French organisation, Mobilians, the main movement of entrepreneurs in the mobility industry, including vehicle trade, fuel and new energy distribution, repair, recycling and all automotive services, to file an appeal with the Conseil d’Etat against the new ELV (VHU) decree in relation to reuse vehicle parts.
Each year, more than 1.3 million end-of-life vehicles are handled by the ATFs to ensure their administrative and physical destruction. These centers, holders of prefectural approvals, take charge of ELVs (end-of-life vehicles) in compliance with environmental rules to clean them up and recover the parts resulting from their dismantling. The sector makes it possible to produce more than 12 million reused parts annually, which makes ATFs the essential link in the vehicle’s circular economy.
However, 400,000 of these vehicles are not subject to any recovery of reused parts . Once depolluted, these vehicles are directly redirected to the shredder to be recycled. Therefore, a third of all the vehicles destroyed annually disregard the principle of the hierarchy of waste treatment methods.
In order to restore ambitious circular economy objectives, Mobilians advocated throughout the consultation process relating to the draft decree on the management of ELVs and extended producer responsibility (EPR) for an obligation for ATFs to produce reusable parts. A very large majority of players voted in favor of this principle, an advisory vote in the EPR inter-sector commission (In French “CifREP”) having even adopted this obligation (18 votes in favor, one abstention, four votes against).
However, against all expectations, and despite this majority vote, the ELV decree published on 1st December 2022 did not take up this principle. The text thus specifies that the ATF corresponds to “any natural or legal person who ensures the reception, storage, depollution, dismantling of parts or disassembly, including cutting and compacting, of end-of-life vehicles for further processing”.
It is clear that the concept of disassembly is not defined and can be interpreted in different ways. This activity consists, in practice, in “tearing” the various pieces of equipment from the ELV in order to sort them by material. Therefore, no subsequent reuse of equipment from the ELVs, which have thus been “ripped off”, can be carried out.
As a result, the decree, as published, does not make it possible to respond to the major challenge of developing reuse and does not respect the hierarchy of waste treatment methods, which consists primarily of favoring repair and reuse over other methods of valuation.
In the context of a shortage of reused parts, it would, however, be absolutely necessary to increase this market today by registering an obligation for the production of parts by approved ELV centres.
For all these reasons, Mobilians has decided to file an appeal with the Conseil d’Etat against the new VHU decree.
MOBILIANS is the first movement of business leaders in the automotive trade and repair and mobility services: cars, motorcycles, bicycles, industrial vehicles, scooters, etc. Our professional organization represents nearly 160,000 local businesses and 500,000 non-relocatable jobs throughout France. MOBILIANS defends the individual and collective interests of road mobility professionals and supports them in the development of their professions. It deploys a prospective action for sustainable development and the promotion of individual or shared mobility in conjunction with all stakeholders.
 Ademe report, ELV sector observatory, 2020 data