The reporting methodologies for recycling and reuse are mentioned in the Directive, the commission decision (2005/293/E) and in de guideline. The Directive is always leading. The guidance should lead to better and better comparable figures. It´s not a limitation in reporting methodologies, it an aid. Monitoring and substraction are still possible. EGARA did not favour one model above another, but was critical and hopes for some spin-off in better registration and fighting illegal players.
DG Environment initialized a Working group on Reporting Methodologies. Aim was harmonisation of the Member States´ reporting on their national recycling rates as these were interpretated in many ways and in many cases wrongfully. In the working group were representatives from DG environment, DG E-stat, ACEA, Member States, reporting bodies (ARN, Febelauto), EGARA and later BIR. The working Group had 3 meetings in total.
Member States can report in 2 ways: By monitoring (substraction) or by making assumptions about the metal content. Both methods have their pro´s and cons. These methods and everything necessary are described in a guidance: ´How to report on end of live vehicles according to Commission decision 2005/293/EC´. The ELV Directive is leading. The guidance only wants to assist member states in their efforts to produce high-quality and harmonized data on ELV´s. The guidance has no legal binding.
ACEA and EGARA
EGARA tried to find out how to offer our services to the producers, ACEA needed our support or at least needed to know our opinion about the methodologies. EGARA and ACEA met twice. It became clear that we were critical about a fixed assumption as an only possibility, but could agree with their proposal for a fixed assumption. ACEA shared our point of view that law enforcement was very necessary to make any system function well, so we may get some support of them on this issue in the future.
DG Environment/DG Estat
It became very clear that the DG´s needed a methodology that would mean reporting on true and reliable figures. Estat realized the last meeting how important a closed vehicle registration system is. Environment already knew this (EGARA did a survey amongst her members about COD issueing and deregistration) and in the document is stressed that Member States should report about vehicles that were issued a COD by an ATF (dismantler). Further we can read that it is still studied why there´s less COD´s than reported ELV´s. For this topic a working group under Ereg (vehicle registratiun bodies) exists, as well as a recommendation for Foreign Trade Statistics (FTS) to investigate the export trades.