[pic] | COMMISSION OF THE EUROPEAN COMMUNITIES |

Brussels, 16.01.2007

SEC(2007)14

COMMISSION STAFF WORKING DOCUMENT

Document acc ompanying the REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT ON THE TARGETS CONTAINED IN ARTICLE 7(2)(b) OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLE IMPACT ASSESSMENT {COM(2007)5 final}{SEC(2007)15}

TABLE OF CONTENTS

1. Procedural Issues and Consultation of Interested Parties 5

1.1 Legislative Requirements 5

1.2 Impact Assessment 6

1.3 Consultation and expertise 6

1.3.1 Stakeholder Working Group 6

1.3.2 Research Study on Benefits and Costs of 2015 Targets 6

1.3.3 Additional Consultation 6

2. Problem Definition 7

2.1 Background to the Problem Definition 7

2.1.1 Characteristics of the Waste Stream 7

2.1.2 Overview of Current Waste Management Practice 9

2.1.3 Existing Treatment and Disposal Routes of ASR 10

2.2 Definition of Problem Issue the Targets are set to Tackle 11

2.2.1 Barriers to Innovation in Treatment of ELVs 12

2.2.2 Potential Lack of Economic Efficiency of Existing Targets for 2015 14

2.3 Parties Affected 14

3. Objectives 15

3.1 EU Sustainable Development 15

3.2 Lisbon Strategy 16

3.3 European Union Resources and Waste Objectives 16

4. Policy Options 17

4.1. Differences between Policy Options due to Definitions 17

4.2 Other Options not Described in Detail Here 17

4.3 Linkage to Other Policy Measures 19

5. Analysis of Impacts 19

5.1 Discussion of Stakeholders Views 19

5.2 Analysis of Impacts in the Future 20

5.3 Scenarios for Future Technological Development 23

5.4 Innovation and Competitiveness - Other Policy Measures 24

5.5 Estimation of the Economic Effects of Different Targets 25

5.6 No Policy Change (85% recycling, 95% recovery) 26

5.6.1 Environmental Impacts 26

5.6.1.1 High Technology Development Scenario 26

5.6.1.2 Low Technology Development Scenario 27

5.6.2 Economic Impacts 28

5.6.2.1 Impacts on Costs in the Economy 28

5.6.2.2 Impacts on the Technology Export Potential of the EU 29

5.6.2.3 Economic Impacts on EU Vehicle Manufacturers 29

5.7 Reduced Recycling Targets (illustrated by 80% recycling and 95% recovery targets) 29

5.7.1 Environmental Impacts 30

5.7.2 Economic Impacts 31

5.7.2.1 Impacts on Direct Costs of ELV Treatment 31

5.7.2.2 Impacts on Competitiveness 31

5.8 Reduced Recovery (scenario 85% recycling and modified recovery target) 32

5.8.1 Environmental Impacts 32

5.8.2 Economic Impacts 33

5.9 Combinations of Different Reductions in Reuse/Recycling and Reuse/Recovery Targets (illustrated by 80% recycling and 85% recovery target) 33

5.9.1 Environmental Impacts 33

5.9.2 Economic Impacts 34

5.10 Administrative Burden of all Considered Policy Options 34

5.11 Social Impacts of all Considered Policy Options 34

6. Comparing the options 34

6.1 Environmental Impacts 34

6.2 Economic Impacts 35

6.3 Sensitivity Analysis 36

6.3.1 Factors Affecting Environmental Impacts 36

6.3.2 Factors Affecting Economic Impacts 37

7. Monitoring and Evaluation 38

8. Conclusions 39

8. ANNEXES 41

This Impact Assessment report describes the estimated effects of different targets for re-use, recycling and recovery of end-of-life vehicles from 2015. It describes why the Commission is considering these targets, the procedures that it has followed to inform assessment of impacts and the rationale behind the assessment.

The report compares different options, looking at the impacts that targets are likely to have on commercial practices in, and outside, the European Union and the environmental and economic effects that would result.

The assessment finds that policy which promotes innovation is most likely to lead to both significant environmental and economic benefits – with net benefits to all affected parties.

1. PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES

1.1 Legislative Requirements

Article 7 of Directive 2000/53/EC of the European Parliament and of the Council of 18 September 2000 on end-of-life vehicles[1] ("ELV Directive") contains a set of reuse, recycling and recovery targets[2]. According to Article 7(2), Member States shall take the necessary measures to ensure that the following targets are attained by economic operators for all end-of-life vehicles by an average weight per vehicle and year:

- 85% of reuse and recovery and 80% of reuse and recycling by 1 January 2006 ("2006 targets"),

- 95% of reuse and recovery and 85% of reuse and recycling by 1 January 2015 ("2015 targets").

The Directive states that by 31 December 2005 at the latest[3] the European Parliament and the Council shall re-examine the 2015 targets on the basis of a report of the Commission, accompanied by a proposal. In its report the Commission shall take into account the development of the material composition of vehicles and any other relevant environmental aspects related to vehicles.

1.2 Impact Assessment

In line with the Commission's Better Regulation approach[4], the consideration of policy options has been developed through an impact assessment of alternatives. The information that has informed this assessment has been gathered from extensive and detailed formal and informal consultation of all interested stakeholders and a study by independent consultants. The decision on the appropriate targets has been based on this consideration of economic and environmental impacts. Environmental impacts are not monetised as, in this case, both economic and environmental impacts point in the same positive direction and monetisation would not help in examining the relative strength of different options. Social impacts were considered, but are broadly similar for each option.

The impact assessment has followed the Commission's guidelines.

1.3 Consultation and expertise

1.3.1 Stakeholder Working Group

The Commission established a Stakeholder Working Group composed of representatives of the vehicle industry (manufacturers, recyclers, materials and components producers), non-governmental organisations, representatives of governments and academia[5]. The Group worked for nine months, held three plenary meetings hosted by the Commission and several additional meetings on specific sub-topics. On the 4th November 2005, it produced a report containing its conclusions[6]. This impact assessment builds on the information provided, with the conclusions and assumptions of the stakeholders discussed in Section 5.1.

1.3.2 Research Study on Benefits and Costs of 2015 Targets

The Commission launched a study in the third quarter 2005 to gather information on the costs and benefits of 2015 ELV Directive targets for recycling, re-use and recovery. The final report was delivered to the Commission in May 2006[7]. The Commission invited all the interested parties to comment on the study to check or challenge its findings and to fill data gaps, receiving informative and helpful responses.

1.3.3 Additional Consultation

In addition, the Commission has directly consulted members of the waste and automobile industry, together with experts from Member States governments. A potential revision of the 2015 targets was initially discussed in the meeting of the Technical Adaptation Committee held on 16 November 2005, subsequently to which Member States’ experts were invited to send their position to the Commission. The final detailed discussion of the targets took place in the meeting of 5 July 2006[8]. Prior to an official Inter Service Consultation, a draft of this Impact Assessment was subject to consultation between Commission's services.

2. Problem Definition

Summary The ELV Directive contains a set of targets for re-use, recycling and recovery of end-of-life vehicles for 2015 established to reduce the environmental impact from the expected 14 million tonnes of ELV waste generated per year at that time. These targets need to be set at an appropriate level to promote the best environmental, economic, and social outcome given blocks to innovation in treatment technology. |

2.1 Background to the Problem Definition

2.1.1 Characteristics of the Waste Stream

The end-of-life vehicles (ELVs) from 2015 will mostly be vehicles produced around 2002-2003, which are on the road at the moment, together with more modern ELVs scrapped as a result of accidents. The typical life of a vehicle varies with the type of vehicle and the country in which it is being used. Based on information from GHK/BIOIS here we assume an average vehicle lifespan of 13 years, so that the largest proportion of ELVs in 2015 will be those cars sold in 2002.

The number of all cars in the EU15 increased by 17% between 1995 and 2002 and the number of light commercial vehicles by 28%, equivalent to combined compound annual growth of 2.4% over this period.

The average weight of vehicles covered by the ELV Directive is increasing, and the data as to the actual ELV weight differ. According to GHK/BIOIS, an average end-of-life vehicle weighs approx. 964 kg[9] and this weight is likely to increase to over 1,025 kg[10] by 2015. This weight was used in this Impact Assessment. However, weighted averages for all car manufacturers show higher weight of ELVs of approximately 1,280 kg by 2019[11], being an average weight of a vehicle put on the market in 2006 as reported in the certificates of conformity (i.e. 1,391 kg) minus the weight of a driver, tools and fuel. Using these figures for weight increases the magnitude of impacts in this assessment; for instance, there would be 17.6 m tonnes of arisings/year by 2019.

Based on the ELV weight of 1,025 kg, it is estimated that almost 14 million tonnes of ELV waste will have to be treated annually by 2015, compared to an estimated 10 million tonnes of EU25 ELV waste in 2005[12]. The increase of the waste volumes is due to the increase of the average weight of a vehicle and growth in ELV numbers. A quarter of this waste is currently classified as hazardous in some Member States.

Year | No ELVs Treated (000) | Average Weight (kg) | Weight ELVs Treated (000t) |

2005 | 10,864 | 955 | 10,375 |

2006 | 11,124 | 964 | 10,724 |

2015 | 13,771 | 1,025 | 14,116 |

Table 1. Estimated weight of ELVs requiring treatment in the EU, GHK/BIOIS 2006.

Material/Component | 2003 ELV (% by weight) | 2015 ELV (% by weight) |

Ferrous Metal | 68% | 66% |

Non Ferrous Metal | 8% | 9% |

Plastics and Process Polymers | 10% | 12% |

Tyres | 3% | 3% |

Glass | 3% | 2% |

Batteries | 1% | 1% |

Fluids | 2% | 2% |

Textiles | 1% | 1% |

Rubber | 2% | 2% |

Other | 2% | 2% |

Total | 100% | 100% |

Table 2 Typical Composition of a 2003 ELV and a 2003 new vehicle (and therefore a 2015 ELV), by weight, UK, Source: TRL (2003) and stakeholder consultation.

