Memorandum by The Society of Motor Manufacturers
and Traders Limited
1. The Society of Motor Manufacturers and
Traders (SMMT) is the leading trade association for the UK automotive
industry, providing expert advice and information to its members
as well as to external organisations. It represents more than
500 member companies ranging from vehicle manufacturers, component
and material suppliers to power-train providers and design engineers.
The motor industry is a crucial sector of the UK economy, generating
a manufacturing turnover of £47 billion, contributing well
over 10 per cent of the UK's total exports and supporting around
850,000 jobs.
2. SMMT members are regulated in many areas that
require them to be resource efficient such as IPPC, packaging
waste and have producer responsibility for End of Life Vehicles
which requires them to meet demanding material recovery targets.
SMMT members are also acutely aware of the need to reduce CO2
emissions from all sources, and therefore seek to be efficient
in manufacturing, operation and recovery of their products.
BETTER DESIGN
AND THE
USE OF
MATERIALS
What role can better design and materials play
in minimising the creation of waste? Are there any barriers to
how knowledge in this area can best be translated and applied?
The automotive product development activity
establishes the key features required for a new vehicle programme.
This could include marketing clinics to gauge consumer opinion
and benchmarking current market leaders in the segment. An important
consideration at this stage is the production cost and weight
of the final vehicle. It follows that every component design will
undergo an evaluation which will include manufacturing and material
efficiency before sign off for prototype production. Computer
aided design packages have given engineers the capability to evaluate
component performance on screen and optimise material usage. The
End of Life Vehicle Directive required manufacturers to eliminate
certain heavy metals from their products; this required the component
supply industry to inform their vehicle manufacturer clients what
materials and quantities were used. This led to the formation
of the International Materials Database System (IMDS) widely used
today. ELV legislation also required the creation of a new ISO
standard 22628 Road Vehicles-Recyclability and Recoverability
Calculation method. This was followed by another EU Directive
for Type Approval for Re-usability, Recoverability and Recyclability.
This Directive requires that from 15 December 2008 Manufacturers
must demonstrate using the ISO standard that a new vehicle can
be reused or re-cycled to 85 per cent within an overall 95 per
cent recovery target. Manufacturers have developed lists of proven
recovery processes to satisfy the heavily regulated material streams
generated at end-of-life. I think this demonstrates that good
design, avoidance of waste and recovery at end-of-life are important
considerations in the development phase.
What factors influence the use of materials? In
what way do considerations of sustainability feature in the selection
of most commonly used materials?
The modern motor vehicle is required to meet
many legislative requirements, crash protection, material recovery,
and the need to reduce weight to achieve CO2 targets. These requirements
often conflict with each other. Looking at the whole life cycle
of a vehicle it is evident that the use phase in terms of CO2
has the most significant environmental impact at around 85 per
cent. Production of the vehicle uses around 10 per cent and end
of life 5 per cent. So materials that offer weight saving offer
the most environmental benefit. This has led to an increase in
the use of light alloys for some applications and total aluminium
body structures in others. High strength steels are used in place
of mild steel in some areas to gain a weight reduction. Metals
are highly sustainable and readily recycled back into new product.
Between 10 per cent and 12 per cent by weight of a car is plastic
of some description. All manufacturers provide dismantling information
for all of their products through the International Dismantling
Information System IDIS this allows a dismantler to identify what
type of plastic a component is made of and how to remove it. The
logistics and economics of this approach are variable. The Plastic
Reprocessing Validation Exercise PRoVE demonstrated that polypropylene
could be extracted from shredder residue and processed with virgin
material into a Nissan air cleaner unit. This post shredder recovery
of material is the most efficient and cost effective method of
reaching recovery targets.
To what extent do product designers and engineers
take into account the availability and the end of life impacts
of raw materials?
As mentioned above Type Approval requires manufacturers
to demonstrate 95 per cent recovery at end of life. Lack of availability
of materials would impact on cost and would promote the search
for more sustainable alternatives. Manufacturers are also concerned
that robust processes exist to reach the high recovery targets.
One example developed by Volkswagen the VW-Sicon process is now
successfully installed in several European countries. The proposed
new Waste Framework Directive changes the definition of recycling
and could affect the viability of this new technology. Only a
broad and consistent recycling definition as proposed by the EU
Commission will create legal certainty and ensure the continued
development and investment in innovative and eco-efficient recycling
plants.
What impact does the development of new materials
have on design? How much interaction is there between material
scientists and designers?
The automotive industry requires materials and
components to undergo accelerated durability testing before incorporating
new materials into production. Our Research and Development centres
in collaboration with the supply chain are continuously evaluating
materials and processes to meet improved product specification
in areas of weight, performance, NVH, safety, durability, assembly
and disassembly. Some of our R&D facilities have access to
patent facilities on site.
Can better designed products offset the increase
in consumption?
Vehicles are more robust and durable than ever
before, with the effect that average vehicle life is increasing.
Consumption remains high because consumers judge that the alternative
options for mobility and transport of goods as not viable or less
attractive.
Are there any other gaps in knowledge and how
are they being addressed?
