Environment Agency fire advisor Peter Buckley warns that shredding ELVs before full depollution is illegal and hazardous-waste mixing that drives fire, explosion, and cost risks for ATFs and metal shredders. Operators must fully depollute, including airbags and pyrotechnics, consign undepolluted ELVs as hazardous, and check their permits with the EA if unsure.
EA sets out fire, hazardous waste and cost risks for ATFs and metal shredders
Peter Buckley, Senior Fire Advisor at the Environment Agency (EA), with responsibility as national lead for fire prevention and end-of-life vehicles (ELVs). Drawing on three decades’ experience with Greater Manchester Fire and Rescue Service and his current EA role, he sets out the emerging depollution and shredding issues the Agency is seeing at ELV sites, the regulatory requirements behind them, and what non-compliance means in practice for ATFs and metal shredders.
EA perspective on depollution and ELV fire risk
I have worked for the Environment Agency (EA) since 2018. My national roles include fire prevention and end-of-life vehicles lead. Before joining the EA, I worked for 30 years in the Greater Manchester Fire and Rescue Service (GMFRS), attending many incidents, including significant events at end-of-life vehicle (ELV) sites.
I want to use this opportunity to highlight some common challenges currently emerging in the ELV sector related to depollution and shredding vehicles. Although this editorial focuses on vehicle types described in the ELV Regulations, my remit covers all waste vehicles, including lorries, trains and aircraft.
While many permitted sites operate to a high standard of depollution and dismantling, we are aware of some operators that cut corners, resulting in environmental pollution, and we take action to bring those sites back into compliance.
Hazardous vs non-hazardous: when an ELV can be shredded
An ELV that has not been fully depolluted is hazardous waste, while a fully depolluted ELV is non-hazardous waste. Our position has always been that only fully depolluted ELVs can be shredded, and shredders are only authorised to shred depolluted ELVs.
This practice has highlighted several concerns:
- An ELV that has not been fully depolluted in accordance with the requirements of Article 6 and Annex 1(3) of the End-of-Life Vehicle Directive remains hazardous waste and must be treated and consigned as hazardous waste.
- Metal shredder operators in England are accepting ELVs in the belief that they have been fully depolluted and, therefore, treating them as non-hazardous.
- Hazardous material is dispersed in the shredder, contaminating non-hazardous fraction.
Permit requirements – and what non-compliance looks like
All ELV permits require that ELVs are fully depolluted, and failing to complete depollution activities is a breach of permit conditions (e.g. Condition 2.5.1 in all Standard Rules permits and Table 2.5).
Operational risks for metal shredders and the wider sector
If an ELV is not fully depolluted, it will be illegally processed in metal shredders. It is an offence to cause someone to contravene their permit condition. This can also lead to:
- An increased risk of fires and explosions within metal shredders.
- An increased risk of noise from the metal shredding operations.
- The illegal mixing of hazardous, undepolluted ELVs (or WEEE) and non-hazardous waste will result in all shredder residue being classified as a pre-mixed hazardous waste, regardless of chemical analysis.
- Shredding of ELVs that have not been fully depolluted is contrary to the requirements of Article 6(3)(b) of the End-of-Life Vehicle Directive.
- Metal shredder residue (MSR) will be hazardous, and therefore, disposal will be more expensive, and the cost will be passed on to ELV dismantlers.
- Increased metal shredder residue (MSR) disposal costs translate into lower scrap prices.
Airbags and pyrotechnics: a growing depollution concern
One significant concern is that some ELV dismantlers are failing to remove or detonate (neutralise) airbags and other pyrotechnic safety devices from ELVs during the depollution process. This is a requirement of the depollution process and of all ELV dismantling permits and is contrary to the requirements of Article 6 of the ELV Directive.
What ELV operators should do if unsure
While this has always been a clear requirement, we have been made aware that this non-compliant practice appears to be more commonplace across the sector.
We ask operators to be aware of the need to fully depollute vehicles and the consequences of failing to do so.
If you are unsure of any of the rules relating to your environmental permits, please contact your local Environment Agency office for guidance via our National Customer Contact Centre on 03708 506 506.
Further reading on ATF Professional
-
EA launches consultation on new waste motor vehicle permit rules
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Cracking Down on Waste Crime: Key Takeaways from the EA’s 2024–25 Chief Regulator’s Report
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Preventing Scrapyard Fires: Essential Information for Authorised Treatment Facilities
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How EVs add complexity to the depollution and dismantling process