Since 2015 ELVs are on the roads today, the material composition of 2015 ELV waste can be estimated from the information on the material composition of current vehicles[13].

Understanding of the composition of the plastics fraction is crucial for an assessment of treatment options and assessment of impacts. Many different polymers are used in cars which will become end-of-life vehicles in 2015. Out of all plastics used in cars, PP (polypropylene) has the greatest share of around 40%. Many parts are composites of different polymers, whilst within a class of a polymer (like polypropylene (PP)) parts may have different physical properties. Vehicle design is increasingly moving towards use of fewer polymers in vehicles, less use of PVC, greater use of PP and greater use of composite parts.

Impacts have been estimated by looking at impacts from treatment of a polypropylene part (an example of a PP/EPDM bumper was used), chosen because polypropylene is likely to be the polymer most recycled, and which has environmental impacts broadly representative of the impacts of most of the other polymers likely to be recycled.

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Diagram 1. Average content of plastics in a new vehicle (2001). Source: ACORD, CEP

2.1.2 Overview of Current Waste Management Practice

Directive 2000/53/EC requires that all end-of-life vehicles[14] in the EU are collected by authorised treatment facilities following a prescribed procedure[15] and are subsequently depolluted, dismantled, and treated.

After depollution (removal of hazardous parts and substances) and dismantling (removal of large parts for reuse and recycling), ELVs are shredded in order to recover the majority of the valuable metal. The material resulting from shredding contains heavy and light fractions which are further separated by their magnetic or density properties. The heavy fraction is mainly composed of ferrous metals. The light fraction contains non-ferrous metals and a combination of other residues such as plastics, foam, glass, textile fibres, and rubber. Non-ferrous metals are often separated from the rest of the light fraction, which is then typically landfilled[16].

Shredding is a capital intensive process undertaken by a limited number of companies in the EU. ELVs are shredded together with waste from electrical equipment (such as fridges and washing machines), because the use of an input of mixed materials is more efficient for operators both technically and economically. The proportion of the light fraction coming from ELVs is approximately 50% by weight. For convenience, this is referred to in this assessment as auto shredder residue ("ASR"), but it is important to remember that residue coming from shredders is a mix of ELVs and waste from other goods, both of which are dealt with together[17].

2.1.3 Existing Treatment and Disposal Routes of ASR

According to PR Newswire, the waste market today is witnessing a shift in focus from direct disposal, which has typically relied on the use of low-cost methods such as landfill, to higher value pre-treatment methods. The enforcement of the Landfill Directive[18], which limits the use of landfill for the disposal of municipal solid waste, has resulted in greater demand for pre-treatment methods[19]. The implementation of the Directive has influenced national landfill policies which are now aiming to discourage landfilling as the environmentally and economically worst option of waste management, placed on the very bottom of the Community waste hierarchy. This can be done either through landfill bans (Germany) or through increasing landfill taxes (the Netherlands, Austria, Italy, Denmark, the UK) and result in an increase of landfill prices across the EU. Such trends are likely to occur in the new Member states as well.

ASR, which is a mix of pieces of plastics, fibre, rubber and some metals, can be treated in various ways. Today, ASR is mainly disposed of in landfills. There is very little use of incineration as a means of disposal, partly because of high gate fees and a limited capacity in countries like the UK or Germany[20]. Depending on the proportion of materials separated out, ASR accounts for around 25% of an ELV weight[21]. Thus, in 2005 between 1.5 and 2.5 million tonnes of ASR required disposal in EU25. This amount is estimated to be 3.5 million tonnes in 2015.

Recently, due to the development of treatment techniques triggered by the recovery and recycling requirements of the ELV Directive and national landfill policies, an increasing amount of ASR is being recovered. There are several potential routes of ASR recovery, including energy recovery in municipal waste incineration plants, energy recovery in cement kilns, and feedstock recovery (in blast furnace or during syngas production)[22].

The development of technologies to separate plastics from shredder residue is essential to the development of recycling of plastics from ELVs. Recently, several technologies - called post-shredder technologies (PSTs) as they treat waste after shredding - have also been developed in order to recycle and recover ASR.

There are two main categories of PSTs. The first one is based on mechanical sorting of different waste fractions which can subsequently be recycled or recovered. The most advanced technique in this category is a density separation based on floating different materials in liquids of various density and their subsequent separation. The second option is based on thermal treatment of a waste stream to generate feedstock for energy generation.

Most of PSTs are still in their development phase, with some that operate on an industrial scale already today[23]. Some of these technologies are licensed to operators[24], others are developed and operated by the companies which own them[25]. Numerous technological institutes and progressive companies are experimenting with combinations of different techniques to produce purer plastics input streams. The potential to produce plastic recyclates from greater proportions of shredder waste depends on the success of efforts to improve waste separation, something itself dependent on the magnitude of those efforts. To date, technological progress in separation has been substantial, although investment in separation of material from shredder residue has been hindered by lack of certainty about demand and outputs.

A summary of current and developing plastics sorting technologies forms part of an ongoing Gaiker study[26].

2.2 Definition of Problem Issue the Targets are set to Tackle

It is estimated here that 14 million tonnes of ELV waste in 2015 will generate approx. 3.5 million tonnes of ASR per year[27]. It is necessary to appraise the environmental and economic impacts of the recovery and recycling of this ASR at the levels currently set for year 2015 and for lower levels. The 2015 targets should be confirmed or amended accordingly to the results of this analysis.

In order to meet the existing 2015 targets, recycling and recovery of plastics contained in shredder residue will be needed. The environmental performance of recycling and recovery of different plastics from ASR is also the key determinant of the environmental impacts of recycling and recovery targets.

Recycling and recovery of different polymers found in ASR has very different environmental effects and consideration of different present and potential treatment routes is necessary to determine impacts of different targets. Not all recycling of plastics is environmentally beneficial, but becomes so only where the post-shredding sorting and recycling process creates less environmental impacts than are created by the process of making plastic from raw material. According to stakeholders, in order to meet the 2015 recycling target of 85%, as much as 50% of the non-metallic shredder residue fraction would need to find profitable new markets as recycled products[28]. This may well not be all plastics recycling.

This assessment is based on the assumptions on plastics recycling described in detail in Annex I, section 6.2. Current waste management practice in the disposal of ASR and development of technologies show that existing market forces on the waste industry will not lead to the best treatment of ELV waste for two reasons:

- The prices for treatment and disposal of shredder residue do not usually reflect the costs to society of treatment and disposal since businesses do not take into account environmental impacts of those methods. When firms choose treatment or disposal methods on the basis of what is financially best for them individually, it is often not the option that would bring greatest economic and environmental benefits to the EU. For example, ASR disposal to landfill can be financially the cheapest option at present.

- There are low levels of investment in new treatment technologies caused by uncertainties about the future market for products (in particular recyclates) and knowledge of existing techniques. Lack of knowledge of the most cost-efficient technologies slows diffusion of technology, in the same way that many firms do not adopt cost-efficient energy efficiency measures. These problems, detailed below, will lead to a lack of R&D in innovative techniques and diffusion of good techniques in ELV treatment.

If current practice continued, shredder residue would mostly go to landfill which would create significant environmental problems – approximately 3 million tonnes of landfilled shredder residue from ELVs per year in 2015 leading to increased emissions of 280,000 tonnes of CO2 equivalent, significant energy losses, increased air acidification, photochemical oxidation, waster pollution and eutrophication, and increase of waste volumes disposed of in landfills. Landfilling of this waste would also represent a loss to the EU economy of approx. 2.5 million tonnes of high-calorific waste per year (including streams of recyclable materials) which could replace imports of energy and raw materials.

2.2.1 Barriers to Innovation in Treatment of ELVs

Innovation in technological development of processing shredder residues is held back by several market failures, some common to industrial innovation as a whole, some relating to eco-innovation, and some specific to the post-shredder and plastics recyclate markets. These lead to a lack of investment and diffusion of advantageous technologies in the EU.

- Diffusion of latest technologies is slow, despite being economically advantageous for all parties (this is comparable to similar problems to uptake of energy efficiency improvements). In some cases, this is due to the lack of information exchange, restricted knowledge of opportunities, or lack of incentives at firm level for individuals to push for innovation.

- In many firms, there is unwillingness to take-up known innovative technology until it has been widely proved to be commercial. This leaves few market opportunities for technology to be proved commercially and, as a result, it may never be proved. Here, rational behaviour by individual firms (each looking after their individual risk) does not lead to the best outcome for the market as a whole (a market failure).

In a related problem, new technologies can create new markets by producing new products that have market value. However, as no proven market will exist until the products have been produced, firms are often unwilling to invest until others have done so and proved the market (so the potential market may never be realised). This circularity also hinders uptake of technology by individual firms. This cause of reduced demand is one of the problems which holds back investment in research and development for post-shredder technologies for sorting and recycling of ELV waste. The others, one of these is a knock on effect:

- Knowledge of the threat of lack of demand for technology (from the above market failures in the technology market) greatly reduces the potential returns on R&D investment whilst at the same time increases the risks. This has lead to sub-optimal investment levels in R&D for post-shredder technologies.

- The risks for individual technological R&D are higher than the risks to society from developing technologies in a particular direction. Firms face the risk both of their individual technology failing and of their technology succeeding but being less competitive than competing technologies. Society as a whole faces a much lower risk that all potential technologies fail. Firms, facing higher risk, invest in R&D at lower levels than society as a whole would invest – a market failure affecting development of post-shredder technologies.

- One of the most likely sources of capital investment in post-shredder technologies are the existing shredder operators. Yet, many of the shredder operators do not include plastics recycling in their main business. Faced with an unknown area of business, they have less incentive to research the market opportunities and therefore little incentive to innovate to sell products into a market they don't know. This restricts capital investment. The same is true of current institutional investment funds.

