Vehicle traceability – The importance of continuous registration of vehicle ownership

EGARA says EU vehicle traceability depends on continuous ownership registration, tied to obligations such as tax, insurance, and roadworthiness, so every vehicle has a responsible keeper at all times. Without it, vehicles can drop out of registration, contributing to 10–12 million deregistrations a year, and over a third have unknown whereabouts, weakening ELV enforcement and recycling reporting.

Stacked end-of-life vehicles in a scrapyard, illustrating the need for traceability and continuous ownership registration — Image credit: Shutterstock

Vehicle traceability starts with one basic principle: someone must be responsible for every vehicle at all times. In this statement, Henk Jan Nix, Secretary of the European Group of Automotive Recycling Associations (EGARA), argues that this requires continuous registration of vehicle ownership across the EU, linked to key vehicle obligations such as taxation, roadworthiness and insurance. Without that continuity, vehicles can drop out of national registers with little consequence, fueling the “unknown whereabouts” problem and undermining efforts to bring ELVs into the regulated, authorised treatment system.

EGARA often advocated continuous registration of vehicle ownership throughout the whole EU, combined with vehicle obligations (tax, roadworthiness and insurance).

Many (most) systems allow vehicles to leave at any moment without any consequences for the owner. This makes vehicles disappear into the illegal sector if they do not reappear. Only CODs (or, in the worst case, export outside the EU) should end vehicle registration. It seems this was in a commission proposal to update the Registration Directive, which is very good and which we support, but appears to have been erased in a council proposal on the same vehicle registration directive. Deleting this element would seriously affect traceability.

Unknown whereabouts

The figure below is not the most recent, but it shows that every year, 10-12 million vehicles leave registration systems permanently, of which more than a third have unknown whereabouts.

Traceability in the Registration Directive

Article 6e specifically describes the continuous traceability of vehicles, as vehicle registers shall include information on any change in vehicle ownership. Someone needs to be responsible for a vehicle at all times. Article 6a seems to have been erased in a council’s proposal. It would seriously affect traceability if this element is deleted, as only temporary deregistration is provided for in the council proposal (proposed article 8a). This way, any other reason for deregistration means the vehicle is out of sight again.

Deregistration

If it were up to EGARA, a vehicle could only be deregistered permanently from a national system if:

A COD is issued;
A vehicle is re-registered in another national vehicle register.

Keeper/ownership

What is really important to solve is the limbo a vehicle is in when exported and not re-registered (yet) somewhere. After being registered as exported, it must be possible to keep track of the vehicle’s whereabouts and who is the owner/keeper/responsible for it. Export itself shouldn’t be banned; misuse of export as a legal route to escape registration and oversight should be. The problem arises when export is used to remove vehicles from national registers without ensuring re-registration and ongoing responsibility. Registration systems of member states need to be able to connect. These issues are not solved in the Commission proposal nor in the Council’s.

Suspension/Temporary deregistration

EGARA can support the technical definitions of suspension (as a result of being not roadworthy) or temporary deregistration (the owner is still responsible, but as the vehicle is not in use, it’s exempt from vehicle obligations). But in both cases, someone is always responsible for the vehicle. We would even suggest connecting some incentives to these statuses, like an annual fee and renewal, to prevent eternal temporary deregistration or suspension.

Continuous registration

EGARA hopes the EU is wise enough to recognize the necessity of a closed, continuous registration system in every member state. Elaborate laws are being made to process ELVs (End-of-Life Vehicles) responsibly, but this starts with bringing all ELVs within scope. As long as more than a third of vehicles are missing because of unknown whereabouts, reporting on recycling is futile.

For the complete commission proposal, click here.