EGARA had her fall meeting last November 21st in Brussels. We took the opportunity to invite Mrs. Artemis Hatzi Hull and she gladly accepted. Artemis works at DG Environment of the European Commission and is responsible for ELV matters. EGARA asked her members to send in questions that Artemis would answer. Artemis promised to also bring a presentation (available at your association) with the results and conclusions from the Fitness Check (see: )earlier this year.

Main points about the Fitness check were:

  • –  Pilot procedures against many countries are going on. Pilots mean the EC has questions for

    Member States (MS) for not fulfilling obligations or good implementation. This procedure is

    followed by infringement procedures if MS remain unwilling to change.

  • –  Some open infringements against MS are going on.
  • –  Missing vehicles and bad registration systems are an item. The EC is working on their own

    statistics and can use all info. There’s no reliable EU database, reporting will become mandatory.

  • –  Backfilling like Germany reports is an issue. The waste frame Directive and ELV Directive have

    different recycling definitions, this is taken care of.

  • –  Amendments of reporting for backfilling and figurers of current car parks, exports, COD’s and


    Main points in the members questions were:

  • –  Parts info: We can complain about producers not fulfilling Euro5/6 (parts info). We should

    however come with good eveidence of things not being right.

  • –  Deregistration figures are an issue. Figures do not match. If anyone can deliver other official

    figures than given in reports, they are very welcome.

  • –  Guidelines on export of waste. Sometimes parts are considered waste, the guidelines are not

    always used the same way. An assesment for all kinds of export is planned by the EC and for

    vehicles the guideline will be used.

  • –  5-Step waste Hierarchy: For specific things, the ELV Directive prevales above the Waste Frame

    Directive (WFD). The difference is to be discussed by lawyers. 5-Step waste hierarchy with reuse as important item in the ELV Directive contradicts with the EC answer in which producers obligations only seem to be voluntary, thus meaningless. The responsible for the Fitness Check will be asked to explain, it’s clearly not as obvious as it seems.

  • –  Used parts status: The ELV Directive prevales, second hand parts are products: it’s reuse. It’s not prevention. (That’s creating products without waste.)
  • –  Some issues are not EU issues, they are a matter of national enforcement. If the ELV Directive is implemented and implemented the right way, that’s as far as law goes. Enforcement of law is the next step. The Directive doesn’t need to be changed in this case. In case it can be proven the lack of enforcement actually happens and endangers the 95% target, a stakeholder should complain.
  • –  EGARA took the opportunity to show Artemis the shortcomings of IDIS. So far, the producers had convinced the EC and others IDIS was what dismantlers need for dismantling cars. We showed we do not need obvious info, we need parts info that’s nowhere in IDIS.

    EGARA thanks Artemis very much for her time and work. Artemis states she’s happy to be with EGARA as she receives very good field info from the industry itself. We hope to welcome Artemis again in a future meeting.