Explanatory Memorandum to COM(2004)162 - Type-approval of motor vehicles with regard to their re-usability, recyclability and recoverability

Please note

This page contains a limited version of this dossier in the EU Monitor.

dossier COM(2004)162 - Type-approval of motor vehicles with regard to their re-usability, recyclability and recoverability.
source COM(2004)162 EN
date 11-03-2004
1. OBJECTIVE OF THE PROPOSAL

This proposal for a Directive lays down the necessary provisions to ensure that new passenger cars and light-duty trucks up to 3 500 kg i are designed to comply with required minimum rates with respect to their re-usability, recyclability and recoverability.

These provisions will be included in the Community type-approval system. In respect of passenger cars, they will be part of the whole vehicle type-approval procedure, which is compulsory for all new passenger cars, since Council Directive 70/156/EEC i was amended by Council Directive 92/53/EC of 18 June 1992 i.

Directive 70/156/EEC is currently being recast with a view inter alia to extending the Community type-approval system to vehicles other than passenger cars. In the meantime, Member States will be requested to apply the provisions of this Directive to light-duty trucks through their national type-approval procedures.

Contents

1.

1.1. Required minimum rates


The relevant minimum thresholds have been set out in Directive 2000/53/EC of the European Parliament and of the Council of 18 September 2000 on end-of-life vehicles i. In application of Article 7 i of that Directive, new vehicles put on the market three years after the adoption of an amendment to Council Directive 70/156/EEC shall be designed and constructed as to be :

- re-usable and/or recyclable up to 85 % by mass i;

- re-usable and/or recoverable up to 95 % by mass.

These provisions will apply to new types of vehicles to be approved and to new vehicles already covered by an approval, put on the market three years after the entry into force of this Directive.1.2. Amendments to Directive 70/156/CEE

As second feature, the proposal creates the necessary binding links with Directive 70/156/EEC, in particular to include in Annex I of this Directive all relevant technical information necessary for type-approval applications.

2.

1.3. Marking of component parts


At the dismantling stage, it is important to identify the materials constituting the component parts that are made of polymers or elastomers in order to avoid the mixing of incompatible products. The component parts, which are concerned in this Directive, are those listed in the dismantling list the manufacturer has to present to the approval authority.

Appropriate markings shall be made in accordance with Commission Decision 2003/138/EC of 27 February 2003 i.

3.

1.4. Re-use of component parts


Lastly, the proposal includes, in accordance with Article 7 i to Directive 2000/53/EC, a list of component parts that shall not be re-used in the construction of vehicles, because they could give rise to safety or environmental hazards.

These provisions shall apply 12 months after the entry into force of the Directive.

4.

2. LEGAL BASIS


The proposed measures are based on the assumption that the more re-usable, recyclable and recoverable new vehicles are, the easier it will be to achieve the targets set in Article 7 i of Directive 2000/53/EC, when those vehicles reach the end of their life. Article 7 i of the same directive provides for the minimum thresholds concerning re-usability, recyclability and recoverability relating to new vehicles.

Article 7 i of Directive 2000/53/EC requires that the measures to be adopted have to be incorporated within the whole vehicle type-approval procedure.

Since the beginning, the Community type-approval system has been firmly anchored on the principle that only total harmonisation of the legislations of the Member States can guarantee the free circulation of goods. Therefore, the proposed measures, which will affect significantly the construction of vehicles, can only be implemented through a single binding set of Community rules.

Therefore, Article 95 of the Treaty establishing the European Community has to be the legal basis with regard to this proposal for a new Directive.

5.

3. BACKGROUND


6.

3.1. Recycling targets


Article 7 i of Directive 2000/53/EC obliges Member States to adopt appropriate measures at national level, to ensure that specified targets are achieved with respect to re-use, recycling and recovery of end-of-life vehicles. As a first step, stated targets must be met no later than 1 January 2006. The second step will start in January 2015 and will require compliance with more stringent targets.

