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Vehicle recyclers and manufacturers raise concerns over dismantling rules for end-of-life vehicles

Introduction:-

The EU is proposing to expand dismantling obligations under the proposed End-of-life Vehicles Regulation (ELVR)

European Recycling Industries’ Confederation (EuRIC), European Automobile Manufacturers’ Association (ACEA), and European Association of Automotive Suppliers (CLEPA) provide recommendations on the proposed expansion, representing vehicle recyclers, manufacturers, and suppliers.

EuRIC serves as the umbrella association for Europe’s recycling businesses. EuRIC, with 75 members from 23 European countries, represents over 5,500 larger and smaller enterprises interested in recycling and trading various resource streams. They contribute 95 billion EUR to the EU economy and create 300,000 green and local jobs. Recycling reuses valuable materials in value chains by converting waste into resources. Recycling is a key driver of Europe’s industrial transition by promoting circularity and climate neutrality.

The European Automobile Manufacturers’ Association (ACEA) unites Europe’s 15 major car, truck,van, and bus makers: BMW Group, DAF Trucks, Daimler Truck, Ferrari, Ford of Europe, Honda Motor Europe, Hyundai Motor Europe, Iveco Group, JLR, Mercedes-Benz, Nissan, Renault Group, Toyota Motor Europe, Volkswagen Group, and Volvo Group. We are the voice of the auto industry, a technological world leader, and the backbone of the EU economy. Our members keep Europe on the move, providing diverse solutions for moving people and goods from A to B.

The European Association of Automotive Suppliers, or CLEPA, is a group of more than 3,000 businesses that provide cutting-edge parts and cutting-edge technologies for intelligent, sustainable, and safe mobility. More than 20 national trade associations, European industry groups, and more than 120 international suppliers of auto parts, systems, and modules are brought together by CLEPA. The EU automotive supplier industry’s voice, CLEPA connects the industry with decision-makers.

The ELV Regulation proposes new requirements for removing parts and components from end-of-life vehicles (ELVs) before shredding. This regulation aims to: 

  • Improve reuse, refurbishing, and remanufacturing;
  • Address compelling safety reasons (e.g. for traction or SLI batteries); and
  • Achieving higher levels of material efficiency, which could not be reached at an equivalent level of material extraction and separation with post-shredding techniques(e.g. catalytic converters).

As long as there is a downstream market for the reuse of vehicle components, none of the three organizations ACEA, EuRIC, and CLEPA disagree on the benefits of doing so,On the other hand, we contest the value addition of some component-specific required dismantle requirements for material efficiency, safety, or repurposing. 

In actuality, dismantling is not the most effective way to accomplish any of the aforementioned goals for a number of the components listed in Annex VII, Part C, and the associated trade-offs have never been evaluated, for example, through a life cycle assessment or feasibility study. Authorised Treatment Facilities (ATFs) would be forced to disassemble ELV parts that are unsuitable for reuse, refurbishing, remanufacturing, or parts where there is no market for them and would be destroyed if all specified ELV parts were to be reused. This has no positive environmental impact but comes with significant disassembly, transportation, and storage expenses as well as an additional carbon footprint. 

The markets and removal rates of recycled, reconditioned, or remanufactured parts would be supported more by demand-side policies (such as lower VAT and insurance policy-based incentives) that have no negative side effects. For example, considering the average lifespan of an automobile, the obligation to deconstruct dashboards and displays for reuse and remanufacturing is ineffective because there is no market for these spare parts. Furthermore, because different industries have different equipment levels and model sizes, the term “dashboard” is not well defined and refers to a wide range of sub-components and materials with no industry-wide standard composition. Consequently, a matching distinct dashboard waste stream would be made up of an odd assortment of materials and would not help to raise the standard of recycled materials.Technologies for disassembly, shredding, and post-shredding would still be required. 

It is also not justified to disassemble a number of components, including wiring harnesses and circuit boards greater than 10 cm² (Annex VII, Part C). Precious metal content, etc., is determined by the purpose and quantity of components on the printed circuit board, not by its size. Additionally, because combustion engine wire harnesses are thoroughly ingrained in the car from the beginning of construction, it is unlikely that they can be simply disassembled. Since they are specially made for every car, it is also impossible to reuse them. Moreover, improved Post-Shredder Technologies (PST) would be required to extract the pertinent components.

Recovering a very wide range of materials is made possible by cutting-edge shredding and post-shredding technologies, as well as future solutions enhanced by digitalization and artificial intelligence (AI). Comparable material separation outcomes can be achieved, provided that modern, cost-effective, and industrially applicable post-shredding technology is applied with appropriate capacity. It is crucial to stress from a quality perspective that high-quality recycled raw materials guarantee that, when state-of-the-art technologies are applied, the relevant industry requirements or specifications whether they pertain to mechanical qualities or contamination levels are reached. The extensive implementation of cutting-edge post-shredding and recycling technologies ought to be encouraged by the new legal framework.

Therefore, the proposed expansion of dismantling obligations is at odds with innovative processes using different advanced technologies (density separation, spectroscopy/optical sorting, gravimetric separation, artificial intelligence-based sorting, etc) to recover extremely high-quality grades of different materials in post-treatment facilities. These investments by recycling industry frontrunners and Europe’s leadership in providing technologies may be lost. Last but not least, in many EU countries, there is simply no labour force available to perform this manual work. It should also be noted that the proposed timeline of requirements for components listed in Annex VII, Part C is inconsistent and should be aligned.

Conclusion:-

Component removal requirements must always be reasonable, technically achievable, economically practical, and consistent with the goals of the European Green Deal. There must also be a particular use. It should only be necessary to mandate manual dismantling if there is no other way to accomplish the intended results. And any recycling procedure should make advantage of the greatest technologies now available.