Amélie Sophie Salau, Environmental Policy Director for the European Automobile Manufacturers’ Association (ACEA) provided us with an overall impression of the common position of the automotive industry with regard to the upcoming revision of the ELV Directive.
This month we are waiting for the evaluation by the European Commission of the End-of-Life Directive (ELV). But before we see the official document – what are your views? Is the ELV Directive already a success story?
Indeed, the European ELV recycling process is one of the most advanced and effective systems for the recycling of complex consumer products around the world. Over the last 20 years, this successful collaboration between stakeholders from across the whole EU value chain – ranging from vehicle manufacturers to recycling companies – has delivered significant achievements, such as:
- Cost-free take-back of vehicles for customers.
- Reuse and recycling rates of at least 85% for some of the most complex consumer products.
- No more abandoned end-of-life vehicles in Europe.
- A high number of authorised treatment facilities (ATFs) with certified environmental requirements in Europe.
- The use of hazardous substances has been either stopped or minimised to the technical limit.
- The EU has become a global driver for innovation in ELV treatment technologies, such as post-shredder processes.
- We now see the proper recycling/recovery of many different material streams, including the ones of negative value.
- The provision of comprehensive dismantling information for the recycling industry by means of the International Dismantling Information System (IDIS).
Do you also see some room for improvement?
First of all, it is important to underline that this review should not lead to new legal measures that could jeopardise the overall success of the existing system. Instead, the review should focus on improving the implementation and enforcement of current legislation in the member states, while reinforcing the progress already made by all stakeholders in the value chain.
How does the ELV Directive work today?
As part of the ELV Directive, all economic operators must set up systems for the collection, treatment and recovery of end-of-life vehicles (ELVs). Vehicle manufacturers take responsibility for the substitution of hazardous substances and for the cost-free delivery of all ELVs to authorised treatment facilities (ATFs), ie dismantlers and/or recyclers. ATFs organise the take-back, ensure the environmentally sound treatment of ELVs and make sure that recycling and recovery quotas are met and monitored.
Is this a self-sustaining business?
Based on this regime, the take-back and treatment of ELVs is generally a self-sustaining business model. The value of an ELV sufficiently covers the cost of all necessary treatment steps throughout the entire recycling value chain. This includes automotive and industrial batteries that are collected together with the ELV.
Who is responsible to hand over the car to the ATF?
It is the legal obligation of a vehicle’s last owner not to abandon it at the end of life, but to hand it over to an ATF, where it must be processed in an environmentally sound manner. ACEA does not support schemes that would financially incentivise the last owner or economic operators to fulfil their legal obligations. Such measures would be counter-productive as they would financially reward the fulfilment of a legal duty instead of penalising legal misconduct.
Let me come back to the point of legal enforcement – what should be considered?
The success of the European ELV recycling system is not only driven by technological solutions but also depends on economic factors, particularly on the rate of ELVs that end up at ATFs. However, due to insufficient enforcement of the existing legal provisions by authorities, a considerable number of ELVs are currently treated by unauthorised operators. These illegal recycling activities prevent legal operators from accessing valuable resources, thereby not only jeopardising their business model but also the overall legal basis of the recycling value chain.
ACEA believes that better implementation and enforcement, through the surveillance of ATFs by competent authorities, is needed to ensure a level playing field and to bring an end to these illegal practices. Today, ATFs must obtain a permit from, or have to be registered by, the competent authorities, as stipulated by article 6.2 of the ELV Directive. In the future, however, this should be complemented by an EU-wide, harmonised system/database for the registration and de-registration of vehicles, covering all member states.
But isn’t it the last owner who is responsible to hand over the car – so shouldn’t he or she be empowered to do so?
Indeed, better enforcement should also include an obligation for the last owner to provide a Certificate of Destruction (CoD) to complete the de-registration of a vehicle. The only entity with the power to issue such a CoD should be an ATF. This method of enforcement could be further strengthened by obliging the last owner to keep paying insurance fees and/or vehicle taxes until the CoD is submitted to the competent authorities. Good examples of how such procedures work can already be found in the Netherlands and the Czech Republic.
Is the European Green Deal promoting a more circular economy, and with this to a more circular ELV directive?
The European Green Deal, with its circular approach, prioritises the reduction and reuse of materials before recycling. It has always been the automobile industry’s goal to design vehicles that not only can be used as long as possible, but that also are reusable, repairable and recyclable to the highest possible degree. The success of our industry’s approach is demonstrated by the fact that the average age of an ELV, according to national authorities, is 14 to 20 years, which is much higher than many other consumer products.
So if I understand you correctly the longevity of the product is actively supported?
Indeed, longevity is supported through the comprehensive re-manufacturing programmes of ACEA’s member companies. These programmes exist for engines, transmissions and electronic components for instance. Moreover, dismantling and further reuse is possible for a significant number of parts, which is supported by detailed dismantling and treatment information provided by manufacturers via IDIS and other systems.
So if we take a closer look at the automotive recycling chain, what are the results?
The automotive recycling chain already delivers outstanding results. The average recycling rate of >85% for passenger cars is proof of environmentally-sound vehicle design and the strong ELV processes in place, especially knowing that cars are some of the most complex consumer products placed on the European market. An additional 10% of the remaining materials, which are not easily recyclable, are energetically recovered – resulting in an overall reuse and recovery rate of about 95%. Indeed, not more than 5% of inert vehicle materials end up in landfills.
Will material-specific recycling targets provide any improvement?
In the industry’s view, material-specific recycling targets will not provide any improvement with regard to the overall quota, nor for the environment. Moreover, it is important to recognise that both the measurement and monitoring of material-specific quotas will be methodologically and technically very challenging, not to mention economically questionable. Consequently, new legal requirements for changes in design will not facilitate more dismantling or recycling, but instead will only increase the economic cost of the material or the part.
Do you think that assessing every single material stream would be an improvement?
ACEA believes that a vehicle must be considered as one single product because customers buy vehicles as a product for its complete functionality with all its characteristics. In addition, the recycling industry treats vehicles holistically, since treatment and recycling of an entire ELV is a profitable business. Changing this approach to assess every single material stream individually may lead to incorrect conclusions, as the valuable material fractions, in any case, exceed the negative fractions and thus subsidise the entire process.