Stena Metall AB
Stena Metallkoncernen är ett ledande återvinningsföretag.
ID: 296886525351-47
Lobbying Activity
Response to Legislation on end-of-life vehicles - evaluation
1 Nov 2018
Stena Metall position on the European Commission’s Roadmap on the evaluation of End-of-life vehicles Directive
As one of Europe’s major recycling companies that is committed to sustainability and environmental protection, Stena Metall welcomes the evaluation of the End-of-life vehicles (ELVs) Directive. Taking this opportunity, Stena Metall recommends that the European Commission considers the following recommendations when evaluating the ELV Directive:
1) Reduce and eliminate illegal activities and actors to reduce the unknown whereabouts of the ELVs
There is a need for a reduction and subsequent elimination of illegal activities both amongst dismantlers as well as treatment operators dealing with ELVs. This could be achieved by ensuring that Authorized Treatment Facilities (ATFs) and treatment operators (such as e.g. shredders) treat these ELVs properly. To achieve this, further recommendations are provided.
2) Introduce well-framed incentives for last-owners of ELVs
The need for better incentives for last-owners of ELVs to properly treat those vehicles is explained by the fact that many cars are being dumped by their last-owners instead of being delivered to an ATF. The additional costs this put upon Member States and their municipalities could be covered by introducing a small fee or tax for each registered vehicle. Subsequently, this fee or tax should be used to finance an incentive for the last-owners when delivering the ELV for proper treatment and deregistration at an ATF. This measure would also allow to distinguish between legal and illegal actors since the latter ones cannot deregister their ELVs.
3) Improved inspections of Authorized Treatment Facilities (ATFs)
Authorities of the Member States should have both the ability and the resources to perform sufficient inspections of ATFs. This could be achieved by increasing the number of inspections of ATFs and by ensuring that such inspections are carried out by personnel with expertise on that matter. What is more, to increase the quality of the way the ELVs are treated, there should be a demand for third party certificates for all ATFs.
4) Higher consistency with related EU legislation
Stena Metall welcomes also the European Commission’s attempt to ensure higher consistency between ELV Directive and other related EU secondary legislation such as e.g. Batteries Directive. In that regard some inconsistencies have been observed between the ELV Directive and the Batteries Directive. One of them concerns recycling rates and second use of batteries in relation to other types of vehicles, e.g. electrical bikes.
5) Better control of the waste streams from ELVs
There is a need for improved control of waste streams from ELVs. One way in which this could be achieved is by obliging recycling companies and treatment operators to report how they have treated the material from ELVs. This requirement would allow also to distinguish between actors who contribute to the achievement of the objectives of the ELV Directive, and those who are not.
6) Better incentives to design cars in a more sustainable way
Stena Metall would like to emphasize that the design of new cars differs to a considerable extent from the design of those cars that are material recycled today. Materials such as Ferrous, Aluminum and Copper are to a large extent replaced or the use thereof is reduced in new cars. These materials are often replaced by fiber-reinforced plastics, composites and laminates, which are much more difficult to recycle and have low or negative value. When looking at the total environmental impact over the whole circle of production, use and recycling some materials, such as e.g. lightweight materials, will however in some cases be better suited than recyclable and heavy materials. In that regard, life-cycle-assessment could be used to evaluate which are the best materials to be used. On a final note, a revised ELV directive should focus on hazardous waste and CRMs.
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