The Federal Association of German Steel Recycling and Waste Management Companies (BDSV), the Federal Association of Secondary Raw Materials and Waste Disposal (bvse) and the Association of German Metal Dealers and Recyclers (VDM) are jointly commenting on the planned new regulation of the EU End-of-Life Vehicles Regulation (ELV).
The associations fundamentally support the European Commission’s goal of promoting the circular economy in the vehicle sector by reusing spare parts more efficiently and improving recycling.
The recycling associations rate the planned measure particularly positively, according to which it will no longer be possible to deregister the vehicle without proof of recycling in the future. This step is considered an effective measure against the illegal shipment of end-of-life vehicles. The planned and increased checks, which are intended to ensure that a vehicle exported is actually a used vehicle or an end-of-life vehicle, are also viewed positively. However, recycling associations emphasize the need for consistent implementation of these controls in order to effectively curb the illegal shipment of end-of-life vehicles. In addition, the associations are in favor of a ban on the shipment of end-of-life vehicles, which constitute hazardous waste, outside the Union.
A central point of the statement relates to the recycling targets for new vehicles. The associations generally support the mandatory use of recyclates in the production of new vehicles. However, they criticize that the prescribed quotas for manufacturers are lower than for recyclers, which is not in line with the goal of expanded producer responsibility. The associations argue that manufacturers should be held more accountable by choosing a vehicle design that enables a higher proportion of plastic recyclates from end-of-life vehicles.
The planned greater producer responsibility is fundamentally supported by the associations. However, they point out that in some crucial points, this responsibility is transferred to the end-of-life vehicle recyclers. The recycling associations consider this to be unjustified, especially given the economic imbalance between internationally active manufacturers and small/medium-sized car recyclers.
BDSV, bvse and VDM also criticize certain requirements for end-of-life vehicle recyclers, particularly with regard to the removal of vehicle parts before shredding. They point out that when removing parts, especially from accident vehicles, both technical and economic reasonableness must be taken into account.
However, the current formulation of cost assumptions by manufacturers is viewed as inadequate. The associations are, therefore, calling for a clear definition of the costs for the mandatory removal of vehicle parts and the possibility for recyclers to claim higher costs depending on the condition of the vehicle.
The planned establishment of organizations by manufacturers raises questions about the appropriate representation of manufacturers and waste managers. The associations advocate that there should be equal participation in the performance committees, whereby the decentralized structure of waste managers should also be taken into account.
The operation of collection points for end-of-life vehicles by waste managers is viewed as a risk of abuse. The associations are in favor of this task being reserved for approved recycling facilities. The associations also point out the unclear cost regulations for vehicles that are located within the EU but whose manufacturers are not based in the EU. Further clarification is required here as the obligations of producer responsibility do not apply.
BDSV, bvse and VDM point out that the end-of-life vehicle regulation should adequately take into account the problem of vehicles for which there is no manufacturer responsibility (e.g. electric cars from China) and for which no information is available. The associations demand that the regulation only apply to vehicles for which manufacturer information is available, and the manufacturers contribute financially to the costs.
The associations reject the planned guarantee obligation of end-of-life vehicle recyclers when selling spare parts because it goes far beyond what sellers of new goods have to guarantee. Basically, recycling is only economically feasible without any guarantee.
The three recycling associations are committed to ensuring that their concerns and suggestions are incorporated into the ongoing discussions on end-of-life vehicle regulation and thus contribute to a practical and balanced regulation.
Source – www.bvse.de