- Levels of R&D and investment in eco-technologies, like recycling technologies, are particularly likely to be at sub-optimal levels. The environmental benefits that the technology brings benefit society as a whole, but are unlikely to bring additional financial returns to the developers and users of the eco-technologies. Even in a perfect market, firms would only invest at a level that reflected their own financial returns – a level of investment below the appropriate level for society.

2.2.2 Potential Lack of Economic Efficiency of Existing Targets for 2015

Stakeholders have expressed concerns that changes in vehicle composition create challenges for the currently specified 2015 recycling and recovery rates[29]. If technological progress were to halt, current commercial practices do not allow for profitable recycling and recovery at the 85%, 95% levels stated in the ELV Directive.

2.3 Parties Affected

It is estimated that in 2004 there were on average 472 passenger cars per 1,000 inhabitants in EU25, with a span ranging from 659 cars in Luxembourg to 280 cars in Hungary[30]. 74% of all vehicles put on the EU25 market were marketed in 5 Member States: 20% on the German market, Italy (16%), France (15%), UK (13%) and Spain (10%). ELV waste in 2015 is likely to be greatest in these Member States, although a growing trade in second-hand vehicles will divert some of the need for ELV treatment to new Member States (also Bulgaria and Romania as of 1 January 2007). This will bring about a large % increases in ELV arisings in the eastern EU Member States[31]. Overall, it is expected that because of an average old age of the car fleet in the new Member States, these countries will face a challenge of an increased amount of ELV deregistrations and their treatment. In 2004, 74% of all passenger cars registered in the Czech Republic were over 10 years old[32], while in Ireland it was only 13.8%. These trends are already reflected in investments made in new Member States to tackle the increase of ELV waste: for example Recycling Technologies, a subsidiary of Spanish engineering firm Equip Tecnic Santandreu, is building a €4.5m car shredding site in Hungary. The site, which will open in 2007, is claimed as the largest in central Europe. It will have a capacity of up to 30,000 cars a year, and recycle 20-30,000 tonnes of scrap metal[33].

The practice of ELV treatment in connection with the legal requirements has lead to the establishment of a system of economic operators involved in the management of this waste stream. The parties which are involved in this policy area and affected by the ELV Directive include stakeholders involved in vehicle manufacturing, sales, collection, depollution and dismantling, recycling and recovery, in particular:

- Consumers,

- ELV collectors, dismantlers, shredders, recyclers, and other businesses involved in waste management,

- Users of raw materials that can be substituted, e.g. steel and cement makers,

- Waste and recycling technology firms, mainly SMEs,

- Vehicle Manufacturers and producers of raw materials used in vehicle manufacture (metals, aluminium, plastics, rubber, textiles etc.),

- National or regional authorities.

3. Objectives

Summary To set appropriate reuse, recycling and recovery targets for ELVs from 2015 onwards that will maximise the net environmental and economic benefits of treatment of ELV waste, making best use of the EU's potential for innovation. |

The 2015 targets should be set to meet the ELV policy objectives below. In this way, specific objectives for 2015 ELV Directive targets should:

- reduce the disposal of ELV waste,

- improve the environmental performance of the treatment of ELV waste,

- promote innovation in waste management technologies

in ways which balance positive economic, environmental and social impacts against negative impacts.

3.1 EU Sustainable Development

The EU Sustainable Development Strategy [34], aims at meeting the needs of the present generation without compromising the ability of future generations to meet their own needs. The Strategy identifies 7 key ways to ensure sustainable development, including an increase of the EU's global market share in the field of environmental technologies and eco-innovations. To this end, the Commission and the Member States are engaged in a dialogue with business and relevant stakeholders aiming at setting environmental and social performance targets for products and processes and to promote and disseminate eco-innovations and environmental technologies.

The Strategy calls for improving resource efficiency to reduce the overall use of non renewable natural resources and the related environmental impacts of raw materials use, thereby using renewable natural resources at a rate that does not exceed their regeneration capacity. In particular, it aims at avoiding the generation of waste and enhancing efficient use of natural resources by applying the concept of life-cycle thinking and promoting reuse and recycling.

3.2 Lisbon Strategy

The Lisbon strategy (or the Strategy for Growth and Jobs ) is one of the European Union's top political goals. The "Integrated Guidelines for Growth and Jobs for 2005 – 2008"[35] addressed to Member States and the European Commission recommend actions aiming to raise the welfare of European citizens, notably through addressing growth performance and insufficient job creation. The micro-economic guidelines place particular importance on policies to boost Research and Development and to promote diffusion of innovation. Guideline 11 focuses on encouraging the sustainable use of resources and strengthening the synergies between environmental protection and growth, particularly through the spread of eco-efficient technologies.

3.3 European Union Resources and Waste Objectives

The key environmental objectives for the European Community are laid down in the Sixth Community Environment Action Programme (6EAP) which sets out a framework of goals and actions for ten years starting from 22 July 2002[36]. The objectives of the 6EAP in the field of the sustainable use and management of natural resources and wastes include “increasing drastically resource and energy efficiency; a significant reduction in the quantity of waste going to disposal and the volumes of hazardous waste produced, while avoiding an increase of emissions to air, water and soil; encouraging re-use for wastes that are still generated (…); preference (…) to recovery and especially recycling", and minimisation of the quantity of waste going to disposal. This programme forms one of the underlying drivers for the revision of the 2015 targets of the ELV Directive.

According to the Thematic Strategy on the sustainable use of natural resources[37], European economies depend on natural resources, including raw materials. These resources are crucial to the functioning of the economy and to our quality of life, and their efficient use contributes to growth and is a key of long-term prosperity. Although Europe has improved its material efficiency over the past 20 years, the need to reduce the negative environmental impacts generated by the use of natural resources and, at the same time, improve resource productivity across the EU economy, remain a major challenge. This challenge is also addressed by this policy measure.

Waste treatment in the EU is governed by a concept known as waste hierarchy, according to which preference should be given to waste prevention, followed by reuse, recycling, energy recovery, and - if none of these options can be used - disposal. Recently adopted Thematic Strategy on waste prevention and recycling[38] reiterates this hierarchy and states that waste policy should have a purpose of contributing to reducing the environmental impacts associated to resource use. It underlines that landfill is the worst waste management option which should be avoided because it accounts for lost resources and potential environmental liability in the future. The Strategy points out that the goal should always be to move up the hierarchy if environmentally and economically feasible with an objective to make Europe a recycling society . In order to achieve these aims, the Strategy calls for encouraging recycling.

The Waste Strategy introduces life-cycle thinking in waste policies, which allows defining environmental impacts on all levels of resource use: "from cradle to grave", which has strong implications also for this impact assessment.

4. Policy Options

This IA report evaluates a range of options for the 2015 targets, using examples of targets as illustrations:

Policy Option | Illustration |

Recycling | Recovery |

No Policy Change (baseline scenario) | 85% | 95% |

Reduced Recycling Target | 80% | 95% |

Reduced Recovery Target | 85% | 90%* |

Combination of different reductions in reduced Recycling and Recovery Targets | 80%* | 85%* |

* an example of a possible target

The analysis shows that the impacts of reductions in the two targets are additive, so that combined targets of e.g. 80% reuse/recycling and 85% reuse/recovery can be considered by combining the analysis of a reduction to 80% reuse/recycling with the impact of a reduction in the reuse/recovery target to 85%.

The targets have been chosen at 5% intervals, which serves to illustrate the direction of changes in impacts resulting from changes in the targets.

4.1. Differences between Policy Options due to Definitions

The difference between the policy options is the need for diversion of fractions of the ASR between various treatment and disposal routes. Recycling is defined in the ELV Directive (Article 2) as "the reprocessing in a production process of the waste materials for the original purpose or for other purposes but excluding energy recovery. Energy recovery means 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".

Certain treatment processes for ASR clearly fall under either recycling or recovery, whilst others are less obviously described. For the purposes of this IA report, use of shredder fibres in treatment of sewage sludge is classed as recycling, whilst use of treated ASR in blast furnaces is classed as recovery.

4.2 Other Options not Described in Detail Here

Different ways in which the targets contained in the ELV Directive could be approached have been identified by stakeholders. These ways ranged from the complete removal of any targets, a removal of one of the targets, adopting a combination of material based targets, moving to a landfill ban (allowing 5% of ASR to go to landfills), introduction of a set of process standards for recovery and recycling of ASR or a combination of options. Not all these options have been discussed in detail in this impact assessment report for several reasons.

Firstly, the impacts of removal of one or both of the targets can be seen from the assessment presented here – as reductions in targets to levels below what would be achieved anyway by existing market practice. The Commission has based its assessment on life-cycle analyses of various treatment options for plastic parts of vehicles conducted by the Fraunhofer Institute (2002)[39] and APME[40]. These analyses show significant environmental benefits from plastics recycling and recovery, particularly obvious when ELV materials are sorted and treated appropriately by fraction. The assessment of reductions in targets is sufficient to indicate that removal of the targets or an introduction of a landfill ban (allowing 5% of ASR to go to landfills) would be significantly worse than the reductions considered. Landfill bans and landfill reduction targets have a similar effect as recycling targets in redirecting waste streams. However, they need to be seen in relation to which waste management option could possibly be used subsequently to achieve the greatest environmental benefit. Recycling targets cannot be simply replaced by landfill bans and landfill reduction targets if this would result in an increase of incineration at the detriment of recycling and the overall environmental benefits of the Directive.

Secondly, as regards an introduction of a combination of material based targets or of a set of process standards for recovery and recycling, these options were indicated by the stakeholders but have not been considered by them in detail. Introduction of material based target would need to be considered in a much broader scope of all product specific directives, including in particular waste electric equipment which is treated together with ELV waste, but also other waste streams. This would extend the impact assessment to questions of approach to treatment of waste in general. As regards the process standards to be introduced instead of the targets, this option suggested by the stakeholders was too vague and undefined to make it suitable for consideration here, raising in particular such questions as who would carry out the assessment, under which criteria, and how to guarantee transparency of the process and avoid hindering of innovativeness.

