The recent proposal for a European Regulation on end-of-life vehicles (ELVs) is raising controversy since it may seem that what it seeks is to force vehicles to be scrapped rather than repaired, but what is true? Manuel Kindelan, General Director of SIGRAUTO, the Spanish Association for the Environmental Treatment of End-of-Use Vehicles, provides his opinion on the intentions behind the proposal.
On July 13, 2023, the proposal for a “European Regulation on circularity requirements for vehicle design and management of end-of-life vehicles” was published, with which the European Commission intends, and I sincerely believe that this will be the case improving the current regulations that have produced such good results in the more than 20 years that they have been in force. From the moment of its publication, a controversy has arisen, both in the traditional media and on social networks, considering that with this proposal, the European Union intends to force citizens to scrap their old vehicles by prohibiting them from repairing them in cases in which the vehicle requires replacement of the engine or gearbox or have excessively worn steering or brakes.
Having been involved in the entire discussion process that led to the proposed text, it is clear to me, and the European Commission itself has already clarified that this proposal pursues the opposite of forced scrapping. But then, what does the Commission really want?
If I had to summarize, I would say that the main objectives pursued by the Commission are:
Treat more: the proposal seeks to prevent vehicles ending up in “unknown whereabouts” by establishing measures to ensure that they are delivered to authorized treatment facilities (ATFs) for ELVs that have all the technical means, personnel and facilities necessary to provide adequate environmental treatment to the vehicles they receive.
Treat better: the aim is to ensure that the management and treatment of ELVs not only does not have negative impacts on the environment but also helps to avoid them by making the most of the resources they contain.
Treat all vehicles: until now, the regulations applied only to passenger cars and light commercial vehicles, and the proposal seeks to extend its scope to all vehicles, including heavy industrial vehicles and motorcycles.
Promote circular design: in the production phase, the aim is to integrate circularity criteria into the design of vehicles, encouraging the use of recycled materials and facilitating disassembly for reuse, recycling and recovery of materials from ELVs.
It is important to note that, thanks to the close collaboration between the sectors involved in the management and treatment of ELVs and the administration, Spain has one of the most advanced regulations in the European Union that already contemplates great part of the measures being considered in the new proposal. As a consequence, Spain treats more because it has a system that guarantees delivery to authorized facilities, and there are no vehicles with unknown whereabouts, it treats better since it has a very high-level infrastructure where the operations provided for in the proposal are carried out and it already treats all vehicles since years ago there is the obligation for the last owner to deliver them to authorized facilities. This places our country as one of the most advanced in all of Europe in this area. The automobile sector in Spain produces a lot of vehicles and well produced, distributes a lot of vehicles and well distributed, repairs a lot of vehicles and well repaired and recycles a lot of vehicles and well recycled.
Taking into account our situation, it is important that the new proposal does not affect us negatively, and that is why we are working so that the text, which has a good number of interesting measures correct some aspects that could be improved, such as:
More clarity regarding the application of irreparability criteria: the text should establish more clearly that these criteria should only be applied to the export of vehicles to avoid the shipment of waste disguised as used vehicles. This is one of the main problems that the European Commission wants to correct and it is necessary that customs authorities have criteria that allow them to deny exports in these cases.
Flexibility in the recycled plastic content: the ambitious objectives for the minimum recycled plastic content, which require that 25% of the plastics used in the manufacture of new vehicles must come from the recycling of post-consumer plastic waste and that 25% of this plastic waste must come from the ELVs, they could be more realistic if they are made more flexible, allowing chemical recycling and pre-consumer waste (mainly production rejects) to be included.
Reconsideration of financial contributions: given that ELVs are waste with positive market value, the imposition of financial contributions by producers should be reviewed as they could lead to distortions of competition in this market.
The removal of parts must be governed by market demand: the text establishes that ATFs must compulsorily remove a long list of parts and components from all vehicles they receive to evaluate their possibilities for reuse, remanufacturing, reconditioning, recycling or valuation. My opinion, shared by practically all the entities that have commented on the text, is that the extraction of parts should be based on market demand, maintaining technological neutrality and thus allowing increasingly efficient recovery processes to continue to be developed by post-shredding facilities.
In summary, it is essential that the Regulation clearly reflects its objectives and promotes sustainable practices but without imposing unnecessary burdens on producers and citizens or on current authorized vehicle treatment operators. This review process represents an opportunity to improve and strengthen regulations while maintaining an appropriate balance between environmental objectives and market efficiency.
This article wasa originally published at neomotor.epe.es
