The European Commission is preparing the revision of its End-of-Life Vehicle Directive with the aim of improving the circularity and sustainability of the automotive sector. In this article, Piotr Barczak of the European Environmental Bureau (EEB) outlines his priorities.
This article was first published as part of an interview in Auto Recycling World.
End-of-Life Vehicles (ELVs) amount to 8 million tonnes in the EU a year and raise several environmental challenges for EU governments. Large amounts of waste could be eliminated if national authorities put in place the right policies and followed the Waste Management Hierarchy outlined in the EU’s Circular Economy Strategy. According to this strategy, waste streams should be tackled at the source by improving the design of vehicles at the production stage. This would help reduce most of the environmental impact of ELVs, notably by incentivising durability and repairability, facilitating recycling and avoiding the circulation of toxic substances.
The European Environmental Bureau, together with its members, outlines several recommendations that can help the automotive sector move towards more responsible and circular business models, aligning it with the EU’s European Green Deal.
Starting at the concept development stage, greater attention will need to be given to how the design of vehicles can influence their full life-cycle impacts. Eco-design style measures are already being applied in other instances. For example, the Packaging and Packaging Waste Directive imposes essential requirements for packaging, whilst the Eco-design Directive does the same for energy-consuming products. So, minimum requirements can clearly support broader objectives around material and energy efficiency. As we transition towards zero-emission vehicles, design that prioritises re-manufacturing, refurbishment, repair and recycling will become more important than ever.
Eco-design measures for electric vehicle batteries are expected to be developed during the revision of the Batteries Directive. Still, these measures will not address other parts of the vehicle, such as chassis, vehicle management system, etc. where extending mileage before the end of life of vehicles may present the most desirable option from a climate and environmental perspective.
Regarding material loops, it is already at the design stage that one has to think about a harmonised product passport to facilitate the information flow from producer to recycler. A product information system would be an inventory of substances of concern, building on the sector’s existing database and supported by the new European Chemicals Agency (ECHA) database. In order to improve the dismantling of the problematic components (i.e. polyvinyl chloride, polyurethane, batteries etc.) , the product passport should include a full listing of materials, key performance data of the vehicle, durability, repairability, life-cycle environmental footprint and chemicals content. A similar inventory requirement already exists in the EU Ship Recycling Regulation.
Additionally, the ELV Directive’s provisions regarding safe pretreatment of components containing hazardous substances should be made stricter, whilst obeying the Waste Management Hierarchy where prevention, followed by reuse, is the top priority. The current target does not give enough attention to activities such as reuse or preparation for reuse.
Not only should this difference from recycling be visible in reporting the rates, it should also be mandatory to to meet a separate target for reuse, thus triggering an increase in this activity. To avoid market distortions, the rules to incentivise reuse should also be harmonised across the EU.
We recommend binding requirements to ensure non-destructive disassembly, the removal of all reusable modules from the vehicle before shredding and their safe storage for reuse. The ease and economic feasibility of dismantling before shredding depend on the design; there should therefore be minimum requirements at the design stage that address this need, as the appropriate dismantling of layers and modules will also facilitate quality recycling (also dependent on a functioning International Dismantling Information System, referred to as IDIS).
After reuse comes recycling. The calculation methodology for the targets should be clear and the same across all Member States to better reflect the progress of the sector in terms of reuse and recycling and to make data more reliable and comparable. For example, any double calculation in two different registries should be avoided and residues from recycling operations should be deducted in order to avoid inaccurate inflating of reported rates.
Further, a target for recovery should be excluded from the Directive: Reuse and recycling provisions need to be better enforced, whereas recovery only drives the incineration of materials, which does not contribute to an improvement of the circularity of the sector.
Currently, although the recycling target is high, it does however not incentivise the recycling of specific materials. Meeting this target can be achieved with little effort by recycling materials like steel that are easy to recycle. To ensure that other materials are also recycled, especially light-weight critical raw materials, one should consider setting specific recycling targets by material, rather than overall weight-based targets. Lastly, the vague definition and calculation of recycling and recovery results in incineration and backfilling of ELV materials when they should in fact be dismantled and recycled. The amendment of this loophole is crucial to bring the automotive sector closer to a circular economy.
Hand in hand with recycling requirements goes the use of recycled content. The revision of the Directive could set a mandatory percentage of recycled content, differentiated by material. The uptake of recycled contents should ensure that the same standards apply for recycled materials as well as for virgin materials with regards to performance and chemical contents, and the any associated incentives and obligations should clearly refer to this.
Lastly, the revision of the ELV Directive should align closely with the upcoming revision of the Batteries Directive, as the market continues to experience rapid growth in electric vehicles use and the related use of batteries. The revision should moreover set appropriate rules on dismantling and the provision of repair information (IDIS) to end-of-life users by the producers, allowing for a second life for batteries from ELVs.
Piotr will be speaking at BCF’s, 3rd Annual Vehicle Recycling Conference that will take place online from the 15 – 16 October 2020.