COMMISSION STAFF WORKING DOCUMENT EVALUATION of Directive (EC) 2000/53 of 18 September 2000 on end-of-life vehicles
Date: 2021-03-15
Institutions: Directorate-General for Environment, European Commission
Subjects: EU Member State, application of EU law, disclosure of information, environmental protection, motor vehicle industry, prevention of pollution, vehicle, waste, waste disposal, waste recycling

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 15.3.2021  SWD(2021) 60 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  of Directive (EC) 2000/53 of 18 September 2000 on end-of-life vehicles {SWD(2021) 61 final}  
 
 
Table of Contents 

GLOSSARY ...................................................................................................................................................1 

1. INTRODUCTION .....................................................................................................................................3 

1.1. Purpose .....................................................................................................................................................3 

1.2. Scope ........................................................................................................................................................5 

1.3. The ELV sector and the COVID-19 pandemic .........................................................................................5 

2. BACKGROUND TO THE INITIATIVE ................................................................................................7 

2.1. Description of the initiative ......................................................................................................................7 

2.1.1. Historic background and response to the ELV problematics .................................................................7 

2.1.2. General purpose and objectives of the ELV Directive...........................................................................7 

2.1.3. Main provisions of the ELV Directive...................................................................................................8 

2.2. Intervention Logic ....................................................................................................................................9 

2.3. Interactions with other EU policies and legislations ............................................................................... 11 

2.4. Baseline .................................................................................................................................................. 11 

3. IMPLEMENTATION AND STATE OF PLAY ................................................................................... 12 

3.1. Implementation of ELV Directive .......................................................................................................... 12 

3.2. Key facts and figures relating to the ELV sector in the EU .................................................................... 13 

4. METHOD ................................................................................................................................................. 15 

4.1. Evaluation questions ............................................................................................................................... 15 

4.2. Process .................................................................................................................................................... 16 

4.3. Limitations – robustness of findings ....................................................................................................... 16 

5. ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS ............................................. 18 

5.1. Effectiveness ........................................................................................................................................... 18 

5.1.1. Have the objectives and targets of the ELV Directive been met and monitored? ................................ 18 

5.1.2. A significant problem affecting the effectiveness of the ELV Directive: the “missing ELV” ............ 29 

5.2. Efficiency ............................................................................................................................................... 37 

5.2.1. Benefits and costs ................................................................................................................................ 37 

5.2.2. Administrative burden and simplification opportunities ...................................................................... 41 

5.3.  Relevance ............................................................................................................................................. 42 

5.3.1. Scope of the ELV Directive ................................................................................................................. 42 

5.3.2. Increased use of electric, electronic and other components in vehicles ............................................... 44 

5.3.3. Increased  use  of  lightweight  materials  in  vehicles  like  plastics,  carbon-fibres,  fibre-reinforced 

(plastics) materials and others .............................................................................................................. 45 

5.3.4. Changes in the types of vehicles put on the EU market: increase of electric or hybrid vehicles and 

of SUV ................................................................................................................................................. 47 

5.4.  Coherence ............................................................................................................................................ 50 

5.4.1. To what extent is the ELV Directive internally coherent? ................................................................... 50 

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5.4.2. To what extent is the ELV Directive coherent with other EU policy instruments and the overall 

EU and international policy goals? .................................................................................................... 50 

5.4.2.1.  Coherence with the EU approach to Circular Economy ............................................................... 50 

5.4.2.2.  Coherence with the EU Climate change policy ............................................................................. 53 

5.4.2.3.  Waste Framework Directive .......................................................................................................... 56 

5.4.2.4.  Basel Convention and the Waste Shipment Regulation ................................................................. 59 

5.4.2.5.  Stockholm  Conventionon  Persistent  Organic  Pollutants  (POPs)  and  the  EU  POPs 

Regulation .......................................................................................................................................... 59 

5.4.2.6.  Directive on Waste Electrical and Electronic Equipment (WEEE) and RoHS Directive .............. 60 

5.4.2.7.  Batteries Directive ......................................................................................................................... 60 

5.4.2.8.  Directive on Vehicle Registration Documents ............................................................................... 61 

5.4.2.9.  Directive  2005/64/EC  on  the  type-approval  of  motor  vehicles  regarding  their  reusability, 

recyclability and recoverability ......................................................................................................... 62 

5.4.2.10.  European List of Waste ............................................................................................................... 63 

5.5.  EU Added Value .................................................................................................................................. 65 

6.5. Conclusions ............................................................................................................................................ 67 

6.1.  Effectiveness ........................................................................................................................................ 67 

6.2.  Efficiency ............................................................................................................................................. 68 

6.3.  Relevance ............................................................................................................................................. 69 

6.4.  Coherence ............................................................................................................................................ 70 

6.5.  EU added value .................................................................................................................................... 72 

6.6.  Lessons learnt ....................................................................................................................................... 72 

ANNEX 1: PROCEDURAL INFORMATION ......................................................................................... 73 

ANNEX 2. SYNOPSIS REPORT OF THE STAKEHOLDER CONSULTATION .............................. 76 

ANNEX 3. METHODS USED IN PREPARING THE EVALUATION ................................................. 94 

ANNEX 4. TECHNICAL INFORMATION ........................................................................................... 102 

ANNEX 5. ANALYSIS ON THE COSTS AND BENEFITS ................................................................. 105 

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GLOSSARY  

Term or acronym 

Meaning or definition 

ACEA  

European Association of Automobile Manufacturers 

ASR 

ATF 

BAT  

BEV 

Automotive Shredder Residues 

Authorised Treatment Facilities 

Best available techniques 

Battery Electric Vehicle 

Batteries 
Directive 

Batteries  Directive  2006/66/EC  on  batteries  and  accumulators  and  waste 
batteries and accumulators  

CLP 

CMI 

CoD 

EC 

Classification, Labelling and Packaging (CLP) Regulation ((EC) No 1272/2008) 

Car Manufacturing Industry 

Certificate of Destruction 

European Commission 

ECHA 

The European Chemicals Agency 

EEA 

EEA  

EEE 

ELV 

ELV Directive 

EoL 

EPR 

ELoW 

EV 

EU  

EuRIC 

FTB 

GHG 

ICE 

IMDS 

ISG 

HDV 

European Economic Area 

European Environment Agency  

Electrical and electronic equipment 

End-of-life vehicle 

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). 

End-of-life 

Extended Producer Responsibility 

European List of Waste 

Electric Vehicle 

European Union 

European Recycling Industries’ Confederation 

Free take-back 

Green House Gas 

Internal Combustion Engine 

International Material Data System 

Inter-service Steering Group 

Heavy Duty Vehicle (e.g. Trucks) 

Li-ion batteries  

Lithium-ion batteries 

LSR 

Light Shredder Residues 

1 

 
MS 

OEM 

PHEV 

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) 

Original Equipment Manufacturer 

Plug-in Hybrid Electric Vehicle 

PPWD   

Packaging and Packaging Waste Directive 

PST 

SVHC 

REACH 

RoHS 

SME  

SUV 

TAC 

ToR 

VAs 

Post-Shredder Technologies 

Substance of Very High Concern 

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 

Restriction  of  Hazardous  Substances  Directive  2011/65/EC,  Directive  on  the 
restriction of the use of certain hazardous substances in electrical and electronic 
equipment 

Small Medium Enterprise 

Sport Utility Vehicle 

Technical Advisory Committee 

Terms of Reference 

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  

2 

 
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  vehicles1  (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  20182,  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 Deal3 and the Circular Economy Action Plan4, 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.   

1OJ L 269, 21.10.2000, p. 34–43, https://eur-lex.europa.eu/legal-
content/EN/TXT/?qid=1599215579091&uri=CELEX:32000L0053 
2 Directive (EU) 2018/849 of the European Parliament and the Council of 30 May 2018 amending Directives 2000/53/EC on 
end-of-life vehicles, 2006/66/EC on batteries and accumulators and 2012/19EU on waste electrical and electronic equipment 
(OJ L 150, 14.6.2018, p. 93–99). 
3 COM(2019) 640 final 
4 COM(2020) 98 final 

3 

 
                                                      
 
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 Sustainability5 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  Guidelines6,  as  presented  in  the 
Commission’s evaluation roadmap7, namely: 

  Effectiveness:  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; 

  Efficiency:  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; 

  Relevance:  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.; 

  Coherence: 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; 

5 COM(2020) 667 final 
6https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-regulation-why-and-how/better-
regulation-guidelines-and-toolbox_en  
7 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1912-Legislation-on-end-of-life-vehicles-
evaluation  

4 

 
                                                      
 
  EU 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 20138 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 sector9. 

8 https://www.acea.be/press-releases/article/eu-car-sales-forecast-2020-record-drop-of-25-expected-this-year-says-acea  
9 Data from the automotive aftermarket sector 

5 

 
                                                      
 
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 202510. 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.   

to 

the  EU  adopted 

the  economic  crisis  caused  by  COVID-19, 

In  response 
the 
NextGenerationEU  recovery  instrument11.  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 

10 https://www.bain.com/insights/covid-19-will-hurt-the-auto-parts-market-in-2020-and-beyond-infographic/ 
11

 Communication from the Commission, Europe's moment: Repair and Prepare for the Next Generation, (COM(2020) 456 

final, 27.5.2020) 

6 

 
                                                      
 
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 Europe1213. 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: 

12 Tuddenham, Mark; Hempen, Susanne; Bongaerts, Jan C. (1996): END OF LIFE VEHICLES (ELV): Current basic data 
reflecting the overall ecological and economic context of the ELV issue. Final report. Institute for European Environmental 
Policy (IEEP). 
13Zoboli, Roberto; Barbiroli, Giancarlo; Leoncini, Riccardo; Mazzanti, Massimiliano; Montresor, Sandro (2000): Regulation 
and innovation in the area of end-of-life vehicles. Hg. v. European Commission JRC-IPTS und Enterprise DG. Instituto Di 
Ricerca Sulla Dinamica Dei Sistemi Economici, IDSE; Consiglio Nazionale delle Ricerche, CNR. Milan, Italy. 

7 

 
                                                      
 
 
•  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. 

Figure 2-1: Summary of the ELV Directive 

8 

 
2.2. Intervention Logic  

The  intervention  logic  below  shows  the  intended  functioning,  desired  results  and  overall 
rationale of the Directive.  

9 

 
 
Intended impacts 
  Improved  quality  of  the  environment  due  to  phase  out  of 
abandoned  ELVs  while  assuring  the  smooth  operation  of  the 
internal market 

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.  

10 

 
 
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  Deal14,  the  Circular  Economy  Action  Plan15,  Chemicals 
Strategy  for  Sustainability16  and  the  New  Industrial  Strategy  for  Europe17.  The  Directive 
touches upon issues which are relevant as well for the EU legislation relating to the design18 
and registration19 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 issues20. 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 

14 COM(2019) 640 final  
15 COM(2020) 98 final 
16 COM(2020) 667 final 
17 COM(2020) 102 final 
18 Directive 2005/64/EC of the European Parliament and of the Council of 26 October 2005 on the type-approval of motor 
vehicles with regard to their reusability, recyclability and recoverability and amending Council Directive 70/156/EEC (OJ L 
310, 25.11.2005, p. 10–27). 
19 Council Directive 1999/37/EC of 29 April 1999 on the registration documents for vehicles (OJ L 138, 1.6.1999, p. 57–65).  
20 Zoboli, Roberto; Barbiroli, Giancarlo; Leoncini, Riccardo; Mazzanti, Massimiliano; Montresor, Sandro (2000): Regulation 
and innovation in the area of end-of-life vehicles. Hg. v. European Commission JRCIPTS und Enterprise DG. Instituto Di 
Ricerca Sulla Dinamica Dei Sistemi Economici, IDSE; Consiglio Nazionale delle Ricerche, CNR. Milan, Italy. 

11 

 
                                                      
 
(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/EC21  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 website22. 

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)23; 

  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)24;  

  Report the End-of-Life Vehicle sector by ADEME (2017)25;  
  Enhancing  the  Separation  of  Components  and  Materials  from  End-of-Life  Vehicles 

Aiming at the Recovery of Critical Metals by ORKAM (2017)26; 

21 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32001D0753  
22 https://ec.europa.eu/environment/waste/elv/implementation_en.htm  
23 https://ec.europa.eu/environment/waste/pdf/study/elv.pdf  
24 https://www.umweltbundesamt.de/publikationen/development-of-proposals-including-legal;  
25 https://www.ademe.fr/sites/default/files/assets/documents/automotive-end-life-vehicles-data-2017-report.pdf;  
26 The final report is in German with a short English abstract (page 4) and an English summary of 13 pages (pages 36 to 48). 
https://www.umweltbundesamt.de/publikationen/optimierung-der-separation-von-bauteilen  

12 

 
 
                                                      
 
  Effectively  tackling  the  issue  of  millions  of  vehicles  with  unknown  whereabouts  - 
European priority measure: establishing leakage-proof vehicle registration systems by 
UBA (2020)27; 

  Used vehicles and the environment. UNEP report (2020)28; 
  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)29. 

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 Commission30.  

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 
EU2731. 
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 kg32. This means that the 11.21 
million vehicles leaving the stock in 2017 represent 12.2 million tonnes of waste. 

27 Effectively tackling the issue of millions of vehicles with unknown whereabouts - European priority measure: establishing 
leakage-proof vehicle registration systems; 
28 A link to the UNEP report: https://www.unep.org/resources/report/global-trade-used-vehicles-report  
29A link to the study: https://www.ilent.nl/binaries/ilt/documenten/rapporten/2020/10/26/rapport--used-vehicles-exported-to-
africa/RAPPORT-+Used+vehicles+exported+to+Africa.pdf  
30 See, https://ec.europa.eu/environment/waste/elv/events_en.htm  
31 Eurostat data is available here:https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Passenger_cars_in_the_EU  

13 

 
                                                      
 
  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. 

32 Source: Eurostat: unpublished data for 2018 for 16 out of 31 EU and EEA countries 

14 

 
                                                                                                                                                                     
 
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?   

15 

 
 
4.2. Process 

The Commission first published a roadmap for the evaluation of the ELV Directive in 201833. 
The  Commission  also  worked  with  a  consortium  of  consultants  which  produced  in  August 
2020 a study designed to support this evaluation34. 

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 prohibitions35; end-of-life vehicle statistics from Eurostat36; 
relevant studies37; data from the reports by Member States); 

  An open public consultation was conducted by the Commission for 12 weeks, 6 
August  2019  –  29  October  201938.  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 

33https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1912-Legislation-on-end-of-life-vehicles-
evaluation 
34 More information on the process of the evaluation is available in the consultants’ webpage: https://www.elv-evaluation.eu/  
35 See consultant final reports published: https://elv.exemptions.oeko.info/index.php?id=20 
36  Clarification  on  statistics 
life_vehicle_statistics  
37 https://ec.europa.eu/environment/waste/elv/events_en.htm 
38https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1912-Legislation-on-end-of-life-vehicles-
evaluation  

is  provided  here:  https://ec.europa.eu/eurostat/statistics-explained/index.php/End-of-

16 

 
 
                                                      
 
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/operators39. 
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 

39 See Annex 5 on the costs and benefits. 

17 

 
 
                                                      
 
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 

18 

 
 
lead-acid  batteries  in  terms  of  the  volume  of  hazardous  substance  applied  is  the  most 
significant remaining one, and is currently being reviewed40.  

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.  

40 See for more information on the process: https://ec.europa.eu/environment/waste/elv/events_en.htm 

19 

 
 
                                                      
 
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, 

20 

 
 
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.41  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”42, 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 
steps43: 

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 

41

  Elliott,  T.;  Hudson,  J.;  Gillie,  H.;  Watson,  S.;  Lugal  L.;  Almasi,  A.  (2019):  Final  Report  on  the  Implementation  of 
Directive  2000/53/EC  on  End-of-Life  Vehicles.  For  the  period  2014–2017  and  Report  from  the  Commission  on  the 
implementation of Directive 2000/53/EC on end-of-life vehicles for the period 2014-2017, COM/2020/33 final 
42 Article 6(5) of ELV Directive 
43  The  overview  of  the  processes  involved  in  depollution  of  end-of-life  vehicles,  dismantling  components,  shredding  and 
post-shredding, although the latter element is not explicitly covered by the ELV Directive, are further detailed in Annex 5 of 
this report. 

21 

 
 
 
                                                      
 
(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 State44.  

Figure 5-1: Number of auto shredders per country  

60

57 

50 

45 

41 

28 

16 

13 

10 

s
r
e
d
d
e
r
h
s
o
t
u
a

f
o
r
e
b
m
u
N

50

40

30

20

10

0

8  8  7  6  6  5  5  5  5 

3  3  2  1  1  1  1  0  0  0  0 

T

I

R
F

K
U

E
D

S
E

E
B

L
P

E
S

G
B

L
N

I

F

T
A

K
S

K
D

U
H

T
P

O
R

E

I

L
E

Z
C

E
E

V
L

T
L

T
M

R
H

Y
C

I

U S
L

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.  

44 Only Malta and Luxembourg report to Eurostat not having a national shredder (source: Statement of Eurostat, 18 April 
2020). 

22 

 
 
 
                                                      
 
 
 
 
 
 
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 

the 
facilities/capacity  to  recycle,  so  that  the  lack  of  recycling  could  be  due  to  the 
higher price of recycled material (vs. virgin material); 

that  every  Member  State  has 

  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.  

Although  an  extensive  material  separation  and  recovery  is  carried  out  post-shredder,  a 
majority of the targeted stakeholders, including branch organisations, recyclers, national and 
regional administration, a trade union and environmental organisations, highlighted removal 
of  other  parts  before  shredding  is  important  to  promote  a  higher  rate  of  recycling  (53%  of 
stakeholders), only 23% responded this was not important. It particularly concerns batteries, 
oils and fluids, and electrical and electronic equipment45. This is because these materials are 
of  high  value  and  a  market  exists  that  supports  their  recycling.  It  also  has  to  be  taken  into 
account  that  ATFs  compete  with  non-registered  dismantlers  and  it  would  impose  an  extra 
burden  on  the  registered  dismantlers  if  they  were  obliged  to  meet  the  additional  costs  of 
dismantling.  

Overall, the insufficient recovery of materials pre-shredding is an example where maximising 
the objectives of the Circular Economy is being constrained by economic barriers and a lack 
of clear language in the ELV Directive. 

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.  

45 Two stakeholders (a Belgian NGO and a Belgian business association) also mentioned catalysts, non-ferrous metals, tyres, 
wiring, control units, electronics, foam and textiles. 

23 

 
 
                                                      
 
Figure 5-2: Reuse/recovery and reuse/recycling rate for end-of life vehicles, 2017 

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  target46.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).  

Figure  5-3:  Share  of  reuse,  compared  to  the  total  volume  of  reuse,  recovery  and 
disposal, 2017 

46 More detailed information is available in the Report from the Commission to the European Parliament, the Council, the 
European Economic and Social Committee and the Committee of the Regions on the implementation of Directive 
2000/53/EC on end-of-life vehicles for the period 2014-2017 (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52020DC0033 ) 

24 

 
 
 
 
                                                      
 
LI
HR
IE
UK
SK
IS, 2016
BG
RO, 2014
DE
PT
LU
LV
FI
NO, 2016
SI, 2014
FR
EE
IT, 2016
PL
MT, 2015
AT
CZ
SE
DK
ES
BE
EL
NL, 2016
HU
LT
CY, 2016

00%

10%

20%

30%

40%

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 report47 on 
these  targets  in  2007,  after  conducting  an  Impact  Assessment48,  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. 

47 COM(2007)5 final 
48 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=SEC%3A2007%3A0015%3AFIN  

25 

 
 
 
                                                      
 
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 Agency49 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 
recovery50.  Retreading  tyres  is  also  a  way  to  increase  resource  efficiency  of  tyres51.  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%.  

49 ADEME (2020): Rapport Annuel de l’Observatoire des Véhicules Hors d’Usage – Données 2018 
50 https://www.etrma.org/library/europe-91-of-all-end-of-life-tyres-collected-and-treated-in-2018/ [accessed on 25/11/2020] 
51 Ernst & Young et Associés. 2016 The socio-economic impact of truck tyre retreading in Europe The circular economy of 

tyres in danger 

26 

 
 
                                                      
 
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 

27 

 
 
 
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.52  

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 

Every three years Member States report on the implementation of the ELV Directive, based 
on Commission Decision 2001/753/EC53, and a questionnaire annexed to this Decision, and 
every  year  they  report  on  the  ELV  targets  on  reuse/recovery  and  reuse/recycling  targets  as 
required  in  the  Commission  Decision  2005/293/EC54,  derived  and  completed  by  the 
information  reported  in  the  tables  1  to  4  of  the  questionnaire  according  to  the  same 
legislation. All this information is published in Eurobase55. According to Article 9, paragraph 
1b  “The  data  reported  by  Member  States  in  accordance  with  paragraph  1a  shall  be 
accompanied by a quality check report”.  The quality check reports56 are  accompanying the 
Eurostat standard questionnaire57 for Member States on the quality and validity of the data for 
the annual reporting and are not agreed for publishing. These reports are not formalised in the 
Commission  Decision  and  therefore  these  are  containing  complementary  information 
regarding the peculiar ELVs processing in each country. As a result, the content of the quality 
reports  varies  across  the  Member  States.  There  is  often  no  information  available  on  the 
existence  of  capacity  in  specific  stages  in  ELV  treatment  capacities  (like  Post  Shredding 
Technology) or information on how Member States provide evidence that exported ELVs or 
parts  of  ELVs  are  effectively  recycled.  Reporting  on  reuse  of  components  of  ELVs  is 

52 https://idis2.com: Accessed: 13.01.2020 
53  2001/753/EC:  Commission  Decision  of  17  October  2001  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 (OJ L 282, 
26.10.2001, p. 77–80) 
54 2005/293/EC: Commission Decision of 1 April 2005 laying down detailed rules on the monitoring of the reuse/recovery 
and  reuse/recycling  targets  set  out  in  Directive  2000/53/EC  of  the  European Parliament  and  of  the  Council  on  end-of-life 
vehicles (OJ L 94, 13.4.2005, p. 30–33). 
55 All data transmitted by Member States in the questionnaires are regularly published in these datasets, including voluntary 
data: https://ec.europa.eu/eurostat/databrowser/bookmark/a1a45e99-9b12-4f21-ad93-fbd63ceb892b?lang=en  
and https://ec.europa.eu/eurostat/databrowser/bookmark/68a973c1-b122-4b2d-b54c-a411c328cb26?lang=en  
56 Article 1 (1) of the Commission Decision 2005/293/EC stipulates that “…Member States shall complete tables 1 to 4 set 
out in the Annex to this Decision together with an appropriate description of the data used.” 
57 See the link on the template of the questionnaire:  
 https://ec.europa.eu/eurostat/documents/342366/351811/Template+questionnaire+for+ELV  

28 

 
 
                                                      
 
hampered by non-existence of an explicit target on reuse and the different reporting options 
available to the Member States. 

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  year58. 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.  

58 See Article 1(3)(b) of Commission Decision 2005/295/EC 

29 

01 000 0002 000 0003 000 0004 000 0005 000 0006 000 0007 000 0008 000 0009 000 00010 000 000200620072008200920102011201220132014201520162017 
 
 
                                                      
 
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.  

Table 5-1: Results of the calculations for unknown whereabouts of vehicles for EU-28 

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  - 
registration 

leakage-proof  vehicle 

European  priority  measure:  establishing 
systems (UBA 2020)59 

  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. 201160), 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.  201761),  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 

59 
https://www.umweltbundesamt.de/sites/default/files/medien/1410/publikationen/sciopap_uba_elv_measures_to_combat_ille
gal_dismantling_2020_06_29.pdf 
60 Mehlhart, Georg; Merz, Cornelia; Akkermans, Lars; Jordal-Jorgensen, Jorgen; (Keine Angabe) (2011): European second-
hand car market analysis. Final Report. Hg. v. Öko-Institut e. V. Darmstadt, Germany. 
61  Mehlhart,  Georg;  Kosinska,  Izabela;  Baron,  Yifaat;  Hermann,  Andreas  (2017):  Assessment  of  the  implementation  of 
Directive  2000/53/EU  on  end-of-life  vehicles  (the  ELV  Directive)  with  emphasis  on  the  end  of  life  vehicles  of  unknown 
whereabouts.  Hg. 
Freiburg,  Germany. 
https://www.oeko.de/fileadmin/oekodoc/ELV_Report_European-Commission_Oeko-Institut.pdf 

European  Commission.  Öko-Institut 

e.  V.,  Germany. 

v. 

30 

 
 
 
 
                                                      
 
figure)62. 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 States63). 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.  

62  According  to  the  methodology  applied  in  the  study  ‘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) . 
63  See  more  information  p.  31  “EU  trade  of  used  vehicle”,  https://www.ecologic.eu/sites/files/publication/2020/2632-

01_ecologicisi_usedvehiclesstocktrade_march2020.pdf. 

31 

 
 
 
 
                                                      
 
Table 5-2: Reasons for ELVs of unknown whereabouts 

Reason for unknown 
whereabouts ELV 

Non-reported export of used 
vehicle to non-EU-countries 

Legal situation 

Environmental concern 

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. 

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. 

No direct environmental concern, 
even though the shipment of old 
vehicles can generate air 
pollution in the country of 
destination 

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.) 

Non-reported treatment in ATFs 
(While it would be possible no 
CoD is issued) 

Treatment in non-authorised 
treatment facilities, within or 
outside the Union. 

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 

Currently not illegal 

Illegal according to ELV Directive 

No concern, if the ATF operates 
according its permits 

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 

32 

 
 
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  Directive64.  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 followed65.  

64 See Article 3a(3) of Directive 1999/37: “In the event that the competent authority of a Member State receives notification 
that a vehicle has been treated as an end-of-life vehicle in accordance with Directive 2000/53/EC of the European 
Parliament and of the Council, the registration of that vehicle shall be cancelled permanently and information to that effect 
shall be added to the electronic register”. 
65 In principle, the Dutch licensing system is based on ownership. Around 660 000 vehicles are removed from the vehicle 
register every year. Vehicle owners must actively deregister their vehicles. If they fail to do so, they remain liable for the 
vehicle obligations. In this way the register is kept up to date. Deregistration can take place through an official export or 
destruction procedure. In case of export, the owner must report the vehicle as exported to the Netherlands Vehicle Authority 
(RDW) and have the documents stamped accordingly. In case of destruction, the owner must deliver the vehicle to an RDW-
accredited destruction firm. The destruction firm reports the vehicle as destroyed to the RDW vehicle register; this is done 
electronically. The owner then receives a warranty against liability. Temporary suspension (for use on private ground) is 
possible for up to 3 years. The average cost of such a transaction is € 121. The Tax Department of the Ministry of Finance 
checks compliance with the regulations concerning the non-use of suspended vehicles. (source: https://www.vehicle-
chain.eu/report.aspx) 

33 

 
 
                                                      
 
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 repaired66.   

