Regarding the “End of Life Vehicles” Directive

The French association Les véhicules de loisirs (UNI-VDL) and the Trailer Industry Association (TIV) are preparing a joint response. We will present the position of the TIV to begin with here.

In collaboration with the French association UNI-VDL, the European Trailer Industry Association is working on a joint response to the EU’s proposed End of Life Vehicles Directive. An initial coordination meeting has already taken place, and a further meeting will soon be held so they can adopt a common position. The goal of this international collaboration is to ensure that, across the EU, all trailers in categories O1 and O2 are exempt from a take-back obligation at the end of their service life. There are strong arguments in support of this.

Drive unit

Both associations believe that the End of Life Vehicles Regulation should be restricted to motor vehicles, since only these—primarily in and around the engine— contain substances and components that always require careful disposal or recycling. Set against this, neither unbraked (O1) nor braked trailers (O2, up to a maximum gross weight of 3,500 kg) have an engine at all.

Installed components

A limited number of trailers, such as sales trailers, may indeed be equipped with appliances like refrigerators, which must be properly disposed of once they have reached the end of their useful lives. However, customers can return such items to the trailer manufacturers who installed them, in accordance with the regulations already in place.

Demand

Up to now, the TIV has not received any indication of potential demand for disposals or recycling from any European trailer market.

Conclusion

In summary, the Trailer Industry Association is convinced that introducing such a system for O1 and O2 trailers would lead to unnecessary additional bureaucracy and significant price increases.

The European Union should do everything possible to avoid this – especially in times of multiple crises, which are also eroding public trust in the European idea, the stability of the European economy, and the prospects for future generations.

The trailer industry recognises the importance of environmental protection and recyclability for both current and future generations, even in the absence of additional bureaucratic regulations. A take-back obligation for manufacturers at the end of the service life of O1 and O2 trailers would be nonsensical, costly, and neither customer nor citizen-friendly.