Sustainability and Environmental Policy

This Sustainability and Environmental Policy is issued by GASPA S.R.L MACCHINE, trading as GASPA MACCHINE, with registered and operational office at Z.I. Predda Niedda Strada 30, 07100 Sassari (SS), Italy, VAT number IT 03006910909, ATECO classification 47.52.40 – Retail sale of hardware, paints, flat glass, and electrical and plumbing materials.

GASPA MACCHINE is a dealership specializing in the sale of new and used agricultural and construction machinery, including agricultural tractors, mini-excavators, wheel loaders, telescopic handlers, tandem rollers, and construction equipment from brands such as JCB. We operate primarily with second-hand machinery, contributing to the circular economy model through the reuse and valorization of high-engineering-content assets.

This policy describes in a transparent and detailed manner how GASPA MACCHINE manages the environmental dimension of its commercial activity: from the impact of machinery sold on atmospheric emissions, to the management of hazardous materials, to compliance with WEEE regulations, to the proper disposal of fluids and batteries, to the environmental responsibilities of the buyer at the end-of-life of the purchased asset.

We sell and ship our products throughout Europe, with deliveries to the following countries:

GASPA MACCHINE recognizes that agricultural and construction machinery have a significant environmental impact during their life cycle: they consume fuel, generate atmospheric emissions, contain hazardous fluids, and produce residues at end-of-life. For this very reason, we adopt an approach of full transparency and responsibility toward the environment and our customers.

Our main activity, namely the commercialization of used and reconditioned machinery, naturally fits into the circular economy model. Selling and purchasing machinery already in use means extending their useful life cycle, delaying their end-of-life, and reducing the need to produce new machinery with the associated energy and raw material costs. This is the most concrete form of sustainability we can practice as a dealership.

• Provide accurate and verified information on the technical condition of each machine, including the condition of emission reduction systems (particulate filters, SCR systems, catalysts) where present.
• Clearly indicate in product sheets the environmental technical specifications of the machine, including engine type, certified emission Stage, and the presence of process fluids (hydraulic oil, coolant, AdBlue).
• Ensure that machinery delivered to customers is ready for use and free from undeclared fluid leaks, to prevent soil or water contamination during transport and initial use.
• Collaborate with professional carriers who comply with European regulations on the transport of dangerous goods and on emission reduction from heavy vehicles.
• Inform customers of their legal disposal obligations at the end-of-life of the purchased machine, with reference to the specific regulations of their country of residence.
• Periodically update this policy in line with the evolution of Italian and European environmental legislation.

The machinery commercialized by GASPA MACCHINE belongs to the category of non-road mobile machinery (NRMM), namely motorized vehicles and equipment designed to be used in off-road environments, such as construction sites, agricultural land, and industrial areas. This classification is relevant from an environmental perspective as such machinery is subject to specific regulations on engine emissions.

The used machinery for sale on GASPA MACCHINE were produced in different years and are therefore subject to the emissions regulations in force at the time of their production and first registration. This means that:

• A machine produced before 2019 may comply with Directive 97/68/EC or with Stages I–IV provided by the previous directive, and not with Stage V.
• Compliance with the original emissions regulation is a requirement that does not lapse over the years: the machine must continue to meet the limits for which it was certified.
• GASPA MACCHINE indicates in the product sheet of each machine the year of production, which allows the buyer to determine the applicable certification Stage.

Regulation (EU) 2016/1628 of the European Parliament and of the Council, relating to requirements for emission limits of gaseous pollutants and particulate matter for internal combustion engines intended for non-road mobile machinery (NRMM), introduced Stage V as the most restrictive level of emission control currently in force in the European Union for this category of engines.

