The European Commission’s public consultation on the evaluation of the Waste Shipment Regulation (WSR) came to a close at the end of April 2018. European Group of Automotive Recycling Associations (EGARA), put forward their views to the consultation with the Regulation No 1418/2007 taken into account.
How does waste legislation affect car dismantling? In some cases used parts are considered waste which means exporting them leads to the seizure of shipments and hefty fines. Under the right conditions, export of used parts is possible.
The reason for EGARAs contribution is so they can be involved in every decision regarding this consultation and to remain involved in the future of this matter.
Positive value needs to be taken from ELVs. Parts that would otherwise not be reused here, can be kept on the road for an affordable price once they are exported abroad.
Problems occur when officials, i.e. customs, environmental inspections or road inspections suspect shipments to be waste. Of course these used parts do not look brand new, but when care is taken to dismantle, load and register, the shipment and transportation should go smoothly. In some cases individual officials lack knowledge. These cases tend to be the easier ones to tackle, for example, parts are broken, or dismantled in a careless way, including half cuts, meaning they contain the remains of other broken parts. Parts should be ready for reuse directly.
According to Egara, it seems that the biggest problem is where countries that parts route through, have their own opinion of the waste status of parts. They consider used parts only as goods when mounted and functioning in their second life on a car. This is counterproductive to any circular economic or sustainable principle. Therefore, containers will be blocked and sent back. This is also a matter of applying the Waste Frame Regulation, but EGARA have had the opportunity to explain how this contradicts with the WSR.
It’s only logical that rules exist to avoid environmental damage by letting
waste, including ELVs disappear from enforcement by exporting it. But these rules should not be counterproductive.
EGARA made the following points:
- If implemented and carried out correctly, the WSR and Regulation 1418/2007 have a positive effect on the industry. In many cases they are not enforced at all or interpreted in a rigid way, counterproductive for parts reuse (no export or transit possible).
- Used parts trade should be possible at all times. Even prepared large body parts should be salable. No problem if conditions are reasonable and logical.
- ELVs should be processed in the country of origin and at least traceable. They should not be dumped elsewhere, disappearing in the black market or left abandoned. There’s enough capacity in every country.
- Rules should not be counterproductive and make reuse impossible (wrong/rigid interpretation) or very expensive/complicated (procedures).
- Guidelines should be clear and reasonable. Some expertise at the enforcement is demanded.
- Dismantlers should not want to ship broken parts, carelessly dismantled parts or poorly loaded containers. We ship plug and play used parts and not waste.