Table of Contents Glossary 1. Introduction 1.1. Purpose 1.2. Scope 1.3. The ELV sector and the COVID-19 pandemic 2. BACKGROUND TO THE INITIATIVE 2.1. Description of the initiative 2.1.1. Historic background and response to the ELV problematics 2.1.2. General purpose and objectives of the ELV Directive 2.1.3. Main provisions of the ELV Directive 2.2. Intervention Logic 2.3. Interactions with other EU policies and legislations 2.4. Baseline 3. Implementation and state of play 3.1. Implementation of ELV Directive 3.2. Key facts and figures relating to the ELV sector in the EU 4. Method

4.1. Evaluation questions 4.2. Process 4.3. Limitations – robustness of findings 5. Analysis and answers to the evaluation questions 5.1. Effectiveness 5.1.1. Have the objectives and targets of the ELV Directive been met and monitored? 5.1.2. A significant problem affecting the effectiveness of the ELV Directive: the “missing ELV” 5.2. Efficiency 5.2.1. Benefits and costs 5.2.2.Administrative burden and simplification opportunities 5.3.Relevance 5.3.1.Scope of the ELV Directive 5.3.2.Increased use of electric, electronic and other components in vehicles 5.3.3.Increased use of lightweight materials in vehicles like plastics, carbon-fibres, fibre-reinforced (plastics) materials and others 5.3.4.Changes in the types of vehicles put on the EU market: increase of electric or hybrid vehicles and of SUV 5.4.Coherence 5.4.1. To what extent is the ELV Directive internally coherent? 5.4.2. To what extent is the ELV Directive coherent with other EU policy instruments and the overall EU and international policy goals? 5.4.2.1.Coherence with the EU approach to Circular Economy 5.4.2.2.Coherence with the EU Climate change policy

5.4.2.3.Waste Framework Directive 5.4.2.4.Basel Convention and the Waste Shipment Regulation 5.4.2.5.Stockholm Conventionon Persistent Organic Pollutants (POPs) and the EU POPs Regulation 5.4.2.6.Directive on Waste Electrical and Electronic Equipment (WEEE) and RoHS Directive 5.4.2.7.Batteries Directive 5.4.2.8.Directive on Vehicle Registration Documents 5.4.2.9.Directive 2005/64/EC on the type-approval of motor vehicles regarding their reusability, recyclability and recoverability 5.4.2.10.European List of Waste 5.5.EU Added Value 6.5. Conclusions 6.1.Effectiveness 6.2.Efficiency 6.3.Relevance69 6.4.Coherence70 6.5.EU added value72 6.6.Lessons learnt72 Annex 1: Procedural information73 Annex 2. Synopsis report of the stakeholder consultation76 Annex 3. Methods used in preparing the evaluation94 Annex 4. Technical information102

Annex 5. Analysis on the costs and benefits105 Glossary Term or acronym Meaning or definition ACEA European Association of Automobile Manufacturers ASR Automotive Shredder Residues ATF Authorised Treatment Facilities BAT Best available techniques BEV Battery Electric Vehicle Batteries Directive Batteries Directive 2006/66/EC on batteries and accumulators and waste batteries and accumulators CLP Classification, Labelling and Packaging (CLP) Regulation ((EC) No 1272/2008) CMI Car Manufacturing Industry CoD Certificate of Destruction EC European Commission ECHA The European Chemicals Agency EEA European Economic Area EEA European Environment Agency EEE Electrical and electronic equipment ELV End-of-life vehicle ELV Directive Directive 2000/53/EC of the European Parliament and of the Council of 18 September 2000 on end-of life vehicles - Commission Statement (OJ L 269, 21.10.2000, p. 34–43). Directive as last amended by Directive (EU) 2018/849 of the European Parliament and of the Council of 30 May 2018 (OJ L 150, 14.6.2018, p. 141). EoL End-of-life EPR Extended Producer Responsibility ELoW European List of Waste EV Electric Vehicle EU European Union EuRIC European Recycling Industries’ Confederation FTB Free take-back GHG Green House Gas ICE Internal Combustion Engine IMDS International Material Data System ISG Inter-service Steering Group HDV Heavy Duty Vehicle (e.g. Trucks) Li-ion batteries Lithium-ion batteries LSR Light Shredder Residues MS Member States as addressed by the WFD and the ELV Directive (‘Text with EEA relevance’): 27 Member States of the European Union plus 3 States of the European Economic Area (Norway, Iceland, Liechtenstein) OEM Original Equipment Manufacturer PHEV Plug-in Hybrid Electric Vehicle PPWD Packaging and Packaging Waste Directive PST Post-Shredder Technologies SVHC Substance of Very High Concern REACH Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency, amending Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC RoHS Restriction of Hazardous Substances Directive 2011/65/EC, Directive on the restriction of the use of certain hazardous substances in electrical and electronic equipment SME Small Medium Enterprise SUV Sport Utility Vehicle TAC Technical Advisory Committee ToR Terms of Reference VAs Voluntary Agreements WEEE Directive Directive 2012/19/EU on waste electrical and electronic equipment (WEEE) WFD Waste Framework Directive, Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on waste and repealing certain Directives (OJ L 312, 22.11.2008, p. 3) as last amended by Directive (EU) 2018/852 of the European Parliament and of the Council of 30 May 2018 (OJ L 150, 14.6.2018, p. 141). WSR / WShipR Waste Shipment Regulation, Regulation (EC) No 1013/2006 of the European Parliament and of the Council of 14 June 2006 on shipments of waste WStatR Waste Statistics Regulation, Regulation (EC) No 2150/2002 on EU waste statistics 1.Introduction 1.1.Purpose The purpose of this document is to present an evaluation of the effectiveness, efficiency, coherence relevance and EU added value of Directive 2000/53/EC of the European Parliament and of the Council of 18 September 2000 on end-of life vehicles (hereinafter - ELV Directive). Since its adoption in 2000, the ELV Directive has not undergone any substantial revision. With the adoption of the Waste Package in 2018, a review clause (Article 10a) was introduced into the Directive establishing a legal obligation for the Commission, as follows: ‘By 31 December 2020, the Commission shall review this Directive, and to that end, shall submit a report to the European Parliament and to the Council, accompanied, if appropriate, by a legislative proposal.’ The production of vehicles has undergone significant changes since the adoption of the Directive 20 years ago. These transformations have been influenced by the increasing use of new technologies and components in cars, such as plastics, carbon fibre or electronics, causing specific challenges for their recovery and recycling from ELVs. The growing number of electric vehicles on the EU market is expected to bring additional new challenges to the ELV sector, as the modern electric vehicles contain parts and components (e.g. batteries), requiring specific treatment at the end of their life, and other (some electric motors, containing rare materials) which are currently hard to recycle, and parts (batteries, strong magnets) which pose significant handling safety issues. The recovery measures adopted to mitigate the economic consequences of the COVID-19 pandemic, and in particular financial incentives to purchase electric/hybrid cars, will accelerate the shift to electric cars in the EU. They might also potentially lead to an increased volume of relatively recent vehicles sent for scrapping. This evaluation assesses to which extent the EU legislation on end-of-life vehicles is fit for purposes to deal and measure with these new developments. The document also evaluates the ELV Directive in light of (i) the political priorities and actions set out in the European Green Deal and the Circular Economy Action Plan, which define an ambitious agenda to transform the European economy, based on a modern, competitive, low carbon and circular industry, and (ii) the EU framework legislation on waste management, as amended in 2018. The European Green Deal and the Circular Economy Action Plan emphasise that the EU policy on waste should place the reduction of waste generation at its core, notably through changes in the design of products, promote high quality recycling and facilitate the uptake of recycled materials in new products. The Chemicals Strategy for Sustainability also strives for a safe and sustainable-by-design approach and for non-toxic material cycles: “it is necessary to ensure that substances of concern in products and recycled materials are minimised. As a principle, the same limit value for hazardous substances should apply for virgin and recycled material.” Where waste cannot be avoided, its economic value must be recovered and its impact on the environment and on climate change should be avoided or minimised. In this regard, the European Green Deal identifies vehicles as one of the products where “the Commission will consider legal requirements to boost the market of secondary raw materials with mandatory recycled content”. Additionally, vehicles are among seven sectors selected as the key product value chains in the new Circular Economy Action Plan, which directly refers to the new legislative initiative by stating “the Commission will also propose to revise the rules on end-of-life vehicles with a view to promoting more circular business models by linking design issues to end-of-life treatment, considering rules on mandatory recycled content for certain materials of components, and improving recycling efficiency”. The evaluation report is based on the evaluation criteria set out in the Better Regulation Guidelines, as presented in the Commission’s evaluation roadmap, namely: üEffectiveness: looking into the extent to which the actions defined under the Directive have been implemented and whether this has resulted in achieving the ELV objectives; üEfficiency: assessing whether the obligations arising from the implementation of the ELV Directive have been implemented in a cost-effective way and if there is a potential for further synergies to strengthen delivery while minimising costs and administrative burden, including impact on SMEs; üRelevance: assessing whether the issues addressed by the ELV Directive still match current needs (e.g. developments in terms of e-mobility or new hazardous substances) and contribute to solutions to issues addressed by wider EU policies on circular economy, climate change, plastics, resource efficiency, raw materials, etc.; üCoherence: assessing coherence of the ELV Directive with the EU wide policy objectives on circular economy, as well as possible inconsistencies and overlaps of the ELV Directive with the waste legislation, in particular the Waste Framework Directive and the Batteries Directive, and EU legislation on car registration and on car type-approval; üEU added value: of the Directive compared to what Member States could have reached acting alone at national, regional and international level. These criteria are operationalised via questions specific to this evaluation (see Section 5 and Annex 3).

