Katie Morrison, TECHMCIWM of What Waste Code Ltd., highlights the growing issue of waste code misclassification at end-of-life vehicle sites.
Waste management is a minefield of regulation, compliance, and ever-evolving best practices. Nowhere is this more apparent than in the treatment of end-of-life vehicles (ELVs), where misclassification of waste codes can cause significant disruptions. One particularly thorny issue is the misidentification of ELV shells:
I regularly see the following EWC code being used:
EWC 20 01 40, which relates to metals found in municipal waste, including separately collected fractions such as scrap copper, aluminium, lead, zinc, iron, and steel.
Rather than the more appropriate EWC 16 01 06, which refers to end-of-life vehicles that contain neither liquids nor other hazardous components. This classification applies to scrapped cars, lorries, motorbikes, and other vehicles that have reached the end of their operational life but do not contain hazardous substances such as oils or coolants.
This practice creates ripple effects across the industry, impacting reporting, recycling rates, financial stability, and even downstream treatment processes.
The Importance of Proper Waste Classification
Each waste type must be assigned a suitable EWC code, ensuring traceability, compliance, and accurate reporting for environmental and regulatory purposes. ELVs primarily fall under the 16 code, which is specifically designated for discarded vehicles and their components. However, some facilities mistakenly, or deliberately, use a 20 code when weighing in ELV shells, leading to inaccuracies in waste tracking and potential contamination of clean waste streams.
The Problem with using the incorrect codes for ELV Shells
The 20 series codes are generally reserved for municipal waste. By weighing ELV shells under these codes, facilities risk misrepresenting the materials they process. This misclassification can have several serious consequences:
- **Distorted Recycling Data** – The UK’s ELV recycling rate is tightly monitored to ensure compliance with the End-of-Life Vehicles Directive. When shells are assigned a 20 code rather than a 16, the recorded figures do not accurately reflect the amount of vehicle waste being processed, potentially undermining national recycling targets.
- **Disruptions in the Supply Chain** – Vehicle dismantlers, recyclers, and metal processors depend on accurate classifications to determine the composition and volume of incoming material. A misclassified load can cause logistical challenges, leading to inefficiencies in sorting and processing.
- **Regulatory Compliance Issues** – Waste management regulations require accurate reporting, and incorrect coding can lead to audits, penalties, or even legal consequences for facilities involved. Misreporting ELV waste, intentionally or unintentionally, puts the entire industry under scrutiny.
- **Financial Ramifications** – Recycling facilities set pricing structures based on EWC classifications. If ELV shells are weighed in under a 20 code, it can affect gate fees, recycling payments, and overall profitability within the waste sector. This inconsistency causes financial strain, particularly for businesses that rely on precise waste categorisation for their operations.
- **Contamination of Clean Waste Streams** – A misdeclared ELV can be particularly problematic for waste processors further down the line. Many recycling and recovery operations rely on clean, well-segregated material streams to ensure efficient treatment. If an ELV is incorrectly coded and mixed into a different waste stream, it can introduce contaminants, reducing the quality of secondary raw materials and forcing additional processing steps to correct the issue.
- **Impact on Final Waste Classification** – The errors made at the start of an ELV’s disposal journey have lasting effects. By the time materials reach the final classification stage, inaccurate reporting can misrepresent what has actually been processed. This can affect compliance assessments, environmental impact evaluations, and even the viability of certain recovery methods.
Finding a Path Forward
The industry must work toward a standard approach, ensuring all ELV shells and parts are weighed under the correct 16 codes. This can be achieved through:
-**Clear Guidance from Regulators** – Authorities should issue firm direction on correct coding practices, eliminating any grey areas that allow misclassification.
– **Improved Training for Waste Facilities** – Staff handling ELVs should receive regular training on classification rules to ensure compliance and reduce errors.
– **Stronger Enforcement Measures** – Increased inspections and reporting requirements would help detect discrepancies early, preventing systemic misclassification.
At the heart of this issue lies a fundamental need for consistency, transparency, and accountability. Proper coding is not just a regulatory tick-box; it ensures ELV sites can operate efficiently, meet environmental targets, and contribute to a sustainable waste management system. The sooner we address this misclassification problem, the sooner the industry can move towards better operational clarity and improved recycling outcomes.
Visit whatwastecode.co.uk
Read Katie’s previous article on ATF Professional: Electric Vehicle Dismantling: Best Practices and Lessons Learned.
