The EC announced a consultation on the evaluation of the Waste Shipment Evaluation (WSR). The Regulation No 1418/2007 is also taken into account. How does waste legislation affect car dismantling? Because in some cases our parts are considered waste which means exporting them leads to seizure of shipments and big fines. Under the right conditions export of used parts is possible.
As the consultation is public, anyone can respond. Most important reason for EGARA to contribute is to get and to stay involved in everything that is decided about this matter.
Some of us export parts abroad. We need to get out all positive value of our ELV’s. Parts that would otherwise not be reused here, keep cars on the road for an affordable price abroad. So far so good.
The problem starts when officials (customs, environmental inspection, road inspection) suspect our shipment to be waste. Of course our used parts do not look brandnew, but when dismantled carefully, loaded carefully and registrated carefully, the shipment and transport/transit should go smoothly. In some cases individual officials lack knowledge. These cases are the rather easy ones to tackle. In some cases parts are broken, or dismantled in a sloppy way, including halfcuts, meaning they contain remains of other broken parts. Parts should be ready for reuse directly.
The biggest problem is where countries that our parts route through, have their own opinion of the waste status of parts. They concider used parts only as goods when mounted and functioning in their second life on a car. This is very counter productive to any circular economic or sustainable principle. Your container will be blocked and sent back. Of course this is also a matter of applying the Waste Frame Regulation, but we have now the opportunity to explain how this contradicts with the WSR.
It’s only logical that rules exist to avoid environmental damage by letting waste, including ELV’s disappear from enforcement by exporting it. But these rules should not be counter productive.
EGARA’s point of view is:
– If implemented and carried out right, the WSR and Regulation 1418/2007 have a positive effect on our industry. Point is in many cases they are not enforced at all or interpreted in a very rigid way, counter productive for parts reuse (no export or transit possible).
– Used parts trade should be possible at all times. Even prepared large bodyparts should be salable. No problem if conditions are reasonable and logic.
– ELV’s should be processed in the country of origin and at least traceable. They should not be dumped elsewhere, disappearing in the black market or left abandoned. There’s enough capacity in every country.
– Rules should not be countrer productive and make reuse impossible (wrong/rigid interpretation) or very expensive/complicated (procedures).
- – Guidelines should be clear and reasonable. Some expertise at the enforcement is demanded.
- – We (as dismantlers) should not want to ship broken parts, sloppy dismantled parts or sloppy loaded containers. We ship plug and play used parts and not waste.EGARA-Secretariat
c/o STIBA Pompmolenlaan 10, NL3447 GK Woerden The Netherlands Tel: +31 88-5011090 e-mail: email@example.com
Consultation on Waste shipment regulation
With these principles in mind, we filled in the consultation. The consultation is open from January, 30th to April, 27th. It can be found here: https://ec.europa.eu/eusurvey/runner/WasteShipmentReg