• Stage I and II – Directive 97/68/EC (1999–2005) First limitations on emissions of nitrogen oxides (NOx), hydrocarbons (HC), and carbon monoxide (CO). Apply to most construction and agricultural machinery produced between the late 1990s and early 2000s.
• Stage IIIA and IIIB – Directive 2004/26/EC (2006–2013) Introduction of more stringent limits, with Stage IIIB requiring for the first time exhaust gas after-treatment systems (DPF filters) on engines with power exceeding 56 kW.
• Stage IV – Directive 97/68/EC amended (2014–2018) Significant reduction of NOx and particulate matter. Widespread introduction of SCR (Selective Catalytic Reduction) systems with AdBlue fluid for nitrogen oxide reduction.
• Stage V – EU Regulation 2016/1628 (from 2019) Regulation currently in force. Introduces for the first time limits on particle number (PN), not only mass. Mandatory for all new machinery placed on the EU market from 2019 (engines with power > 56 kW) and from 2020 (engines 19–56 kW).

In the product sheet of each machine for sale, GASPA MACCHINE clearly indicates:

• The year of production, which allows determination of the emissions regulation applicable at the time of first placing on the market.
• The engine type and power (in kW or HP), relevant data for the application of the correct certification Stage.
• The presence of exhaust gas after-treatment systems (DPF, SCR, EGR) where known and declared by the original manufacturer.
• The condition of the particulate filter (if cleaned, regenerated, or to be replaced) in the description of the machine's condition.

Agricultural and construction machinery contain several types of operating fluids classified as hazardous waste under Italian and European regulations. Improper management of these fluids can cause serious environmental damage, including contamination of soil and groundwater. GASPA MACCHINE is committed to providing the necessary information for responsible use and disposal.

The machinery for sale contains engine oil and hydraulic oil. These fluids are classified as hazardous waste (EWC 13 01 and EWC 13 02) under Legislative Decree 152/2006 and Decision 2000/532/EC (European Waste List). Therefore:

• Used oil cannot be disposed of in sewers, surface waters, soil, or together with municipal solid waste.
• In Italy, the disposal of used mineral oils is regulated by CONOU (National Consortium for the Management, Collection, and Treatment of Used Mineral Oils). Private individuals can deliver used oils free of charge at authorized municipal collection centers.
• GASPA MACCHINE verifies, before shipment, that the machinery does not have active oil leaks not declared in the product sheet. Any previous or superficial leaks already stopped are reported in the machine's condition notes.

Ethylene glycol-based coolant is classified as hazardous waste (EWC 16 01 14). It cannot be poured into soil or water. In Italy, it must be delivered to authorized collection centers or authorized recovery facilities under Legislative Decree 152/2006, Part IV.

Some very old machinery (generally prior to the 1990s and early 2000s) may contain asbestos materials in gaskets, clutches, brake linings, or thermal insulation. Asbestos is classified as an extremely hazardous substance under Legislative Decree 277/1991 and Legislative Decree 81/2008 (Consolidated Safety at Work Act) and by Regulation (EC) No. 1907/2006 (REACH).

• GASPA MACCHINE explicitly indicates in the product sheet, where known, the presence of components potentially containing asbestos in old machinery.
• It is absolutely prohibited to dismantle, drill, sand, or alter in any way components suspected of containing asbestos without proper remediation by certified specialized companies.
• Waste containing asbestos is special hazardous waste: its disposal is subject to strict regulations and must be carried out exclusively by authorized companies registered in the National Environmental Managers Register.

Delivered machinery may contain residual diesel fuel in the tank. Diesel is classified as a hazardous substance and cannot be spilled on soil or in water. If tank emptying is necessary, the fuel must be recovered in approved containers and disposed of at authorized centers or reintroduced into the use cycle.

The agricultural and construction machinery commercialized by GASPA MACCHINE contain electrical and electronic components (electronic control units, control instruments, wiring, alternators, starter motors, digital displays, engine management systems). These components are subject to regulations on Waste Electrical and Electronic Equipment (WEEE).

In Italy, WEEE regulations are governed by Legislative Decree 49/2014, which transposed Directive 2012/19/EU (WEEE Directive II). At European level, the directive has been transposed by all EU countries where we operate. The regulations classify electrical and electronic components contained in non-road vehicles as part of WEEE category 4 (Large equipment) and category 11 (Equipment not classified elsewhere).