1.2.Scope This evaluation covers the whole Directive 2000/53/EC on end-of-life vehicles, from its adoption in 2000 until present, including the amendments and the implementation in all EU-28 Member States. As a consequence, this report analyses both the issues deriving from the nature of the legislation itself as well as those deriving from its transposition and implementation in Member States, including monitoring and enforcement. 1.3.The ELV sector and the COVID-19 pandemic The evaluation of the ELV Directive also needs to factor in, as much as possible, the impact of the COVID-19 pandemic on the various economic sectors affected by the Directive. The structural implications of the COVID-19 pandemic for the ELV Directive are difficult to foresee, in view of the numerous uncertainties linked to the pandemic itself and to its long term consequences for the interested sectors. It will require later estimations as the second wave of the pandemic started in Europe in October 2020, when this evaluation was being finalised. This section therefore attempts to describe the short term, immediate impact that the pandemic had on the automotive chain, as well as indications as to what could be its more medium term implications, based on the views of the sectors concerned and relevant experts. All the automotive chain, from manufacturers to suppliers to aftersales market and recyclers, has been hard-hit by the first wave of the COVID-19 pandemic. In June 2020, the European Automobile Manufacturers’ Association (ACEA) indicated that car registrations were expected to drop by 25% in 2020, meaning that car sales would decrease by more than 3 million from 12.8 million units in 2019 to some 9.6 million units this year. This would represent the lowest number of new cars sold since 2013 and is mainly due to factory shutdowns during the lockdowns put in place in different EU Member States, as well as the disruption of supply chains. The aftermarket automotive sector (vehicle parts production, their distribution, diagnostics and repair & maintenance) was also largely impacted in the EU by the pandemic: the confinement measures and the temporary closing of business-consumer interfaces has resulted in a drop in demand, with a clear effect on the access to liquidities for the overwhelming majority of SMEs and family businesses of the sector. Many ELV recycling facilities have been subject to temporary closures, while aluminium and steel prices decreased, supply chains and production lines were disrupted and the trade in goods and services interrupted. This has resulted in serious operational and financial difficulties for many businesses active in the sector, many of them small and medium-size enterprises (SMEs) that have been facing serious liquidity issues. The impact on the ELV sector was a reduction in the number of ELVs, reduction of auto parts sales, lack of storage as many facilities were closed or could not proceed with treatment and lack of available shipping logistics to ship Automotive Shredder Residue (ASR) to available installations. Recent studies show that auto parts sales will slow significantly and will fall by 15% in 2020 and remain 4% to 8% lower than forecasts through 2025. Experts in the sector predict that a more complete and accurate estimate of the impact of crisis on dismantlers and shredders will only be possible in 2021. The dismantling sector also pointed to the surge of ELV treatment by illegal operators as sales of the spare parts for reuse via Internet platforms were on the rise and the sellers are not always certified dismantlers and recyclers. In response to the economic crisis caused by COVID-19, the EU adopted the NextGenerationEU recovery instrument. Under this instrument, grants, notably from the new Recovery and Resilience Facility, ERDF and Cohesion Fund, should be prioritised for projects with the highest social, environment, economic and EU added-value, offering an opportunity to accelerate the green transition. Furthermore, to mitigate the economic impact of the COVID-19 pandemic, most Member States have put in place considerable incentives (e.g. grants, tax reduction, free parking) for acquiring cars with low tailpipe greenhouse gas emissions (EVs and hybrids), or e-scooters and e-bikes. In the short term, these incentives to purchase new cars might result in the replacement of old cars with newly purchased cars, leading to a higher number of used vehicles becoming end-of-life vehicles, and additional activities for the ELV dismantling sector. This would be the case especially if the incentive schemes also comprise premiums for the scrapping of used cars, which however does not seem to be the case in most EU Member States. Past experiences have shown that such scrapping premiums can actually destabilise the car dismantling sector if it leads to a sudden afflux of ELVs to their facilities, bringing with it a decrease in prices and additional storage costs. In the medium term, it is expected a further acceleration towards the electrification and higher automation of the automotive sector. This will have important consequences for the vehicle dismantling and recycling sectors, as much fewer parts are needed in electric vehicles (no gearbox, no exhaust system, much fewer moving parts in the engine, etc.), and increased digitalization will increase the share of on-board electronics. On the other hand, batteries and motors of EVs contain many valuable materials (cobalt, lithium copper, rare earths, etc.) for which recycling will represent both technical challenges and an economic interest, and shall have strong impact on innovation within the sector, but also pose safety issues which require training of the personnel coming in contact with such material. This issue is further discussed in this evaluation report. At the same time, the automotive aftermarket stakeholders pointed out that the demand for new cars might go down if the economic crisis persists, and with it a reduced purchasing power for consumers. This could mean that households keep their cars longer, with more activities on the repairing side to keep them in good conditions, as well as increased demand for second-hand vehicles, which are cheaper. 2.BACKGROUND TO THE INITIATIVE 2.1.Description of the initiative 2.1.1.Historic background and response to the ELV problematics The EU policy on waste management, and its associated legislation, dates back from 1975 with Directive 75/442 on waste and Directive 75/439 on waste oil. Discussions on waste from ELVs date back to the 1970s. They were focusing particularly on the concerns caused by the illegal disposal of hazardous waste and the difficulties to treat plastic waste derived from ELVs. Increasing quantities of plastic waste were found in the Light Shredder Residues (LSR) and, due to their limited compacting characteristics, used a large amount of volume within landfills. Their incineration was also challenging as it required pre-treatment operations. The treatment of exhaust gas of waste incinerators was less developed at that time. In addition, other environmental and health risks, such as contamination of the metal scrap with heavy metals, raised public concerns. A number of reports and studies exposed the environmental, economic and social challenges linked to the growing number of ELVs in Europe. The number of ELVs generated in the EU-15 Member States was estimated to amount to between 7.6 and 10.3 million units per year, representing between 8 and 9 million tonnes of waste. As a response, under the Article 175(1) of TEC (current Article 192 of TFEU), the Directive 2000/53/EC on end-of-life vehicles (ELV Directive) was adopted in 2000 in order to minimise the impact of end-of-life vehicles (ELVs) on the environment and to improve the environmental performance of all the economic operators involved in the life-cycle of vehicles.

2.1.2.General purpose and objectives of the ELV Directive The first EU-wide legal framework on the ELV sets three key objectives with the aim of: • preventing waste from vehicles; • promoting reuse, recycling and other forms of recovery of ELVs and their components so as to reduce the disposal of waste; • improving the environmental performance of all economic operators involved in the life cycle of vehicles, especially those involved in the treatment of end-of life vehicles. While harmonising environmental requirements, the Directive also seeks to ensure the smooth operation of the internal market and to avoid distortions of competition in the EU through an EU-wide framework in order to ensure coherence between national approaches. In order to pursue these objectives, the Directive contains measures regarding: • the prevention of waste, especially measures to limit the presence of hazardous substances (lead, mercury, cadmium and hexavalent chromium) in vehicles and encouragement for Member States to take account and facilitate the recycling and reuse of vehicles and their parts, in the design and production stage of new vehicles; • the collection of ELVs, notably through the obligations for Member States to ensure that authorised treatment facilities (ATFs) are available within their territory, that ELVs are transferred to such ATFs, and that the delivery of an ELV to ATFs occurs without any costs for the last holder. ATFs must be registered, comply with minimum technical requirements and permitted by Member States’ competent authorities; • the environmentally sound treatment of ELVs; • the targets (by weight) for the re-use and recycling (85%) of ELVs as well as re-use and recovery (95%) of components from ELVs; • the provision of information by producers on components and materials used in vehicles, to facilitate their identification for reuse and recovery. Specific requirements apply to remove certain vehicle components and liquids that are high pollution risks and/or contain materials of high value. 2.1.3.Main provisions of the ELV Directive Figure 2 ‑1 provides an overview of the provisions of the ELV Directive. 2.2.Intervention Logic The intervention logic below shows the intended functioning, desired results and overall rationale of the Directive.