Finally , changes to the form of the policy instrument in the ELV Directive such as complete removal of targets or introducing process standards are outside the scope of the assessment as the discussion on the type of instrument was finalised with the adoption of the ELV Directive that selected binding recycling and recovery targets as appropriate instruments. Significant change to the ELV Directive that is currently being implemented by the Member States and industry would also reduce regulatory stability, potentially damaging legislative credibility after industry has made investments towards meeting 2006 targets.

4.3 Linkage to Other Policy Measures

The selection of targets does not stand alone as a policy instrument to tackle the blocks to innovation affecting development of ELV treatment technology. In analysing the impacts of targets, consideration is given to the strong linkage between the results of the targets and other complementary policy instruments, particularly in those that promote investment into R&D for innovation in waste treatment, including those mentioned below in section 5.4.

5. Analysis of Impacts

Summary Assessment of the impacts of different policy options indicates a wide range of substantial impacts on both the environment and the EU economy, with an indicative maximum economic difference in processing costs between options of €16bn over a 10 year period from 2015. The stakeholders directly affected by difference in the options are the EU waste management industry, suppliers of waste technology and, potentially, consumers. Impacts on the automotive industry are estimated to be insignificant. Differences in impacts between options are significant, but relatively small in the general waste context: waste generated by ELVs constitutes less than 0.7% of the total amount of waste generated in the EU annually[41], with ASR representing between 3 and 4% of all hazardous waste generated in the EU; changes in costs per vehicle represent around 0.3% of the life cycle economic cost of a vehicle; even extreme assumptions show ELV treatment accounts for a maximum of 3% of the environmental life cycle impacts of a vehicle[42]. |

- 5.1 Discussion of Stakeholders Views

The Commission has welcomed the views of stakeholders on the impacts of target levels, many of which have been crucial to building the analysis of impacts. Stakeholder conclusions about the impacts of the targets differ and the reasons for this are discussed in Annex 2. Three important views are taken here:

View 1: Achievement of 85% recycling 95% recovery targets makes an insignificant difference in terms of the life-cycle impact of a vehicle. The Commission agrees that the impact is a small proportion of the life cycle impact of a vehicle. Yet, when applied across the EU ELV waste arisings, the environmental benefits are substantial, whilst still small in proportion to the total impact of vehicles. The economic benefits are similarly substantial, but small in relation to the total lifetime expenditure on personal road transport in the EU.

View 2: Achievement of 85% recycling targets will be environmentally disadvantageous as changes to vehicle design to achieve recycling reduce the lifetime environmental performance of vehicles . To date, the targets for treatment of ELVs have not led to design changes in vehicles which affect the weight or environmental performance of vehicles, and with 2015 ELVs having been mainly designed before 2001, no changes to future car design arising from a 2015+ 85% target can be expected. Recent increases in designed weight of vehicles are mainly due to consumer preferences and resulting market incentives for auto-manufacturers as well as safety requirements.

View 3: Achievement of 85% recycling will negatively affect the competitiveness of EU industry, in particular auto-manufactures. Since the targets apply equally to all ELVs in the EU, the EU manufacturers could not in any event be disadvantaged by recycling and recovery target levels in ways that non-EU competitors were not, even where targets imposed costs, which will not be the case. In fact, the economic benefits of slightly reduced material prices in the EU market could be available to firms manufacturing in the EU, where EU vehicle manufacturers are dominant.

5.2 Analysis of Impacts in the Future

It would be misleading to analyse the achievement of the 2015 targets on the basis of current practices and technology because there are clear tendencies towards a larger deployment of new waste treatment technologies in the future (see Annex XVIII). Therefore, the question asked here is not what the impacts of targets would be if they were applied now, but what the impacts will be if the targets are set now and apply in 9 years time. This affects the analysis in two ways:

A) practices, markets, technology in use will all have changed by 2015,

B) choice of options will – and is intended to – bring about changes in practices and technology by 2015.

This analysis must necessarily make predictions of practices and technology in 2015 and for the years afterwards. Views on practices and technology during that period must be based on the situation in 2006 and in the analysis these practices are the starting points for predictions.

This summary of effects and impacts is described in more detail in Annex I, together with the reasoning and assumptions behind the assessment. In summary, it is expected that by 2015 and under different targets (scenarios) the following shares of materials will go for different treatment routes:

Materials and Treatment Options | % for each scenario |

No Policy Change (High Tech) | No Policy Change (Low Tech) | 80% recycling, 95% recovery | 85% recycling, 90% recovery | 80% recycling, 85% recovery |

Recycling |

Ferrous metals | 66% | 66% | 66% | 66% | 66% |

Non-ferrous metals | 9% | 9% | 9% | 9% | 9% |

Fluids | 1% | 1% | 1% | 1% | 1% |

Tyres | 2% | 2% | 1% | 1% | 1% |

Batteries | 1% | 1% | 1% | 1% | 1% |

Plastics | 7% | 2% | 2% | 7% | 2% |

Shredder sand (glass, road dust, rust, etc) | 4% | 4% | 0% | 4% | 0% |

Recovery |

Fluids | 1% | 1% | 1% | 1% | 1% |

Tyres | 1% | 1% | 2% | 2% | 1-2% |

Plastics | 5% | 10% | 10% | 0-5% | 0-10% |

Other residues (textiles, rubber) | 2% | 2% | 2% | 2% | 2% |

Landfill |

Other residues from shredder sand (glass, road dust, rust, etc) | 1% | 1% | 5% | 1% | 5% |

Plastics | 0% | 0% | 0% | 0-5% | 0-5% |

Table 3 Shares of materials going for different treatment routes under different targets and scenarios.

For each of the options considered, recycling possibilities of plastics will play a key role. Technology exists and is being used commercially to produce plastics recyclates from waste to a standard that meets some market demands. In order to recycle plastics for more than the most basic uses, it is necessary to have pure inputs of waste. In this respect, the development of technology to separate plastics from shredder residue is essential to the development of recycling of plastics from ELVs.

At the moment, with the most advanced post-shredder separation techniques used in industrial operations, 15-25% of shredder residue will go to a plastics mix fraction that is sent for recycling, depending on the specification of the plastics mix. Thus, plastics representing 7% of the ELV by weight would go to recycling operators.

From this fraction, currently only parts of the PE and PP and ABS/HIPS fractions are sometimes used for recycling, with up to 2% of the ELV by weight becoming recyclates. Where the current maximum of polymers (PE, PP and ABS/HIPS) is used this proportion might reach 4%, though this is not currently done.

Developments in separation technology in the period up to 2015 would allow greater extraction of a greater range of polymers and in turn lead to a greater proportion of ELV plastics made into recyclates. The increase in the proportion depends on technological developments and is not possible to predict with any certainty.

The market demand for recycled polymer material depends on the properties of this material. Today, demand exists for any plastic recyclates that can be used to substitute for virgin plastic in a way that allows the resulting plastic part to meet the properties required, as recyclates are typically cheaper than virgin material. The recyclate price lies below the price of virgin material and is an incentive for manufacturers to use the recyclate.

Closed-loop recycling for vehicle applications is not easy and is often done in parts that are not seen by the car-user. Today, an increasing number of car manufacturers incorporate recycled components into their vehicles, however the use of recycled plastics is hindered by plastics manufacturers who are unwilling to undermine their virgin plastic market by developing use of recyclates. The specifications of plastics used in modern cars means that closed-loop recycling of ELV plastics is unlikely to reach more than a low percentage of plastics recycled from ELVs.

5.3 Scenarios for Future Technological Development

R&D investment is very likely to result in further commercial development of the existing technologies or the development of new treatment technologies. To reflect the possible range of resulting effects, the Commission has assessed the impacts in a scenario of the High Technological Development and of the Low Technological Development, based on information described in section 4 of Annex I. These scenarios show the ends of the range of impacts, with the actual impact lying somewhere in between

Under the High Technological Development Scenario , around half the plastics in ELVs would be able to by recycled from 2015 onwards (a large proportion of PP, some PE, ABS/HIPS and some PA), a greater proportion of tyres would be recycled and much of the shredder sand fraction could be made inert and used in construction (see table on p. 20).

This scenario is based on an assumption that between 2006 and 2015 technological progress allows greater separation of material fractions (in particular, a polymer recyclate of a high degree of purity from part of some major groups of ELV plastics: PP, PS, PE and PA) within ASR and greater use of the material and energy contained in ASR. This would allow 70kg of plastics (out of 130kg) to be recycled. To bring about this additional technological change would require policies that stimulate both R&D in new technologies and an uptake of technologies.

This scenario would achieve reuse and recycling of 90% of ELVs, with the potential (not shown in the table above) of higher recycling if the use of shredder fibre as a dewatering agent for sewage sludge takes places and is included as recycling. This may provide a use for around 7% of the ELV, comprising plastics, remaining tyres, textiles and rubber. However, under an 85% target, recovery may be a more financially attractive option for this fraction.

Under the Low Technological Development Scenario , a significantly smaller proportion of ELV plastics would be recycled, a proportion of tyres, and either the majority of shredder sand or the fibrous fraction of ASR would be recycled (see table on p. 20).

It is possible that the fibrous fraction of ASR, which would be made up of around 5% of plastics with textiles and rubber, is recycled to meet the 85% target instead of shredder sand.

5.4 Innovation and Competitiveness - Other Policy Measures

Whilst the level of targets has an impact on the incentives for innovation in waste treatment, it will not affect all the blocks to innovation. Other existing and planned policy instruments can tackle some of those blocks. The impacts from setting the levels of particular targets will be influenced by the effect of these other policy measures.

Many of these solutions could be addressed and further developed with European projects and initiatives under the Competitiveness and Innovation Framework programme, a flexible programme which could be partly directed to tackle the issues of shredder residue treatment. Moreover, Members States should be encouraged to implement the Community strategic guidelines on cohesion by using funding earmarked for eco-innovation under the European Regional Development Fund, the Cohesion Fund to further the promotion and uptake of advanced shredder technologies. However, financial assistance from these funds is only possible provided it is given according to the objectives, rules and procedures applicable to these funds respects the polluter pays principle. Moreover, the upcoming 7th Research Framework Programme has a clear priority research in the area of life strategies for vehicles, vessels and infrastructures.

