Recently EGARA was invited by the Waste Management Unit of the EC to inform them about the missing vehicles. It seems the EC begins to consider missing vehicles as a problem, as they realize that national recycling reports are only about part of the vehicles. Apart from that, vehicles out of the scope of enforcement most likely mean pollution and environmental issues. Needless to say, that missing vehicles are not done at ATF’s so we as a legal industry miss business and worse: these missing vehicles mean unfair competion.
The head of Unit was even more surprised to hear that part of the missing vehicles are treated legally as participation of ATF’s in producers networks for collecting ELV’s is voluntary. So even legal treatment doesn’t always mean contributing to reports.
Apart form simple national enforcement (finding and closing down black sheep), the EC starts to realize that the ELV Directive foresees in networks, COD’s and deregistration, but never took care of covering all vehicles that would become an ELV. Reason is that deregistratration in many national systems can be done at any time, or there’s many escapes from registration which means these vehicles never re-appear anywhere. The result: missing vehicles, unknown status.
But it’s not all that negative. Because we start to understand the little imperfections in the ELV Directive and even the EC admits there’s room for improvements, a so-called fitness-check for the ELV Directive is planned. This is a great opportunity to help improve the Directive where necessary. Not only can be stated that the current version does not lead to have all vehicles end up as ELV’s to be treated at ATF’s, we can also make clear that we have never received any dismantling info for reuse of spare-parts. In countries that have banlists, national associations should be the first file a complaint to the EC about the Directive.
Even better is that this fitness check means anyone can file complaints. Not just EGARA, not only dismantlers asociations, but also registration bodies, crime fighting organsations, network organisations and all other allies possible can file complaints. The EC will gladly receive them in order to close some leaks in the Directive. This is the chance to work together with your stakeholders that have the same interests as the dismantlers industry and to improve our situation.
EGARA will inform her members in particular, but anyone who has questions or is interested is free to ask.