Some time ago we pointed out that it’s important to make ourselves heard to the officials of the various governments. We talk about local government, national government, European Commission and al kinds of stakeholders. Since August 6th we have a big opportunity that we should grab.
The EC announced that they opened an open internet consultation about the ELV Directive from August 6th till October 29th. This is our chance to have influence on the weak spots of the Directive. The Directive is implemented differently in every country, so it’s important to participate yourself. Both weak points in the Directive itself, as well as wrong implementation are important to mention. There are a lot of open fields in the consultation, so all your points can be described and explained. Both descriptions of problems and suggestions for solutions are welcome.
We discussed many times the weak points of the Directive itself (implementation in national legislation, dependent on other directives for registration systems, no clear description of recovery/recycling definitions). We also mentioned the implementation issues (import/export, registration, grey zone, COD’s at other places than dismantling, home storage of ELV’s (DIY), costs oftransportations, costs of recycling, wrong responsibilities (recycling chain), reporting, recyclability, parts info, etc). We should speak out now. This is our chance and we are the ones that know best how the Directive is taking care of abandoned vehicles, missing vehicles, recycling and reporting. The EC needs our knowledge and it’s in our own interest to inform them well.
The consultation can be found at https://ec.europa.eu/info/law/better-regulation/initiatives/ares- 2018-4731779/public-consultation_en .
The whole project can be found at https://ec.europa.eu/info/law/better-regulation/initiatives/ares- 2018-4731779_en . Over here it’s also possible to view the contributions on the feedback.
We hope everybody will take some time to think critically about his/her position as a dismantler in the European playing field. For extra info we suggest that you look up some articles that EGARA published previously on the EGARA website https://www.egaranet.org/ . Especially the articles in the ‘Newsflash’ and ‘Other EGARA Items’ sections can help you describing some ideas and not forgetting issues.
We hope everybody will take this chance and will contribute to this opportunity.