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  waste67,  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  guidelines68  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 

of 

the 

Cf. 

102 

2020 

Article 

66 
economy 
(https://circulaire.legifrance.gouv.fr/jorf/article_jo/JORFARTI000041553867 ). More information is available in the Ademe 
report (2019) on the Global overview of incentive schemes aiming to bring ELVS (End-of-Life Vehicles) through authorised 
processing channels:  https://partage.ademe.fr/public/4741b6   
67 Unless for ELVs which have been, before export,  depolluted (a stripped vehicle) and do not contain neither liquids nor 
other  hazardous  components  e.g.  batteries  or  brake  fluids;  in  this  case,  the  ELVs  could  typically  be  classified  as  non-
hazardous wastes. Their export outside the EU is allowed, except to those 3rd countries which have notified the Commission 
under Commission Regulation 1418/2007 that they do not accept the import of such waste.  
68 Correspondents' Guidelines No 9 on shipment of waste vehicles: 
 https://ec.europa.eu/environment/waste/shipments/pdf/correspondents_guidelines9_en.pdf  

circular 

law 

on 

34 

 
 
                                                      
 
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  vehicles69  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 world70 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-

69 For more information see the Dutch report on the used vehicles exported to Africa: 
https://www.ilent.nl/documenten/rapporten/2020/10/26/rapport--used-vehicles-exported-to-africa  
70 See the full UNEP report here: https://www.unep.org/news-and-stories/press-release/new-un-report-details-environmental-
impacts-export-used-vehicles  

35 

 
 
                                                      
 
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 year71.  

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  Africa72.  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 standards73.  These 
findings  reconfirm  the  need  to  strengthen  the  control  of  the  vehicles,  since  the  EU  was  the 

71 See press release: https://www.unep.org/news-and-stories/press-release/new-un-report-details-environmental-impacts-
export-used-vehicles  
72 See full report here: https://www.ilent.nl/documenten/rapporten/2020/10/26/rapport--used-vehicles-exported-to-africa  
73 Directive 2014/45/EU of the European Parliament and of the Council of 3 April 2014 on periodic roadworthiness tests for 
motor vehicles and their trailers and repealing Directive 2009/40/EC (OJ L 127, 29.4.2014, p. 51–128) 

36 

 
 
                                                      
 
largest exporter with 54 % of the totally exported used vehicles worldwide between 2015 and 
201874.  

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 Regulation75 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 evaluation76. 

5.2.1.1. Benefits 

There  environmental,  social  and  economic  benefits  attributable  to  the  Directive  are 
presented below.  

74 https://wedocs.unep.org/bitstream/handle/20.500.11822/34175/UVE.pdf?sequence=1&isAllowed=y  
75 Regulation (EU) 2018/858 of 30 May 2018 on the approval and market surveillance of motor vehicles and their trailers, 
and  of  systems,  components  and  separate  technical  units  intended  for  such  vehicles,  amending  Regulations  (EC)  No 
715/2007 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32018R0858&from=EN) 
76https://ec.europa.eu/environment/waste/elv/pdf/ELV DIRECTIVE%20Evaluation-
Final%20report%20Aug2020%20(002).pdf  

repealing  Directive 

2007/46/EC 

(EC)  No 

595/2009 

and 

and 

37 

 
 
 
                                                      
 
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 report77 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  ATFs78  and  in  352  “automotive 
shredders”  across  the  EU79.  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 

77 Annual detailed enterprise statistics for industry (NACE Rev. 2, B-E), Code:sbs_na_ind_r2. Accessed 7/5/2020 
78 Elliott, T.; Hudson, J.; Gillie, H.; Watson, S.; Lugal L.; Almasi, A. (2019): Final Report on the Implementation of 
Directive 2000/53/EC on End-of-Life Vehicles. For the period 2014–2017. 
79 Mc Kenna (2014): European Auto Shredder List and Map. An interactive map of auto shredding plants in the 28 member 
states of the European Union plus Norway. 

38 

 
 
                                                      
 
materials sent for recycling or recovery80. 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.  

5.2.1.2. 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. 

Table 5-3: ELV Directive compliance costs for the automotive industry in the EU 

Costs  since  implementation  2000  –  2020  cumulative 
(million €) 

Running  costs  per  year 
(million €/a) 

IMDS (ELV Directive only) 

1,632 

Take-back networks 

Dismantling Info 

980 

58 

107 

49 

3 

80 Ademe 2015. Terra SA – Deloitte – BIOIS – Évaluation économique de la filière de traitement des véhicules hors d’usage 
– 2015 – Synthèse. 40 p. 

39 

 
 
 
                                                      
 
Consumer-Info 

Overall Cost 

26 

2,696 

1 

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 
year81. 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. 

81 For more explanation see Table C- Error! Main Document Only. on the overall costs as a result of the implementation of 
the ELV Directive (estimates)in the Annex 5 of this document and page 67 of the study supporting the evaluation of the 
ELV 
https://ec.europa.eu/environment/waste/elv/pdf/ELVD%20Evaluation-
Final%20report%20Aug2020%20(002).pdf  

Directive 

40 

 
 
                                                      
 
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 report82. 

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 

82See especially pages 62 to 72 of this study https://ec.europa.eu/environment/waste/elv/pdf/ELV 
DIRECTIVE%20Evaluation-Final%20report%20Aug2020%20(002).pdf  

41 

 
 
                                                      
 
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  M183,  light  commercial  vehicles 
classified  as  N184  and  three-wheel  motor  vehicles85  as  defined  in  Directive  92/61/EEC  but 
excludes  motor  tricycles86.  Other  vehicles,  such  as  buses  with  more  than  9  seats,  specialty 
vehicles  such  as  ambulances,  motorcycles,  commercial  vehicles  for  the  transport  of  goods 

83Category  M1:  Motor  vehicles  designed  and  constructed  primarily  for  the  carriage  of  persons  and  their  luggage  and 
comprising not more than eight seating positions in addition to the driver’s seating position. Vehicles belonging to category 
M 1 shall have no space for standing passengers. The number of seating positions may be restricted to one (i.e. the driver’s 
seating  position).  More  details  on  the  terms  used  in  this  definition  e.g.  ‘seating  position’  are  provided  in  Annex  II  of 
Directive 2007/46/EC of 5 September 2007 establishing a framework  for the approval of motor vehicles and their trailers, 
and of systems, components and separate technical units intended for such vehicles, last amended by 4.4.2019.  
84 Category N1: Motor vehicles designed and constructed primarily for the carriage of goods and having a maximum mass 
not exceeding 3,5 tonnes. More details on the terms used in this definition e.g. ‘mass’ are provided in Annex II of Directive 
2007/46/EC  of  5  September  2007  establishing  a  framework  for  the  approval  of  motor  vehicles  and  their  trailers,  and  of 
systems, components and separate technical units intended for such vehicles, last amended by 4.4.2019. 
85  The terms used in the ELV Directive are not as specific as the Regulation (EU) No 168/2013 of 15 January 2013, last 
amended by 4.4.2019 on the approval and market surveillance of two- or three-wheel vehicles and quadricycles repealing the 
mentioned  Directive  92/61/EEC.  For  details  on  the  vehicle  classification,  please  refer  to  Annex  II,  General  definitions, 
criteria for vehicle categorisation, vehicle types and types of bodywork of Regulation (EU) No 168/2013. 
86 See footnote before. 

42 

 
 
                                                      
 
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 Directive87. 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.  

Table 5-4: Share of vehicle type (by numbers) in EU 28 for 2016 

Vehicle type 

Passenger cars 

Trucks 

Motorcycles 

Trailers and semi-trailers 

Road tractors 

Special vehicles 

Motor  coaches,  buses  and  trolley 
buses 

Number 

258 003 552 

34 413 937 

22 018 223 

15 898 235 

3 809 333 

3 256 933 

902 522 

Percentage 

76.3% 

10.2% 

6.5% 

4.7% 

1.1% 

1.0% 

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 

87 Note: Eurostat definition of trucks does not distinguish trucks below the maximum weight of 3.5 tonnes and 
above. 

43 

 
 
                                                      
 
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 long lifespan of these vehicles. The 
European  Automobile  Manufacturers  Association  (ACEA)  also  noted  that  manufacturers  of 
heavy-duty  vehicles  already  phase  out  heavy  metals  on  a  voluntary  basis  whenever  that  is 
technically  and  economically  possible  and  provide  dismantling  information.  All  vehicle 
manufacturers  operating  in  the  EU  must  fulfil  the  requirements  of  the  REACH  which  sets 
restriction, or even prohibition, of potentially dangerous materials and substances applies to 
all products placed on the European market, including trucks and buses. In addition, ACEA 
pointed  out  notably  that  the  reuse  and  recycling  of  trucks  and  buses  is  a  highly  profitable 
business driven by market forces, since average heavy duty vehicle consists 80% of steel and 
iron,  resulting  in  high  recycling  rates88.    The  processes  for  depollution  and  dismantling  are 
also  different  from  those  for  passenger  cars,  as  they  require  different  types  of  treatment, 
additional  storage  and  physical  resources89.  Therefore,  it  might  be  difficult  to  develop 
common  requirements  for  the  dismantling,  decontamination  and  further  treatment  of 
industrial vehicles and passenger cars. 

Stakeholders  from  the  motorcycle  manufacturing  industry  also  highlighted  the  differences 
between  their  sector  and  passenger  cars.  They  emphasised  that  the  manufacturing  of 
motorcycles is composed of a higher number of SMEs than for cars, that motorcycles have a 
relatively longer life, and that there was no strong evidence that the current situation created 
negative environmental impacts in respect of the treatment of end-of-life motorcycles.   

These  stakeholders  indicated  that  the  arguments  presented  above  represent  the  reasons  why 
trucks,  buses  and  motorcycles  have  not  been  originally  covered  within  the  scope  of  ELV 
Directive.  

A  survey  on  the  types  of  non-car  vehicles  received  by  ATFs  in  France  showed  that  most 
ATFs do not  frequently receive end-of-life vehicles other than passenger cars. For instance, 
70-90% of ATFs in France “never” or “rarely” receive motorcycles, light two-wheel powered 
vehicles,  quads  and  cars  without  licence90.  This  seems  to  support  the  claims  that  these 
vehicles require specific dismantling and treatment processes.  

The relevance of leaving 45 millions of vehicles outside the scope the ELV Directive seems 
questionable,  as  these  vehicles  are  currently  not  subject  to  any  specific  EU-wide  rules 
regarding  the  treatment  of  the  waste  they  generate,  which  also  causes  loss  in  circular 
economy  terms.The  specific  features  of  these  vehicles  need  however  to  be  fully  taken  in 
consideration in future reflexion on the extension of the scope of the ELV Directive.   

5.3.2.  Increased use of electric, electronic and other components in vehicles 

88https://www.acea.be/uploads/publications/ACEA_Position_Paper-End-of-Life_Vehicles_Directive_Trucks_Buses.pdf  
89 The Spanish national association for recycling of industrial vehicles (Anervi, 2011). 
90ADEME (2018). Presentation of results of the ADEME’s survey about the treatment by ATF of other end-of-life vehicles 
than cars and light industrial vehicles. 

44 

 
 
                                                      
 
Vehicles  are  increasingly  equipped  with  electronic  components,  which  contain  valuable 
materials,  such  as  gold,  silver,  palladium,  tantalum  and  other  rare  earth  materials.  The 
unsound  management  of  these  materials  during  the  dismantling  process  creates  negative 
environmental consequences and represent a loss of valuable resources. There is no specific 
requirement in the ELV Directive to separate and recover these materials. There are also no 
specific  recovery/recycling  targets  for  these  materials.  The  conventional  treatment  methods 
(shredding  after  depollution)  for  ELV  are  not  appropriate  to  ensure  the  separation  and 
recovery  of  such  materials91.  Ensuring  a  proper  recovery  of  these  materials  brings  with  it 
additional costs for dismantlers, but their sale should also generate additional revenues. Many 
electric  and  electronic  components  have  a  long  life-span  and  can  be  sold  as  spare  parts  if 
separated.  On  the  other  hand,  their  durability  is  expected  to  be  longer  compared  to  the 
mechanical  components. A business  association  noted that the increased  use of  electric and 
electronic  components  will  make  the  95%  recovery  target  impossible  to  achieve,  as  these 
materials cannot be technically or economically recycled under current conditions. 

There is no legal basis either in the ELV Directive requiring the provision of information by 
the  producers  on  the  localisation  of  such  electric  or  electronic  components  and  on  how  to 
separate  and  recover  them  during  the  dismantling  process.  As  a  solution,  this  may  be 
addressed  through  the  SCIP  database92  mandated  to  European  Chemicals  Agency  under  the 
Waste Framework Directive. However, it is unclear if this will be sufficient for dismantlers to 
dispose of all the required information to perform their dismantling.  

The  provisions  of  the  ELV  Directive  are  not  suited  to  ensure  a  high  level  of  recovery  and 
recycling  of  valuable  materials  contained  in  the  electric  and  electronic  components 
increasingly used in recent vehicles.  

5.3.3.  Increased  use  of  lightweight  materials  in  vehicles  like  plastics,  carbon-fibres, 

fibre-reinforced (plastics) materials and others 

It is estimated that the automotive sector generates around 5% of all plastic waste in the EU. 
The  use  of  plastics  in  cars  has  been  increasing  in  the  last  decades,  together  with  other 
lightweight  materials,  primarily  at  the  expense  of  metals,  helping  curb  the  increase  in  the 
mass of vehicles and their associated emissions of greenhouse gases. The share of plastics is 
estimated to reach 15-20% of the weight of cars built today, so in the range of 100 to 200kg 
per car (depending on the models). This is not only the amount of plastics used in cars that is 
on  the  rise  but  also  the  plastics  composition  that  is  different  due  to  a  broader  range  of 
applications  (e.g.  the  increase  of  electronics  in  cars  requires  plastic  housing  for  these 
electronics, the use of plastic in coachwork parts).   
Table 5-5: Average composition of an ELV in 2015 in France according to ADEME93  

Polypropylene (PP) - other parts  

4.4%  

91 Groke, M.; Kaerger, W.; Sander, K.; Bergamos, M. (2017): Optimierung der Separation von Bauteilen und Materialien aus 
Altfahrzeugen zur Rückgewinnung kritischer Metalle (ORKAM). In: Umweltbundesamt, UBA Texte (02/2017). 
92 SCIP is the database for information on Substances of Concern In articles as such or in complex objects (Products), see 
https://echa.europa.eu/scip  
93 Monier, V.; Salès, K.; Lucet, L.; Benhallam, R. (2017): Annual Report End-of life vehicles 2015. Annual Report of the 

End-of-life vehicle sector observatory – 2015. France. 

45 

 
 
                                                      
 
ABS, PVC, PC, PMMA, PS, etc.  

Polyurethane foam  

Textiles, other  

Other rubber compounds  

Polypropylene (PP) - bumpers  

Polyamides (PA)  

Polyethylene (PE) - fuel tanks  

Polyethylene (PE) - other parts  

Total  

Tyres  

Lead starter battery  

Wiring harnesses  

Paint  

Total  

Ferrous metals  

Non-ferrous metals (excluding wiring 

harnesses)  

Glass  

Spent oil and filters  

Catalytic converters  

Cooling or brake fluids  

Air-conditioning fluids  

Total  

2.2%  

2.0%  

1.7%  

1.1%  

1.1%  

1.0%  

0.8%  

0.5%  

14.8% 

3.4%  

1.4%  

1.0%  

0.8%  

6.6% 

70.0%  

4.0%  

3.0%  

0.7%  

0.5%  

0.4%  

0.1%  

78.7% 

In  practice,  when  compared  with  other  materials  present  in  ELVs,  plastic  components  are 
those which have the lowest recycling rates and the highest rates when it comes to materials 
sent  for  disposal  (cf.  Section  5.1  on  material  recovery  in  the  effectiveness  part).  There  are 
therefore  considerable  quantities  of  plastic  waste  from  ELVs  sent  for  incineration  or 
landfilling each year. If nothing changes, these quantities will increase further, along with the 
trends to use more plastic materials in cars observed over the last decade.  

The perspective that the automotive sector starts to use other new types of components, like 
fiber  reinforced  plastics,  also  poses  a  challenge  in  terms  of  waste  management,  as  they  are 
currently particularly difficult to recycle.  

Many stakeholders indicate that the increased use of these lightweight materials like plastics 
will  affect  waste  management  costs.  It  was  also  recognized  by  the  ATF  that  some  new 
materials  require  more  complex  technologies  and  higher  energy  demand  to  recycle  which 
would  consequently  result  in  higher  waste  management  costs  and  GHG  emissions.  Some 
stakeholders  indicated  that  the  situation  is  not  the  same  for  other  lightweight  materials 
(aluminium for example).  

There are no specific requirements in the ELV Directive or in the “type approval” Directive 
2005/64/EC  designed  to  facilitate  the  proper  treatment  of  plastics  and  other  lightweight 
materials such as carbon fibre and fibre reinforced plastics derived from ELVs. There are for 
example  no  provisions  requiring  that  information  is  made  available  on  these  materials,  no 

46 

 
 
 
 
 
obligation for ATF to separate them before shredding and no specific recovery or recycling 
targets.  

Overall, it seems clear that the ELV Directive does not contain sufficient provisions to deal 
adequately with the challenges posed by the increased use of lightweight materials in cars.  

5.3.4.  Changes  in  the  types  of  vehicles  put  on  the  EU  market:  increase  of  electric  or 

hybrid vehicles and of SUV 

The  volume  of  electric  and  hybrid  vehicles  reaching  the  end  of  their  life  and  sent  for 
dismantling is currently still low compared to the vehicles with internal combustion engines 
in  the  EU.  Therefore,  there  is  limited  to  no  experience  in  the  dismantling  sector  on  how  to 
deal with such vehicles, as well as on its overall impact on their business model. In view of an 
average life time of 15 years, this is likely to continue to be the case in the near future.  

Nevertheless,  this  situation  is  expected  to  change  considerably  in  the  next  decade,  with  the 
foreseeable  boom  in  the  sale  of  electric  and  hybrid  vehicles  on  the  EU  market.  A  strong 
increase in the electrification of vehicles is expected to take place between 2020 and 2030. In 
2030, approximately a quarter of all passenger cars sold in the EU are predicted to be battery 
powered. Plug-In Hybrids and Hybrids together are expected to account for another quarter of 
sales  while  the  rest  of  the  vehicles  are  expected  to  be  based  on  the  Internal  Combustion 
Engines.  

The expected increase in uptake of all electric vehicle (EV) types is illustrated in the Figure 
5-7  below.  It  illustrates  the  projected  development  of  passenger  car  sales  in  the  EU  until 
2030, which also correlates with the EU long-term climate neutrality targets, but it should be 
noted  that  it  does  not  take  into  account  the  possible  impact  of  the  COVID-19  pandemic, 
which is not yet possible to factor in.   

Figure  5-7:  Development  of  passenger  car  sales  in  the  EU  (BEV=Battery  Electric 
Vehicles, ICE=Internal Combustion Engine94) 

on 

94 The  data  in the figure up to 2017 are  statistics (Eurostat, ACEA) and the projections of the future sales are 
based 
2017: 
https://www.iea.org/reports/energy-technology-perspectives-2017) and statistical trends in the EU’s share of 
total  global  sales  (Boston  Consulting  Group  2017:  https://www.bcg.com/en-be/press/2november2017-
electrified-vehicles-take-half-of-global-auto-market). 

Energy  Agency’s 

International 

scenario 

(IEA) 

(IEA 

2DS 

the 

47 

 
 
 
 
 
 
                                                      
 
20.000.000

15.000.000

10.000.000

5.000.000

0

BEV

Plug-In

Hybrid

ICE

9
0
0
2

0
1
0
2

1
1
0
2

2
1
0
2

3
1
0
2

4
1
0
2

5
1
0
2

6
1
0
2

7
1
0
2

8
1
0
2

9
1
0
2

0
2
0
2

1
2
0
2

2
2
0
2

3
2
0
2

4
2
0
2

5
2
0
2

6
2
0
2

7
2
0
2

8
2
0
2

9
2
0
2

0
3
0
2

BEV: Battery Electric Vehicle (pure EV);  
Plug-In: Plug-In electric vehicle (combination of ICE and electric motor, which is the main source of power); 
Hybrid:  hybrid  electric  vehicle  (combination  of  electric  motor  ICE,  which  is  the  main  source  of  power) 
engines  powered  by  gasoline,  diesel,  biofuels  or  natural  gas  
ICE: 
Source: Model for passenger cars sales, Oeko-Institut e.V 

combustion 

internal 

The massive arrival from electric and hybrid vehicles will lead to considerable changes in the 
management of ELVs at the 2030-2035 horizon. The ELV Directive was not designed to deal 
with this evolution. More than 50% of the consulted stakeholders noted that the increased use 
of EV will increase waste management costs for ELVs. Dismantling may temporarily become 
less profitable as costs for storage, training, equipment, safety (e.g. against fires from Li-ion 
batteries)  and  transportation  may  increase.  Several  of  the  consulted  stakeholders,  including 
companies, business associations and academics suggested it would require new technology 
and processes for ATFs.  Dismantling of high voltage traction batteries requires specific staff 
training  and  equipment,  and  is  time  consuming.  This  effort  might  be  compensated  if  the 
traction  battery  is  sold  for  ‘second  use’  but  it  might  also  be  possible  that  additional  costs 
occur for long distance transport to qualified repurposing or recycling facilities, which should 
be addressed in the separate future EU legislation on batteries.  As to other parts and materials 
contained in electric and hybrid vehicles, it is unclear if the ELV Directive in its current form 
is  sufficient  to  ensure  that  they  are  properly  recovered  and  recycled.  The  dismantling  and 
recycling sectors are also expected to derive higher revenues from the recovery and recycling 
of  valuable  raw  materials95  (copper,  nickel,  cobalt,  palladium,  platinum,  ruthenium, 
lanthanum etc.) used in EVs batteries, electronic devices and other components contained in 
low-emissions  vehicles.  In  addition,  increased  flow  of  secondary  (critical)  raw  materials 
could  “improve  supply  security  for  the  EU”96.  Also,  increased  resource  efficiency  and 
business opportunities can derive from remanufacturing of new components in vehicles97, e.g. 

95  EC,  2020.  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European 
Economic  and  Social  Committee  and  the  Committee  of  the  Regions  -  Critical  Raw  materials  Resilience: 
Charting a path towards greater security and sustainability. COM(2020) 474 final. 
96 EC, 2020. Critical Raw Materials for strategic technologies and sectors in the EU  - A foresight study. Joint 
Research Centre (JRC) of the European Commission. https://doi.org/10.2873/865242 
97  Matsumoto,  M.,  2020.  Product  remanufacturing  in  Japan:  trends  and  challenges,  in:  27th  CIRP  Life  Cycle 
Engineering Conference (LCE2020). Grenoble (held online) 

48 

 
 
 
 
                                                      
 
electric  motors.  In  a  life-cycle  perspective,  the  transition  towards  low-emissions  vehicles 
entails a shift of environmental impacts from the use phase to the manufacturing phase98.  

The proposal  by the Commission  for a new Regulation  on Batteries is  expected to  improve 
circularity in the design of batteries of EVs. The articulation with the ELV Directive will be 
important.  

In  addition  to  the  batteries,  ELVs  from  EVs  contain  very  costly  components  like  electric 
motors,  which  may  generate  income  for  the  dismantlers.  However,  dismantlers  are  not 
currently experienced with such components and the markets for them is not yet developed. 

In  addition  to  the  shift  to  electric  vehicles,  another  major  development  in  the  automotive 
sector has been the rise in sales of Sport Utility Vehicles (SUVs).  Around 40% of annual car 
sales today are SUVs, compared with less than 20% a decade ago99. In addition to the fact that 
SUVs produce CO2 emissions which are higher than conventional cars, they are also heavier 
and  larger  than  conventional  cars.  These  trends  mean  that  the  weight  of  ELVs  and  related 
waste generated by the automotive sector are expected to increase correspondingly.  

Overall,  the  emergence  of  new  generation  of  vehicles  will  require  adaptations  among 
different  economic  operators,  e.g.  ATFs,  dismantlers,  shredders  to  recyclers,  insurance 
companies.  These  factors  once  again  confirm  the  important  role  of  the  ELV  Directive  to 
provide a solid legal framework which would be able to accommodate the dynamics related 
to the automotive sector. 

5.3.5.  Online sales of spare parts from ELVs  

During  the  consultation,  a  number  of  stakeholders  pointed  to  the  challenges  posed  by  the 
online  sales  of  spare  parts.  They  stressed  this  happens  in  the  absence  of  traceability  on  the 
origin of the parts. Notably, the vehicle identification number (VIN) is not always provided at 
the  point  of  online  sale.  This  is  also  the  case  for  the  registration  number  of  the  dismantler 
showing that the parts were dismantled in an authorised facility. This makes it easier for non-
ATFs  to  benefit  from  selling  used  parts  without  complying  with  the  minimum  standards 
required for ATFs.  

Some stakeholders stated that in the USA one cannot sell spare parts (online or offline) for a 
vehicle without being registered as a commercial company. In some countries, the authorities 
have also set up partnership with online sales websites to ensure that used spare parts are only 
put on the market if they come from a licensed ATF100.  

98  Ellingsen,  L.A.-W.,  Hung,  C.R.,  2018.  Research  for TRAN  Committee  -  Battery-powered  electric vehicles: 
market development and lifecycle emissions. Study requested by the European Parliament’s Committee on 
Transport and Tourism. 

Agency: 

99  More  observations  on  the  changes  in  the  car  market  related  to  SUVs  can  be  found  in  the  website  of  the  International 
Energy 
https://www.iea.org/commentaries/growing-preference-for-suvs-challenges-emissions-reductions-in-
passenger-car-market   
100 See for example the partnership between the UK authorities and eBay in this regard: 
https://www.gov.uk/government/news/environment-agency-joins-forces-with-ebay-to-stop-illegal-vehicle-breakers 

49 

 
 
 
                                                      
 
5.3.6.  Role of insurance companies in the end-of-life stage of vehicles 

Insurance companies own very large volumes of cars which have become ELVs (as vehicles 
damaged beyond repair in accidents typically become ELVs owned by insurance companies). 
They are also a major actor when it comes to car repairing.  These companies are defined in 
the  ELV  Directive  as  one  the  relevant  “economic  operators”,  which  should  notably  be 
involved  in  setting  up  systems  for  the  collection,  treatment  and  recovery  of  end-of  life 
vehicles. In practice, it seems that these provisions have not been leading to any obligations 
for insurance companies to contribute actively to the objectives of the ELV Directive.  

