Dansk Autogenbrug
DAG
Dansk Autogenbrug, the Danish Association of Car Dismantlers, was established in 1963 with the following goals: 1) To strengthen the public image of the trade 2) To represent the political interests of the trade among decision makers 3) To follow and convey information about new legislation and technical development in and around the trade 4) Supervising that members observe the level of quality and service as a condition for upholding membership
ID: 740730847736-66
Lobbying Activity
Response to Revision of EU legislation on end-of-life vehicles
30 Nov 2023
Dansk Autogenbrug (DAG), the Danish business association for auto recyclers, welcomes this proposal. This space only allows us to draw attention to matters which we assess will not sufficiently contribute to the fulfilment of the regulation or may work to the disadvantage of the efficiency of our industry: Art 6 However laudable these targets are, we fear in general that car manufacturers increasingly will want to control material flows and reduce the free circulation of both certain components and residual materials, to the detriment of independent players in the free aftermarket. Similar concerns apply to the provisions on components suitable for refurbishment and to the development of a circular strategy of each vehicle type as referred to in Art 8 and 9 and detailed in Annex IV, Part A. We urge this proposal to be read through the lens of competition law, since a weakened recycling industry will find it all the more difficult to fulfil the role it is intended to play. Art 20 DAG welcomes that car manufacturers should be made financially co-responsible for ensuring that the scrapping of vehicles complies with the objectives of the proposal, if and when revenues from the sale of spare parts, residual fragments and stripped bodies do not cover the costs of treatment. However, we propose that Art 20 be clarified so that there are more objective criteria for determining when and to what extent the payment obligation of car manufacturers arises. Art 23 (4) DAG is sceptical about allowing for collection points and calls for clarification of when end-of-life vehicles (ELVs) must be handed over to authorised treatment facilities (ATFs). It is crucial there may be no doubt that only ATFs can issue CODs. Art 24 (2) DAG will insist that the electric vehicle battery is an essential part of the ELV, similar to engines and gearboxes, and must therefore remain in the vehicle as a prerequisite for it to be submitted free of charge. Art 27 (5) DAG recommends that all ATFs should be obliged to introduce a certified environmental system. Art 29 (1) DAG recommends laying down a deadline for how soon an ELV should undergo environmental treatment. Ar 31 (1) DAG understands the relevance of assessing each part but is warning against a heavy administrative burden. Art 31 (2) It must be specified what is meant by a "guarantee," including duration and scope. Art 32 (a) We agree to requirements for labeling to ensure that parts lacking such labeling are considered illegal. We see this as an important tool against illegal treatment and sale of second-hand parts. Art 32 (b) Like in 31 (2) a specification is needed for what is meant by a guarantee, including duration and scope. Art 38 (3) We interpret this provision to mean that vehicles declared total loss cars cannot be considered as used vehicles according to Ann 1, A, and are therefore initially defined as waste and can only be exported as such. It is crucial for the national supply of used spare parts that export of total loss cars is restricted. Art 46 We note with interest the requirements for inspection of approved businesses and for the control of export activities. However, we call for proactive efforts to curb the number of unapproved illegal businesses. Additionally, attention should be paid to online portals that advertise used spare parts on a larger scale. We fear that these parts may originate from illegally scrapped vehicles. ANN I, A (1) (g) This provision would certainly mean that second-hand engines and gearboxes would never become re-used which would be an awful waste of resources. ANN VII, E We urge caution in listing parts that must not be reused. Catalytic converters and particle filters, if relatively new, could be effectively used as second-hand parts. It should be remembered that a damaged vehicle must be restored to its pre-damaged condition, which is ensured by using second-hand parts. We look forward to following the legislative process.
Read full response