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2. Methods to achieve more complete reporting on extra-EU export and ways to distinguish between exporting ELVs vs. used vehicles

1.      Background information

Extra-EU export typically refers to EU transactions with all countries outside of the EU, i.e. the rest of the world except for the European Union. Different cases may be distinguished, as presented in the following tables.

Table 1:    Extra-EU export/ import of used vehicles, absolute count[1]





253 808

1 016 415


130 207

905 633


138 009

1 003 532


141 209

1 387 896


90 232

1 631 148


114 546

1 497 640


136 328

1 153 646


139 456

947 055


Information derived from waste shipment information[2] is not applicable as the relevant European List of Waste codes 16 01 04* (hazardous) and 16 01 06 (depolluted) have a broader scope than the ELV Directive and cover also ships/ vessels, trains and aeroplanes.  

In result the data on extra-EU export is incomplete. Customs might not notice the export of used vehicles if such information is not provided by the owner. ELV shipment may be reported under the Waste Shipment Regulation[3] but not identified as ELV according the definition of the ELV Directive. In practice, it is difficult to distinguish between a used vehicle and an ELV. The Correspondents’ Guidelines No 9 on shipment of waste vehicles defines criteria for the differentiation between second-hand vehicles and ELVs. However, this document is not legally binding except for in the few Member States that incorporated the Guidelines’ content into the law, such as Austria and the Wallonia region in Belgium.


2.       Key issues

Information on export/ import of used vehicles is necessary to validate the reported numbers of treated ELVs in the Member States. Extra-EU export might be underestimated, since not all exported vehicles are reported or known to the national registers.

One crucial factor favouring the illegal shipment of ELVs is the difficulty to distinguish between ELVs and used vehicles. No EU provisions currently establish legally binding criteria[4] for such distinction.


[1]    Source: Eurostat COMEXT Foreign Trade Statistics: reporter: EU 28; shipment to/ from extra EU; Product codes: 87032 190, 87032 290, 87032 390, 87032 490, 87033 190, 87033 290, 87033 390, 87042 139, 87042 199, 87043 139, 87043 199. Download 13 May 2016.

[2]    Source: Eurostat Data on Waste Shipment:; accessed: 12 May 2016.

[3]    OJ L 190 12.7.2006, p. 1

[4]    Except for the intention of the holder to discard his/ her vehicle. Article 3(1) of the Waste Framework Directive (WFD) defines “waste” as “...any substance or object which the holder discards or intends or is required to discard...”. Therefore, if holders of a vehicle intend to dispose of the vehicle, it will be considered waste.