Verband der Internationalen Kraftfahrzeughersteller (VDIK)
VDIK
Der Verband der internationalen Kraftfahrzeughersteller vertritt seit 1952 die Interessen der internationalen Pkw- und Nutzfahrzeughersteller in Deutschland.
ID: 8763303252-70
Lobbying Activity
Meeting with Engin Eroglu (Member of the European Parliament)
28 Nov 2025 · Automotive market
Response to Commission Regulation amending Annex III to Directive 2008/98/EC
17 Aug 2016
The Association of International Motor vehicle Manufacturers in Germany much concerned that the proposed Commission Regulation amending Annex III to Directive 2008/98/EC as regards the hazardous property HP 14 (ʻEcotoxic’), based on the outcome of “Study to assess the impacts of different classification approaches for hazard property "HP 14" preferring the calculation method 1 for classification purposes, will adversely impact recycling.
An approach relying on chemical analysis, as it is the case with method 1, is techni-cally unfit for characterisation of complex solid waste streams, such as fluff-light fraction and dust from shredding of metal containing waste (19 10 03*/19 10 04).
The chemical analysis is suited for assessing homogeneous substances and well-defined mixtures commonly found in virgin materials but absolutely not adapted to the characterisation of solid waste which by nature is heterogeneous and complex. Sampling solid waste coupled a chemical lixiviation of the sample to obtain a homogeneous liquid and exhibit its chemical properties would provide only a very poor indication of the hazardous properties of the waste sample analysed: It would neither be representative of complex materials found in solid waste nor would it be indicative of the bioavailability of hazardous substances in water as only a very small fraction of what is recycled in scrap can be soluble in water.
However, we welcome the introduction of generic cut-off values, being in line with the position of Dutch authorities, even if it does not address the limits of relying on a method using a chemical analysis.
The Study, used as a basis for the draft Commission Regulation, is based on an ex-tremely limited dataset not allowing to draw conclusions relying on solid scientific evidence. The Study explicitly acknowledges “the lack of availability of characterisation data from chemical analysis” in general (p.91, sec. 5.4.1, 1.par) and the lack of data for fluff and dust from metal shredding (p.15, above the table and p.126, sec. 6.4.5, last par). Moreover, the study acknowledges that the method 1 is associated to a potential overestimation of waste classification (p.13, Results).
Neither the suggested approach nor the far-reaching detrimental impacts expected for the recycling industry, stemming from the application of method 1, are in support of the transition to a circular economy.
Socio-economic impacts resulting from a probable reclassification of fluff-light fraction and dust from metal shredding from currently non-hazardous to hazardous, on the basis of an unfit method, would seriously disrupt if not render impossible recycling of streams reaching high recycling targets and force facilities to temporary or definitively cease operation for no environmental benefits.
Applying the method 1 for classification of fluff-light fraction and dust would from a scientific viewpoint be irrational. Given the limitations of the chemical analysis ap-proach, it would be justified to develop a harmonised method which is scientifically fit for purpose of assessing the ecotoxicity of complex solid waste streams instead of relying on a preferred method 1 which is inadequate for assessing HP 14 for complex streams. As long as such a method is not developed, complex solid waste streams such as fluff-light fractions and dust must be exempted from any method based on chemical analysis for assessing HP 14 and regulatory changes to incorporate such a method in the legislation.
We urge the European Commission and the Technical Adaptation Committee to re-frain from approving any proposal relying on chemical analysis for the assessment of the ecotoxic property of waste HP 14 applicable to fluff-light fraction and dust until a proper harmonized method fit for the purpose of characterising complex solid waste streams is set up.
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