, or hexavalent chromium, except for the cases specified in
Annex II of the Directive.
Specific components must be marked as per Annex II and removed during the vehicle recovery
process. These components must be easy to remove.
Annex II of Directive 2000/53/EC [1] is revised on a regular basis so as to conform to scientific and
technical advances. The latest version must always be used for this reason.
Information on additional banned or declarable substances can be found in VW 91101 and the
GADSL „Global Automotive Declarable Substance List“.

4.3 Removal requirements

Pursuant to Directive 2000/53/EC (Annex I and Annex II) [1] and Directive 2006/66/EC [6], all fuels,
coolants, fluids, and lubricants and certain components/assemblies must be removed during the
vehicle recovery process.
The pertinent components/assemblies must be easy to remove. Moreover, it must be possible to
easily remove portable batteries, as well as all fuels, coolants, fluids, and lubricants, from compo-
nents. Having to use multiple removal tools for the same component or module must be avoided.
As per Annex I of the aforementioned Directive, the following parts must be removed during the
vehicle recovery process:
– Batteries (applies to all batteries in the vehicle and its components) and LP-gas tanks
– Potentially explosive components (e.g., airbags, seat belt pretensioners, pyrotechnical high-
voltage battery disconnect unit). As an alternative to removal, these components may be neu-
tralized.
– Catalytic converters
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– Metal components containing copper, aluminum, or magnesium, if these metals are not sepa-
rated during shredding
– Tires and large plastic components (bumpers, dashboards, fluid containers, etc.) if the re-
spective materials are not separated during shredding in such a way that they can be recy-
cled as raw materials
– Glass, if it is not separated and recycled downstream of shredding
Pursuant Annex I of the aforementioned Directive, the following fluids must be removed during the
vehicle recovery process:
– Fuel, engine oil, power-transmitting fluid, transmission fluid, hydraulic fluid, coolant, antifreeze
agents, brake fluid, air conditioning system fluids, and any other fluids in end-of-life vehicles
must be removed and separately collected and stored unless the fluids are required in order
to reuse the respective components.
The removal of fuels, coolants, fluids, and lubricants must be considered when designing parts and
components that carry them. In order to minimize remaining fluid volumes and the resources re-
quired in order to handle fluids, the following measures must be taken:
– As far as possible, draining options (drain plugs, points for puncturing the component, etc.)
must be designed at the lowest point of the component. If necessary, multiple points for punc-
turing the component must be defined.
– Draining options must be accessible with little effort.
– Points for puncturing the component must be marked on the component.
The parts marked as per the latest version of Annex II of the aforementioned Directive must be re-
moved as per the pertinent specifications in the national implementations.

4.4 Design for post shredder technology

These measures are intended to improve materials separation during/after shredding and hence
recyclability, especially of plastics from shredded material.
1. Basic information
– Avoiding inseparable composite materials
– Testing the use of mechanical connections
– Promoting the use of recycling-compatible materials
– Promoting the use of single-type materials or a select number of materials to allow for eco-
nomically feasible recycling
2. Recommendation of specific materials
– Using thermoplastics instead of hard-to-recycle thermosets
– Replacing PUR semi-rigid foam with, e.g., PET or PE nonwoven
– Replacing elastomers
– Promoting the use of the most common polymers:
– PP
– Filled PP (up to 20%, accounting for standardized fillers in the assembly)
– PET
– PA66 and PA6
– ABS
– In the case of composite materials, promoting the use of materials with similar properties
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– Avoiding multi-layer laminated films/materials that are not single-type materials and not com-
patible/separable (e.g., headliners and soft-touch materials as in armrests and door waist
rails). Films must be made of the same polymer as the substrate plastic wherever possible
– Avoiding PVC
– Avoiding CFRP in series production of large scale if it is not necessary to use it based on
structural/technological reasons
– Avoiding electroplated and painted materials
– Avoiding the use of biodegradable plastics (e.g., based on PE) that contaminate thermoplastic
polymers in recycling

4.5 Recovery strategies

On request by the part owner, a recovery strategy must be presented for materials or parts for
which no established recovery methods exist or no information on possible recovery methods is
available.
A recovery strategy is required, e.g., for:
– New material or part strategies (e.g., permanent magnets in drive motors, fuel cells)
– Use of CFRP
– Use of renewable raw materials such as hemp fiber
Notes on how to prepare a recovery strategy can be found in VW 91102, Supplement 3.

4.6 Marking of materials

Given the fact that components and materials must be marked as per Directive 2003/138/EC [9]
and 2005/64/EC [2], all components made of polymers or elastomers (including textiles) must have
material markings as follows:
– Polymers as per ISO 11469 in the arrow symbols with codes as per ISO 1043-1 and
ISO 1043-2
– Elastomers with codes as per ISO 1629, written in the arrow symbols as per ISO 11469
Electronic components that fall within the scope of Directive 2012/19/EC [5] must have the legally
required marking (VW 10500).
Batteries and rechargeable batteries must be marked as per Directive 2006/66/EC [6] and Direc-
tive 2013/56/EC [7], as well as DIN EN 61429 and SAE J2936 (crossed-out trash can, international
recycling symbol ISO 7000-1135 and the chemical symbol) (VW 10500).
Additional country-specific requirements for marking of components and materials must be ad-
hered to for the particular target markets.