There  are  a  few  examples  of  insurance  companies  which  voluntarily  opted  for  a  proactive 
policy for a sustainable management of ELVs. This includes for example the establishment of 
partnerships  between  an  insurance  company  in  France  and  a  network  of  qualified  ATF  and 
repair companies, so as to ensure that damaged cars or ELVs sold by insurance companies get 
dismantled with a view to maximising the reuse of their spare parts101. These seem to remain 
marginal  examples,  while  the  most  common  practice  is  for  insurance  companies  to  sell 
damaged  cars  or  ELVs  in  auction  to  the  best  prices,  without  paying  attention  to  their  final 
destination. This can be problematic for the traceability of such cars and does not encourage a 
high  quality  treatment  of  the  ELVs.  As  a  result,  a  number  of  stakeholders  pleaded  for 
insurance  companies  to  be  more  involved  in  the  implementation  of  the  Directive.  Some 
stakeholders also suggested to link insurance payments to CoD so that only the presentation 
of a CoD will allow the insurance payment to cease, as a way to better ensure that CoD are 
issued when a vehicle is not used any longer.  

5.4.  Coherence 

This  section looks at  the overall coherence of the ELV Directive,  assessing how provisions 
interact  internally  across  the  Directive  and  also  in  relation  to  the  other  EU  legislation  and 
policies. 

5.4.1. To what extent is the ELV Directive internally coherent?  

The  ELV  Directive  is  considered  as  internally  coherent  (i.e.  it  does  not  contradict  itself). 
During  the  consultation  process,  it  was  pointed  out  that  Article  4(1)(a)102on  prevention 
encourages Member States to limit hazardous  substances, in  addition to those prohibited by 
the  Directive.  However,  it  was  indicated  that  individual  prohibition  measures  taken  at 
national  level  might  hamper  the  functioning  of  the  internal  market  but  there  is  no  evidence 
that such measures were taken.  In any event, this does not affect the internal coherence of the 
ELV Directive. 

101 See https://www.maif.fr/particuliers/auto-moto/recycler-auto/recycler-voiture.html 
102 Article 4 (1)  - Prevention 
“1. In order to promote the prevention of waste Member States shall encourage, in particular: 
(a) vehicle manufacturers, in liaison with material and equipment manufacturers, 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; (…)”. 

50 

 
 
                                                      
 
5.4.2.  To  what  extent  is  the  ELV  Directive  coherent  with  other  EU  policy  instruments 
and the overall EU and international policy goals? 

The coherence of the ELV Directive is evaluated first with regard to EU overarching policies 
on  circular  economy  and  climate  change,  and  then  with  regard  to  the  EU  waste  legislation, 
and the Basel Convention.   

5.4.2.1.Coherence with the EU approach to Circular Economy  

The circular economy model aims to maximise the reduction of waste and reuse of materials. 
The  European  Commission  has  recently  adopted  a  new  Circular  Economy  Action  Plan103  - 
one  of  the  main  blocks  of  the  European  Green  Deal104.  The  new  Action  Plan  announces 
initiatives  along  the  entire  life  cycle  of  products,  targeting  for  example  their  design  and 
manufacturing,  promoting  circular  economy  processes,  fostering  sustainable  consumption, 
promoting repair, re-use and remanufacturing and aiming to reduce waste and ensure that the 
resources used are kept in the EU economy for as long as possible.  

The  ELV  Directive  contains  general  provisions  which  contributes  to  the  development  of  a 
more circular economy, especially the measures on the: 

  Use of recycled materials in new vehicles; 
  Recovery, recycling and re-use targets; 
  Regulation of recovery and sale of parts removed from ELVs. 

However,  the  evaluation  results  show  that  the  ELV  Directive  needs  better  consistency  with 
the objectives of the European Green Deal and the Circular Economy Action Plan. The ELV 
Directive  does  not  sufficiently  address  key  areas,  notably  waste  prevention,  including  eco-
design  of  cars  to  facilitate  re-use,  repair,  remanufacturing  and  recycling.  The  potential  to 
increase recycling and re-use and ensure a level playing field for high quality recycling is not 
used.  The  same  is  true  for  the  promotion  of  concrete  measures  to  facilitate  re-
use/remanufacturing of parts and high quality recycling of ELV across the EU. These issues 
are  addressed  in  previous  sections  of  this  evaluation,  which  reflect  the  fact  that  the  ELV 
Directive  often  contains  provisions  which  are  too  general  to  have  any  real  impact  (for 
example on the design and production of new vehicles) or which are not adapted to deal with 
the challenges posed by the evolution of the market of current vehicles (for example general 
targets for re-use/recycling and re-use/recovery by weight, which does not lead to the optimal 
treatment of many components and materials, such as glass or plastics). 

  Use of recycled materials (e.g. plastics) in new vehicles 

The  uptake  of  recycled  materials  is  identified  in  the  Circular  Economy  Action  Plan  as  a 
priority for the building of circular economy models across the EU. This is also a key pillar of 
the  Plastics  Strategy  adopted  by  the  European  Commission  in  2018.  While  doing  so,  the 

103 To access the document: https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1583933814386&uri=COM:2020:98:FIN 
104 To access the document: https://ec.europa.eu/info/node/123797 

51 

 
 
                                                      
 
Chemicals  Strategy  for  Sustainability105  is  emphasising  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.” The automotive sector is identified as particularly important in 
that  respect,  notably  for  plastics.  As  indicated  in  section  5.3.3,  the  use  of  plastics  in  new 
vehicles  has  increased  and  will  further  increase  and,  therefore,  the  automotive  industry 
represents a considerable potential for the use of recycled plastics.  

According  to  Article  4(1)(c)  of  the  ELV  Directive,  “Member  States  shall  encourage  […] 
vehicle manufacturers, in liaison with material and equipment manufacturers, to integrate an 
increasing quantity of recycled material in vehicles and other products, in order to develop 
the markets for recycled materials”. 

Hence, the ELV Directive sets only a general obligation for the Member States to encourage 
integrating of increasing quantity of recycled material. These provisions have not been made 
more  specific  or  operational  and  there  are  no  specific  legal  provisions  for  a  mandatory 
minimum  content of recycled materials  in  new vehicles.  Several manufacturers have taken 
voluntary actions to increase the use of secondary materials in the production of new vehicles 
(see Table 5-6 below). For example, Volkswagen reported in 2009 that 40% of vehicle weight 
of  its  Golf  model  was  from  recycled  material.  Other  manufacturers  also  reported  that  they 
achieved,  or  aim  to  achieve,  an  increase  in  the  share  of  recycled  content  in  their  vehicles 
(total or plastic).  

Table 5-6: Manufacturer data on recycled content in vehicles 

Manufacturer 
and model 

Type 
recycled 
content 

of 

Year  Share of recycled material 

Volkswagen, 
Golf 

total recyclate 

2009  Secondary raw materials ca. 40% of vehicle weight (501 
kg metal recyclates, 15 kg plastics recyclates, 9 kg glass 
and 2 kg operating fluids)106 

Daimler, 
general 

total recyclate 

is 

to  be 

2015  The specifications for Daimler vehicles stipulate that the 
raw  materials, 
proportion  of  so-called  secondary 
including  recycled  materials, 
increased 
continuously.  The  planning  therefore  provides  for  an 
annual  review  until  2020.  As  an  interim  target,  25 
percent  more  renewable  raw  materials  and  recyclates 
should  be  used  by  2015  compared  with  the  base  year 
2010.  The  target  was  even  exceeded  with  a  39% 
increase in use of recyclates and 28% in renewable raw 
materials  in  comparison  to  2010  by  2015  (exceeded 
target of 25% increase).107 

105 COM(2020) 667 final 
106 https://www.recyclingmagazin.de/2009/02/20/ueber-500-kg-rezyklate-im-neuen-golf/; accessed: 23 March 2020 
107https://www.globalcompact.de/de/themen/Good-Practices/Umweltschutz/Best-Practice-Kreislaufwirtschaft-bei-
Daimler.php; accessed: 23 March 2020 

52 

 
 
                                                      
 
Manufacturer 
and model 

Type 
recycled 
content 

of 

Year  Share of recycled material 

Daimler  

plastic recyclate 

? 

Mercedes S 
Class,  

Daimler  

plastic recyclate 

? 

Mercedes B 
Class  

Daimler 

plastic recyclate 

? 

Mercedes A 
Class 

Total  weight  of  components  made  of  recycled  plastics: 
49.7  kgs  All  black  plastic  parts  of  the  Mercedes  S-
Class's outer skin are made of recycled materials.108 

13%  increase  in  recycled  material  compared  with  the 
predecessor model.  

Typical  areas  of  application  are  wheel  arch  linings, 
cable ducts and underbody panelling.109 

118 components plus small parts with a total weight of 
58.3 kilograms from resource-saving materials.110 

Opel Adam 

? 

2015  170 components with recyclates;  

BMW 

7er 

BMW 

i3  

Volvo 

Renault 

Espace 

plastic recyclate 

? 

15-20% by weight of a vehicle's total plastic volume111 

plastic recyclate 

? 

ca. 25% of the thermoplastics used in the production of 
the car consist of recycled materials.  

plastic recyclate 

? 

at  least  25%  recycled  plastics  in  every  new  car  from 
2025 onwards112  

plastic recyclate 

? 

50 kg recycled plastic content.113 

As  it  is  shown  in  the  table,  the  use  of  recycled  materials,  in  particular  plastic,  is  steadily 
increasing. This shows that the uptake of such recycled materials is a reality already for many 
car  manufacturers.  There  is  however  no  clear  overview  on  the  overall  uptake  of  recycled 
plastics by the car manufacturing industry and the practice in that respect depends largely on 
the individual strategies of each company.  

Car manufacturers have indicated that the incorporation of larger volumes of recycled plastics 
in new vehicles depends on the necessity to guarantee a stable supply for suitable quality and 

108https://www.tagesspiegel.de/mobil/recycling-bei-der-automobilproduktion-wiederverwendung-spart-nicht-nur-
geld/12044148.html; accessed: 23 March 2020 
109 https://www.daimler.com/nachhaltigkeit/umweltzertifikate/b-klasse.html; accessed: 23 March 2020 
110 Ibid. 
111 https://www.bmw.de/de/topics/service-zubehoer/bmw-service/recycling.html; accessed: 23 March 2020 
112 https://group.volvocars.com/news/sustainability/2018/volvo-aims-for-25-per-cent-recycled-plastics-in-cars-from-2025  
113https://group.renault.com/en/news-on-air/news/renault-actively-developing-circular-economy-throughout-vehicles-life-
cycle/; accessed: 23 March 2020 

53 

 
 
                                                      
 
volume of such plastic. Another determining factor is the difference in costs between the cost 
of production of virgin plastics and the production of recycled plastics.  

The Circular Plastics Alliance114 was launched in December 2018 to “take action to boost the 
EU market for recycled plastics up to 10 million tonnes by 2025”. A working group has been 
created to work on this objective for the automotive industry and the outcome of their work 
will be relevant to assess the potential for a higher uptake in recycled plastics in new cars.  

While  many  different  technological  and  economic  factors  determine  the  use  of  recycled 
plastics in new cars, it can be concluded that the current provisions of the ELV Directive in 
this  regard  have  not  been  sufficient  specific  to  prompt  a  general  higher  uptake  of  recycled 
plastics, and thereby consistency with the objectives of the EU policy on circular economy.  

5.4.2.2.Coherence with the EU Climate change policy 

The ELV  Directive also needs to  be  assessed with  regard to  the EU climate change policy. 
The European Green Deal115 has reconfirmed the EU commitment to fight climate change and 
to  become  the  world’s  first  climate-neutral  continent  by  2050.  For  this  purpose,  the 
Commission  has  adopted  the  Communication  on  stepping  up  Europe’s  2030  climate 
ambition116  and  proposed  to  address  the  climate  crisis  by  raising  the  EU's  ambition  on 
reducing greenhouse gas emissions to at least 55% below 1990 levels by 2030.  

The climate neutrality objective is of key importance for the transport sector which is one of 
the  largest  contributors  to  greenhouse  gas  emissions.  Globally,  the  transport  sector  is 
responsible for nearly a quarter of total energy-related carbon dioxide (CO2) emissions117. In 
2017, 27 % of total EU-28 greenhouse gas emissions in 2017 came from the transport sector, 
including aviation and maritime emissions. Road transport was responsible for almost 72 % 
of  total  greenhouse  gas  emissions  from  the  transport  sector,  where  44%  of  these  emissions 
were  from  passenger  cars,  9%  from  light  commercial  vehicles  and  19  %  from  heavy-duty 
vehicles.118 Passenger cars are responsible for around 12.0% of total EU emissions of carbon 
dioxide (CO2), i.e. the main greenhouse gas119.  

To  address  the  problem  and  to  reduce  emissions,  since  2009,  the  EU  legislation  has  set 
mandatory tailpipe emission targets for new cars and, since 2011, for new vans.  On 17 April 
2019,  the  European  Parliament  and  the  Council  adopted  Regulation  (EU)  2019/631  setting 
CO2  emission  performance  standards  for  new  passenger  cars  and  for  new  vans  in  the  EU. 
This Regulation started applying on 1 January 2020, setting reduction targets of 15% for cars 
and vans to be achieved from 2025, and of 37.5% for cars and 31% for vans to be achieved 
from 2030, compared to 2021. For road transport, CO2 and vehicle standards have proven to 
be an effective policy tool, while stringent CO2 emissions performance standards ensure the 

114 https://ec.europa.eu/growth/industry/policy/circular-plastics-alliance_en 
115

 COM (2019)640 final.   

116 COM(2020)562 final  
117 https://www.ipcc.ch/site/assets/uploads/2018/02/ipcc_wg3_ar5_chapter8.pdf  
118https://www.eea.europa.eu/data-and-maps/indicators/transport-emissions-of-greenhouse-gases/transport-emissions-of-

greenhouse-gases-12  

119 https://ec.europa.eu/clima/policies/transport/vehicles/regulation_en  

54 

 
 
                                                      
 
supply  of  modern  and  innovative  clean  vehicles.  However,  as  highlighted  in  the  European 
Green Deal, to contribute to the overall climate neutrality objective for 2050, emissions of the 
transport sector need to be reduced by 90% by 2050.  The CO2 standards are currently under 
revision, the Commission’s new proposal is expected to be delivered in June 2021, with the 
aim to align standards with the new 2030 and 2050 ambitions. 

In  this  process,  electrification  is  seen  as  a  key  avenue  for  decarbonisation  during  the  use 
phase, meaning that conventional cars will gradually be displaced by zero tailpipe emissions 
vehicles. This trend is further exacerbated by the EU policy designed to reduce air pollutant 
emissions from vehicles.  Successive "Euro" standards were adopted in that respect for light-
duty  vehicles  (cars  and  vans)  and  for  heavy-duty  vehicles  (trucks,  buses  and  coaches).  The 
latest standards are Euro 6 for light-duty, and Euro VI for heavy-duty. In addition, the need to 
reduce  the  emissions  of  GHG  during  the  use  phase  might  also  encourage  the  use  of 
lightweight  materials  in  new  cars,  particularly  combustion-based  ones,  thus  complicating 
recycling.  

It  is  clear  that  the  fleet  renewal  prompted  by  the  EU  policies  on  climate  change  and  air 
pollution  will  eventually  bring  changes  and  challenges  for  the  ELV  sector,  as  exposed  in 
sections 5.3.2, 5.3.3 and 5.3.4.  

As highlighted in 5.3.4, the transition towards low-tailpipe emissions vehicles entails a shift 
of  environmental  impacts  between  life  cycle  stages.  Although  it  is  currently  difficult  to 
appropriately  quantify  impacts/benefits  of  end-of-life  phase  due  to  lack  of  robust  data, 
improvements in end-of-life management of vehicles and especially of low-tailpipe emissions 
vehicles  has  the  potential  to  reduce  greenhouse  emissions  beyond  the  transport  sector  and 
including  from  industry,  where  vehicles  are  produced,  or  from  waste,  where  vehicles  are 
recycled,  and  other  impacts120,  hence  making    “circularity  […]  a  prerequisite  for  climate 
neutrality”121. For instance, further investigating emissions linked to battery recycling will be 
instrumental in ensuring that end-of-life emissions, and therefore overall lifecycle emissions, 
of vehicles with an electric powertrain are aligned with climate objectives.  

Another possible impact of the EU policies on climate change and air pollution, which is also 
relevant  for  the  ELV  Directive,  relates  to  the  export  of  second-hand  vehicles.  Based  on 
ACEA information, the EU motor vehicle fleet is getting older year-on-year. Passenger cars 
are  now  on  average  10.8  years  old,  vans  10.9  years  and  heavy  commercial  vehicles  12.3 
years122. Besides higher operational costs and safety concerns, the used vehicles pose greater 
environmental challenges as vehicle emissions are a significant source of the fine particulate 
matter (PM2.5) and nitrogen oxides (NOx) being major causes of urban air pollution.  

120  Hill,  N.,  Amaral,  S.,  Morgan-Price,  S.,  Nokes,  T.,  Bates,  J.,  Helms,  H.,  Fehrenbach,  H.,  Biemann,  K., 
Abdalla,  N.,  Jöhrens,  J.,  Cotton,  E.,  German,  L.,  Harris,  A.,  Haye,  S.,  Sim,  C.,  Bauen,  A.,  2020. 
Determining  the  environmental  impacts  of  conventional  and  alternatively  fuelled  vehicles  through  LCA. 
Ricardo Energy & Environment for the European Commission. 

121 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee and the Committee of the Regions – A new Circular Economy Action Plan For a cleaner 
and more competitive Europe, COM(2020) 98 final 
122 https://www.acea.be/statistics/tag/category/average-vehicle-age  

55 

 
 
                                                      
 
It  is  expected  that  the  global  fleet  of  light  duty  vehicles  is  set  to  at  least  double  by  2050. 
Around  90%  of  this  growth  will  take  place  in  non-OECD  countries,  which  import  a  large 
number of used vehicles123. It is likely that the combination of stricter emission limits in the 
EU and increased demand for second-hand vehicles in non-OECD countries leads to a growth 
of  export  of  such  vehicles  from  the  EU.  The  negative  impacts  of  such  export  for  the 
environment  and  road  safety  are  laid  out  in  a  recent  report  by  the  Dutch  Ministry  of 
Infrastructure  and  Water  Management  on  the  quality  of  the  used  vehicles  exported  to 
Africa124.  The  vehicles  exported  to  African  countries  often  do  not  meet  the  Euro  4/IV 
emission standard and do not have a valid periodic roadworthiness certificate. Around 20% of 
tested  petrol  vehicles  fail  tests  for  emission  requirements.  Many  of  these  export  vehicles, 
therefore,  are  a  cause  for  polluting  emissions  and  present  risks  for  road  safety  and  an 
increased flow of ELVs in the recipient countries. As a response, fifteen ECOWAS countries 
in  West  Africa  adopted  a  coordinated  approach  on  the  import  policy  which  would  allow  to 
only  accept  vehicles  with  a  minimum  Euro  4/IV  emission  standard  from  January  1,  2021. 
This  underlines  the  seriousness  of  the  problems  linked  to  the  export  of  used  vehicles, 
presented in section 5.1.2 of this document. 

The treatment process of ELVs also affects climate change by releasing GHG emissions, in 
particular  for  operations  which  release  powerful  GHGs  like  air  conditioning  fluids.    They 
require  specific  technologies  and  are  energy-intensive,  which  is  likely  to  be  the  case  for 
components  and  materials  which  are  difficult  to  recover  or  recycle,  such  as  plastics  and 
electronics. On the other hand, the dismantling of spare parts before shredding requires less 
technology and energy, and the re-use/remanufacturing of these parts would reduce the need 
for  new  resources  for  the  production  of  new  parts  and  also  offer  skilled  employment 
opportunities125.Moreover,  requirement  to  incorporate  recycled  plastics  into  new  vehicles 
would boost recycling of plastics, reduce dependence on virgin raw materials and lower GHG 
emissions126.   

5.4.2.3.Waste Framework Directive127  

-  Definitions of recycling and re-use 

These definitions of the terms “reuse” and “recycling” are different in the ELV Directive and 
in the Waste Framework Directive (WFD).  

The definition for recycling is broader under the ELV Directive, since it allows backfilling128 
to  be  accounted  as  recycling,  while  backfilling  is  not  considered  as  recycling  under  the 

123 https://wedocs.unep.org/bitstream/handle/20.500.11822/34175/UVE.pdf?sequence=1&isAllowed=y  
124 Used Vehicles Exported to Africa, Netherlands Human Environment and Transport Inspectorate, Ministry of 
Infrastructure and Water Management, 2020 https://www.ilent.nl/documenten/rapporten/2020/10/26/rapport--used-vehicles-
exported-to-africa  
125  Parker,  D.,  Riley,  K.,  Robinson,  S.,  Symington,  H.,  Hollins,  O.,  2015.  Remanufacturing  Market  Study.  European 
Remanufacturing  Network  (ERN).  Available  at  https://www.remanufacturing.eu/assets/pdfs/remanufacturing-market-
study.pdf”  
126 More than 90% of plastics today are produced from fossil feedstock and plastics production gives rise to approximately 
400 million tonnes of GHG emissions per year globally (2012). If current trends continue, by 2050 it could rise to 20% of 
global oil consumption and 15% of the global annual carbon emissions.  Ibid. 
127 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. 3–30). 

56 

 
 
 
                                                      
 
WFD129. Waste from ELVs which are typically sent to backfilling operations are reported as 
recycling.  If  such  waste  were  not  accounted  for  recycling,  it  is  likely  that  some  Member 
States would not be able to meet the recycling targets under the ELV Directive.  

While the WFD distinguishes between “reuse” and “preparing for reuse”, the ELV Directive 
establishes  its  own  definition  of  “reuse”.    Under  Article  2  (6)  of  the  ELV  Directive  reuse 
means  any  operation  by  which  components  of  end-of-life  vehicles  are  used  for  the  same 
purpose for which they were conceived.  Reuse of ELV components is thus an operation that 
takes  place  when  the  vehicle  reaches  the  waste  stage.  In  practice,  such  components  are 
removed from an ELV, tested and sold cease being waste and are sold as used parts, usually 
with a warranty. The WFD adopts a different approach by defining reuse as the operation by 
which that products or components that are not waste are used again for the same purpose for 
which they were conceived have never been waste.130 In addition, it is important to mention 
that  the  notion  of  “preparing  for  re-use”131,  which  applies  to  products  or  components  of 
products that have become waste, and is included in the waste hierarchy defined in Article 4 
of the WFD, does not appear in the ELV Directive. It can be concluded that reuse in the ELV 
Directive is  understood  more as a practical  concept  that the used part (and still functional) 
part is actually functional and can be placed in a car as used part, therefore effectively reused, 
while preparation for reuse does not necessarily mean that the same part from an ELV would 
be actually reused for the same purpose it was initially conceived. 

-  Extended Producer Responsibility 

The  ELV  Directive  sets  out  provisions  on  the  role  of  producers  (e.g.  car  manufacturers)  in 
respect to the collection of ELVs, as well as on making dismantling information available for 
each new car, as reflected in the table below: 

Main requirements for vehicle producers under the ELV Directive: Article 2(13): 

‘Dismantling information’ means all information required for the correct and environmentally sound 
treatment  of  end-of  life  vehicles.  It  shall  be  made  available  to  authorised  treatment  facilities  by 
vehicle  manufacturers  and  component  producers  in  the  form  of  manuals  or  by  means  of  electronic 
media (e.g. CD-ROM, on-line services). 
Article 5(4): 
Member  States  shall  take  the  necessary  measures  to  ensure  that  the  delivery  of  the  vehicle  to  an 
authorised  treatment  facility  in  accordance  with  paragraph  3  occurs  without  any  cost  for  the  last 
holder and/or owner as a result of the vehicle's having no or a negative market value.  

128 Under the WFD, backfilling is defined as “any recovery operation where suitable non- hazardous waste is used for 
purposes of reclamation in excavated areas or for engineering purposes in landscaping. Waste used for backfilling must 
substitute non-waste materials, be suitable for the aforementioned purposes, and be limited to the amount strictly necessary 
to achieve those purposes” 
129 More clarification is provided in the Guidance on the interpretation of the term backfilling  
prepared by EUROSTAT: https://ec.europa.eu/eurostat/documents/342366/4953052/Guidance-on-Backfilling.pdf/c18d330c-
97f2-4f8c-badd-ba446491b47e 
130  Article  3  (13)  of  the  WFD  ‘reuse’  means  any  operation  by  which  products  or  components  that  are  not  waste  are  used 
again for the same purpose for which they were conceived; 
131Article  3(16)  of  the  WFD  ‘preparing  for  re-use’  means  checking,  cleaning  or  repairing  recovery  operations,  by  which 
products or components of products that have become waste are prepared so that they can be re-used without any other pre-
processing; 

57 

 
 
                                                                                                                                                                     
 
Member States shall take the necessary measures to ensure that producers meet all, or a significant 
part of, the costs of the implementation of this measure and/or take back end-of life vehicles under the 
same conditions as referred to in the first subparagraph. 
Article 8(3): 
Member  States  shall  take  the  necessary  measures  to  ensure  that  producers  provide  dismantling 
information for each type of new vehicle put on the market within six months after the vehicle is put on 
the  market.  This  information  shall  identify,  as  far  as  it  is  needed  by  treatment  facilities  in  order  to 
comply with the provisions of this Directive, the different vehicle components and materials, and the 
location of all hazardous substances in the vehicles, in particular with a view to the achievement of 
the objectives laid down in Article 7. 
Article 8(4): 
Without  prejudice  to  commercial  and  industrial  confidentiality,  Member  States  shall  take  the 
necessary measures to ensure that manufacturers of components used in  vehicles make available to 
authorised  treatment  facilities,  as  far  as  it  is  requested  by  these  facilities,  appropriate  information 
concerning dismantling, storage and testing of components which can be reused. 

All Member States have transposed the provision that the delivery of the vehicle for the last 
holder/owner to an ATF must occur without any costs.  