It is important to clarify that agricultural and construction machinery in their entirety do not fall within the scope of the WEEE Directive, as they are vehicles and machinery intended for professional and industrial purposes not covered by the directive. However, individual electronic components removed during repairs or at the end-of-life of the machine – such as electronic control units, digital on-board instruments, engine control units – must be disposed of as WEEE.

• Electronic components replaced during maintenance must be delivered to authorized WEEE collection centers and cannot be disposed of as ordinary waste.
• Electronic control units (ECU/ECM), cabin digital displays, and hydraulic control units are WEEE in all respects.
• The buyer who replaces these components is responsible for their proper disposal under WEEE regulations in force in the country of use of the machine.

All agricultural and construction machinery are equipped with one or more lead-acid batteries (starting and/or auxiliary batteries). Lead batteries are classified as hazardous waste (EWC 16 06 01) as they contain lead and sulfuric acid, both highly toxic to the environment and human health.

In Italy, the management of used batteries is governed by Legislative Decree 188/2008, which transposed Directive 2006/66/EC. From 2023, the new Regulation (EU) 2023/1542 (Batteries Regulation) replaced the previous directive, introducing more stringent obligations for producers and distributors regarding traceability, recycling, and extended producer responsibility (EPR).

• Used lead batteries must never be disposed of together with municipal solid waste, nor abandoned in the environment.
• In Italy, used batteries must be delivered to authorized municipal eco-centers or to battery retailers, who are legally obliged to free collection under the Legislative Decree. 188/2008.
• The competent Italian national consortium for lead battery recovery is COBAT (National Collection and Recycling Consortium).
• Machinery shipped by GASPA MACCHINE contains the original functional battery, unless otherwise indicated in the product sheet. The battery delivered with the machine is the property of the buyer, who assumes responsibility for disposal at end-of-life.

Under Regulation (EU) 2023/1542, batteries and accumulators on the market must bear the crossed-out wheelie bin symbol, indicating that they must not be disposed of in unsorted waste. This symbol is affixed to the starting batteries of the machinery we commercialize.

The machinery commercialized by GASPA MACCHINE are large in size and weight, therefore their transport takes place on trucks with fixed or tipping platforms, specialized trailers, or car carriers. Conventional packaging in the traditional sense is not used. However, some accessory components, spare parts, or technical documentation may be provided in secondary packaging.

In Italy, regulations on packaging and packaging waste are governed by Legislative Decree 152/2006, Part IV, Title II and by Legislative Decree 116/2020, which transposed EU Directive 2018/851 on waste. At European level, Directive 94/62/EC on packaging and the more recent Regulation (EU) 2024/1781 on packaging and packaging waste (PPWR) define recycling and packaging reduction targets.

• Machinery is secured to vehicle platforms with reusable anchor straps and metal fasteners, without the use of single-use packaging.
• Sales documents, technical manuals, and any attached certificates are provided in recycled paper envelopes or folders, or in digital format upon customer request, to reduce paper use.
• Temporary protections applied to fragile parts of the machine during transport (plastic film covers, foam bumpers) are reduced to the minimum necessary and, where possible, replaced with reusable protections.
• GASPA MACCHINE encourages customers to report any redundant or unnecessary packaging received with the machine, to contribute to the continuous improvement of our shipping practices.

The buyer who receives residual packaging materials (non-reusable fastening straps, protective plastic films, cardboard for documentation) is required to dispose of them in accordance with regulations in force in their country. In Italy, packaging materials must be disposed of according to municipal separate collection (plastic, paper, metal). Non-domestic packaging waste of commercial and industrial origin is subject to the obligation of delivery to authorized entities under the Legislative Decree. 152/2006.

The transport of heavy machinery is one of the activities with the greatest environmental impact in the entire value chain of a machinery dealership. GASPA MACCHINE is aware of this impact and adopts concrete measures to reduce it within the limits of what is possible for a medium-sized enterprise.

The transport of heavy goods by road in Europe is subject, from an environmental perspective, to Directive 1999/96/EC and Regulation (EU) 2019/1242, which introduce CO₂ emission standards for new heavy vehicles. The transport vehicles used for our deliveries must comply with Euro VI standards for heavy vehicles (applicable from 2014) or equivalent standards in force.

