Producer responsibility and the value of an ELV
- the views are different!
After having experienced two presentations from producers about how this should be handled in practice as the producers see it:
- Joakim Halvarsson, SAAB/GM during the Nordic Congress on 6th of May in Stockholm
- Jack Uudla, AMTEL- Estonia, representing then producers/importers in Estonia, during the EGARA-meeting in Tallinn on 20th. of May
I am tempted to use an old proverb to describe the messages communicated at both events:
“A false message does not become true just be repeating it!”
To me it was striking that, at both events I saw an almost identical set of transparencies holding the message communicated by producers! And of course based on the same firm opinion:
“Every ELV has a positive value and therefore producers look for a solution until 2015 guaranteeing, that their partners will accept all ELVs at zero costs!”
Professionally this creates a good deal of respect for the car-producers and their associations: They have in an excellent way made sure that messages communicated are consistent! – a very important thing and this deserves respect! Congratulations!
But this does not necessarily make the statements true!
However, we in EGARA also consistently repeat our statement – as I did it in Stockholm, as I did it in Tallinn and as I will do it at this week’s Car Recycling Conference in Cologne, Germany – 31.05 -02.06.2005, where I will repeat:
There are cases when an ELV has a negative value, and where there are net costs as a result of following the rules of the Directive!”
Why do we in EGARA enter this “game” of repeating messages? – the reader may wonder!
The answer is simple. For years we have been throwing figures at each other, the producers saying that we – the dismantlers – are not efficient enough and therefore too expensive – and a de-pollution etc. according to the Directive can be done in 23 minutes, whereas we on our side would claim that it takes some 90 – 100 minutes, based on the data we have collected from some 100 dismantlers all over Europe.
OK – our figures are statistically weak because of the method we have used, where we have identified 26 work-operations. This method does not properly take into account that some work-operations are done in parallel, which means that the total time used will be less than the sum of individual operations. But 23 minutes v. 100 makes you reflect on what is the truth?
So if our data are statistical “thin”, why do we then use them? The answer is, that we want to get into a constructive dialogue concerning defining the value of an ELV.
Our view is:
All we need to do is to make a model for how to calculate the costs for treating an ELV according to the “rules” of the Directive, or more precisely: Its national implementations.
It is simple! All we have to agree on is:
- Which are the operations necessary in order to “treat” an ELV according to “rules”?
- How long time do these operations take to perform? – and then:
- What are the labor costs(including overheads for investments) for doing this
- What does it cost to get rid of the waste fractions?
- Which revenues can be retrieved from some waste fractions?
The equation therefore looks as follows:
Value of an ELV:
Income from (certain) waste fractions.
÷ Labour costs for de-polluting according to the Directive
÷ Costs for delivering (most) waste fractions to authorised receivers
And in the above equation, the income from an eventual sales of good quality, second hand car-parts and components, should not be taken into account!
This is basically because:
- Dismantling for re-use is a quite different process, requiring different skills, tools and working methods and being a lot more time consuming
- It is up to the individual ATF with the individual ELV to decide which parts should be dismantled for re-use
- We are forced to do the treatment operations specified in the Directive on all ELVs – whether or not parts can be dismantled for re-use
Therefore: Let’s stop throwing figures at each other and instead concentrate on – together with the producers – agreeing on a model (per country) based on:
- average ELVs, perhaps in 3-4 different types
- average treatment times for these, using adequate equipment
- average labor costs with average overheads
- average waste fees, with regular updates, e.g. quarterly
This would be fair to all stakeholders, at the same time being administratively simple to work with.
It would also be in line with “market conditions”, since ATFs that have higher costs than the “averages” would be forced to become more effective, whereas those that have “done the extra” would get a “reward”.
EGARA is willing to work on this and looks forward to a constructive collaboration with other “operators”.
EGARA-meeting at Tallinn, 20. – 21.05.2005
EGARA has just held its spring meeting in Tallinn, Estonia – hosted by the Estonian NGO-ELV, who is looking for membership of EGARA. As always the meeting also had visits to dismantlers, and our impression is, that Estonian dismantlers are “on the track” and they will in a few years come up to the standard as in the other Member States. One of the sites visited was that of the host, Tiit Plaks, NGO-ELV, who runs a dismantling company – see picture with sign, and on the other picture you see – left to right:
Marc van den Brand, STIBA – Tiit Plaks (behind the counter) – Henk Jan Nix, STIBA – Lennart Scharff and then from behind: Henry Gustafsson, SBR – Steen Errendal, DAG – Paul Fox, MVDA.
(Photos: Torvald Forsman)
As always the spring meeting also elected the new EGARA Executive Committee – and this time there was “nothing new”. The new Committee is exactly as the old one.
EGARA seeks EU-support for Research concerning the “Dismantling Station of the Future”
Under the 6th. Framework Programme for Research and Technological Development, the European Commission has just closed a call for proposal, and EGARA has – together with a bunch of partners – made a proposal. In a consortium headed by the Dutch RTD-organisation TNO and with participation of NIWL in Sweden (Working life – Heath & Security), a proposal for a three year program of research into “new technologies for dismantling” at a costs of more than 3 mill. Euro, with the following main objectives has been delivered:
– to increase the reuse of car components and recycling of materials up to the quantitative goals set by Directive 2000/53/EC (Appendix 1)
– to develop of an economically strong industrial sector of SMEs
– to improve the health and safety of the workers in car dismantling.
On the association side, we have participation from: EGARA; DAG – Denmark; STIBA- Netherlands; SBR – Sweden and VASSO – Switzerland. Also Nordic dismantlers are in the project – dismantlers who will act as test-beds for the new technologies. These are: Dansk-Tysk, Denmark; Bromma and Botkyrka + Frykmalms, Sweden.
This is juts the first phase, and the Commission will now evaluate proposals during 06/07-2005. Sometime in September we will then be informed about whether we will be allowed to make a full-proposal, or in Commission terms: Be invited to submit a full proposal, which should then be delivered in November 2005. If this passes and we are selected, it is foreseen to make contracts in May 2006 – and the project will start.
As can quite clearly be understood, there is no guarantee for getting a grant and a lot of time will pass before we know that, but it clearly underlines that we are not just sitting back waiting to see what happens! We are actively working for development of the sector!
Lennart Scharff
EGARA-secretary
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