There are 1,275 ATFs in England and Wales, all of which should now be undertaking full de-pollution. However, only 521,000 CoDs were issued between January and October this year, which suggests a great number are not following the correct procedure for dealing with vehicles.
The Environment Agency estimates that as many as 50% of all ATFs have issued few or no CoDs, with the Department of Trade and Industry (DTI) and Driver and Vehicle Licensing Agency (DVLA) said to be looking into ways of correcting this.
British Metals Recycling Association (BMRA) director general Lindsay Millington said: It would be quite likely that a lot of businesses registered without knowing what the full requirements were, while some may not be members of established associations and are not being kept fully informed of what their required to do.
But this is merely speculation, with one concern the fact that it isnt possible to monitor progress through CoDs. These are issues that have come up in the ELV consultation groups convened by the DTI which have been very productive in moving the issue forward.
The fact that the DVLA is still issuing Notices of Destruction is said to be causing confusion, but Millington suggests that the biggest concerns are illegal operators making it more difficult for those following the rules and not enough obligation on the cars last owner.
There are a number of causes, but a major problem is that there is not much pressure on the last owner to ensure that the CoD is issued. It would be a major move forward if the DVLA started issuing financial penalties for not doing this.
There is currently no legal power making sure that members of the public follow this procedure and someone keeping an eye on them seems to be the bit that is lacking [from legislation], added Millington.
There is thought to be around 500 illegal operators dismantling vehicles in the UK, and it has been suggested that the failure of the DVLA to make a CoD an absolute requirement is making it impossible for many to comply with the requirements of the ELV Directive.
This means that an estimated 18,000 tonnes of vehicles fluids and the same amount of batteries could be being poured down the drain and dumped each year.