With a view to achieving these objectives, manufacturers shall develop and shall put on the market new vehicles, which comply with requirements that are sufficiently stringent as to ensure that targets will effectively be met when these vehicles will reach the end of their life i. This is the purpose of Article 7 i to Directive 2000/53/EC, which provides for the appropriate minimum thresholds in respect of construction of new vehicles.

7.

3.1.1. Safety or environmental hazards


One of the main objectives of Directive 2000/53/EC is to avoid the final disposal of waste by promoting the re-use, recycling and recovery of vehicle component parts. Article 7 i of that Directive requires, however, that the re-use process must not be prejudicial to requirements regarding the safety of vehicles and to requirements regarding the protection of the environment.

Article 7 i of Directive 2000/53/EC prescribes the Commission 'to take into account as appropriate the need to ensure that the re-use of components does not give rise to safety or environmental hazards when proposing the amendment to Directive 70/156/EEC.'

Insofar as Directive 70/156/EEC relates to type-approval of new vehicles only, the Commission has taken the view that certain component parts of vehicles shall not be re-used in the construction of vehicles.

8.

4. SUBSIDIARITY


The principles of subsidiarity and proportionality enshrined in Article 5 of the Treaty have been taken into account.

The main objective of this proposal, in connection with Directive 2000/53/EC, is to protect the environment and human health by reducing, to the largest extent as possible, the final disposal of waste from end-of-life vehicles. Measures concerning the construction of vehicles in order that the targets assigned to the Member States will be met, must be taken in the frame of the achievement of the internal market, which implies the avoidance of barriers to trade within the Community. It has been experienced that such objectives cannot properly be attained by the Member States on account of the scale and impact of the action and may therefore be attained more effectively at Community level.

This Directive does not go beyond what is necessary to reach these objectives.

9.

5. INVOLVEMENT OF INTERESTED PARTIES


10.

5.1. Position of the Member States


The representatives of the Member States have been informed of the content of this proposal on a number of occasions via the Commission's Consultative Group, the Motor Vehicle Working Group, which is made up of representatives of the Member States, the industry and non-governmental organisations.

The majority of the Member States supports the proposal but one Member State could only support the enforcement of the Directive to new vehicle types and not to vehicles already in production.

Another Member State has stated that it favoured a global approach with respect to design aspects of new vehicles in this area. It suggested to include, in this proposal for a Directive, type-approval requirements implementing some provisions already provided for in Directive 2000/53/EC, such as the ban on heavy metals, the permitted exemptions to the ban and the marking of polymers.

11.

5.2. Position of the industry


The manufacturers associations expressed reservation about the fact that provisions concerning design features in relation to end-of-life vehicles could be included in the Community type-approval process. They would have preferred that it would be required only a single assessment of the manufacturers capability to gather data received from suppliers and to manage these ones in such a way as to ensure compliance with the requirements at the stage of the development of a new vehicle.

They advocated that a type-approval procedure would require a huge amount of data to be compiled and submitted to the approval authorities.

They oppose that the Directive should apply to vehicle types already in production. They argue that the design of those vehicles would require significant changes aiming to facilitate the dismantling of component parts and to include new materials. Should the institutions adopt the Directive as proposed by the Commission, a longer lead-time period would be necessary for suppliers and manufacturers to take such technical changes into account before to integrate them in their production schedules.

The suppliers association is supporting the proposal. However, it regrets that Article 7 i of Directive 2000/53/EC has not been extensively taken into account. The association suggested that the Commission would include appropriate provisions in order that dismantled component parts be submitted to quality control checks before they can be re-used on vehicles in service. These quality checks should be incorporated into the Community legislation, taking into account that there exists no international standard covering that area.

12.

6. CONTENT OF THE PROPOSAL


13.

6.1. The whole vehicle type-approval


Since 1998, Directive 70/156/EEC has successfully imposed the Community whole vehicle type-approval as the unique procedure capable of ensuring that vehicles comply with the harmonised technical rules of the European Union, thus enabling the creation of the single market in the automobile sector.

