The demand came in response to the Department of Trade and Industry's latest consultation on new end-of-life vehicles regulations, which will govern how motor manufacturers set up networks of Authorised Treatment Facilities (ATFs) to carry out the recycling of ELVs after 2007.
The government proposed that manufacturers should set up their networks so that on average, last owners should have to travel no more than 10 miles to their nearest ATF. And, the government suggested that no single last owner should have to travel more than 50 miles to dispose of their ELV.
But while the motor manufacturers feel this approach would not be appropriate for smaller or niche manufacturers, the MVDA urged the government to be strict about the 10 mile rule.
Making last owners travel longer distances towing vehicles or driving vehicles that have failed their MOTs would pose obvious risks, it warned. And, allowing manufacturers to form networks of dismantlers any further apart would distort free market forces, the MVDA said.
Most dismantlers are small, processing about 1,400 vehicles a year, while only 20 to 30 UK companies handle 10,000 to 20,000 vehicles a year. Altering this situation would be a “clear deviation” from the text of the Directive, the MVDA said.
Furthermore, where long distances to ATFs bring about costs or nuisance for last owners, “abandonment may be the only solution”, the association warned.
Uncontracted ATFs
The dismantlers believe it is unfair for ATFs that have not won contracts with motor manufacturers to be obliged to reach the recovery or recycling targets on behalf of manufacturers.
The MVDA went on to say that it would be “unrealistic” to legally enforce those uncontracted ATFs to provide free take back for ELVs if the market conditions are not favourable. If scrap prices were to fall, such an eventuality would bring about a “total collapse” of uncontracted dismantlers.
The MVDA said: “In reality, the (government's) proposals are sending clear signal to ATFs, 'c;ontract' or cease business if scrap metals prices fall. This is a completely unacceptable position to begin contract negotiations.”
Funding
Elsewhere in the MVDA's response, it again expressed its “total disappointment” that the government chose to pursue only the own marque option in its proposals for the new ELV regulations. The approach would make the motor manufacturers responsible for setting up ATF networks to treat and recycle vehicles they originally placed on the market.
Instead, the MVDA said the government should have opted for a levy system similar to the packaging waste recovery note (PRN) system. Costs associated with removal, storage, transportation, administration and recycling would be left to market forces. This would, the association argued, see efficiencies improve while costs for manufacturers would be likely to fall over time.
The MVDA also highlighted concerns about accruals, asking who would be responsible for paying for free take back of vehicles whose manufacturer was declared bankrupt. It said the issue had been raised by manufacturers early in the consultation process, but that it had not been addressed under the government's own marque proposal.
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