This week’s joint ENVI/IMCO vote on the End-of-Life Vehicles Regulation (ELVR) is a welcome step towards a more circular automotive industry in Europe. However, while progress has been made, EuRIC warns that low targets, loopholes, and legal uncertainties risk holding back the investments and market confidence needed to scale Europe’s circular economy in practice.
The Parliament’s committees agreed on a reduced recycled content (RC) target for plastics to 20%, with only 10% post-consumer, and a closed-loop target to 15%, within six years of the rules’ entry into force. Although the recycled content target is increased to 25% within 10 years of entry into force, half of it can still be met with pre-consumer waste and a review clause is stablished. EuRIC regrets this outcome, which ignores the JRC’s clear evidence that higher post-consumer recycled content targets are both feasible and realistic, and falls short of Europe’s circular ambitions.
“These low targets reward neither frontrunners who have already invested in circular solutions nor recyclers facing a 30% recycling obligation for ELV plastics without a guaranteed market,” said Maria Vera Duran, EuRIC’s Senior Technical Manager.
The lack of a mirror clause for imports under fair conditions further threatens European recyclers. Moreover, the review clause referencing “excessive prices” adds policy uncertainty, discouraging necessary investments.
Regarding metals, EuRIC welcomes the decision to introduce recycled content targets for steel in ELVs following a feasibility study, aligning with efforts to increase post-consumer recycled metal use in vehicle manufacturing. However, EuRIC urges co-legislators to prioritise the use of post-consumer recycled metals, noting that references in the text to pre-consumer waste and “ferrous scrap” should not dilute the circular ambition. EuRIC also calls for bringing forward the obligation to declare recycled content in vehicles, which has now been postponed to 48 months, despite the inclusion of plastics.
Additionally, EuRIC cautions against introducing low-carbon steel targets in the ELVR while the definition remains under development, reminding co-legislators that the primary aim of the ELVR is to increase circularity within the automotive industry.
The vote also confirmed technology-neutral treatment rules and flexibility for Authorised Treatment Facilities (ATFs), which EuRIC strongly supports. However, EuRIC cautions against future EU rules on shredder output quality, emphasising that quality specifications should remain market-driven, defined by customers to encourage innovation and investment in advanced recycling technologies.
EuRIC also supports the Committees’ move to tighten controls on ELV exports disguised as used vehicles, calling for mandatory roadworthiness checks before export. This will help retain valuable materials in Europe while ensuring exported vehicles are genuinely fit for use.
Lastly, EuRIC welcomes the inclusion of balanced representation within Producer Responsibility Organisations (PROs) but stresses that PROs must remain strictly non-profit. Contracts between PROs and ATFs should remain voluntary and limited to EPR-related obligations, not become a tool for supply control.
The ELVR is a unique opportunity to accelerate Europe’s circular economy and reduce its material footprint. We urge co-legislators to strengthen targets and close loopholes in the next stages so that the ELVR can truly deliver on Europe’s circular and climate ambitions.
Source EuRIC
