5. Aspects to improve coverage and data quality when reporting on ELVs (possible revision of the Commission Decision on ELV annual reporting)
1. Background information
Under the ELV Directive Article 7(2), the Commission is required to establish detailed rules to control Member States’ compliance with the reuse/ recovery and reuse/ recycling targets.
Accordingly, Commission Decision on ELV annual reporting lay down detailed rules on the monitoring of the above-mentioned targets in order to harmonise the characteristics and presentation of the calculations.
In order to support MSs in their efforts to produce high quality and harmonised ELV data, the Commission published two guidelines[1]:
- How to report on end-of life vehicles according to Commission Decision on ELV annual reporting
- Guidance document on “how to perform a shredder campaign”
2. Key issues regarding the Commission Decision 2005/293/EC
Because the provision in Article 1(1) in the Commission Decision on ELV annual reporting, which addresses the “appropriate description of the data used”, is not sufficiently detailed and guidance addressing this issue is not obligatory, the content and level of detail in MS quality reports submitted with the national annual data on the ELV targets is quite diverse. In addition, since the quality reports are normally not published[2], transparency is lacking.
The provisions within Article 1(3), addressing the breakdown of the national vehicle market, are also not detailed enough. A Eurostat guidance document that addresses this issue is likewise not legally binding (see above). Therefore, the coverage of information on the national vehicle market is quite diverse. In particular, the information on the export/ import of used vehicles is evidently incomplete and/or simply reported as “not available”. In addition, since accompanying information submitted together with the data is not public, transparency is also lacking.
Several MS reported discrepancies between the numbers of ELVs and CoDs issued, where most reported less CoDs than ELVs.
The current approach of reporting in table 1 and 2[3] only “Materials... of ELVs arising in the Member State and treated within the Member State” in the Commission Decision on ELV annual reporting causes difficulties since several MS cannot determine whether shredder output was exported or not. It is not clear if the materials (e.g. shredder output) treated outside the MS should be reported in table 3 of the Commission Decision on ELV annual reporting on export, and also whether a breakdown by origin is required. The exception to report metals in table 2 only (for cases applying the Metal Content Assumption) causes limited comparability and challenges for data evaluation and usability.
[1] ec.europa.eu/eurostat/web/waste/reporting/2015
[2] Some of them are available upon request
[3] Reporting tables in Annex of the Commission Decision on ELV annual reporting