The  question  of  the  availability  and  quality  of  dismantling  information  made  available  by 
producers is analysed in Section 5.1.1.7. 

While these elements are relevant to facilitate the collection and treatment of ELVs, it should 
be noted that they are pretty limited, when compared to other areas where Extended Producer 
Responsibility (EPR) schemes have been established. Under such schemes, producers bear a 
higher financial or organisational  responsibility for the end-of-life stage  of goods placed on 
the EU market.  

In  that  respect,  the  ELV  Directive  does  not  take  into  account  the  “general  minimum 
requirements  for  extended  producer  responsibility  schemes”  as  defined  in  Article  8a  the 
Waste Framework Directive. Notably, there is no clear provision in the ELV Directive on the 
need for producer to cover the costs of the treatment of ELVs necessary to meet the targets set 
out  in  the  Directive.  The  Packaging  and  Packaging  Waste  Directive  foresees  that  EPR 
schemes should be put in place for packaging, based on the criteria set out in the WFD, by 
2024.  Other  EU  waste  legislation,  such  as  the  WEEE  Directive,  also  contains  obligations 
relating  to  the  establishment  of  EPR  scheme  covering  a  wide  range  of  actions  designed  to 
ensure the proper treatment of waste from electrical and electronic equipment.  

The  absence  of  sufficient  responsibility  from  the  side  of  producers  was  presented  by  some 
stakeholders  as  an  important  impediment  to  achieve  the  recovery  and  recycling  of  some 
materials in ELV.  For example, the dismantling of glass before shredding is rarely performed 
by  ATF,  in  view  of  the  costs  of  the  operation,  which  are  not  compensated  by  the  revenues 
from  their  sale.    As  a  result,  glass  is  instead  directed  to  the  shredder  heavy  fraction  (SHF) 
which is used for construction purposes or for backfilling or disposed of in landfills. This is a 

58 

 
 
loss  of  resources,  as  glass  removed  before  shredding  could  be  rather  recycled  and  used  by 
glass producers132.    

Similar  shortcomings  exist  for  other  materials  (plastics,  electronic  components)  where  the 
current cost for dismantling and subsequent separation and recycling are not compensated by 
the revenues generated for the dismantlers or recyclers133.  

The targeted survey  carried as  a part of evaluation included a question on the extent of the 
ELV  Directive  related  costs  attributable  to  the  vehicle  producers.  The  results  demonstrated 
that public authorities (national, regional and local) were generally more likely to agree that 
vehicle  producers  bear  the  costs  linked  to  the  implementation  of  the  Directive.  Companies, 
mainly representing the recyclers or ATFs, were the most likely to disagree.  Most of them 
indicated  that  dismantlers  and  shredders  cover  the  main  costs  of  the  implementation  of  the 
Directive.  A  number  of  stakeholders  from  a  broader  range  of  representatives  presumed  the 
current additional costs are normally shared by dismantlers and shredders. Five stakeholders 
responded  that  the  treatment  of  ELVs  is  sustainable/self-supporting,  which  implies  that  the 
costs of the entire ELV treatment process are covered by the value of the recovered material 
and/or the sale of recovered parts. 

The  reduced  financial  viability  of  shredding  and  dismantling  companies  was  noted  (see 
section  on  efficiency  above).  Five  responses  pointed  out  that  legal  ATFs  will  become  less 
profitable in comparison to informal/fraudulent companies that purchase and dismantle ELVs, 
with  a  presumption  that  the  current  economic  model  encourages  down-cycling  rather  than 
recycling.   

The provisions in the ELV Directive on the producers’ responsibility for the management of 
ELVs are rather limited when compared to the general minimum requirements set out in the 
Waste Framework Directive and those in place in other EU waste legislation. This results in 
limited support to high quality recycling of materials which are costly to recover from ELVs.   

5.4.2.4.Basel Convention134 and the Waste Shipment Regulation135  

There is a close link between the ELV Directive and the Waste Shipment Regulation, which 
is  under  revision  process  at  the  time  of  preparing  this  evaluation  document136.  The  Waste 
Shipment  Regulation  establishes  the  rules  governing  the  transboundary  movement  of  waste 
vehicles, which are classified as “hazardous waste” for shipments inside and outside the EU. 
There is  however a difficulty in  distinguishing between a  “used vehicle” and an “ELV” for 

132 Bartels, Pieter (2016): ELV glass: Re-cycling or Re-covery? 16th International Automobile Recycling Congress IARC 
2016. FERVER. Berlin, Germany, 15.03.2016. 
133 Sander, Knut; Kohlmeyer, Regina; Rödig, Lisa; Wagner, Lukas (2017): ELV: Recovery Rates and High Grade Recycling. 
17th international Automobile Recycling Congress IARC 2017. Ökopol, Germany; Umweltbundesamt, Germany. IARC 
2017 Berlin. Berlin, Germany, 22.03.2017.  
134 More information on the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their 
Disposal: https://www.basel.int/portals/4/basel%20convention/docs/text/baselconventiontext-e.pdf  
135 Regulation (EC) No 1013/2006 of the European Parliament and of the Council of 14 June 2006 on shipments of waste 
(OJ L 190 12.7.2006, p. 1). 
136 For more information on the revision of the WSR, see here: 
https://ec.europa.eu/environment/waste/shipments/review_of_the_wsr.htm  

59 

 
 
                                                      
 
export  purposes.  This  is  not  specifically  defined  by  the  legal  instruments,  but  guidance 
documents,  such  as  the  Waste  Correspondents’  Guidelines  No  9  on  waste  vehicles137,  have 
been  developed.  These  guidelines  have  however  proven  difficult  to  use  in  practice.  This 
might cause the undefined situation when “used vehicles” are exported but the EU authorities 
are  not  able  to  track  their  final  de  facto  status  whether  they  are  re-registered  or  illegally 
scrapped. More aspects regarding the shipment of ELVs are discussed in the section 5.1.2. on 
“missing vehicles”. 

5.4.2.5.Stockholm Convention138 on Persistent Organic Pollutants (POPs) and the EU 

POPs Regulation139  

The  Stockholm  Convention  is  implemented  in  the  EU  through  the  POPs  Regulation,  which 
bans or restricts the production of persistent organic pollutants and their use in both chemical 
products and articles. These provisions apply to vehicles. There is no incoherence or overlap 
between  the  ELV  Directive  on  one  hand  and  the  Stockholm  Convention  and  the  POPs 
Regulation  on  the  other  hand.  The  POPs  Regulation  has  an  impact  on  the  ELV  sector:  it 
affects firstly the substances/materials used for the production of new vehicles and, secondly, 
the treatment of materials separated from ELVs, which subsequently may impact the ability 
of  ELV  operators  to  fulfil  the  targets  specified  in  the  ELV  Directive.  In  practice,  the  most 
important POP-related issue for the treatment of ELVs relates to the presence and disposal of 
the  flame  retardant  decabromodiphenyl  ether  (DecaBDE)  and  other  POP-BDE  in  shredder 
residue,  which  needs  to  be  taken  into  account  in  recycling.  The  disposal  and  recovery  of 
waste containing such POPs is regulated through the POPs Regulation (Article 7).  

5.4.2.6.Directive on  Waste Electrical and Electronic Equipment  (WEEE)140 and RoHS 

Directive141  

Questions have arisen on the EU legal waste regime applying to certain EEE that are istalled 
into vehicles or used exclusively in vehicles.   
The Guidance document142 of European Commision “Directive 2000/53/EC on the end-of-life 
vehicles”  provides  the  general  rule  on  clarifying  the  links  of  the  ELV  Directive  with  the 
WEEE and RoHS Directive: “if the ELV Directives applies, the WEEE and RoHS Directives 
are not applicable”. 

The  Guidance  document  further  states  that  if  a  device  is  designed  specifically  for  use  in  a 
vehicle,  the  ELV  Directive  applies.   If  a  device  is  not  specifically  designed  for  use  in  a 

137 See the text of guidance document: https://ec.europa.eu/environment/waste/shipments/guidance.htm 
138 More information on the Stockholm Convention on Persistent Organic Pollutants 
http://www.pops.int/TheConvention/Overview/TextoftheConvention/tabid/2232/Default.aspx  
139  Regulation  (EU)  2019/1021  of  the  European  Parliament  and  of  the  Council  of  20  June  2019  on  persistent  organic 
pollutants (OJ L 169, 25.6.2019, p. 45–77).  
140 Directive 2012/19/EU of the European Parliament and of the Council of 4 July 2012 on waste electrical and electronic 
equipment (WEEE) (OJ L 197, 24.7.2012, p. 38–71). 
141  Directive  2011/65/EU  of  the  European  Parliament  and  of  the  Council  of  8  June  2011  on  the  restriction  of  the  use  of 
certain hazardous substances in electrical and electronic equipment (OJ L 174, 1.7.2011, p. 88–110). 
142  See,Guidance  Document  on  the  ELV  Directive  (http://ec.europa.eu/environment/waste/elv/legislation_en.htm)  (page  8) 

and the WEEE Frequently Asked Questions (http://ec.europa.eu/environment/waste/weee/legis_en.htm) 

60 

 
 
                                                      
 
vehicle,  that  device  is  covered  by  the  RoHS  and  WEEE  legislation143. It  can  be  concluded  
that EEEs that are specifically designed for the use in/with vehicles and cannot be used alone, 
are excluded from the scope of the WEEE Directive144, e.g. GPS installed in vehicles or car 
keys.  

Questions of coherence arise over certain EEEs that fall into the scope of RoHS Directive and 
WEEE  Directive  and  are  also  used  in  vehicles145.  This  EEE  shall  be  compliant  with  RoHS 
Directive and when it comes to the end-of-life shall be handled as WEEE146. This means that 
ELV operators shall attribute the waste of this equipment to WEEE operators.  

Clearer distinction on defining which components are under the scope of the ELV Directive 
and  which  are  under  the  scope  of  the  RoHS/WEEE  Directives  would  facilitate  an  ELV 
operator in attributing devices or parts of them to the correct waste stream.   

5.4.2.7.Batteries Directive147 

The  Batteries  Directive  establishes  general  requirements  for  the  treatment  and  recycling  of 
batteries at the end of their life, but does not lay down detailed obligations. It establishes  also 
some provisions in relation to their design (substance prohibitions, battery removability from 
appliances, etc.). As batteries used in vehicles are within the scope of the Batteries Directive 
but  also  regulated  through  ELV  Directive,  there  are  certain  overlaps  between  the  two 
Directives.   

In relation to prohibition of hazardous substances, the Batteries Directive specifically refers to 
cadmium, lead and mercury as “dangerous” substances, however prohibitions are only made 
in this Directive for mercury (in all battery applications) and for cadmium (in most portable 
batteries). Automotive batteries are defined as batteries used for automotive starter, lighting 
or ignition power functions. Other batteries used in vehicles fall under the Batteries Directive 
definition  for  “industrial  batteries”.  In  both  cases,  Recital  30  of  the  Batteries  Directive 
specifies that “Automotive and industrial batteries and accumulators used in vehicles should 
meet  the  requirements  of  Directive  2000/53/EC,  in  particular  Article  4  thereof”.  The 
substance prohibitions of the ELV Directive therefore apply to these components. Exemption 
5b of Annex II of ELV  refers to  lead in  batteries and is  still  valid for lead acid  batteries in 
most vehicles and currently under evaluation148.   

143 For instance,  car radios cannot fulfil their purpose in equipment other than the vehicle, the Commission does 

not consider them to be in scope of the WEEE Directive.  

144 on the basis of the article 2, par. 4, d), 
145  See,  Guidance  Document  on  the  ELV  Directive  (http://ec.europa.eu/environment/waste/elv/legislation_en.htm)  and  the 
WEEE Frequently Asked Questions (http://ec.europa.eu/environment/waste/weee/legis_en.htm) . 
146 For more information see FAQ on WEEE and RoHS Directive https://ec.europa.eu/environment/waste/pdf/faq_weee.pdf  
‘Some electrical and electronic devices such as radios, CD players and navigation systems can be bought separately in repair 
shops, supermarkets or specialized shops and installed and used in vehicles. Where devices are not specifically designed to 
be used in vehicles, those devices would be covered by the RoHS Directive. Where electrical and electronic devisces, such as 
radios, CD players and navigation systems, are designed primarily for use in vehicles (such as car radios) the ELV Directive’ 
147 Directive 2006/66/EC of the European Parliament and of the Council of 6 September 2006 on batteries and accumulators 
and waste batteries and accumulators and repealing Directive 91/157/EEC (OJ L 266, 26.9.2006, p. 1–14). 
148 More information about the evaluations is available here: https://ec.europa.eu/environment/waste/elv/events_en.htm 

61 

 
 
                                                      
 
Regarding waste management, the ELV Directive stipulates that batteries shall be removed as 
part of the depollution treatment of ELV. The treatment and recycling of the batteries and the 
recycling rates and efficiencies are governed by the Batteries Directive. The amount resulting 
from recycling of the dismantled batteries contributes to the recycling rate of the ELVs.   

The treatment of large and heavy traction batteries of EVs is set to become more relevant in 
the  future.  As  the  traction  batteries  are  considered  industrial  batteries  and  according  to  the 
Batteries Directive the ‘producer shall not refuse to take back’, it is not clear under the current 
framework  if  the  dismantler  must  bear  the  cost  for  storage  and  transport  of  such  batteries 
(today mostly Li-ion and for some hybrid EV also NiMH batteries) or the batteries producer. 
The targeted ‘recycling efficiency rate’ for ‘other batteries’ is 50% according to the Batteries 
Directive.  Traction  batteries  for  EV  (both  Li-ion  and  NiMH)  fall  under  this  category. 
Depending on the growing share of the battery in the total weight of the vehicle, achieving the 
target of the Batteries Directive might not be sufficient to achieve the recycling target of the 
ELV Directive.   

The legislative proposal of a Regulation on batteries and waste batteries149, which is expected 
to  repeal  and  replace  the  Batteries  Directive,  intends  to  address  many  issues  of  direct 
relevance  for  the  ELV  sector  and  the  ELV  Directive.  First  of  all,  the  proposal  introduces  a 
clear  classification  of  batteries,  including  a  separate  definition  on  “electric  vehicle  battery” 
which intends to cover batteries specifically designed to provide traction to electric vehicles. 
It also sets out comprehensive rules cocerning the design, collection, treatment and recycling 
of batteries. In addition, it reinforces the principle of extended producer responsibility, for the 
collection,  transportation  and  treatment/recycling  of  all  batteries.  Detailed  reporting 
obligations  are  proposed  for  all  actors  involved  in  the  collection  of  waste  automotive, 
industrial  and  electric  vehicles  batteries  as  for  portable  batteries.  The  revised  Batteries 
legislation  is  expected  to  ensure  stronger  coherence  between  the  ELV  and  batteries  policy 
frameworks. One example is the use of lead in batteries, which is currently regulated through 
the  ELV  Directive.  As  currently  proposed,  the  new  Batteries  Regulation  would  deal  with 
hazardous substances in batteries and their evaluation in a coherent and comprehensive way, 
in conjunction with Regulation (EC) N° 1907/2006 concerning the Registration, Evaluation, 
Authorisation and Restriction of Chemicals (REACH). 

149Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL concerning batteries and 
waste batteries, repealing Directive 2006/66/EC and amending Regulation (EU) No 2019/1020 (COM(2020) 798/3) 
(2020/353 (COD) (Proposal and Annexes)  

62 

 
 
 
 
 
 
 
                                                      
 
5.4.2.8.Directive on Vehicle Registration Documents150  

As  indicated  in  section 5.1.2  on  the  problem  of “missing  vehicles”,  the  existing  procedures 
for registration and deregistration of vehicles in the EU Member States do not allow to keep 
track  of  all  ELVs  generated  in  the  EU.  The  Directive  on  the  registration  documents  for 
vehicles  (1999/37/EC)  and  the  ELV  Directive  have  different  objectives  and  their  interplay 
does  not  ensure  that  one  vehicle  de-registered  in  one  Member  State  be  reported  to  the 
Member  State  where  it  was  initially  registered.  There  are  a  number  of  reasons  for  such 
shortcomings,  including  the  absence  of  a  harmonised  set  of  terms  linked  to  definitive  or 
temporary  de-registration,  the  absence  of  a  ‘conclusive  list  of  conditions  defining  when  a 
permanent cancellation shall apply’ as well as the absence of an obligation for Member States 
to share information on de-registered vehicles imported from another Member State.  

5.4.2.9.  Directive 2005/64/EC on the type-approval of motor vehicles regarding their 

reusability, recyclability and recoverability151 

Directive 2005/64/EC is the main piece of EU legislation linking the design of new vehicles 
and  their  reusability,  recyclability  and  recoverability.  One  of  its  purpose  is  to  ensure 
coherence  between  the  type  approval  procedures  for  new  vehicles  on  one  hand,  and  the 
obligations  contained  in  the  ELV  Directive  with  respect  to  the  prohibition  of  hazardous 
substances, treatment of ELVs and the re-use, recycling and recovery targets.  

According to Article 6(1) of Directive 2005/64/EC “Member States shall not grant any type 
approval  without  first  ensuring  that  the  manufacturer  has  put  in  place  satisfactory 
arrangements and procedures, in accordance with point 3 of Annex IV, to manage properly 
the reusability, recyclability and recoverability aspects covered by this Directive. When this 
preliminary assessment has been carried out, a certificate named ‘Certificate of Compliance 
with  Annex  IV’  (hereinafter  the  certificate  of  compliance)  shall  be  granted  to  the 
manufacturer”. 

The Directive 2005/64/EC provides a number of obligations that need to be complied with by 
the  Member  States  and  car  manufacturers  on  how  to  demonstrate  that  new  models  comply 
with the relevant obligations under EU law on reusability, recyclability and recoverability.   

150 Council Directive 1999/37/EC of 29 April 1999 on the registration documents for vehicles, OJ L 138, 1.6.1999, p. 57–65 
Regulation  (EU)  2019/2144  of  the  European  Parliament  and  of  the  Council  of  27  November  2019  on  type-approval 
requirements for  motor vehicles and their trailers, and systems, components and separate technical units intended for such 
vehicles,  as  regards  their  general  safety  and  the  protection  of  vehicle  occupants  and  vulnerable  road  users,  amending 
Regulation (EU) 2018/858 of the European Parliament and of the Council and repealing Regulations (EC) No 78/2009, (EC) 
No 79/2009 and (EC) No 661/2009 of the European Parliament and of the Council and Commission Regulations (EC) No 
631/2009, (EU) No 406/2010, (EU) No 672/2010, (EU) No 1003/2010, (EU) No 1005/2010, (EU) No 1008/2010, (EU) No 
1009/2010,  (EU)  No  19/2011,  (EU)  No  109/2011,  (EU)  No  458/2011,  (EU)  No  65/2012,  (EU)  No  130/2012,  (EU)  No 
347/2012, (EU) No 351/2012, (EU) No 1230/2012 and (EU) 2015/166: 
https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1602848873781&uri=CELEX:32019R2144  
151 Directive 2005/64/EC of the European Parliament and of the Council of 26 October 2005 on the type-approval of motor 
vehicles with regard to their reusability, recyclability and recoverability and amending Council Directive 70/156/EEC (OJ L 
310, 25.11.2005, p. 10–27)  

63 

 
 
                                                      
 
In some instances, the wording used in the Directive 2005/64/EC lacks precision and leaves 
room for interpretation,  which could jeopardise the attainment of the objectives of the ELV 
Directive,  particularly  when  it  comes  to  the  reuse,  recycling  and  recovery  targets.  The 
definitions  of  “reusability”,  “recyclability”  and  “recoverability”  in  Directive  2005/64/EC 
refers to the “potential” for “reusability”, “recyclability” and “recoverability”152. It is not clear 
how  this  potential  is  calculated.  Potential  recycling  seems  quite  different  from  actual 
recycling for example and there is a risk that the provision could be interpreted quite broadly. 

Directive  2005/64/EC  (Article  6)  also  states  that,  in  order  to  obtain  the  type  approval,  car 
manufacturers “shall recommend a strategy to ensure dismantling, reuse of component parts, 
recycling and recovery of materials” and that this strategy “shall take into account the proven 
technologies  available  or  in  development  at  the  time  of  the  application  for  a  vehicle  type-
approval”.  The  reference  to  proven  technologies  “in  development”  also  creates  some 
uncertainty as to the fact that these technologies will be available when the cars in question 
will become ELVs.  

Another example on the possible insufficient link between the aims of the ELV Directive and 
Directive 2005/64/EC is the fact that the latter considers that “tyres should be considered as 
recyclable”  for  the  purpose  of  calculating  the  recyclability  of  cars.  There  is  no  justification 
for  this  consideration,  while  available  data  show  that,  despite  the  potential,  a  large  part  of 
end-of-life tyres are actually not recycled.153  

During the consultation process for this evaluation, some stakeholders have expressed doubts 
that  some  recent  car  models  actually  comply  with  the  obligations  of  Directive  2005/64/EC 
relating  to  the  recyclability  of  new  vehicles,  notably  in  view  of  the  important  quantities  of 
materials  contained  in  these  models  which  are  difficult  to  recycle  (especially  plastics  and 
carbon fibre-reinforced plastics).  

There  is  no  reporting  requirement  for  Member  States  on  the  implementation  of  Directive 
2005/64/EC154.  It is therefore not possible to evaluate to which extent this Directive is being 
implemented and if its provisions are still fit for purpose in view of the evolution of the car 
manufacturing  sector  since  2005  and  of  the  EU  policy  objectives  on  circular  economy. 
However,  the  new  type-approval  Regulation155  reinforces  the  type-approval  testing  of  new 
cars on the EU market and where tests and investigations show non-compliance, the market 
surveillance authority of the Member State can decide to demand a recall or, in severe cases, 

152 See, article 4 of the Directive. 
153  According  to  ETRMA  62%  is  recycled  into  other  applications  than  tyres.  https://www.etrma.org/key-topics/circular-
economy/ 
154 Directive 2005/64/EC of the European Parliament and of the Council of 26 October 2005 on the type-approval of motor 
vehicles with regard to their reusability, recyclability and recoverability and amending Council Directive 70/156/EEC (1) and 
Commission Directive 2009/1/EC of 7 January 2009 amending, for the purposes of its adaptation to technical progress, 
Directive 2005/64/EC of the European Parliament and of the Council on the type-approval of motor vehicles with regard to 
their reusability, recyclability and recoverability (OJ L 310, 25.11.2005, p. 10–27). 
155 Regulation (EU) 2018/858 of the European Parliament and of the Council of 30 May 2018 on the approval and market 
surveillance of motor vehicles and their trailers, and of systems, components and separate technical units intended for such 
vehicles, amending Regulations (EC) No 715/2007 and (EC) No 595/2009 and repealing Directive 2007/46/EC (OJ L 151, 
14.6.2018, p. 1–218). 

64 

 
 
                                                      
 
full withdrawal from the market.  The Commission will also have the right to order recalls or 
market withdrawals. This will allow the remedial measure to have an EU wide effect, which 
did not exist.  

Even so, the elements presented above show that there are a number of areas where coherence 
with the ELV Directive seems insufficient.  

5.4.2.10.  European List of Waste156  

The  European  List  of  Waste  (ELoW)  includes  several  notes  on  the  classification  of  the 
outputs of the ELVs, i.e. any waste marked with an asterisk (*) in the list of wastes shall be 
considered  as  hazardous  waste  pursuant  to  Directive  2008/98/EC,  unless  Article  20  of  that 
Directive applies (see table below). The ELV Directive though does not refer to the ELoW, 
while this could be useful to ensure coherence and data comparability in the area of reporting. 

Table 5-7: Waste from ELVs as indicated in the European List of Waste 

European List 
of Waste 
Number 

Label 

16 01 

end-of-life  vehicles  from  different  means  of  transport  (including  off-road 
machinery)  and  wastes  from  dismantling  of  end-of-life  vehicles  and  vehicle 
maintenance (except 13, 14, 16 06 and 16 08) 

16 01 03 

end-of-life tyres 

16 01 04* 

end-of-life vehicles 

16 01 06 

end-of-life vehicles, containing neither liquids nor other hazardous components 

16 01 07* 

oil filters 

16 01 08* 

components containing mercury 

16 01 09* 

components containing PCBs 

16 01 10* 

explosive components (for example air bags) 

16 01 11* 

brake pads containing asbestos 

16 01 12 

brake pads other than those mentioned in 16 01 11 

156 Commission Decision of 3 May 2000 replacing Decision 94/3/EC establishing a list of wastes pursuant to Article 1(a) of 
Council Directive 75/442/EEC on waste and Council Decision 94/904/EC establishing a list of hazardous waste pursuant to 
Article 1(4) of Council Directive 91/689/EEC on hazardous waste (notified under document number C(2000) 1147) ( OJ L 
226, 6.9.2000, p. 3) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02000D0532-20150601  

65 

 
 
                                                      
 
European List 
of Waste 
Number 

Label 

16 01 13* 

brake fluids 

16 01 14* 

antifreeze fluids containing hazardous substances 

16 01 15 

antifreeze fluids other than those mentioned in 16 01 14 

16 01 16 

tanks for liquefied gas 

16 01 17 

ferrous metal 

16 01 18 

non-ferrous metal 

16 01 19 

Plastic 

16 01 20 

Glass 

16 01 21* 

hazardous components other than those mentioned in 16 01 07 to 16 01 11 and 16 
01 13 and 16 01 14 

16 01 22 

components not otherwise specified 

16 01 99 

wastes not otherwise specified 

16 06 

batteries and accumulators 

16 06 01* 

lead batteries 

16 06 02* 

Ni-Cd batteries 

16 06 03* 

mercury-containing batteries 

16 06 04 

alkaline batteries (except 16 06 03) 

16 06 05 

other batteries and accumulators 

16 06 06* 

separately collected electrolyte from batteries and accumulators 

16 08 

spent catalysts 

16 08 01 

16 08 02* 

16 08 03 

spent  catalysts  containing  gold,  silver,  rhenium,  rhodium,  palladium,  iridium  or 
platinum (except 16 08 07) 

spent catalysts containing hazardous transition metals or hazardous transition metal 
compounds 

spent  catalysts  containing  transition  metals  or  transition  metal  compounds  not 
otherwise specified 

66 

 
 
European List 
of Waste 
Number 

Label 

16 08 07* 

spent catalysts contaminated with hazardous substances 

13 01 

13 04 

13 05 

13 08 

14 06 

waste hydraulic oils 

bilge oils 

oil/water separator contents 

oil wastes not otherwise specified 

waste organic solvents, refrigerants and foam/aerosolpropellant 

5.5.  EU Added Value 

Since its entry into force in 2000, the ELV Directive has improved the consistency of national 
conditions and harmonized the fragmented regulation of ELV among Member States. Based 
on the Article 192 of TFEU, it established the first EU wide legal framework on ELVs by 
imposing  requirements  on  the  manufacturing  of  new  cars,  setting  recovery  and  recycling 
targets, minimum requirements for the ELV treatment, prevention of waste generation from 
cars.   