It identifies: ·The needs to be addressed; ·The objectives to put in place aiming to address the needs; ·The inputs to implement the Directive; ·The actions and measures undertaken to meet the objectives; ·The consequences (expected outputs and results) evolving from the actions; and ·The expected impacts, which should fully resolve the needs. ·The external influences – other factors that influence the expected outputs, results and impacts outside the scope of the ELV Directive. 2.3.Interactions with other EU policies and legislations The ELV Directive needs to be considered in the broad context set out by the EU policies on climate change, circular economy, combating pollution and industrial strategies, as reflected especially in the European Green Deal, the Circular Economy Action Plan, Chemicals Strategy for Sustainability and the New Industrial Strategy for Europe. The Directive touches upon issues which are relevant as well for the EU legislation relating to the design and registration of vehicles. It also interacts with many pieces of EU legislation on waste, especially the Waste Framework Directive, and also the Batteries Directive, the WEEE Directive and the Waste Shipment Regulation. The interaction and coherence with these EU policies and legislation are assessed in detail in Section 5 of this document. 2.4.Baseline The baseline and starting point of the evaluation is defined by the date of entry into force of the Directive (2000). At the time the ELV Directive was drafted, there was no requirement to proceed with a formal impact assessment including a baseline/counter factual of no intervention. Therefore, the lack of data limits possibility to present a comprehensive overview of the original baseline. The evaluation takes into account the situation prior to the adoption of Directive, where national frameworks of ELV Directive type legislation had been established only in some Member States. The earliest information on the legislative situation before the ELV Directive entered into force in the EU is described in the JRC-IPTS report, providing the general overview of the ELV Directive related issues. The report contains the following summary: “At end of 1999, 10 EU member countries (AT, BE, FR, DE, IT, NL, PT, ES, SE and the UK) had specific regulations and/or industrial voluntary agreements (VAs) for ELV. Another three countries were discussing industrial agreements (FI and IE) or introducing legislation (DK). Six countries (AT, BE, DE, IT, NL and SE) combine VAs with legislation directly addressing ELV. AT, FR, IT and NL introduced VAs or countrywide initiatives before the drafting of the EU Directive proposal. The VAs and legislation in other countries (BE, DE, PT, ES and SE) were developed in 1997–99 during the debate on the EU Directive proposal. A process of integration between industrial agreements and legislation occurred in DE and SE after a long confrontation between industry and environmental policy-makers. In other large countries (FR, IT and the UK), ELV policy is mainly based only on VAs promoted by the car industry and involving a number of other industries. One major feature of these VAs is the absence of specific economic instruments of the free take-back (FTB) type and the prominence of free-market relationships. The agreement implemented in NL represents a specific approach for both its organisational framework and its economic incentives. A recycling fee is levied on new car prices and redistributed to dismantlers and recyclers to pay incremental recycling costs. Specific mechanical recycling targets are established. Most national voluntary agreements and/or legislation established a recovery target rate of 85 % of car weight by 2002 and a total recovery target rate of 95 % by 2015. Most countries specify the targets only in terms of recovery rates (not recycling rates, as in the EU Directive) thus allowing unconstrained energy recovery of ASR.” 3.Implementation and state of play 3.1.Implementation of ELV Directive A number of reports and studies have been published since 2000 on the implementation of the ELV Directive. This includes in particular Commission implementation reports based on information provided by Member States pursuant to Commission Decision 2001/753/EC concerning a questionnaire for Member States reports on the implementation of Directive 2000/53/EC of the European Parliament and of the Council on end-of-life vehicles and the Compliance Promotion Initiative to assess the implementation of Directive 2000/53/EC on end-of life vehicles (the ELV Directive) with emphasis on the end-of life vehicles of unknown whereabouts. They can be found on the Commission’s website. A number of specific reports and studies were also carried out on legal, economic and practical aspects linked to the ELV Directive, in particular the following:

·End of life vehicles: Legal aspects, national practices and recommendations for future successful approach (study for the European Parliament's Committee on Environment, Public Health and Food Safety, 2010); ·Requirements for the management of waste containing persistent organic pollutants – Rules concerning waste in the POP Regulation and their application to Waste Electrical and Electronic Equipment and end-of-life vehicles (2016) ·Development of proposals, including legal instruments, to improve the data situation on the whereabouts of end-of-life vehicles (2017); ·Report the End-of-Life Vehicle sector by ADEME (2017); ·Enhancing the Separation of Components and Materials from End-of-Life Vehicles Aiming at the Recovery of Critical Metals by ORKAM (2017); ·Effectively tackling the issue of millions of vehicles with unknown whereabouts - European priority measure: establishing leakage-proof vehicle registration systems by UBA (2020); ·Used vehicles and the environment. UNEP report (2020); ·Used vehicles exported to Africa – a study on the quality of used export vehicles. Human Environment and Transport Inspectorate the Dutch Ministry of Infrastructure and Water Management (2020). The implementation of the ELV Directive required that multiple changes be made to its Annex II, relating to hazardous substances. Under the ELV Directive, vehicle and equipment manufacturers are required to limit the use of lead, mercury, cadmium and hexavalent chromium for materials and components put on the market after 1 July 2003, subject to the exemptions listed in Annex II to the Directive. Until 2019, where their use is unavoidable. Annex II has been amended 10 times in order to reduce these exemptions while taking into account the technical and scientific progress. More information on these changes is provided in the webpage of the European Commission. 3.2.Key facts and figures relating to the ELV sector in the EU ·In 2016, 258 million passenger cars were registered in the EU, and these all fall within the scope of the ELV Directive. Around 90% of the 34 million trucks registered weigh less than 3.5 tonnes and are also within the scope of the ELV Directive. Trucks weighing more than 3.5 tonnes are not covered by the ELV Directive. The remaining 45 million vehicles, including motorcycles, trailers and semi-trailers, road tractors, special purpose vehicles, motor coaches, buses and trolley buses, are not within the scope of the ELV Directive. ·The average age of an ELV in the EU is between 15 and 22 years. ·In 2018, approximately 15 million new passenger cars were registered in the EU27. ·In 2017, 11.21 million light commercial vehicles below 3.5 tonnes total mass (category M1) and passenger cars (category N1) left the stock of registered vehicles. Of these, 6.57 million were reported as ELVs and 0.87 million were reported as exports of used cars to non-EU countries. Therefore, the whereabouts of 3.77 million vehicles which left the stock of registered vehicles are unknown (see further development on this in section 5.1.2). ·The ELV Directive establishes minimum technical requirements for the treatments used in ATFs and shredders. Europe has approximately 14 000 ATFs and 350 automotive shredding facilities. ·The average weight of an ELV in 2017 was 1088 kg. This means that the 11.21 million vehicles leaving the stock in 2017 represent 12.2 million tonnes of waste. ·Based on the average material composition of ELVs, 12.2 million tonnes of represent a material flow of 70% (8.5 million tonnes) of ferrous metals, 4% (490 000 tonnes) of non-ferrous metals (excluding wiring harnesses), 3% (365 000 tonnes (glass)) and 14.8% (1.48 million tonnes) of mixed plastics. These figures exclude tyres, battery casings and the plastic sheathing of wiring harnesses. 4.Method 4.1.Evaluation questions In line with the Commission's better regulation policy, this report assesses the Directive according to five evaluation criteria: effectiveness, efficiency, relevance, coherence and EU added value. To this end, this report answers the following evaluation questions:

Effectiveness: ·To what extent have the objectives of the ELV Directive been achieved? ·To what extent have the results been effectively monitored? ·Which factors contributed to or hampered the observed achievements of the ELV Directive? ·Did the ELV Directive lead to other significant changes or results? ·What and to which extent did Member States implement measures to address the problems of “missing ELV” (e.g. cooperation mechanisms between MSs)? Efficiency: ·To what extent are the costs proportionate to the benefits which have been achieved as a result of the ELV Directive? · How are the overall costs and benefits linked to the implementation of the ELV Directive distributed across the relevant economic actors? ·What factors influenced the efficiency? Relevance: ·To what extent is the ELV Directive appropriately covering the new challenges, changing environment and developments affecting the automotive and ELV sectors? ·How well do the objectives and provisions of the ELV Directive correspond to the current EU policy objectives? Coherence: ·To what extent is the ELV Directive coherent with other EU policies and legislation? EU added value: ·What is the added-value resulting from the ELV Directive? 4.2.Process The Commission first published a roadmap for the evaluation of the ELV Directive in 2018. The Commission also worked with a consortium of consultants which produced in August 2020 a study designed to support this evaluation. The main steps undertaken and sources of information used for this evaluation are the following:

·A review of existing literature and data (the legal acts and documents related to the implementation of the Directive; exemption evaluation reports related to the hazardous substance prohibitions; end-of-life vehicle statistics from Eurostat; relevant studies; data from the reports by Member States); ·An open public consultation was conducted by the Commission for 12 weeks, 6 August 2019 – 29 October 2019. In total, 141 stakeholders responded to the consultation, approximately half of them have been received from the business community; ·Targeted consultation activities were also performed, consisting of a survey and interviews which key stakeholders for the ELV Directive. A total of 72 stakeholders responded to the targeted questionnaire coming from a range of stakeholder groups, including Member State Competent Authorities, Trade Associations, Non-Government Organisations and other stakeholders; ·On 5 February 2020, a Stakeholder workshop was organised to verify and to support the findings of the evaluation. It involved 71 representatives of Member States authorities, economic operators and their representatives at EU and national level, NGOs and academics. More information on the methodology and process followed for this evaluation (including on the consultation of stakeholders) can be found in the Annexes to the present document and on the European Commission’s webpage specially dedicated for the evaluation of the ELV Directive: https://ec.europa.eu/environment/waste/elv/review_en.htm . 4.3.Limitations – robustness of findings Stakeholder consultation The evaluation aimed to involve all affected stakeholders via the most appropriate methods. A variety of tools were used to collect the evidence required for the evaluation, including the targeted survey and interviews, the Open Public Consultation (OPC) and the stakeholder workshop. Several limitations were identified in the capacity to obtain the relevant information: ·Input from targeted interviews was relatively limited. Despite multiple contacts, a number of stakeholders declined invitations for various reasons, e.g., preference to provide responses in written through the survey, no availability. As such, the number of individual responses was less than initially planned. However, in view of the participation of most of those contacted to the targeted survey and the stakeholder workshop, the impact to the validity of the conclusions is considered to be limited; ·Despite the surveys and the interviews, no input was received from certain stakeholder groups, including insurers (except for one company), consumer representatives and vehicle registration experts. This information gap was partially mitigated by applying a tailored desk research with the aim reflect the viewpoints of these groups in the overall assessment; ·There was a “Consultation fatigue” by the stakeholders in the consultation process. For the time efficiency purposes, the tailored approach was applied to manage the stakeholder communication, in particular, through the targeted surveys ensuring the questions addressed are appropriate and clearly stated. Costs and other data collection The collection of data on costs associated with the ELV was rather challenging. Stakeholders were asked to provide information on the costs resulting from the implementation of the Directive, such as administrative, technical compliance, monitoring, collecting and reporting data and estimates, labour costs, including their distribution among the sectors/operators. Contribution from stakeholders was relatively limited. There were conflicting views and data available regarding the costs associated with ELVs. In some cases, respondents were unable to identify the costs associated with the Directive from other costs. This posed limitations to the capacity to provide a comprehensive estimation of the costs. Where available, data from relevant studies/reports was used to fill relevant gaps and verify the input from stakeholders. Where necessary, the combination of expert and qualitative judgments was applied. Due to the strong interrelation of the ELV Directive with other EU legislation (such as the Batteries Directive and Chemical legislation), evaluation and focus exclusively on the ELVs regulatory aspects required critical analysis. It was particularly important in identifying the costs solely imposed by the Directive. As there was no impact assessment required for the primary proposal of the Directive before 2000, it was impossible to retrieve the original estimate of costs. Validity of analysis and conclusions The input provided by stakeholders during the consultation process on some important data remained limited. In order to address possible information and data gaps, after the completion of the open public consultation, a stakeholder workshop was organised to present the initial findings and test them against a broad range of stakeholders. As a result, and on the basis of the additional input received, the evaluation was accordingly refined and, where necessary, revised. It ensured validity and confidence of the findings and conclusions of the report. 5.Analysis and answers to the evaluation questions This section provides an evaluation of the ELV Directive according to the five evaluation criteria (effectiveness, efficiency, relevance, coherence and added-value of the Directive). The evaluation work was initiated based on a series of questions – the questions and corresponding answers are compiled in this section, so as to provide an analysis of the most relevant aspects linked to the ELV Directive. More information on the initial questions and their rationale can be found in the evaluation matrix presented in Annex 3. 5.1.Effectiveness The overall effectiveness of the ELV Directive is analysed in the following sections, through examining the progress towards achievement the objectives and targets, factors hindering such progress and issues relating to reporting. It contains an important focus on the issue of “missing ELV”, which represents the major problem affecting the effectiveness of the ELV Directive.

