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CRM Alliance submits Evidence to the European Commission's Revision of the ELV Directive

On 26 October, the CRM Alliance submitted feedback to the European Commission's open consultation on the roadmap for the revision of the ELV Directive.

The Directive on end-of-life vehicles (ELV Directive) set clear targets for ELVs and their components. It also prohibits the use of hazardous substances when manufacturing new vehicles (especially lead, mercury, cadmium and hexavalent chromium) except in defined exemptions when there are no adequate alternatives. The exemptions are listed in annex II of the Directive.

Since this Directive was introduced, several amendments have been made (for more information, see amendments below). The EU has also introduced several related rules such as the Directive on the type-approval of motor vehicles regarding their reusability, recyclability and recoverability.

Among other issues, the CRM-A (1) supports realistic and feasible targets for re-use and recycling, (2) believes that substances should be regulated under REACH and not under the ELV Directive and (3) supports regulatory coherence with other EU initiatives, such as RoHS.

Read our submission below:

CRM-A ELV Directive October 2021
Download DOCX • 69KB

The CRM-A previously responded to the ELV Directive roadmap consultation in November 2020. To read our submission, please click below:

CRM-A ELV Directive November 2020
Download DOCX • 58KB


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