Legislation and environmental performance
Implementation
of
legislation
Developments in recycling legislation at both the national and the European level are important to ARN. These developments concern both specific product decrees – which regulate product responsibility for cars and automotive batteries – and generic legislation that regulates waste management at a European level. This European waste management legislation is implemented in the Netherlands through the Environmental Management Act.
Legislation and regulations in the Netherlands
Second part of the Activiteitenbesluit (Environmental Management Installations Decree)
The second part of the Environmental Management Installations Decree came into effect in 2009. Under this decree, a company no longer needs to apply for a provincial environmental permit; it now only needs to make a report about the activities it undertakes. This change reduces the administrative burden on the private sector. Despite the fact that policy-neutral implementation was top priority, the change does have practical implications. There is a shift from granting permits (preventive enforcement) to more active enforcement. The risk that free riders will start operating in the market has therefore increased.
ARN took part in a vehicle dismantling working group in order to make preparations for the coming into force of the second part of the Environmental Management Installations Decree. The working group also comprised representatives of the government and the vehicle dismantling sector. Together with STIBA, ARN advocated the addition of an approval decision, that is, permission of the competent authorities before an activity may be started. The objective of this assessment is to check beforehand whether the applicant company meets the tough requirements that are set for dismantling companies in order to guarantee high quality management of end-of-life vehicles such that all vehicles are accounted for.
2009 – 2021
National Waste Management Plan
The second National Waste Management Plan, which covers the period 2009–2021, came into effect on 24 December 2009. The plan states that the minimum standard for processing automotive shredder waste is thermal processing. The land-filling of shredder waste is therefore not permitted. This is consistent with the landfill ban on shredder waste that came into effect on 1 January 2009. It is possible to grant an exemption as long as there is no or insufficient processing capacity for the waste. In 2009 the low rate of waste tax incorporated in the Environmental Taxes Act (WBM) for landfilling wastes applied in regard to this exemption. The low rate applies in a limited number of cases, including hazardous waste. Shredder waste is also in this category. The low rate for hazardous waste was scrapped at the end of 2009. Since 1 January 2010, the normal waste land-filling taxation rate applies to shredder waste. The application of this normal taxation rate represents a substantial cost increase for land-filled automotive shredder waste.
Management of Batteries and Accumulators Decree
The collective notification about automotive starter batteries and high voltage (HV) batteries for hybrid vehicles was approved on 24 April. ARN agreed with SenterNovem that newcomers will be registered periodically with reference to the aforementioned collective notification. At the end of 2009, 65 importers of automotive starter batteries and hv batteries for hybrid vehicles were participating in the collective notification.
Besides ARN’s collective notification about automotive starter batteries, four individual notifications were submitted to and approved by SenterNovem.
Despite the fact that the Management of Batteries and Accumulators Decree came into effect on 26 September 2008, many importers have still not submitted an individual or collective notification. Last year ARN urged the Inspectorate of the Ministry of Housing, Spatial Planning and the Environment to hold these free riders to account and ensure that they comply with the decree.
Legislation and regulations in Europe
End-of-Life Vehicles Directive reports
In 2009 the European Commission had a study made of the reports by the Member States with regard to the End-of-Life Vehicles Directive. As these reports show significant variations, there are considerable doubts about the correctness of the recycling performances that are presented. Eurostat (the eu’s statistical organization) compared and analysed the Member States’ reports. The European Commission also commissioned an external integrity review. These investigations were worked out in greater detail by a working group. The final objective is to arrive at a uniform method with which the Member States’ reports must comply. Representatives of the Member States, the motor industry and the dismantling sector are participating in this working group. The group’s starting point is that there will be no revision of Decision 293/2005/ec – which would necessitate legal changes – and that a directive will be prepared such that the Member States can deliver unambiguous reports.
ARN is playing an active role in this working group and hopes that this will contribute to creating a level playing field between the Member States. ARN’s position in this regard is that protection of the environment must remain the top priority of the End-of-Life Vehicles Directive. Simplification of the reporting method must not lead to poorer environmental performance.
