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Thursday, July 21, 2011

De-registration and recycling of end-of-life vehicles

Renewed interest has been raised in the de-registration and recycling of end-of-life vehicles in EU Member States. End-of-life vehicle treatment and recycling has been legislated by the European Union in the ELV Directive (2000/53/EC) and has been implemented in the national legislation of all 27 member states.

The ELV Directive has been a source of concern for many however, since 14 out of 27 member states didn’t meet the required recycling quota in 2006, as reported by Eurostat (1). Additionally, the reported recycling quota differ greatly between member states. This is attributed to differences in interpretation of the monitoring and reporting standards.

Another issue recently emphasized by several parties is the influence of illegal operators in the market. The European car industry carries out its producer responsibilities as stipulated by the ELV Directive 2000/53/EC and has set up collection networks in all member states. Requirements for authorized treatment facilities have also been recorded in Annex I of the aforementioned Directive. These requirements have to be met by all facilities operating in the national collection networks. This is enforced be governmental licensing procedures in the different member states.

Because of the relatively high value of metals and car components, cars have become an attractive trade product and non-licensed parties are trying to claim their share of the lucrative market. In many cases however, these parties are not upholding the necessary environmental standards nor are they reporting their recycling performance to government and/or national recycling organizations. This creates a uneven playing field and poses economical problems for recycling parties operating by the book.

Several organizations have researched the problem with these “leakages” in the recycling chain. ARN, the Dutch expertise centre for mobility recycling has found cutting of car hulks by illegal operators and waste shipments with erroneous waste transport codes to be among the causes of these leaks. Another cause of leaks are so called ‘paper exports’, transactions happening only on paper without actual export of a vehicle. This is giving illegal dismantlers the possibility to perform any illegitimate action since the vehicle does not exists anymore in the country of export (because of deregistration). Deregistration/export in an exporting country should only be possible after registration in the importing country. ARN and her partners are taking action to mitigate the problems where possible (2). ACEA, the industry organization for European automobile manufacturers proposes a number of actions in its recent position paper on the issue (3):

- Link vehicle deregistration to national registration system, if not already in place.
- Ensure that the national process has no possibility of leakage that enables continued activity by illegal operators.
- Close supervision and prosecution of illegal treatment operators with mandatory shut‐down of facility.

It is clear from these statements and the aforementioned statistics that national road registration authorities hold one of the keys to solving this issue and creating a watertight recycling network for end-of-life vehicles. This is not just of importance for car recyclers and manufacturers, but for the environment in Europe as a whole and for the preservation of valuable resources present in today’s end-of-life vehicles. The European Commission has already started a dozen infringement procedures against member states related to the ELV Directive, and more could follow. The time to act is now.


From Association of European Vehicle and Driver Registration Authorities (EReg)

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