5.1.1.Have the objectives and targets of the ELV Directive been met and monitored? This section provides an overview of the implementation of the objectives established by the ELV Directive. It encompasses the implementation of the provisions relating to waste prevention, to the collection and treatment of ELV, to the reuse, recovery and recycling targets, as well as the provisions on reporting. 5.1.1.1.Waste prevention: elimination of hazardous substances Article 4(1)(a) of the Directive stipulates that, in order to promote the prevention of waste Member States shall encourage vehicle manufacturers and their supply chain “to limit the use of hazardous substances in vehicles and to reduce them as far as possible from the conception of the vehicle onwards, so as in particular to prevent their release into the environment, make recycling easier, and avoid the need to dispose of hazardous waste”. To this end, Article 4(2)(a) prohibits the use of lead, mercury, cadmium or hexavalent chromium in materials and components of vehicles put on the market after 1 July 2003, other than in cases listed in Annex II. This annex specifies a number of materials and components in which the use of these substances is tolerated, if the use of these substances is unavoidable. The Commission amends this annex on a regular basis adapting it to technical and scientific progress. The items listed in this annex are referred to as “exemptions” throughout this document. When the ELV Directive was adopted in 2000, Annex II specified 13 exemptions: 5 exemptions for the use of lead (Pb) in various alloys; six exemptions for the use of Pb in various components, an exemption for hexavalent chromium (Cr VI) in coatings and one for mercury (Hg) in bulbs and displays. The annex also required the Commission to review two of the specified exemptions as well as a number of additional ones according to the procedure specified in Art. 4(2) (via a Commission delegated act). To date, the annex has been reviewed ten times and all exemptions for cadmium and mercury have expired as well as all but one exemption for hexavalent chromium and most of the exemptions for lead. The exemption for lead-acid batteries in terms of the volume of hazardous substance applied is the most significant remaining one, and is currently being reviewed. The most frequent issues raised by stakeholders do not question the overall logic and effectiveness of the ELV Directive in addressing hazardous substances, but relate to the frequency of the review of the exemptions, as well as to the justification for keeping or removing these exemptions. There is no reference in the Directive on the frequency of the review of the exemptions. Since 2002, Annex II has been reviewed every 2-3 years. In relation to the frequency of the amendments of Annex II, most stakeholders did not have an opinion (40%) as to whether amendments were frequent enough, another large group, mostly representing national or regional administrations, responded they were sufficient (35%) and a number of stakeholders, notably from companies or business associations, considered the reviews were too frequent (24%). It was noted that in cases where substitute candidates are not yet known, more time could be given between exemption evaluations to allow sufficient time for the design of vehicles to progress and to be adapted to scientific and technical progress. It would address long design cycles of vehicles that include re-design, a number of testing phases (on component, vehicle and field level), type-approval and ramp-up of production scale. The RoHS Directive allows exemptions of a maximum duration of up to 7 years for categories with longer design cycles, e.g. medical devices, monitoring and control devices. A longer maximum duration of exemptions might also be explored for the ELV Directive. The maximum duration should only be applied where candidate substitutes are not identified, assuming that the time for development of substitutes, their testing and the ramp-up of full scale manufacture will need a longer period to ensure implementation. Where substitutes are identified and in development, the exemption duration should be considered in relation to the stage of development and the plan for development and implementation of substitutes. Indications that substitutes are expected to reach maturity within less than the maximum duration would justify a shorter exemption, with the aim of the evaluation allowing the specification of an end-date for the exemption. Recital 11 of the Directive states that “in particular the use of lead, mercury, cadmium and hexavalent chromium should be prohibited”, explaining that these “heavy metals should only be used in certain applications according to a list which will be regularly reviewed”. The main criterion for deciding on the continuation of an exemption is whether the use of the substances concerned is unavoidable. Stakeholders have noticed that the justification criteria are not harmonised with those used notably in the RoHS Directive. It was also pointed out that the situation in which a substitute may also have negative environmental impacts is not specifically addressed under the ELV Directive and could lead to undesirable substitutions. Some stakeholders pleaded for the introduction of socio-economic aspects, as in the RoHS Directive, which may also be relevant with the aim to weigh impacts on the environment and on health against economic impacts. The European Chemicals Agency currently does not play any role in the assessment of the exemptions relating to hazardous substances laid down in the ELV Directive. It should be noted that, in its recent proposal for a Regulation on batteries, the Commission has proposed that the European Chemicals Agency is tasked to perform a similar assessment for batteries. Overall, it can be concluded that the ELV Directive has been largely effective in achieving its aim to limit the presence of hazardous substances in vehicles. The main problematic issues relate to the inconsistency of the ELV Directive with other EU legislation on the criteria used to justify/remove exemptions and the duration of these exemptions. However, this does not invalidate the conclusion that these provisions have generally been effective. 5.1.1.2.Waste prevention: design and production of new vehicles and integration of recycled materials in vehicles Article 4 of the ELV Directive contains provisions regarding the design and production of new vehicles. It notably requests Member States to “encourage” the facilitation of dismantling, reuse and recovery, in particular the recycling, of end-of life vehicles, their components and materials, at the design and production stage. Member States shall also “encourage” the automotive sector to “integrate an increasing quantity of recycled material in vehicles and other products, in order to develop the markets for recycled materials”. These provisions are very general and not sufficiently specific and measurable. No information is available which shows that Member States have taken measures in these fields, in order to implement that provisions of the ELV Directive, which “encouraged” them to do so. These provisions have therefore had little to no impact on the design and manufacturing of new vehicles. It is doubtful that vehicles currently put on the market are easier to dismantle and recycle than in 2000, notably in view of the changes in the composition of cars which includes a growing volume of plastics and electronics. Some interesting initiatives have been adopted by some car manufacturers, notably to promote the re-use of spare parts, the re-manufacturing of components or recycling of materials, as well as the use of recycled materials. These initiatives were taken on a voluntary basis and cannot be traced back to the implementation of the ELV Directive. It can therefore be concluded, that in view of their general nature, the provisions of the ELV Directive on the design and production of new vehicles and on the integration of recycled materials have not brought about real improvements at the EU level on these issues. These issues are further discussed in the parts of the present report assessing the relevance of the ELV Directive and its coherence with the Circular Economy Action Plan and the Directive 2005/64/EC on the type-approval of motor vehicles regarding their reusability, recyclability and recoverability. 5.1.1.3.Collection and treatment of ELV in Authorised Treatment Facilities (ATFs) and shredders Article 5 of the ELV Directive requires that “systems for the collection of all end-of life vehicles” are set up in all Member States, which should have “adequate availability” within their territory. The number of Authorised Treatment Facilities (ATFs) is therefore an important indicator to assess how the ELV Directive has been implemented on this point. The concept of “authorised treatment facility” did not exist in EU law before the adoption of the ELV Directive. The first reporting on the number of ATF dates back from the period 2011-2014, for which the Member States informed the Commission of the existence of approximately 13 000 ATFs, each of which treat an average of around 500 ELVs per year (minimum 69 in LT and maximum 2295 in HU). The total number of ATFs increased during the period 2014 – 2017 to about 14 000, although the development of ATF capacity varies between Member States. The evaluation did not point to any major problems in the implementation of the provisions regarding the availability of ATFs across the EU. To ensure effectiveness, Member States encourage ATFs and other establishments operating treatment operations to introduce “certified environmental management systems”, for which there is however no definition. The EU Eco-Management and Audit Scheme (EMAS) and ISO 14001 are among the most commonly used certification systems. ATF registration under these systems has been used as measure of compliance with this requirement. The reporting on the implementation of EMAS for ATFs varies across the Member States. Relatively few Member States report a large number of EMAS certified ATFs. Certification to the less demanding ISO 14001, an alternative environmental management system, is more often applied than EMAS certification.

