Volkswagen Aktiengesellschaft strategy for compliance with recycling and recovery rates Dr. Frank Welsch Head of Technical Development signature see German version Peter Maiwald Head of Sales Service signature see German version
Contents: Page: 1. INTRODUCTION... 3 1.1 GENERAL POINTS... 3 1.2 STATUTORY FRAMEWORK... 3 2. ORGANISATIONAL MEASURES BY VOLKSWAGEN AKTIENGESELLSCHAFT... 3 2.1 BODIES OF RULES APPLYING TO PRODUCT CREATION... 4 2.2 DESIGN FOR EFFICIENT RECOVERY AND DISMANTLING... 5 2.3 MANUFACTURER'S OBLIGATION TO TAKE BACK VEHICLES... 6 2.3.1 Individual systems... 6 2.3.2 Collective systems... 6 2.4 DISMANTLING INFORMATION... 6 3. TECHNICAL MEASURES BY VOLKSWAGEN AKTIENGESELLSCHAFT... 7 3.1 COMPLIANCE WITH RECYCLING AND RECOVERY RATES... 7 3.2 PRE-TREATMENT AND DISMANTLING OF END-OF-LIFE VEHICLES... 7 3.2.1 Direct reuse and reuse after treatment... 7 3.2.2 Component removal for recycling... 7 3.3 SHREDDING OF END-OF-LIFE VEHICLES... 8 4. CONCLUSION... 8
1. Introduction 1.1 General points This recycling strategy for the vehicle recovery process has been drawn up to classify and explain the sequence of necessary processes for compliance with the statutory requirements, according to which 85 percent by mass of each vehicle must be reusable and/or recyclable and at least 95 percent by mass of each vehicle must be recoverable. This strategy contains agreed measures for development, treatment and recovery, and ensures the ability of Volkswagen Aktiengesellschaft to achieve the target recycling and recovery rates. The scope of this strategy includes all vehicles and it forms part of the environmental objectives of the Technical Development division. A Vehicle Recycling Steering Committee, in which the companies of Volkswagen Aktiengesellschaft and the business divisions involved are represented, has been set up to direct activities at Group and brand level. Alongside this, there are working groups that deal with and report on particular issues, e.g. material controlling and restrictions on the use of heavy metals. 1.2 Statutory framework The adoption of Directive 2000/53/EC of the European Parliament and of the Council on end-of-life vehicles (hereafter "ELV Directive") put in place the statutory framework for improvement of environmental protection. It applies to all economic operators. The Directive 2005/64/EC of the European Parliament and of the Council on the typeapproval of motor vehicles with regard to their reusability, recyclability and recoverability and amending Council Directive 70/156/EEC (hereafter "RRR") has developed into an independent system regulation. This is a special directive forming part of the EC type approval process and contains the requirement in Article 6 Paragraph 3 for a "preliminary assessment" of the manufacturer and with regard to Article 4 Paragraph 18 a strategy for the implementation of the EU ELV Directive. The Volkswagen Aktiengesellschaft strategy includes compliance with the applicable legal requirements. For type approval to be granted, the preliminary assessment must be carried out to ensure the manufacturer has put in place suitable measures to comply with requirements, such as the restrictions on the use of heavy metals in accordance with Directive 2000/53/EC and Directive 2009/1/EC. Arrangements and procedures are also required for the marking of polymers and elastomers in accordance with Commission Decision 2003/138/EC establishing component and material coding standards. The directive also determines that the recycling and recovery rates must be calculated in accordance with the standard ISO 22628: 2002. 3
2. Organisational measures by Volkswagen Aktiengesellschaft 2.1 Bodies of rules applying to product creation Environmental protection is treated as a corporate responsibility within the Volkswagen Group. To ensure environmentally sound product development, Volkswagen Aktiengesellschaft is guided by Technical Development's environmental objectives, which are embedded in the environmental management system certified under ISO 14001. One of the fields of these environmental objectives deals exclusively with saving resources. The series of standards VW 91100 ff. is one of the bodies of rules containing detailed specifications for the implementation of the environmental objectives. This series of standards governs the uniform environmental requirements applying to the development, production, use, repair and disposal of vehicles for the whole Volkswagen Group. The standard VW 91101 deals with the use and treatment of materials containing verifiable or potential harmful substances and contains material restrictions including the heavy metal ban of the European ELV Directive. It refers to the Global Automotive Declarable Substance List (GADSL). The standard VW 91102 summarizes all other