Adam Price 29/07/2012

The effects of the 2015 End of Life Vehicle legislation: On the Welsh Automotive Forum.
Draft Report



(Cliftongrade)







Introduction
This report has been prepared by Adam Price for Ecodesign Centre Wales (EDC) The effects of the
2015 End of Life Vehicle Directive legislation: On the Welsh Automotive Forum.The research study
was conducted during June and July 2011.

Objectives
This research outlines the EU Directive and will be continued to look at who is affected by the 2015
legislation in the Welsh Automotive Forum.
The study highlights End of Life Vehicle Legislation.
I believe this report will invoke further discussions about who is going to be affected by this
legislation and how it can be regulated to ensure that the new requirements coming in 2015 are
met. I also hope to highlight the level of awareness of this legislation in WAF and what ecodesign is
currently being implemented if any and what ecodesign can be implemented to ensure the designs
of 2015 meet the requirements of ELV legislation. If SMEs in Wales are going to be affected by this
legislation is it in there commercial interest to be aware of it and prepare in advance.

Methodology
The research was desk based, but further research will consist of primary research questioning a
field of 15 different businesses from WAF that are likely to be affected by new legislation. It will look
at Welsh SMEs, Global brands such as Ford and Toyota who produces engines here in Wales to
producers of small components such as suspension springs, but who have a Global network.







Initial questions
Waste management policies?
What are Authorised Treatment Facilities?
What are the most recycled materials, which are the least?
Who knows what materials are being used?
What are the key design considerations?
Who are the Automotive companies in Wales?
What are the effects on the Manufacturers suppliers?
What are the indirect affects?
Should the Automotive forum wales do something about ELV?
Which other companies in wales need to address ELV?
Rare Materials?
End of life vehicle Directive 2015?
Welsh Automotive Forum Automotive Sector Understanding Company/Sector NeedsIndustry?

Summary of EU directive end of life vehicle legislation 2000-2015
The EU Directive on End of life vehicle first came to existence in 2000, it set out design
requirements for materials and components to improve recyclability and increase reuse.
The vehicle certification agency enforces the technical requirements affecting the design of
new vehicles. (vca.gov.uk)
In 2003 it was amended to include the requirement of the economic operators (producers,
dismantlers and shredder operators etc) to set up the collection of ELVs by treatment and
disposal systems to hopefully ensure that vehicles get recovered and then are actually being
recycled or reused at the vehicles end of life.
..Also in 2003 legislation required producers to ensure that materials and components of
vehicles do not contain any heavy metals such as lead, mercury, cadmium or hexavalent
chromium.
From 2005 producers have been required to register their responsibility for their vehicles
and apply for the approval of their vehicle collection system. The collection system consists
of a sufficient network capacity of authorised treatment facilities.
The authorised treatment facilities which comprise all of a producers system for collection
of vehicles shall contain sufficient capacity to the number of that producers vehicles which
are likely to become end-of-life vehicles in 2006 and in each year thereafter.
(Business.wales.gov.uk)
It comes down to the Environment agency to enforce these requirements on ATFS.
(Environment-agency.gov)
1
st
January 2007 its a requirement that the producer and operator of an authorised
treatment facility accepts delivery of an end of life vehicle to no further charge to the last
owner of that vehicle.
BIS enforces vehicle producers to provide convenient networks of ATFs that offer free take
back for their brand of vehicle and ensure that ATFs reach the targets of recovery/recycling.
(Bis.gov.uk)
In 2015 it is all go with Authorised Treatment Facilities (ATF) being required to meet new
targets where 95% of ELVs are recovered up on the previous target of 85%....Then if that
wasnt enough for you the recycling target will be going up as well from a mere 80% of ELVs
being recycled to a full 85% to be recycled.

Who is affected?

Affected are producers of cars and/or light goods vehicles under european whole vehicle
type approval categories M1 and N1.( manufacturers and professional importers of these
types of vehicles) Also producers of replacement components for such vehicles. (Bis.gov.uk)
The legislations definition of recycling and recovery.
Recycling defined by ELV is the reprocessing in a production process of waste materials for
the original purpose or for other purposes but excluding the use of combustible waste as a
means to generate energy through direct incineration with or without other waste but with
recovery of the heat.
Reuse defined by ELV is any operation by which components of end of life vehicles are used
for the same purpose for which they were conceived.

What is an ATF?

An Authorised Treatment Facility is a permitted facility that accepts waste motor vehicles.


