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

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CoD reversals … a simple process?

CoD reversals - a simple process?Recently all ATFs received a letter from the DVLA regarding the issuing of Certificates of Destruction (CoD) and how any requests to reverse the declaration of a CoD, will, ‘in the first instance, be refused.’ 

We got in touch with some dismantlers as well as the BVSF to find out their thoughts on the CoD reversal process, whether it has affected their businesses and if they have any suggestions to help make the CoD reversal process run a bit smoother:

 

Les Knock, General Manager ASM Auto Recycling said:

As a permitted Authorised Treatment Facility (ATF) ASM Auto Recycling has over 35 years experience in handling scrap cars and end-of-life vehicles, processing over 30,000 vehicles last year.

All things considered, we feel that the present CoD process works very well and we don’t generally encounter many issues or problems. However, on the rare occasion when a CoD has been processed in error it is very difficult to reverse or delete, which is very frustrating given the potential implications of such an error. Any data input based system is bound to experience a certain degree of human error, and this being the case, it would be great if DVLA could adopt a slightly more user-friendly policy with regards to rectifying these genuine admin errors.”

Millie Davies, Co Owner of Davies Salvage Ltd said:

Millie Davies - J Davies Salvage - CoD reversal quote
Millie Davies

“Recently we received a letter from the DVLA stating that when a CoD has been declared, any requests to reverse it will in the first instance be refused, however there is a chance for it to be appealed.

Through our own experience, having made the mistake once recently, it was very tricky and time consuming to get it reversed. It took around 8 weeks to get it reversed. I was passed from one department to another, then after 6 weeks of ringing for updates, I was all of a sudden told that because I wasn’t the registered keeper, they were no longer allowed to speak to me regarding the car, even though I was the one who made all the phone calls and sent all the evidence in.

After I had been refused any information on the case, I got in contact with the customer again and this is what they had to say”: “Hi, Yes it’s all been sorted thanks and they said they sent an email to you guys already but didn’t tell me… they are useless. Thanks”

“The customer or myself had not received an email to say that the CoD had been reversed.

Although I understand the importance of not making this mistake, I think the DVLA must take into consideration that mistakes will be made and they should have something put into place that can speed up the process of the reversal. Our customer was without a car for 8 weeks and had children they needed to run around, and let’s not forget, they were driving around illegally for a short while before realising their car had been ‘scrapped’.

A company who we work quite closely with made a good point …”: “What I can’t understand is what if you just made a simple mistake and added 1 digit wrong – How would you be able to get the photos or the V5c? There has to be another process or they would be breaking recycling laws by false reporting surely; CoDs get used as part of recycling rates, so non destroyed cars that have a CoD will be reported as recycled but not. Very confusing.”

“It’s such a simple process to scrap a car, yet such a difficult process to reverse.

We have now made a few changes to how we handle CoD’s so hopefully this won’t happen again in the future.”

Thomas Hayward, Managing Director of I Need Spares Ltd said:

Thomas Hayward - I Need Spares
Thomas Hayward

“We as an ATF site have stringent processes in place when issuing CoDs. This starts at the first point of contact with the vehicle; in a two person check with the vehicle details, followed by photographing for our own use and also for evidence (if ever needed) and then using the DVLA CoD login website we input the details and should any difference occur from the Reg and VIN number it is flagged as an error. We use professional industry software which also helps identify any anomalies.

However, if there was an instance where a vehicle was professionally messed about with at some point of its life and documents and vehicle stamped VIN numbers matched and then subsequently CoD’d then this should be more of a police matter and investigation between all parties involved and not really the fault of the ATF. 

If the DVLA website could be brought into the 21st century with the help and advice from its users, whilst implementing some extra check procedures within it, then this could also combat human error when issuing CoDs. We have already helped the GOV website develop the online permit application process and would be happy to share some thoughts if the DVLA website team would like to discuss this. 

Both industries need to collaborate on these issues to bring a better solution for everyone involved.” 

BVSF Secretary General, Roger West said:

Roger West BVSF
Roger West

“In the first half of this year the number of CoD’s in error that I have been asked to investigate have increased significantly. The total amount in relation to all CoD’s completed is still no more than a drop in the ocean but each mistake has the ability to cost various individuals and companies not only time but money. I have emphasised to BVSF members the necessity to be totally accurate in the completion of CoDs. Just one digit error has the ability to render an innocent member of the public to be unable to use their car, I know how I would feel if that happened but also it means that if the entire CoD was completed in error a vehicle destined for repair may well be, to all intents and purposes and certainly in the eyes of the DVLA, not fit for repair. The new owner/repairer may expend large amounts of money repairing the vehicle only to find on application for a V5c that as far as DVLA are concerned the vehicle is listed as “Scrapped” and therefore a V5c will not be issued. The DVLA can only act on the information they are given!

In the cases I have dealt with, with the DVLA, there have been varying degrees of error from one or two digit errors to “Simply” creating a CoD on entirely the wrong vehicle and I have to say at all the times the DVLA have acted in a professional manner and have at no time not listened to reason and for this I am grateful. However, this action for them is very time consuming as they have rules concerning the “investigation” they have to complete. The DVLA have accepted that “Human Error” will creep in at times and are prepared to look at these cases but they, like me, would emphasise the need for accuracy, the CoD is, after all, a legal document and needs to be accurately completed.

I will close by thanking the DVLA for their assistance and confirm that all cases currently dealt with have been successfully resolved.”

 

It seems that most dismantlers are very much aware of the CoD reversals process and they are doing their utmost to avoid making mistakes. However, human error can occur and it is felt that the DVLA are refusing to understand that these mistakes can happen. 

Perhaps a suggestion to create a more effective way of recording CoDs online which have ways of raising potential mistakes could be the answer and something that would be good to see the DVLA implement.

We asked the DVLA for their input with regards to the thoughts provided by the dismantlers we got in touch with. 

A DVLA Spokesman said:

DVLA - CoD Reversal Quote“The issuing of a Certificate of Destruction (CoD) is a legal requirement contained within the End of Life Vehicle Regulations 2003. In line with regulations, authorised treatment facilities (ATFs) are legally obliged to make CoD notifications in a timely and accurate way. This CoD declaration from the ATF automatically closes down the DVLA record for the vehicle involved.”

“As recently communicated within the DVLA letter to the industry, there is no legal basis for the removal of a CoD notification. This means that any request to reverse such a notification should only be made in exceptional circumstances. Any application to reverse a CoD notification will therefore be subject to thorough investigations, including a possible inspection of the vehicle.  These checks are necessary to prevent incorrect or fraudulent applications and to safeguard the integrity of the vehicle record. While this can at times seem to be a lengthy process, DVLA depends on receiving enough information from the application (the current keeper of the vehicle).”

“DVLA continues to work closely with industry representatives and others to understand any issues that arise with the incorrect issuing of a CoD and should any improvements be identified, these will be communicated to all relevant stakeholders.”

If you have any further comments you would like to make on this subject or if there is an aspect of the vehicle recycling industry affecting your business which you would like us to cover, please contact us at info@atfpro.co.uk 

 

 

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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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