aspects of the European ELV Directive and the RRR that are relevant to vehicle development. It also contains the demand for increased use of recyclate. In addition, the standard provides arrangements by which suppliers are required to produce recovery concepts for components for the purpose of more environmentally friendly product design. The marking of materials is required by the standard VW 91102 and the standard VW 10500. The latter governs the general marking of components in the VW Group. The marking of materials is carried out in accordance with the guideline VDA 260. Requirements for complete documentation of material data are laid down in the standard on component development (VW 99000) and the environmental standard (VW 91102). They are thus a fixed part of the product creation process (PEP) and contained in the PEP manual. Compliance with these requirements is monitored in the Reifegradspiegel and is a precondition for procurement release ( B Freigabe ). The material data recorded in the documentation are used to calculate recyclability and recoverability in accordance with ISO 22628:2002. If required, the material data are determined or checked by dismantling a vehicle. The standard template for component specifications makes the above-mentioned standards an obligatory part of all component specifications catalogues. In addition, these standards are automatically included as part of all drawings by means of the standardized drawing frame. 4
Specifications catalogues and drawings form the basis of component development and the technical documents for contracts with suppliers and development partners. All relevant documents are available to suppliers and development partners via the Procurement division's Internet portal (http://www.vwgroupsupply.com/b2b/vwb2b_folder/supplypublic/de.html). Compliance with development requirements is checked at the first piece inspection of components. First piece inspections are obligatory for initial deliveries and in the case of major changes. These measures ensure the specification, verification and ultimately compliance with the material restrictions and recycling requirements in all vehicle development projects. 2.2 Design for efficient recovery and dismantling Working in cooperation with material manufacturers and suppliers across the various stages from vehicle conceptual development to engineering design and production, the strategy of Volkswagen Aktiengesellschaft is to put measures in place that: limit the use of hazardous materials, allow an ideal treatment and recovery of vehicles and facilitate the recycling of vehicles. Alongside the wide range of technical requirements a component has to fulfil, engineering design also takes into account aspects of design for efficient dismantling and material selection for efficient recovery. In particular, the avoidance of materials that contain heavy metals facilitates recovery. Since 1989, Volkswagen Aktiengesellschaft has been carrying out detailed dismantling studies on prototypes, new vehicles and end-of-life vehicles. The data obtained are analyzed and findings on potential for improvement are continuously incorporated into subsequent development. Volkswagen thus applies a continuous improvement process to vehicle recovery and dismantling properties. As it is already the case for ferrous and non-ferrous metals, recyclates are also used for plastic and textile materials. To promote the use of recyclates, Volkswagen Aktiengesellschaft has approved their application in almost all components. Recyclates are used in cases where they can be applied at an equivalent price, they fulfil the quality criteria, and they are sufficiently available on the market. 5
2.3 Manufacturer's obligation to take back vehicles Another core area of the recycling strategy concerns the establishment of take-back systems for end-of-life vehicles with full geographical coverage. This is implemented in compliance with the respective end-of-life vehicle legislation in the individual countries in collaboration with suitable partners from the recycling industry. As a result of the different ways in which the ELV Directive has been incorporated into national law, the following basic forms of take-back system have emerged. 2.3.1 Individual systems The essential feature of an individual system is a direct contractual relationship between the manufacturer/wholesaler and recycling industry companies to comply with Volkswagen Aktiengesellschaft's statutory obligation to take back end-of-life vehicles. Market principles are applied in the establishment of the system. 