Last November the stakeholders meeting evaluating some EU Directives including the ELV Directive was held in Brussels. All kinds of stakeholders were consulted in advance and all remarks and suggestions were summarized in an overview. This overview was discussed and asked for comments again.
Explained was the difference between national problems as a result from poor implementation and/or poor enforcement against descriptions in the Directive not being effective or even unessential. The focus of this evaluation was on the latter. Of course bad and unclear legislation will lead to poor implementation, so enough was to be discussed.
In short, most problems can be summarised in following items:
- – Escapes for deregistration;
- – Export resulting in illegal dismantling without reporting;
- – Not all ATF’s are monitored (in many countries only ELV’s treated within the networks arereported about).
Many participants called for good registration systems connected to each other as a base for good cardismantling. A new and welcome trend as EGARA was in the past the only one with this vision.
The EC mentioned one important principle in the evaluation that we had almost forgotten about or thought of as no longer actual:
– The 5-step waste hierarchy (recycling ladder).
This is a big opportunity for us as dismantlers industry, or a welcome acknowledgement. With this base our spare-parts business is priority number one as reuse prevents waste. All other materials need to be recycled as material. This is what we as dismantlers industry always have done and still do. Our role as collectionpoint, depolluter, reuser, separator and start for legal recycling of ELV’s never has lost any of it’s value. New techniques will appear some day, maybe taking over part of our job, but as long as we with our knowledge and networks know where to sell our parts and materials, we serve the waste hierarchy principle better than any other player! EGARA will keep the focus on this status and for sure claim it at the EC.