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

oth pieces of legislation is to restrict, or eliminate, the use of hazardous materials in
manufactured goods sold overseas.
22.12 Effect of the Policy on Pricing of Resources / Services
It is difficult to determine the actual costs for the treatment of ELVs, however, it has
been estimated to be in the region of €60 to €80/vehicle. These costs could accrue
to circa €6.6m annually.
KPMG carried out two studies with a view to determining the appropriate levy to be
paid to authorised treatment facilities for the depollution of ELVs. 492 The first report in
May 2002 recommended that a levy be set at €153/ELV excluding VAT; in a
subsequent report completed in 2003 KPMG recommended a revised figure of
€120/ELV excluding VAT. These figures included the costs of depollution. The reports
were based on an analysis of the costs and revenues associated with dismantling an
end-of-life vehicle, taking account of the labour / administration costs. The reports
noted the volatile nature of the market for hulks and scrap metal and the
susceptibility of this market to price fluctuations. The second KPMG report noted that
there was scope for the price of any proposed levy to fall to €60 to €70 per vehicle.
It is reasonable to suggest the manufacturing cost of vehicles has been affected by
the specific requirements imposed on vehicle manufacturers. The reduction of
hazardous components, the labelling of components for recycling, design for
dismantling has, most likely, imposed upward pressure on vehicle manufacturing
costs. However, as technologies develop the cost of such change may diminish. As a
result of the competitive nature of vehicle sales and the numerous variables involved,
it is difficult to determine if additional costs have been passed on to the end
user/customer.
22.13 Evasion and Enforcement
It is an offence for an individual or an ATF to fail to comply with the law on the
disposal of ELVs. In particular, it is an offence not to obey the rules concerning vehicle
CoD, or not to deposit at an ATF a vehicle intended to discard as waste.
Penalties for offences set out under the Waste Management Acts apply. On summary
conviction a fine of up to €3,000 and/or 12 months imprisonment can be imposed.
For conviction on indictment a fine of up to €15,000,000 and/or 10 years
imprisonment is available to the court.
492 Department of the Environment, Heritage & Local Government (May 2006) Statement on
Regulatory Impact – Waste Management (End of Life Vehicles) Regulations 2006.
429
International Review of Waste Policy: Annexes