All Member States are also implementing correctly the provisions of the ELV Directive according to which the delivery of the vehicle to an authorised treatment facility shall occur without any cost for the last holder and/or owner. Article 5(2) of the ELV Directive specifies that “Member States shall also take the necessary measures to ensure that all end-of life vehicles are transferred to authorised treatment facilities”. The number of ELVs transferred to ATFs across the EU amount to around 6 million per year. However, a large number of ELVs are not transferred to ATFs and are considered as “missing vehicles” (see section 5.1.2. on this issue in the present report). After collection, the typical treatment of end-of-life vehicles usually consists of two different steps: I.The first step is the treatment in an ATF, where ELVs are de-polluted and dismantled, as required by the ELV Directive. Minimum requirements for installations for storage and treatment of ELVs in such ATFs are described in Annex I to the ELV Directive. Additional national requirements might also be established. No particular problems were reported on the implementation of these standards during the evaluation process; II.The second step is the shredding of depolluted ELVs. Shredders for ELVs are regulated by the best available techniques (BAT) reference document for waste treatment. A total of 352 “automotive shredders” were operating in the EU and Norway in 2014. Most of these were in Italy (62), France (50), UK (47), Germany (43) and Spain (31). The remaining 33% of this type of shredders are distributed across 20 countries. There is minimum one shredder identified per Member State. Source: Mc Kenna 2014 After shredding, the residues are either disposed of or treated in post-shredder technology (PST) facilities. Some shredders have integrated PST or separate PST on site; other shredders send residues of the shredding process to offsite PST plants while some operators send shredder residues without PST for disposal e.g. at landfills. PST facilities allow to recover or recycle residues and improve recycling rates. The current reporting rules do not require Member States to present information on the existence and capacity of PST facilities, so that there is not comprehensive overview of the situation across the EU, or comparison between Member States on this point. 5.1.1.4.Factors increasing material recovery Removal of materials from ELVs prior to shredding allows to maximise their recovery from ELVs. It prevents mixing of materials at the shredding stage and preserves their value, and recyclability and reusability properties. The ELV Directive sets out provisions on the removal of parts to promote reuse and recycling (see Article 6(3) and Annex I(4)) which are not sufficiently precise, and whose effect is limited. For example, these provisions mention the removal of glass without specifying at which stage of the treatment this removal should take place. This means that, in practice, the removal of glass is rarely performed before the shredding stage, which seriously undermines the possibility to recycle glass. The targeted survey confirmed that ATFs tend to remove parts and materials pre-shredding, if a profitable market exists for these. According to eight stakeholders, including experts and business organisations not all parts/materials are economically profitable to dismantle. According to three stakeholders, including administrative organisations, the reason why materials are currently not removed is the lack of an obligation to do so in the Directive. Removal of catalysts, tyres, metal components are considered as the operations which are the most commonly performed at the pre-shredding phase. Potential reasons of non-existence of pre-shredding treatment operations in the EU were indicated at the workshop: ·Glass: A glass association noted that every Member State has the facilities/capacity to recycle, so that the lack of recycling could be due to the higher price of recycled material (vs. virgin material); ·Plastic components: an EPR organisation noted that they are not removed due to the costs and low value of recycled materials; ·Copper: such as that found in wiring (removal requiring precise recycling practices) has a high extraction cost and it is therefore not economically viable for an ATF to extract it. 5.1.1.5.Reuse and recycling targets

Article 7 of the ELV Directive sets out targets for the re-use and recycling of ELVs (85% by an average weight per vehicle and year) as well as re-use and recovery of ELVs (95% by an average weight per vehicle and year). These targets were due to be met by the Member States by 1 January 2015. As presented in Figure 5 ‑2 a large majority of the Member States reported compliance with meeting these targets for 2017 which is the latest year where this information is available. 15 Member States had met the minimum reuse and recovery target of 95% by an average weight per vehicle and year. The average reuse and recovery rate for the EU28 as a whole was 94%, just below the target.The data reported by the Member States indicate that the recovery/reuse and recycling/reuse targets set out in the ELV Directive have largely been met, as it is shown in Figure above. The different options available to the Member States for reporting on the attainment of the targets means however that the data are not necessarily comparable and that their quality varies across Member States. There is no separate target established for reuse, and the level of reuse reported by the EU Member States varies considerably. Figure 5 ‑3 displays the share of reuse, compared to the total volume of reported reuse, recovery and disposal operations, as reported by the Member States for the year 2017 (or for the year otherwise indicated in the table). Source: Data: Eurostat; compilation: Oeko-Institut e.V. The date set out for achieving these targets is 2015 and these targets have not be revised since the adoption of the ELV Directive in 2000. Article 7(3) foresees that targets should have been set for the post 2015 period, but this was not done. The Commission published a report on these targets in 2007, after conducting an Impact Assessment, assessing available information from a study on the costs and benefits of the ELV Directive. The assessment showed that the targets set by the ELV Directive for 2015 generated both substantial environmental and economic benefits and that repealing or reducing the targets would reduce these benefits. The report concluded that these targets should remain stable in order to guarantee investment security into more cost efficient waste treatment technologies. Therefore, the report concluded that Commission should not propose a revision of the targets. Other important aspects relating to these targets are addressed in other parts of the present report (notably the lack of coherence with the Waste Framework Directive on the definition of “recycling”, as well as the added-value of setting targets per weight vs per materials). 5.1.1.6.Material specific recovery targets There is a limited quantitative data available on the recycling of specific materials from ELVs. Table 1 in the Annex of Commission Decision 2005/293/EC laying down detailed rules on the monitoring of the reuse/recovery and reuse/recycling targets set out in the ELV Directive contains some materials from the depollution and dismantling for which reporting on reuse/recycling/energy recovery/total recovery is requested. However this table is not mandatory and Member States do not provide this detailed information. A report by the French Environment Agency provides details on the reuse, recycling, energy recovery and disposal by material, based on data for ELVs treated in France in 2018 (see table below). The figure shows that metal and metallic components (such as catalytic converters and batteries) are almost 100% reused and/or recycled. For non-metallic components, the share of re-use is 12,5%, recycling 39%, sent to energy recovery facilities for 27% and landfilled for 22%. A higher share of such materials (e.g. glass, tyres and most plastics) are directed to energy recovery or disposal. Regarding tyres, in 2018, 62% of end-of-life tyres were recycled into other applications and 33% of tyres is directed to energy recovery. Retreading tyres is also a way to increase resource efficiency of tyres. The lowest reuse and recycling rates are reported for textiles and polyurethane foams. The targeted survey included a specific question on whether specific waste management targets per material, such as a specific rate for aluminium, plastic, glass, would improve the implementation of the ELV Directive. Different reactions were received, although a majority of respondents agreed specific material targets would improve the implementation of the Directive. Eight stakeholders, representing recyclers, experts and public authorities, noted it would lead to incentives for higher recycling and better eco-design of cars. Specific targets were suggested for certain materials such as aluminium, glass and plastic. However, it was opposed by one stakeholder that a specific rate for aluminium would highly increase costs for ELV dismantling, while another business association indicated that aluminium recycling from automotive applications is already in the average of 95%. Figure 5‑4: Breakdown by type of treatment of each material constituting an ELV Source: Ademe (2020)

On the other hand, some stakeholders did not see material specific targets as the best solution and argued that the material market values should remain as the driving force. This view was supported by the EPR organisation and an ATF company stating that material targets would not be effective without pre-existing markets for secondary materials. The glass-related association, however, strongly supported the idea of introducing specific targets per materials, especially for glass, noting that such target is already established in other EU legislation. The current targets render material recovery highly dependent on the profitability factor, which level varies from material to material. Such situation implies that the current model is left for self-regulatory, and constraints the effectiveness of the Directive and its contribution to the circular economy. 5.1.1.7.Information on cars components and materials designed to improve dismantling Article 8 of the ELV Directive contains provisions designed to facilitate the identification of components and materials in vehicles which are suitable for reuse and recovery, as well as to make this information accessible to dismantlers. To comply with these requirements, the car industry established the International Dismantling Information System (IDIS) which provides the dismantling information to the ATFs. 26 manufacturers representing 77 brands and 3 161 models and variants use IDIS to provide dismantling information to 6 476 registered users. Repair and maintenance information (RMI) might also be required for reuse. The Directive does not oblige the producers to provide such information for free. In fact, the producers provide the dismantling information in IDIS free of charge, while access to RMI may incur a fee. Stakeholders from the repair and dismantling sectors, as well as those involved in the sale of spare parts, have been complaining of a lack of transparency from the car manufacturing side with regard to the characteristics of components in cars. The car manufacturers often invoke commercial or confidentiality reasons to limit in practice the sharing of this information. While the ELV Directive has contributed to improve transparency with regard to information needed for dismantling and reuse purposes, it seems that there are still obstacles which prevent the dismantling, reuse and repair sectors from benefiting of a range of information and data which could contribute to their activities and to the objectives of the Directive. 5.1.1.8.Effectiveness in monitoring the results: reporting provisions 5.1.2.A significant problem affecting the effectiveness of the ELV Directive: the “missing ELV” 5.1.2.1.Overview of the problem of “missing vehicles” Commission Decision 2005/293/EC lays down that Member States shall report on the total number of ELVs on their territory each year. The reported numbers of ELVs generated in EU-28 until 2017 are displayed in Figure 5 ‑5 . Figure 5‑5: Number of ELVs generated in EU-28 Source: Eurostat The rise in 2009 was caused by scrappage schemes, including pay out to the last owner, in the context of the financial crisis 2008/2009. The slight peak in 2017 is considered to be a result by incentives to scrap old diesel vehicles as a consequence of diesel exhaust gas treatment fraud. While around 6.5 million ELVs are reported to be treated according to the ELV Directive every year, it is estimated that around 35% of de-registered vehicles, i.e. approximately 4 million units per year, are of unknown whereabouts. These vehicles are not properly accounted for and these de-registered vehicles are not tracked properly. There is a possibility that many of these vehicles become ELVs and are not dismantled and finally treated according to the standards set out in the ELV Directive. This is the most serious problem affecting the effectiveness of the ELV Directive. The table below displays number of unknown whereabouts of vehicles each year in the EU. As observed, there were no significant changes in trends from 2008 to 2017. 2008 2009 2010 2011 2012 2013 2014 2015* 2016* 2017* Unknown whereabouts