To support the diffusion of high technology shredder residue solutions, efforts could be made to raise awareness and support the uptake of technologies among the shredder industry, to educate all players involved (businesses, procurers, investors, national and regional authorities, etc.) about the possibilities that these new technologies offer as well as create incentives for the use of high technology recycling and recovery by shredders. The measures could include:

- Pro-active promotion of innovative shredder technologies and plastic recycling,

- Programmes that professionally accompany the technology transfer process (patenting, licensing, market analysis, market introduction, financing, etc.),

- Promotional and educational activities towards public and private procurers (shredder and recycling technologies) encouraging the uptake of innovative technologies.

At the same time, it would be necessary to facilitate access to finance by, for instance, addressing investors which are specialising in the area of eco-innovation / environmental technologies in a special financing programme and informing them about the opportunities that new technologies offer, thus facilitating investment decisions in this area. Moreover, the Competitiveness and Innovation Programmes (CIP) of the European Commission foresees considerable funds for investments in eco-innovative technologies and businesses. This funding could be used to set up a special fund focusing, for example, on recycling industries and technologies.

5.5 Estimation of the Economic Effects of Different Targets

This Impact Assessment has examined the economic impacts by looking at the total value and cost generated across the ELV disposal chain in 2015 from deregistration to disposal, identifying which parties gain or bear cost.

The value of an ELV is made up of the value of ferrous metal for recycling (a % of the value of the recycled metal), the value of non-ferrous metals for recycling (a % of the value of the recycled metal), the value of the recycled plastics, the value/cost of the final use/disposal of the mineral fraction, and the value/cost of use/disposal of the fibrous shredder light fraction and un-recycled plastics.

Out of this net value, there are certain costs of the processes steps, including the cost of shredding, of advanced post-shredder sorting and separation, of processing high plastic fractions into plastic recyclates, transport costs (of an ELV going to shredder and of shredder fractions going to next use/disposal), depollution costs, and – possibly - dismantling costs.

The difference between the values and the costs is shared between the price paid to the last owner/supplier of the ELV, and the profit taken by the dismantler, shredder, plastics recycler, and the receiver of fractions for final disposal (e.g. landfill owner or cement kiln operator). In a market economy, the net value of the ELV would be expected to be spread between these parties, though market pressure may give one of the parties/firms a strong position to be able to extract most of the benefits.

It is clear that the net economic benefit of the treatment of ELVs will depend on the price of metals, the costs of processing, and the value of recycled plastics. Note that there will be no costs for automobile manufacturers, whose liability depends on the legislative regime in the Member State, but who in many Member States currently have no legal financial liability for the costs of ELV treatment, even if those are negative.

The details of the calculations based on the above value and costs chain are described in section 8.2 of Annex I.

5.6 No Policy Change (85% recycling, 95% recovery)

Effects

The 85% and 95% targets will reduce some of the existing blocks to research and development in waste treatment technologies, and in diffusion of those technologies. An 85% recycling target creates certain markets for both advanced post-shredder technologies and advanced polymer recycling technologies. This will substantially increase R&D investment in new technologies by reducing the risks that lead to sub-optimal investment in R&D. Keeping the current 2015 targets gives seven years for R&D and two years for commercial installation of the technologies to meet the targets.

The result will be technological development that is higher than the low technological development scenario, but how much higher depends on the success of increased R&D in promoting innovation. Where complementary policy measures – of the kind suggested in section 5.4 above – are applied, the impacts of targets are more likely to be close to the High Technological Development Scenario, which forms the upper bound of likely progress.

Even if there was no further technology development, 85% recycling target would boost the diffusion of the existing most efficient technologies.

The assessment of impacts below looks at the impacts at the two ends of the ranges.

5.6.1 Environmental Impacts

5.6.1.1 High Technology Development Scenario

- Recycling of Plastics

The environmental benefits of plastics recycling depend on the balance between the negative environmental impact of the plastics recycling process and the avoided impacts from production of the material replaced by the recycled plastics. If the recycled plastic product has significantly different physical performance characteristics, it might have additional environmental impacts. Negative environmental impacts may also come from the additional activities required to separate plastics from other materials and any difference in the transport of plastics to recycling facilities compared to transport to recovery or landfill facilities.

The different polymers in ELVs have different characteristics which affect the impacts from the recycling process. Numerous studies on the treatment of ELV plastics indicate that the benefits of plastics recycling as compared to recovery are not always environmentally clear. The evidence on individual polymers is clearer. The use of a recyclate depends on its physical characteristics and therefore on its purity. When the impacts of recycling into granulates are discussed in this impact assessment, it refers to the recycling of sorted polymers into recyclate. Only part of the plastics in an ELV would be able to be treated in this way, even under the highest technological scenario considered.

Key environmental benefits come from the recycling of the plastic fraction representing 7% of ELV by weight. For the EU, this would represent recycling of around 988,000 tonnes[43] of plastics per year and:

- estimated environmental benefit of saving 980,000 tonnes of CO2 equivalent a year[44], or approx. 10 m tonnes of CO2 equivalent over 10 years[45], compared with manufacturing of virgin plastic.

- substantial environmental benefits from reductions in photochemical oxidation, air acidification, water pollution, water eutrophication and reductions in waste generated[46].

It should be noted that these figures relate to polyolefins (example of a PP/EPDM bumper) and can change for other resins.

- Recycling of shredder sand and tyres

This option would neither generate significant environmental benefit nor significant environmental costs, indicating that it would result in a small increase in CO2 emissions.

- Recovery

Increased recovery could bring about a reduction of over 200,000 tonnes of CO2 equivalent[47] per year mainly from the substitution of other fuels[48].

5.6.1.2 Low Technology Development Scenario

- Plastics Recycling

Significant environmental benefits are generated by the recycling of 2% of the plastics:

- savings of 280,000 tonnes of CO2 equivalent[49] per year or approx. 3 m tonnes[50] over 10 years,

- correspondingly smaller, but still substantial environmental benefits from reductions in photochemical oxidation, air acidification, water pollution, water eutrophication and reductions in waste generated.

- Recycling of Shredder Sand and Tyres

This recycling process would have small negative impacts on greenhouse gas emissions.

- Recovery of 95% of ELVs

High recovery level could generate important environmental benefits, in particular CO2 emissions reduction of 450,000 tonnes of CO2 equivalent/year[51], but which is not large enough to offset the lost benefits from reduced recycling[52].

5.6.2 Economic Impacts

In the low technology development scenario , the net added value of the ELV treatment process with the 2015 targets would be between €80 and €55 [53] per ELV . Therefore, the minimum net added value of the ELV treatment process in this scenario for the estimated number of ELVs arising in 2015 would be €760million per year. With the ELV targets assumed to operate over10 years and the economics taken to remain similar, the added value of the process under this set of targets would be €7.6bn [54] . This value would be shared in profit between the operators involved in the ELV process, with, most likely, some payment to the last owner.

In the high technology development scenario , a greater share of plastics could be recycled at a higher value, while some disposal costs and the costs of the separation process would be smaller. Based on the assumptions presented in table on p.20, the net added value from the treatment of an ELV would be between €120 and €90 . Therefore, the total maximum value of the ELV treatment process in this case for the estimated number of ELVs arising in 2015 would approximate €1.6 bn per year, giving the maximum value of the process of €16bn over the 10 year period under this set of targets.

Thus, with the future impacts estimated to lie within the range of these scenarios, the ELV treatment process under the 85% recycling and 95% recovery targets has substantial net economic benefits on reasonable assumptions, with the benefit being greater with greater technological development.

5.6.2.1 Impacts on Costs in the Economy

New technologies would provide greater resource efficiency by facilitating the recycling of increased shares of plastics in ELV and WEEE waste, production of better quality secondary materials, and providing those at lower prices than the existing materials that are substituted. This will reduce the costs of the EU economy in terms of energy costs (plastics are substituted for fuels or electricity generation) and of plastics processing feedstock. Even with low technological development, the best technologies currently available offer cost advantages over the use of current practices. In the future, it is likely that these costs substantially decrease following a typical decrease pattern of the costs of new technologies.

5.6.2.2 Impacts on the Technology Export Potential of the EU

Stimulation of R&D in this area may make the EU the world leader in a technology market with great potential. The resource from ELV and WEEE waste is growing across the world and many countries in the world are developing recycling policies for ELVs as the number of cars increases globally. Technologies that offer products from these waste streams that can substitute currently used virgin materials at lower prices have a large global potential.

5.6.2.3 Economic Impacts on EU Vehicle Manufacturers

There will be small savings to the EU vehicle industry from the promotion of high-quality plastics recycling, a decrease in any potential liability from increased value in the ELV treatment chain, whilst other costs to vehicle manufacturers will not be affected by 2015 targets. Very little impact on the design of vehicles is expected, as changes to design started now for new cars will only change the composition of the typical end-of life vehicle in 2021 onwards.

5.7 Reduced Recycling Targets (illustrated by 80% recycling and 95% recovery targets)

Effects

The 80% recycling target can be met without the use of new technologies, with some efforts to increase dismantling of large plastics, glass, or tyres. In fact, several Member States have already achieved the 80% or higher target for recycling[55], or are close to its attainment.

The change in the target from 85% will significantly slow down development of new technologies, removing incentives for technological development and increasing the risks to companies planning any R&D investments. Moreover, the 80% recycling target will slow diffusion of current most eco-efficient technologies.

Technology for recycling of plastics out of ASR will cease development. Recycling of plastics will continue to take place through dismantling.

This policy option would lead to the recycling of 75% of metals, 3% of tyres, fluids and batteries, and 2% of plastics. The majority of ELV plastics (10%) would be recovered, together with 5% of other materials including the remaining tyres, fluids, textiles and rubber. The remaining 5% of shredder residue mainly composed of glass, road dust, rust etc. would be landfilled.

