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Illegal ELV exports from the EU – a serious concern

A study commissioned by the German Federal Environment Agency shows that between 3.4 million to 4.7 million end-of-life vehicles (ELVs) are exported illegally from the EU every year.

Illegal ELV exports from the EU - a serious concern two

With 3.4 – 4.7 million end-of-life vehicles disappear with unknown destination from the EU per year or are illegally disposed of and tremendous environmental damage due to improper disposal, a policy needs to introduce mandatory registration and deregistration systems and financial incentives for take-back and recycling are necessary.

Manfred Födinger, Managing Director of Scholz Rohstoffhandel, an Austria based scrap metal company said: “Current statistics from Eurostat confirm what also applies to the Austrian market.” He added: “The unknown whereabouts of end-of-life vehicles have been at a high level for decades, politics and authorities are still inactive”. 

The German Federal Environment Agency has drawn attention to these undesirable developments in a scientific paper1 and suggested some helpful approaches to solving the problem. As many as 6 million. end-of-life vehicles are dismantled and recycled in 13,000 treatment plants in the EU every year, but the fate of a further 3.4 – 4.7 million end-of-life vehicles is unclear. 

“We must assume that more than 4 million tonnes of valuable raw materials are lost to European industry. Plant capacities in the EU are definitely not being fully utilised and we urgently need political support,” continued Födinger. 

The environmental damage is immense according to the mentioned survey and on the basis of previous studies2. The improper and professional disposal of end-of-life vehicles releases between 20 and 55 million litres of hazardous liquids into the environment each year. In 2017 alone, illegal dismantling of end-of-life vehicles released around 630 tonnes of refrigerant, causing ozone-depleting emissions of around 900,000 COequivalents. In addition, Member States suffer immense fiscal damage when end-of-life vehicles are treated in unauthorised facilities. 

In order to improve the current situation, numerous measures are proposed, which are fully supported by the Austrian recycling industry. In particular, the proposal for compulsory deregistration – as opposed to temporary immobilisation – coupled with proof of recovery can lead to a significant improvement in the tracking of end-of-life vehicles throughout Europe.

“In times of increasing digitalisation, it is high time to have a harmonised electronic registration and deregistration system in the EU,” said Födinger. “It should also be possible to exchange data within Europe on the whereabouts of end-of-life vehicles and on registration and deregistration on this basis”. 

1 Umweltbundesamt (Authors: Kitazume, C., Kohlmeyer, R. and Oehme, I.) 2020, Effectively tackling the issue of millions of vehicles with unknown whereabouts. 

2 Mehlhart, G., and Kosinska, I., 2017, Assessment of the implementation of Directive 2000/53/EU on end-of-life vehicles (the ELV Directive) with emphasis on the end of life vehicles of unknown whereabouts. 

The above-mentioned studies have shown that the introduction of financial incentives for the collection and dismantling of end-of-life vehicles – current practice in some Member States (e.g. the Netherlands) – leads to a significant reduction of illegal exports from the EU. 

Enforcement and monitoring problems are known to exist in all Member States, partly due to the difficulty in defining the terms “used car” and “end-of-life vehicle”. If a used car is involved, waste legislation is not applicable and no waste permits are required for exports from the EU. Austria is already following a successful special path in this respect. The so- called “repair certificate” has been in existence for some years now, which practically proves the existence of a used car. 

In 2015, a decision of the Austrian Administrative Court of the highest instance on the distinction between a used car and an end-of-life vehicle – the latter being classified as waste – was issued. At that time, three essential parameters were identified which will ultimately determine whether waste is present or not: registration capability, operational readiness and intended use. This was translated into regulatory measures. Thus, if no repair certificate is available, the export of this “end-of-life vehicle” is not possible without prior official approval. 

“However, the official confiscation of an end-of-life vehicle without a repair certificate is not easy from a legal point of view, so it has to be legally adapted in individual cases in the Member States and things are not yet running optimally in Austria either,” said Walter Kletzmayr, Managing Director of the Austrian Shredder Association. “The Austrian system should nevertheless set an example and can serve as a model for the entire EU in establishing a digital registration and deregistration system in the future”. 

The EU Commission is, therefore, requested to deal with these proposals as soon as possible in the revision of the End-of-Life Vehicles Directive (2000/53/EC). 

“Resource efficiency and climate protection are important goals for the implementation of the European Green Deal. And especially under the effects of the corona crisis, we should not lose sight of jobs in the recycling industry,” demands Födinger. 

The International Automobile Congress will also be held in Geneva at the beginning of September, where stakeholders and representatives of the authorities will meet to exchange views. There will be some opportunity to discuss the proposed measures and other possible solutions in a broader context with various stakeholders. 


Manfred Födinger, Managing Director, Scholz Rohstoffhandel GmbH 
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Dr. Beate Kummer Kummer:Umweltkommunikation GmbH 
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