In response to the proposed European Regulation on End-of-Life Vehicles by the European Commission, Manuel Kindelan, the General Director of SIGRAUTO has articulated significant concerns and suggested modifications for various articles.
The initial proposal, titled “European Regulation on Circularity Requirements for the Design of Vehicles and the Management of End-of-Life Vehicles,” has undergone a thorough public consultation process since its publication on July 13, 2023. The proposed regulation aims to replace Directive 2000/53 and has garnered significant attention and feedback from various stakeholders during the comment period, which concluded on December 4.
A Proposal for a Regulation that Could Be Improved:
The proposal has received widespread commentary, with 874 submissions during the consultation period. Notably, citizens from Finland, Sweden, and Poland, along with business associations, companies, NGOs, and a few public authorities, expressed their opinions. Among the various concerns and suggestions, SIGRAUTO, after careful analysis, highlights key aspects in the proposed regulation that require modification.
Key Points for Modification:
Article 3: Alarm about the Criteria for Determining a Vehicle’s Irreparability:
Citizens from specific countries raise concerns about the definition of “end-of-life vehicle” in Article 3. They advocate for a more reasonable approach, expressing worries that the criteria for determining irreparability are too restrictive. The call is for a balanced approach allowing citizens to replace faulty components without rendering the entire vehicle irreparable.
Article 6: Flexible Minimum Content of Recycled Plastic for New Vehicles:
Stakeholders argue that the proposed regulation’s goals for the minimum content of recycled plastic in new vehicles are overly ambitious. Recommendations include incorporating chemical recycling and pre-consumer waste to achieve these objectives. Concerns are raised about recycling older plastics and the need for measures to enable their incorporation into new vehicles.
Article 20: No Need for a Financial Contribution from Producers:
Many participants assert that end-of-life vehicles have a positive market value, questioning the necessity for financial contributions from producers. Emphasis is placed on the competitive nature of the market, with concerns about potential infringements on competition laws.
Article 23: Limiting the Role of Collection Points:
Broad consensus emerges against the inclusion of “collection points” in the regulation. Participants argue that, given the coverage of Authorized Treatment Centers (CATs) across the EU, collection points add unnecessary complexity. Suggestions include limiting collection points to exceptional cases in isolated territories without CAT services.
Article 24: Controversy Over the Free Delivery of Electric Vehicles Without Batteries:
Concerns are raised about Article 24, which mandates the free delivery of end-of-life electric vehicles to CATs for the last owner. Consensus suggests potential risks, emphasizing that battery removal should occur at CATs due to the specialized equipment and training required.
Article 30: Demand-Driven Removal of Parts in CATs:
Business associations unanimously agree that the mandatory removal of parts is not environmentally optimal. Suggestions include making part removal demand-driven, maintaining technological neutrality for recycling, and granting exemptions based on demonstrating recovery in post-fragmentation processes.
SIGRAUTO outlines these main concerns and proposed modifications in response to the proposed Regulation. The organization remains committed to closely monitoring the development of the Regulation and advocating for its position. For detailed information, interested parties can refer to SIGRAUTO’s comprehensive position document.
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