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Workshop Review ELV Directive

As the Directive is already 20 years old, The EC has decided to evaluate the Directive on effectiveness, coherence, relevance and efficiency. We will put the presentation that was used during the workshop online on the EGARA website, but here we would like to mention some interesting topics. The meeting room was crowded, almost 100 people in a room for 80.

First of all the new head of unit was introduced: Mattia Pellegrini. He was formerly involved in SME’s and also in raw materials. He seems to be very eager for results, which is what we need.

Closely related to this review, is the review of the Battery Directive that will start in 2021. The Battery Directive is of influence on traction batteries, but is heavily obsolete regarding li-ion batteries, their handling and their technology as well as the possible percentage of recycling and other possibilities for reuse.

Apart from the battery directive other legislation is of influence on ELV recycling, like:

  • Reach (description production hazardous substances)
  • RoHS (Restriction of hazardous substances in Electronics)
  • WEEE Directive
  • Waste frame directive (WFD)
  • Registration (DG Move)

The researchers made a good inventory of points that need attention. The setup of the workshop was very practical:

  • What do we disagree with?
  • What do we miss?
  • Evidence of things going really wrong(!)

Some good German and French studies about best practises are available on the EC websites. Costs for depollution differ per country, but depollution is not profitable. For us this is in line with our opinion that we need to take out all value of parts reuse, especially with the low scrap prices. What was interesting is the price of a ton of clean pp (poly propylene): € 1000,- .

Things that get attention are missing vehicles, reporting, batteries and EPR. OEM’s state that they make costs  with reporting and take back networks, but we feel a lot is missed and we are the ones doing the job which is not free at all. Even if consumers are obliged to take their vehicles to ATF’s, it’s still possible to sell them to people that just take them abroad. As it’s hard to distinguish ELV’s from cars, the Italian way of allowing export only with a current MOT was favoured. ATF’s giving money to last owners is also more effective than just legislation. It’s not because we are stupid, it’s because they otherwise disappear to illegals. EV batteries are a different matter. Do they need to be only recycled for 50%? Is it possible to recycle an EV for 95% if the batterie is removed?

The EC is really interested in things going wrong, but needs hard evidence. For this reason we have asked our members to report on single use parts for instance, but we also organised and organise meetings in countries that want to show their situation. We are always open for any info.

Artemis wishes to discuss batteries with ACEA and EGARA, which we of course will do! This is a good way to effectively come to good proposals.

So far we see no reason to fear the outcome of the review and future development. What will happen next is:

  • Evaluation was looking back; – What are we going to change?
  • Howe are we going to change them?
  • Commission proposal(co-decision);
  • Amendment Commission Decision on How to Report?

It seems the EC wants to keep the speed in this process and come to effective results. We will stay involved where possible and keep you updated.