All passenger cars are now concerned by such harmonised procedures.

On the occasion of the recasting of Directive 70/156/EEC, the principle of a unique, Community type-approval system will be extended to commercial vehicles and to light-duty trucks in particular. This is scheduled to be operational in 2006.

The Community whole vehicle type-approval includes the following features :

- harmonised implementation within the Member States;

- effective controls performed by governmental authorities on prototypes of vehicles ;

- granting of type-approvals when requirements are fulfilled, withdrawing of type-approval when the requirements are no longer fulfilled ;

- checks performed during the production process.

The system is credible only if the manufacturer can demonstrate to the authorities that he is manufacturing each vehicle in conformity with the approved type. Regular checks organised in the manufacturing premises are the determining factor guaranteeing confidence in the type-approval system.

For such purposes, the Community type-approval procedure entails an initial assessment of the conformity of production arrangements put in place by the manufacturer to ensure effective control of the conformity of vehicles to the approved type during the production process.

Community whole vehicle type-approval is granted to a vehicle type after the approval authority has ascertained that it complied with the requirements of all applicable separate Directives listed in Annex IV or Annex XI to Directive 70/156/EEC.

As soon as it has been adopted, this Directive will complete the list of the required separate Directives and will bear the reference number 59. Consequently, no Community whole vehicle approval will be granted to a vehicle type if this last does not comply with this proposed Directive.

14.

6.2. Specific requirements for type-approval in accordance with the proposed Directive


15.

6.2.1. Preliminary assessment of the manufacturer


The proposal provides for a preliminary assessment to be carried out by the competent authority appointed by a Member State before granting any type-approval.

The purpose of this assessment is to ensure that the manufacturer effectively has control over the relevant inputs received from its suppliers with respect to materials and is able to monitor the information. As part of the preliminary assessment procedure, the manufacturer must demonstrate that he manages properly the collection of relevant data received from his suppliers with a view to calculating the recyclability and recoverability rates for any version within a vehicle type to be produced.

In the framework of the preliminary assessment, the manufacturer will advise the authority of the strategy he recommends in the field of re-use, recycling and recovery. The relevance of the process that he is recommending has however not to be assessed by the competent authority.

After the competent authority has completed all the necessary checks, it will issue a certificate to ascertain that the manufacturer satisfies to his obligations under this Directive. This certificate is designated Certificate of Compliance with Annex IV.

The competent authority must have skilled experience in the field of the certification of quality management systems. This authority can be the type-approval authority itself but could also be a specialised body. These measures are in conformity with Council Decision 93/465/EEC, which lays down the modules for conformity assessment.

16.

6.2.2. Procedure to be applied with respect to type-approval


Compliance with the requirements of this Directive shall be verified in accordance with the general rules governing the type-approval of a vehicle.

The manufacturer shall demonstrate to the satisfaction of the approval authority that the vehicle type has been designed and constructed to meet the recyclability and recoverability thresholds laid down in the proposed Directive.

With respect to the calculation of the recyclability and recoverability rates, calculation sheets, conforming to the standard ISO 22628 : 2002, shall be submitted to the type-approval authority or to its appointed technical service before the vehicle could be granted a type-approval. Insofar as the calculation of the rates is deeply influenced by the breakdown of the materials in the various categories provided for in the calculation sheet, the materials breakdown shall be part of the information to be submitted.

The approval authority in turn has to validate the calculation in the light of the strategy recommended by the manufacturer in the field of the prevention of waste from end-of-life vehicles, which is properly documented in the enclosures to the Certificate of Compliance.

For the sake of simplification, and for the purposes of type-approval only, detailed calculations will be restricted to one or several vehicles - the so-called reference vehicles. They shall be chosen amongst the versions within a type that will constitute the greatest challenge in the area of re-usability, recyclability and recoverability.

