Missing ELV’s consultation
As numbers of missing ELV’s vary from 4 to 8 million a year in Europe, it’s high enough to have the Commissions’ attention. Ökopol had the task of performing a consultation which ended in the end of September. EGARA is glad with this consultation because we as dismantlers need to collect all ELV’s (End of Life Vehicles) and we invested substantially in our companies to do so. The problems with missing vehicles are both environmental as well as business related. EGARA tried to name the causes and solutions in the missing ELV’s situation:
To avoid missing vehicles is to make sure they go to the right places. Both pull and push factors work. It depends on registration systems, their enforcement and national other situations that decide which work best.
Push factors are vehicle obligations: tax, insurance and MOT/TÜV (all national (bi-)annual safety/environmental tests). This only works if national registration systems are closed (continuously as long as the vehicle exists, even when not used) and if the vehicle obligations are related to owning the vehicle and if this is enforced seriously with substantial consequenses (fines).
Pull factors are rewards for the last owner. Somestimes just the CoD (Certificate of Destruction) is a reward (or a relief) in case the registration system is solid and the obligations are well enforced, others are premiums or simply good prices, offered by the legal industry (ATF’s or Authorised Treatment Facilities) for ELV’s. A reward can be premium for the last owner when he can show a CoD. The premium can be paid from a fund like an EPR (Extended Producers Responsibility) fund or a governmental one. Funds can be filled by common meanes from the national budget, but also with fees connected to new cars sales, roadtaxes or insurance. Even if funds are used for labour of dismantlers, this has a positive effect towards the consumer, as ATF’s can offer better prices for ELV’s, which makes it more attarctive for the consumer to take his ELV to the right place and which makes it possible for an ATF to compete with the illegal sector.
Even the favoured by producers Zero-cost model can help. No fund is necessary when producers assist in getting out all positive value out of an ELV by providing vehicle info (parts numbers and their history, interchangebility and digital procedures) and make it possible to implement this information in our company systems. This way we can offer the last owner a rerasonable price for his ELV.
There are several reasons for rewards: in some countries the density of ATF’s is problematic. Countries with a big surface and low population see big distances to get rid of their old car. Space is never a problem in such situations, so cars are abandoned easily if no consequences or considerable rewards exist. Also the illegal sector is an important factor. Because illegals do not have costs of their legal situation, they can offer higer prices than ATF’s.
All this only works if ATF’s are the only ones to issue CoD’s. If CoD’s are issued somewhere else, the vehicle is not in the right place to be depolluted and dismantled and are likely to wander and end up at undesired locations.
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Other points where collection of ELV’s fails are Member States where no solid registration systems are implemented, where deregistration is possible without COD or when no consequenses exist for not fulfilling vehicle obligations.
Export is the only point that remains problematic. Because export means the vehicle is out of sight until it’s re-registered again, everything possible can happen. Export is very often used as an escape to end registration without the burden of, for instance, a CoD and legal dismantling/depollution and their costs. Especially in good solid registration systems it’s the only escape. Export needs attention as long as national systems cannot be connected to each other to follow the whereabouts of cars (/ELV’s).
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