• GASPA MACCHINE collaborates with specialized carriers in heavy machinery transport, with modern fleets compliant with Euro VI standards where available.
• Where possible, we organize combined shipments for multiple customers in the same geographical area, reducing the number of trips and associated emissions.
• Door-to-door delivery is planned with route optimization to minimize kilometers traveled.
• GASPA MACCHINE does not use air transport services for its deliveries; all shipments take place by road, with CO₂ impact per unit of load significantly lower than air transport.

For shipments to countries outside Italy, GASPA MACCHINE ensures that all necessary transport documentation (CMR – International Consignment Note, customs declaration when applicable, ADR documentation for dangerous loads) is correctly completed and compliant with regulations in force, including the provisions of the ADR Agreement (European Agreement concerning the International Carriage of Dangerous Goods by Road) for the transport of goods that may be classified as dangerous.

The end-of-life of agricultural and construction machinery is a critical moment from an environmental perspective. An end-of-life machine contains dozens of different materials, many of which are potentially hazardous, and must be managed in accordance with regulations on special hazardous and non-hazardous waste.

In Italy, the disposal of end-of-life agricultural and construction machinery is governed primarily by Legislative Decree 152/2006 (Environmental Code), and in particular by Part IV on waste. Vehicle machinery (under the classification of the Highway Code) may also be subject to Legislative Decree 209/2003, which transposes Directive 2000/53/EC on end-of-life vehicles (ELV). For machinery not classified as road vehicles, general regulations on special industrial waste apply.

• The machine must be delivered to an authorized dismantler registered in the National Environmental Managers Register under Legislative Decree 152/2006 or to an authorized treatment facility (for machinery comparable to vehicles).
• Before dismantling, all hazardous fluids (engine oil, hydraulic oil, coolant, fuel, AdBlue) must be drained and disposed of separately as hazardous waste.
• Recyclable metal components (steel, cast iron, aluminum, copper from electrical cables) must be sent for recovery at authorized recycling facilities.
• The tires and rubber components of the machines must be disposed of in accordance with D.M. 82/2011 at authorized treatment facilities. In Italy, the competent consortium is Ecopneus.
• Electronic and electrical components (control units, instruments, alternators) must be disposed of as WEEE at authorized collection centers.

Before proceeding with final disposal, GASPA MACCHINE encourages its customers to consider the following more sustainable alternatives:

• Resale of the machine to interested third parties: a machine at the end of its life for one operator may still have operational value for another. GASPA MACCHINE can provide advice on the used equipment market.
• Transfer for spare parts: many components of used machines (engines, gearboxes, hydraulic components, cabs) have value as spare parts for machines of the same make and model.
• Remanufacturing: some machines can undergo complete overhaul (rebuild) by specialized workshops, extending their useful life by several additional years and significantly reducing the overall environmental impact compared to the production of a new machine.

Agricultural and construction machinery contains various materials and substances subject to European regulations on hazardous chemicals. Transparency regarding the presence of these substances is a legal obligation and a commitment that GASPA MACCHINE makes to its customers and the environment.

Regulation (EC) No. 1907/2006 (REACH) – concerning the registration, evaluation, authorization and restriction of chemicals – applies to chemical substances placed on the European market. In the context of GASPA MACCHINE's activities, REACH is relevant because:

• The operating fluids (oils, hydraulic fluids, coolant, AdBlue) contained in the machines are substances subject to REACH and must be managed in accordance with the relevant safety data sheets (SDS – Safety Data Sheet).
• The machines may contain articles with Substances of Very High Concern (SVHC) on the REACH candidate list in concentrations exceeding 0.1% by weight. If known, GASPA MACCHINE communicates this information upon request from the purchaser within 45 days, as required by Art. 33 of the REACH Regulation.
• The purchaser who uses the machine fluids in a professional context has access to the safety data sheets (SDS) of the fluids, available from the original manufacturers of the machines (e.g. JCB Parts Service).