Lastly, physical controls shall be conducted by the authority or the appointed technical service on vehicle prototypes to verify the information submitted by the manufacturer and its suppliers, in terms of markings, nature of the materials, masses of component parts, e.g. bumpers, seats foam, volume of the tank, volume of reservoirs etc. including mass of the vehicle.

6.2.3. The concept of the reference vehicle

A vehicle type belonging to the category M1 generally includes a number of technical variants - up to 100, even more in the case of category N1 vehicles -, each variant being in turn sub-divided into versions.

To date, the trim level (i.e. the interior arrangement and the options proposed to compete on the market) has never been formally taken into account for the purposes of type-approval; in particular the trim is not included in the criteria defining versions. However, in the case of calculation of recyclability and recoverability rates, it will without doubt play an important role.

After investigation, it has been concluded that incorporating the commercial execution of a vehicle explicitly within the criteria for defining versions would generate an appalling administrative burden for both manufacturers and type-approval authorities.

Therefore, detailed calculations will be restricted to those vehicles - the reference vehicles - that will constitute the greatest challenge in the area of re-usability, recyclability and recoverability.

These vehicles will be chosen by the approval authority amongst the different versions within a type in agreement with the manufacturer. The following criteria shall be taken into account :

- the kind of bodywork i;

- the available trim levels

- the available optional equipment which can be fitted under the manufacturer's responsibility.

17.

6.3. Re-use of component parts


18.

6.3.1. General


In order to ensure that road safety and the protection of the environment are not impaired by the re-use of component parts, a list has been drawn up of component parts, which are not allowed to be re-used in the construction of new vehicles i. They are listed in Annex V.

These parts play a major role in the protection of vehicle occupants and in the safe use of vehicles. Their re-used in another vehicle after they have been dismantled from end-of-life vehicles entails serious risks for the following reasons :

- they have been designed for a specific type of vehicle and their use in another type could give rise to problems of compatibility or,

- they might be removed from vehicles involved in accidents in which, for example, their pyrotechnic actuators may have been activated or,

- their intensive use during the lifetime of the vehicle could render them unfit for safe re-use.

Up to now, there exists no particular harmonised legislation to ensure that re-used component parts continue to offer the same level of performance that is required to obtain type-approval. Consequently, the relevant separate Directives apply for such purposes. In this respect, it must be underlined that most of the component parts which are listed in Annex V cannot be tested on new vehicle types because the test procedures require destructive or durability tests to be performed on several samples.

19.

6.3.2. Environment related issues


Component parts such as catalytic converters and exhaust silencers, dismantled from end-of-life vehicles, cannot be guaranteed to offer the required level of environmental protection. It is indeed extremely difficult to check whether dismantled parts from end-of-life vehicles will meet the durability requirements as provided for in the relevant separate Directives.

Catalytic converters as any emission control device are covered by conformity of production requirements contained in Directive 98/69/EC of the European Parliament and of the Council of 13 October 1998 i amending Council Directive 70/220/EEC i of 20 March 1970 relating to emissions. Section 7 of that Directive provides for durability requirements for a period of 80 000 km or 100 000 km, depending whether Euro III or Euro IV requirements apply.

Exhaust silencers are tested on vehicles during pass-by tests in accordance with Council Directive 70/157/EEC of 6 February 1970 i as last amended by Commission Directive 1999/101/EC of 15 December 1999 i. Noise tests are first performed on vehicles fitted with brand new silencers and after they have been conditioned during a lifetime cycle of 10 000 km. Such tests cannot by nature be performed with re-used silencers.

20.

6.3.3. Safety related issues


Appropriate separate Directives provide for test procedures to ensure that component parts such as safety-belts and air-bags will operate safely in the case of accidents. The test procedures entail resistance tests to traction as well as durability tests on retractors which can only be performed on prototype parts representative of production parts. Such tests performed on re-usable component parts would render them unfit for use.

