European Commission: End-of-life motorcycles must be handed in

The European Commission wants to make it mandatory to hand in motorcycles when the have come to ‘the end of their life’. FEMA’s Wim Taal explains.

The European Commission (EC) has recently adopted a Proposal for a Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles (end-of-life vehicle means a vehicle which is waste or vehicles that are irreparable).

The inclusion of motorcycles in the Regulation could mean the end of so-called home recycling. Recycling of motorcycles and motorcycle parts is an inherent part of motorcycle use. Home recycling, where you end the bike’s registration and take it apart for re-use of its parts, is a significant part of the motorcycle culture. Home recycling helps to keep bikes on the road with used spare parts, instead of using new parts that have to be produced from raw materials.

The Regulation aims ‘to cover all aspects of a vehicle from its design and placement on the market until its final treatment at the end-of-life:

Improve circular design of vehicles to facilitate removal of materials, parts and components for re-use and recycling.
Ensure that at least 25% of plastic used to build a vehicle comes from recycling (of which 25% from recycled end-of-life vehicles.
Recover more and better-quality raw materials, including CRMs, plastics, steel and aluminium.
Ensure that producers are made financially responsible for vehicles when they become waste, to ensure proper financing for mandatory end-of-life vehicles treatment operations and incentivise recyclers to improve quality.
Put a stop to vehicles going ‘missing’, through more inspections, interoperability of national vehicle registration systems, improved distinction of used vehicles from end-of-life vehicles and a ban on exporting used vehicles that aren’t roadworthy.
Cover more vehicles, and gradually expand EU rules to include new categories such as motorcycles, lorries, and buses, ensuring a proper end of life treatment.’

Wim Taal, FEMA’s Communications Officer: “Virtually all motorcycle parts can be re-used, through a large network of specialised second-hand part suppliers or by users themselves who swap and change parts with other owners. Parts that are not re-used are recycled through local recycling schemes or sent on by second-hand part shops. There is no evidence of motorcycles being dumped beside the road or otherwise disposed of in an inappropriate manner.”

Motorcycles are currently exempt from the-end-of-life directive (a position that was lobbied for by FEMA when the directive was written and adopted in the late 1990s). That will change if it’s up to the EC. The proposal obliges vehicle owners to deliver their vehicles to an authorised treatment facility when it reaches the end-of-life stage and to present the subsequent certificate of destruction for the vehicle’s deregistration to the relevant registration authority.

If adopted, this Regulation will amend Regulations (EU)2018/858 and 2019/1020 and repeal Directives 2000/53/EC and 2005/64/EC (Regulations have binding legal force throughout every Member State and enter into force on a set date in all the Member States. Directives lay down certain results that must be achieved but each Member State is free to decide how to transpose directives into national laws). The proposal will now be considered by the European Parliament and the Council.

The proposal states: ‘Two- and three-wheeled vehicles are currently not subject to any Union legislation concerning their eco-design and management at their end-of-life stages. To ensure a circular framework for all vehicles registered in the European Union, including their environmentally sound treatment, as well as to prevent fragmentation of the single market, this Regulation should also apply L-category vehicles L3e-L7e (L3e = two-wheel motorcycle, L4e = two-wheel motorcycle with side-car, L5e = powered tricycle, L6e = light quadricycle, L7e = heavy quadricycles). The requirements regarding the collection of end-of-life vehicles, their mandatory delivery to authorised treatment facilities for treatment as well as their depollution should apply to L-category vehicles (L3e-L7e). Manufacturers will be required to provide information on the removal and replacement of parts, components, and materials.’

The EC expects ‘lower prices for second-hand parts and components, meaning it will be cheaper to maintain and repair vehicles’ but does acknowledge that ‘the advanced requirements for end-of-life vehicle treatment may pose challenges for SMEs (small and medium-sized enterprises) in terms of higher short- and medium-term implementation costs and adaptation to new treatment technologies’, a possible development that was recognised in the study by Finnish FEMA member SMOTO. The SMOTO study shows that if motorized two-wheelers were covered by the directive/regulation, some of the operators specializing in their handling would have to close due to increased requirements and regulation of their activities. Most of the powered two-wheelers to be dismantled would be transported to operators who do not reuse dismantled parts efficiently, but mainly utilize them as metal waste. It would also be much more difficult to get the parts of enthusiasts.

‘We see the danger for smaller treatment facilities that currently sell used motorcycle parts; they can be overwhelmed by high implementation costs and adaptation to new treatment technologies.’

For manufacturers the proposal means they must declare in type-approval documentation the share of recycled content of indicated materials present in vehicles. It also obliges manufacturers to provide information on the safe removal and replacement of parts, components and materials contained in vehicles. This information must be accessible free of charge to waste management operators and repair and maintenance operators.

The European Association of Motorcycle Manufacturers (ACEM) states: ‘ACEM supports a comprehensive framework for the collection and treatment operations for L-category vehicles ensuring a positive contribution towards the Green Deal goals with several benefits for the society. However, further assessment of technical and economical specificities for various sub-categories should be considered to ensure a successful achievement of the ELV objectives and full alignment with other vehicles.’

In 2020 FEMA responded to the European Commission’s request for feedback, explaining why in our view motorcycles should not be included in a new directive or regulation.

If motorcycles were to be included in the scope of the directive, that could mean the end of so-called home recycling. Recycling of motorcycles and motorcycle parts is an inherent part of motorcycle use. Home recycling, where you end the bike’s registration and take it apart for re-use of its parts, is a significant part of the motorcycle culture. Home recycling helps to keep bikes on the road with used spare parts, instead of using new parts that must be produced from raw materials.

In FEMA’s view, the current Directive succeeded in preventing waste from vehicles, the re-use of parts from vehicles and improvement of the environmental performance of all economic operators involved in the life cycle of vehicles. We can also understand the need to extend the scope of the directive to other kinds of vehicles than cars.

FEMA asked the European Commission to ensure that the possibility of controlled in-house demolition remains possible (as part of a circular economy), either by including it in the Directive, or by allowing Member States to make their own rules and regulations for in-house demolition. FEMA will re-emphasise its position in communication with the EC, since this is not addressed in the proposed Regulation.

FEMA also asked the Commission to ensure that historic powered two-wheelers of value to collectors or intended for museums, kept in a proper and environmentally sound manner, either ready for use or stripped into parts, do not fall within the scope of this Directive. FEMA will re-emphasise its position in communication with the EC, since this is not addressed in the proposed Regulation.

Although FEMA supports the overall goals of the proposed Regulation, we do see the danger for smaller treatment facilities that currently sell used motorcycle parts; they can be overwhelmed by high implementation costs and adaptation to new treatment technologies.

Written by Wim Taal

Top photograph by Wim Taal