The Waste Package was published in June and has the focus of all that are involved in ELV processing. Some topics are about electrics in vehicles and splitting up waste from ELV’s to other Directives than the ELV Directive or about future technical and legal (ownwership) development. But we also see some room for improvement of the ELV Directive itself. At least we are happy to see some problems are adressed now that we already distilled some year sago.

The ELV Directive

The Directive itself is not really wrong. We stated this many times before. The biggest problems related to the ELV Directive are about implementation and national enforcement. The weak points of the Directive itself are:

  • –  The Directive is not direct working, it must be implemented in national legislation;
  • –  PRE scemes are voluntary, so in many countries this means not all ELV’s are covered in the

    recycling reports;

  • –  The base for the Directive to cover all vehicles lies in good registration systems, which is

    outside the scope of DG Environment. It depends on registration systems which are taken care op by DG Move. And for some reasons national authorities do not want to put effort in this, despite it may be good for fighting fraude and financial income. Now we still miss almost 5 million ELV’s annually and EGARA thinks this number may be much higher as many ELV’s are registered as exported or suspended cars.


    We are happy to see that national recycling reports need to be more precise and detailed and be compared to the national situation. This means member states need to give info about their actual carpark and mutations like new registrations and export too. We see too many vehicles disappearing from systems with unknown whereabouts. This is not good for the environment, it means unfair competition from illegals to ATF’s and reports give a false image about a country’s situation.


    As EGARA we contributed to the consultation about the Battery Directive. Our focus is on H/EV (Hybrid/Electrical Vehicles) batteries. The current Directive is obsolete and our opinion is that legislation needs to be more flexible in order not to become counter productive when new techniques appear. It also needs to enable the entrepreneur himself to take measures for handling, processing and storing goods that fulfill safety and environmental requirements without being driven into expensive products or unnecessary certification. We see no problem in dealing with 2 Directives where it concerns H/EV’s as it hasn’t been for lead/acid batteries also.


    We have our reservations towards electrics and WEEE legislation. For now there are no real benefits or easy possibilities to take out car electronics for recycling. Financially the outcome is negative, Environmentally, we think more research needs to be done. If certain substances become really scarce, the value will go up and the market will do it’s job, in that case there’s no need for targets about electronics in legislation. If the situation turns out to be different, we will reconsider this view.

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Apart from the Directive where electrics are taken care of, we think this also needs to be dynamic legislation, so it can move along with future techniques and developments.


The EC is focusing on plastics, also on car plastics. We think the reuse of car plastics starts with design for recycling. This means we need to know what plastic is used where, or better: plastics should be just one kind, big and easy to remove. The problem however is that virgin plastics are so cheap that taking plastics out of ELV’s, the return transport and processing will never be cheaper. Also the plastics quality goes down every cycle. We see possibilities in other use of plastics like functioning as reductor at the blast furnaces, as plastics contain a high amount of carbon. Of course taking off big parts to get a mono stream that can be recycled will be done, if the labour is covered. But that would take recycling funds as plastics as a material are not profitable yet.


Generally we think targets need to be realistic. And they need to be described carefully. We see to often that different countries use different definitions or simply adjust definitions to reach targets. Sometimes reaching targets mean high costs with little or no real benefits for environment. We are not aganist targets, but if targets only mean window dressing, we are better off with directions or simple enforcement.


But all in all we (EGARA) think analysing ELV matters on this scale is a good thing and will give insight for many years in the future also. Discussing the items will probably reveil more than we can oversee just now.