Many times the draft Regulation was a topic in Egara’s articles. Long story short: The European Commission expects the new regulation will be published before the summer. Before it is adopted, the text needs to be agreed about by the European Parliament and the European Council. At this moment the text is being consolidated by the EC. All amendments and advises need to be included in the text, contradictions within the text and with other legislation need to be taken out, so the ELV team is quite busy with the last chores.
Final text
The big question however is: what will the final text look like? What will be the final changes in the text? What obligations need to be followed up? What restrictions will limit our business? How did the amendments turn out? What advises were taken? What contradictions were taken out and remained? Who had the most successful lobby? The making of the draft was quite a heavy birth in itself, but the following amendments by the European politicians stirred everything up to the next level.
Concerns
As Egara we are concerned about more than one topic:
- Parts not to be reused;
- Compensation for unprofitable material removal;
- Procedure how to decide parts from reuse or recycling;
- Acceptance of complete vehicles only;
- When does the Battery Regulation take over from the Vehicle regulation?
Parts not to be reused. (article 31.3)
This is about parts we have always sold like airbags, ECUs, steering houses, mufflers and emission filters. Safety nor environment suffered from this, quite the opposite is true. We keep cars on the road clean and safely for low costs. Perfectly good parts with a goal are not discarded in vain. We could live with the restriction of selling these parts to only professionals, but a ban in general serves no goal. It lowers the value of the ELV and it makes repairs on older vehicles unnecessary expensive. Perfectly good parts cannot be reused. It’s a waste of capital and environment.
Compensation for mandatory removal of unprofitable materials (article 20.1.a)
It’s not the total value of the ELV that decides compensation. Parts reuse needs to be considered apart from material reuse. We buy vehicles for parts reuse and new obligations should not disturb the market or our competitive position. We often have to pay to prevent these EVs end up at illegals. We do need to make a profit with mandatory removal, but we need to be compensated for removal of materials without a market.
Description of parts assessment is not in line with practice (article 31.1.a
Parts assessment (do we reuse or recycle?) is done at the vehicle, so it should be described correctly or not at all. We even assess a complete vehicle for parts reuse before we buy it. We do not just remove any part and then decide if we will reuse it or put it the material recycling pile. Often we need to test the part while it’s still on the vehicle and in case of resetting parts digitally it only works if we do it at the original vehicle. They will not function on another vehicle if we don’t. It’s very ineffective to first dismantle any part and then decide what to do with it and it’s simply not what we do.
No acceptance without costs for EELVs without the battery (article 24.2)
We do not see how this encourages second use. If a battery is removed without replacing it or putting it back, it’s dismantling. Only ATFs are allowed to dismantle vehicles. This article encourages illegal dismantling at dealers and workshops. They can cherry pick the best batteries and leave the remains for the ATF. We need complete vehicles. We can accept complete vehicles without costs for the last owner. It should be allowed to ask a fee for any incomplete vehicle.
When does the VR (Vehicle Regulation) apply to the battery? (article 31.1)
Until what moment does the VR apply to the Battery in al ELV and from what moment on does the Battery Regulation (BR) kick in? Point is that some countries consider every activity as ‘prepare for reuse’ (in the BR, but coming from the Waste Frame Directive), which means EPR (extended producer responsibility) shifts to a dismantler. We can understand that at this very moment, only a BR exists as the VR isn’t adopted and published yet, but why is EPR demanded from an ATF that only sells a battery for the same purpose? Nothing is changed on the battery or the purpose. We hope the text isn’t adjusted anywhere to make a battery apply to the BR before we can assess it.
A Circular and sustainable law?
Apart that these items could make life unnecessary difficult for ATFs, unnecessary ineffective counter productive restrictions on reuse do not promote or encourage a circular sustainable economy. A vehicle’s footprint becomes unnecessary big if it’s not kept roadworthy and safe with used parts; either parts are used with a potential lifespan of 20 years on a vehicle with only 5, or a vehicle that could serve for a few years is written off prematurely as it’s too expensive to repair or maintain it with new parts, while used ones are plenty available. In the amendments of past year, we saw some important items disappear or limited, so we are very curious to see the final text and if member states will respond to these matters in the last round.
EGARA hopes for the best and continues to inform any possible ally for our course.
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