2000.11.21

Introduction

Understanding that the EU-directive on ELVs (2000/53/EC) specifies the Commission to promote standards on vehicle recyclability and recoverability, EGARA discussed this issue seen from the vehicle dismantlers’ point of view during its meeting in Zürich on 18.11.2000.

We further understand that, the issue will be raised during a forthcoming meeting of ISO TC22, on 29.11.2000 in Brussels. EGARA believes, that our views on the issue could be valuable for this Committee at its meeting, and we therefore kindly ask the Commission to communicate them to ISO TC 22.

Basic considerations

As stated previously by EGARA, we believe that, in order to reach the acquired recycling targets of 85% and, later on: 95%, the priorities must be:

1. Re-use for original purpose
2. Materials recycling
3. Other forms of recycling.

Hence, we believe that a vehicle from which it, with full respect to environmental, health and safety requirements, and with the use of appropriate tools, is as easy as possible to dismantle spare parts from, with a view to re-using them, is a dismantling friendly vehicle and therefore also a vehicle which has a high degree of recyclability and recoverability.

Concerning spare parts for re-use, it is of course a condition that these do not endanger the safety of vehicles and environmental requirements such as air emissions and noise control.

 

Realising that the above clearly is a ‘generic statement’, EGARA during its meeting tried to analyse possibilities for making this operational, i.e. finding methods by which these issues could be quantified, perhaps using a methodology like the one used in order to classify refrigerators according to energy consumption

 

2.

One idea to consider is, with the use of appropriate tools, the time necessary in order to remove fluids and other elements as specified in the directive, and then assign ‘dismantlability friendliness codes’ accordingly, i.e.:

 

Item	Classification
Removal of oil	A
Removal of fuel	B
Removal of break-fluid	A
Removal of batteries and liquified gas tanks	C
Removal or neutralisation of potential explosive components	D
Removal of cooling liquids	A
Removal of components identified as containing mercury	B
Removal of catalysts	A
Removal of metal components containing copper, aluminium and magnesium	C
Removal of tyres	D
Removal of large plastic components	E
Removal of glass	B
Etc.
Total	B

 

A condition for using this kind of scheme, is that ‘appropriate tools’ are specified, and of course, that the times corresponding to the codes A, B, C….. are defined. EGARA can, with the collaboration of its National Associations, provide very good averages concerning ‘time needed’ for the different car-models and –types, and we are course also willing to make tests and samples.

Further, and concerning appropriate tools, we also have knowledge about these, which can be provided.

In this context we underline, that ‘dismantling friendly’ clearly also means, that the necessary operations can be performed by the use of standardised tools, thus avoiding that for each car-type (and perhaps also car-model) special tool-kits are needed.

Finally we wish to mention, that improving recyclability and recoverability would also mean that, the less the used materials are mixed and the easier it is to separate the different materials used, e.g. metal components from plastics, one plastic family from the other etc., the more ‘recyclable’ the vehicle is.

These are our basic ideas put forward, but we are of course willing to explain these further and to provide the data necessary, if TC 22 should wish so – as well as we are willing to make direct contributions to the Committee.

 

EGARA

2000.11.21