TO : European Commission
DG Environment, Unit G4- Consultation Directive 2000/53 EC
B-1049 Brussels
Email :
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BIL Sweden represents manufacturers and importers of cars, trucks and buses. Together our members represent 99% of all new registrations in Sweden.BIL Sweden is dealing with matters relating to automotive safety, automobile taxes, environmental protection, distribution, trade policy, traffic policy and Swedish and international regulations.
BIL Sweden • Box 26173 • SE-100 41 STOCKHOLM • Tfn: +468 701 63 60 • Fax: +468 791 23 11 • e-mail:
BIL Sweden Stockholm 2006-12-20
STAKEHOLDER CONSULTATION
FOR THE PURPOSE OF A POSSIBLE AMENDMENT OF ANNEX II
TO DIIRECTIVE 2000/53/EC OF THE EUROPEAN PARLIAMENT AND OF
THE COUNCIL ON END-OF-LIFE VEHICLES
Issue of certain spare parts for vehicles put on the market after 1 July 2003
--“Repair as produced” for remaining six entries of Annex II--
One goal of the ELV Directive (2000/53/EC, Article 4, 2(a)) is to eliminate/reduce the heavy metals Pb, Cd, Hg, and Cr(VI) within the production of vehicles - when technically feasible and avoidable.
The unavoidable exemptions are listed in the Annex II of the directive.
In future, this ensures the elimination/reduction of heavy metals in material streams during vehicle recycling and recovery. Furthermore, the directive aims to encourage recycling and reuse.
With regard to the heavy metal use prohibitions, the COMM clearly demonstrated with decision 2005/438/EC, that spare parts for vehicles put on the market before July 1, 2003, are exempted from the heavy metal use prohibitions.
The concept of "repair as produced" has been embraced, thus avoiding retroactive legislation for these vehicles already in the market and spare parts for them.
For spare parts for vehicles put on the market after July 1, 2003 still containing components profiting from Annex II exemptions, the same rule needs to be applied.
Only six remaining entries of Annex II have to be considered.
The general exemption for these spare parts is the open issue.
“Repair as produced” as a general concept and need, is essential for the automotive industry.
During various conversations with the COMM and the MemberStates, the technical arguments have brought forward.
These basic arguments are the starting point for the discussion in this Stakeholder Consultation.
Please find attached* the requested information based on the already known justifications.
* ) no attachements as BIL Sweden supports the proposals and positions already submitted by the Association of European Car Manufacturers (Acea) under : “1Request for exemptions Comments of Acea”.
Dokument11 (2)KKv