|FEMA responded to the European Commission’s request for feedback with the following statement and explains why in their view motorcycles and other powered two-wheelers should not be included in a new directive.
The Federation of European Motorcyclists’ Associations (FEMA) thanks the European Commission for the opportunity to give its vision on the revision of the End-of-life Vehicles Directive (2000/53/EC).
In FEMA’s view, the current Directive succeeded in preventing waste from vehicles, the reuse 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.
However, extension of the working of the Directive to powered two-wheelers (PTWs) is less obvious because of the different nature of both use and build of PTWs. PTWs do not have a body like cars; they can have body parts attached to the frame, but this cannot be compared with the body of cars. Most PTWs spend the largest part of their live indoors and as a rule are used for far less kilometers than cars. Because of this, and because parts can easily be removed, PTWs seldomly reach the end of their life like other vehicles do.
Virtually all PTW parts can be reused, through a large network of specialized second-hand part suppliers throughout the European Union, or by users themselves who swap and change parts with other owners. Parts that are not reused are recycled through local recycling schemes or sent on by second-hand part shops. There is no evidence of PTWs being dumped beside the road or otherwise disposed of in an inappropriate manner. Inclusion of PTWs could even be contrary to the aim the directive, by causing a problem where none exists now. In particular, the certificate of destruction may prohibit users from dismantling their vehicles for the purpose of reusing components. Furthermore, the administrative requirement on specialized second-hand parts businesses, which are generally small and medium-sized enterprises (SMEs), could mean job losses.
An exception could be made for electric powered vehicles (EVs). The demolition of EVs is specialistic work that should not be done by unqualified people. To ensure that the demolition of PTWs with a combustion engine can still be done in-house by the owners themselves or by SMEs, and to ensure that demolition of electric PTWs is done by qualified specialists, FEMA suggests not to include PTWs in the End-of-life Vehicles Directive but to draw a separate Directive for powered two-wheelers and perhaps other L-category vehicles.
If the European Commission does propose to include motorcycles and other powered two-wheelers in an End-of-life Vehicles Directive, FEMA would ask the 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.
If the European Commission does propose to include motorcycles and other powered two-wheelers in an End-of-life Vehicles Directive, FEMA would ask the Commission to ensure that historic PTWs or PTWs 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.