(million vehicles) 4.1 3.4 3.4 3.8 3.5 3.7 4.7 3.8 3.9 3.8 * EU-28, excluding Bulgaria

Source 2008 – 2014: (Mehlhart et al. 2017); 2015 – 2017: Oeko-Institut, update for this evaluation report A number of studies have assessed the issue of ELVs of unknown whereabouts:

· Effectively tackling the issue of millions of vehicles with unknown whereabouts - European priority measure: establishing leakage-proof vehicle registration systems (UBA 2020) ·Velten, Eike Karola; Clemens Brauer, Jan-Erik Thie (2020): Used vehicle trade and fleet composition in Europe. Final report of the project “Used vehicle trade and fleet composition in Europe” on behalf of the EEA. Ecologic Institute and Fraunhofer Institute for Systems and Innovation Research ISI: Berlin, Karlsruhe; ·‘End of life vehicles: Legal aspects, national practices and commissioned recommendations for future successful approach’ (Schneider et al. 2010), commissioned by the European Parliament; ·‘European second-hand car market analysis’, (Mehlhart et al. 2011), commissioned by the European Commission (DG CLIMA); ·‘Compliance promotion initiative to assess the implementation of Directive 2000/53/EU on end-of-life vehicles with emphasis on the end of life vehicles of unknown whereabouts’ (Mehlhart et al. 2017), commissioned by the European Commission (DG ENV). All these studies identified shortcomings in the vehicle registration and de-registration procedures, impeding the possibility to identify the correct number of ELVs generated in each Member State. As shown in Figure 5 ‑6 , 11.21 million vehicles exited the stock of registered vehicles in EU-28 in 2017 (sum of the red, green and yellow arrows to the right of the figure). 6.57 million were treated as ELVs within the EU-28, 0.87 million were exported to non-EU-28 countries. Figure 5‑6: Unknown whereabouts of vehicles (M1 + N1) in the EU-28 excluding Bulgaria in 2017 Source: Oeko-Institut The final destination of the difference of 3.77 million vehicles is not easy to be derived from official sources. These vehicles may be either shipped and sold as second hand vehicles in other EU Member States, and not properly reported to the country of registration (there is an important volume of second-hand cars shipped between EU Member States ). These vehicles can also be kept for exclusive use in private properties. Another reason might that these vehicles are illegally treated as ELVs and thereby not reported officially, or illegally exported outside the EU. The lack of incentives for the last vehicle owners to deliver their ELV to an ATF was mentioned as one factor which contributes to the low number of vehicles reported as ELV compared to the number of “missing vehicles”. This problem shows that the current framework does not ensure a sufficient traceability of de-reregistered/used vehicles. It does not ensure that all ELVs are reported according to the minimum requirements established by the Directive. It has not been possible to date to estimate the proportion of ELVs missing due to “administrative problems” (linked to the loss of information on the fate of vehicles shipped from one Member State to another, and going through de-registration and re-registration procedures in different Member States) compared to the proportion of missing ELVs due to illegal activities (especially illegal exports and illegal disposals). Table 5 ‑2 compiles the most important causes for the high number of “missing ELVs”, as well as the corresponding legal situation and environmental impacts. Table 5‑2: Reasons for ELVs of unknown whereabouts Reason for unknown whereabouts ELV Legal situation Environmental concern Non-reported export of used vehicle to non-EU-countries The export of second-hand vehicles is permitted under European law, but failure to declare is a breach of the obligation to report to the customs authorities. In some importing countries, import bans apply to used vehicles with different characteristics. Thus, undeclared exports could also violate the regulations of the destination country. If the used vehicle is near to end of life, hazardous components might be harming the environment in the near future if not treated according to the minimum requirements applicable in the EU. Non-reported transfer of used vehicles to other EU Member States Currently there is no obligation in force to report to the vehicle register of origin the re-registration in the country of destination. In the context of the car registration procedure there is a request to the register of origin if the car is stolen or other police information is registered. However, this communication is not necessarily introduced in the register of the country of origin. No direct environmental concern, even though the shipment of old vehicles can generate air pollution in the country of destination Export of ELVs to non-EU non-OECD countries Infringement of European law (Waste Shipment Regulation), which bans the export of hazardous waste outside the OECD. Not appropriate treatment of hazardous waste might cause environmental harm. Illegal transfer might cause clean-up cost and compensation to the receiving country by the country of origin Non-reported shipment of ELVs to other EU Member States. Treatment in the receiving MS in ATF or non-ATF. (Even if a CoD is issued, it is not forwarded to the country of origin.) The shipment of ELVs from one EU MS to another one should require the application of the prior informed consent procedure (PIC) as ELVs would usually be considered as hazardous waste No concern, if the ATF operates according its permits. The risk of environmental pollution is higher in non-ATFs compared to ATFs Non-reported treatment in ATFs (While it would be possible no CoD is issued) Currently not illegal No concern, if the ATF operates according its permits Treatment in non-authorised treatment facilities, within or outside the Union. Illegal according to ELV Directive The risk of environmental pollution is higher compared to ATFs Increase of ELVs / de-registered vehicles on stock Unlikely option as the number of vehicles of unknown whereabouts is simply too high, vehicles would be visible. The problems linked to deregistration of vehicles and the differences between ELVs and used vehicles, as well as initiatives to address them, are described further below. 5.1.2.2.Certificates of Destruction (CoD) and conditions for deregistration of vehicles The ELV Directive (Article 5(3)) states that “Member States shall set up a system according to which the presentation of a certificate of destruction is a condition for deregistration of the end-of life vehicle. This certificate shall be issued to the holder and/or owner when the end-of life vehicle is transferred to a treatment facility”. This provision attempts to make a link between the legal requirement of issuing a certificate of destruction under the ELV Directive and deregistration of vehicles, which is otherwise regulated through the Directive 1999/37/EC on the registration documents for vehicles. There is also a general provision in this Directive linking the cancellation of the registration of vehicles and the ELV Directive. There are many situations where vehicles get deregistered, which are not linked to the fact that they are becoming ELV. Declaration that the vehicle will not be used for a certain period of time and is used exclusively on private grounds can in some countries be a condition for (sometimes temporary) deregistration. For example, Germany maintains procedures of automatic deregistration, if a vehicle is temporarily deregistered for a particular length of time and not re-registered. Other conditions may include export to another country (which may include vehicles that are then becoming ELVs in the importing country), migration of the vehicle together with the owner to another EU country or theft. Therefore the total number of ELVs reported by the Member States cannot be assumed to correspond to the number of deregistered vehicles.

