**Note to Ms. Rosalinde van der Vlies, DG Environment**

**concerning**

**Calculation of reuse and recovery rates**

**relative to the WD for the meeting of**

**Committee for the Adaptation to Scientific and Technical Progress**

**of 15. January 2003**

# 1. Introduction

Having studied the above document and the relevant Ökopol document, EGARA, the European Group of Automotive Recycling Associations, comprising vehicle dismantlers in: Austria, Denmark, Finland, France, Ireland, Netherlands, Norway, Poland, Spain, Sweden, Switzerland and the UK wishes to express the following observations concerning the idea of monitoring reuse and recycling as well as the proposal contained in the working document:

- we fully understand and support the need for common calculation methods across Member States
- in satisfying this need however, it is essential to define methods that reflect the way dismantlers work with de-pollution of ELVs and dismantling for reuse and recovery
- these methods must put the least possible burden on the dismantlers and as far as is possible, be based on figures already present at dismantlers and as such impose very little additional administrative work on the dismantlers, while at the same time, however, giving Member States and the Commission the required figures as accurately as possible.

EGARA finds that the method described below satisfies these conditions and strongly recommends that the Commission and the Committee take this method into consideration. The main advantage of this model is that there is no specific need for taking the weight of spare parts stored at the dismantlers, a work that in practice would be cumbersome and require additional work.

**The processes taking place at the dismantlers.**

In practice, the processes taking place at a certified dismantler are the following:

- Recording of the vehicle, including the weight according to the registration

document.

The number of ELVs is called M, the total weight of the ELVs is called W_{M.}

- De-pollution and dismantling for recycling. ELVs are de-polluted according to the Directive, and all fluids etc. are stored in appropriate containers, which are later handed over to authorised receivers of such waste fractions, i.e. coolant, oils, brake-fluid etc. and these collectors then communicate the total weights of these fluids received.

Following de-pollution, parts and components for recycling, i.e. catalysts, batteries, oil-filters etc., are dismantled. Here also, the collectors of such parts for recycling, communicate the weights of the components and parts received.

All fluids and/or parts and components for recycling, are now referred to as W_{WF1} – W_{WFn, } , and the sum of them as W_{WF-SUM}.

- Dismantling for landfill, destruction or incineration. Certain fluids, components and other materials do not yet qualify for recycling, but have to be delivered for landfill, destruction or incineration. Here also, the weights of such items are communicated to the dismantler by the collectors or given to the dismantler in the case where he delivers it himself.

Such materials are referred to as W_{LF1} – W_{LFn} and the sum of these as: W_{LF_SUM}.

- Dismantling of parts and components for re-use. Additionally, dismantling of parts and components for re-use takes place. After inspection, these are stored at the dismantlers. The weight of these parts is referred to as W
_{RU }– a figure that can be derived, as shown below. - Carcasses to shredder. After de-pollution, dismantling for recycling, dismantling for landfill etc. and dismantling for re-use, the “carcasses” of the ELVs are now handed over to shredders. The total weight of the carcasses is communicated to the dismantler by the shredder – at loading – whereas the dismantler himself keeps track of the number of carcasses handled. The total weight of carcasses is referred to as S
_{W.} - Weight of spare parts and components for re-use can now be calculated, based on the above mentioned figures
**which all exist at the dismantlers’.**Hence there is no specific need for measuring the weights of the spare parts put into stock – it can be calculated as: W_{M}– (S_{W}+ W_{WF-SUM}+ W_{LF-SUM}). - Similarly, the total weight of materials for re-use
**and recycling**,*at the dismantlers,*can be calculated as: W_{RU}+ W_{WF-SUM.}

**Advantages of the above model**

As can clearly be seen from the above, this calculation model follows the normal processes at the dismantlers, and in practice, the figures mentioned are all given to dismantlers automatically. In most Member States, there are even legal requirements to give them and dismantlers have to use them in their annual environment reports. Therefore, they do not impose any additional administrative work on the dismantlers.

We would strongly resist any methods which impose additional monitoring and additional work, and we would further argue, that if one would even consider – theoretically – to take the weights of components spare parts put on stock for re-use, such weights would be incorrect, unless one would force the dismantlers to use standardised and calibrated weighting tools – a requirement that would be impossible to satisfy in practice.

Therefore, the method proposed here by EGARA would give the best data one could achieve in practice, without imposing too much additional work and subsequent additional costs.

In our opinion, it also gives Member States and the Commission sufficient data to monitor the development in reuse and recycling figures, which, as we see it, is the most important issue.

Further, all relevant average figures can easily be calculated, as can be seen in the annex.

EGARA

2003.01.08

Annex:

**DEFINITIONS AND EXPLANATIONS**

** **

**Definition Formula/data acquisition**

** **

M : No. of ELVs received: Counted by dismantler

W_{M}: Weight of ELVs received Taken from registration doc.

W_{M-AVE}: Average weight of ELVs received W_{M }/ M

S : No. of de-polluted ”carcasses” delivered Counted by dismantler

to shredder

S_{W} : Weight of ”carcasses” delivered to shredder Figure given by shredder

on loading of carcasses

S_{W-AVE:} Average weight of carcasses delivered

to shredder S_{W} / S

W_{wF1} –W_{WFn}: Weight of waste fractions delivered for

recycling Figures given by collectors

of waste fractions for recycling

W_{WF-SUM} Total weight of waste fractions for recycling ∑ (W_{WF1 –}W_{ WFn})

W_{LF1}-W_{LFn}: Weight of waste fractions delivered to

landfill, destruction or burning/incineration Figures given by collectors

of waste fractions for landfill, etc.

W_{LF-SUM:} Total weight of waste fractions for landfill etc. ∑ (W_{LF1 –}W_{ LFn})

W_{RU} Weight for reuse W_{M} – (S_{W} + W_{WF-SUM} + W_{LF-SUM})

W_{RU-AVE} Average weight of spare parts for re-use W_{RU}

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