The impacts of the option are described as changes against the baseline scenario.

5.7.1 Environmental Impacts

- Recycling of metals

Economic incentives continue to remain for the separation of all metals from ASR and by 2015 this can be expected in well-run shredding operations[56]. However, lower targets for recycling will discourage the spread of advanced post shredder sorting technology to shredding yards across the EU. This would lead to the situation where less progressive shredding firms continue with their existing practices, leaving a proportion of ferrous and non-ferrous metals in the shredder residue which eventually goes to landfill.

The reduction in metals recycling against baseline can have substantial environmental costs which, however, are not quantified.

- Recycling of plastics

Compared to the 85% high technology development scenario, plastics constituting 5% of the ELV by weight will go to recovery rather than to mechanical recycling which amounts to around 700,000 tonnes[57] per year in 2015 onwards. A key environmental impact of this 80% recycling target will be the difference between the environmental impacts of plastics going to recovery compared to the estimated impacts of their recycling in 2015. As a result, depending on the type of plastic considered, significant environmental harm could occur, for example 500,000 tonnes[58] of additional CO2 emissions would be produced per year, or an indicative 5 million tonnes[59] over a 10 year period. It should be noted that these figures relate to polyolefins (example of a PP/EPDM bumper) and can change for other resins.

Compared to the 85% lowest technological development scenario (in which there is very low technological development by 2015), there would be no environmental impacts from the treatment of plastics.

The environmental benefits foregone from this option depend on the technological development that would be achieved by R&D stimulated by 85% targets.

- Recovery of the remainder of the shredder light fraction not mechanically recycled and landfill or reuse of the mineral fraction

The parts of the shredder light fraction that went to recovery in the baseline scenario will continue to be recovered. With consistent assumptions on the recovery used and the environmental impacts of those routes, the environmental impacts of this part of ELV waste will be unchanged from the baseline. There will be no significant change compared to the baseline scenario as regards the disposal route of the mineral fraction of shredder residue.

5.7.2 Economic Impacts

5.7.2.1 Impacts on Direct Costs of ELV Treatment

The direct economic impacts on costs of this option depend on the cost advantages foregone from technological innovation not becoming available to be used in 2015 onwards.

Again, the range of economic impacts depends on the assumptions of innovation under the no policy change option. If no additional innovation would have taken place under an 85% recycling target, there would be no cost difference under this policy option. If, however, the high technological development scenario under the 85% recycling and 95% recovery target is predicted, the estimated maximum lost direct benefits will be the difference between the high technological development scenario under the 85% recycling target and the lowest technological development scenario without the targets. This is the situation where lower targets undermine existing technological development and the level of technology remains as it does in 2006, with the use of the techniques available now[60].

If high technological development is assumed under 85% recycling targets and a pessimistic view is taken of technological development under an 80% target (zero technological development), dismantling might remain the route to attain the 80% target. In this case, the value from the ELV chain would be between +€35 and -€15. The maximum negative economic impact of this option would then be €1.1bn a year (€85 times 13.8m), as explained in Annex I, p.50

If low technological development was predicted under 85% recycling targets and an optimistic view is taken of development under an 80% recycling target (the line that setting of targets will make no difference to innovation development and dissemination), there would consequently be no difference in economic value between the treatment – this option would have neither economic costs nor benefits.

5.7.2.2 Impacts on Competitiveness

Apart from the loss of direct costs savings, the negative impacts on innovation mentioned above will have further negative impacts on EU competitiveness from the increased costs to the economy, reduced resource efficiency in Europe, greater imports of raw materials, and the loss of export markets for waste technologies. These costs are hard to quantify and monetise, but nevertheless significant.

5.8 Reduced Recovery (scenario 85% recycling and modified recovery target)

Effects

Under this policy option, the impacts of high recycling will remain unchanged. The major change compared to the baseline scenario includes a diversion to landfill of some of the plastics that were previously going to recovery.

With lower targets for recovery, the percentage of ELVs that go to recovery or landfill will be determined by the relative prices of landfill and recovery options available in each Member State. If in one Member State landfill costs €150/tonne including gate fee and tax, while at the same time a cement kiln accepts processed shredder residue at a cost of €120/tonne (including processing costs), then the maximum feasible percentage of shredder residue would go to cement kilns whatever the recovery target. There may be limited capacity in several recovery options in many Member States, in which case not only the price, but also the availability will determine the proportions of ELV going to either recovery or landfill. Because of these variables, it is not possible to precisely estimate the possible impacts of decreased recovery without relying on probable assumptions on the situation in each Member State.

In Member States where landfill in 2015 remained more economic than recovery, the maximum diversion from recovery to landfill from lowering recovery targets (with an 85% recycling target in place) would be the diversion of 9% of the ELV by weight (made up of 6% plastics, 1% tyres, 2% other rubber and textiles.)

Whilst this assessment considers the impacts of the 85% recycling and 90% recovery targets, other targets for recovery below 95% would have similar impacts for each % target reduction.

5.8.1 Environmental Impacts

Under the assumptions used, diversion of plastics from recovery to landfill would be the key environmental impact. A 90% recovery target allows for landfilling of 10% of ASR, which would most likely result in the maximum of a diversion of plastics making up 5% of the ELV. This could result in production of a maximum of 480,000 extra tonnes of CO2 equivalent/year with substantial increases in air acidification, water pollution and eutrophication, and photochemical oxidation.

This diversion would also lead to detrimental environmental impacts including the loss of resources, occupied space, and potential problems linked to landfill of shredder residue (pollutant discharge via leachates from plastics). Moreover, a cross contamination of the material in the shredding process due to its contact with pollutants from other waste streams such as PCBs may occur[61], which has led some Member States to classify ASR as hazardous waste and to ban its landfilling completely. Finally, higher landfill rates bring about various disamenity effects including visual disturbance, noise and odours.

The environmental impacts of a decreased recovery target compared to the baseline are estimated as a difference in environmental impact per tonne between landfill and recovery, multiplied by the number of tonnes estimated to go to landfill instead of recovery. Again, the key environmental impact will be the change in high-calorific plastics and rubber that go to landfill instead of going to recovery options. The result will depend on the policy and mix of recovery options in each Member State.

For any change in the percentage other than 10%, similar calculations can be made. These calculations assume that changes in recovery targets bring about changes in the treatment of the shredder light fraction, with use or disposal of the inert fraction remaining the same.

5.8.2 Economic Impacts

The change in direct costs to the economy from changes in the recovery targets will depend to a large extent on the costs of landfill[62] relative to other disposal options. With the costs of recovery options estimated at between €80 and €100 per tonne, depending on the level of innovation expected under the baseline scenario of 85% recycling / 95% recovery, only landfill prices below €80 and €100 per tonne would have any impact on the economic costs as the amount recovered would not change. If landfill prices were above those figures, a reduction in the recovery target would not make any difference. Note that permitted trade in shredder residue might allow landfill outside the boundaries of the Member States with high landfill costs.

If we illustrate these costs by comparing the likely €80 recovery cost with a landfill cost of €65[63], the impact will be an decrease in costs of €15 for each tonne landfilled. With 5% extra of each ELV going to landfill, being 708,000 tonnes, this would amount to around €11m per year, or €110m over 10 years.

5.9 Combinations of Different Reductions in Reuse/Recycling and Reuse/Recovery Targets (illustrated by 80% recycling and 85% recovery target)

The effects of this option can be estimated as the sum of the effects from separate reductions in either the reuse/recycling or the reuse/recovery targets. For 80% recycling and 85% recovery targets these will be the impacts from a reduction of 5% in recycling and 10% in recovery, with the main impact being the continuation in blocks to innovation to waste treatment technologies.

5.9.1 Environmental Impacts

The environmental impacts of this option are the sum of the impacts from lowering recycling targets from 85% to 80% plus the impacts of lowering the recovery targets from 95% to 85%.

Compared to the high technological development scenario, this will result in substantial environmental harm, including the release of 0.8 million tonnes of CO2 equivalent a year.

5.9.2 Economic Impacts

Similarly, the economic impacts are the sum of the impacts from lowering recycling targets from 85% to 80% plus the impacts of lowering the recovery targets from 95% to 85%. Using the calculations of these impacts from consideration of the two options above, there are costs from the lowering of recycling targets with either costs or benefits from lowering the recovery target depending on the relative price of recovery and landfill options in each Member State.

The change in recycling target would lead to costs of up to €1.1bn per year, or €11bn over a ten year period where technological development is foregone with no saving if no technological development under an 85% recycling target is foreseen.

The negative impacts on cost and competitiveness for the EU economy from lowering recycling targets remain as described above in Section 5.7.2

5.10 Administrative Burden of all Considered Policy Options

Under each option, the requirements on organisations to provide information appear likely to remain unchanged. In each case, the monitoring and reporting requirements of the targets will need to remain in place. As there appears to be no significant difference between the options on administrative burden, this has not been mentioned above under economic impacts.

5.11 Social Impacts of all Considered Policy Options

Changes in targets are not likely to produce any significant social changes. Further discussion of impacts on employment is contained in section 9.5 of Annex I.

6. Comparing the options

Summary The determining parameter in comparing the options is the environmental and economic performance of plastics recycling. Targets are technology forcing and lead to the development of the most eco-efficient ELV treatment technologies. The targets set today will shape treatment paths of ELVs beyond 2015. |

6.1 Environmental Impacts

The costs and benefits of different recycling and recovery targets will differ due to the various levels of plastics recycling, recovery or landfill. Since the change of the targets is unlikely to significantly affect the recycling of metals or other material fractions contained in ELVs, it was not considered here.

The relative environmental impacts of plastics recovery largely depend on various factors such as the recovery method used, the type of plastic resin used to replace fuels, and the type of substituted resources. The environmental performance of all plastic fractions contained in ELVs is not certain and differs from one resin to another. The most representative type of plastic used in vehicles – polypropylene (PP) – served as a basis for this assessment.

