EuRIC, the European Recycling Industries’ Confederation shares their comments on the revision of Directive 2000/53/EC (ELV Directive).
Issues for the recycling sector
Every year, end-of-life vehicles (ELVs) generate between 7 and 8 million tonnes of waste in the European Union which should be treated in an environmentally sound manner. The ELV Directive, its ambitious targets of 95% recovery coupled with the requirements laid down to ensure proper ELV recycling, has profoundly shaped the ELV recycling industry which has made very significant investments throughout the recycling process (from depollution to the recovery of complex materials) to achieve it.
The most significant issue for the whole ELV recycling industry is around 4 million vehicles of unknown whereabouts per year in Europe, compared to 6 to 7 million ELVs treated in compliance with the ELV Directive1. This deprives authorised treatment facilities (ATFs) and ELV recycling facilities (shredders and post-shredder installations) from ELVs which should be treated in an environmentally friendly way in accordance with the ELV Directive and results in net economic losses for compliant treatment and recycling operators, given the uneven playing field in which compliant facilities operate.
EuRIC via its European Shredder Group (ESG) represents ATFs and the vast majority of ELV recycling facilities (shredders and post-shredder installations) which recycle ELVs in Europe. EuRIC fully supports the goals of the ELV Directive and calls for measures aiming at strengthening its enforcement, linking the ELV Directive with the objectives of the Plastics Strategy and adapting it to the challenges posed by new types of cars progressively entering the market. Among the various challenges these cars pose at recycling stage are the difficulty to meet the existing recovery targets of 85% and 95% given the increase of composite materials which are currently very difficult when not impossible to recycle under technically and economically viable conditions.
EuRIC strongly supports the inclusion of binding recycled content for plastics in cars to pull the demand for technical plastics and incidentally boost eco-design and correct the failure of the markets to reward plastics’ recycling huge environmental benefits.
1 https://ec.europa.eu/environment/waste/elv/pdf/ELV_report.pdf
Key requests by the recycling industry
The revision of the ELV Directive is the right opportunity to implement urgently needed measures to solve practical challenges linked to the Directive. EuRIC therefore proposes the following measures:
- Well-framed financial incentives for the last holder to deliver a vehicle to authorised treatment facilities in exchange of a CoD.
- Improve registration and de-registrations systems
- “Clear & easy way to implement” distinction between used cars and ELVs
- Improvement in the information exchange about the fate of temporary de- registered vehicles
- Emphasise the important role of insurers in case of total loss
- Tackling illegal online sales of valuable spare parts from ELVs cars which have been declared total losses, scavenged cars etc.
- Minimum target of post-consumer recycled content of plastics in new cars to foster the demand for recycled plastics from ELVs
For more information, contact: euric@euric-aisbl.eu
To read the full report go to www.euric-aisbl.eu
