EGARA POSITION PAPER
EGARA, the European Group of Automotive Recycling Associations, comprising vehicle dismantlers in: 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 7.1 of the Directive, where it is specifically mentioned, that:
“Member States shall take the necessary measures to encourage the
reuse of components which are suitable for reuse …”
In this context, it has been discussed on, which “routes” the treatment of elv’s should take, basically whether it is more efficient and financially viable to pre-treat and dismantle components and materials at the car dismantlers, or carry out this process at the post-shredder stage
This position paper evaluates this with a view to ensuring that the re-use and recyclability percentages required in the directive are reached.
EGARA’s basic opinion
As we have stated it 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. Further, in environmental terms, re-use is clearly to be preferred to recycling, due to economic considerations, as well as energy conservation and other environmental factors. Finally, to our knowledge, the currently available shredder-technologies in Europe, do not ensure the necessary material separation in a fully satisfactory way.
Some organisations, such as car-producers and recycling companies, claim that, in general, most of the available elvs are of only little interest to car-dismantlers, simply because their general condition is such that, it will impossible – both in technical as well as in economical terms – to dismantle useable and saleable parts from them.
Hence, these elvs are of no interest to car-dismantlers, but of much more interest to e.g. shredders.
Further, that given a critical mass can be achieved, a shredder can do the handling of such elvs in a cost-effective way, still respecting the re-use and recycling objectives of the directive and, most likely, cheaper than a dismantler, hence avoiding any economical producer responsibility for the treatment. Therefore, shredders could be points of delivery for elvs.
EGARA is not of that opinion.
The above model does, as we see it, represent a rather mechanistic approach.
No car-owner and no shredder can, by simple inspection and/or by simple calculations, effectively decide, if an elv contains a potential for re-use of components and parts.
The market conditions in this area are simply too complex. They depend on a lot of different factors which, for each single elv and depending on country, region and at which point of time the elv is delivered, are unique. Based on their long-time knowledge about market conditions for components and parts, a competence which has been compiled and structured into computer based decision support systems, car-dismantlers are the only ones which will have the necessary knowledge to make the right and environment friendly decision.
Further, until shredder technologies are more developed, a pre-sorting of materials is needed in order to achieve the necessary material separation that leads to cleaner waste-fractions, which in turn then increases recycling possibilities.
Hence, EGARA stresses that, the “natural” delivery point for elvs are dismantlers – since:
- dismantlers are locally based and therefore easily accessible for the car-owners;
- only dismantlers have the unique competence required in order to decide whether a received elv, after de-pollution, is suitable for disassembling into re-useable spare parts;
- dismantlers undertake the necessary pre-sorting of materials that, with current shredder-technologies, ensures that an optimal degree of recycling is possible;
- in some cases a cleaner, more useable material is produced
If elvs go directly to shredders, optimal re-use cannot be ensured, and recycling will get priority over re-use, which is not the intention of the directive.