Recently EGARA invited her member associations to give feedback on the ELV Directive as the EC asked for this in an online questionnaire. These requests are often mentioned in the EU Transparancy register. Sometimes EGARA is invited via mail, we always check if the request is from a reliable stakeholder that’s somehow connected to the EC and not just using us for their own merits.

Making us heard

Why is it important to concede to these invitations? The EC or the executing party always first draws the opinions from the field. Of course anyone is free to respond to a consultation, but the contributor of the comments is taken into account. It makes a difference if an opinion is from an active civilian or an involved company or organisation representing the industry. Making your voice and your opinion heard is of importance. It may also lead to invitations to working groups, which means you can directly inform the ones setting up or adjusting EU legislation. I can’t be made any easier to influence the legislative process.


In the past year passed more than once the chance to give your/our opinion to EU laws that almost directly concern our car recycling business. I will mention them and give some of the important aspects of these laws.

ELV Directive

Most important was the recent evaluation of the ELV Directive. Here we could display our ideas of what still needs to be improved and suggestions how to do that. Unknown whereabouts are a direct result from failing national systems. National governments have not made producers provide reuse info. targets need to be formulated much clearer, so better efforts need to be made than just redefining recycling, Responsibilities need to be put at the right players.


Via mail, the European Commission Study on Investment Needs in the Plastic Waste Sector was introduced. We could explain that labour costs are an important factor to take out plastics, as plastics have hardly any value. It’s still way too cheap and to make virgin plastics and much easier. We have hardly any idea what plastics are use where. Reused plastics also have a problem with quality and smell. Plastic tanks for instance, are a nice monostream, but their recycled products smell like fuel always. We suggested that alternatives need to be taken into account also.

Batteries Directive

Public consultation on the evaluation of the Batteries Directive was open in November last year. We tried to make clear that legislation needs to be dynamic as techniques evolves much faster than legislation can keep up with. Directions how to handle Li-ion batteries are not in the Directive and what is said about handling does not apply on Li-ion batteries as they have other characteristics than older types of batteries. Apart from that, traction batteries are now considered industrial, but they work in consumer goods. The EPR for them is unclear and recycling targets are different.

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Waste Shipment Regulation

The Public consultation on the evaluation of the Waste Shipment Regulation was another important item as some countries have a very peculiar interpretation of used goods status, including our spare parts. We need a uniform policy in any country so it does not prohibit transport of used parts. It’s very frustrating that some many laws and intentions for recycling and reuse are made and so many counterproductive actions are done.

Getting involved

These responds to consultations and evaluations are in many cases the first step to get actually involved in the processes to improve legislation. We are the industry, we know best what will work and what not. It would be silly to let these opportunities go. EGARA will always respond on behalf of her members, but our message would be heard better if we all contribute to these EU requests. It’s in our own benefit.

Transparency register

For anyone that is interested in getting involved in topics that might affect your business or is of interest, it’s easy to register to the Transparency register :