Statement – 18^th November 2025

Storage length of ELVs

3 Years is the least for proper parts reuse

In one of the last versions of the circular vehicle regulation proposal, it was suggested to keep an ELV no longer than 6 months on an ATF. See the EP version of 03/07 Article 27 3. f.:

3. Authorised treatment facilities shall:

…

(f) treat the received end-of-life vehicle within 6 months

from the delivery date.

Apart from a missing definition of the word ‘treat’ we think that depollution within a month is reasonable, but a vehicle needs to be kept longer than 6 months to enable parts sales. We feel the Regulation should follow the 1999/31/EG Directive on the landfill of waste Article 2.g:

‘landfill’ means a waste disposal site for the deposit of the waste onto or into land (i.e. underground), including:

…

But excluding:

…

• Storage of waste prior to recovery or a treatment for a period less than three years as a general rule, or

…

Also the Waste Directive 2008/1998/EC, recital 16, refers to a storage period of 3 years “or more”.

In order not to contradict any other EU law it seems only logical and reasonable to follow these terms. As parts reuse is the highest form of recycling (certainly higher than recovery) this justifies storage of ELVs for 3 years in order to be able to reuse as much as possible from an ELV.

Additional motivation:

Most ELVs will be processed and removed to a shredder much sooner than 3 years. Of most 20-year old ELVs the fast moving parts are known or not much receiving cars are still on the road that need to be kept roadworthy. Many ATFs have to use their available surface in an economical way in order to have room for cars to be received, so there are incentives not to keep an ELV any longer than necessary.

Reason to keep ELVs longer is to be able to sell the most parts possible. The storage of parts is limited and in many cases parts are best kept in the vehicle itself. Especially young accident vehicles contain valuable parts and serious prices are paid to insurance companies and lease in order to obtain these vehicles. It is however impossible to plan availability or request of parts. The flexibility is in the possibility of buying donor vehicle when available and store until the parts are requested. The younger the vehicles, the more expensive it to acquire, but also the less knowledge of which parts are fast movers and the longer it will take before parts are necessary for the market. For these reasons in particular it is of utmost importance to keep ELVs at least 3 years in order to be able to reach the highest amount of reuse of an ELV. Six months or even one year is too short.

We see no reason to mandate a shorter storage of ELVs than 3 years.

Waste Directive 2008/1998/EC, recital 16, it also reinforces a storage period of 3 years “or more”.