In addition, the exchange of information between the different national administrations in charge of the ELV Directive and those in charge of the registration of vehicles is often not organised in a way which allows to keep track of vehicles, particularly for those which are shipped to another Member States and become afterwards ELV. For all these reasons, the vehicle registration systems and the reporting of ELVs in the Member States are not functioning well together. To address this problem, some Member States have adopted specific incentives or rules to ensure that ELVs are delivered to ATFs and reported as ELV to all relevant administrations. Financial incentives have been established in Denmark in a form of “pay out scheme” to encourage the vehicle’s last owner to bring a vehicle to an authorised treatment facility (ATF) in exchange for a payment. One of the most comprehensive approaches is applied in Portugal where the vehicle tax is levied until an ATF provides the CoD. Although functional, this approach would be difficult to implement in Member States where vehicles can be registered as no longer “on the road” and exempted from vehicle tax. The Netherlands have a different registration system where the whereabouts of vehicles is very strictly followed. Stakeholders agreed that stronger regulation on registration/deregistration procedures and exchange on deregistration information between Member States are key steps to reinforce the application of the CoD. It was also observed that insurance companies are in position to better contribute to the implementation of the Directive, in particular through strengthening control in organising the auctions of ELVs. Selling large quantities of ELVs to the highest bidder is currently unregulated and could serve as a channel for the illegal operations, including export. There are some attempts in this area. For instance, France introduced in 2020 a new legal approach which strengthens the conditions to terminate a car insurance in cases when a car owner refuses compensation after a car accident which led to damages which cannot be technically or economically repaired. For such cars, the new legislation only allows the termination of the insurance upon production of a CoD, or of a new insurance contract, or proof that the car has been repaired. Stakeholders advocated for closer cooperation between authorities at national and regional level to address the issue of registration/deregistration of vehicles and its connections to the ELVs of unknown whereabouts. 5.1.2.3.Shipments of ELVs vs. used cars The problem of “missing ELVs” is also linked to the shipment of used cars from one Member States to another or to 3rd countries outside the EU. The transboundary shipment of ELVs is not covered by the ELV Directive but is subject to the provisions of of the Waste Shipment Regulation (WSR). ELV are considered as hazardous waste, which cannot be exported outside the OECD under the Waste Shipment Regulation. Shipments of ELVs within the EU and from and to OECD countries, are subject to the procedure of prior written notification and consent referred to in the WSR, unless they are depolluted (and hence considered as non-hazardous waste). While the export of ELVs outside the OECD is prohibited, this is not the case for the export of “used cars”. In practice, it is often difficult to distinguish used vehicles (non-waste) from ELVs (which are waste) for the purposes of shipments. This is mainly related to the interpretation of whether the vehicle in question meets the waste definition. Specific guidelines were developed by the Waste Shipment Correspondents to assist enforcement and customs officials in implementing the rules on the export of ELVs, and especially to distinguish between ELVs and used cars. According to these guidelines, the distinction between waste vehicles and used vehicles, first of all, depends on the answer to the question whether the holder of the vehicle intended to discard it or not. To make this judgment it is necessary to examine the situation of the vehicle on a case-by-case basis. The guidelines further indicate the characteristics of a used vehicle vs characteristics of waste. For instance, a vehicle would qualify as waste if it is not suitable for minor repair or has badly damaged essential parts (e.g. as a result of an accident) or is cut into pieces (e.g. two halves); if the repair costs exceed the present value of the vehicle (exception: vintage cars or vehicles) and the possibility for repair cannot be assumed, it would classify as a waste. In practice, as the guidelines are not legally binding and contain advice rather than straightforward criteria to distinguish between waste and non-waste, they are not applied consistently across the Union. Furthermore, the guidelines refers to a case-by-case approach according to a number of characteristics. Customs and other enforcement authorities at large shipment hubs like Rotterdam port claim that it is not possible for them to assess each single used vehicle for export to decide if it is waste or not. In the event of targeted controls, the guidelines can still be used, but apparently, they are not applied largely in practice. The effect is that many used vehicles, considered within the EU as ELVs, are illegally exported to third countries. A recent study on the quality of used vehicles carried by the Dutch Ministry of Infrastructure and Water Management shows that a significant part of the used vehicles exported to African countries, where Libya, Nigeria, and Ghana are the top three destinations, is of similar age as end-of-life vehicles recycled in the Netherlands. Most of them do not meet Euro 4/IV emissions standard, i.e. they are older than 15 years. The findings from this study, based on their sample, show that most used vehicles exported today outside the EU do not have a valid roadworthiness certificate. These exports to African countries are likely to cause environmental harm with hazardous liquids or other hazardous substances leaking into the environment and causing public health problems, in particular to those people involved in their treatment. The study also shows that the exchange of information on the export of used vehicles is hampered by the fact that the information on vehicle registrations is not made available from one Member State to other Member States, in the absence of obligation to do so under EU law. The absence of the Vehicle Identification Number (VIN) in the customs declaration is also singled out as hampering a proper traceability on the export of used vehicles. A UNEP report on the environmental impacts of export of used vehicles to the developing world states that the lack of effective standards and regulations is resulting in the dumping of old, polluting and unsafe vehicles. It urges developed countries to stop exporting vehicles that fail environment and safety inspections and are no longer considered roadworthy. It further invites the importing countries to introduce stronger quality standards. The environmental implications of such exports and their links with the climate change policy are discussed in the Section 5.4.2. The export of used vehicles or ELV furthermore causes valuable resources to be lost for the EU circular economy. It also puts into questions the application of producer responsibility. While the manufacturers and importers are obliged to set up systems for the collection, treatment, and reuse/recovery of parts and materials from vehicles that have reached the end-of-life phase, these obligations are not implemented when they are exported to countries which do not have appropriate and environmentally sound disposal and treatment infrastructure for ELVs. This situation raises concerns as only about 55% of the EU trade in used light duty vehicles was traded within the EU in 2018, while the remaining part mainly went to developing countries. It is estimated that in 2018 alone, the EU exported over 1 million used light duty vehicles to African countries out of a total of 1.5 million used light duty vehicles imported in these countries that year. To facilitate the distinction between used cars and ELVs, a number of Member States have put in place specific measures, so as to better monitor and track their shipment. For example, in the Netherlands, a vehicle is considered as an ELV when it cannot be repaired for market value realistic costs in the country of export. A similar approach is applied in Ireland. Despite available at the national level, the provisions of the ELV Directive have not been effective to ensure that all ELVs get properly reported and it is likely that an important number of these unreported ELVs are not treated according to the rules in the ELV Directive, notably as they are exported outside the EU without sufficient controls. The fact that individual Member States have adopted several specific measures on this point is a sign that, in its current form, the ELV Directive does not provide a sufficient solution to address this problem. 5.1.2.4.Inspections and enforcement of ELV Directive There are no provisions in the ELV Directive requesting Member States to take enforcement actions to ensure a proper implementation of its provisions. There are in particular no provisions on inspection of ATFs and other treatment facilities, or relating to the export of ELVs. Several Member States reported that they carry out occasional inspections of ATFs through standard procedures of the competent environmental authorities. During the consultation, stakeholders indicated that inspections in non-ATFs are not undertaken. It means that the scope of inspections are usually limited to the ATFs, leaving repair car workshops, spare parts shops, export companies and online market places unassessed in terms of illegal trafficking of cars and spare parts. In terms of vehicle exporters, inspections are effective to some extent, but the enforcement of exporting regulation requires more knowledge and expertise. As it was observed by the Netherlands experience, inspections based on the EU Waste Shipment Regulation currently only stop the worst quality vehicles (wrecks), which constitute one or two cases from every hundred vehicles lining up for West Africa. Moreover, 80% of exported vehicles to Africa do not have a valid roadworthiness certificate, which means that such vehicles are not fit to be used on public roads in the EU as they do not conform to vehicle safety and emissions standards. These findings reconfirm the need to strengthen the control of the vehicles, since the EU was the largest exporter with 54 % of the totally exported used vehicles worldwide between 2015 and 2018. Problems with the enforcement of the ELV Directive have also been sporadically observed with regard to the obligations under Article 4(2)(a) to ensure that materials and components in vehicles do not contain lead, mercury, cadmium and hexavalent chromium, with the exceptions of the cases listed in Annex II of the Directive. The finding in 2019 that a number of car manufacturers were using components in circuit boards containing lead above the authorised limits illustrated the insufficient efforts put in enforcing these rules. The revised rules on market surveillance in the type-approval Regulation should help addressing better such problems at EU level in the future. Nevertheless, insufficient human and financial resources were the most decisive factors mentioned as preventing Member States from carrying out enforcement/inspection activities.

5.2.Efficiency The evaluation on the efficiency of the ELV Directive focuses on the actual costs and benefits associated with the implementation of the ELV Directive, as well as on the administrative burden linked to it. A special emphasis is placed upon the distribution of costs and benefits across economic actors, aiming to answer whether the total benefits overweight the costs faced by operators at the different ELV treatment phases. 5.2.1. Benefits and costs This section attempts to present an overview of environmental, social and economic costs and benefits related to the implementation to the ELV Directive, as they accrue to different stakeholders, identifying what factors are driving these costs/benefits and how these factors relate to the Directive. Although it is difficult to identify precisely, extrapolate at EU level and compare costs and benefits associated with the ELV Directive, the consultation carried out as part of this evaluation showed that the vast majority of the stakeholders recognised that the total benefits of the Directive outweigh its costs. A detailed analysis on the costs and benefits, including figures and tables, is provided in the Annex 4 of this report and Chapter 6.7 of the study supporting this evaluation. 5.2.2.1.Benefits There environmental, social and economic benefits attributable to the Directive are presented below. The environmental benefits include the avoided damages to the environment due to inappropriate handling of ELVs, leading to uncontrolled disposal of hazardous substances, fluids and other components, as well as the reduction of hazardous substances in vehicles. Indirect environmental benefit may include the lower environmental damage associated with resource extraction avoided due to recycling and reuse of materials and components from ELVs. Social benefits involve the avoided damage in human health due to exposure to hazardous substances and unregulated dismantling operations. Other social benefits include the employment and income generation for employees across the EU in the dismantling sector and other economic operators, the majority of which are small-medium enterprises (SMEs). According to the statistical classification of economic activities in the European Community (NACE), the nearest definition to the ATFs is E38.3.1 – ‘Dismantling of wrecks’. In the 2017 Eurostat report there were 2 675 enterprises with 14 137 employees and a total production value of EUR 2 787 million across the EU 28. Comparing these numbers with the known number of ATFs indicated above suggests that this NACE code covers only the number of active ATFs (e.g. 14 000 ATFs will have more than 14 137 employees). Economic benefits comprise business revenues for the dismantling and shredding sectors and for a number of other sectors that use secondary materials derived from ELV treatment. The creation of a level playing field for all market participants across the EU is also considered an economic benefit derived from the Directive. Approximately 6 to 7 million ELVs are reportedly treated each year in approximately 14 000 ATFs and in 352 “automotive shredders” across the EU. The analysis of the ELV economic activity of ATFs alone is complex, as the majority of companies do not conduct cost accounting based on the ELV activity, which often coexists with other activities, such as purchase/sale of damaged vehicles and second-hand vehicles, sale of new spare parts, trade in scrap metal. ATFs derive income from selling both parts for reuse and materials for recycling from ELVs. Based on the information provided by the stakeholders, the most profitable components for removal included lead-acid batteries, catalysts, metal components (with Cu, Al, Mg), engines and gear boxes. Other materials reported as profitable for removal were electronics, especially electronic control units, wiring, foam and textiles. It is difficult to retrieve data on benefits which provide a comprehensive picture for the whole dismantling sector at the EU level. Data presented below are approximate that will vary over time, depend on market prices, and are likely to be different per Member States. In a 2015 report relating to the economic situation of the vehicle dismantling sector in France, it was estimated that the operating income derived from the sale of recovered/removed parts by ATFs was estimated to amounted to an average of €130/ELV and of 134€/ELV for the materials sent for recycling or recovery. For shredders, the sale of materials (mostly ferrous and non-ferrous metals) represented an average amount of 258€ per tonne. This report found that the average operational income of ATFs was slightly negative, while the operational income for shredders was close to zero. As a large share of the revenues derived from the dismantling and shredding of ELV is represented by the sale of ferrous metal, the overall value of these sales at EU level can also be used as an indicator to assess the turnover of the sector: based on an average price of 235€/tonne for shredder steel scrap, and the fact that non-ferrous metal accounts for 70% approximately of the weight of vehicle and that 6 million ELV are dismantled every year, this overall amount of the sales is around 1 billion €/year. For the car manufacturing sector, the overall direct economic benefits of the ELV Directive are more difficult to quantify. Such benefits could include the promotion by the car industry of their practices to improve the sustainability of their products through ensuring that most of their parts and components are re-used, recovered or recycled. The most important economic benefits of the ELV Directive have been to help consolidating the vehicle dismantling and recycling sector in the EU Member States, while ensuring to consumers that they can dispose of their ELV free of charge. 5.2.2.2.Costs Costs associated with the ELV Directive are incurred by various economic operators for technical compliance, data collection, reporting and monitoring. The costs for the automotive industry relates to the design of vehicles taking account of dismantling/recyclability requirements, to the replacement of hazardous materials which get prohibited through changes to Annex II of the Directive, to the free take-back of ELV and to the information provided to dismantlers. Based on the input received from the European Automobile Manufacturers’ Association (ACEA) on the compliance costs of the automotive industry with the ELV Directive, overall costs of the sector are estimated to amount to around 160 million Euros per year, as shown in the Table 5 ‑3 bellow. Despite the costs attributable to the sector, there is no evidence nor claims that the ELV Directive has a negative impact on the competitiveness of the automotive industry within the EU.

