Certificates of Destruction
35. All ELVs will be issued with a Certificate of
Destruction (CoD) by an Authorised Treatment Facility. The reliability
of the issuing system is crucial to ensure that vehicles do not
re-enter the market after a CoD has been issued. Certificates
will also provide information on the number of vehicles treated
and recycled. Valpack told us that in their experience, "a
single clearly defined point in the chain needs to be identified
as the most practical stage to determine that a given tonnnage
of ELVs has been treated and that the resulting material has been
sent for reprocessing".
36. The DVLA are trialling electronic systems for
issuing CoDs. A pilot scheme has been running since 25 May 2001.
The system is currently 'one-way' with information going to DVLA
but it will become a 'two-way' link. The DTI estimated that it
would cost around £2,000 for each ATF to install a computer
to run the electronic system.
The MVDA pointed out that the staff to operate them will be a
further expense for many existing operators.
BMRA companies are participating in the pilot scheme. Mrs Dawn
Allen told us "the only problem we are having is the time
it is taking to actually put the throughput to the DVLA".
The DVLA told us the system "is being developed to support
a minimum of 2 million notifications a year".
37. The DTI told us that CoDs "would be issued
at the point of entry into the system, whether that is at a dismantler,
or shredder, or what have you, and ... would only be issued once".
The DVLA told us the last registered keeper of a vehicle would
be issued with a certificate:
"Generation of the certificate
will trigger an electronic notification to the Driver and Vehicle
Licensing Agency. This will update the vehicle record and end
the keeper's responsibility for the vehicle".
38. There seems to be confusion, however, over whether
a CoD guarantees a vehicle has actually been destroyed. The DTI
consultation paper asked for views on "whether it should
be possible for vehicles to be returned to the road after a CoD
has been issued".
The SMMT believed that there should be a two stage Certificate
of Destruction; one when the final owner hands over the vehicle
to the treatment facility, and a second when the vehicle is actually
The BMRA agreed that a two stage system has some merit: the MVDA
felt that a two stage system could work.
The DVLA told us: "details of the safeguards which will be
in place to ensure that an ELV will not be returned to the road
have not yet been finalised".
39. The Directive requires the European Commission
to draw up minimum standards for the CoD by 21 October 2001.
The DVLA told us a working document was issued on 6 September
2001, it was discussed on 2 October 2001, but a final proposal
is not expected until January 2002.
40. It is not yet clear exactly how the system
of issuing Certificates of Destruction will work. The DTI and
DVLA must issue clear guidance on each step in the process and
where the ultimate responsibility lies. We think there is some
merit in a two stage process. The owner would receive a document
to prove that he/she no longer had responsibility for the vehicle,
but the vehicle would not be finally 'signed off' until it was
actually destroyed. We trust that any problems the DVLA are currently
having with handling large numbers of CoDs are dealt with well
in advance of the system going live.
41. The DVLA told us that "it is highly unlikely
that a fully automated system to issue CoDs can be rolled out"
by 21 April 2002, when the Directive comes into force.
The DTI's consultation paper noted that it would not be sensible
to run a paper system in parallel with the electronic system,
and: "all permitted facilities would need to have electronic
systems in place from the outset". Given that the electronic
system for issuing CoDs will not be rolled out when the Directive
comes into force in April 2002, we are concerned there will be
some confusion when the initial CoDs are issued. We recommend
that the DTI set out clearly how the initial issuing of CoDs will
work. We trust that there will be a smooth and speedy transition
to the fully automated system.