Paul Downing, Environmental Consultant provides us with information on environmental permits relating to eBay and the requirements of registering as an Authorised Treatment Facility.
Whilst the majority of clients I work with are traditional breakers yards with on-site stores and sales offices, there are also a growing number of traders in end of life vehicles (ELVs) and car spare parts who have an online presence such as an eBay shop. I have recently been made aware by several clients who I am preparing environmental permits for that they have been visited by the Environment Agency (EA) after their sale of ELVs or vehicle spare parts was reviewed on eBay by the EA and their dismantling operation location was identified and subsequently visited by the local EA enforcement officer.
In order to become a registered Authorised Treatment Facility for the depollution and dismantling of vehicles you have to be in possession of an environmental permit which is issued by the EA. The application process is not straight forward and you have to demonstrate that your activity and the facility is managed in such a way that it poses no risk to the environment via oil leaks, fires, waste, noise and vibration, air quality or nuisance. The determination period for a standard rules permit may be up to 6 months with larger more complex bespoke permit applications taking a year or more before all issues are fully bottomed out and the permit is issued. The standard determination times on the EA website are the lengths of time the EA takes to determine the permit not the time it takes you to answer their questions or produce additional surveys or reports after the permit is “duly made” hence the additional timescales.
As a business registered with eBay you have to confirm that your vehicle has been depolluted at a registered ATF (if you are selling spare parts) or that you hold a permit to dismantle the vehicle and sell the parts on and are a registered ATF yourself. An ELV is classified as an ELV as soon as a certificate of destruction (CoD) has been issued to the seller of the vehicle via the DVLA management system or as soon as the vehicle is taken off the road and no longer used for its intended purpose (transport) and is to be dismantled into its constituent parts. If you or the ATF fail to depollute the vehicle in accordance to DEFRA (Department for the Environment & Rural Affairs) then it will be classed as hazardous waste and substantial fines and penalties may be incurred for the storage/transfer of hazardous waste illegally.
If you are looking to sell vehicles or vehicle parts online as part of a depollution or dismantling facility, make sure you are aware of the permits and licences that you have to comply with before you also get an unexpected visit from the Environment Agency.
For more information call Paul on 07790147084 or visit www.pauldowningltd.co.uk