End-of Life Vehicle (ELV) Directive Implementation in Estonia , Valencia Peeter Eek Director General Waste Department Ministry of the Environment

Estonia - ELV Background, up to 2004 The car Register mainly registered cars and few of them was de-registered ever.... There was no incentive to de-register the car – the outcome - Motor Vehicle Register became slowly a dead souls register Even, if dismantled and and handed to scrapyards, often Vehicles remained in register as Registered Vehicle Dismantling was quiet disorganised business, often 'on grey business area', On the end of the 90-s rapidly grew criminality on metal scrap (especially on energy lines) and also on ELV- steals

Estonia - ELV Background, up to 2004 Vehickles (M1 and N1) ca 82 % from Registered items ( other 18 % are buses, trucks, trailors etc.) Source: Estonian Motor Vehicle Registration Centre

Registration of the New Vehicles by Years

Passenger cars registered – 401 cars per Th inhabitants

First registrations of passengers cars Total/ incl new cars

Number of imported vehicles into Estonia

Age pattern of the Estonian car fleet (year 2001) average on 2007 – 13 y

Distribution of car producers within the Estonian car fleet (year 2001)

Concerns with the Register of the Motor Vehicles On 2002 all Vehicles in Register, with the Certificates issued before 1993 and not presented for re-registration, was cancelled from Register (ca 40 th. Cars from Soviet period) On 2004 the COD (Certificate of destruction) was implemented as a pre-requirement for de-registration On 2005 mandatory insurance requirement for all registered vehicles was introduced (temporary de- registration is also possible) RESULT – huge amount of applications for de-registration, with the explanations, 'why the Vehicle does not exist'

Legislation – in General Waste Act 2004, - The term Product of Concern was introduced as general term for all products, falling under theproducer responsibility principle Regulation of the Government of the Republic (No 352, 13 th December 2004) Requirements for collection, take back, reuse or dispose of vehicles and their spare parts Regulation of the Minister of the Environment (No 89, 8 th July 2004 Treatment Requirements for End-of Life Vehicles

Regulation of ELV take-back Producers (= importers) organise the collection and treatment of ELV and their spare parts. The owner of the ELV should have a possibility to get rid of his/her ELV for free in the County, where he/she lives or in range of 50 km. The costs of take back, reuse and disposal of the ELV shall be covered by the producer.

Regulation of the Government : Producers, or a third parties acting on their behalf, are obliged to take back all the vehicles which have registration certificate and which are registered in the Register of Vehicles. If waste handlers or Dismantlers take back ELV-s (= issuing COD), then they are equalised on terms of treatments and recovery obligations with the Producers Collection point or treatment facility issues COD (Certificate of Destruction) which is a pre- requisite for de-registration of the ELV.

Reuse and recovery: – No later than 1 January 2006, for all ELV, the reuse and recovery shall be increased to a minimum of 85 % by an average weight per vehicle and year. Within the same time limit the reuse and recycling shall be increased to a minimum of 80 % by an average weight per vehicle and year. – No later than 1 January 2015, for all ELV, the reuse and recovery shall be increased to a minimum of 95 % by an average weight per vehicle and year. Within the same time limit the reuse and recycling shall be increased to a minimum of 85 % by an average weight per vehicle and year.

Requirement for Dismantling sites and Dismantling Sites for temporary storage of ELV shall have: a fence a guard equipment or keeping watch over site for 24 H impermeable surfaces, where ELV-s are stored decanters and cleanser-degreasers, Sites for treatment (additionally to above mentioned places): Equipments or buildings for storage of spare parts and hazardous waste containers for storage of batteries, filters and PCB/PCT- containing condensers storage tanks for the segregated storage of end-of-life vehicle fluids and gases storage for used tyres and for other flammable parts scales

Dismantling requirements: Parts which have to be removed prior to Shredding: reusable parts accumulators and liquefied gas tanks PCB/PCT-containing condensers fuel, oils, cooling liquid and all other liquids oil and fuel filters air-conditioning system fluid potential explosive components (e.g. air bags) all components identified as containing mercury

Regulation of the Minister of the Environment Before the final shredding there should be removed: catalysts metal components containing copper, aluminium and magnesium if these metals are not segregated in the shredding process tyres glass large plastic components (bumpers, dashboard, fluid containers, etc), if these materials are not separated after shredding

Practical Concerns: Financial issues On 2002 the EU Commission report estimated, that value of ELV, when treated in accordance with the requirements is ca On 2004 'hot debate' whether the ELV treatment is possible with 0 price On : Dismantlers pay for each ELV ca 100 RESULT: No ELV is delivered back to producers, hence – there have not been motivation to establish Producer Responsibility Organisation (Collective scheme)

Legal Concerns: When is Car a waste? Question by cars (or waste?) transport There are companies, which buy 'crashed cars' from other EU countries, usually newer models Those are brought to the Country 'as goods' (= not waste!) Often are those cars never registered in Producer Responsibility register – as are not registered in Vehicle Register – but are actually dismantled... So will actually 'a steam of materials' generated, which does not comply with the Reporting of de- registrations and COD-s.

System proposed by Car manufacturers and importers

ELV 'full and 'undrained'is HazW - but bought by dismantlers as ca 120 per ELV

ELV 'drained' before delivery to Dismantlers or uncompleted-ELV – Problem for reporting and supervision

ELV- cleaned, non-hazardous - often delivered so, but sometimes unclear, where were treated?

Association of Dismantlers Over 20 Dismantlers, holders of the HazW Licences Oriented as first priority to sell reusable parts Hand removal of glasses, bigger plastic parts etc., Draining of ELV Internet-based search system for re-use spare parts over all members

General operation of the system: The first reciver of the ELV issues a COD - pre-requisite for de-registration Then – removal of all liquids, re-usable parts, but also glasses, tyres, bigger plastic parts The 'treated ELV is delivered to the Shredder Company' All metals are removed, ferrous and non-ferrous metals separated All liquids are incinerated in cement kiln Tyres are recovered SLF – until now mainly landfilled, but separation of plastics for incineration is on the way Also Post-shredder technology is under the way

Shreddering the Hard-plastics from ELV (delivered to Asia mainly)

Shreddered tyres – recovered mainly as a construction material in road construction

Results On 2006 – there was de-registered ca 11 th cars, recovery was ca 82 % Actually is summary of the waste reports 'a pussle' - there is serious need to try to improve the reporting quality - Supervision is one of the key-issues to have better overview over issues: who are putting cars – and parts to the market, - what is imported as goods, but handled as waste

Concerns and Future With the growth of economy is market for reusable parts decreasing, also as difference in prices with B-quality parts is often insignificant The 'Post-shredder' treatment of SLF (shredder light fraction) seems unavoidable The de-registration of 'in fact ELV-s' should be motivated – best option would be 'car-tax' – this have been discussed already many years, as revenue tax or 'air pollution' issue – but it's most important as well to get REAL overview of ELV-s.

Thank for Your attention!