The table below illustrates the environmental impacts of different sets of targets considered above for all the impact categories considered. Note that the results are simplified, taking mid points of ranges. Particularly for the recovery target, changes in assumptions about the proportion of the ELV waste going to landfill rather than recovery would make a significant difference to the figures. Negative figures indicate environmental benefits from the treatment process.

85% recycling / 95% recovery | 80% recycling / 95% recovery | 80% recycling / 85% recovery | 85% recycling / 90 % recovery | unit |

Energy savings / losses | -79.539.040 | -62.745.280 | -39.041.440 | -67.687.120 | GJ |

Greenhouse gas emissions | -1.205.240 | -728.048 | -362.366 | -1.022.399 | t CO2 eq |

Air acidification | -17.886 | -6.770 | -5.248 | -17.125 | t SO2 eq |

Photochemical oxidation | -709.590 | -198.060 | -150.270 | -685.695 | kg ethylene |

Water pollution | 1.329.560 | 2.625.200 | 18.342.800 | 9.188.360 | m3 |

Eutrophication | -784.800 | -246.720 | 75.420 | -623.730 | kg PO4 |

Municipal waste | -81.413 | -196.746 | 612.427 | 323.173 | t |

Hazardous waste | 11.196 | 8.824 | 5.532 | 9.550 | t |

Table 4. Environmental impacts of different sets of targets.

The results illustrate that the environmental performance of the targets is not necessarily clear and depends on many variables.

As regards recycling and based on the assumptions made, the 85% level seems to be currently optimal as it allows for the recycling of all metals with clear environmental and economic benefits and increased recycling of non-metallic fractions (in particular plastics). The maintenance of the recycling target at 85% brings about the greatest net environmental benefit.

6.2 Economic Impacts

The estimated economic impacts of different options must be described as ranges, with the eventual impact dependent on the technological development that would come about under the baseline scenario.

In addition, the indirect costs of options (lost competitiveness benefits to the economy from lost export opportunities and reduced resource costs) have not been estimated. These are significant costs, despite not being given monetary value. The table below therefore only represents estimates of direct costs, under the assumptions described in section 8.2 of Annex I. Costs are given per year, and could be multiplied by 10 to give an indication of the costs over the likely lifetime of the policy.

Direct Costs (billion euros) | 85% recycling / 95% recovery | 80% recycling / 95% recovery | 85% recycling / 90 % recovery | 80% recycling / 85% recovery |

Maximum | Baseline | 1.1 | 0 | 1.1* |

Minimum | 0 | -0.11* | -0.11* |

* The impacts of reduced recovery targets are likely to reduce this cost in Member States where landfill remains cheaper than recovery. However, the value depends on Member State policy and relative landfill costs.

Table 5. Economic impacts of different sets of targets.

In the calculations assumed in this economic analysis, for clarity of understanding, ELVs from 2015 onwards are assumed to weigh approximately 1,000kg. Estimations of ELV weight based on the weights of new manufactured cars indicate that the weights will be around 1,280kg by 2019 and on an increasing trend. This increased weight increases the total value of the materials in the ELV, but also increases the costs of processing, which are typically estimated per tonne. These increases offset each other, but do not balance out exactly.

The effect of changing the assumption about the weight would be an increase of the net costs in the low and zero technological development scenario by around €4/ELV and an increase of the net value in the high technological scenario by around €4/ELV. As weights get higher from 2015 onwards this effect would increase, e.g. with the increase in value being €5 towards 2020.

This increase in weight therefore accentuates the difference between the value from scenarios by around €8 to €10/ELV, with the high technological development bringing €10 greater net value than the low technological scenario.

This sensitivity should be borne in mind when considering the estimates of value above.

6.3 Sensitivity Analysis

6.3.1 Factors Affecting Environmental Impacts

Various factors will affect the assumptions about environmental performance of treatment of ASR. Increases or decreases in any of the factors below will lead to corresponding increases or decreases in environmental impacts from recycling and recovery. Where they lead to increases, this will increase the environmental harm from reduction in recycling targets and, similarly, where they decrease, the environmental harm will become smaller:

- Efficiency of recycling process

- Development of sorting technology/purity of recycling inputs

- Diffusion of advanced technology

- Environmental performance of recovery options available in Member States

- Greater than expected use of plastics in vehicles

- Use of plastic and tyre fraction of ASR in sewage sludge dewatering (rather than other forms of tyre recycling).

6.3.2 Factors Affecting Economic Impacts

Increases or decreases in the factors below will lead to corresponding increases or decreases in the economic impacts of options:

- Price of oil – and so the price of virgin plastics

- Wage costs of dismantling

- The costs of plastic composition to be recycled

Also note that changes in the prices of metals, although showing an upward trend, are subject to fluctuations. Moreover, metal content of each vehicle is different: in some Member States the ELV park is composed of cars which contain less metals since more expensive vehicles with higher metal content tend to be exported at a certain age to other countries (where they become ELVs). Higher technological development will allow for greater separation of fractions and the reduction of processing costs. Therefore, it appears that if the higher targets improve treatment technologies, it will stabilise incomes of the treatment sector. On the contrary, lower targets bring about risks of additional costs for vehicle manufacturers if metal prices drop. According to the ELV Directive, manufacturers shall meet all or a significant part of the costs of free take-back. This means that they would need to pay collection and treatment facilities for dealing with negative value ELVs. It is therefore in the interest of producers to guarantee that the treatment of ELVs brings about a positive value for the treatment sector.

The assessment here assumes full compliance by 2015. If there is incomplete compliance, the environmental and economic benefits will be proportionately lower. However, a degree of incomplete compliance in some countries is unlikely to change the impacts of different targets for promoting innovation. Geographic pockets of non-compliance would reduce the demand for innovations, but not stop that demand.

Summary table comparing impacts of different illustrative options

OPTION | Baseline scenario 85% recycling 95% recovery | Reduced recycling 80% recycling 95% recovery | Reduced recovery 85% recycling 85 or 90% recovery | Combination 80% recycling 85% recovery |

Environmental |

Recycling | full metals recycling recycling of PP, PS and PA plastics, greater resource efficiency | (-) significant lost benefits from decreased plastics recycling | (=) no change | (-) Significant lost benefits from decreased plastics recycling |

Recovery | substitution of other resources' recovery | (=) no change | (-) lost benefits from reduced recovery | (-) lost benefits from reduced recovery |

Landfill | low levels of landfill | (=) no change | (-) moderate to high detriments due to increased landfill | (-) high detriments due to increased landfill |

Economic |

Costs for businesses (treatment sector) | high net added value per ELV treated | (+ to =) loss of net added value per ELV treated (depending on innovation level) | (?)costs dependent on relative costs of landfill and innovation level | (- to =) low net added value per ELV treated, high costs of treatment |

Costs for businesses (vehicle manufacturers) | (=) neutral or positive | (=) neutral | (=) neutral | (=) neutral to negative (if needed to compensate for negative value ELVs) |

Innovation and research | high potential for R&D leading to most eco-efficient treatment of ELVs, boost on diffusion of most efficient technologies | (-) foregone technological innovation because no clear signal is given, innovation is not encouraged | (=) neutral impact on innovation (boost from high recycling but limited by low recovery) | (-)foregone technological innovation because no clear signal is given, innovation is not encouraged |

Social | (=) No direct impact identified apart from a potential shifts of employment within the treatment sector. |

Table 6. Qualitative summary of environmental, economic and social impacts of different targets.

7. MONITORING AND EVALUATION

At Community level, the policy will be implemented by Article 7(2)(b) of Directive 2000/53/EC on end-of-life vehicles, which the Member States will need to implement in their national territories.

Developing tools to monitor and report progress in reducing the negative impacts of resource use in the EU, Member States and economic operators is one of the actions which need to be undertaken according to Thematic Strategy on the sustainable use of natural resources[64].

The Commission established the principles necessary to control compliance of Member States with the reuse, recovery and recycling targets in Commission Decision 2005/293/EC laying down detailed rules on the monitoring of the reuse/recovery and reuse/recycling targets[65]. Based on this decision, MS are obliged to collect data for the rates of reuse, recycling and recovery starting from 2006. Therefore, monitoring systems should already exist[66]. If not already in place, monitoring systems will need to be set up by the Member States. The results of the reports sent by the Member States will be assembled by the Commission and published on the website.

In particular, Commission Decision 2005/293/EC lays down in what way the calculation of the attainability of the targets should be made, which assumptions can be made in the absence of precise data, how to determine shredder output streams, and under which conditions exported ELVs can be calculated for the achieved targets of the exporting country. It also contains tables with material breakdowns and explanations on how to use them.

In addition, the Commission will encourage an exchange of best practices between the Member States within the framework of the Technical Adaptation Committee established on the basis of Article 18 of Directive 2006/12/EC on waste[67].

8. Conclusions

Setting levels of targets will affect not only the end point of fractions of ELV waste, but also the development of the technology to treat it. The environmental and economic impacts of treatment and disposal of ELV waste depend on the commercial availability and diffusion of technology.

Analysis of the state of innovation and progress to date indicates that confirmation of the current 2015 targets would reduce current blocks to innovation. This is likely, though not certain to bring significant environmental and economic benefits in the period from 2015.

The ELV Directive has triggered technological development in the area of ELV treatment, but new techniques have not yet diffused across the European recycling market. Continued development of treatment technologies to recycle some types of plastics would bring substantial the environmental benefits from recycling those plastics .Further support for the technological development is still necessary to overcome market failures, and changing the instruments, or lowering the targets of the ELV Directive is very likely to slow down or even stop this development, also endangering planning reliability. The observed lack of investment in PSTs has not been helped by the reduced regulatory stability caused by the clause of the ELV Directive requiring the review of the 2015 targets.

Comparison of different target levels demonstrates that no convincing arguments exist that could justify a modification of these targets: lowering of either set of the targets is most likely to increase both economic and environmental costs. At the same time, higher targets for recycling or recovery remove flexibility with no corresponding gain to innovation.

