The European Automobile Manufacturers’ Association (ACEA) would like to contribute to the ongoing discussions on the evaluation of the End-of-Life Vehicles (ELV) Directive, and more specifically on the potential inclusion of heavy-duty vehicles (HDVs), ie trucks and buses. Ever since the ELV Directive was implemented back in 2000, trucks and buses have been kept outside of its scope, which is limited to the M1 and N1 vehicle categories.
The ACEA would like to take this opportunity to elaborate on manufacturers’ current efforts with regard to the end of life of trucks and buses. This position paper also explains why the situation of HDVs is not comparable to that of passenger cars.
Indeed, the automobile industry believes that an extension of the Directive’s scope to trucks and buses is not the right solution going forward, especially with the circular economy and the competitiveness of industry in mind.
Each heavy-duty vehicle is tailored to fulfil specific commercial needs for the transportation of goods and/or people. Hence, there are literally thousands of different HDVs and, unlike in the passenger car segment, there are no ‘standard’ vehicle models.
Moreover, generally speaking a truck is not a finished vehicle when it leaves the manufacturer’s production line. Body builders complete these vehicles with a wide variety of special purpose equipment (cranes, concrete pumps, refrigerator units, etc) needed to fulfil the specific task of a vehicle.
Those body builders are often small and medium sized enterprises (SMEs). The situation is similar for buses, as manufacturers deliver the vehicle chassis (including the driveline) for completion to specialised body makers, many of which are also SMEs. Customers buying buses usually decide on the interior components (like seats, ticket- vending machines, etc) themselves.
In other words, manufacturers do not have the choice to use other components (as they are a mandatory part of the tender). This means that up to three different companies (chassis manufacturer, body manufacturer and professional customer) are responsible for different components of the completed vehicle, which creates a very complex situation when it comes to the producer’s responsibility at the end of life of a truck or a bus. Furthermore, trucks are often retooled by vehicle operators during their long service life. For example, a long-haul truck might be converted into a distribution truck by a body builder after some years of long-haulage operation when reliability is decreasing, and the truck no longer meets the customer’s uptime requirements.
Should the scope of the ELV Directive be extended to completed HDVs, recycling targets cannot be set due to the sheer magnitude of customised solutions and the fact that many vehicles are re-built or converted during their service time. ACEA Position Paper: End-of- Life Vehicles Directive: Trucks and buses – January 2020 2 Certain types of trucks (such as long-haul ones) are exclusively designed for the transport of goods using trailers.