Select Committee on Trade and Industry Appendices to the Minutes of Evidence


APPENDIX 7

Memorandum by Honda

IMPACT OF THE END OF LIFE VEHICLE DIRECTIVE

  Honda (UK) welcomes the Trade and Industries Committee effort to understand the main issues with the End of Life Directive and the economic impact this will have on the car industry.

  To assist the Trade and Industry Committee we would like to highlight the issues that greatly concern us with the Government Consultation Document published 10 August 2001.

  Our three key concerns are:

  1.  In implementing the Directive we would urge the Government to respect the dates established in the Directive for the introductive of the free take back obligation. 2002 for new vehicles and 2007 for the existing vehicle parc. It should be noted that no other member state is considering early implementation of the Directive.

  2.  The cost of compliance with the Directive will have a significant effect on the Honda (UK) financial status.

    —  Various economic operators benefit economically from a car during its lifetime, we strongly believe that the cost of treating End of Life vehicles should be shared between the different economic operators. We would like to recommend that a committee be set up to look specifically at this subject. We see the economic operators as the fuel companies, insurance companies, retailers, service and maintenance outlets, manufacturers and importers. This concept has already been applied to Packaging Waste Regulations.

    —  We would urge the Government to implement the cost of End of Life Vehicle (ELV) treatment based on cars scrapped and not based on market share, because:

    —  Honda (UK) was historically prohibited by import restrictions, which applied to all non EU-vehicles. Therefore our market share was restricted for a period of time during which other vehicle manufacturers profited from increased sales, it would be unfair for Honda (UK) to now pay a disproportionate amount of the total industry liability. Honda has invested over £2 billion in the UK to overcome those restrictions.

    —  The financial burden will have a significant impact on Honda (UK) if it is to be based on market share. It would be unreasonable for Honda (UK) to be penalised for a growing market share, and under these circumstances should not be expected to pay for the scraping of other manufacturer vehicles.

  3.  The free take back obligation is limited to ELVs with zero or negative value. The Government should ensure that the implementation regime introduces a mechanism to differentiate between ELVs with a positive and negative value.

  The following are comments that Honda (UK) believes should be seriously taken into consideration.

    —  Hazardous Waste

    ELVs have been classified as hazardous waste, in order to avoid extra costs and to stop any potential fraud it is important that the Certificate of Destruction is issued when the vehicle is destroyed.

    —  Abandoned Cars

    To avoid cars being abandoned, a continuous taxation system should be introduced. This will result in the last owner of the vehicle having to continue to pay tax until they can prove they have taken the car to an Authorised Treatment Facility.

    —  Lack of Treatment Facilities

    We are deeply concerned about the lack of treatment facilities that comply with Annex 1 requirements. The Government will need to put in place an effective policing system, which will ensure cars are being treated by treatment facilities according to the Directive standards.

    —  Orphan Brands

    Orphan brands should be the ultimate responsibility of the Government. Honda (UK) will not pay for the costs of ELV treatment of other brands.

    —  Independent Importers

    A system should be in place to ensure independent importers are made responsible for treatment and cost of treatment of their vehicles.

    —  Annex II Restrictions

    We cannot agree to Annex II restrictions to be put on replacement parts, as we do not have complete control over parts being fitted to cars on the market. We can implement this through our dealer network but cannot be made responsible for other Servicing outlets.


 
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Prepared 6 December 2001