Communiqué on Technical Procedures for the Storage, Depollution, Dismantling and Treatment of End-of-Life Vehicles

The Communiqué on Technical Procedures for the Storage, Depollution, Dismantling and Treatment of End-of-Life Vehicles was published in Official Gazette No. 27986 of 6 July 2011. Its purpose is to set the criteria that end-of-life vehicle (ELV) collection points, temporary storage areas, individual storage sites and treatment facilities must meet (Articles 1 and 2). It is based on the Regulation on the Control of End-of-Life Vehicles, published in Official Gazette No. 27448 of 30 December 2009 (Article 3). The communiqué is therefore the technical arm of the regulation for facilities.

Which facilities does the communiqué cover and what does it regulate?

It covers four kinds of sites: ELV collection points, temporary storage areas, individual storage sites and treatment facilities. A collection point is where economic operators take vehicles over from their owners and complete the vehicle deregistration and disposal form; a temporary storage area is a facility where vehicles are depolluted and dismantled and the parts removed are made ready for reuse (Articles 5 and 6).

What conditions apply to collection points and temporary storage areas?

At collection points the ground is covered with concrete, vehicles that have been in accidents are covered with a tarpaulin, and a fixed sign is displayed. Vehicles brought to a collection point may not be kept for more than sixty days, no more than ten vehicles may be held, and the vehicles are sent within sixty days to a contracted temporary storage area holding an environmental permit and licence. Collection points cannot be set up inside CNG and LPG filling stations or cylinder-filling plants. Compliance is documented by a letter of conformity from the provincial environment directorate (Article 5).

A temporary storage area consists of an ELV storage section, an administrative office, a workshop, a reusable parts store and a waste store (Article 6). In the ELV store, vehicles are held to be depolluted within thirty days; the floor is sloped and impermeable, and there are grated drainage channels and an oil separator (Article 7). Impermeability of the site floor is achieved with mesh-reinforced concrete of a specified slope and thickness (Article 12).

How are depollution and dismantling carried out in the workshop?

Operations in the workshop follow the order listed in Article 9. First the vehicle dismantling manual or the International Dismantling Information System is consulted; the battery is removed, the fuel tank and any LPG tank are emptied, air-conditioning gases are extracted by vacuum, and fluids such as engine, gearbox and hydraulic oils, antifreeze and brake fluid are drained. Airbags are removed at least twenty minutes after the battery has been taken out.

Next the catalytic converter and the parts marked in Annex 2 of the Regulation as containing hazardous substances are removed; reusable parts are cleaned, barcoded and entered into the Ministry’s data system; and tyres, wheel rims and lead balance weights are removed. Airbags that will not be reused are destroyed by detonation in a special area that meets safety requirements.

What does it mean for destruction and recycling?

The communiqué determines where each stream coming out of an end-of-life vehicle goes. Reusable parts require a closed store of at least 100 square metres with shelving and a reinforced concrete floor (Article 10). The waste store has three sections, for liquid waste, solid waste and scrap; wastes such as batteries, accumulators, filters, catalytic converters, parts containing hazardous substances and neutralised airbags are stored by group in separate containers, and recovery and disposal of the wastes is arranged at facilities holding an environmental permit and licence appropriate to the waste codes (Article 11).

Ferrous and non-ferrous metals, large plastic parts, glass, textiles, rubber, tyres and composite parts are kept in the scrap store in bays enclosed on three sides. Treatment facilities do not accept vehicles and parts that have not been depolluted and dismantled in temporary storage areas, and prepare the scrap for recovery or disposal by cutting, shredding and grinding (Article 19).

What should be watched in practice?

Custody depots, ELV parts depots and insurers’ damaged-vehicle depots count as individual storage sites; depollution, dismantling, cutting and shredding may not be carried out at them (Article 18). Their conditions are also documented by a letter of conformity from the provincial environment directorate.

The communiqué builds a chain that prevents temporary storage areas from sending vehicles to treatment facilities without depollution and dismantling, and treatment facilities from accepting them. Temporary storage areas must also send the deregistration and disposal forms to licensed scrap metal treatment facilities, which deliver them to the Ministry in bulk by the end of February of the following year (Article 19). The periods in the provisional articles for existing facilities have expired; anyone investing in new facilities should rely on the current consolidated text of the communiqué.