Batteries and Accumulators Directive
For the purposes of the Batteries and Accumulators Directive, preparations were made in 2009 for consultation with the Technical Adaptation Committee (TAC). The TAC supports the Commission in defining measures for the execution of a decision. The TAC consists of national officials and is chaired by a representative of the European Commission. A decision has to be taken about the calculation method for end-of-life batteries and accumulators. This decision will lead to new regulations. ARN takes the view that a plastic battery casing is an integral part of the battery and should therefore be counted in the recycling efficiency. This should also be the case if this plastic casing is used as a reducing agent in the recycling smelting process, where it replaces primary raw materials that would otherwise have to be added to the process. There is a debate going on in Europe about whether this concerns a thermal reaction, a chemical reaction, or a thermal and chemical reaction. The opinion of ARN is that the type of reaction does not alter the fact that this is an efficient recycling method.
2010 environmental performance
ARN was established in response to society’s demand for a reduction in the waste from end-of-life vehicles. This section reports on the results that have been achieved in that respect.
Starting points Rules governing the treatment of end-of-life vehicles were laid down in eu Directive 2000/53/ec (End-of-Life Vehicles Directive). In 2002, this directive was implemented at a national level in the End-of-Life Vehicles Management Decree. The decree acts as a leitmotif for all activities related to the treatment of end-of-life vehicles. For example, the decree prescribes that at least 85% of the weight of end-of-life vehicles in the Netherlands must be recycled or reused. At least 80% must be recovered by recycling or reuse, while a maximum of 5% can be achieved through energy recovery. The weight target has been increased with effect from 2015 to 95%, of which at least 85% through recycling and a maximum of 10% through energy recovery.
Various data are collected for the purposes of verifying these percentages. The European Commission has drawn up detailed rules on how these data are to be collected. European Member States must follow these rules in their reporting to the Commission in order to ensure that they report in a comparable way. The EU uses these reports to verify that the objectives laid down in Directive 2000/53/EC are being met.
The figures for the recycling percentages and the volumes of processed materials published in this report were compiled in accordance with the EU ’s monitoring rules.
Quantities recycled Table 1 presents the EU codes for the materials and the volumes of materials actually collected and processed last year. In 2009, 191,980 end-of-life vehicles were registered with shredder companies. The number of registrations in orad (the on-line vehicle dismantling registration system) in 2009 at ARN companies was 228,783. The difference between these two figures represents the stock at dismantling companies. The materials that are still at a dismantling company or held in storage by a collection company are not included in the table.
Determination of the metal content in each end-of-life vehicle Car dismantling companies provide ARN with the weights of the end-of-life vehicles that are sent to the shredder. In 2009, the average weight of the individual body shells of the 191,980 end-of-life vehicles on arrival at the shredder was 665 kg.
Determination of the weight of ARN materials Dismantling companies are obliged to remove a number of prescribed materials from end-of-life vehicles. These materials are subject to standards that are kept up to date on the basis of standard measurements and changes in the population of end-of-life vehicles. The standards and the total number of deregistered end-of-life vehicles give an indication of the total quantity of materials collected. These figures are compared with the actual quantity of collected material as given in table 1. The figures in table 1 are included in the calculation of the reuse percentage. This is based on weight data from the processing companies.
The processing companies with which ARN has a contract supply monthly quality and quantity reports. Once a year they provide data about the mass balance. These data include a declaration of the quantity of processed material that has been reused, incinerated with energy recovery and land-filled. The mass balance data are compared with the weight data from the processing and collection companies to produce a report that is based on sound figures.
The ratios of reuse, energy recovery and final removal are calculated on the basis of the mass balance data from the processors.
Fuel and LPG tanks are not included in the calculation of the recycling percentage. In 2009, 265,154 litres of fuel (diesel, petrol and LPG) and 3,235 LPG tanks were recycled in an environmentally sound manner.
Determination of the average weight of end-of-life vehicles In 2009, the average empty weight of all end-of-life vehicles was calculated to be 975.6 kg. This figure was obtained on the basis of the ORAD reports, corrected by the RDW for the weight of the driver and the fuel. The term ‘reuse’ refers to complete parts being reused, whereas ‘recycling’ is used to describe how such materials as steel, glass and plastic are used again. Finally there is ‘energy recovery’, which means that a material is used as a secondary fuel (e.g. through incineration). Energy recovery and recycling are together known as ‘recovery’
Recycling yield in 2009 The figures in table 2 show that the reuse percentage in 2009 was 85.2%, of which energy recovery accounted for 1.1%.
