Over recent weeks there have been a number of enquiries to the MVDA office about the export of used parts. This blog contains information on consignments of vehicle parts for reuse provided by the Environment Agency.
Some companies sell parts ‘ex-works’ to companies/ individuals that carry out the export, whereas others actually carry out the export themselves. The following information will prove useful in both cases.
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This note outlines the steps ATFs can take to ensure that working vehicle parts intended for ‘reuse’ overseas for their ‘original purpose’ can be clearly distinguished from waste that requires greater control. The EA is unlikely to view shipments of reusable parts as waste where these parts have been competently assessed as working and they are satisfied they are intended for reuse for their original intended purpose. Other competent authorities overseas may take a different view and may insist on such parts being notified as waste or may prohibit their import altogether.
It should be borne in mind that in the event that any shipment of fluid containing parts (e.g. engines, gearboxes) that are judged to be waste, by either the EA or overseas regulators, will be classified as hazardous waste, with the concurrent significant repatriation charges. For this reason it is recommended that these procedures are followed.
Preparing parts for reuse
The EA developed the following procedures in partnership with experienced UK operators. They are not compulsory but are considered a helpful and practical means of fostering a common understanding between ATFs and regulators both here and overseas for exporting parts for reuse.
Assessment
All parts intended for reuse should be assessed by the operator to ensure that they are suitable for re-use without modification or repair.
Engines should be assessed as suitable for re-use prior to depollution of the ELV and removal of the engine. Engines should be drained of oil and bunged prior to export, retaining no more oil than necessary to prevent corrosion during storage and transit. Engines that leak oil in transit are a pollution risk and carry a significant risk of being detained or repatriated at the cost of the operator.
Other fluid containing components (e.g. gearboxes) should also be drained of fluids if a drain point is available & drainage does not damage the unit. Once drained, any holes should be plugged to prevent leakage of oils. ‘Sealed for life’ units (e.g. shock absorbers) do not need to be drained.
Tyres intended for reuse should be assessed as suitable for re-use as per the UK part-worn tyre regulations (having regard to tread wear, side wall damage etc.). Tyres that would not be road legal in the UK are regarded as waste regardless of the whether or not they would be road legal in the destination country.
Information about the parts
To support the claim that the parts are intended for reuse without further treatment, the following information should accompany each consignment of parts:
Engines & gearboxes
- Donor vehicle make/ model
- Engine size (cc)
- Engine number (where applicable/ possible)
- Fuel type
- Unit value
Other parts
- Item description (e.g. door panel, wing mirror, rear light etc.).
- Quantity of item (e.g. Doors x6, rear lights x12 etc.)
- Unit value
Other information to accompany the consignment
Statement that: “All items listed originate from de-registered UK vehicles and are sold as working used parts for reuse only”.
Details of the seller, including:
- Full company name
- Full company address
- VAT number
- ELV ATF permit number
- Telephone number
- Fax and email details if available
- Contact name
Details of the purchaser, including:
- Full company name
- Full company address
- Telephone number
- Fax and email details if available
- Contact name
- Regulation Authority reference if applicable
Seller’s company stamp signed over by the company’s authorised person and dated.
Paperwork to include
- Total number of containers in consignment
- Shipping container seal number if applicable
If you have any questions, please do not hesitate to call the office
Motor Vehicle Dismantlers Association of Great Britain Office 5, Top Floor,
Charrington House, 17A Market St, Lichfield, Staffordshire, WS13 6JX, UK.
Charrington House, 17A Market St, Lichfield, Staffordshire, WS13 6JX, UK.
Image courtesy of Salvage Wire Ltd (www.salvagewire.com)
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