The  implementation  of  the  ELV  Directive  increased  the  collection  of  ELVs,  which 
subsequently led to increased rates of reuse and recycling of ELV parts and materials. As a 
result  of  minimum  technical  requirements,  currently  there  are  approximately  14  000  ATFs 
and 350 automotive shredding facilities in Europe. 

The prohibition of certain  hazardous substances is  considered to  have  a long-term positive 
impact on the possibilities to reuse or recycle materials retrieved from the ELVs.  

The ELV Directive has also positively influenced the composition of components in other 
vehicle  sectors,  which  are  not  covered  by  the  scope  of  the  Directive157.  In  relation  to  the 
global effect, although Article 4(2)(a)158only requires that vehicles placed on the EU market 
are  compliant  with  the  substance  prohibitions,  the  progress  achieved  here  is  also  often 
implemented  in  vehicles  marketed  outside  the  EU.  It  suggests  that  the  benefits  from  the 
substance prohibitions is expected to exceed the EU market. Nonetheless, it was also noted by 
some  stakeholders  that,  compared  to  the  legislation  outside  the  EU,  the  ELV  Directive  sets 
stricter standards which might impact the competitiveness of the EU car industry (but this is 

157 Based on the information provided by the motorcycle trade association, prohibitions have affected the composition of 
components used in the motorcycle sector because the two industries use common parts. 
158 Article 4(2)(a) also requires Member States to “ensure that materials and components of vehicles put on the market after 
1 July 2003 do not contain lead, mercury, cadmium or hexavalent chromium other than in cases listed in Annex II under the 
conditions specified therein”. 

67 

 
 
                                                      
 
counterbalanced  by  the  fact  that  the  ELV  Directive  applies  to  all  vehicles  put  on  the  EU 
market and not just to cars produced in the EU).  

Taking into consideration all aspects, the ELV Directive has been having a clear added-value 
and a withdrawal of the Directive would present a serious risk in increasing the uncontrolled 
disposal of ELVs, uncontrolled use of hazardous substances and lowering the rates of reuse, 
recycling and recovery from ELVs.  

On the other hand, the evaluation has identified several aspects which limit the added value of 
the Directive: 

  The  reporting  according  to  Commission  Decision  2005/293/EC159  laying  down 
detailed rules for the monitoring of the reuse/recovery and reuse/recycling targets 
does  not  provide  sufficient  evidence  on  the  recycling  rates  achieved.  This  is 
notably due to the fact that Member States do not all have the same interpretation 
of  some  terms  in  the  Directive,  as  well,  for  example,  that  the  current  reporting 
provisions  do  not  require  the  information  on  the  PST  capacity  available  in  each 
Member State.  

  The  ELV  Directive  does  not  ensure  that  information  is  made  available  on  the 
overall number of ELVs in the EU. Member States have to report the number of 
ELVs treated in  their country160.  However,  not  all Member States  are providing 
information on the destiny of deregistered cars and there is no way to know which 
of these vehicles are becoming ELVs. 

  The procedure to demonstrate the effective recycling of vehicles exported to a 3rd 

country is not clearly defined; 

  While  the  transposition  into  national  legislation  has  been  completed  by  the 
Member  States,  there  is  evidence  of  implementation  and  enforcement  deficits 
across the EU. Considering the large number of missing vehicles, de-registration 
procedures are not properly established and monitored ensuring that that all ELVs 
are sent to ATFs.  

  The  ELV  Directive  does  not  establish  requirements  for  mandatory 
inspections  of  the  sector,  including  ATFs,  workshops,  garages  performing 
dismantling/depollution activities; 

  Ineffective  tracking  information.  Parts  for  reuse  are  offered,  inter  alia  via 
internet  sales,  to  consumers  from  unidentified  providers  and  often  without  a 
certificate or other documentation demonstrating that the parts are dismantled by 
ATFs.  

6.5. Conclusions 

159 2005/293/EC: Commission Decision of 1 April 2005 laying down detailed rules on the monitoring of the reuse/recovery 
and reuse/recycling targets set out in Directive 2000/53/EC of the European Parliament and of the Council on end-of-life 
vehicles (notified under document number C(2004) 2849) 
160 Article 1(1), par.2 of Commission Decision 2005/293/EC, (OJ L 94, 13.4.2005, p. 30) and the guidance document: 

https://ec.europa.eu/eurostat/documents/342366/0/ELV+Guidance-2019 

68 

 
 
                                                      
 
This section presents the main conclusions relating to the effectiveness, efficiency, relevance, 
coherence and EU added value of the ELV Directive, based on the findings presented above.  

6.1. Effectiveness 

The Directive has established a robust legal framework which has been effective to harmonise 
minimum ELV treatment across the EU by restricting hazardous substances on manufacturing 
of new cars, setting minimum requirements for the ELV treatment and recovery and recycling 
targets,. 

It has contributed to numerous achievements, in particular in the following areas: 

  Setting  high  recycling,  recovery  and  reuse  targets:  Member  States  reported 
compliance  with  meeting  the  85%  reuse  and  recycling  target  as  well  as  the 
recovery targets for 2017;  
Increase of collection rates of ELVs; 

 
  Reduction  of  uncontrolled  disposal  and  illegal  activities  with  a  consequent 
increase  in  proper  collection  and  proper  recovery  of  environmentally  damaging 
materials; 

  14  000  ATFs  have  been  established  across  the  EU  based  under  the  harmonised 

minimum requirement set in the ELV Directive;  

  Establishment of the International Dismantling Information System (IDIS). 

The  ELV  Directive  contains  general  provisions  on  the  design  of  cars  to  facilitate  their 
dismantling  and  the  uptake  of  recycled  materials.  These  provisions  are  directly  relevant  to 
building a circular model for the car industry but are not sufficiently detailed, specific and/or 
measurable.  As  a  result,  they  have  not  brought  about  real  improvements  at  the  EU  level  to 
match the expectations that the car industry is truly a circular industry. 

In addition, the problem of “missing vehicles” remain of considerable importance: 

  Around  10  million  ELVs  are  expected  to  become  available  for  treatment  each 
year. However, the number of ELVs officially treated in the EU is well below the 
number of vehicles leaving the stock of registered vehicles. The numbers reported 
and treated in ATFs are around 6 million, leaving about 35% of the total vehicles 
which  exited  the  stock    as  “unknown  whereabouts”  each  year.  Although  no 
conclusive  data  is  available  to  quantify  the  most  significant  reasons,  the  most 
important factors explaining the problem are linked to: 

o 

o 

o 

the  lack  of  a  coherent  vehicle  deregistration  approach  among  Member 
States, which creates the conditions for vehicles to effectively ‘disappear’ 
from  the  statistics  of  Member  States.  While  Article  5(3)  of  the  ELV 
Directive  obliges  to  present  a  CoD  to  deregister  an  ELV,  there  are  other 
situations where vehicles can get de-registered and there is no exhaustive 
list established at the EU legislation for the deregistration conditions; 
the lack of systematic reporting by Member States to the country of origin 
if an imported used vehicle is  re-registered in  the importing country or if 
an imported used vehicle is scrapped; 
the  challenges  with  the  distinction  between  “used  vehicles”  and  ELVs, 
which  is  of  particular  acuity  in  relation  to  the  export  of  second-hand 
vehicles  outside  the  EU  (1  million/year  according  to  official  data). 

69 

 
 
Inspections  and  controls  are  currently  insufficient  to  ensure  that  such 
distinction is properly respected. 

Another problem undermining the effectiveness of the ELV Directive is  lack  of provisions 
on inspections of ATFs or the wider dismantling/recycling sector. Due to insufficient human 
and  financial  resources,  only  occasional  inspections  are  carried  by  Member  States  with  a 
limited  focus  on  the  ATFs.  Thus  it  is  considered  that  setting  a  legal  obligation  to  perform 
inspections  and  minimum  standards  followed  by  reporting  requirement  would  improve  the 
effectiveness  of the EVL Directive and, moreover, would strengthen the competitiveness  of 
ATFs vs. unregistered facilities. 

The effectiveness  of the ELV Directive is  also  undermined by the lack of sufficiently  clear 
reporting obligations. This is especially the case to properly monitor how the re-use, recycling 
and  recovery  targets  are  implemented  by  the  relevant  economic  actors  across  the  Member 
States.  

6.2.  Efficiency 

  Costs and Benefits 

Although it is difficult to compare the costs and benefits associated with the Directive, the 
vast majority of the stakeholders considered that the total benefits of the Directive outweigh 
its costs. 

The main benefits of the Directive can be summarised as follows: 

  Environmental  benefits  include  avoided  damages  to  ecosystems  due  to  hazardous 

substances and inappropriate handling of ELV fluids and other components. 

  Social  benefits  involve  the  avoided  damage  to  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 SMEs. 
  Economic  benefits  comprise  business  revenues  for  the  dismantling  and  shredding 
sectors and for a number of other sectors that use secondary materials derived by ELV 
treatment. The creation of a level playing field across the EU for all economic actors 
involved in the collection, treatment and reuse, recycling and recovery of ELVs is also 
an important economic benefit derived from the ELV Directive. 

Costs associated with the ELV Directive are incurred by various economic operators for data 
collection,  reporting,  monitoring,  and  technical  compliance.  The  distribution  of  these  costs 
among economic operators in the automotive sector is an issue where diverging views were 
expressed by the interested players. There is notably no definitive data on the profitability of 
the ATFs, even though available information seems to show that their economic situation is 
generally fragile. For the consumers, the ELV Directive did not incur any cost, especially as it 
foresees that the disposal of ELVs by its last owner should occur for free.  

There  is  also  no  evidence  nor  claims  that  the  ELV  Directive  has  a  negative  impact  on  the 
competitiveness of the automotive industry within the EU.  

  Administrative Burden and Simplification Opportunities 

70 

 
 
Based  on  the  results  of  the  stakeholders’  consultation,  there  is  no  clear  evidence  that  the 
ELV  Directive  leads  to  unnecessary  administrative  burden  or  complex  procedures  for 
stakeholders  and  public  authorities.  Public  authorities  experience  costs  to  administer  the 
ELV  Directive,  including  data  collection,  reporting,  monitoring  and  technical  compliance 
issues.  Companies,  e.g.  recyclers  and  ATFs,  on  average  spend  more  resources  on  technical 
compliance  than  other  stakeholder  types.  Move  to  online  tools  (i.e.  online  reporting  for 
issuing  a  CoD)  and  shift  to  digitalisation  would  help  to  reduce  avoidable  administrative 
burden,  notably  related  to  the  reporting  obligations  or  other  procedures,  e.g.  vehicle  (de-) 
registration and notification systems. 

6.3.  Relevance 

  Scope 

The  vast  majority  of  the  vehicle  market  is  covered  by  the  ELV  Directive,  where  passenger 
vehicles  comprise  the  major  share  of  vehicles  currently  operating  in  the  market  (76.3%). 
However, 25% of vehicles do not fall within the scope of the Directive, e.g. trucks of more 
than 3, 5 tonnes, big buses, specialty vehicles and motorcycles. The relevance of leaving 45 
millions  of  vehicles  outside  the  scope  the  ELV  Directive  seems  questionable,  as  these 
vehicles are currently not subject to any specific EU-wide rules regarding the treatment of the 
waste they generate. Most stakeholders supported the extension of scope across other vehicle 
types, motorcycles, buses and trucks, justified by environmental reasons.  Also it was noted 
that  there  is  a  fragmented  regulation  of  small  e-vehicles  (e.g.  e-scooters,  e-bikes, 
wheelchairs), which certain aspects are covered by different EU legislations.  Expanding the 
scope of the ELV Directive to other vehicle types is seen relevant and hence requires a further 
analysis  of  the  economic,  social  and  environmental  impacts.  The  specific  features  of  these 
vehicles need however to be fully taken in consideration in future reflexion on the extension 
of the scope of the ELV Directive.   

  Increased  use  of  electric,  electronic  components  and  lightweight  materials  in 

vehicles 

The evaluation revealed that the provisions of the ELV Directive are not suited to ensure a 
high level of recovery and recycling of increasingly used valuable materials, such as gold, 
silver, palladium, tantalum and other rare earth metals, contained in the electric and electronic 
components. One of the major reasons causing this vacuum in this area is related to the lack 
of specific requirements in the ELV Directive to separate and recover these materials and this 
is impossible to be achieved without a higher level of dismantling processing. In addition, the 
Directive  does  not  foresee  specific  recovery/recycling  targets  for  these  materials.  The 
increased use of lightweight  materials  in  vehicles, e.g. carbon-fibre  reinforced plastics, also 
creates  challenges  for  the  ELV  treatment,  as  they  are  currently  particularly  difficult  to 
recycle. This is likely to increase the cost and complexity of dismantling. On the other hand, 
costly  components  are  expected  to  generate  dismantling  income,  as  electric/hybrid  vehicles 
will  eventually  increase  the  revenues  of  the  recycling  sector  due  to  the  higher  recovery  of 
valuable metals. 

As a result, the ELV Directive does not contain sufficient provisions to deal adequately with 
the  challenges  posed  by  the  increased  use  of  lightweight  materials,  electronic  and  electric 
components in cars.  

  Increase in sales of electric or hybrid vehicles 

71 

 
 
By 2030 approximately a half of all passenger cars sold in the EU are predicted to be electric 
vehicles or hybrid. This represents a considerable change compared to the situation when the 
ELV Directive was adopted in 2000. More than 50% of the consulted stakeholders noted that 
the  increased  use  of  EVs  will  increase  waste  management  costs  for  ELVs.  An  important 
challenge is the management of batteries from electric vehicles, which should be addressed in 
the separate future EU legislation on batteries. The ELV Directive should be well articulated 
with  this  new  legislation.  As  to  other  parts  and  materials  contained  in  electric  and  hybrid 
vehicles, it is unclear if the ELV Directive in its current form is sufficient to ensure that they 
are properly recovered and recycled.  

6.4.  Coherence 

The ELV Directive is considered as internally coherent. 

The  ELV  Directive  relies  on  a  general  approach  which  is  coherent  with  the  EU  policy 
objectives on circular economy. However, its provisions are in many respect not sufficient to 
ensure that the general orientations expressed in the ELV Directive are turned into concrete 
deliverables.  As  indicated  in  the  effectiveness  part,  this  is  the  case  especially  for  the 
provisions on the design and manufacturing of vehicles and on the use of recycled materials. 
In addition, the provisions on the treatment of ELVs (notably the fact that they do not specify 
which  materials/parts  should  be  removed  prior  to  shredding)  and  the  targets  for  re-use  and 
recycling, and for re-use and recovery (which are based on the overall weight of vehicles) are 
also  too  general  to  ensure  that  some  valuable  materials  are  recovered  and  recycled.  The 
absence of provisions setting out a full-fledged EPR scheme to support the treatment of end-
of-life vehicles is another obstacle to high quality recycling and recovery of such materials: 
these  operations  are  costly  for  ATFs  and  recyclers  to  perform,  and  the  revenues  generated 
from  these  activities  might  not  offset  these  costs.  As  a  result,  important  quantities  of  waste 
from ELVs, which could be avoided or recycled, are destined for energy recovery or disposed 
in landfills. 

The evaluation showed that synergy is also important with the EU ambitious climate change 
agenda.  The  EU  legislation  on  the  reduction  of  GHG  and  air  pollutants  from  vehicles  will 
accelerate the shift of the automotive sector to electric cars and will also encourage the use of 
lightweight  materials  like  plastics  in  vehicles.  As  indicated  above,  this  will  represent 
considerable challenges for the recycling of ELVs. In addition, the adoption of strict norms in 
the  EU  might  further  increase  the  export  of  used  vehicles  outside  the  EU,  rendering  the 
inspection  and  control  of  the  export  of  ELVs  even  more  challenging  than  is  currently  the 
case. A more circular design for the production of cars, a higher rate of re-use of spare parts 
from ELVs, a higher uptake of recycled materials in new cars and higher levels of recycling 
would bring with them reduction of GHG both in the production phase and the dismantling 
phases of vehicles.    

While the ELV Directive is generally coherent with other pieces of EU legislation, there are a 
number of instances where incoherencies are problematic: 

  The  definition  of  “recycling”  of  the  ELV  Directive  is  too  broad  and  not  aligned 
with  the WFD. The ELV Directive does  not  refer to  the term  extended producer 
responsibility  and  does  not  establish  minimum  requirements  in  line  with  the 
provisions  of  the  WFD  on  EPR,  or  other  EU  legislation  on  waste  (such  as 
packaging waste or  WEEE). As a result, there is no full EPR system established 

72 

 
 
by the ELV Directive, clearly defining distribution of costs for the collection and 
treatment of waste between producers and other economic operators. The current 
provisions of the ELV Directive do not appear sufficient to address the challenges 
related  to  the  growing  market  of  electric  vehicles,  increased  use  of  lightweight 
materials, in particular plastic carbon fibre, and digital components in the vehicles. 
  Questions  have  arisen  over  ceratin  EEE  that  is  installed  into  vehicles  or  used 
exclusively  with  vehicles  and  what  legislation,  ELV  or  RoHS/WEEE,  is 
applicable.  Clearer distinction on defining which components are under the scope 
of the ELV Directive and which are under the scope of the RoHS/WEEE would 
facilitate  an  ELV  operator  in  attributing  devices  or  parts  of  them  to  the  correct 
waste stream. 

     Better  coherence  is  needed  with  Directive  2005/64/EC  on  the  type-approval  of 
motor  vehicles  with  regard  to  their  reusability,  recyclability  and  recoverability, 
notably to ensure that the design of new cars properly allows for the attainment of 
targets set by the ELV Directive. 

     The  ELV  Directive  and  Directive  1999/37/EC  on  the  registration  documents  for 
vehicles  are  not  based  on  the  harmonised  set  of  terms,  which  has  effects  on 
deregistration and the issuing of CoDs. 

  There is a reference to the European List of Waste (ELoW) in the implementation 
of ELV Directive161. Although this coding was a mere indication, there is evidence 
that Member States are currently reporting in line with the the LoW, whenever the 
Member  States  have  a  reporting  system  permitting  to  collect  such  information, 
supported  also  by  the  indications  provided  by  Eurostat  in  past  years  and  in  the 
Eurobase codes definitions. The current problem is that not all the Member States 
have  implemented  a  reporting  system  permitting  to  gather  the  most  part  of  the 
the  Commission  Decision 
voluntary 
2005/293/EC.  

information  set  up 

in  Table  1  of 

6.5.  EU added value 

There  are  no  doubts  that  the  ELV  Directive  has  improved  the  consistency  of  national 
conditions  and  harmonized  the  fragmented  regulation  on  ELVs  among  Member  States. 
Implementation  of  the  provisions  increased  collection  of  ELVs,  which  subsequently  led  to 
increased  rates  of  reuse  and  recycling  of  ELV  parts  and  materials.  Prohibition  of  certain 
hazardous substances in ELVs and their parts is considered to have a long-term impact on the 
possibilities  to  reuse  or  recycle  materials  retrieved  from  the  ELVs.  Benefits  from  the 
substance prohibitions is expected to exceed the EU market. 

6.6.  Lessons learnt 

The evaluation of the ELV Directive confirmed that it remains an useful piece of legislation, 
which aptly contributed to the EU environmental acquis by harmonising the approach among 
the  EU  Member  States  on  the  ELVs  collection  and  treatment,  and  improved  the 
environmental performance of the economic operators involved in the life cycle of vehicles. 

161 See, note 3 in Commission Decision 2005/293/EC 

73 

 
 
                                                      
 
Although  the  ELV  Directive  has  largely  served  its  purpose,  its  implementation  showed 
certain weaknesses, mainly related to the general nature of its provisions, its lack of relevance 
to  address  the  challenges  linked  to  the  evolution  of  the  automotive  industry  and  its 
incoherence with other pieces of EU legislation. These elements are a clear indication that the 
Directive should be reviewed.  

The review could usefully look into the way to improve the ELV Directive with the following 
objectives:  

1)  addressing    the  current  implementation  challenges,  notably  obstacles 
hampering  the  performance  of  the  Directive  (i.e.  examining  the  extension  of 
the  scope  of  ELVs,  addressing  the  factors  feeding  the  “missing  vehicles”, 
setting  up  proper  Extended  Producer  Responsibility  schemes,  reinforcing 
inspections of treatment facilities and export); 

2)  addressing  the  technological  advancement  and  future  challenges  (i.e. 
electrification  of  vehicles, 
lightweight  materials, 
digitalisation,  online  sales)  and  encouraging  the  transition  of  the 
automotive sector to the circular economy (i.e. better design of vehicles for 
re-use, remanufacturing, recycling; higher uptake of recycled materials).  

increased  use  of 

These  options  and  measures  will  be  assessed  as  part  of  the  review  process  of  the  ELV 
Directive,  which  started  in  October  2020  with  the  publication  of  an  inception  impact 
assessment roadmap162 and is expected to be concluded in 2022.   

162 
life-vehicles  

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12633-Revision-of-EU-legislation-on-end-of-

74 

 
 
 
 
 
 
                                                      
 
 
ANNEX 1: PROCEDURAL INFORMATION 

Lead DGs and internal references  

The  evaluation  has  been  coordinated  by  the  European  Commission's  Directorate-General 
(DG)  for  Environment  supported  by  an  interservice  steering  group  (ISG)  involving 
representatives  of  DG  Internal  Market,  Industry,  Entrepreneurship  and  SMEs,  DG  Energy, 
DG  for  Climate  Action,  DG  for  Communications  Networks,  Content  and  Technology,  DG 
Mobility  and  Transport,  DG  for  Research  and  Innovation,  the  Joint  Research  Centre,  DG 
Eurostat, the Legal Service and the Secretariat-General. The group steered and monitored the 
evaluation's progress and ensured that it met the necessary standards for quality, impartiality 
and usefulness.  

Organisation and timing 

The roadmap163 was published on 4 October 2018 and feedback on this roadmap was received 
until 1 November 2018. 

The  stakeholder  consultation  strategy  was  prepared  and  made  publicly  available  in  2018.  It 
set  a  number  or  consultation  activities  comprising  a  public  consultation  and  targeted 
consultation in the form of interviews and surveys. While a detailed consultation synopsis is 
provided in Annex 2, a brief explanation of consultation activities follows here. 

In order to maximise the engagement of the stakeholders, the evaluation process was based on 
the  targeted  consultation  approach.  In  this  respect,  the  online  survey  was  launched  on 
September 25th 2019 and remained open for 8 weeks, until November 22nd to obtain input on 
the questions examined in the report. Accordingly, the online questionnaire was developed in 
consultation with the Commission services and was pilot tested with five stakeholders. A total 
of  72  stakeholders  responded  to  the  targeted  questionnaire  coming  from  a  range  of 
stakeholder groups. 

In  addition  to  the  targeted  survey,  9  interviews  with  selected  stakeholders  were  conducted 
with  a  view  to  complement  the  input  from  the  survey.  A  total  of  nine  interviews  were 
conducted out of the total of 19 organisations contacted. These included four interviews that 
were  conducted  during  the  initial  stages  that  assisted  in  the  development  of  the  survey 
questionnaire.  Totally,  over  50  representative  associations  and  individual  companies 
responded in writing to the targeted consultation. 

In  addition  to  the  targeted  consultation,  open  public  consultation  was  conducted  by  the 
Commission for 12 weeks (6 August 2019 – 29 October 2019). In total, 141 responses were 
received.  

163https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1912-Legislation-on-end-of-life-vehicles-
evaluation  

75 

 
 
 
                                                      
 
In order to supplement the input of the stakeholder consultation, a stakeholder workshop was 
organised on 5 February 2020 on the basis of initial analysis of the findings. The workshop 
was  attended  by  71  stakeholders  from  authorities,  industry  representatives  (economic 
operators and their representatives at EU and national level) and other stakeholders, including 
NGOs and academic experts. 

A Europa webpage was set to provide information on the evaluation process164. 

Exceptions to the Better Regulation Guidelines 

No exceptions were made to the Better Regulation Guidelines165 during this evaluation. 

Evidence, sources and quality 

The  evaluation  was  supported  by  a  study  that  inter  alia  provided  support  on  stakeholder 
consultation.  This  study  was  initiated  in  2017  and  was  performed  by  a  consortium  led  by 
Trinomics166. The study was completed in August 2020167. 

Stakeholder  consultation  and  targeted  data  collection  were  an  important  element  of  the 
exercise  (see  Annex  2).  A  Stakeholder  workshop  was  held  on  5  February  2020  to  actively 
involve  Member  State  competent  authorities  and  stakeholders  and  to  gather  views  and 
information necessary to support the evaluation of the ELV Directive168. 

The following key studies and reports have been taken into account: 

the legal acts and documents related to the implementation of the Directive;  

 
  Commission implementation reports based on information provided by Member States 
pursuant  to  Commission  Decision  2001/753/EC169  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; 

  exemption evaluation reports related to the hazardous substance prohibitions170;  
  End-of-life vehicle statistics from Eurostat171;  
  Effectively  tackling  the  issue  of  millions  of  vehicles  with  unknown  whereabouts  - 
European priority measure: establishing leakage-proof vehicle registration systems by 
UBA (2020)172; 

  Used vehicles and the environment. UNEP report (2020)173; 

164 https://ec.europa.eu/environment/waste/elv/evaluation_en.htm  
165 https://ec.europa.eu/info/better-regulation-guidelines-and-toolbox_en  
166 Study “Service contract supporting the Evaluation of the Directive 2000/53/EC on end-of-life vehicles”, commissioned by 
the European Commission, DG Environ-ment A.2, under the framework contract ENV.F.1./FRA/2014/0063, and between 
Trinomics and the contractors Oeko-Institut e.V. and Ricardo. 
167https://publications.europa.eu/en/publication-detail/-/publication/926420bc-8284-11e9-9f05-01aa75ed71a1/language-
en/format-PDF  
168The minutes of the meeting have been published are available at: https://www.elv-
evaluation.eu/fileadmin/user_upload/documents/ELV_Evaluation_Workshop_Minutes.pdf  
169 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32001D0753  
170 See consultant final reports published under: https://elv.exemptions.oeko.info/index.php?id=20  
171 https://ec.europa.eu/eurostat/statistics-explained/index.php/End-of-life_vehicle_statistics  
172 Effectively tackling the issue of millions of vehicles with unknown whereabouts - European priority measure: 
establishing leakage-proof vehicle registration systems; 

76 

 
 
                                                      
 
  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)174. 
relevant studies175 and presentations176. 

