Essential information for end of life vehicle dismantling, depollution and recycling

green parts specialists

Key factors to know about export of waste vehicles and parts

vehicle dismantlingRecently there have been more instances where shipments of vehicle parts originating from the UK and destined for overseas markets have been stopped/seized en route by various regulatory authorities and deemed to be waste. These loads are usually repatriated back to the UK. This can be very expensive, time-consuming and frustrating for all parties involved. 


We have also seen an increase in loads containing end of life vehicles (ELVs) that have been exported from the UK being stopped by customs officers in other EU countries. In several cases, because there has been no waste shipment paperwork for the load or it has been destined for a country that prohibits the import of un-depolluted ELVs, resulting in the load being returned (repatriated) to the UK. 

Below are some useful pointers and the key things that you need to do to comply and minimise the risk that shipments of vehicle parts loads from your site get stopped. 

Exporting second-hand parts

Although the ELV is waste and the dismantling of the ELV is a waste treatment activity, the dismantling process can produce parts that cease to be waste if they meet the following criteria: 

  • they are fit for reuse without any further repair or testing;  
  • they are certain to be used for their original intended purpose; 
  • they are handled and stored in a manner so they are not damaged and can be used for their original intended purpose. 

This means parts that have been removed from an ELV and checked to see that they are undamaged and fit for re-use for their original intended purpose would be considered a second hand part and not waste. This is provided they are stored, handled, transported and sold as second-hand goods rather than scrap. 

Regulatory authorities (such as customs or Environment Agency equivalents) outside the UK may have a completely different view about whether a part is waste or not. Although in the EU, member states tend to have similar views, this may not always be the case. If there is any doubt you should check with that regulatory authority and you must comply with their requirements. 

Demonstrating parts removed from ELVs are not waste 

There are some simple steps you can take to demonstrate that the parts are second-hand goods and are not waste. This evidence could be crucial to convince customs and regulatory authorities in other countries that the load is not waste and not subject to international Waste Shipment controls.  


  • Engines should be assessed as fully functional and therefore suitable for re-use without repair prior to the ELV being depolluted and the engine being removed.  
  • Engines should be fully drained, oil filters removed and bunged prior to storage and/or export to prevent oil leaking. 
  • Engines that have not been depolluted and still have an attached oil filter or leak oil in transit are a pollution risk and carry a significant risk of being detained or repatriated as waste  
  • Engines with significant damage (e.g. hole in the block) or parts missing (sump or cylinder head) will not be suitable for direct reuse without repair, so will be considered waste.


  • Tyres destined for reuse should be assessed as suitable for direct re-use, following The Motor Vehicle Tyres (Safety) Regulations 1994
  • Tyres that are not road legal in the UK are regarded as waste regardless of whether or not they would be road legal in the destination country.

Other parts 

  • Other parts intended for reuse for their original intended purpose must be assessed by the operator to determine functionality, quality and condition to ensure that they are suitable for re-use without modification or repair.

The manner in which parts are stored and packed during transportation will also strongly indicate the status of the part. Parts destined for direct reuse would be expected to be carefully packed so damage in transit is avoided.

Exporting ELVs 

If you are selling whole ELVs to a buyer overseas or planning to export the following ELVs you will need to make sure the correct waste shipment paperwork is in place: 

  • Category B write off; 
  • Category S or N vehicle that is going to be dismantled for parts; 
  • any other vehicle that is going to be dismantled for spare parts. 

Before the ELV can legally be exported from the UK the international Waste Shipment notification documents and movement forms must be completed. This is not a new regulatory requirement it has been in place for many years. Information on the notification process can be found on the GOV.UK website at  

Export is often not undertaken by the vehicle seller but by the overseas vehicle purchaser. However, sellers have a legal duty, under Duty of Care, to check that the person receiving the vehicle is authorised to do so and that the correct international waste shipment paperwork is in place. There is further information on the Duty of Care at

You are also required to keep a copy of the shipment paperwork which is similar to hazardous waste consignment notes.

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Adam Hewitt

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The views and opinions expressed on ATF Professional are solely those of the original authors and other contributors. These views and opinions do not necessarily represent those of the editor, publisher or staff of ATF Professional.


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Owain Griffiths

Owain Griffiths

Head of Circular Economy at Volvo Cars

Owain joined Volvo Cars in June 2021 to lead Circular Economy in the Global Sustainability Team. The company has committed to being a circular business by 2040 and has financial, recycled content and CO2 based targets for 2025, all of which Owain is working across the company to make happen. Owain previously worked for circular economy consultancy Oakdene Hollins where he advised businesses on evidence led circular economy implementation. 

Turning into a circular business and the importance of vehicle reuse and recycling.

The presentation will cover the work Volvo Cars is doing to achieve 2025 but mainly focus on the transformational work towards 2040 and the business and value chain changes being considered. Attention will be paid to the way vehicles are being dealt with at the end of life and the complexities of closing material and component loops. Opportunities and challenges which Volvo Cars is facing will be presented including engagement with 3rd parties and increasing pressure from stakeholders.

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e2e Total Loss Vehicle Management [e2e] is the UK’s only salvage and automotive recycling network with nationwide, environmentally compliant sites delivering performance resilience and service reliability to the insurance and fleet markets.  The network’s online salvage auction drives strong salvage resale values and faster sales.  e2e’s salvage clients have access to the network’s stocks of over 5 million quality graded, warranty assured reclaimed parts. 

The power of the network model means e2e has the ability to influence industry standards and is committed to continually raising the bar whilst redefining the role and perceived value of the salvage operator.  Network members adhere to robust service level agreements, against which they are audited, in order to ensure performance consistency and a market leading customer experience.  

The salvage and recycling operating environment is evolving rapidly, and e2e is anticipating, listening and responding to changing market needs.  Regulatory compliance, ESG, reclaimed parts, customer experience, EVs, new vehicle technologies, data and reputation risk are just some of many considerations linked to the procurement of salvage services.  e2e will drive further added value to clients and members through the adoption and application of emerging technologies, continuing to differentiate its proposition and position salvage services as a professional partnership. 

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