Seat-belts assemblies are covered by Council Directive 77/541/EEC of 28 June 1977 i as amended by Commission Directive 2000/3/EC i of 22 February 2000.

In most of the recent passenger cars, seat-belts are bolted to anchorage points fitted to the front seats. The inboard anchorage is generally provided with a pre-tensioner system which is actuated by a pyrotechnic actuator in the case of impact. Such a restraint system needs to be tested when attached to the seat under simulated impact conditions. In such cases, the traction forces are undergone both by the seat-belts, their anchorages and the seat rails.

Council Directive 74/408/EEC of 22 July 1974 i as amended by Commission Directive 96/37/EC i prescribes the necessary tests to be performed. As said in the previous paragraphs, such tests performed on re-usable safety-belts fitted to seats and the seats themselves would render them useless.

With respect to air-bags, the system consists of air bag modules located in the steering wheel and in the dash-board for the passenger module, deceleration sensors and a diagnostic unit. Recent evolutions have led to the development of side-air-bags which deploy in the space between the upper torso and the door trim in case of side impacts. The front side-air-bags (and those at the rear if fitted) are integrated into the seat backs.

Air-bag systems are tested during impact tests performed on whole vehicles. Directive 96/79/EC of the European Parliament and of the Council of 16 December 1996 i on frontal impact and Directive 96/27/EC of the European Parliament and of the Council of 20 May 1996 i on side impact provide for test procedures. As already stated for seat-belt assemblies and seats, tests performed on vehicles would render re-usable air-bags unfit for use.

Steering lock assemblies including immobilisers are subject to type-approval in accordance with Council Directive 74/61/EEC of 17 December 1973 i as amended by Commission Directive 95/56/EC of 8 November 1995 i. The steering lock assembly fitted to the steering column of the vehicle has to undergone durability tests during 2 500 locking cycles in each direction before the approval can be granted. Here also the re-use of these parts cannot be subject to type-approval.

21.

6.4. Implementation


Measures regarding recyclability and recoverability shall apply to all new vehicles put on the market 36 months after the entry into force of this Directive.

Under Article 7 i of Directive 2000/53/EC, these measures only apply to vehicles covered by Community type-approval procedures. They will apply to passenger cars through the Community whole vehicle type-approval system, since Community type-approval is compulsory only for this category of vehicles. However, light-duty trucks will be included in the Community type-approval procedures as soon as the recasting of Directive 70/156/EEC has been adopted. It is therefore proposed that the directive be compulsory even in the case these vehicles are covered by a national type-approval.

The proposed timetable for the different categories of vehicles is as follows:

>TABLE POSITION>

The provisions concerning re-used parts shall apply as soon as the Directive has been transposed by the Member States.

22.

6.5. Content of the proposal


23.

6.5.1. General


The proposal contains 13 articles and six annexes.

24.

6.5.2. Articles 1 to 7


These articles contain the general requirements, which are further detailed in the Annexes.

25.

6.5.3. Exemptions (Article 3)


26.

6.5.3.1. Special purpose vehicles


Special purpose vehicles are specifically excluded from Article 7 of Directive 2000/53/EC by virtue of Article 3 of the same Directive.

These vehicles are defined in Annex II to Directive 70/156/EEC, as amended by Directive 2001/116/EC. They includes, as a general rule, vehicles designed for performing a specific function such as motor caravans, armoured vehicles', ambulances, hearses etc.

A large number of special purpose vehicles belonging to the light-duty trucks family are multi-stages built vehicles; that means that they receive special bodywork arrangements at the final stage of their construction, outside the manufacturer's premises. Because the manufacturer of the base vehicle does not know at the time of its development which kind of bodywork will be fitted to the vehicle, it is rational to exempt them from this Directive.

6.5.3.2. Completed light-duty trucks

Many light-duty trucks are unit-body vehicles but manufacturers also produce chassis-cab vehicles consisting of a complete cabin, with engine, axles, suspension fitted and provided with frame-members. Those so-called base vehicles are completed during a multi-stage construction process, by adding component parts and bodywork.