 

173 A link to the UNEP report: https://www.unep.org/resources/report/global-trade-used-vehicles-report  
174A link to the study: https://www.ilent.nl/binaries/ilt/documenten/rapporten/2020/10/26/rapport--used-vehicles-exported-
to-africa/RAPPORT-+Used+vehicles+exported+to+Africa.pdf  
175 https://ec.europa.eu/environment/waste/elv/events_en.htm 
176 More information on information sources, studies and presentations can be find in the webpage of the study performed by 
the consortium consultants: https://www.elv-evaluation.eu/  

77 

 
 
 
 
                                                                                                                                                                     
 
ANNEX 2. SYNOPSIS REPORT OF THE STAKEHOLDER CONSULTATION 

Stakeholder Consultation Strategy 

A stakeholder consultation strategy was prepared and adopted for this evaluation. It defined 
the objectives of the consultation, which are the following: 

To  involve  stakeholders  in  the  policy  evaluation  process  by  gathering  their  views  on  the 
functioning of the ELV Directive and receiving suggestions for improvement; 

To  collect  additional  data  and  relevant  facts  on  the  implementation  of  the  ELV  Directive 
beyond the materials already available; 

To  identify  all  those  parts  of  the  ELV  Directive  that  stakeholders  consider  negative, 
problematic or undesirable, including implementation problems, excessive administrative or 
regulatory  burden,  inconsistencies  both  within  the  ELV  and  with  other  legislation, 
duplications or overlaps, measures that no longer address present and future challenges, and 
gaps in the Directive that limit its ability to meet its objectives. 

To  identify  those  parts  of  the  ELV  Directive  that  stakeholders  consider  positive  and  that 
worked  well.  To  identify  positive  elements  in  the  implementation  of  the  ELV  Directive  in 
different Member States so that best practices can be highlighted and shared. 

To analyse potential divergences between Member States in the implementation of the ELV 
Directive across the EU, identify the reasons for these, and suggest appropriate measures for 
better harmonisation of rules.  

A combination of survey  and targeted interviews has been used to  obtain contribution  from 
relevant stakeholders, which included the following target groups: 

Industry stakeholders: This group of stakeholders included trade associations and individual 
entities  including  vehicle  manufacturers,  authorised  treatment  facilities  (ATF),  recyclers, 
insurers (as vehicles which are damaged beyond repair in accidents typically become end of 
life  vehicles  that  are  owned  by  insurance  companies),  material  recycling  companies  and 
organisations; 

Authorities  including  national  and  regional  authorities  responsible  for  ELV  implementation 
as well national authorities responsible with vehicles registration;  

Representatives  of  civil  society  including  environmental  and  motoring  NGOs,  consumer 
representatives and academics.  

Targeted survey 

A targeted online survey has been used to obtain input on the broad range of topics examined 
in  the  evaluation.  The  online  questionnaire  was  developed  by  the  external  consultant  in 
consultation with the Commission services and was pilot tested with five stakeholders.  

The  survey  was  launched  on  25  September  2019  and  remained  open  for  8  weeks,  until  22 
November 2019.   

78 

 
 
A  total  of  72  stakeholders  responded  to  the  targeted  questionnaire  coming  from  a  range  of 
stakeholder  groups (see  below,  Table A- 1). Most  responses came from  authorities  (mainly 
national  and  regional)  followed  by  individual  businesses  and  business  associations.  There 
were  fewer  responses  from  representatives  of  the  civil  society,  including  environmental 
organisations,  NGOs,  academic  experts  and  trade  unions.  There  were  no  responses  from 
consumer representatives.  

Table A-1: Respondents to the targeted survey by type 

Stakeholder type 

Authorities  

National 

Regional  

Local 

Industry  

Individual enterprises 

Business associations 

Civic society 

Environmental organisations/NGOs 

Academic/research organisation 

Trade unions 

Individual citizens 

Other/non-identified 

Total 

Number of responses 

Share of total 

34 

20 

10 

4 

21 

12 

9 

10 

4 

2 

1 

3 

7 

72 

47% 

28% 

14% 

6% 

29% 

17% 

13% 

14% 

6% 

3% 

1% 

4% 

10% 

100% 

In terms of the responses from industry sector, most respondents were from the dismantling 
sector (ATFs) (see  Figure A- 1). However, input  was  obtained from  all parts of the supply 
chain  directly  or  indirectly  affected,  including  both  vehicle  manufacturers,  dealers  and 
importers  as  well  as  those  involved  in  the  processing  stages  (end-users  of  secondary  raw 
materials, scrap dealers and shredder operators). The only gap was the absence of responses 
from the insurance sector.      

79 

 
 
   
 
 
 
 
 
Figure A- 1: Private sector stakeholders’ ELV areas of operation 

Stakeholder interviews  

In  addition  to  the  survey,  9  interviews  with  a  selected  stakeholders  were  conducted.  These 
were intended to supplement the input from the survey.  

A  total  of  nine  interviews  were  conducted  out  of  the  total  of  19  organisations  contacted. 
These included four interviews that were conducted during the initial  stages that assisted in 
the  development  of  the  survey  questionnaire  and  provide  some  initial  output.  A  number  of 
stakeholders did not respond to the invitation for an interview despite the multiple requests. 
Nonetheless,  the  interviewees  do  represent  a  range  of  stakeholders  including  business 
associations, one European EPR organisation, one European ATF company, and one national 
authority. 

Table A-2: Summary of individual face to face* interviews 

Type of stakeholder 

Contacted 

Completed (face to face)* 

Industry association 

ATF enterprise 

EPR enterprise 

National authority 

Total 

14 

1 

2 

1 

6 

(including 4 initial interviews) 

1 

1 

1 

9 

*  over  50  representative  associations  and  individual  companies  responded  in  writing  to  the  targeted 
consultation 

Open Public Consultation (OPC) 

In  addition  to  the  targeted  consultation  and  open  public  consultation  was  conducted  by  the 
Commission,  running  from  6  August  2019  –  29  October  2019  (12  weeks).  In  total,  141 
responses were received. The breakdown by stakeholder type is presented in the Figure A- 1 
below. 

80 

1111456678140246810121416Insurance companyOfficial vehicle dealerSecond-hand vehicle dealerCar repair workshopEnergy recovery sectorVehicle producer / manufacturer / importerPost-shredder operatorShredder operatorScrap dealerEnd-user of secondary raw materialsOther (for example, exporter / importer of used…Dismantling sector, Authorised Treatment Facility 
 
 
 
 
Figure A- 2: Responses to the OPC by type (n=141) 

More information is provided in the consultation synopsis report (Annex C).  

Stakeholder workshop 

In order to supplement the input of the stakeholder consultation, a stakeholder workshop on 
was organised February 5th 2020. The workshop took place after all the consultations (surveys 
and  interviews)  had  been  completed,  followed  by  the  initial  analysis  of  the  findings.  The 
objective of the workshop was to present the results of the OPC and targeted consultations to 
stakeholders, present our initial/emerging findings and receive input that could help us fill in 
information gaps.  

A total of 71 stakeholders from authorities, industry representatives (economic operators and 
their  representatives  at  EU  and  national  level)  and  other  stakeholders,  including  NGOs  and 
academic experts participated.  

Table A-3: Stakeholder workshop participants by type 

Stakeholder type 

National Authorities  

Industry  

Individual enterprises 

Industry associations  

Civic society 

Environmental organisations/NGOs 

Academic/research organisation 

Other/non-identified 

Total 

Number of participants 

Share of total 

20 

50 

16 

28 (14 EU and 14 national) 

4 

3 

1 

3 

71 

28.2% 

61.9% 

22.5% 

39.4% 

5.6% 

4.2% 

1.4% 

4.2% 

100% 

The following topics were covered during the workshop: 

 

Introduction to the purpose of the evaluation, as well as an overview of the evaluation 
roadmap and the expected timeframe (presented by DG ENV); 

81 

11113571328344705101520253035404550Academic/research institutionTrade unionNon-EU citizenConsumer organisationEnvironmental organisationOtherNon-governmental organisation (NGO)Public authorityEU citizenBusiness associationCompany/business organisation 
 
 
  Presentation by the study team on the analysis of the implementation of the Directive 
and  the  preliminary  findings  by  evaluation  question,  followed  by  a  Question  & 
Answer session; 
Initial  summary  of  the  feedback  received  from  stakeholders  during  the  interactive 
session, followed by conclusions and closing remarks. 

 

The  workshop  participants  were  invited  to  provide  further  feedback  on  the  evaluation  and 
were  encouraged  to  reflect  on  the  future  developments.  The  obtained  input  was  used  to 
validate and revise the findings in the preparation of this evaluation. The detailed report of the 
workshop can be found in Annex E of the study supporting this document177 and also in the 
website dedicated to publicise events and share results:  https://www.elv-evaluation.eu/.  

Overview of the stakeholder inputs 

This  section summarises the responses  from  the  targeted survey, OPC and interviews, what 
principally  build  the  synopsis  report  for  the  evaluation  of  the  ELV  Directive  in  accordance 
with  the  criteria  set  out  in  the  Better  Regulation  Guidelines178,  as  presented  in  the 
Commission’s evaluation roadmap179. 

I. Effectiveness 

Has the ELV Directive done what it was intended to do? 

Question: From your experience, to what extent do you agree that the ELV DIRECTIVE has 
led to the following changes or results? 

Stakeholders perceived that the Directive has led to a decrease in uncontrolled disposal and 
an increase in the reuse, recycling and recovery of material from ELV and their components. 

Stakeholders  were  less  clear  on  whether  the  ELV  Directive  has  contributed  to  the  smooth 
operation  of  the  internal  market.  Most  were  neutral  to  this  statement  (n=23),  with  the  next 
largest groups either agreeing or having no opinion (n=16 for both). 

Question: Whether the Directive led to any significant changes or results? 

It  was  seen  as  leading  to  an  increase  in  proper  collection  systems  for  ELV,  particularly 
influencing  the  increase  of  the  number  of  quality  ATFs  .It  has  also  contributed  to  a  slight 
reduction of illegal operations in the ELV sector. 

Question: Factors hampering the achievement of the ELV 

177 165-176 p. 
178https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-regulation-why-and-how/better-
regulation-guidelines-and-toolbox_en  
179 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1912-Legislation-on-end-of-life-vehicles-
evaluation  

82 

 
 
                                                      
 
Illegal  operations  were  noted  by  most  respondents  as  hampering  the  implementation  of  the 
Directive, mostly in relation to the improper export and treatment of vehicles. This was seen 
as being combatable with better MS enforcement of the Directive (n=12). 

Interviews 

  Majority  of  stakeholders  expressed  the  opinion  that  the  Directive  achieved    the 
reduction of uncontrolled disposal of ELVs an increased recycling reuse and recovery 
of  ELV  components  achieved  by  the  Directive.  One  battery  association  noted  that 
disposal of EV batteries is the only issue to address still.  

  Several stakeholders less clear that the Directive achieved a smooth operation of the 
internal  market.  Illegal  operations  and  enforcement  vary  across  Member  States  and 
therefore effect market competitiveness (as noted by an EU EPR organisation and an 
ATF). This factor further was seen as the main issues hampering the achievements of 
the Directive.  

  It was noted ELVs with missing essential components can still be processed at an ATF 
for  a  small  fee.  This  can  incentivise  removal  of  essential  parts  without  justification 
(car accident etc.). This therefore fosters illegal and profitable disposal of such parts. 
Legal justification for missing parts was recommended as being necessary to stop such 
practices.  

Extended Producer Responsibility (EPR) 

Question: To what extent do you agree that vehicle producers currently bear the cost of the 
ELV DIRECTIVE implementation according to EPR provisions? 

Lithuanian stakeholders and public authorities (particularly regional administrations) believed 
vehicle producers bear the costs of the Directive. 

Companies were the most likely to disagree with this statement, the key explanation for this is 
likely  to  be  that  many  of  them  are  recyclers  and  ATFs.  {raises  the  question  -  if  they  are 
bearing the costs how do they continue to operate?} 

Question: If vehicle producers don’t bear most costs of the Directive then who does? 

Dismantlers (n=29) and shredders (n=21) were perceived by most stakeholders as bearing the 
main costs of the Directive. With another large group believing vehicle producers do (n=25). 

There  were  a  large  number  of  open  responses  that  noted  that  there  are  shared  costs  across 
different stakeholder types, however most focused on shredders and dismantlers (n=8). 

 Question: If shredders and dismantlers are meeting implementation costs – what effect is this 
having? 

A  variety  of  stakeholders  noted  that  such  costs  lead  to  more  informal/fraudulent  activities 
related to the purchase and dismantling of ELVs. This was because their financial viability is 
reduced by increased costs. They therefore have to make ends meet in other ways.  

Question:  How  likely  do  you  think  illegal  operations  (such  as  the  illegal  disposal  of 
refrigerants  from  air  conditioning)  are  to  be  found  in  the  following  ELV  destinations  / 
treatment routes? 

83 

 
 
DIY and small car repair workshops were perceived as being more likely to  be involved in 
illegal operations. ATFs were not deemed as likely.  

Question: To what extent are the following obligatory treatment operations for depollution  of 
end-of-life vehicles established in your country? 

The  removal  of  batteries,  fluids  and  potentially  explosive  materials  were  noted  as  being 
almost 100-75% established as obligatory treatment operations across EU MS.  

High response rates came from Belgium and Czechia (two of the three highest response MS 
types). Lithuania (the MS with most responses - typically wrote ‘I do not know’ for all three).  

Interviews 

  Stakeholders split into two main camps on the topic of EPR systems in various MS. 

Those who believe that: 

  Manufacturers  do  not  bear  the  cost  for  the  delivery  of  all  the  ELVs  to  an  ATF 
without any costs to the last holder/owner (often citing it falls onto ATFs to finance, 
or some stating it’s the responsibility of dismantlers and shredders); and 

  Manufacturers do pay for cost of delivery of ELVs to the ATFs gate.  
  Stakeholders  noted  that  illegal  operations  are  less  likely  to  occur  in  ATFs,  whereas 
such  operations  are  more  of  a  problem  in  small  car  repair  workshops  and  the  DIY 
sector.  These  sectors  have  lower  enforcement  as  they  pose  a  smaller  environmental 
risk (according to a Dutch stakeholder). 

Circular Economy Links 

Question: To what extent are the following treatment operations before shredding intended to 
promote the recycling of end-of-life vehicles, established in your country? 

Treatment  operations  noted  as  promoting  recycling  pre-shredding  processes  included:  the 
removal of catalysts (65% of stakeholders), tyres (60%) and metal components (34%). 

On several other operations there was a relatively high “I do not know” response, including 
removal of secondary metals (56%), glass (36%) and metal components (34%). 

Question:  Do  you  think  it  is  important  to  remove  other  parts  before  shredding  in  order  to 
promote a higher rate of recycling? 

A  majority  of  stakeholders  thought  it  was  important  (53%)  including  recyclers,  a  branch 
organisation, national and regional administrations.  

Batteries,  fluids/oils  and  electronics  were  seen  as  the  most  important  parts  that  should  be 
removed.  

Stakeholders also elaborate why some materials (listed in the bullet above) are not removed. 
This  included low economic viability (n=8 including companies and experts), and a lack of 
obligations in the Directive (n=3 mostly national governments). 

84 

 
 
 
 
Interviews 

When asked why some treatment operations before shredding were not equally established in 
Europe, stakeholders discussed the following materials: 

  Glass:  glass  removal  is  completely  absent  from  Greece  (according  to  a  Greek 
stakeholder), however a glass association noted every MS has the facilities/capacity to 
recycle,  a  lack  of  recycling  could  therefore  be  due  to  the  higher  price  of  recycled 
material. 

  Plastic  components:  Again  they are not  removed due to  the  costs and low value of 

recycled materials. 

  Copper:  such  as  that  found  in  wiring  (therefore  constituting  precise  recycling 

practices) has high extraction costs. 

Motor  cycle  industry  stakeholders  noted  they  are  practicing  with  aiding  the  Circular 
Economy, even though they are not forced to by the Directive. The inclusion of motorbikes 
would create a level playing for the market – however it could endanger bike users to bikes 
with lower-grade parts.   

Inspections of ELV treatment facilities and implementation 

Question: How useful and effective are the inspections carried out by the national authorities 
of the facilities mentioned in the box below in your country? 

ATFs was the only option were stakeholders believed inspections were useful and effective 
[fully  (n=17),  to  a  large  extent  (n=14),  or  to  some  extent  (n=13)],  with  few  stakeholders 
stating “not at all”. Non-ATFs and exporters of used vehicles had a more mixed response. 

Some stakeholders (two public authorities and an NGO) are of the opinion that authorities do 
not  have  enough  staff/resources  to  fully  execute  inspections  across  ATFs,  non-ATFs  and 
exports.  

Question: Would specific waste management targets per material, such as a specific rate for 
aluminium, plastic, glass, improve the implementation of the ELV Directive? 

There  were  mixed  reactions,  however  more  (43%)  stated 
the 
implementation of the Directive. Eight stakeholders (including recyclers, experts and public 
authorities) noted it would lead to incentives for higher recycling, create a level playing field 
across EU and would lead to better ecodesign in car design.  

it  would 

improve 

Interviews 

An EPR organisation and an association noted inspections of ATFs were thorough and useful. 
A Greek stakeholder noted that in Greece inspections are less thorough.  

On  the  need  for  specific  material  waste  management  targets  stakeholders  were  generally 
against this as it would require existing secondary material markets for this – which is not the 
case  for  many  materials.  However  a  glass  association  was  in  favour  of  this  for  glass 
components.  

85 

 
 
 
Innovation 

Question:  From  your  experience,  to  what  extent  do  you  agree  that  the  ELV  Directive  has 
caused a change in the design of vehicles in the following aspects? 

Stakeholders  perceive  that  the  Directive  has  had  a  positive  influence,  by  limiting  restricted 
hazardous substances in vehicles (Ca, Hg, Pb, Cr(VI)) (22% strongly agree, 41% agree). 

Open responses noted that legislative harmonisation (particularly with the Batteries Directive) 
was sought after.  

Question: Do you think the ELV Directive fosters or hampers innovation? (both in car design 
and ELV treatment)? 

Few stakeholders perceive that the Directive hampers innovation for either car design or ELV 
treatment.  

40% believed that is fosters ELV treatment innovation. Examples included the 2015 recycling 
targets  which  (in  combination  with  complex  plastic  car  designs)  foster  the  development  of 
post-shredder technologies and complex plastic recycling of ELVs.  

Less conclusive on car design with a mixed response (either no impact or fosters innovation). 

Interviews  

Although,  the  dismantling  of  ELVs  and  their  components  has  become  more  difficult, 
stakeholders the Directive did foster innovation in ELV treatment.  

II. Efficiency 

Costs and benefits 

Question: With regard to the relationship between the cost of dismantling and the value of the 
parts recovered from end of  life vehicles, are any of  the components  mentioned in  the non-
exhaustive list below profitable to remove from ELVs? 

Profitable  components  to  remove  included:  Pb-acid  batteries  (70%  of  stakeholders  agree), 
catalysts  (66%),  metal  components  (Cu,  Al,  Mg)  (55%),  engines  (48%),  and  gear  boxes 
(48%). Electronics were mentioned as a component missing from the list. 

Question: Please estimate your staff and other costs related to the ELV Directive 

It  was  hard  to  draw  broad  conclusions  about  resource  use  by  stakeholder  types,  due  to  the 
lack of quantifiable and comparable data.  It was clear that on average recyclers and ATFs, do 
spend more resources on technical compliance than other stakeholder types. 

Public  authorities  seemed  to  have  higher  costs  across  most  categories,  but  particularly  for 
Data collection, and Technical compliance.  

Question:  For  those  with  experience  in  more  than  one  Member  State  (MS),  do  these  costs 
vary between MSs? 

86 

 
 
Most stakeholders “did not know” whether costs varied between MS (73%).  

Only stakeholders that know are EU associations. 

Nine stakeholders pointed out that the main issue of varying costs is labour costs.  

Question:  Has  the  ELV  Directive  caused  any  unnecessary  regulatory  burdens  or 
complexities? 

Most  stakeholders  do  not  know  and  an  even  split  said  both  yes  and  no  (35%  and  33% 
respectively). 

Three  companies  noted  the  overlap  of  ELV  Directive  and  Batteries  Directive  caused  a 
concern about burdens in this respect.  

Question: Do you have any suggestions for reducing the administrative burden?  

 Most  pressing  concern  (although  only  noted  by  5  stakeholders)  was  to  digitalise  the 
(de)registration system to make it less of a burden.  

Question:  Regarding  the  intended  objectives  of  the  ELV  Directive,  to  what  extent  do  you 
agree  with  the  following  statements:  a)  The  ELV  Directive  has  helped  to  protect  the 
environment; b) The ELV Directive has helped to protect human health; c) The ELV Directive 
contributed to a level playing field for companies involved in vehicles and their end of life 

Most stakeholders noted it had performed positively  on all the above statements  (with very 
few disagree or strongly disagree responses – Agree being the largest responses for all). 

The highest consensus was for the ELV Directive helping to protect the environment which 
received 25% of stakeholders strongly agreeing and 48% agreeing.  

The  least  positive  category  was  c)  on  the  Directive  creating  a  level  playing  field  for 
companies  involved  with  ELV  (the  highest  response  was  split  between  agree  and  I  do  not 
know n=17 for both).  

Question: To what extent do you agree with the following statements on the costs and benefits 
of the ELV Directive? It has increased the income for the different operators of the sector 

Most stakeholders ‘do not know’ across all categories. Unclear to analyse.  

Based on a smaller amount of data, it seems some stakeholders perceive ATF stakeholders to 
be gaining an increased income and vehicle producers as receiving a decreased income as a 
result of the Directive (however based on less than 25% of respondents – as most wrote “I do 
not know”.  

Those  that  (strongly)  disagreed  that  the  ELV  Directive  led  to  increased  income  of  car 
manufacturers  were  unsurprisingly  in  the  automotive  production  industry.  Similarly,  on 
income  of  ELV  treatment  sector,  it  was  mostly  recycling  companies  and  associations  that 
(strongly) disagreed and the automotive sector that agreed.  

87 

 
 
Question: To what extent do you agree with the following statements on the costs and benefits 
of  the  ELV  Directive?  It  has  reduced  costs  (e.g.  through  harmonisation  of  rules)  for  the 
different operators of the sector 

Similar response to the previous question – most do not know.  

Very small amount of stakeholders that do not perceive ATFs and vehicle manufacturers as 
having increased costs. In both cases it was stakeholders from the relevant sector that stated 
their costs had not been reduced.  

Question: To what extent do you agree with the following statement on the costs and benefits 
of  the  ELV  Directive?  The  benefits  (economic  and  environmental)  outweigh  the  costs  of  its 
implementation 

Many  stakeholders  (32  responses  or  56%  of  total  responses)  noted  that  the  Directives’ 
benefits outweighed the costs. Very few (4%) disagreed with this.  

National governments and business associations were more like to agree and companies were 
most likely to be neutral on the topic. 

Interviews 

  One stakeholder noted on the relationship of cost of dismantling and the value of the 
parts recovered of an ELV that  Li-ion  batteries  should be regulated better under the 
Batteries  Directive.  This  was  because  although  the  market  functions  properly  (and 
informally) now, there are risks if the market grows in the future, which it is predicted 
to do. Some costs created for stakeholders who have to monitor coherent and overlaps 
of ELV, Batteries and Chemicals Directives for the use of automotive batteries.  

  General  mixed  opinions  on  the  costs  and  benefits  of  the  Directive.  Different 
stakeholders  with  different  interests  and  market  operations  perceive  the  Directive  to 
negatively effect their sector and positively effect (or be neutral) to other sectors.  

Simplification opportunities 

Question:  Can  you  identify  any  opportunities  to  simplify  the  legislation  or  reduce 
unnecessary  regulatory  costs  without  undermining  the  intended  objectives  of  the  ELV 
Directive? 

There  was  no  large  consensus  on  one/two  issues.  However  several  varying  opinions  were 
presented, the largest of which are presented here.  

Simplified  reporting  (n=2),  monitoring  and  controlling  systems  (n=5),  better  harmonisation 
and enforcements of CoDs (n=5), harmonised legislation (make the  Directive a Regulation) 
(n=6), harmonise vehicle (de-)registration (n=6). 

Interviews 

Stakeholders 

I.  Effectiveness/Efficiency: Communication and data transfer 

88 

 
 
Question:  How  well  does  the  cooperation  and  data  exchange  work  within  and  between 
Member  States  services  on  de-registration  of  vehicles,  provision  of  Certificates  of 
Destruction, data  on vehicle recycling  (including PST) and ELV  monitoring, export of  used 
vehicles, and re-registration of exported / imported vehicles 

The area perceived as having the most/best cooperation and data exchange  within MSs was 
the  data  on  vehicle  recycling  and  ELV  monitoring,  while  the  areas  with  the  least 
cooperation and data exchange were the re-registration of exported / imported vehicles and 
the export of used vehicles. 

The areas with the most cooperation and data exchange between MSs were sharing of data 
on vehicle recycling and ELV monitoring, whereas the areas with the least cooperation and 
data  exchange  between  MS  were  the  export  of  used  vehicles  and  the  de-registration  of 
vehicles. 

Question: What measures and criteria were applied by your Member State for shipments to 
distinguish ELVs from used vehicles when vehicles are shipped out of the territory of the MS 
to another MS or outside the EU? (If you are able to answer for more than one MS please do 
so) (This question should include any views you have on the implementation/ actual situation, 
effectiveness of correspondents’ guideline No 9.)  

The  Netherlands  was  suggested  as  the  best  practice  example.  In  the  Netherlands  a  vehicle 
becomes  an  ELV  when  it  cannot  be  repaired  for  realistic  costs  in  the  country  of  export.  In 
Italy, a provision will enter into force and will oblige exported cars to pass a roadworthiness 
test  in  the  previous  6  months  before  an  export  to  another  country  is  possible.  Dublin  City 
Council  (the  designated  national  competent  authority  for  Ireland)  has  developed  guidance, 
which incorporates the provisions of Guidelines No. 9 and enforces the requirement to have 
mechanical certification for all used vehicles and used vehicle parts. 