2.3.2 Collective systems Collective systems represent another type of take-back system. Their key feature is that a third party is engaged to establish and maintain a joint take-back network for all manufacturers / wholesalers. A particular form of collective system is the "fund system". The essential characteristic of a fund system is that manufacturers, importers or buyers of new cars pay an up-front disposal fee. Volkswagen Aktiengesellschaft takes a critical view of this type of system as fund operators have yet to demonstrate that this form of take-back system ensures that the money paid into the fund is tied to the purpose of promoting/improving the environment. The strategy of Volkswagen Aktiengesellschaft is therefore to support individual take-back systems based on market principles. 2.4 Dismantling information At a very early stage, Volkswagen recognized the need to supply the recycling industry with the necessary information for the treatment of end-of-life vehicles. The European project "International Dismantling Information System" (IDIS) exists for this purpose. Within six months of the time at which a new vehicle is released to the market, the necessary information is made available via IDIS. 6
3. Technical measures by Volkswagen Aktiengesellschaft 3.1 Compliance with recycling and recovery rates To comply with the required rates, Volkswagen makes use of a combined and coordinated selection of technical measures to achieve the economic optimum under differing regional conditions. The strategy for the calculation of the rates is to take into account both component dismantling and post-shredder technologies. 3.2 Pretreatment and dismantling of end-of-life vehicles The end-of-life vehicle recovery process begins when the last holder of the vehicle delivers it to a dismantler or take-back point. The information required for pretreatment and pollutant extraction is made available by Volkswagen to the dismantler via IDIS (see 2.4). The pretreatment and pollutant extraction activities and the further treatment of the components and materials are based on generally accepted technical rules. Part of the Volkswagen strategy is to analyze and assess the technologies available on the market, and to introduce measures to optimize them in individual cases. 3.2.1 Direct reuse and reuse after treatment For Volkswagen Aktiengesellschaft, product recycling by reuse of replacement parts and exchange parts is an integral part of its recycling strategy. The direct reuse by removal and sale of used components forms the core business of European dismantlers and is in Volkswagen's interest as it serves to retain the original buyer's loyalty to the brand. Volkswagen Aktiengesellschaft runs its own operations for reuse of components after treatment. Especially for older vehicles, this provides a source of high-quality, economical and ecologically sound replacement parts. 3.2.2 Component removal for recycling With consideration to statutory, ecological and economic conditions, it can be beneficial to dismantle certain materials for recycling. An essential requirement for dismantling to be feasible is the availability of recycling facilities for the components concerned. A compilation of the existing recycling processes can be found in the "Proven Technologies" list, which is continuously updated by manufacturers and importers in the EU. The dismantling of components is economically justifiable if the income from the recycled material exceeds the costs of dismantling, sorting, transport and treatment of the vehicle parts by a recycler. If the economic conditions are not fulfilled, Volkswagen seeks to achieve recycling by means of post-shredder technologies, taking ecological aspects into account. 7
3.3 Shredding of end-of-life vehicles The economic driver for the treatment of end-of-life vehicles in shredder plants is the recovery of ferrous and non-ferrous metals. The remaining non-metallic fractions represent another potential source of raw material. Volkswagen Aktiengesellschaft supports the exploitation of this source through the development and optimization of post-shredder technologies. Post-shredder technologies represent an alternative to the dismantling of components and are part of the strategy of Volkswagen Aktiengesellschaft. Technologies of this kind are listed in the second section of "Proven Technologies". Volkswagen has been pursuing the development of such a process since 1999 and has made available the process foundations and patents created to businesses in Europe. Other activities are the establishment of post-shredder technologies in the European markets where economically feasible and the optimization and extension of existing processes and process technologies. 4. Conclusion The organizational and technical measures for vehicle recycling described by Volkswagen Akti- engesellschaft demonstrate the theoretical recoverability rate for new vehicles of 95 percent and ensure the achievement of this rate in practice since the year 2015. 8