Statement – 19^th November 2025

Incorrect details Regulation

Parts assessment

In Article 31 1.a  is stated that ATFs need to assess parts that have been removed from an ELV to determine whether they are fit for reuse. EGARA wants to stress that this description does not fit the practice of how parts need to be assessed. In order to assess is a part is fit for reuse, it’s often already decided when the vehicle is acquired by the ATF which parts will be reused. The final check is by definition on the vehicle, before removing it. Reason for this is that parts can be checked and often oeven tested, but most important is that todays parts have an electronical, digital component which needs to be reset before removal. If not, the part cannot be relearned in the receiving car’s digital system. For This EGARA is of opinion that assessment for reuse is described in another way, in any case before removal. Not only in article 31, but in all related articles as well and in recital 56.

Airbag neutralisation and removal

Article 29 describes the mandatory depollution and refers to Annex VII, part B 2.a:  The following components, parts and materials shall be removed from end-of-life vehicles:

(a) airbags, … and any other potentially explosive parts and components shall be neutralized.

EGARA is of opinion that airbags (and retainers or other pyrotechnics) that are neutralized in the vehicle, do not need to be removed. The risk of unforeseen activation is gone and removal of deployed airbags serves no purpose.

Removal of EV batteries before delivery to an ATF

Recital 57 states second life of batteries if supported by taking out batteries before an ELV arrives at an ATF. We cannot image how this helps second life. If a battery is good for reuse as traction battery, it will be sold for this purpose, if a battery is under capacity for traction, but good enough for second life in a stationary power storage, builders of these devices will give better prices than recycling for sure. The ATF is the right operator to dismantle batteries from EELVs. Dismantling anywhere else than at an ATF means illegal dismantling. This should be changed as should article 24.2. ATFs need complete ELVs. Cherrypicking by other operators need to be prevented. Batteries should not be excluded in any way as essential parts.