The  enforcement  of  the  guidelines  was  highlighted  as  the  main  problem.  The  fact  that  the 
guidelines  are  legally  non-binding  and  the  lack  of  shipment  inspections  contribute  to  the 
lower enforcement.  

Question:  What  measures  (for  example  use  of  CoD  to  deregister  vehicles,  or  financial 
incentives  etc.)  are  applied  by  your  MS  (and/or  any  other  MS  you  are  aware  of)  to  ensure 
that  if  a  Certificate  of  Destruction  (CoD)  is  issued  the  related  ELV  is  dismantled  at  an 
authorised treatment facilities (ATFs)? 

In  Portugal,  a  road  tax  (IUC  -  Imposto  Único  de  Circulação)  is  levied,  each  year,  to  the 
owners  of  all  registered  vehicles  until  a  valid  CoD  is  presented.  In  the  Netherlands  the 
ownership  concept  ensures  that  owners  of  vehicles  pay  taxes  on  use  until  official 
deregistration. In Germany, penalties are used to ensure that CoDs are required to send ELVs 
to official ATFs. Stakeholders mentioned that in Belgium and Czechia, there are no financial 
incentives to ensure the use of CoDs. 

It was mentioned that financial incentives are only effective when they are linked to CoDs. 

Question:  What  are  your views  on the incentives offered by some MSs to  ensure that ELVs 
are treated in legal ATFs and get a CoD? 

89 

 
 
a) Pay-out scheme kind of deposit refund scheme, where the last owner benefits by receiving 
an extra pay out 

This  measure  was  mostly  seen  as  effective  (effective  n=22,  ineffective  n=6,  don’t  know 
n=22); 

The level  of the initial  deposit  is  important,  as if it is too low it provides no steering effect 
towards legal ATFs and if its’ too high it incentivises early scrapping of vehicles. 

b) Termination of ongoing taxes levies if the vehicle is finally deregistered or exported 

This  measure  had  even  higher  percentage  of  acceptance  than  the  above  (effective  n=29, 
ineffective n=3, don’t know n=18); 

This measure is used in the Czech and Dutch systems. Stakeholders mentioned that they are 
effective systems as they were easy to implement and comprehensive. 

Question: Are you aware of other types of MS measures to address the problems of vehicles 
going missing from the system? 

Most  stakeholders  that  provided  a  concrete  answer  referred  to  the  termination  of  ongoing 
taxation when presenting an ELV with an official CoD at a legal ATF. 

Question:  It  has  been  observed  that  the  whereabouts  of  a  significant  number  of  end  of  life 
vehicles is unknown. Please rank the following potential reasons for these ‘missing’ vehicles. 

  This  question  was  not  analysed  because  some  respondents  did  not  really  rank  the 
options  but  chose  only  some  preferred  options.  Some  options  had  45  responses  and 
others 27, so it was not possible to make a ranking. 

  However,  with  these  statistical  inconsistencies  in  mind,  we  can  infer  that  the  three 
reasons  for  the  missing  vehicles  that  were  ranked  high  are  that  1)  the  ELVs  are 
scraped  in  the  country  of  origin  but  not  deregistered,  2)  ELVs  exported  to  other 
Member  States  as  used  vehicles.  Never  registered  in  the  receiving  Member  State 
instead  scraped  in  the  receiving  Member  States  but  without  data  exchange  with  the 
Member  State  of  origin,  3)  Used  vehicles  exported  outside  the  EU  and  not 
deregistered in the Member State of origin.  

Question: Annex II of the ELV Directive lists materials and components that are exempt from 
Article 4(2)(a) regarding the restriction for the use of lead, mercury, cadmium or hexavalent 
chromium.  

a) Are the criteria “according to technical and scientific progress” for amending Annex II to 
the ELV Directive adequate? 

Most of the stakeholders (48%) stated that they did not know. Otherwise, more stakeholders 
believed  the  criteria  were  to  a  large  extent  adequate  (26%),  with  only  6%  of  stakeholders 
saying they were not at all relevant. 

Stakeholders  mentioned  that  socio-economic  aspects  should  be  further  considered  together 
with the “technical and scientific” aspects (i.e. whether a scientific alternative is economically 
and practically viable) 

90 

 
 
b) Annex II to the ELV Directive has been updated frequently with an average of 2 years.  Is 
the  frequency  of  the  review  of  exemptions  listed  in  Annex  II  to  the  ELV  Directive  by  the 
Commission adequate? 

Most  stakeholders  did  not  know  (40%),  another  large  group  believed  they  were  sufficient 
(35%) and a number of stakeholders noted the reviews were too frequent (24%); 

From  those  who  said  is  sufficient,  58%  are  national  or  regional  administrations,  and  from 
those who said too frequent, 60% were either companies or business associations.  

Interviews 

  Within the Netherlands, data exchange seems to work very well, while within Greece 
very badly. Between MS, both stakeholders agreed that data exchange is problematic, 
except maybe for the data on vehicle recycling and ELV monitoring.  

 

  The issuance of a CoD  as a measure that  ensures that ELVs are dismantled in  legal 
ATFs  works  well  in  the  Netherlands  as  it  is  inspected  by  the  Dutch  inspection 
authority.  In Greece, due to the lack of inspections to identify illegal operations, the 
CoD does not necessarily mean that ELVs have been treated legally.  
In terms of the incentives that could be used to ensuring that ELVs are treated legally, 
the interviewees indicated that a pay-out scheme would not work in the Netherlands, 
but it could work in Greece. The termination of ongoing taxes / levies once the vehicle 
is  deregistered  was  considered  as  the  most  effective.  Insurance  premiums  as 
incentives were suggested by one association. According to that the last owner would 
be obliged to annually pay insurance until he/she can provide a CoD or a proof of sale. 

II.  Relevance  

Future relevance  

Question: What do you think will be the impact on ELV procedures (i.e. waste management 
costs and the regulatory needs) of the following changes that are expected to occur (and/or 
continue) during the next five to twenty years (multiple answers were allowed)? 

a)  Increase in sales of electric or hybrid vehicles 

More  than  50%  of  the  respondents  said  that  this  will  increase  waste  management  costs  for 
ELVs and 30% mentioned that this will require changes in regulation; 

The  most  significant  impact  will  come  from  the  rising  interest  in  electric/hybrid  vehicles. 
Stakeholders mentioned that this among others will require new technology and processes for 
vehicle  disposal  and  increased  requirements  on  the  ATFs,  meaning  that  producer’s 
responsibility will have to be strengthened; 

Other  stakeholders  mentioned  that  electric/hybrid  vehicles  will  increase  the  revenues  of  the 
recycling sector due to the higher recovery of valuable metals. 

b)  Increased use of lightweight materials in vehicles (i.e. plastics) 

42%  of  stakeholders  believe  this  will  increase  waste  management  costs  for  ELVs  and  25% 
mentioned that this will require changes in regulation; 

91 

 
 
 
Recycling of lightweight materials,  such as carbon fibres and plastics, will  be an issue, and 
thus it was suggested that their separation before shredding should be enforced. The increased 
use  of  such  materials  may  render  the  95%  recovery  target  impossible  to  be  achieved.  The 
ELV Dire can function as an instrument to balance the trade-off between lightweight material 
use and recyclability. 

c)  Increased use of electronic components in vehicles 

Almost  half  of  the  respondents  believe  that  this  will  increase  waste  management  costs  for 
ELVs and 22% mentioned that this will require changes in regulation; 

Some  stakeholders  mentioned  that  increased  use  of  electronic  components  in  vehicles  will 
increase dismantler’s revenue through trade of used parts. 

d)  Other changes to vehicle design and/or use  

Economies  of  scale  will  be  a  determining  factor  whether  the  cost  of  ELV  treatment  will 
increase; 

Technological  development  should  increase  the  life  of  vehicles  and  car-sharing  will  reduce 
the need for cars, which may reduce the ELV management cost. 

Question:  Are  there  any  other  issues  or  changes  in  context  that  you  think  the  current  ELV 
Directive should be adjusted in order to address?  

There is a need for a clear definition of what an ELV is, mainly a distinction of ELVs from 
used  vehicles.  Harmonisation  of  definitions  with  the  Waste  Framework  Directive  were  also 
raised. Harmonisation of the Directive among the MS was mentioned.  

The  involvement  of  different  stakeholder  types  in  the  Directive  was  raised.  In  particular,  it 
was  mentioned  that  the  role  of  insurance  companies  has  to  be  enhanced.  Greater 
responsibility  of  vehicle  manufacturers  in  the  implementation  of  the  Directive  was  also 
mentioned. 

Interviews 

 

Increase  in  sales  of  electric/hybrid  vehicles  will  increase  future  waste  management 
costs, according to  an ATF company,  while an  association and an EPR organisation 
mentioned that it will require changes in regulation.  

  Lightweight materials may also lead to increased costs of ELV treatment, according to 
the  ATF.  The  EPR  organisation  mentioned  that  treating  such  materials  is  highly 
energy intensive, and as such change in regulation to allow GHG monitoring might be 
necessary. 

  Both the ATF and the EPR organisation mentioned that the increased use of electronic 

components in vehicles will increase the waste management costs. 

  Regarding the future adjustments of the ELV Directive, the EPR organisation and the 
ATF  mentioned  that  insurance  companies  need  to  be  involved  more  in  the 
implementation  of the  Directive. The ATF also  brought up the need for a system to 
address the unregulated trafficking of spare parts.  

92 

 
 
 
Scope 

Question:  What  are  your  views  on  extending  the  scope  of  the  ELV  Directive  to  include 
motorcycles, buses, and trucks? 

More than 60% support of including all three vehicle types in the scope of the Directive. 

Those  in  favour  mentioned  that  all  these  vehicles  have  comparable  vehicle  documents  and 
produce comparable waste streams, therefore they could be included in the Directive’s scope. 

Those  against  argued  that  trucks  and  buses  usually  do  not  end  their  life  in  Europe,  but 
exported and used in non-EU countries. 

Interviews 

  There was no strong opposition to adding motorcycles, buses, and trucks in the scope 

of the Directive. 

  The association related to motorcycle manufacturers mentioned that the Directive was 
prepared  without  having  motorcycles  in  mind  and  thus  it  would  require  significant 
adjustment.  According  to  them,  the  lead  time  and  phase-in  are  the  most  important 
factors if the Commission decides to add motorcycles in the scope of the Directive.   

III.  EU Added Value 

Question: Is the value resulting from the ELV Directive additional, the same, or lower than 
the  value  that  would  otherwise  have  been  created  by  Member  State  action  only  through 
national legislation? 

44% of respondents thinks the Directive has added value, while 25% thinks is the same. From 
those who responded that there is added value (n=26), 40% believe that if the Directive was 
not in place, there would be more uncontrolled disposal of ELVs and 35% believe that there 
would be lower reuse, recycling, and other forms of recovery of ELVs and their components. 

Question: Does the ELV Directive affect the competitiveness of the EU car sector compared 
to the global car sector? 

Most  respondents  did  not  know  (62%)  and  23%  answered  that  it  does  affect  its 
competitiveness.  Those  who  said  it  does  affect  competitiveness  mentioned  that  the  ATF 
requirements are more strict than in any other non-EU country and that the Directive causes 
business uncertainty for battery and car manufacturers. 

Interviews 

  A  Greek  stakeholder  mentioned  that  the  value  of  the  Directive  is  additional  to  what 
would  be  the  case  without  the  Directive  and  that  the  consequence  of  not  having  the 
Directive  would  be  more  uncontrolled  disposal  of  ELVs  and  lower  reuse,  recycling, 
and other forms of recovery of ELVs and their components. 

  A batteries-related association mentioned that ELV Directive increases uncertainty for 

European manufacturers of batteries and they presume also for the car industry. 

IV.  Coherence 

93 

 
 
 
 
Question: Is the ELV Directive coherent with the Basel Convention? 

The majority of the respondents perceived the ELV Directive to be coherent with the Basel 
Convention (57%) and only 3% of the respondents (n=2) think that it is not coherent.  

Question: Is the ELV Directive coherent with international obligations as referred to in the 
Stockholm Convention? 

A  large  group  of  the  respondents  also  found  the  Directive  coherent  with  the  Stockholm 
Convention (40%), while 9% of the respondents (n=6) thought it is not.  

Question: Is the ELV Directive coherent with the WEEE Directive, Batteries Directive, RoHS 
Directive,  POP  Regulation,  REACH  Regulation,  Circular  Economy  policy,  Waste  Shipment 
Regulation, Directive 1999/37/EC, and ISO 22628? 

The most perceived coherent policies were the Batteries Directive and the WEEE Directive. 
The least perceived coherent policy was EU Circular Economy Policy. 

Interviews 

A  batteries-related  association  expressed  the  desire  for  automotive  batteries  to  be  removed 
from  the  ELV  Directive  and  to  be  solely  addressed  by  the  Batteries  Directive,  highlighting 
that the ELV Directive duplicates the Batteries Directive and REACH and it is not coherent 
with the principles used in RoHS Directive. 

The  EPR  organisation  had  the  same  opinion  about  the  Batteries  Directive.  They  also 
mentioned that there are some issues with the WEEE recast from 2018, which causes a high 
burden for car importers to work out the electronics in these vehicles, as it is not clear if these 
are regulated by the WEEE or the ELV Directive. In addition, they claimed that although the 
circular economy is a good goal, it should be recognised that it is not easy to be achieved for 
complex products like vehicles. 

OPC Responses 

Questions: On the deregistration of vehicles (n=141 per question) 

  Stakeholders perceive that there are adequate facilities in their region for collection of 

ELVs (strongly agree: n=64 and agree: n=49). 

  Stakeholders perceive that deregistering their vehicle would not incur costs (strongly 

agree: n=59, agree n=24). 

  Stakeholders perceive that certificates of destruction are provided to the last owner of 

a vehicle before EoL (strongly agree: n=46, agree: 30). 

  They  were  positive  that  payments  received  reflect  the  components  recovered  from 

ELV (strongly agree: n=41, agree: n=37) 

  The deregistration system is perceived as simple (strongly agree: n=37; agree n=39). 
  Stakeholders  only  strongly  disagreed  with  the  fact  that  financial  incentives  are 
provided  to  encourage  proper  disposal  at  ATFs  (strongly  disagree  n=37,  disagree 
n=18).  

  Finally stakeholders were unsure about issues of deregistering a car in country A and 
registering  the  same  car  in  a  second  country  but  not  receiving  deregistration  proof 
from country A (unsure: n=88). 

94 

 
 
Question: On the facilities that accept defective parts or used liquids removed from vehicles 

The  65%  of  respondents  said  that  if  repairing  their  vehicle  independently,  there  would  be 
facilities  to  give  their  defective  vehicle  parts  without  a  fee,  as  opposed  to  the  24%  of  the 
respondents that would only find such facilities that would accept parts only with a fee. 

The 46% of respondents mentioned that there would be facilities in their country of residence 
to accept used liquids from the vehicle for free and 45% said that they would have to pay a 
fee. 

Question:  An  increasing  number  of  spare  parts  are  sold  via  the  internet.  Please  indicate  if 
spare  parts  purchased  via  the  internet  in  your  country  are  accompanied  with  the  following 
information 

Most  stakeholders  (34%)  noted  that  spare  parts  are  not  sold  with  any  information  on  their 
origin or that they were unaware of the issue (31%). 

Some  stakeholders  (16%)  mentioned  that  they  can  see  the  name  of  the  dismantler  who 
dismantled the spare part  from  an ELV, while 10% of the respondents  said  that the vehicle 
Identification number (VIN) of the vehicle from which the spare part was removed is known 
and  10%  said  that  the  registration  number  of  the  dismantler,  which  indicates  that  the 
dismantler is an authorised treatment facility and registered in the national registry, is known. 

Question: Are you aware of  any problems related to  the disposal  and treatment  of ELVs in 
your country or region? 

Most  stakeholders  perceive  there  are  some  issues  with  disposal  of  ELVs  in  their 
country/region (61%). Only a mere 20% noted they thought there were no issues. 

Germany,  Spain,  France  and  Denmark  represented  countries  that  had  proportionally  higher 
numbers of stakeholders that noted problems with disposal 

Issues  included  illegal  and  black  market  operations,  lack  of  enforcement,  problems  with 
recycling systems and issues identifying the last registered owner.  

OPC Open responses 

  The issues of illegal and black market ELV operations and a lack of enforcement 
was  a  key  issue  brought  up  by  the  following  stakeholders:  companies/business 
organisations, public and business associations. They believe that these issues should 
be more explicitly covered by the Directive. 

  Concerns were raised over recycling of specific materials not being well addressed in 
the legislation. Current practices miss crucial and efficient technologies and often lead 
to lower quality secondary materials. This issue was mainly discussed by EU citizens 
and company and business organisations. 

  Reuse and repair were also deemed vital to be strongly integrated into the Directive. 
Stakeholders  noted  that  there  needs  to  be  a  larger  EU  market  for  the  renovation 
(upgrade) of vehicles, spare parts and general repair of ELVs.   

  Other topics included the broadening of the scope of the Directive, tackling missing 
vehicles, end producer responsibility, digitalisation, registration and deregistration and 
EU policy synergy. 

95 

 
 
Use of Stakeholder inputs 

The  draft  and  final  report  include  the  key  points  taken  from  the  consultations  for  each 
evaluation question. The report shows where these inputs have been used to triangulate and/or 
supplement  the  information  from  literature  and  data  in  order  to  carry  out  the  analysis.

96 

 
 
ANNEX 3. METHODS USED IN PREPARING THE EVALUATION 

This  Annex  provides  the  overall  evaluation  framework  as  presented  in  Appendix  A  of  the  study  performed  by  the  consortium  led  by  Trinomics  in 
support of this evaluation. It links with the various methodological tools used (i.e. interviews, workshops, survey, open public consultation, literature 
analysis) and supplements Section 4 to this evaluation document. 

Evaluation (sub) question 

ToR 

Judgment criteria 

Indicators 

Method/Source 

# 
Effectiveness 
1 

To what extent have the objectives of the ELV Directive been achieved? 

1.1 

1.2 

1.3 

To  what  extent  have  the  targets  on 
ELVs,  on  reuse/recycling/recovery  and 
on 
the  use  of 
the  elimination  of 
hazardous substances been met? 
To  what  extent  have  the  provisions  on 
prevention, collection, treatment, reuse, 
recovery,  coding  standards/dismantling 
information been implemented? 

1 

3 

To  what  extent  can 
the  achieved 
results/effects  be  credited  to  the  ELV 
Directive? 

N 

 Performance in terms of increase in recycling, 
reduction  in  the  use  of  hazardous  substances 
etc.  

  Reuse/recovery/recycling rates 
  Amounts 

hazardous 
of 
substances still used or removed. 

  Data analysis on judgment criteria 
  Review of literature on implementation 

reports, fitness check 

 Performance  of  MSs  with 
transposing  ELV  Directive 
policies 

regard 
to 
into  national 

 Performance  of  MSs  with 

regard 

to 

implementing these national policies 

 Assessment  of  (e.g.)  stakeholder  views  and 
literature  consensus  on  the  extent  to  which 
results can be credited to the ELV Directive 
 Comparison to the baseline (when defined) 

  Implementation rates per MS 
  Stakeholder 

views 

on 

implementation 

  List  of  drivers  (e.g.  political 
research 
active 

support, 
community) and barriers  

  Review  of 
legislation, 
coding 
implementation review  

literature  on  national 
standards, 

  Stakeholder  input  from  recyclers,  MS 

officials etc. (at MS level) 

  Literature  review  on  contribution  of 

other policies to targets 

  Stakeholder  input  from  MS  and  EU 
officials,  (re)manufacturers,  recyclers, 
NGOs, academia  

1.4 

To  what  extent  were 
expected? 

the  results 

1 

 Difference between results and expectations  
 Any unexpected results? 

 List of effects / expectations 
 Group  expected  and  unexpected 

  Literature 

review 
implementation of ELV Directive  

on 

intentions/ 

effects 

  Stakeholder  input  from  EU  officials, 

MS officials, academia   

2 

To what extent have the results been effectively monitored? 

2.1  Have  the  reporting  data  from  Eurostat 
and  the  information  provided  in  data 
accompanying  national  quality  reports 
been  effective  for  monitoring  of  the 
targets? 

17 

  Assessment of stakeholder views and literature 

on monitoring techniques 

 Monitoring  performance  (based  on  Eurostat 

data) 

 List of monitoring techniques 
 Eurostat data 
 Views on monitoring of ELV data 

(Eurostat specifically) 

2.2 

the  current 
To  what  extent  does 
cooperation and data exchange between 
the  national  services  and  links  with 
the 
other  relevant 

legislation  serve 

8 

  Assessment of stakeholder views  
  Involvement / performance of ministries in (de-

  Views on the current cooperation 

and data exchange  

) registration of vehicles 

  Degree 

of 
ministries in (de-) registration of 

involvement 

of 

  Literature  review  on  implementation 

reports, fitness check 

  Stakeholder  input  from  MS  and  EU 
officials  (monitoring  agencies)  and 
(re)manufacturers,  recyclers,  NGOs, 
academia 
  Stakeholder 

(targeted 
consultation  and  interviews)  from  MS 
and EU officials  

input 

97 

 
 
 
2.3 

2.4 

3 

3.1 

3.2 

purpose of the ELV Directive? 

vehicles 

To  what  extent  are 
the  current 
challenges  for  the  communication  of 
data  on  ELV  for  the  compilation  of 
statistics  and  the  monitoring  of  target 
achievements addressed? 
the  current 
To  what  extent  have 
mechanisms 
the 
performance  in  the  implementation  of 
the  ELV  Directive  and  to  monitor  the 
results 
with 
communication of data) been effective? 

challenges 

measure 

(e.g. 

to 

2 

 Assessment of stakeholder views and literature 

  Views 

on 

challenges 

on 
communication/data/  monitoring 
(specifically  addressing  PST  and 
exported ELVs 

16 

 Assessment of stakeholder views, literature and 

ATF data 

 List of monitoring techniques 
 Views on monitoring of ELV data 
  The number of ATFs certified by 

EMAS 

Which factors contributed to or hampered the observed achievements of the ELV Directive? 

To  what  extent  are  the  provisions  on 
Extended  Producers  Responsibility 
(EPR) sufficient in the ELV Directive to 
contribute  to a  good  implementation of 
its objectives? 
To  what  extent  did  the  dismantling  of 
parts  before  shredding  affect  the  ELV 
targets and the quality of recyclates, in 
view  of  the  objectives  of  the  Waste 
Framework  Directive  (WFD)  and  the 
Circular Economy Action Plan? 

19 

 Assessment of stakeholder views 
 How  EPR  is  applied  in  other  Directives,  in 
comparison to how it is applied in the ELV. 

20 

  Performance  in  terms  of  the  dismantling  of 

parts and components for reuse/recycling  

  Assessment of stakeholder views and literature 
on relation between results and ELV targets 

  Views  on  the  effectiveness  of 
EPR  provisions 
the  ELV 
Directive and in other Directives 
(to  what  extent  do  they  leave 
room for interpretation?) 

in 

  Data  on  number  and  quality  of 
and 
of 

parts 

dismantling 
recyclates 

  Views  and  data  on  market 
conditions  (costs  to  dismantle) 
Evidence  on  relevance  of  the 
WFD  and  Circular  Economy 
Action Plan   

3.3  What  other  factors  contributed  to  or 
the 

the  achievement  of 

hampered 
objectives of the ELV Directive? 

4 

  Assess 

the  differences  between 

the  ELV 
Directive’s effects and expectations and assess 
the effect of a set of factors  

Did the ELV Directive lead to other significant changes or results? 

4 
4.1  Did the ELV Directive foster or hamper 

innovation? 

7 

  Assessment  of  views  and  literature  on  the 
relation between ELV Directive and innovation 
(both in car design and ELV treatment) 

  List 

of 

factors 

that 
contributed/hampered  the  ELV 
Directive  

  List  of  effects/expectations  from 

ELV Directive 

  List of ELV treatment techniques 
  List of vehicle design changes 
  Views  on  potential  negative 
(e.g. 

innovation 

effect 
chemicals policy) 

on 

  Literature  review  on  implementation 

reports, fitness check 

  Stakeholder  input  questionnaire  and 
interviews with MS and EU officials 

  Literature  review  on  implementation 
reports 
the 
Eunomia  and  ARGUS  reports),  fitness 
check 

(comparison  between 

  Stakeholder  input  (questionnaire  and 
interviews) 
from  monitoring 
officials,  (re)manufacturers,  recyclers, 
NGOs, academia 

e.g. 

  Literature  review  on  implementation 

reports and EPR elsewhere.  

  Stakeholder  input  from  MS  officials, 

manufacturers and ATFs   

  Literature 

review  on  WFD  and 

Circular Economy Action Plan 

  Stakeholder  input  from  MS  officials, 
and 

recyclers 

remanufacturers, 
dismantlers 

  Literature  review  on  implementation 

reports 

  Stakeholder  input  from  MS  and  EU 
officials, NGOs and motor industry. 

  Literature  review  on  implementation 

reports, material evolution  

  Stakeholder  input  (e.g.  producers  and 
processors)  Case  studies  on  pre  vs. 
post  shredder  recovery.  (Pre  shredder 
may be more innovative) 

98 

 
 
4.2  Did  the  ELV  Directive  undermine  the 
achievement of the objectives of the raw 
materials and innovation policies? 

8 

  Performance on raw material use 
  Assessment of views and literature on interplay 
between the ELV Directive with raw materials 
and innovation 

  List 

of 

ELV 

Directive 

  Literature review on raw material and 

achievements 

innovation policies  

  List  of 

raw  materials  and 

innovation results 
  Data on material use 

  Stakeholder 

input 

(targeted 
consultation)  from  EU  officials  and 
others  involved  in  raw  materials  and 
innovation policies  

4.3  Did  the  ELV  Directive  lead  to  other 
significant  changes  or  results  (aside  of 
sub question 4.1 and 4.2)? 
What and to which extent did MSs implement measures to address the problems of “missing ELV” (e.g. cooperation mechanisms between MSs)? 

