The last phase of the EU law making process for the ELV/Circular vehicle Regulation has started. The Members of Parliament (MEP’s) have made the last amendments in the 3rd July version. The so called trilogues mean the European Commission (EC), European Parliament (EP) and the Counsel are negotiating about the last details of the text of the Vehicle Regulation. The first one will be on 16th October.
Influence possible
For EGARA and for all Member States (MS) this means it’s the last chance to influence the final text with zal lobbying possibilities you can think of. Why? Because in the version of 11th June and 3rd July are some differences about parts reuse and because it becomes clear what the battery regulation turns out to be for reuse of batteries.
Main points of concern
EGARA has a focus on these points, but of course there are more details and of course the situation in every country is different which means priorities can be different. But we think this covers most of the main concerns of all our members:
- All parts must be reused;
- Battery reuse including lead acid batteries;
- Definition ATF;
- PRO’s shall make contracts for all that apply to the conditions;
- Treatment and terms;
- Scam in parts sales.
Let’s highlight them a bit:
Parts not to be reused.
In the 11th June version article 31 said a group of parts (mainly safety parts like airbags and emission parts like particle filters) cannot be reused unless it was B to B. This condition is left out in the next version of 3rd July, which means these parts cannot be sold by ATFs for reuse, which is a big loss for ATFs, for circularity and sustainability and a big gain for the criminal and illegal sector. We feel it will:
- Contribute to illegals that will sell these parts anyway
- Contribute to criminality as these parts will be stolen from cars like radios in the past;
- Make the footprint of cars bigger if they have no cheap way for maintenance and repair;
- Make the footprint of cars bigger if used parts are te only source when new is no longer available;
- Make the footprint of parts bigger if they could last longer on a receiving vehicle;
- Make the footprint of parts bigger if they are new and put on a 17-year old vehicle;
- Contribute to fraude if a consumer thinks he bought a safe vehicle, but the airbags are missing and only empty covers are used to hide them;
- For sure contradict with the producers statement that there’s so much positive value in an ELV;
- If unreliable airbags like Takata are the problem, we can use the lists that are issued and avoid selling airbags that come from certain brands and series.
We hope this will be put right in the trilogues, but it will only happen if we make our contacts use the right motivations. This is a job for al of us!
Battery reuse
It seems some MS state if a battery comes from an ELV (waste), the battery is waste and the Battery applies. Taking the battery out is considered to be ‘prepare for reuse’ and as such the dismantler is regarded as a producer, complete with EPR obligations. We feel this frustrates reuse in a very undesired way. Legislation is made to be circular and sustainable, green, eco-friendly and whatever, but in the same effort rules to make this impossible apply…. This is 100% counter effective. We feel it would be so much better to follow the path in which the Vehicle Directive applies to the complete ELV, and as soon as we take out a part, it’s a product. If we take out a battery it’s not waste we take out, taking it out means it’s a product that is already fit for reuse. That would be so much more logical and if not, European legislators should find a way to make this possible again. If the goal is to make very battery a waste battery that cannot simply be reused, why do we even care?
Definition ATF
It should be avoided that shredders, dealers or collection points can act as ATFs without fulfilling the ATF obligations. The ATF is to carry out the collection and storage of end-of-life vehicles or of their parts and components, the issuance of the COD, the depollution ELVs, and the removal of parts and components and parts, where technically feasible and economically sustainable.
Contracts
OEMs and PROs should allow all to get contracts if they meet the standards. Nobody should be excluded. All contracts should be the same in an MS.
Treatment
Confusion about treatment (only depollution or complete dismantling) and terms must be avoided. It should be clear for all that depollution is done within a month and the total treatment within 3 years. Not every ELV should remain the full 3 years in a yard, but for some very young accident vehicles it is necessary to keep them longer than others.
Scam
In some countries ATFs data and identity is abused by scammers to trick consumers in buying parts that will never be sold. If the consumer complains, he ends up at the real ATF. What we hope for is stricter rule for the sales of parts coming from ELVs.
Lobby
What is necessary is to keep on lobbying at all your contacts. We need to do this as in this forcefield many powers are active and not all act in our benefit. Contact us if you need more info or help in this.
Recent Comments