The Directive requires vehicle producers to pay all or a significant part of the costs of takeback and treatment, subject to some initial flexibility, and has important implications for producers, dismantlers and shredders. It is also expected to bring environmental benefits, including reduced emissions of carbon dioxide equivalents and sulphur and nitrogen oxides.
The consultation paper proposes three options for the systems of collection, treatment and recycling of ELVs:
- producers could be responsible for collection systems, tightened standards and recycling targets for their own makes, either individually or by forming collectives with other producers. Producers could meet their responsibilities through contracts with treatment facilities or establish their own facilities. Vehicle owners could also take back their vehicles to facilities that were not contracted with the producers;
- vehicles could be delivered by their owners to any treatment facility that holds a permit, with producers required to meet some or all of the takeback and treatment costs for vehicles of their own make. Each producer could also be required to meet tonnage recycling targets, which might be set according to each producers’ current market share and could be met by purchasing either ‘evidence notes’ (proof that certain tonnages of ELV material had been recycled) or tradeable permits; and
- to differentiate between vehicles sold before 2002 and from that year onwards. For the former, producers could be set tonnage targets based on their current market shares, again met by purchasing evidence notes or tradeable permits. For new vehicles, producers would be required to pay bonds into funds for each vehicle sold, which would meet treatment and recycling costs when the new cars began to be scrapped.
Other proposals contained in the consultation paper include:
- the exemption of small volume producers from some provisions of the Directive;
- the incorporation of restrictions on the use of heavy metals
in new vehicles into requirements, without applying the restrictions to replacement parts for old vehicles;
- the introduction of an electronic notification system for Certificates of Destruction (issued when vehicles are delivered to treatment facilities) from the outset;
- an information paper on the licensing or permitting requirements that will need to be met by treatment facilities; and
- a proposed voluntary agreement with industry to introduce
some provisions of the Directive.
Comments are invited from all sides of industry and other interested parties by 2 November, to enable the most cost-effective way of implementing the Directive to be identified. The issue of financing the costs imposed by the legislation is not covered by the paper and will be considered separately.