Piotr Barczak, Senior Policy Officer for Waste of the European Environmental Bureau (EEB), based in Brussels, provides reasons why the upcoming revision of the ELV Directive must be brought in line with the EU’s European Green Deal in order to improve the circularity of the automotive sector.
End-of-Life Vehicles (ELVs) amount to 8 million tonnes in the EU a year and raise several environmental challenges for EU governments. Large amounts of waste could be cut down if national authorities put in place the right policies and followed the Waste Management Hierarchy outlined in the EU’s Circular Economy strategy. According to this strategy, waste streams should be tackled at the source by improving the design of vehicles at the production stage, which would help reduce most of the environmental impact of ELVs, notably by incentivising durability and repairability, facilitating recycling and avoiding the circulation of toxic substances.
The European Environmental Bureau with its members outlines several recommendations that can help the automotive sector move towards more responsible and circular business models and bring it in line with the EU’s overarching European Green Deal.
Starting from the designer’s table, greater attention will need to be given to how the design of vehicles can influence their full life-cycle impacts. Eco-design style measures already applied in other product groups, e.g. the Essential Requirements for the PPWD in the case of packaging, and the Eco-design Directive for energy-using products, demonstrate that minimum requirements can support broader material and energy efficiency objectives. It might be particularly important in the time of the transition towards zero-emission vehicles, where design for reuse, remanufacturing, refurbishment, repair and recycling will become more important than ever.
Eco-design measures for EV’s batteries are expected to be developed during the revision of the Batteries Directive. However, these measures will not address other parts of the vehicle, such as chassis, vehicle management system, etc. where extending mileage before the end of life of vehicles may present the most desirable option from a climate and environmental perspective.
Regarding material loops, it is already at the design stage one has to think about a harmonised product passport to facilitate the information flow from producer to recycler; a product information system shall be established in the form of an inventory of substances of concern, building on the existing sector database of the sector and supported by the new ECHA database. Such a product passport should contain the full bill of materials, key performances of the vehicle, durability, repairability, life-cycle environmental footprint and chemicals content, to improve dismantling of the problematic substances (ie PVC, PU, Batteries etc). A similar inventory requirement exists in the EU Ship Recycling Regulation.
Additionally, the Directive’s provisions regarding safe pretreatment of components containing hazardous substances should be made stricter.
The ELV Directive should better reflect the Waste Management Hierarchy, where prevention is the top priority, followed by reuse. The current target does not give enough attention to such activities as reuse or preparation for reuse. Not only should this difference from recycling be visible in reporting the rates, but also a separate mandatory target for reuse should be considered to incentivise this activity. The rules to incentivise reuse should also be harmonised across the EU to avoid market distortions.
We recommend binding requirements to ensure non-destructive disassembly and removal of all reusable modules from the vehicle before shredding, and to store them safely for reuse. The easiness and economic feasibility of dismantling before shredding depend on design for dismantling, therefore that should also be one of the minimum requirements for the design stage. Appropriate dismantling of layers and modules will also facilitate quality recycling. It also depends on a functioning IDIS (International Dismantling Information System).
After reuse comes recycling. The calculation methodology for the targets should be clear and the same across all Member States to better reflect the progress of the sector in terms of reuse and recycling and to make data more reliable and comparative. Any double calculation in two different registries should be avoided. Any residues coming from recycling operations should be deducted in order to avoid inaccurate inflating of reported rates.
Additionally, a target for recovery should be taken out of the Directive. Reuse and recycling provisions should be better enforced, while recovery term is redundant and only drives incineration of materials, which does not improve the circularity of the sector.
The recycling target today is high but does not incentivise the recycling of specific materials. It can be easily achieved by recycling the easiest to recycle materials (i.e. steel). To ensure recycling of other materials, especially light-weight critical raw materials it should be considered to set material specific recycling targets rather than overall weight-based targets. Lastly, the vague definition and calculation of recycling and recovery opens door to much incineration and backfilling of ELV materials that should instead be dismantled and recycled. This loophole is crucial to amend to bring the automotive sector closer to the circular economy.
Hand in hand with recycling requirements goes recycled content. The revision of the Directive could set a mandatory recycled content rate. Such a target could be differentiated per material and staged over 2025 and then 2030 years. The uptake of recycled contents should ensure the same standards apply for recycled materials as for virgin materials with regards to performance and chemical contents, and the potential incentives and obligations should clearly refer to this.
Lastly, the revision of the ELV Directive should align closely with the upcoming revision of the Batteries Directive, as the market continues to experience rapid growth in electric vehicles use and related use of batteries. The revision of the ELV Directive should set appropriate rules on dismantling and repair information (IDIS) provided to end-of-life users by the producers and enable second life for batteries from ELVs.
The revision of ELVs should remediate some identified implementation gaps and remaining legal uncertainties. Without entering the detailed description of those issues largely covered by existing studies, the main implementation difficulties should, however, be reminded and built upon to ensure the improvements suggested along the above directions would be properly formulated and associated with the relevant conditions to enhance their implementation and enforcement.
Alternatively, Piotr will be speaking at BCF’s, 3rd Annual Vehicle Recycling Conference that will take place online from the 15th – 16th October 2020.