Some people never give up – it seems:

Polish proposal to ban re-use of certain parts proposed!

EGARA makes a complaint.

Way back in summer 2002, the Commission’s DG Enterprise – as responsible for the Type Approval Directive – held a work-shop on re-use of parts for all stakeholders. This work-shop was held as a response to a claim from CLEPA – the European umbrella membership organisation for the global Automotive Supply industry. CLEPA found that a directive which would ban re-use of a lot of components and parts + require quality certification of dismantlers, was necessary in order to avoid environment and traffic security hazards as a result of re-use. EGARA of course presented its views there, and the general conclusion of the work-shop was, that the Commission did not see any need at all for a directive.

Although CLEPA never really gave up the idea of a ban of certain parts, and has done some lobbying in order to get the subject re-introduced, we all thought that the subject was “dead” and in fact, there is not a word on ban of parts for re-use in the newly approved amendment of the Type Approval Directive. But as said in the heading: Some people never give up!

Funny enough, during the work-shop only one delegate found it necessary: The representative of the Polish government! – at that time not even a full member of the EU. So although we have all believed that the issue died then, it now appears that it did not! At least not in Poland, where the Minister for Infrastructure has issued a proposal in the context of the ELV-directive, proposing to put a ban on re-use of the following parts and components:


No Equipment and parts
1 Airbags with pyrotechnic activators, electronic control units and sensors
2 Brake pads and shoes
3 Brake lines and seals
4 Exhaust silencers
5 Steering and suspension joints
6 Car seats with integrated seatbelts and/or airbags
7 Steering wheel locking systems
8 Immobilisers and electric control transponders
9 Anti-theft and alarm devices
10 Electric and electronic components of road safety systems (in particular ABS and ASR)
11 Fuel pipes
12 Disposable filters and filter refills
13 Exhaust gas recirculation valves
14 Accelerators
15 Automatic and non-automatic seatbelt sets, including seatbelt parts made of fabric, buckles, belt retractor mechanisms and pyrotechnic and mechanical activators
16 Windscreen wiper blades
17 Working fluids, in particular motor oil, gear oil, oil for hydraulic gears, oil for hydraulic systems, cooling liquids, antifreeze, brake fluids and air-conditioning system fluids
18 Catalytic converters
19 Capacitors containing PCBs


EGARA’s view on this is of course, that if proper quality control of these equipments and parts are done, there are absolutely no hazards, and taking into account that in many countries quality certification systems have been developed, and that in particular the Polish association is working on developing a system according to the EGARA minimum standards for certification system, this piece of (proposed) legislation is not only out of line with the ELV-directive – where re-use should be encouraged – but also completely unnecessary!

We have therefore issued a position paper on this subject, which can be found at our home-page on in the document store, and sent this together with a letter to the Commission and the Polish government.

We have in the paper said that the proposed Polish legislation is out of line with the ELV-directive and is a sort of distortion of the inner market.

We simply have to protest! A Polish law may create a precedent in other countries – and that would not at all be of interest to our business – at least not to the serious and professional side of it we represent.

And we are not alone in this. The Dutch government has also complained, and in this particular case, our opinion is shared by the producers. GM has – on behalf of the producers – sent a note to the Polish minister, saying that, the Automotive Industry is of the opinion that such a list poses a threat to the recovery market. In its current content this list sets strong restrictions to the range of parts which can be reused and thereby limits the business opportunities and the economic basis of dismantlers. In particular, small and medium sized dismantling companies would only survive if they would be subsidized. We are convinced that every service station or workshop would be in the position to evaluate the condition of the parts for reuse and apply existing regulations on road safety, civil law regulations or environment.

With this in mind, there is good hope that the Polish government will “revise it ideas” and hopefully withdraw the proposal. We will keep you informed.

Lithuanian car dismantlers are in the process of establishing an association.

The Business workers Confederation of Lithuania is in the process of establishing an association for car-dismantlers, and has in this context been in contact with the EGARA-secretariat asking for help and advice on “what to do about the ELV-directive” and subsequent activities on certification etc.

As always – when such demands turn up – we offer to help them, and it seems as if the EGARA-secretary will go to Lithuania to participate in and speak at a seminar during October, as well as discussing practical items with our (new) Lithuanian colleagues. Further we have invited them to attend the forthcoming EGARA-meeting in Brussels on 18.11.2005, and invitation they have accepted.

So hopefully they manage to make a real association that then can join EGARA.

Lennart Scharff