Depollution under Annex I: what every EU dismantler must remove, whatever the country

Most compliance questions a dismantler asks are national — which permit, which form, which authority. Depollution is the exception. Annex I of Directive 2000/53/EC applies in every member state, and a yard in Sofia, Lyon or Gdańsk is stripping the same things in the same order.

That matters if you operate across borders, or if you are trying to work out which of your obligations come from Brussels and which from your own capital.

The order is not arbitrary

Annex I separates two groups of operations, and the sequence is the point. Depollution comes first — before the vehicle is dismantled for parts, and certainly before anything is shredded. Strip the value first and the hazardous material ends up dispersed through the waste stream, which is precisely what the Directive exists to prevent.

What must come out, everywhere

The depollution operations are:

• Batteries and liquefied gas tanks.
• Potentially explosive components — airbags and pretensioners — removed or neutralised.
• All fluids, removed and stored separately: fuel, engine oil, transmission and gearbox oil, hydraulic oil, coolant, antifreeze, brake fluid, air-conditioning refrigerant, and any other fluid in the vehicle — unless a fluid is needed for the reuse of the part that contains it.
• Mercury-containing components, as far as they can be identified.

Two of these are worth calling out because they are the ones most often treated as optional.

The battery is not conditional. It comes out of every vehicle, not only those where it is convenient or where the vehicle is electric.

Mercury is an identification duty, not just a removal duty. "As far as feasible" means you are expected to know where such components typically sit — switches, some instrument-cluster and display backlights on older vehicles — rather than to remove one only if it happens to fall out.

The second group: dismantling to promote recycling

After depollution, Annex I asks for the removal of catalysts; metal components containing copper, aluminium and magnesium if they are not separated during shredding; tyres and large plastic components (bumpers, dashboards, fluid containers) if not separated in shredding; and glass.

Note the condition: several of these are required if not separated in the shredding process. Catalysts are not conditional.

Storage counts as an operation

Annex I also requires storage that avoids damaging fluid-containing components, and parts suitable for recovery or reuse. A correctly depolluted vehicle stacked so that a sump splits is not compliant.

Is this still the law? Yes, until September 2028

Regulation (EU) 2026/1738 entered into force on 13 August 2026 and will replace this Directive — but it generally applies only from 1 September 2028. Until that date Annex I remains the operative depollution floor across the Union, and the national rules built on it stay in force. The separate guide on the new regulation covers what changes and when.

Where your country adds to this

The Directive is a floor, not a ceiling. National transpositions commonly add operations and, more often, deadlines the Directive itself does not set:

• Romania adds components containing cadmium, lead or hexavalent chromium, lead balancing weights, and oil, fuel and air filters — and sets a five-day clock from intake to depollution.
• Bulgaria enumerates the same operations under «Операции по отделяне на опасни материали и компоненти» and requires separate tanks per fluid type.
• France attaches the requirements to the agrément's cahier des charges, with an annual third-party audit.

Nothing in the Directive obliges a Dutch yard to meet a Romanian deadline. If a system tells you otherwise, it is applying one country's rules to everybody.

How ELVPro handles this

The treatment checklist is generated from the Annex I baseline plus whatever the yard's own country adds, resolved from the yard's registered country — not from a single national template. The checklist is the record, so the depollution log is a by-product of doing the work rather than something written up afterwards.