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European Group of Automotive Recyclings Associations

EGARA

Founded in 1991, EGARA is the European umbrella association for the national associations of automotive recyclers in Europe.

Lobbying Activity

Response to Heavy metals in end-of-life vehicles (updated list of exemptions)

30 Jun 2022

Lead acid batteries are a perfect example of circular economy. Lead has a value and laed can be recycled until eternity for low costs. Transport is not problematic, costly or complex. Problems with lead will start when banned and value drops. Costs will be eveaded. Li-ion batteries are an alternative, they are light and store a lot of energy. But they are also a risk as they can catch fire when damaged and even without damage. They can barely be extinguished and burn at a temperature of 1300 degrees C. For this at end of life it's necessary to know the state of health and the stability. Storage and transport of unstable batteries are very expensive. Recycling is very expensive. The risk and costs need to be taken into account before radically banning lead and switching over to Li-ion batteries as the only alternative. Metallic lithium batteries may also be a rwalistic option, but not as widely implemented as li-ion. In a fire, metallic lithium batteries catch fire, opposed to lead acid. Metallic lithium batteries are lighter than lead acid, but heavier than li-ion. Recycling costs are unknown tous. For this we do not favous a drastic ban on lead acid batteries. Alternatives have way too many different characteristics and other risks that should not be ignored, apart from costs and lead as a new problematic material that will disappear at wrong places.
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Response to Modernising the EU’s batteries legislation

1 Mar 2021

EGARA is the European association of car dismantlers. We collect ELV’s rather than batteries and we take the batteries out of ELV’s according to the ELV Directive. For this we deal with mainly EV batteries, Automotive batteries and smaller system (backup) batteries (read: E-call, tire pressure, seat heating etc.). It’s hard to predict how the Regulation will involve car dismantling in reality, but we have some points to state. ELV’s sometimes contain batteries that are not automotive or EV batteries. Costs for these batteries also need to be covered by the EPR. Dismantling a battery of an ELV does not necessarily mean the battery can only go to a recycler. In case of a reusable battery, it should be possible to sell the battery to an authorised workshop to build the battery in a vehicle for exactly the same purpose. The regulation seems to be very restrictive and leaves not much room for direct reuse or open market under certain conditions. Also if we are obliged to deliver to the choice of producers only, there is not a free market on batteries for reuse and for repurposing. Dismantlers do not bring new batteries into the market. We keep batteries that are fully functional in the market for original purpose only. Non-functional batteries go to authorised collectors. To help decide if a battery that shows no signs of damage, is stable, reliable and fit for reuse of the original purpose, access to information for ATF’s to decide the condition of the battery is necessary. EPR transfer to second use producers need to be stated very clear. We are of opinion that direct reuse is not second life as the battery is reused for the same purpose. EPR needs to be described very clear to avoid it will be subject to many interpretation which will act counterproductive. The situation should be leading. If costs for dismantling from the vehicle, storage, collection (transport) are high, these need to be covered. Especially since producers also need to provide information how to handle waste batteries. EPR now only seems limited to the end user. For recycling rates must be taken into account that not all ELV’s end up at ATF’s
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Response to Modernising the EU’s batteries legislation

8 Jul 2020

EGARA is the European association of car dismantlers. In this case we focus on traction batteries. A few items need special attention. Traction batteries are a class of their own. They are not just industrial batteries. They are used in vehicles used by mainly consumers or professional drivers on the road in cars, vans and even bigger commercial vehicles. Battery techniques change all the time. Now the Lithium-ion batteries are very popular and produced on large scales, but they have their own characteristics. The directions in the current Directive no longer apply to this new type. Not on recycling, not on handling, storage or EPR. Recycling techniques change all the time also. We feel the waste hierarchy ladder also applies on for whatever reason discarded batteries and this needs to be stressed, rather than prescribe preferred techniques that can be obsolete before published. Storage of either new, used or discarded batteries need to be described in easy to adjust legislation. The focus needs to be on prevention, testing and monitoring, rather than heavy rules for facilities. EPR needs to be described. EPR needs to be logical. Second life is a very easy way for an original producer to get rid of EPR. Is it fair that EPR is moved to what’s the new producer in legal sense or are we creating a big problem for the future when batteries are end of life and only material recycling remains? Do not forget about dismantling from equipment, storage and transport. Ownership is an issue to take into account. Legislation needs to be flexible and prepared to apply to new (now unknown) situations and techniques. Details need to be in lower legislation like an annex.
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Response to Legislation on end-of-life vehicles - evaluation

31 Oct 2018

EGARA thinks in itself the ELV Directive is quite good. There’s a few weak points that need attention so reuse and recycling can be optimised and no ELV’s get lost. Because the Directive needs to be implemented reluctant MS can slow down the process to almost zero in getting current. Also in some countries the responsibility for reaching targets is put at players that are not able to take these responsibilities. This implementation process is a weak point. The obligations for MS and producers about reuse and necessary info are too weakly described. Reuse is the highest step in the recycling hierarchy. Cars get more complex every year, meaning for reuse producers info is crucial. Especially the digital installation of components leads to problems. So far the necessary info is hardly accessable or only to an insufficient level. This means perfectly good parts cannot be made functional on a receiving vehicle. Many MS are convinced the producers gave this info via IDIS which is not treu. As said the links that can be found do not lead to the requested info. No MS actually took effective measures for reuse info. The quality of recycling (material, process and safety) info in IDIS is limited. Many info is obvious, but much is also incomplete or missing. COD’s should only be issued by ATF’s, not by collection points that do not the actual depollution or other players like shredders that cannot be controlled on depollution, parts and material reuse and recycling. The EPR networks are voluntary in many MS. This means not all ATF’s are in the system. Reporting means in some cases extrapolation to 100% is allowed, which can give a better result in figures that the actual situation. In many cases the number of ELV’s covered by the networks are so low extrapolation is not allowed. Networks need the figures of the independent ATF’s. Reporting depends on functionality of national registration systems. These should cover all vehicles in a country and should be continuous. In to many systems (temporary?) deregistration is an option, meaning a vehicle is registered, but in fact is an unknown whereabout until it’s reregistered again. Only a COD should mean definite deregistration. Export should mean a vehicle should show up in another national system. Export is now an escape as vehicles are in a twilight zone until they reappear. Export is also abused as a disguise of ELV’s that are exported as vehicles and dismantled in the illegal sector in the country or abroad, out of sight of the enforcement. Either national systems need to be improved and made compatible, or an EU systems needs to be set up. The output in the reports depends on the input. If the input is not reliable, so isn’t the output. Description of targets should be more precise. Now we see too many different national definitions of reuse, recycling and recovery. This leads to redefining terms in order to reach targets without actually improving processes or covered amounts. In some countries extra incentives to draw ELV’s to the right operators (ATF’s) seem to be necessary. Especially countries with a big black market or low density (big distances) need to make it financially more attractive for a last owner to take his car to an ATF. In some cases this means negative incentives like hight costs for car owners that have a cart hey cannot use, in other cases it means funds to cover transport costs or getting a better position aquiring ELV’s than illegals. The links to WEEE, plastics and Batteries does not need to be problematic. Many aspects in these Directives are mentioned above. What needs to be taken in mind is that costs need to be covered one way or another. If product or material reuse/recycling is profitable, it will be done, if costs of obliged or desired processes can be covered in other ways like funds, it’s an offer that needs to be carried out. We also need to keep an open mind to alternative processes.
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