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
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
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
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.
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.
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 should be the ultimate responsibility
of the Government. Honda (UK) will not pay for the costs of ELV
treatment of other brands.
A system should be in place to ensure independent
importers are made responsible for treatment and cost of treatment
of their vehicles.
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.