By Chas Ambrose
The Fall meeting of EGARA (European Group of Auto Recycling Associations) was held on November 16th-17th in Brussels, the home of the European Union/ Commission/ Council/ Parliament.
Fittingly, as part of the meeting, the EGARA Secretariat had organised a meeting with a representative of the European Commission DG Environment to discuss some ongoing work on the EU End of Life Vehicle (ELV) & Batteries Directives. EGARA was very pleasantly surprised by the unexpected attendance of the EC’s most senior ELV advisor Artemis Hazi-Hull.
With the EU ELV Directive now being 17 years old (it became EU law in September 2000) & the Battery Directive being 11 years old, various aspects of the Directives are still very much under review. This served to highlight that the role of the various European ‘organisations’ does not simply cease at the point at which the Directive becomes national law. No, the work of the EC on the Directive continues, with attention on both Governmental and operator activities.
With the EU being composed of (currently) 27 member states, each reporting slightly differently on compliance with the Directive (recognising that each member state has slightly different legislative structures & industrial dynamics) it is often challenging to ensure that ALL member states are fully complying with all of the Directive requirements. For this reason, some of the changes now being proposed are to make reporting by national Governments clearer and more consis tent, and hence to improve transparency on how Directive requirements are being met. It is safe to say that it is clear (and has been for some time) that some EU member states are complying to a greater degree than others. As there needs to be a level playing field within the EU, this is one current focus of the EC.
From an auto-recyclers perspective, the different ways that each EU member state has implemented the Directive is reflected in the way in which the ‘free take back’ obligation is met. In som e EU member states a financial fund has was set up to ensure correct treatment of ELVs; whereas in others it was very much left down to basic market forces. To date, since the ELV Directive was introduced, ELVs have always had a ‘positive value’ so this aspect has never had to be tested, but this isn’t necessarily always going to be the case.
Another area under consideration is the use of Management Systems by vehicle recyclers to demonstrate compliance with Directive requirements. There is an increasing emphasis by Government regulators on ‘self-regulation’ by industry; a natural consequence of government regulators being subject to continued resource squeezes, and an expectation of industry being able to run (& demonstrate) their business and operation compliance with the law. This is likely to pose a significant challenge to many operators that while able to operate a traditional vehicle recycling business are often not aware of or understand the complex environmental context in which they now find themselves.
The debate during and after the presentation was very much two-way, with animated discussion between EGARA members and EC representatives. This led, again, to a discussion about the huge problem of illegal operators and how their activities are undermining investment by legitimate operators. And the widespread use by illegal recyclers of on-line platforms such as ebay to sell used parts. This is clearly a problem throughout Europe and probably the rest of the world. To date, attempts to address the problems at local level have been of very limited success and a much higher level EU-wide approach is really needed.