Spare parts is one of the main topics at EGARA. We need them to know what we have, if we can sell the customer what he needs and what is necessary in order to make it function in the customers car. In this update we try to give an overview of the aspects of parts reuse.
What is going on?
Today parts are used in a variety of vehicles. They are used in several types, over several years, even in several different brands. But parts can change from year to year without any visual recognition. Partsnumbers sometimes change often without any obvious reason. The same part can have up to 50 different numbers without changes in shape or function. Second is the digital component of parts. Parts not only need to be mounted correctly, they also need to be installed digitally. Some parts need to be reset on the original vehicle before they can be installed on another one. Not installing correctly means a car will not recognise the other part and it will not function. For installing, The right procedure, software or acces to the producer is necessary. Sometimes parts can only function if a group is replaced also. Some parts can even function in only one VIN and cannot be reused for another car with another VIN.
Producers obligations and difficulties
Producers need to provide infor about their parts to economic operators or for reuse. Acces is limited. Sometimes it costs money, sometimes acces is only possible to a certain level, sometimes acces is limited to a specific group only.
ELV Directive 200/53/EC
Article 7.1 describes the obligation for MS to take measures to encourage reuse. We know of no memberstate that took any action encouraging reuse. What we do see is issues with end of waste, despite ‘circular economy’ and ‘sustainability’ as buzzwords. Article 8.1 describes that MS make producers use standardised codes. It’s not really standard codes that we need. We need acces to data.
Articles 6 and 7 say. Producers should provide info (in Oasis format), but they may charge a reasonable fee to so called ‘economic operators’. We as dismantlers are economic operators. This was confirmed to us by the EC. We do not care about the format, we just need info.
The IDIS information system is about dismantling and recycling only. There’s no reuse or parts info at all. IDIS provides some links to producers sites, but the info is very limited and not what we need. Most national governments are convinced that producers helped them to fulfill article 7 from the Directive by issueing IDIS in 30 different languages, which is not true.
Zero cost model
Recycling costs money. The business model of the average ATF (Authorised Treatment Facility or dismantler) covers the costs of recycling and being legal by selling parts. Selling parts is one of the
c/o STIBA Pompmolenlaan 10, NL3447 GK Woerden The Netherlands Tel: +31 88-5011090 e-mail: email@example.com
best examples of circular economy and is sustainability at the highest level, if performed by a legal ATF. Producers are not keen on funds for recycling costs and claim the ELV ‘has a lot of positive value’ and the dismantler is allowed to do with this valuble ELV what he feels is right. So if an ELV contains so much positive value and if it should cover our costs and help us make some money, why do they make it so hard to get this value out of the ELV?
What we need
Simply: we need acces to producers info. We understand this info is valuable and should not be issued for free and should not be issued to just anyone. But we are not just anyone and we never claimed we want it for free. We are hard working entrepreneurs, we close the circle and we are circular and sustainable, just doing our job.
What is our position
As economic operators we should have acces to producers info. We need parts numbers, history of parts numbers or acces to a system that can help us determine in what cars what parts can be used. We need info about procedures for installation and we need acces to installation software. We are willing to pay a reasonable fee. If the producer feels he needs commitment from, or some other controll over dismantlers, let’s start with the ATF’s that are in the EPR systems. They already have contracts with either producers or their EPR organisations .
What are our actions
The gentle way we are taking at the moment, is informing the EC about the current status of obligations and how they are filled in. We are in contact with ACEA also to find out if this topic can be discussed with them. If we can find agreement this way, we would favour that.
The hard way is to start court cases and make parties oblige to the EU laws. But that is not our style and we would rather try any other way to see if we can cooperate with one another as this gives the best results always.
Our American sister organisation ARA faces the same problems. They are very big and started trails with airbags and recalls as a crowbar to open up the producers info. They seem somehow succesfull, but the goal is not reached yet. If they do, it will be very interesting for EGARA also and may speed up some processes.