EGARA called her members to join consultations more than once. We see consultations as the opportunity to make ourselves heard. The EC is open for comments and plans to evaluate and improve legislation of all kinds. As we are dismantlers, we are to only ones to state what’s good for us and how we can help, guarantee or mention conditions for reaching targets and fulfilling obligations. Consultations can lead to effective laws.
Last 26th October the public internet consultation ended. We know many of our members contributed and so did we as EGARA. For this we had planned a single-item-only-meeting to inform each other, discuss some complex matter and encourage all to participate. Especially during corona time, we experienced these short meetings worked out great to discuss a topic and to have some contact with each other. We will continue with these between spring and fall meetings and if necessary as often as special items come along.
Interesting to see are the topics in the consultation. Questions are about a merge between the Type Approval Directive and the ELV Directive. This might imply that design for recycling will get a much more important role as design and recycling targets are in the same law, rather than divided. EPR was a main point. As we do not have the illusion that producers will pay anything in the phase of dismantling and recycling, we do believe that they play an important role in making cars circular. A percentage recycled material content would mean a market for materials that now have no value as virgin material is preferred and cheap. Let’s wait and see what comes out.
As export is an open wound an any registration system, we favour to have the national systems connect in whatever way. Cars should not be registered in 2 systems at the same time, but also cars should not be gone until they reappear or stay lost forever. This is directly linked to definitions of both ELV and dismantling and the distinction between car and ELV. EGARA is working on a brief survey of national definitions to see if some useful and simple definitions can be distilled. We are of opinion that ELV’s should be treated in one company and in the country where the car becomes an ELV. We do not favour export of ELV’s. Not as ELV’s and certainly not disguised as cars. Not within the EU and not abroad. That said, export of cars should not be limited. But we need good workable definitions.
The reuse target is a real point of discussion. Parts reuse is market driven. Dismantlers will sell any parts the market asks for (and if available). But it would be a good thing if no other operators can hand out CODs and dismantlers will be the first step in recycling. An ELV should be complete. Also the manufacturer has a responsibility as they need to give access to their information and digital procedures. Parts reuse is encouraged if we know in what cars our parts can be used and if parts are not digitally locked.
Batteries is still another hot topic. Ownership is a point of discussion and as long as traction batteries are costly to recycle, storage and transport are costly as well. It wouldn’t hurt if a fund is created to cover these costs. We should be able to sell batteries for reuse for the same purpose to professional customers without any limitation. Hidden batteries are a risk as well. If not dismantled, they may cause fires during storage of hulks or in the shredder. We need info (if via IDIS it should not be 6 clicks under the surface) where they are hidden.
Other vehicle types was another topic. In many countries already rules exist for ATFs that dismantle trucks/buses and motorcycles/scooters. Including them in the Directive (or regulation, whatever it will be) could be a good thing to keep these vehicles from illegals. Reuse targets might be about the same, but material amounts will be different and for instance selling motorcycle parts is a specialism just as selling car parts is. Trucks are big. So big, that it’s not wise to oblige any ATF to accept them. Truck ATFs are a kind of their own. Another characteristic of trucks is that parts sales are even bigger than with cars. And trucks have often installations on them that are not built by the truck manufacturer, but by a specialised company. Think of cranes, cooling installations or other constructions.
We hope the EC can work out a good new version of the 20-year old Directive with all the input they got. At this moment the targeted consultation is going on. EGARA was one of the first ones to be interviewed. We are really curious for the first draft. We keep you posted about the progress.