Recently the consutation about the ELV Directive was closed, but it’s not over yet with giving comments on the Directive and making and explaining suggestions for improvement. We expect working groups of stakeholders will be formed and our opinions need to be repeated as often as possible.
This consultation is a good thing, but we have some points of critic. First it was hard submitting the contribution after filling in everything, as it was impossible to fill in your name and email adress. We think such a problem should not happen and we fear some contributions got lost as participants gave up. We submitted ours via mail. Then there was the way some questions were asked. It was not clear if actual situations were asked for or desired ones. This means the answers of this questions cannot contribute to statistics.
Good points are there was an escape via mail to contact the organisation behind the internet consultation and we feel the free fields will give the most valuable info to the commission. It’s hard to get consistent answers since situations vary enormously between countries, so this was a good solution.
We hope many of the points from the free fields will be elaborated during future sessions. Here’s a brief overview of our main points:
- COD’s should be provided by ATF’s only. No other collection points that cannot guarantee depollution and parts reuse should be able to hand out COD’s;
- Registration systems need to be closed systems. Deregistration should only be possible by issueing a COD. Registration should automatically be connected to the vehicle obligations (tax, MOT and insurance) as an incentive to get rid of a vehicle that’s not in use;
- Export should only be accepted if the vehicle is directly transferred to another national registration system, otherwise they are gone forever;
- Costs for materials with no or low value and transport in low density countries should come from a fund that is filled annualy with just enough money. The fund needs to be operated by an independent player. Car owners fill the fund with a small fee (a few Euro’s) every year;
- Recycling definitions should be harmonised and not vary per country;
- Recycling targets are a shared chain responsibility. It’s not the responsibility of just one shackle. National enforcement needs to explain how to organise control of the chain;
- Quantitative recycling rates should not prevale above qualitative recycling, even if qualitative recycling lowers the percentage a bit. Good techniques and necessary extra work need to be encouraged;
- Design for recycling should lead to clean recyclabe monostreams;
- Producers info should lead to better reuse. It should be available for a reasonable fee; – Single use parts should be banned as they are not sustainable. Not even for safety reasons. Accces to producers systems to activate parts must be possible for a reasonable fee;
- Governments need to set up incentives to repair vehicles with used parts like the French example.
We hope all EGARA members will continue to share their views about the ELV Directive. In itself the Directive is quite good, it’s just 19 years old and this 19 years of experience needs to be evaluated and should result in an update of the Directive. If the EC listens to the remarks from the professionals from the field, it could lead more effective legislation and an actual sustainable and circular industry.