Directive 2011/65/EU (RoHS II) and the subsequent Directive 2015/863/EU (RoHS III) restrict the use of certain hazardous substances in electrical and electronic equipment (EEE). It is important to clarify that:

• Agricultural and construction machinery does not fall within the scope of the RoHS Directive, as these are machines intended for non-domestic, professional and industrial use explicitly excluded from the scope of the directive (Art. 2, paragraph 4).
• However, the individual electronic and electrical components installed by manufacturers in the machines (e.g. JCB) are produced by suppliers who must comply with RoHS requirements for the component supply chain.

Regulation (EU) 2019/1021 on persistent organic pollutants (POPs) prohibits or restricts the use of certain highly persistent chemicals in the environment. In the context of heavy machinery, this regulation is relevant because:

• Some old hydraulic fluids and lubricants contained PCBs (polychlorinated biphenyls), classified as POPs and now banned. Machines from very old production lines may still contain these fluids if they have not been replaced. GASPA MACCHINE reports this possibility in the product sheet where suspected.
• Waste containing POPs must be disposed of exclusively at facilities authorized to treat hazardous waste using technologies that irreversibly destroy or transform the POP substances.

Every country to which GASPA MACCHINE ships has transposed European environmental directives and, in some cases, has adopted more stringent national regulations. Below we provide a summary of the main environmental regulations relevant to the purchase, use, and end-of-life of agricultural and construction machinery in each country.

In Italy, the reference environmental regulatory framework is Legislative Decree 152/2006 (Environmental Code), which systematically regulates waste management, water protection, atmospheric emissions, and environmental remediation. The disposal of end-of-life machinery is subject to regulations on special waste. Legislative Decree 49/2014 regulates WEEE. Tires are managed by Ecopneus. Batteries by COBAT. Used oils by CONOU. The environmental control authorities are ISPRA (Higher Institute for Environmental Protection and Research) and the regional ARPAs.

In Austria, waste management is regulated by the Abfallwirtschaftsgesetz 2002 (AWG 2002). End-of-life machines are classified as special waste (Sondermüll or Problemstoffe) and must be delivered to authorized facilities. WEEE regulations were transposed into the Elektroaltgeräte-Verordnung (EAG-VO). The battery collection body is SAMMELSYSTEM Österreich. Used oils are collected by ASZ (Altstoffsammelzentrum).

In Finland, the main environmental regulation is the Jätelaki (Waste Act 646/2011). End-of-life heavy machinery is classified as industrial waste and must be managed by authorized operators registered in the Ympäristöhallinnon tietojärjestelmä (Yhteystietohakemisto). WEEE regulations are governed by the Laki sähkö- ja elektroniikkalaiteromusta (1390/2014). The producer responsible for waste management is coordinated by Pirkanmaan ELY-keskus.

In France, environmental regulations are governed by the Code de l'Environnement. Hazardous special waste (including machine fluids) is subject to the classification of the BSDP (Bordereau de Suivi des Déchets Dangereux). WEEE regulations are transposed in décret n° 2005-829 and subsequent amendments. The disposal of end-of-life heavy machinery utilizes the Responsabilité Élargie du Producteur (REP) system, coordinated by ADEME (Agence de la transition écologique). Batteries are managed by SCRELEC and COREPILE.

In Germany, the main environmental regulation is the Kreislaufwirtschaftsgesetz (KrWG – Circular Economy Act). The disposal of hazardous waste is subject to the Nachweisverordnung (NachwV), which requires traceable documentation of the waste path. WEEE regulations are governed by the ElektroG (Elektro- und Elektronikgerätegesetz). Batteries are managed pursuant to the BattG (Batteriegesetz). The environmental control body is the Umweltbundesamt (UBA).

In the Netherlands, the main environmental regulation is the Wet milieubeheer (Wm). The disposal of special waste is regulated by the Besluit beheer autowrakken for vehicles and by the EVOA (Verordening overbrenging van afvalstoffen) for transboundary waste. WEEE is regulated by the Besluit beheer elektrische en elektronische apparatuur (WEEE). The battery collection body is Stibat. The used oil collection body is BSAB.

