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Preamble

 

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, have carefully studied the ELV Directive (2000/53/EC), with special regard to Article 7 and 8 of the Directive, where it is specifically mentioned, that:

Article 7,1.: “Member States shall take the necessary measures to encourage the reuse of components which are suitable for reuse …”

Article 7.5.: “ …. the Commission shall take into account as appropriate the need to ensure that the reuse of components does not give rise to safety or environmental hazards.

Article 8.4.: ” … Without prejudice to commercial and industrial confidentiality, Member States shall take the necessary measures to ensure that manufacturers of components used in vehicles make available to authorised treatment facilities, as far as it is requested by these facilities, appropriate information concerning dismantling, storage and testing of components which can be reused.

In our opinion, these Articles must be taken into consideration when evaluating the working paper of DG Enterprise, with a view to amending the Type-approval Directive  (70/156/EEC), based on the ISO standard ISO/DIS 22628.

EGARA position on reuse/ recycling targets

As we have already stated previously, EGARA is of the firm opinion that, the established targets for reuse/recycling, can only be obtained, on the condition that, a high degree of reuse of components is ensured.

In this context, three items concerning elvs and re-use of parts and components must be taken into consideration.

Firstly, it must be remembered that in many cases, and depending on national laws, damaged vehicles are deemed to be elvs depending on repair costs in combination with tax legislation.

Thus, and although only a part of the vehicle is damaged, it is deemed an ELV, meaning, that in the majority of cases, there are nearly-new parts to be dismantled and sold as second hand/used parts. These parts are the core element of the vehicle dismantler’s business, and it would be a waste of resources if these parts could not be reused.

Secondly, in environmental terms, re-use is clearly to be preferred to recycling, due to economic considerations, as well as energy considerations and other environmental factors. Hence, if reuse is restricted by bureaucratic rules, it will have a negative environmental impact.

Thirdly, in EGARA we are well aware, and have been for a number of years, that necessary attention must be paid to safety and environmental hazards and all EGARA national associations do work with quality classification schemes to satisfy this. We, the dismantlers in EGARA have always paid attention to this and, thus only supplying the market with parts for re-use that do meet normal functional requirements. It is our firm opinion that, if parts are dismantled/disassembled by professionals, stored and tested appropriately and mounted/fitted also by professionals, there are neither safety nor environmental hazards in re-use of parts and components. Eventual hazards will be further eliminated when the authorised treatment facilities receive the information specified in Article 8.4.

Further, in some countries the EGARA National associations have already initiated certified quality management systems for the quality classification of used parts and component, based on the ISO Standard 9001:2000 or similar. This is for example the case in the Netherlands, Denmark and Sweden.

EGARA’s policy on quality management certification

At it meeting in November 2001, EGARA adopted the following policy concerning this:

EGARA fully understands and supports the necessity to ensure, that re-use of component and parts, as specified in directive 2000/53/EC must not lead to increased safety or environment hazards.

EGARA has therefore decided that parts for re-use must be assigned quality codes according to a quality management system, the basic elements of which are drawn up by EGARA. The EGARA National Associations, taking into account relevant law in the individual countries, will detail it further.

In the long term, these National system should be certified according to ISO-9001:2000 or similar, comprising quality management for quality classification of parts, and environment management issues, ensuring conformity with the national legal requirements as decided in the national implementation of the elv-directive 2000/53/EC.

EGARA urges its members to bring their systems in line with ISO-9001:2000 or similar not later than 1. January 2007.

Consequences of this

When the EGARA policy is fully implemented, we will obtain a situation where all spare parts and components for re-use will have a distinct quality code, assigned according to the international standard ISO-9001:2000 or similar, thus ensuring that parts and components being reused have been properly controlled and tested and therefore do not impose safety or environment hazards.

List of components not to be reused

In its working document, DG Environment has in Annex XVI established a list of parts that must not be re-used. It is EGARAs firm opinion, that with the exception of pyrotechnical components, where there seems to be some doubts concerning control and test methods, control and test methods do exist for the other parts listed in DG Enterprise’s Working Paper, Annex XVI under 3.4 to 3.8, and under the condition that parts for re-use are mounted/fitted by professionals following adequate instructions, as produced by the manufactures, there are no safety and environments hazards due to re-use of parts and components.

The mentioned control and testing methods will be contained in the EGARA standard and will be based upon the information provided by the manufacturers.

Corning pyrotechnical equipment for airbags and safety belts etc., the producers claim that, there are no control and testing methods that can be applied for used airbags and safety belts, since some components imbedded into the systems can only be controlled and tested at the time of assembly.

We have no reason not to believe in these claims. However, there is good analytical evidence that used airbags is not a safety hazard. Our American colleagues in ARA, Automotive Recyclers Association have deployed a total of 195 recycled OEM airbags without failure and within accepted parameters (Analysis performed by a NASA Institute).

EGARA therefore has the same position as ARA:

“The use of non-deployed ‘recycled’ OEM air bags is a viable, economical

and safe alternative to the use of new, more costly OEM airbags

when properly evaluated, handled, shipped and professionally installed.”

EGARA

2001.11.20