International Review of Waste Management Policy - Department of ...

expenditure incurred in implementing and enforcing the Regulations for this producer
responsibility based scheme. These fees are based on estimates provided by local
authorities. Article 11(7) of the Regulations allow the Minister to review the fees after
the 1 st October 2007 and empowers the Minister to adjust the fees set upwards or
downwards.
The Regulations impose administrative responsibilities on producers in terms of the
preparation and submission of implementation plans to local authorities and data
compilation and reporting, the latter also applying to ATFs who in addition will incur
some costs in managing the system of CoDs. Permitted facilities have to report data
to local authorities and the extra administrative burden on ATFs should not give rise
to significant costs.
While there is no accurate information available on the establishment and upgrading
of ATFs, the initial investment in Ireland to ensure a national network of 43
contracted ATF’s to the standards required by the Regulations could cost in the range
of €1.7m. 483 The National Hazardous Waste Management Plan 2008-2012 states
that approximately 82 ATFs were confirmed to be in operation in Ireland. This plan
suggests the need for the number of ATFs to increase in order to ensure that all ELVs
are managed according to the Regulations and EU Directive.
22.8 Response from Public and Industry
We are not aware of any document, which highlights these. 484
The vehicle manufacturers business strategy is based around selling new vehicles
and supplying new parts for these vehicles. The ELV Regulations state that all
information required for the appropriate treatment and recovery of end-of-life vehicles
shall be made available to authorised treatment facilities by vehicle producers and
vehicle component manufacturers. This effectively allows for the availability of
professional and technical information to the car dismantling industry.
22.9 Effects on Technical Change / Innovation
The EU Directive on ELVs aims to improve the environmental performance of all
economic operators involved in the life cycle of vehicles. Bearing in mind that cars,
vans, etc. driven on Irish roads are manufactured outside of Ireland, it is decided to
consider technical change and innovation on an international context.
The impact of economic instruments, induced by the EU Directive on end of life
vehicles, on innovation paths in car manufacturing is addressed in a paper produced
by Massimiliani Mazzanti and Roberto Zoboli (University of Ferrara). 485
483 Department of the Environment, Heritage & Local Governement (May 2006) Statement on
Regulatory Impact – Waste Management (End of Life Vehicles) Regulations 2006.
484 The EPA were contacted in relation to responses from public and industry.
485 Massimiliano Mazzanti and Roberto Zoboli (May 2005) Economic Instruments and Induced
Innovation: The Case of End of life Vehicles European Policies, University of Ferrara, Italy.
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