Costs since implementation 2000 – 2020 cumulative (million €) Running costs per year (million €/a) IMDS (ELV Directive only) 1,632 107 Take-back networks 980 49 Dismantling Info 58 3 Consumer-Info 26 1 Overall Cost 2,696 160 *Source: Estimate by the European Automobile Manufacturers’ Association (ACEA) The costs for the vehicle dismantling sector relate to the purchase of the ELV to their last owners, staff cost, compliance with the technical requirements in Annex I of the ELV Directive and their reporting obligations. According to a compilation of data from different sources, the overall costs, including those covering reporting, monitoring, operating and payments to the last owner of an ELV, is estimated to amount to around 1.2 billion Euros per year. This figure must be treated with caution as it is based on an extrapolation of different data and does not stem from a comprehensive economic assessment of the situation across the EU. The evaluation did not reveal any data on significant differences between Member States in relation to costs incurred by different economic operators, except from the ATF reporting costs. There is significant variation across Member States on their experienced costs in collecting and reporting data. It is considered to be caused by differences in the level of reporting detail requested by national authorities and difference in vehicle registration and de-registration procedures. Enforcement costs were not reported by national governments. The large number of ELVs with unknown whereabouts, which are partially attributed to illegal activities (i.e. illegal exports and illegal dismantling) implies that the ELV Directive is not being fully enforced in some Member States. Therefore, although the cost of the Directive enforcement cannot be estimated, it is observed as lower than required, meaning that proper enforcement would have to mobilise additional resources from Member States. The costs for consumers for disposing of their ELVs has been identified as either zero or even positive. It has been reported that ATFs often pay to acquire an ELV from the last owner or an insurance companies, if considered that the ELV has a high value due to spare parts or materials. In rare cases, where justified by the Directive, it was mentioned that the final owners might have to pay for the transportation of the ELV from the last owner’s storage place to the ATF. Distribution of costs and benefits across economic actors The distribution of the costs and benefits associated with the ELV Directive across the different economic operators is an issue where diverging views were expressed by the interested players. There is first disagreement and inconsistent data on the profitability of ATFs. The car manufacturing industry tends to consider that on average ATFs already operate at a profit. ATFs claim they lose money, but still process the ELVs in compliance with regulations, although economically they have no incentive to treat some ELVs. For example, the economic analysis of the ATF activity in France in 2015 showed that around 40% of ATFs were operating at a loss. It suggests that the treatment (and removal of parts for resale) of some (typically newer) vehicles may subsidise the treatment of older ELVs which have a negative-value to the ATFs. ATFs argue that they are exposed to illegal competitors who do not have to cover inter alia all depollution and disposal efforts. Producers argue that the costs for depollution and dismantling are covered by revenues from the reuse of components and recycling of materials. It shows that the Directive has increased costs for the economic operators (e.g. dismantlers, shredders, etc.) at the end of the vehicle life cycle. The second point relates to whether the car manufacturing sector contributes sufficiently to the costs incurred by the management of end-of-life vehicles. This issue is discussed more in details in the part of the present document dealing with the coherence of the ELV Directive with other EU legislation on the question of “Extended Producer Responsibility” (EPR). Additional, detailed data on the costs and benefits linked to the ELV Directive for the different stakeholders can be found in the study conducted to support this evaluation report. 5.2.2.Administrative burden and simplification opportunities Regarding the question if the ELV Directive caused any unnecessary regulatory burdens or complexities, the majority of stakeholders did not know (52%), with a relatively even split between yes (35%) and no (33%). In the written comments the most common response on this point concerned the overlaps between the ELV Directive and Batteries Directive, as collection and recycling of batteries is already regulated by the latter. Burdensome reporting was another issue highlighted by some ATFs due to the existing duplicated reporting obligations at the national level. Respondents were also specifically asked for suggestions to reduce the administrative burden. First, it was suggested to simplify the reporting obligations deriving from the ELV Directive by using online tools. Secondly, changes were proposed in the vehicle (de-) registration and notification systems, with the suggestion that vehicle registrations could be cancelled directly by authorised dismantlers, which would reduce the workload for authorities and represent an effective measure to reduce the amount of untracked exports and unregulated ELVs. Findings of the survey on the administrative specific costs contribute to the overall assessment of the administrative burden. Stakeholders were asked to provide information on their hours and costs necessary to administer ELV Directive issues, including data collection, reporting, monitoring and technical compliance issues. Although the responses received are variable between Member States and should be treated with caution, the data collected show the tendency that companies, e.g. recyclers and ATFs, on average spend more resources on technical compliance than other stakeholder types. It also appears that public authorities seem to have higher costs across most categories, but particularly for data collection, and technical compliance. The most robust data were presented by the French Environment and Energy Management Agency (ADEME) where dismantlers (1 700 companies) and shredders (60 companies) declare their activities to ADEME via a specialised website, roughly accounting for 1.2 million ELVs per year. This costs ADEME €170 000 a year (about 0.15 Euros per ELV) and they use roughly 20 days a year to validate their ELV annual report. Due to the different approaches applied between Member States, estimation of the total administrative cost of compliance would require a detailed review of procedures and interviews in each Member State. Taking into consideration that Member State raised no particular concerns about their administrative costs, such detailed investigation was not carried out. Taking into consideration abovementioned aspects, the digitalisation of procedures linked to the implementation of the ELV Directive can potentially contribute to reducing administrative burden. However, regarding the other aspects, there is no clear evidence that the ELV Directive leads to unnecessary administrative burden or complex procedures for stakeholders, including private sector and public authorities. 5.3.Relevance Different aspects are presented in the section, evaluating how the ELV Directive is adequate to address the evolution of the automotive sector and other current challenges linked to the treatment of end-of-life vehicles. The section evaluates the relevance of the scope of the ELV Directive and how it correlates with the objectives of the ELV Directive itself. Furthermore, it assesses the ability of the ELV Directive to adapt to subsequent technological advancement, such as the increased use of lightweight materials, electric, electronic and other components in vehicles and the sales of electric or hybrid vehicles, as well as the development of online sales for spare parts.

5.3.1.Scope of the ELV Directive The ELV Directive covers passenger cars classified as M1, light commercial vehicles classified as N1 and three-wheel motor vehicles as defined in Directive 92/61/EEC but excludes motor tricycles. Other vehicles, such as buses with more than 9 seats, specialty vehicles such as ambulances, motorcycles, commercial vehicles for the transport of goods with a maximum mass of more than 3.5 tonnes, trailers and other vehicles (e.g. trains, boats and airplanes) are not covered by the ELV Directive, meaning that totally 25 % of all vehicles are not subject to compulsory treatment in ATFs under minimum requirements at the end of their lifecycle. The Eurostat statistics show that after the passenger cars, trucks (including to a large extent N1 vehicles) and motorcycles represent respectively the second and third largest groups of the vehicles of all vehicles registered in the EU in 2016. In the context of the ELV Directive, it means that 258 million passenger cars, representing over 75 % of all vehicles, and around 90% of the 34 million trucks with the weight less than 3.5 tonnes registered in the EU fall within the scope of the Directive. The remaining 45 million vehicles, including motorcycles, trailers and semi-trailers, road tractors, special vehicles, motor coaches, buses and trolley buses, are not within the scope of the ELV Directive. Vehicle type Number Percentage Passenger cars 258 003 552 76.3% Trucks 34 413 937 10.2% Motorcycles 22 018 223 6.5% Trailers and semi-trailers 15 898 235 4.7% Road tractors 3 809 333 1.1% Special vehicles 3 256 933 1.0% Motor coaches, buses and trolley buses 902 522 0.3% Source: Eurostat, stock of vehicles by category, [tran_r_vehst]; download 2020/01/05 Their inclusion should be assessed in light of the environmental concerns that the disposal and treatment of waste derived from these vehicles might be posing a potential risk to the environment. Although the general provisions from the Waste Framework Directive apply to end-of-life vehicles which are not covered by the ELV Directive, their effect is limited, as they do not contain requirements which are specifically tailored to these vehicles, notably on waste prevention, collection, recovery and recycling. Many stakeholders supported the extension of the scope of the ELV Directive to motorcycles, buses and trucks, but a number of them stressed that they should not be subject to the same rules as the vehicles currently covered by the Directive. Stakeholders from the vehicle manufacturing sector highlighted that the situation of heavy duty vehicles, mainly vehicles designed for the carriage of passenger and their luggage with more than 8 seats plus the driver and commercial vehicles for the transport of goods with a maximum mass exceeding 3.5 tonnes, cannot be comparable to that of passenger cars. First of all, the lifetime of trucks and buses is longer than passenger cars. The exploitation of these vehicles is based on different technical features, since trucks and buses must perform under more challenging conditions. The durability and reparability of these vehicles are often prerequisites for their customers. To that end, many manufacturers offer maintenance and repair contracts to ensure the proper performance and a lo