European Group of Automotive Recycling Associations, EGARA

Position Paper

EU Battery Regulation, Proposal Article 52

Article 52 of the proposal gives obligation of treatment facilities

The key role of Authorized Treatment Facilities, ATFs, in the circular economy of electric and hybrid vehicles

ATFs are the main actor in the circular economy of the automotive industry. They have an essential role to play in the sustainable transition of a rapidly changing automotive industry. ATFs handle all types of vehicles, whether ICE, electric or hybrid, in accordance with Directive 2000/53/EC. Indeed, they are the only actors authorized to deregister the vehicles, to carry out their depollution, the dismantling of the parts, the repair, and the sorting of certain materials before transmitting hulks to the shredders.

In accordance with the principle of hierarchy of waste management methods, the prevention of waste and its reuse must be favoured before any other form of recycling (Waste Framework Directive 2008/98/EC). ATFs have the knowledge to prepare all quality parts of electric and hybrid vehicles for reuse, including batteries. Quality and safety are the highest priority when parts from the circular economy are brought to market. Thus, ATFs, experts in reuse, must be free to assess the possibilities of reusing parts from electric and hybrid vehicles.

Finally, ATFs are the only operators authorized to handle administratively and physically end-of-life vehicles. This position of single and mandatory entry point in the ELV sector is key in the fight against illegal industries. It guarantees exhaustive traceability of ELVs, physical and administrative. A common objective of the entire automotive recycling sector must be to ensure that electric and hybrid ELVs are directed through the legal end-of-life vehicle treatment sector, in particular to minimize the technological risks associated with the treatment of traction, ensuring secure, tracked and environmentally friendly processing.

The knowledge of ATFs makes it possible to guarantee environmental and safe treatment of end-of-life vehicles. The profession has been able to adapt over the years and continues to do so through its active participation in developments in the electric and hybrid market.

EGARA believes that it is crucial that the battery regulation does not limit the ATFs, experts in reuse, to assess the possibilities of reusing all parts, including the batteries, from electric and hybrid vehicles.

EGARA, founded in 1991, represents the interests of the independent European car dismantling industry, thus representing the SME car recycling industry. Today 11 Member States are represented. The United Kingdom, Norway and Switzerland are also represented. In total the EGARA members recycle approximately 2 million vehicles per year.


European Group of Automotive Recycling Associations

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