The automotive industry operates on a global
scale and there are many alliances between companies on power
train or body components. Very often they have a common supply
base. Companies work in close co-operation with academia and chartered
institutes. There is in the UK Government sponsored Knowledge
Transfer Networks including SMMT Foresight Vehicle programme a
collaboration between industry, academia and Government. More
than 100 research projects have benefited.
BUSINESS FRAMEWORK
Does the current policy, regulatory and legal
framework support and incentivise the development of better, more
sustainable products and processes? How is the framework communicated
to businesses and what is the level of awareness and understanding
among businesses?
Existing and new proposed EU legislation is
not always coherent and is sometimes contradictory. New legislation
should be based on good impact assessments with a life cycle perspective.
The ELV Directive provided in article 7.2 that by the end of 2005
there would be a review of the targets set for 2015 of 85 per
cent reuse and recycling within an overall 95 per cent recovery
target. A multi stakeholder group provided a report that gave
several options but that concluded that targets would not be as
effective in reducing waste from vehicles as restricting landfill.
This would stimulate investment in innovative post shredder technologies.
How central is sustainable design to business
thinking? What initiatives are in place to encourage this and
are they meeting business needs?
Vehicle Manufactures all have environmental
policies that promote sustainable thinking from the top of the
organisation. At the detailed level there are specific internal
processes that ensure the consideration of sustainability in design
and other business areas.
GOVERNMENT POLICY
What is and should be the role of Government in
addressing the issue of waste reduction?
Government as the regulator and its agencies
as enforcers should first ensure that waste laws are practical
in application and simple to understand. Industry views should
be listened to and UK competitiveness protected. Like manufacturers'
good design, legislation should be tested for unintended consequences.
Once laws are passed they must be correctly enforced, those who
comply often have to invest heavily whilst those who do not comply
escape both investment and too often enforcement. Looking at ELV
enforcement, Government agencies are failing to enforce correctly
in the ELV recovery network and non compliant businesses are making
the compliant sector un-competitive. DVLA have failed to implement
a foolproof Certificate of Destruction system, an essential component
of ELV legislation. For 2006 this led to only recording around
600,000 vehicles as depolluted and recycled against an expected
2,000,000. For 2007 this has reached around 1,000,000 but still
represents less than 50 per cent of the forecast for scrapped
vehicles.
How does Government policy link up with European
strategies and action plans?
Vehicle manufacturers must have consistent harmonised
legislation in all member states. It is impossible to design and
build vehicles for specific national material requirements. It
is also important that duplication of legislation is avoided,
ELV, WEEE, and the batteries directive all require collection
systems and recycling targets to be met. It is essential that
there is no product overlap and that vehicle manufacturers meet
their obligations through the ELV regulations.
CONSUMER BEHAVIOUR
How can better product design be used to effect
a change in consumption patterns and behaviour?
CO2 emissions from the UK passenger car fleet
are now below 1990 levels, linked to a 13 per cent reduction in
average new car CO2 emissions in the last ten years. This has
been achieved partly by improved design and technology and partly
by market shift. As smaller cars have become as highly specified
as larger cars, the option to down size is more attractive. Diesel
engines are quieter and more efficient as well as meeting demanding
regulated emission standards. Government is hindering further
CO2 progress by not encouraging dieselisation. In 1997 there were
no cars below 120gm/km of CO2 now that is 5.4 per cent under 120
and 23.5 per cent under 140.
What role do marketing strategies play in influencing
more sustainable design?
Evidence from the King report, LowCVP Car buyer
research report and DfT 2004 found that the most important factors
in car purchase are, in order price, size, reliability, comfort,
safety, running costs, fuel consumption, appearance. Least important
are Environment and emissions. If the consumer was buying the
lowest emitter in any VM model range then new car CO2 emissions
would be 139gm/km (ie 16 per cent lower than today) The consumer
wants choice and diversity, manufactures have to deliver that
and build in environmental performance as standard.
The SMMT 8th report "Towards Sustainability"
examines production, consumption and recovery of vehicles and
examines CO2 emitted through the vehicle life cycle. Based on
LIRECAR 2004 study less than 5 per cent of a vehicle's total life
energy is consumed in recovery/disposal. This 5 per cent can be
mitigated by efficient post shredder recovery operations.
RECOVERY AND
DISPOSAL
SMMT is of the opinion that only waste recovery
that is environmentally sound should be undertaken. The energy
consumed and consequent CO2 emissions produced can only be justified
where worthwhile substitution or efficiency levels are reached.
END OF
WASTE
SMMT consider that the reclassification of waste
as a secondary raw material once it reaches a standardised specification
is correct. This has been achieved with the PROVE project for
recycled plastics. Whether a market exists or not does not affect
the product, and should not be a criterion for deciding whether
it is still waste or secondary raw material, markets for recycled
materials have to compete economically with virgin material. The
incentive to recycle efficiently to reduce cost and the fluctuation
of virgin material price will impact markets differently over
time.
SMMT would prefer that existing engineering
standard processes and bodies determine the quality criteria required
rather than use the comitology procedure.
February 2008
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