While writing this the consultation has already ended. Of course we sent in our vision and desired solutions about EPR, funds, targets, implementation issues and other ideas. We hope everybody did, because even if we try to be one Europe, in different countries we have different circumstances, varying from big distances for ELV’s to end up at ATF’s, to different labour costs, black sheep and implementation by national governments.

We need to inform the EC about the issues that we are involved with. And only we (not just EGARA, but all of us) can do that properly. Nobody else does it for us and being dismantlers, we know best.

We also had the EGARA Fall Meeting. Another time online, forced because of Corona which seems harder to beat than expected. This time we chose for a Teams meeting, which was happily received by the members, that could see each other this time and gave no technical issues. To our surprise, the meeting discipline really worked out great. 2 Big issues took all the time, The review and the EGARA calculation model. So we chose to split the meeting and treated the other agenda points later. We will also have some meetings in between with dedicated discussion points.

Also this meeting Artemis Hatzi-Hull from the European Commission chose to join us another time.  Her presence is really appreciated, because we hear news out of the first hand and we can inform her directly. Artemis mentioned some important and interesting points:

  • Member states (MS) need to explain their figures and how they reach their targets;
  • The EC aims for more plastics reuse;
  • EPR: investigate if operators are financially responsible (our data are important!);
  • To be circular, a market for recycled materials is necessary;
  • Should the Directive include other vehicles also like trucks and buses and motorcycles?
  • Handling EV/Hybrid batteries need to be coordinated with the Battery Directive.
  • Batteries: Who will be owner, who will be responsible?
  • The EC needs feeds feedback and hopes to find new ideas also.

Again, this last point shows how important it is to share information with your national association. They can only represent our interests optimally when informed well. They need to know what’s going on and what our wishes are and our possible solutions. Now is the moment that we need to act to realise our wishes and our interest for the coming years.

Part of this point is costs of dismantling (depollution following the Directive’s standard) an ELV. Roughly said, we can depollute an ELV for the income of the materials. But this is different in every country and even depends on the month of the year. And we have to remove more than just fluids. We need to take off tires and glass also. We make costs for this. Imaging what happens if the EC decides we need to take off other materials, for instance plastics. Or new, now still unknown materials.

For this, SBR was so friendly to let us use their calculation model that they use for many years to get insight in costs for dismantling. What EGARA did was adjust this model slightly in order to make it work for other countries also and to add a free field for remarks. We also made a sheet in which the company can calculate his company costs per hour. These costs do not involve only labour, but also equipment, education, costs for permits and certification, write offs and so on. Not all companies seem to be fully aware of that.

This calculation model has 2 benefits. We can help the individual company to get more insight in his costs, but we get also outcome of real dismantlers costs. We need to inform the EC about these costs ourselves and let nobody else tell them what our costs are. And the EC is open for it.

Make sure you stay in touch with your branche organisations. Even details that may seem logical or obvious or even trivial, make sure your organisation is aware of them. It’s in our own interests.