Whilst all estimations of future impacts for a period of 9 years in the future contain uncertainty and required assumptions, the Commission concludes that the 85% reuse/recycling and 95% reuse/recovery targets are currently optimal both in terms of environmental and economic performance and should remain stable in order to guarantee investment security into more cost-efficient technologies.

In addition, Annex I of the ELV Directive contains a set of mandatory requirements for treatment operations aimed to promote recycling, including an obligation to remove glass. If high targets for recycling and recovery are promoted, technological development is likely to allow the separation of glass fraction after the shredding process. This operation will be much less expensive than manual removal of glass, as confirmed by both stakeholders and Member States. Therefore, a possible amendment of Annex I in accordance with the procedure provided for in Article 11 of the ELV Directive should be considered in order to adopt it to scientific and technical progress and make the removal of glass optional if it is possible to segregate it in further treatment processes.

ANNEXES

TABLE OF CONTENTS

Annex I The Basis for assessment of environmental and economic impacts of different sets of the targets 44

Annex II Comments on Stakeholder views 102

Annex III The GHK/BIO Intelligence Service Report 109

Annex IV Environmental impacts of recyling PP/EPDM (per tonne) 111

Annex V Environmental impacts of recovery PP/EPDM (per tonne) 112

Annex VI Environmental impacts of landfilling PP/EPDM (per tonne) 113

Annex VII Qualitative Summary of Comparative Environmental Impact Assessment – All plastic resins (per kg) 114

Annex VIII (a) Environmental benefits of plastics treatment per resin and treatment option (per kg) Source: GHK/BIOIS 2006, p. 128. 119

Annex VIII (B) Environmental costs of plastics treatment per resin and treatment option (per kg) Source: GHK/BIOIS 2006, p. 129. 120

Annex IX Current practice per material – overview 121

Annex X Impact Categories 123

Annex XI Ranges of impacts per treatment option for all plastic resins (per kg) 127

Annex XII Global warming potential for different ELV materials and treatment options 128

Annex XIII Environmental impacts of different sets of recycling and recovery targets 129

Annex XIV Numbers of deregistered vehicles in the EU 135

Annex XV ELV Treatment sector in Europe 136

Annex XVI Typical landfill costs for ASR in the EU 137

Annex XVII Estimated composition of ASR in Germany, 1998 138

Annex XVIII List of Contributing Stakeholders 139

Annex XIX List of Abbreviations 142

Annex IThe Basis for assessment of environmental and economic impacts of different sets of the targets

1. General Approach taken in this impact assessment

This Annex explains the background of the impact assessment and details the assumptions and analysis made to evaluate the targets. It necessarily contains some overlaps with the text of the impact assessment, as it develops the various points addressed there. |

The main question raised in this analysis is not what the impacts of the different targets would be if they were applied now, but what the impacts will be if they are set now and apply in 9 years time and afterwards, which affects the analysis in two ways:

- practices, markets, technology in use will all have changed by 2015,

- the choice of options will bring about changes in practices and technology by 2015.

There is a significant scope of uncertainties as regards the possible future scenarios, which made it necessary to develop certain assumptions and make predictions of practices and technology in 2015 and afterwards explained in detail in this Annex.

Views on practices and technology between today and 2015 are based on the situation in 2006, which is the starting point for developing future scenarios. This analysis is not set out as the costs and benefits of moving from the 2006 situation to 2015 situation. The policy choice is between different alternatives in 2015 and afterwards.

This Annex contains the evidence and rationale behind the assessment of impacts. It explains the assumptions on which predictions of the future must rest and the consequences of those assumptions. The impact assessment is proportionate; it can not and does not attempt to answer every question or see how every change in assumptions affects impacts, but should serve as a framework for consideration of the issue and provide guidance as to the direction of impacts under different targets.

The analysis rests on a set of building blocks:

- Analysis of Future ELV Waste Streams

- Analysis of Potential Waste Treatment Options

- Innovation and Technological Development

From this basis, the Annex describes the method for estimation of environmental and economic impacts, before describing the likely treatment of ELVs under different options, and then estimating the impacts of those options.

It clarifies further assumptions and looks at how those assumptions and analysis build on or differ from stakeholders and the information provided to the Commission.

2. ANALYSIS OF FUTURE ELV WASTE STREAMS

ELVs may enter the waste stream from a variety of sources, including private individuals, garages, local authorities (in the case of abandoned vehicles) and insurance companies (in the case of accident damaged vehicles). In the UK, it is estimated that 10-15% of ELVs are accident damaged vehicles and that the remaining 85-90% have reached the end of their life naturally.

The average age of ELVs has been variously estimated at 15.3 years (Netherlands, 2004), 12.1 years (UK) and more than 11 years (Hungary). In the UK, TRL (2003) estimated the average age of ELVs as a whole at 12.1 years, with the average age of natural end-of-life vehicles at 12.8 years and that of premature end-of-life vehicles at 6.7 years (the average age of the vehicle park). The average used in the impact assessment is of 13 years.

ELVs from 2015 onwards will therefore mainly be vehicles already in use, being vehicles that were produced between 2001 and 2004. The weight and composition of these vehicles is known and an average can be taken[68]. According to GHK/BIOIS, an average end-of-life vehicle weighs approx. 964 kg and this weight is likely to increase to over 1,025 kg by 2015. Weighted averages for all car manufacturers show higher weights of ELVs e.g. of approximately 1,280 kg by 2019, being an average weight of a vehicle put on the market in 2006 as reported in the certificates of conformity (i.e. 1,391 kg) minus the weight of a driver, tools and extra fuel[69]. If this higher weight was used in the Impact Assessment, the direction of impacts would be the same, but they would be greater. The differences resulting from changed weight estimations are described in the relevant sections below.

GHK/BIOIS estimate the following volumes of ELV arisings:

Year | No ELVs Treated (000) | Average Weight (kg) | Weight of ELVs Treated (000t) |

2005 | 10,864 | 955 | 10,375 |

2006 | 11,124 | 964 | 10,724 |

2015 | 13,771 | 1,025 | 14,116 |

Table 1. Estimated weight of ELVs requiring treatment in the EU, GHK/BIOIS.

These figures are used in this analysis. If average ELVs weigh 1,280kg in 2019, there will be 17.6m tonnes or waste arising.

The composition of a 2015 ELV can also be estimated. In 2003, an ELV in the UK had the following composition:

Material/Component | % by weight |

Ferrous Metal | 68% |

Non Ferrous Metal | 8% |

Plastics and Process Polymers | 10% |

Tyres | 3% |

Glass | 3% |

Batteries | 1% |

Fluids | 2% |

Textiles | 1% |

Rubber | 2% |

Other | 2% |

Total | 100% |

Table 2. Typical Composition of an ELV, by Weight, UK, Source: TRL (2003)

Due to changes in the composition of vehicles, a 2015 ELV is estimated to have a smaller percentage of ferrous metal, and greater percentages of non-ferrous metal and plastic:

Material/Component | % by weight |

Ferrous Metal | 66% |

Non Ferrous Metal | 9% |

Plastics and Process Polymers | 12% |

Tyres | 3% |

Glass | 2% |

Batteries | 1% |

Fluids | 2% |

Textiles | 1% |

Rubber | 1% |

Other | 3% |

Total | 100% |

Table 3. Typical Composition of a 2015 ELV, by weigh. Source: GHK/BIOIS and information from stakeholder consultation.

2.1 Composition of the Plastics Fraction of an ELV

Understanding of the composition of the plastics fraction is important for an assessment of treatment options and assessment of impacts. Many different polymers are used in vehicles, with the 2001 composition of a vehicle described below.

Many parts are composites of different polymers, whilst within a class of polymer (like polypropylene (PP)) parts may have different physical properties. Vehicle design is increasingly moving towards use of fewer polymers in vehicles, less use of PVC, greater use of PP and greater use of composite parts.

[pic]

Diagram 1. Average content of plastics in a vehicle (2001). Source: ACORD, CEP.

2.2 Location of Plastic Parts in ELVs

[pic]

Table 4. Location of plastic parts in end-of-life vehicles. Source: PlasticsEurope, 2005.

3. ANALYSIS OF POTENTIAL ELV TREATMENT ROUTES

The disposal route for ELVs is influenced by several factors such as material prices, legislative requirements and available treatment technologies. Before treatment, some valuable parts are dismantled and reused. Afterwards, the metal fraction of a car wreck is recycled, while the remaining residues undergo recovery, incineration, or are disposed in landfills. Typical treatment process of an ELV comprises several stages.

Initial processes of depollution and dismantling are obligatory and subject to the requirements outlined in Annex I to the Directive. In fact, not all ELVs are dismantled prior to being shredded[70], and not all the parts are removed. Depollution may take place either at the dismantling phase or prior to shredding.

Depollution of an ELV, which accounts for 3% of vehicle materials by weight, is the first step in its treatment and involves the removal of batteries and liquefied tanks, removal and neutralisation of potentially explosive components (e.g. air bags), removal and separate collection or storage of liquids (fuel, oils, cooling liquids, antifreeze, brake fluids, air-conditioning system fluids etc., unless such fluids are necessary for the re-use of the concerned parts), removal of vehicle components which contain heavy metals. Batteries are either reused or reprocessed, depending on their condition. Fluids are generally reprocessed or sold for use as fuels. This initial process is heavily labour intensive[71].

This process is followed by dismantling – an operation aimed to promote recycling - which accounts for the removal of valuable parts and materials that can be reused or easily recycled (e.g. catalysts, glass, metal components containing copper, aluminium and magnesium, tyres, large plastic parts such as bumpers, dashboards, fluid containers). Metal components, tyres and plastic parts need to be removed only if they are not segregated in the shredding process in such a way that they can be effectively recycled as materials. The most commonly reused parts include wheels, engines, gearboxes, carburettors, alternators, starter motors, distributors, headlamps, brake discs and callipers, tyres, radiators, and batteries. If not reused, larger metals parts are usually sent for metal recovery to specialist reprocessors. The percentage by weight of parts removed depends on the age and condition of a vehicle as well as on the method of operation of a d