Suomen Romukauppiaiden Liitto ry / Finnish Scrapdealers Association
To promote the interests of the scrap metal recycling industry.
ID: 269877132983-47
Lobbying Activity
Response to Revision of EU legislation on end-of-life vehicles
19 Nov 2020
The Finnish Scrapdealers Association welcomes the Revision of Directive 2000/53/EC on end-of-life vehicles (ELV) as part of the new Green Deal. We support the goals of the ELV Directive and call for measures linking the ELV Directive with the objectives of the Plastics Strategy and adapting it to the challenges posed by new types of cars progressively entering the market.
Recycling operators authorized by the Finnish Car Recycling Ltd. are responsible for the creation, maintenance and operation of the end-of-life vehicle collection and collection system (Authorized treatment facilities ATF’s). The Association is of the opinion that the implementation of the Directive in Finland is well organized. Still, more ELV’s need to be collected for proper treatment.
The treatment of end-of-life vehicles after the dismantling of spare parts is a mass industry, not a treatment of individual vehicles. The entire value chain and resourcing should be considered when looking for ways to increase recycling and reuse. In addition, the recycling rate in ELV's is currently calculated from the weight of the entire ELV, before any parts have been removed. More appropriate would be taking into consideration the removal of hazardous components. Due to tighter chemical regulation, recycling is becoming increasingly difficult, for example for plastics containing brominated flame retardants. This should be considered when setting goals and defining the calculation method, especially as in modern cars the amount of plastic is already 12-15 %.
Losses occur for ATF’s and ELV treatment facilities since they suffer from scavenging of valuable spare parts which are often sold online. We would also like to point out that a large part of ELV’s are in a poor condition and in practice it is not possible to separate recycled materials other than metals. Thus, CoD’s should also in the future be granted by ATF’s, not e.g. by dismantlers. Currently the average age of the ELV’s is 21 years and they have little spare parts with market demand.
When setting targets for the ELV’s, also car manufacturers' responsibility for promoting reuse and recycling for example through the Eco-design directive should also be strengthened. This includes preventing the re-use of spare parts from ELV’s by digitally coding car parts. Operating models must support the circular economy and the reuse of usable parts. Also, the use of recycled plastic in new cars should be promoted, with clear minimum targets. Recyclable plastics from cars may not be used in all applications, but recycling for a similar purpose would increase the recycling rate through demand. Also, for the auto shredder residues it has got more and more difficult to find a proper and economically feasible treatment. Removing barriers to recycling should be considered in the broader context than that of accepting a car for treatment at the end of its life.
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