  Assessment  between  causality  of  changes  and 
ELV Directive (based on stakeholder views) 

 List  of  potential  changes  caused 

by ELV Directive 

 Stakeholder 
interviews)   

5, 6 

5 

input 

(questionnaire, 

5.1  What  measures  and  criteria  were 
to 

applied  by  MSs 
distinguish ELVs from used vehicles?  

for  shipments 

10 

  Assessment of stakeholder views 
  Performance of measures 

  List of all measures and criteria, 

  Literature  review  on  implementation 

per MS 

  Views  on  implementation/  actual 
correspondents’ 
situation, 
(which 
guideline 
distinguishes  ELVs  from  used 
vehicles) 

No 

9 

reports/fitness check 

  Stakeholder  input  from  MS  customs 

services, NGOs 

  Performance of CoD systems 
  Assessment of stakeholder views 

  List and quality of CoD systems 

  Literature  review  on  implementation 

report and the 2017 study

180

5.2 

5.3 

To  what  extent  were 
implemented 
national  Certificates  of  Destruction 
(CoD)  systems  designed  to  make  sure 
that  ELVs  were 
at 
authorised treatment facilities (ATFs)? 

dismantled 

the 

To  what  extent  do 
incentives 
adopted  by  some  MSs  contribute  to 
ensure  that  ELVs  are  treated  in  legal 
ATFs and get a CoD? 

12 

13 

5.4  How  effective  were  inspections  in  the 
MSs  in  the  ATFs  to  identity  their 
legality? 

5.5  What  and  to  which  extent  did  MSs 
implement  other  measures  to  address 
the problems of “missing feedback”?  

  Performance of incentives 
  Assessment of stakeholder views and literature 

on actual situation/practical issues 

  Stakeholder  input  (e.g.  questionnaire, 
environmental 
and 

registration 
authorities)  

  List  of 

incentives 

(and  best 

  Literature 

review 

on 

MS 

practices) 

implementation  

input 

  Stakeholder 

(targeted 
consultation)  from  processors,  ATFs, 
MS officials   
  Stakeholder 

(e.g. 
authorities from different MS) 

public 

input 

15 

  Assessment of views 

  Views on inspections and success 
rate (best practices from specific 
MSs) 

9 

  Existence and performance of other measures 

  List of other measures 

  Literature 

review 

on 

MS 

implementation  

  Stakeholder 

input 

(e.g. 

public 

180 Mehlhart, G.; Kosińska, I.; Baron, Y. Hermann, A. (2017): Assessment of the implementation of Directive 2000/53/EU on end-of-life vehicles (the ELV Directive) with emphasis on the end 
of life vehicles of unknown whereabouts, Study commissioned by the European Commission and carried out by Öko-Institut 

99 

 
 
                                                      
 
 
 
 
Efficiency 

6 

To what extent are the costs involved proportionate, given the benefits which have been achieved? 

the  costs  and  benefits 
6.1  What  are 
(monetary 
non-monetary) 
associated  with  the  implementation  of 
the  ELV  Directive  for  different  players 
(e.g. public authorities, consumers? 

and 

21, 
22, 
23 

  Identification  and  assessment  of  these  costs 

and benefits 

6.2 

To  what  extent  are  there  distributional 
impacts  of 
the  costs  and  benefits 
resulting  from  the  ELV  Directive  (e.g. 
on  SMEs,  different  sectors,  across 
MSs)? 

21 

  Quantitative assessment of costs and benefits 
  Assessment of stakeholder views and literature 

for 

  Direct and indirect technical and 
the 
administrative  costs 
various  actors  and  processes 
arising  from  the  ELV  Directive 
(including 
requirements 
competition 
illegal 
operators) 

with 

  Direct  and  indirect  benefits  for 
the  various  actors  (including 
society  as  a  whole)  arising  from 
the 
Directive 
ELV 
implementation 

costs 

  List  of  (in)  direct  technical  and 
administrative 
(and 
benefits) per MS arising from the 
implementation of ELV Directive 
the 
(indicate  who 
costs/benefits  -  e.g.  type/size  of 
business/sector).  
quantitative 
/ 
indicators  building  on  impacts 
and benefits per MS. 

  Qualitative 

incurs 

authorities from different MS)  

  Data analysis  
  Review  of  literature  (e.g.  studies  from 

DE and FR) 

from 

  Stakeholder  input  (targeted  survey, 
interviews) 
operators, 
processors,  manufacturers,  regulators 
etc. – to collect data for standard cost 
model assessment 

e.g. 

  Data analysis  
  Review of literature 
  Stakeholder  input  (targeted  surveys 
and  interviews)  from  e.g.  operators, 
processors,  manufacturers,  regulators 
etc. from different MS 

  Assessment  of  distribution  of  costs  amongst 

  Description of the EPR effects on 

operators 

operators 
  (In)direct 

technical 

and 

administrative costs  

  Data analysis   
  Review of literature 
  Stakeholder input from e.g. operators, 
processors,  manufacturers  etc.  –  to 
collect data, among other 

6.3  How  does  the  polluter-pays  principle, 
producers 
Extended 
applied 
as 
Responsibility 
the 
(EPR), 
different operators involved and are the 
costs  resulting  from  the  EPR  fairly 
allocated? 
To  what  extent  were  there  (and  what 
caused) differences in costs and benefits 
between MSs? 

affect 

6.4 

29, 
30 

25 

  Assessment  of  differences  and  graphic  display 
of  quantitative  results  where  appropriate  (e.g. 
labour costs, age of vehicle fleet) 

  Description  of  specific  examples 
of  cost  differences,  reasons  and 
consequences 

6.5 

To  what  extent  did  the  ELV  Directive 
support the EU internal market and the 
creation  of  a  level  playing  field  for 
economic operators?  

32 

  Assessment  of  the  size  of  the  effect  on  the 

internal market, per element  

  Data  on  labour  costs,  age  of 

vehicle fleet etc.  

  List  of  elements  in  the  ELV 
Directive 
to 
supporting  the  internal  market 
(e.g. minimum requirements) 

that  contribute 

  Data analysis  
  Review of literature 
  Stakeholder input (public and targeted 
operators, 

survey) 
processors, manufacturers etc.  

from 

e.g. 

  Review of literature 
  Stakeholder  input  from  e.g.  operators 

and particularly SMEs 

6.6  What  is  the  impact  of  the  provisions  in  33 

  Assessment of stakeholder views and literature  

  Competitiveness 

of 

EU 

  Data analysis competitiveness 

100 

 
 
  Review of literature on implementation 
  Stakeholder input (targeted survey and 
interviews) 
operators, 
manufacturers,  producers,  insurance 
companies across MS 

from 

e.g. 

  Stakeholder input from e.g. operators, 
processors, manufacturers, MS and EU 
officials  etc.  (data  analysis  based  on 
input) 

  Review  of  literature  particularly  the 
compliance  promotion  initiative  and 
the study on missing whereabouts

181

  Stakeholder input (interviews, targeted 
survey)  from  e.g.  public  authorities 
from different MSs 

  Stakeholder input (interviews, targeted 
survey)  from  e.g.  public  authorities 
from different MSs 

  Assessment  of  differences  between  ELV 

Directive and legislation outside EU 

automotive  sector  and  other 
regions 

  List of similar regulations  

  Stakeholder 

input 

(interviews  and 
targeted  survey)  from  e.g.  operators 
and  particularly  manufacturers  and 
producers 

and 

ELV 

the 
its 
Directive 
harmonisation  of  requirements  on  the 
competitiveness  of 
the  automotive 
industry within the EU? 
What factors influenced the efficiency? 
Is 
the 
implementation  of  the  ELV  Directive 
has  caused  unnecessary 
regulatory 
burden or complexity? 

evidence 

there 

that 

any 

7 
7.1 

7.2 

24 

  Assessment  of  difference  in  costs  compared  to 

other comparable regimes 

  Assessment  of  stakeholder  views  on 

the 

regulatory burden 

  Costs 

resulting 

from  ELV 
Directive and (e.g.) costs prior to 
the 
Directive 
implementation  in  the  EU  or 
costs in non-EU countries 

ELV 

Are  there  any  good  or  bad  practices 
that  can  be  identified  in  terms  of 
efficiency in the achievement of results? 

31 

  Assessment of stakeholder views 

  List  of  practices  highlighted  as 

good / bad 

7.3  How  efficient 

information 
registration  and 
departments in the MSs? 

is 
between 

the  exchange  of 
car 
the 
the  environmental 

1 

  Assessment  of  type  of  information  exchanged 
and processes (based on stakeholder views and 
literature) 

7.4  How efficient has been the exchange of 
information/notification  between 
the 
national  authorities  on  re-registration 
of exported cars? 

Relevance 

14 

  Assessment of stakeholder views 

8 

8.1 

How well do the objectives of the ELV Directive correspond to the current needs within the EU? 

Is  there  still  a  need  for  the  ELV 
DIRECTIVE? 

34 

  Assessment  of  stakeholder  views  and  data  on 
the  potential  impact  of  not  having  the  ELV 
Directive 

  Description  of 

types  of 
information  exchanged  between 
the relevant departments 

the 

  Description of processes involved 
in the exchange of information 

  Description of processes involved 
in the exchange of information 

  Data  on  relation  between  ELV 
and  environmental  degradation 
(e.g. scrap pollution data) 

  Views  of  stakeholders  on  the 

  Intervention logic 
  Literature review on indicators  
  Stakeholder input (public consultation, 
targeted survey) from all stakeholders 

(future) needs 

8.2 

Are  there  any  needs  relevant  to  the 
management of end-of-life vehicles that 

37 

  Assessment  of  views  on  unaddressed  needs  of 

  List  ELV  Directive  results  and 

stakeholders and literature 

other needs 

  Literature review 
  Stakeholder 

consultation 

(public 

181 Mehlhart, G.; Kosińska, I.; Baron, Y. Hermann, A. (2017): Assessment of the implementation of Directive 2000/53/EU on end-of-life vehicles (the ELV Directive) with emphasis on 
the end of life vehicles of unknown whereabouts, Study commissioned by the European Commission and carried out by Öko-Institut 

101 

 
 
                                                      
 
 
 
were  not  adequately  covered  by  the 
ELV  Directive  or  by  any  other 
instrument? 
Are  there  opportunities  to  simplify  the 
legislation  or 
reduce  unnecessary 
regulatory  costs  without  undermining 
the  intended  objectives  of  the  ELV 
Directive? 
To what extent are the definitions in the 
ELV Directive still up to date? 

36 

  Assessment  on 

the 

impact  of  potential 

  List  of  potential  amendments  to 

amendments to the ELV Directive 

simply ELV Directive 

41 

  Assessment  of  definition  and  potential  future 

  Views 

of 

stakeholders 

changes 

definition 
developments) 

(and 

on 
future 

consultation,  targeted  survey)  from  all 
stakeholders 

  Literature review 
  Stakeholder  input  (targeted  survey, 
interviews)  from  e.g.  from  operators, 
processors, manufacturers, MS and EU 
officials 

  Literature  review  on  (reports  on) 

relevant Directives  
input 

  Stakeholder 

from 
operators,  processors,  manufacturers, 
MS and EU officials 

from  e.g. 

To what extent can the ELV Directive appropriately cover the new challenges, changing environment and developments related to ELV?  

To  what  extent  can  the  ELV  Directive 
cover technological developments? (e.g. 
the growing share of electric vehicles)? 

38, 
 39, 
40 

  Assessment of stakeholder views and literature 
on the relation between the ELV Directive  and 
technological change in sector 

To  what  extent  can  the  ELV  Directive 
cover new challenges for recycling that 
will contribute to better implementation 
of the aims of the ELV Directive? 

38 

  Assessment  of  uptake  of  new  approaches  and 

stakeholder views 

39 

  Assessment of stakeholder views and literature  

  Data  on 

take  up  of  new 
model 

and 

approaches, 
projections of future take up 

  Views  of  stakeholders  (focus  on 

EVs) 

  Data  on 

take  up  of  new 
approaches 
(e.g.  PST),  and 
model  projections  of  future  take 
up 

   
  Innovative  examples  –  possibly 

case studies 

  Literature 

review 

on 

technical 

developments in sector 

  Stakeholder input e.g. from operators, 
processors, manufacturers, MS and EU 
officials 
  Literature 

recycling 

review 

on 

developments 

material 

  Stakeholder  input  (interviews)  from 
recyclers, 

e.g. 
(re)manufacturers 
  Literature review 
  Stakeholder  input  (interviews)  from 
recyclers, 

material 

e.g. 
(re)manufacturers 

reuse/recycling 

factors 
to 

remanufacturing 

To  what  extent  is  the  ELV  Directive 
influencing  EoL 
addressing 
(strategies 
of 
materials,  improved  replaceability  and 
repairability, 
and 
second use possibilities)? 
To  what  extent  is  the  ELV  Directive 
addressing  the  co-operation  between 
producers  and  recyclers  in  order  to 
achieve  better  recycling  and  resource 
use? 
Are  the  frequency  and  motivations  for 
amending Annex II to the ELV Directive 
adequate? 

40 

  Assessment of stakeholder views and literature  

  Examples of cooperation (if data 

available) 

  Overview of stakeholder network 

42 

  Assessment  of  the  number  of  requests  to 

  No. changes requested and made 

change and the reasons to change 

to date 

8.3 

8.4 

9 

9.1 

9.2 

9.3 

9.4 

9.5 

9.6 

To  what  extent is  the  scope  of  the  ELV  35 

  Assessment of stakeholder views and literature  

  Views of stakeholders 

  Literature review 
  Network analysis (if possible) 
  Stakeholder  input  (interviews)  from 
recyclers, 

material 

e.g. 
(re)manufacturers 
  Literature review 
  Stakeholder 

input 

(open 

public 
consultation, targeted survey) from e.g. 
material  recyclers,  (re)manufacturers, 
shredders ATFs 
  Intervention logic 

102 

 
 
10 
10.
1 

11 
11.
1 

Directive still appropriate? 

Coherence 

To what extent is the ELV Directive internally coherent? 
Does  the  ELV  Directive  contain  any 
internal incoherencies? 

N 

  Assessment of potential incoherencies  

  Literature review on developments 
  Stakeholder input 

(interviews) 
recyclers, (re)manufacturers 

from 

e.g.  material 

  List 

potential 

areas 

of 

  Stakeholder input 

incoherence  

(interviews) 
recyclers, manufacturers  

from 

e.g.  material 

To what extent is the ELV Directive coherent with other EU policy instruments and the overall EU and international policy goals? 
To  what  extent  are  there  synergies  and 
overlaps  between  the  ELV  Directive 
and other EU policy instruments? 

  Assessment of stakeholder views and literature  

44, 
45, 
46 

on 

  Description  of  any  potential 
conflicts (e e.g. WSR; Directive 
vehicle 
1999/37/EC 
ISO 
registration  documents; 
vehicles  — 
22628  Road 
and 
Recyclability 
recoverability; 
chemicals 
legislation) 

11.
2 

To  what  extent  does  the  ELV  Directive 
support the overall EU policy goals? 

43, 
46 

  Assess the potential effect of the ELV Directive 

on different policy goals  

  List of EU overall policy goals 
and ELV Directive effects 

11.
3 

11.
4 

To what extent are the Definitions in the 
ELV  Directive  coherent  with  other  EU 
policies? 

43, 
46 

 Identification of definitions in conflict 

  List 

of 
definitions 
definitions  

ELV  Directive 
related 

and 

To  what  extent  is  the  ELV  Directive 
coherent  with  international  obligations 
(i.e.  from  the  Basel  Convention  and 
Stockholm Convention? 

EU Added value 

N 

 Assessment of stakeholder views and literature 
(alignment with WSR and POP-regulation) 

 List  of  international  obligations 
and ELV Directive objectives and 
results   

  Evaluations  of  other  Directives  – 

e.g. WSR, ROHS, REACH 

  Stakeholder 

(open  public 
input 
consultation  and  targeted  survey) 
from  e.g.  EU  officials,  material 
recyclers, (re)manufacturers  

  Intervention logic 
  Literature review (other evaluations) 
  Stakeholder  input  from    EU  officials 
(view  on  policy  overlap  synergies  and 
conflicts) 

 Literature  review  on  alignment  of 

policies 

 Stakeholder 
officials, 
recyclers  

input 

(re)manufacturers 

from  e.g.  EU 
and 

 Literature  review  (WSR  and  POP-

regulation evaluation) 

 Stakeholder 
officials, 
recyclers  

input 
(re)manufacturers 

  e.g.  EU 
and 

from 

12  What is the Added value resulting from the ELV Directive?  
12.
1 

What  is  the  Added  value  of  the  ELV 
Directive  compared  to  what  MSs  could 
have  been  reached  without  the  ELV 
Directive? 

47 

  Assessment of views of stakeholders on benefits 
compared  to  the  situation  without  the  ELV 
Directive 

  Views of stakeholders on benefits 
compared to the situation without 
the ELV Directive 

  Literature  review  past  evaluations  of 
the  ELV  Directive  –  including  the 
baseline assessments 

  Stakeholder  input  from    e.g.  MS  and 
(re)manufacturers, 

EU 
recyclers, NGOs, academics 

officials, 

103 

 
 
12.
2 

12.
3 

the  most 
stopping 
existing 

What  would  be 
of 
consequences 
withdrawing 
the 
intervention? 
What  is  the  Added  value  of  the  ELV 
Directive at EU and a global level (e.g. 
on the global automotive industry)?  

likely 
or 
EU 

N 

 Assessment  of  the potential  withdrawal  -  what 

 List 

of 

such 

potential 

would occur with just MS action? 

consequences 

  Stakeholder  input  from    e.g.  MS  and 
(re)manufacturers, 

EU 
recyclers, NGOs, academics 

officials, 

48 

 Assessment of views of stakeholders on benefits 
compared  to  the  situation  without  the  ELV 
Directive, but with international obligations 

  List 

of 

global 

actions 

  Literature  review  on  past  evaluations 

(comparable to ELV Directive) 

of the ELV Directive  

  Stakeholder  input  from    e.g.  MS  and 
EU  officials,  NGOs,  academics,  esp 
global auto industry) 

104 

 
 
ANNEX 4. TECHNICAL INFORMATION 

Technical solutions and treatment of the ELVs are indispensable in the overall process of the 
implementation  of  the  ELV  Directive.  This  Annex  describes  the  processes  involved  in 
depollution  of  end-of-life  vehicles,  dismantling  components,  shredding  and  post-shredding, 
although the latter element is not explicitly mentioned in the ELV Directive. 

The typical treatment of end-of-life vehicles is separated into different steps. The first step is 
the  treatment  in  an  Authorised  Treatment  Facility  (ATF)  as  required  by  the  ELV  Directive 
and displayed in  Figure  B-1 below. 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. 

Figure B-1: Operations in an authorised treatment facility (ATF) 

Source: Oeko-Institut 

The second step is shredding the depolluted ELV as displayed in  Figure B-2. Shredders for 
ELVs  are  regulated  by  the  best  available  techniques  (BAT)  reference  document  for  waste 
treatment182.  

It  is  important  to  note  that  shredding  is  a  sorting  operation  and  shall  not  be  considered  as 
recycling for the objectives of the Directive. The main outputs of the shredding process are 

182 https://ec.europa.eu/jrc/en/publication/eur-scientific-and-technical-research-reports/best-available-techniques-bat-
reference-document-waste-treatment-industrial-emissions  

105 

 
 
 
 
                                                      
 
ferrous metals, aluminium and other metallic fractions. The shredder light fraction (SLF) and 
some parts of the shredder heavy fraction (SHF) are either disposed of or treated in so-called 
post-shredder technology (PST) facilities.  

Figure B- 2: Shredding process for ELVs  

Source: Oeko-Institut 

106 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Post-shredder technology is the further reprocessing of shredder residues. It is considered as a 
necessary  operation  to  fulfil  the  recycling  targets  set  by  the  ELV  Directive.  Different 
technical  adaptations  are  applied  across  Europe.  Some  PST  are  integrated  into  the  shredder 
facility or they are installed separately on site. Residues after the shredding process can also 
be sent to offsite PST plants, while other operators direct shredder residues for disposal to the 
landfills. 

Typical operations of PST are displayed in Figure B- 3 below.  

Figure B- 3: Operations in the post-shredder technology (PST) facilities 

107 

 
 
 
 
ANNEX 5. ANALYSIS ON THE COSTS AND BENEFITS 

ELV Directive specific costs 

Table C- 1: Summary of cost data collected via targeted consultations 

Stakeholder Type 

No. 
responses 

Hours per year 

Cost per hour 
(€) 

Other costs (€ 
per year) (e.g. 
software or 
training) 

EU Recycling Association 
(EuRIC) 
Recycler/ATF 
National 
government/administration 
Regional 
government/administration 

EU Recycling Association 
(EuRIC) 
Recyclers (ATFs) 
National 
government/administration 
Regional 
government/administration 

EU Recycling Association 
(EuRIC) 

Recyclers (ATFs) 

National 
government/administration 
Regional 
government/administration 

EU Recycling Association 
(EuRIC) 

Recyclers (ATFs) 

National 
government/administration 
Regional 
government/administration 

Data collection 

100-200 depending 
on the country 
100 – 4,000 

12-60 depending 
on the country 
6-120 

100,000 

0 – 500,000 

16-5,000 

10 - 35 

10 – 7,700 

145 – 10,600 

33 – 40 

123 – 1,100 

Reporting 
10-40 depending on 
the country 
50 – 4,800 

12-60 depending 
on the country 
5 – 120 

- 

50 – 500,000 

8 – 5,000 

10 - 35 

10 – 6,700 

5 – 10,600 

30 – 2,300 

123 - 1100 

Monitoring 
20-40 depending on 
the country 

11-60 depending 
on the country 

- 

200 – 4,800 

5 - 120 

150 – 500,000 

3 

4 

3 

5 

5 

4 (from 3 
MSs) 

5 (from 3 
MSs)  

4 

300 – 2,500 

10 - 35 

0 

5 (4 MSs) 

5 – 10,600 

30 - 123 

3 – 10.200 

Technical compliance 
10,000 variable 
depending on the 
country 

14-35 depending 
on the country 

- 

5 (from 3 
MSs) 

100 – 20,000 

5 - 100 

100 – 500,000 

3 

300 – 4,000 

10 - 35 

0 - 20 

5 (4 MSs) 

145 – 10,600 

33 - 134 

21 – 1,100 

Table  C-  2:  Overall  costs  as  a  result  of  the  implementation  of  the  ELV  Directive 
(estimates) 

Element 

Total cost 

ELV specific (vs, counter factual)  

ATFs and shredders (source = EURIC unless otherwise stated) 

Reporting and 
monitoring  

Operating 

205 hours per year @ 
€35/hr for 14,000 ATFs = 
€100.5m/year 
€40 / ELV (Ademe average) 
for 6 million ELVs = 

Hard to say how much would occur without ELV Directive. Some 
sites would be monitored by MS specific legislation 

Depends on the MS requirements. Likely that in some MSs costs 
are higher to comply with ELV Directive requirements. 

108 

 
 
 
 
 
 
€240m/year 

Payments to 
ELV last owners 

Highly variable (from €0 to 
€300 per ELV) average of 
€150 = €900m/year 

Will vary by car, MS and ATF, could be high if the MS in 
question set low standards. ELV only requires no charge (not 
payment), Payments vary, and ATFs can vary according to 
vehicle and its value to them (in parts and scrap) 

Car industry (ACEA –estimated annual costs) 

IMDS  

€107m/year 

€49m/year 

Take-back 
networks 
Dismantling 
Information 
Consumer-
Information 
Member States (Average from data collected in this study)  

€3m / year 

€1m/year 

Set up as a result of the ELV Directive, but may have occurred 
anyway.  
May have developed as a result of other legislative and consumer 
pressure, but hard to know.  
Set up as a result of the ELV Directive, but may have occurred 
anyway. 
Set up as a result of the ELV Directive, but may have occurred 
anyway. 

Reporting and 
Inspecting 

6,400 hours per year @ 
€30/hour x 28 MSs=  
€5.4m/year 

Some inspection and data collection would presumably occur 
without the ELV Directive, in virtually all MSs. Additional 
burden because of ELV Directive is hard to estimate. Low 
confidence in quality of reported data. 

Table  C-  3:  Overall  benefits  as  a  result  of  the  implementation  of  the  ELV  Directive 
(estimates) 

Element 
ATFs and shredders (EURIC) 

Total (€m/ year) 

Sale of recovered / 
removed parts 

6 million ELVs treated per year, Ademe 
estimate of €130/ELV = €780m. 

Sale of recovered 
materials (e.g. 
recycled steel) 

6-million ELVs treated, 1088kg/ ELV, 
70% Ferrous metal = 4.56 million tonnes 
million tonnes @ €235/tonne = € 1.073 
billion, 

Car industry  
Consumer good 
will from role / 
contribution of 
OEMs to ELV 
collection costs 
and use of 
reclaimed material 
Savings from use 
of recovered 
material 
Member States / citizens   
Removal of 
hazardous 

Very hard to value, but some 
manufacturers do promote their green 
credentials (though nothing specific on the 
ELV Directive specific costs has been 
seen), so it is of interest and value to some 
consumers 

Maybe low (or even negative), as virgin 
material is often lower cost than recovered 
material 

Lead removal (for example) has been 
shown to offer clear benefits in other 

ELV Directive (vs, counter factual)  

ELV Directive does nothing specific to make 
this easier (despite it being an ELV Directive 
objective), but it could be argued that the ELV 
Directive helps attract ELVs to ATFS, where the 
parts can be removed. 
ELVs would still be scrapped and the profitable 
material would be recovered without the ELV 
Directive, but the ELV Directive arguably 
increases the number of ELVs that are collected. 
Handling of hazardous and non profitable 
materials would not be regulated at the EU level, 
creating the risk of diverse national approaches. 

Car manufacturers may well have done this 
anyway, via this or some other route. 

Some (even most) MSs would have developed 
similar prohibitions, but EU wide action has 

109 

 
 
 
 
Element 
substances 

Avoidance of 
impact from 
recovered 
resources 

Total (€m/ year) 
environmental policies. The same would be 
true for removal of the prohibited 
substances from ELVs. 

GHG savings and other benefits from 
avoided extraction of virgin materials 

Level playing field 
within and 
between MSs 

Benefits to citizens and legitimate 
businesses through competing on a fair 
basis within MSs and between MSs 

Savings on second 
hand vs. new parts 

Consumers arguably benefit from access to 
recovered part, also avoids energy use in 
the manufacture of new parts. Though 
there are also risks in purchasing used parts 
of unknown history. 

ELV Directive (vs, counter factual)  
standardised this and probably made the process 
quicker (and more thorough) in several MSs. EU 
wide prohibitions obliged OEMS to act on a 
market wide basis. 

Resource recovery likely to have speeded up and 
occurred in more MSs with the ELV Directive 
than without it. 

Most MSs would have aimed to achieve this 
within their own borders, but the likelihood of 
consistency between MSs would have been 
lower 
Would have happened without ELV Directive. 
Role of ELV Directive in increasing this is 
unclear (not part of its original intention, but 
increased collection of ELVs arguably makes 
this easier) 

110