Minutes of the meeting with the European Commission
on recycling car glass, Brussels, 4th of April 2011
Subject of the meeting
ELV Directive / Diversity in Implementation by Member States
Introduction
A delegation of FERVER, composed of President Ulli Ix, Steering Committee Chairman Pieter Bartels and the Secretariat (Baudouin Ska and Hans De Belder), has been received on April 4th 2011 by Ms. Artemis Hatzi-Hull, Desk Officer of Direction C of DG Environment (Mrs. Rosalinde van der Vlies being sick).
This meeting took place just ten days after the 11th International Automobile Recycling Congress (Budapest 23/25-3-2011), organised by the IARC in Hungary, the country presently acting as Chair of the EU Council of Ministers.
Formally, the main topic of our meeting was the great diversity in the implementation by the Member States of the Directive 2000/53/EC on end-of life vehicles (September 18th 2000). Concerning the question of the recycling of car glass, particularly art. 6 (3) and Annexes I and II of the Directive were often referred to. Was also important: Page 15 of the draft report of the JoinResearchCenter, presented to the Working Group on End of Waste in Seville on the 2nd of December 2010. Finally, some decisions of the European Court of Justice (ruling C-64/09 dd.April 15th 2010 against France and Italy) are playing an important role in this issue.
Unclear targets of the Directive on End-of life vehicles
Since the Directive was approved, years of discussions were spent to the fact that in some countries car glass is removed before the car wrecks are shredded, and in other countries this is not the case. The bigger Member States, the car industry and the producers of shredding technology tend to adhere to the second group, whereas smaller countries like the Eastern European new Member States (where the car industryis not very much developed and the labour cost to extract the glass is generally lower) and of course FERVERprefer the dismantling before shredding.For the FERVER members, the preliminary dimantling is the best guarantee for an effective recycling of an average (increasing) of 30 to 35 kg of glass per car.
For Ms. Hadzi-Hull one of the problems is that the Directive did not define targets per stream, but only a global recycling target expressed in weight.
The cause or the uncertainty lies in the text of the Directive itself: there is no explicit mention of a mandatory removal of the glass fraction before shredding, only a mention to remove glass in order to promote recycling (Annex I). Since its main political objective was to protect the environment (note that is has been approved several years before the Waste Framework Directive with its much wider and very different ambitions), it leaves the possibility to the Member States to go beyond the European text, if they so wish.
If some Member States want to, they can enforce thetaking out of the glass fraction before shredding.
FERVER mentioned clearly that recovering the glass after shredding is definetely downcycling, leads to unacceptable quality and to a much lower rate of yield. Mrs. Hazdi-Hull fully supports this opinion.
Therefore, it looks like we cannot hope- at least not in the short term- that the text of the European Directive (especially Annex I) will quickly be legally amended in order to oblige Member States to come to a European uniform implementation. Letters and several questionnaires have been sent out by the Commission time and again and all kinds of arguments have been used.
Not even the decisions of the Court seem to be able to change the situation.
But considering the target of at least 95% reuse + recovery as from 01.01.2015 (art. 7,2°b of the Directive), the effective recycling of the 3% of glass will be as good as unavoidable.
Working group
The Commission has created a Working Group in order to discuss the methodology of the reporting (foreseen by the Directive). The car industry, the producers of the shredding machines, DG Environment, Eurostat, the makers of car glass, the member States i.e. the most important stakeholders areall participating in this exercise.
FERVER expressed our readiness to assist the commission in the elaboration of the European policy in this matter and to give them our advise, based on our practical experiences.
We agreed that the point of view of the glass recycling industry should be clearly expressed from now on.The Commission will invite FERVER to attend the meetings of the Working Group, starting from this summer.
Our delegation will support each initiative to specify more clearly the topics on which the Member States will be obliged to report (the grey column in the reports).
NB: DG Industry and DG Research & Innovation are also participating in the Commission’s policy strategies.
Initiatives on national level
FERVER members can take some initiatives on national level:
Ask the competent authorities to control- and report on- the effectiveness of the glass recycling, conform annex I of the Directive 2000/53 on End-of life vehicles.
Ask the member states presently applying the preliminary dismantling of glass to promote this approach on European level (in working groups, TAC and European Parliament).
HDB & BS
Coordinates Ms. Artemis Hatzi-Hull:
DG ENV-Unit C2-Sustainable Production & Consumption
Avenue de Beaulieu 5, BU 5/170
1160 Auderghem
Tél: +32-(0)2-29.52578