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Since the European End-of-Life Vehicles Directive (Directive 2000/53/EC, also known as the “ELV Directive”) was adopted in 2000, it has not changed fundamentally. However, in mid-March 2021, the EU Commission presented a report on the evaluation of the directive, which restricts the use of certain hazardous substances in ELVs (end-of-life vehicles). A renewed public consultation is planned for the second quarter of the year (more information here: https://elv.biois.eu/registration.html). The EU Commission’s revision proposal is to follow next year.
Two main points of criticism in the evaluation of the ELV Directive
In its evaluation report, the EU Commission points out two main shortcomings of the previous legislation. For example, there is a high number of “missing vehicles”: at 35 percent of all deregistered vehicles in the EU, about one third. Institutions such as the German Federal Environment Agency have been pointing out this undesirable development for some time. It is true that around 6.5 million end-of-life vehicles are dismantled and recycled in the EU every year. However, it is not clear where the remaining 4 million vehicles remain. It is likely that a large proportion of these ELVs that have disappeared from the balance sheet will not be scrapped and recycled in accordance with the End-of-Life Vehicles Directive. This is also indicated by recent studies by UNEP as well as the Dutch government. According to these studies, millions of used vehicles in poor condition and below the Euro 4 emissions standard, which are more than 15 years old and no longer roadworthy, are mainly transferred to African countries. There, they are responsible for high emissions and numerous accidents. With around 7.56 million vehicles between the years 2015 and 2018 alone, exports from the European Union are the highest in this regard, accounting for 54 percent. This is followed by the USA and Japan. For the EU, this also means a loss of raw materials, estimated at about eight million tons of ferrous and non-ferrous metals and plastics.
Another main point of criticism cited by the EU Commission is the hitherto inadequate provisions of the End-of-Life Vehicles Directive with regard to the construction of new vehicles. More recycled materials should be used in the construction process and it should be easier to dismantle and recycle the vehicles afterwards. However, the provisions for this have so far not been detailed and specific enough and are also difficult to measure. They would therefore have only a limited effect on the construction of new cars. Above all, the EU Commission criticizes the fact that the provisions obliging car manufacturers to provide and pass on information about the materials and components contained in vehicles are insufficient. Companies in the repair, dismantling and recycling sectors would have to be better supported here.
Data quality lags behind in EU comparison
While most EU member states reported meeting reuse and recycling targets, there are differences in how they measure and the extent to which they do so. However, there are different ways of measuring this and, as a result, the quality of the data varies greatly, according to the EU Commission. This raises doubts as to whether the data are at all comparable. Moreover, because the calculation is based on the total weight of all vehicles, there is no incentive to promote the recovery and recycling of materials beyond metal waste, such as glass, plastics or critical raw materials.
The evaluation report cites as further shortcomings of the ELV Directive that its definition of “recovery” includes underground backfill, i.e., waste stored in open pits. In addition, a separate target for “reuse” was missing.
Overall, the EU Commission took into account the changing vehicle market in Europe in its evaluation. Although a high proportion of end-of-life vehicle waste consists of iron and other metals, lightweight materials and electronics are increasingly being used in new cars. As a result, the proportion of plastics and electrical and electronic components is constantly increasing. New problems arise here for recovery and recycling, and the trend toward electric vehicles in the EU means that these are more likely to grow in the future.
The Commission therefore also points out in its evaluation that the EU’s Green Deal sets new targets here: both in the context of a new EU action plan for the circular economy and through the updated legislation on the Waste Framework Directive and on certain waste streams.
Exemptions on the review bench
The End-of-Life Vehicles Directive also contains a list of exemptions, which is adapted to technical and scientific findings every four to five years as part of the revision process. During this process, the industries concerned are required to submit a technical dossier in which exemptions must be justified. A consulting consortium then reviews and evaluates the arguments and proposes to the EU Commission that the exemption be allowed to expire or be extended.
Currently under review is the exemption for copper alloys containing up to 4 percent lead by weight, which is valid until July 2021. In the process, the European Automobile Manufacturers’ Association (ACEA) has submitted the results of some preliminary tests with new lead-free materials to the stakeholder consultation, which have been incorporated into the accompanying report (https://elv.biois.eu/registration.html). The revision is not expected to be completed until 2022, but the exemptions will continue to apply until then. Industry observers:inside expect the Commission to further extend the exemption. If this does not happen, a transitional arrangement for the changeover would take effect, usually lasting at least twelve months and up to several years.
Further Sources:
https://www.bde.de/documents/359/BDE_VOEB_Europaspiegel_April2021.pdf