EGARA POSITION PAPER

ON

CODING STANDARDS/DISMANTLING INFORMATION

 

2002.01.15

Preamble

EGARA, the European Group of Automotive Recyclers Associations, comprising vehicle dismantlers in: Denmark, Finland, France, Ireland, Netherlands, Norway, Poland, Spain, Sweden, Switzerland and the UK, have carefully studied the ELV Directive (2000/53/EC), with special regard to Article 8 of the Directive, where it is specifically mentioned, that:

“.. producers, in concert with material and equipment manufacturers, (shall) use component and material coding standards, in particular to facilitate the identification of those components and materials which are suitable for reuse and recovery.”

In evaluating which fluids, materials, parts and components that should be identified/labelled by producers, EGARA feels that a clear distinction between materials for recycling, fluids included, and parts and components should be made, basically because the dismantlers needs for information and identification are different.

EGARA position

Introduction

In evaluating dismantlers’ needs for information and identification, EGARA has taken the viewpoint that, only on the condition that identification/labelling will facilitate a pre-sorting before further treatment, in particular shredding, that in a cost-beneficial way will lead to a higher degree of re-use and recycling, a specific identification/labelling according to an ISO-standard is necessary. With this as a basis, the following EGARA opinions are expressed.

Materials for recycling

EGARA is of the opinion, that the foreseen identification and labelling of plastics and elastomers components are satisfactory. Concerning fluids we see no distinct need for specific labelling of these. We know where they are and how to separate and store them in the pre-treatment of the elvs, and, finally, they can only be labelled on the containers in the elvs, which do not at all give any guarantees, since the car owner can have done several substitutions during the life on an elv.

Similarly, we see no distinct need for identification of glasses since, basically, with the known technologies, there is only a need to separate into laminated and non-laminated glass, a process that can easily be done without further identification. Concerning metals and metal alloys, our opinion is, that although some separation is done during the shredding process, an identification and labelling of materials could possibly lead to a higher degree of materials sorting at the pre-processing /dismantling stage, which could lead to a higher degree of recycling.

Concerning textiles, EGARA is of the opinion, that a sorting at the pre-treatment step according to different kinds of fabrics, currently not at all is cost-beneficial. Hence no labelling is currently needed. However, we are aware of that some experiments concerning seat linings are taking place, and if these turn positively out, a labelling could be beneficial.

Parts and components for re-use

Given that the information to be provided according to Article 8.4 in the directive is provided, EGARA wishes to express that increased re-use of components, with due respect to avoiding safety and environment hazards, is of paramount importance if the re-use and recycling targets in the directive should be achieved.

In this context, it would greatly stimulated re-use, at the same time reducing eventual safety and environment hazards, if it would be possible to “label” parts and components in a way that would provide information about into which car-makes and models and specific part and component fits.

The information/labelling needed would, in this context, be OEM-numbers and original numbers of the parts.

Finally, we would like to express that, the information provided by IDIS seems very promising according to dismantlers’ needs concerning dismantling information, and with further improvements in “numbering/labelling”, IDIS may become the universal tool when all cars and all details concerning numbers are in it.

EGARA

2002.01.15