The proportion of chassis-cab vehicles varies from manufacturer to manufacturer. However, a proportion of 40 %, as a mean value within a single type of vehicle is commonly observed in the production of light-duty trucks.

For the same reasons as invoked in the third indent of paragraph 6.5.3.1. above, they have to be exempted from the scope of this directive.

However, the chassis-cab vehicles are not exempted from the provisions of this directive and must comply with all the requirements including the required minimum rates.

6.5.3.3. Vehicles produced in small series

'Small series vehicles' must be understood as a family of vehicle type put into service at a maximum quantity of 500 vehicles a year, in each Member State.

By virtue of Article 8(2)(a) of Directive 70/156/EEC, Member States may exempt vehicles produced in small series from one or more of the provisions of a separate directive. This is also confirmed by Article 3 i to Directive 2000/53/EC which states that Members States may exempt vehicles produced in small series from the provisions of Article 7 i.

While passenger cars built in small series falls under the Community whole vehicle type-approval system, light-duty trucks built in small series are type-approved at national level.

Consequently, until harmonised provisions in respect of small series production are adopted, it is proposed to exclude de jure these vehicles from the provisions of this Directive.

However, for safety and environmental reasons, they shall not be fitted with the re-used parts listed in Annex V.

27.

6.5.4. Preliminary assessment of the manufacturer (Article 6)


Article 6 contains the general provisions concerning the preliminary assessment of the manufacturer.

The preliminary assessment of the manufacturer is the most appropriate method to ensure that calculations are properly made in accordance with ISO 22628 : 2002. In so far as a vehicle is constituted from 10 000 to 20 000 component parts, calculations cannot be checked deep into details at the time of the type-approval of a vehicle ; for this reason, it is highly preferable to proceed by an assessment of the system put in place by the manufacturer to ensure that the whole calculation process works properly and can be used for the purposes of approval of any type of vehicle.

Annex IV, to which Article 6 refers, explains in details which practical arrangements the manufacturer has to put in place to fulfil his obligations. These arrangements have to be assessed by the competent authority appointed by the Member State according to specific criteria. Once the competent authority has carried out the preliminary assessment, it will grant a certificate of compliance to the Annex IV to this Directive.

Article 6 also lays down provisions concerning the content of this certificate, its validity and the procedure to be followed to obtain its renewal or extension when it expires. Appendix 1 to Annex IV shows the model to be used by the competent authority.

28.

6.5.5. Re-use of component parts (Article 7)


This Article concerns the ban on the re-use of some component parts. The component parts listed in Annex V cannot be re-used in the construction of new vehicles.

29.

6.5.6. Amendment to Directive 70/156/EEC (Article 8)


This Article refers to Annex VI which includes all the administrative adaptations that are necessary to establish a binding link with the type-approval procedures described in Directive 70/156/EEC and the proposed Directive.

30.

6.5.7. Articles 9 to 13


Those Articles relate to the implementation measures, and to the procedure to be followed to adapt this Directive to scientific and technical progress.

31.

6.5.8. Annex I


Annex I contains the technical provisions that have to be fulfilled in order to obtain type-approval.

32.

6.5.9. Annex II and Annex III


Annex II sets out the documents needed for the submission of applications, while Annex III sets out the model of the approval certificate, which has to be used for the granting of an approval.

33.

6.5.10. Annex IV


Annex IV describes in detail the necessary arrangements the manufacturer has to put in place in a view of obtaining a certificate of compliance and be further allowed to introduce applications for type-approvals.

34.

6.5.11. Annex V


This Annex lists the component parts, which must not be re-used. The coverage of this annex is restricted to re-use in the construction of vehicles, since the scope of this Directive is limited to the approval of vehicles.

35.

