According to recyclingportal.eu, in a letter to the Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection, and the Federal Ministry for Economic Affairs and Climate Protection in Germany, in view of the ongoing process to amend the end-of-life vehicle ordinance at European level, associations, bvse, VDM, BDSV, VDA and VDIK, are clearly opposed to the manual removal of cable harnesses and aluminum cast and wrought aluminum alloys, as repeatedly demanded by representatives of the Federal Environment Agency.
Such a regulation does not correspond to the state of the art of recycling technology, the possibilities offered by Germany as an internationally recognized industrial location would be thwarted:
“The best available technology is constantly being developed here. Due to restrictive specifications for the manual separation of materials, and thus without the possibility of alternatives to manual dismantling, we are technologically falling behind in the international standard and are lagging behind our possibilities in securing raw materials.
It is in the primary interest of the shredder operator to optimize the yield of non-ferrous metals. In particular, the aluminum cast and wrought aluminum alloys mentioned above are separated during shredding, and 100 percent of the aluminum present is separated. Using the LIBS technology, the individual cast and wrought alloys can also be separated in the subsequent process. Quantities and qualities are possible that can never be achieved with manual removal before shredding, because the variety of materials in modern vehicles makes certain manual dismantling steps completely uneconomical and, in some cases, technically impossible.
All reusable spare parts from end-of-life cars are largely obtained through manual disassembly. Extending this process to other parts only makes the process more expensive, but does not create any environmentally relevant added value. We strongly warn against ignoring existing recycling technology in the upcoming amendment. The negative experiences with the treatment ordinance within the framework of the ElektroG have shown that such micromanagement on the part of the legislator does not make it easier, but more difficult, to secure raw materials. We need framework conditions in which the closed-loop and, thus, the recycling industry can develop technically and economically for the benefit of the environment. A basic requirement for this is a certified processing chain.
Neither in Germany nor in Europe do we need backward-looking dismantling regulations.”
Source: bvse, VDM, BDSV, VDA, VDIK (association letter)