4.7 Use of recycled material

The contractor must favor the use of recycled materials or materials with recycled material content
if technically suitable.
The use of recycled materials, including type and quantity information, must be documented in
IMDS/MISS under "Ingredients" („Recycled material“ category). The recycled material content must
be based on the material as a whole (e.g., polymer with filler: PP-GF30 can contain a maximum of
70% recycled material if the glass fiber is new material).
The following are prerequisites for the use of recycled material:
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– Adherence to the corresponding component- and material-related quality specifications

– Sufficient availability for series production (SOP to EOP or EOS)
The use of recycled material for safety-relevant (mandatory TLD) components requires the appro-
val of both the appropriate Development department and Materials Engineering.
Note on thermoplastics: Definitions and use notes as per VW 50026

4.8 Components considered not reusable when manufacturing new vehicles

As per Directive 2005/64/EC [2] and UN ECE R133 (Annex 6) [3], certain components in vehicles
of class M1 and N1 must not be reused in the manufacture of new vehicles in order for a type ap-
proval to be granted.
This applies to the following components:
– All airbag modules including airbags, pyrotechnic actuators, electronic control units, and sen-
sors; steering wheels with airbag
– Automatic and non-automatic seat belt systems, including webbing, buckles, seat belt preten-
sioners, pyrotechnic actuators
– Seats (only in cases where seat belt anchorages and/or airbags are incorporated in the seat)
– Steering lock assemblies acting on the steering column
– Immobilizers, including transponders and electronic control units
– Exhaust gas treatment systems (e.g., catalytic converters, particulate filters)
– Mufflers.

4.9 Reporting obligations for electronic components

Companies that market electrical and electronic equipment are obligated, as per Directive
2012/19/EC [5], to mark, register, report, and take back the quantities of electrical and electronic
components marketed. Data from the Engineering Data Management System (KVS) are used for
the annual report.
Thus the contractor must check and indicate whether the Directive is applicable to the compo-
nents. The part owner must indicate all components to which the guideline applies using a selec-
tion box in the KVS and mark them with the crossed-out trash can symbol by the B-release at the
latest. The marking obligation is described in VW 10500.

4.10 Reporting obligations for portable batteries and rechargeable portable batteries
Pursuant to Directive 2006/66/EC[6], companies are obligated to mark, register, report, and take
back the quantities of portable batteries marketed. Data from the Engineering Data Management
System (KVS) are used for the annual report.
Thus the contractor must check and indicate whether the Directive is applicable to the compo-
nents. Using a selection box in the KVS, the part owner must indicate components that contain
portable batteries or rechargeable portable batteries and mark them with the crossed-out trash can
symbol by the B-release at the latest. The marking obligation is described in VW 10500.
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5 Applicable documents
The following documents cited in the standard are required for the application of this standard:
Some of the cited documents are translations from the German original. The translations of Ger-
man terms in such documents may differ from those used in this standard, resulting in terminologi-
cal inconsistency.
Standards whose titles are given in German may be available only in German. Editions in other
languages may be available from the institution issuing the standard.

VW 10500 Company Designation, Marking of Parts; Guidelines for Use

VW 91101 Environmental Standard for Articles; Material and Chemical Conformity
VW 91102, Environmental Standard for Vehicles; Requirements for Recovery Strat-
Supplement 3 egies
VW 99000 Overall Requirements for the Performance of Component Development
Contracts
DIN EN 61429 Marking of secondary cells and batteries with the international recycling
symbol ISO 7000-1135
GADSL Global Automotive Declarable Substance List
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
ISO 1629 Rubber and latices - Nomenclature
ISO 22628 Road vehicles - Recyclability and recoverability - Calculation method
ISO 7000-1135 General Symbol for Recovery/Recyclable
SAE J2936 SAE Electrical Energy Storage Device Labeling Recommended Practice
VW 50026 Granular Material for Components Made From Thermoplastics and Ther-
moplastic Elastomers; Classification and Basic Principles of Use

6 Bibliography
[1] Directive 2000/53/EC „End-of Life Vehicles“
[2] Directive 2005/64/EC „Type-Approval of Motor Vehicles with Regard to Their Reusability,
Recyclability and Recoverability“
[3] UN ECE R133 „Uniform Provisions Concerning the Approval of Motor Vehicles with Re-
gard to Their Reusability, Recyclability and Recoverability“
[4] Directive 2009/1/EC „Amending Directive 2005/64/EC“
[5] Directive 2012/19/EC „Waste Electrical and Electronic Equipment“
[6] Directive 2006/66/EC „Batteries and Accumulators and Waste Batteries and Accumula-
tors“
[7] Directive 2013/56/EC „Amending Directive 2006/66/EC“
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[8] Directive 2008/98/EC „EU Waste Directive“

[9] Directive 2003/138/EC „Establishing Component and Material Coding Standards“