6.5.12. Annex VI


In accordance with Directive 70/156/EEC, a manufacturer may apply for a Community vehicle type-approval without being obliged to apply for the whole set of separate Directives listed in Annex IV to that Directive. Therefore, it is necessary to include also the particulars listed in Annex II of this Directive in the information document to be used for whole vehicle type-approval.

36.

7. ECONOMIC ASPECTS


37.

7.1. Impact on Automotive Industry


The impact on the automotive industry is substantial. In the year 2002, about 15.7 million new passenger cars and new light-duty trucks have been put on the European market i.

Quantitative long-term forecasts show no sign whatsoever of stagnation. In terms of vehicle fleet, it is to be expected that the number of passenger cars and light-duty trucks in circulation will increase by 18 % between 2000 and 2014, i.e. from 174 million passenger cars in 2000 to 206 million passenger cars in 2014 i.

Every year, between 9 and 10 million of vehicles reach the stage of end-of-life vehicles. That means that end-of-life vehicles will generate in the Community between 8 and 9 million tonnes of waste every year.

In France, where agreements between the competent authorities and the economic sectors concerned to promote reuse, recycling and recovery exist since more than 20 years 1.2 million end-of-life vehicles produced, before the implementation of Directive 2000/53/EC, 400 000 tonnes of waste i, each year.
& Automobile - Rapport 2001 PSA Peugeot Citroën

38.

7.2. Trends in the construction with regard to end-of-life treatment


The environmental and economic impact of end-of-life treatment is influenced by the material regime prevailing in production as well as by design and assembly methods that affect the share and the amount of recoverable materials.

Most of the vehicles now reaching the end-of-life stage were designed in the late 1980s and early 1990s at a time when ongoing policy developments on recycling may not have greatly influenced their design. They may incorporate a high share of materials with low recycling potential.

Significant changes have occurred in materials regime in recent years, based on the shift towards materials that are lighter and easily recyclable. The following table shows a comparison between the average material composition in percentage by mass of passenger cars produced in the first half of the 1990s and modern passenger cars produced in early 2001.

>TABLE POSITION>

It was probably in the early 1990s that the need to incorporate end-of-life measures in the design of new vehicles was first realised. At that time, bilateral agreements were concluded between Manufacturers and Governments, first in France and in the Netherlands, later in other Members States with a view to setting realistic recycling and recovery targets.

The concept design to be recycled was very soon brought into the design features of European vehicles. It is a fact that since several years, European manufacturers have been developing research work and a significant experience has already been built up in the area of recycling processing.

With respect to recyclability, key factors are the choice of the materials, the appropriate marking of components and the assembling techniques. These ones can only ensure that component parts will be properly separated and recovered.

Instead of focusing on the metals used in manufacturing, manufacturers generally prefer to increase the proportion of plastics and of organic natural materials to reduce vehicle mass and consequently fuel consumption. With their increasing use, the recyclability issue of these materials has become more important than ever before. As of now, almost 15% of plastic component parts are made of recyclates and this proportion should rise as market conditions and technical feasibility develop.

Natural fibres and other renewable raw materials are also being increasingly used, mainly for soundproofing. The potential for further development of these materials is very promising for they are light-weight, have a favourable environmental balance and are cheaper than other materials.

39.

It should be underlined that a certain number of vehicle manufacturers have announced that they already meet the targets, which will be introduced by this directive.7.3. Costs assessment


40.

7.3.1. General


Economic impact on the development of new vehicles in order to meet the targets set out in this proposal has to consider several steps :

- development of new vehicles;

- assembly of such vehicles;

- treatment of the end-of-life vehicles;

- type-approval.

41.

7.3.2. Impact on the development of vehicles


The measures envisaged require a full check of materials composition, which includes a continuous input from a materials database at each stage of the development of the prototype. Materials must be selected also on the basis of recycling properties as well as that of a pure technical analysis, which could increase the costs.

New materials will need appropriate validation procedures, which are very costly.

However, the availability of high quality recyclates will certainly lead to a fall in the price of certain component parts.

42.