In Poland, environmental regulations are governed by the Ustawa o odpadach (Waste Act) of December 14, 2012. Hazardous waste is subject to registration in the BDO (Baza danych o produktach i opakowaniach oraz o gospodarce odpadami). WEEE regulations are transposed in the Ustawa o zużytym sprzęcie elektrycznym i elektronicznym. The environmental supervision body is the Główny Inspektorat Ochrony Środowiska (GIOŚ).

In Romania, the main environmental regulation is Legea nr. 211/2011 privind regimul deșeurilor. Hazardous waste is subject to management by authorized operators. WEEE regulations are transposed by HG nr. 1037/2010. The environmental supervision body is the Agenția Națională pentru Protecția Mediului (ANPM). Batteries are managed pursuant to HG nr. 1132/2008.

In Spain, the main environmental regulation is Ley 7/2022 de residuos y suelos contaminados para una economía circular, which transposed EU Directive 2018/851. WEEE regulations are governed by Real Decreto 110/2015. The management of end-of-life tires is coordinated by SIGNUS. Batteries are managed by ECOBATERÍAS and ECOPILAS. The environmental supervision body is the Ministerio para la Transición Ecológica y el Reto Demográfico.

Switzerland, although not a member of the European Union, has very advanced environmental regulations, primarily governed by the Federal Act on the Protection of the Environment (EPA, SR 814.01) and the Ordinance on the Avoidance and the Disposal of Waste (ADWO, SR 814.600). Hazardous waste is subject to the Ordinance on Movements of Waste (OMW, SR 814.610). WEEE regulations are governed by the Ordinance on the Return, the Taking Back and the Disposal of Electrical and Electronic Equipment (ORDEE, SR 814.620). The competent body is the Federal Office for the Environment (FOEN/BAFU).

By purchasing a machine from GASPA MACCHINE, the buyer assumes full legal and environmental responsibility for the correct management of the machine during its use and at the time of its end-of-life. GASPA MACCHINE has the obligation to inform the buyer of these obligations, which we list below in a clear and detailed manner.

• Maintain the machine in good environmental efficiency conditions, ensuring that emission reduction systems (DPF, SCR, catalysts, gas recirculation system) are functional and not tampered with.
• Provide for the periodic change of oils and fluids according to the times indicated by the original manufacturer, relying on authorized mechanical workshops that guarantee the correct disposal of waste fluids.
• Do not modify or neutralize emission control systems (so-called chip tuning or DPF/SCR removal), a practice that is illegal in Italy pursuant to Legislative Decree 285/1992 (Highway Code) and in equivalent regulations of other European countries, and which significantly worsens particulate and nitrogen oxide emissions.
• Avoid spills of hazardous fluids on the ground or into surface or groundwater during maintenance operations. In the event of an accidental spill, proceed immediately with containment and remediation, and notify the competent authorities where required by local regulations.

• Deliver the end-of-life machine exclusively to demolishers or authorized treatment centers pursuant to the regulations in force in the country of use, not to unauthorized private individuals or operators not registered in the National Register of Environmental Managers (in Italy).
• Obtain from the demolisher the Certificate of Destruction or equivalent document provided for by local regulations, certifying the correct commencement of the machine's end-of-life.
• Ensure that all hazardous fluids have been drained before delivery to the demolisher, or expressly agree that the removal of fluids takes place at the treatment facility by qualified operators.
• Do not abandon the machine on public or private land, as this constitutes a crime pursuant to Art. 192 of Legislative Decree 152/2006 in Italy and equivalent regulations in other countries.

GASPA MACCHINE declines all responsibility for:

• Environmental damage caused by improper management of the machine after delivery, including fluid spills, excessive emissions from tampered systems, or non-compliant disposal at end-of-life.
• Administrative or criminal penalties imposed on the buyer for violations of environmental regulations during use or at the end-of-life of the machine.
• Costs of environmental remediation resulting from accidental or voluntary spills of hazardous fluids occurring after the delivery of the machine to the buyer.