Giulia Caroli, Junior Technical Officer at FEAD (the European Waste Management Association), outlines key priorities for the upcoming End-of-Life Vehicle Regulation. As Europe’s automotive sector evolves, FEAD calls for robust, circularity-focused measures to support recyclers, ensure fair competition, and strengthen Europe’s secondary raw materials market.
The automotive sector is undergoing rapid transformation. With the shift to electric vehicles, the use of increasingly complex materials, and evolving consumer expectations, legislation must evolve in step. The upcoming End-of-Life Vehicle Regulation (ELV Regulation) presents a crucial opportunity to embed circularity into the sector, foster healthy competition, and support Europe’s recyclers.
At FEAD, the European Waste Management Association, we represent the voice of private waste and resource management companies. Our members handle a significant share of Europe’s waste flows (60% share in the household waste market and handle more than 75% of industrial and commercial waste in Europe), and are critical players in the circular economy. In this light, we see the ELV Regulation as a much-needed step forward. But to ensure it delivers in practice, it must set clear and effective rules that support recyclers, promote fair competition, and help build a resilient European market for secondary raw materials.
We need to avoid practices that could distort the market, limit competition, or hinder recycling efforts. Which is why we’re calling on EU policymakers to include five essential recommendations in the final text of the Regulation:
- Uphold the 25% recycled plastics content target
The 25% minimum recycled content target for plastics in new vehicles, as proposed by the European Commission, is not only realistic but also essential. However, to maintain its credibility and effectiveness, the target must focus on post-consumer waste and exclude pre-consumer waste and biobased plastics. Indeed, biobased plastics are not waste-derived as they are not the result of a recycling process. Including pre-consumer plastic waste creates a false perception of progress. Weakening the target by broadening the definition of recycled content would undermine progress towards a more circular automotive sector.
- Introduce a mandatory recycled content target for steel
Steel remains the backbone of vehicle manufacturing. Introducing a mandatory recycled content target for automotive steel will incentivise the use of secondary raw materials, boost investments in advanced recycling technologies, and improve the quality of steel recovered from ELVs. Europe seeks to reduce dependency on primary materials and cut industrial emissions; this presents a clear opportunity to align environmental ambition with industrial resilience.
- Include the waste management sector in the governing bodies of the PROs
EPR schemes can contribute to better ELV recycling, but they are not a catch-all solution, which is why the entire waste management value chain (from ATFs to mechanical recyclers) must be included in the governance of PROs to ensure effective and transparent recycling practices. A collaborative and inclusive approach is key to making EPR work for the sector.
- Ensure full cost coverage of ELVs with ownership retained by recyclers
Manufacturers must cover the full costs of ELV recycling, including dismantling and treatment. But just as importantly, recyclers should retain ownership of the valuable materials and parts they recover. This principle is vital for ensuring fair competition and rewarding recyclers for their efforts in creating value from waste. Without it, investment in recycling could stall, undermining the very objectives of the Regulation.
- Clarify the role of ATFs and collection points
To ensure a clear separation of responsibilities between collection points and Authorised Treatment Facilities (ATFs), the Regulation must establish ATFs as the sole entities authorised to issue Certificates of Destruction.
End-of-life vehicles (ELVs) should be delivered to ATFs within a reasonable period, ideally no later than 30 days after collection. To guarantee the correct handling and treatment of ELVs, formal and binding contractual arrangements between collection points and ATFs should be made mandatory.
The ELV Regulation has the potential to become a cornerstone of circularity in Europe’s automotive sector, but only if it includes the right provisions to support innovation, investment, and competitive markets. At FEAD, we are ready to collaborate with policymakers and stakeholders to ensure this Regulation delivers on its promise, enabling Europe’s recyclers to continue driving the circular economy forward.
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