7.3.3. Impact on assembly


Design for dismantling will lead to higher costs due to re-arrangements on the production line. Economic recycling imperatives will in fact mean redesigning assemblies in a more monolithic way in order to facilitate dismantling.

For example, dash-boards will have to be assembled preferably in one piece to be secured by bolts on the vehicle.

43.

7.3.4. Impact on the treatment


New technologies will have to be introduced to reduce after-treatment costs. Technologies proved to be efficient already exist. However, heavy investments will be necessary to work at a large scale to reduce costs and promote the use of recyclates.

44.

7.3.5. Impact on type-approval


Costs relating to type-approval will increase significantly because representative vehicles will have to be built for checks by the authority. Vehicles conforming to the production specifications do not exist usually at the prototype development stage but are available only at the pre-series stage, just before the launch of a new vehicle type.

The situation is similar with respect to suppliers; for this reason, component parts, such as complete dashboard, seats etc., will have to be prepared specially to be presented to authorities for control of materials and masses.

Calculation checks and preliminary assessment of the capacity of the manufacturer to monitor all data will require specific examination at the manufacturer's premises. Even if test witnessing at the manufacturer's premises is not exceptional in the world of type-approval, this proposal for a new Directive will enshrine it as a rule. Specific arrangements, including workshops and means of investigation will be required.

45.

7.4. Cost-benefit analysis


46.

7.4.1. Costs for the manufacturer


Because the inputs necessary to a detailed cost-benefit analysis are not available in the technical literature, it is extremely difficult to predict what investments manufacturers will have to make to fulfil the requirements of this Directive.

The European Automobile Manufacturers Association has presented to the Commission a provisional assessment, which can be summed up as follows, with respect to a medium-size vehicle in the European car segment C i.

- production and development costs : increased by between EUR 11 to EUR 55 per vehicle;

- cost savings due to ELV treatment : ranging from EUR 5 to EUR 25 per vehicle.

This association estimates the balance ranging from EUR 14 benefit to EUR 50 additional costs per vehicle.

Assuming a mean cost value of EUR 30 per vehicle, a production plant producing 280 000 passenger cars a year will generate a yearly cost increase of EUR 8 400 000.

An additional input is given by the type-approval procedure that has to be implemented. Type-approval costs are mainly calculated on the basis of fees due to technical services, including the administration costs. It is to be expected that the preliminary assessment procedure and the checks to be performed on vehicles will take up to 5 days in investigating manufacturers' data. Based on an hourly rate of EUR 135, the costs of the type-approval tests could equate to some EUR 7 500 per vehicle type.

In addition, the type-approval procedure will generate internal costs such as investments in new computer tools and in organisational systems. One-off compliance costs and engineering expenditures will also have to be included in the total costs covering the type-approval activities.

All these costs depend on the structure of the enterprise and can not be easily described in qualitative terms. For example, one major European manufacturer has calculated that type-approving one vehicle type will cost on average EUR 11 650 i.

As example, a single type of a popular passenger car was produced at 2 777 962 units during a period of 10 years ; the cost per vehicle resulting from type-approval is therefore insignificant. With respect to light duty-trucks, models in great demand are produced at a rate of 75 000 vehicles a year. Assuming that four kinds of bodywork will require close examination for granting type-approval, then cost per vehicle s insignificant, if the type remains unchanged for more than 10 years.

47.

7.4.2. Benefits


Benefits should be seen from the environmental policy point of view and should be assessed in the global framework of the end-of-life vehicles Directive, which is not the subject-matter of this directive.

48.

8. CONCLUSION


The Commission takes the view that the measures it is proposing will guarantee that manufacturers develop and put on the market new vehicles which will permit the main objective of Directive 2000/53/EC to be met : the prevention of waste from vehicles by promoting the reuse, recycling and recovery of component parts and materials.

It is also confident that the ban on the re-use of certain parts in the construction of vehicles will benefit road safety and protection of the environment.