Key issues
It is important for producers to have a clear understanding of the materials that make up their
products. With Imds Europe companies can create a valuable material database which covers the
entire supply chain. As a typical vehicle is made up of 10,000 different assemblies, sub-assemblies
and components, the responsibility for collecting and reporting the material data has been cascaded
down the supply chain. (imds-europe.com) If producers know what materials are being used in each
component out of the thousands that make up a vehicle they can start calculating where the extra
10% of materials needed to be recovered and the 5% extra material to be recycled can be found.
Not only that but producers can take responsibility and start applying ecodesign to their
components, the producers of the seating for the car arent necessarily going to take on the
responsibility of meeting the end of life vehicle directive. As Plastics require extensive cleaning and
separation to allow material recycling, making separation uneconomical. Design for Disassembly in
the design process does not reduce disassembly times enough to make manual dismantling
economic. (RAHIMIFARD, 2007) It is going to take financial investment for a producer of plastic
components for vehicles to start redesigning their products to improve disassembly for end of life.
Thats why its important to see what companies in Wales are taking on this responsibility and which
ones are lagging behind.
There are well established separation technologies that are focused on metallic metals. These
processes provide the most efficient recovery, recovering over 3/4-provide highest revenues
through recycling ferrous and non-ferrous metals. Success is mostly in ferrous metals. Many
fractions that are destined for landfill consist of non-metallic materials. (RAHIMIFARD, 2007)
The results of a UK trial by (bis.gov) found that the metal content recovered from the ELVs in this
trial where 74.48% of the total vehicle weight, excluding fuel. The UK trial is comparable to those of
other EU Member States:
In 2004, Netherlands conducted a trial of 1153 vehicles, whose average weight at 855 Kg was
slightly lighter than ours, from which they identified a recovered metal content of 72.5%, excluding
the tyres and battery.
France has assumed an average vehicle weight of 900 Kg, of which 74.2% is identified as metal,
excluding the tyres.
Germany has assumed a recovered metal content of 75%, comprising 70% ferrous and 5% non-
ferrous metals. (Bis.gov.uk) http://www.bis.gov.uk/files/file30654.pdf



As the results of trials across Europe and as shown in the pie chart about 70% of vehicles content is
metal which can be recovered and particularly ferrous metal can be recycled. With the new
legislation coming in 95% of the vehicle must be recovered so thats roughly 25% non-metal
materials so we are looking at recovering some of the components listed below.
Non-Metallic Parts-Average Weight (Kgs)
Mirror (door) 1.00, Headlight 1.75, Light (rear) 1.00, Engine (rubber hoses/plastic) 6.00, Indicator
Unit (front) 0.25, Door Front (glass content) 2.50, Switch 0.25, Bumper (rear) 5.00, Grille 1.30,
Door Glass (front) 2.50, Bumper (front) 6.00, Wheel Trim 0.50, Qtr Light 0.75, Parcel Shelf 3.50,
Speedo Head 1.25, Screen (front) 9.00, Screen (rear) 4.75, Door Glass (rear) 2.50, Door Rear (glass
content) 2.50, Seat 6.00, Sun Roof 4.00, Fuel tank (plastic) 9.00, Glovebox (plastic) 2.50, Tyre
(exc.metal content) 6.00, Catalytic converter (ceramic core) 1.00
The Authorised Treatment Facilities are going to have to be able to recover Non-Metallic material in
a commercially viable way. Which is currently not the case; contaminated materials such as plastics
made with 2 polymer types are very hard to recover. The value of post fragmentation material
streams is dependent on material purity and contamination. This can be improved through design
for end of life, material reduction and design for disassembly.
Manufacturers of these components in Wales are the important ones to target and question their
understanding of the End of life vehicle directive and ensure that they are aware of it; hopefully
doing something about it, if they are not EDC can ensure they start implementing ecodesign so they
are ready for 2015.
Welsh Automotive Forum (WAF)
It is crucial Non-metallic materials become commercially viable to separate as they are one of the
10% of unrecovered materials that has to be recovered for 2015 and the 5% of currently non-
recycled material that has to be recycled to meet the 2015ELV regulations. These materials with
often end up in landfill and it is important for companies in the Welsh Automotive Forum are aware
what materials are ending up where, so they can start using ecodesign. Some component
manufacturers selected are aware and are already using recycled material. In my research I found
Castalum in Welshpool are feeding off cut aluminium straight back into the furnace to be recycled.
Other companies in Wales I would like to question that have shown awareness are Probe RTS who
provide environmental management support and legal monitoring. It would be interesting to find
out how there affected by ELV and how they are approaching there role to ensure its met. BMW are
said to be seeking to use recycled plastics in its vehicles and average 15% recycled plastics at the
moment . (letsrecycle.com)
Below are 15 Companies that I have selected to investigate further in the future. Selected to show a
range of effects of the ELV 2015 directive? Ive selected companies with Global Networks, some big
brands like Ford and Toyota. Some tier 1 manufacturing suppliers, producing bespoke components
on a small scale and plenty of Welsh SMEs.





To be continued..