EU Vehicle Regulation: What Comes Next for ATFs?

The EU’s new Vehicle Regulation will bring major changes for authorised treatment facilities from 2028 onwards, including expanded dismantling requirements and new recycled-content targets. However, concerns remain over plastics economics, extended producer responsibility and how costs will be shared, making effective implementation and industry cooperation critical.

EGARA representative speaking at an automotive recycling conference — Henk Jan Nix

Henk Jan Nix, Secretary of the European Group of Automotive Recycling Associations (EGARA), examines the publication of the EU’s new Vehicle Regulation and what it means for authorised treatment facilities across Europe. He looks at the staged introduction of new requirements, concerns around plastics recycling and extended producer responsibility, and the challenges still facing the sector as implementation begins.

On 24 July 2026, the long-awaited “Regulation (EU) 2026/1738 of the European Parliament and of the Council of 8 July 2026 on circularity requirements for vehicle design and on management of end-of-life vehicles, amending Regulations (EU) No 168/2013, (EU) 2018/858, (EU) 2019/1020 and (EU) 2023/1542 and repealing Directives 2000/53/EC and 2005/64/EC”, more simply referred to as the Vehicle Regulation (VR), was finally published. Although the final text had been adopted a month earlier, it had not yet become the formal legal text. The publication date is therefore significant, as it sets the timetable from which the various obligations will begin to apply. This does not mean every requirement must be met immediately from 24 July, however, as most obligations will be introduced in stages.

For instance, the VR will generally apply from 1 September 2028. So we have some time to prepare. Our governments also need time to adapt other national laws to the VR so they don’t contradict or overlap. But other obligations have more specific stages. From 1 September 2029, ATFs will need to remove more specified parts and components before shredding or compacting than they do now.

OEMs also face specific stages. New vehicle types type-approved from 1 September 2032 will need to contain at least 15% recycled plastic, of which at least 20% must come from plastics recycled from ELVs or from vehicle parts removed during their use phase. Four years later, from 1 September 2036, recycled plastic content must increase to 25%, with at least 20% of that target still coming from ELVs or vehicle parts removed during use.

Dismantled vehicles stored at an automotive recycling facility — Image credit: Envato Elements

Removed vehicle bumpers and automotive plastic components awaiting processing — Image credit: Envato Elements

If we look at these percentages, we do not expect the targets alone to create a sufficient market for the ELV plastics that ATFs may need to separate. Effectively, 20% of the 15% recycled plastic target equates to 3%. Four years later, 20% of the 25% target equates to 5%. Also bear in mind that ATFs will face expanded dismantling and separation requirements from 2029, several years before these recycled plastic requirements for new vehicle types take effect. This is quite a clear example of potentially unprofitable material removal for ATFs.

To avoid shifting all negative effects onto the dismantlers, the VR describes extended producer responsibility (EPR) in greater detail. The question, however, is whether EPR will be sufficiently addressed by the time these requirements apply. Will PROs be capable of setting up EPR systems that actually compensate unprofitable labour? Will individual producer systems, where each brand operates separately, be able to perform the EPR obligations to the satisfaction of ATFs?

The VR may be published, but it is not a matter of simply relying on everyone to comply or to at least act as expected. There are so many stakeholders, so many interests, and so many interpretations. Many will probably just wait and see what comes to them. Many will probably hope for the best and that they will not be affected. Some just need to take the first step, some need to respond, and some should take the initiative to avoid complicated or negative situations for themselves.

*Historic vehicles at Båstnäs Car Cemetery in Sweden, a reminder of how approaches to end-of-life vehicle management have evolved. Credit: Henk Jan Nix*

Another issue we have described before is: How is the VR related to the Battery Regulation (BR)? Who provides EPR? Will gaps and overlaps actually be addressed? In the car, a battery falls under the scope of the VR, including its removal, but once removed from the vehicle, the battery falls under the scope of the BR. The fact that batteries have their own Regulation makes the situation even more complicated. In many countries, not even the costs of battery collection are covered, while the BR’s waste-battery provisions, including EPR, have been in effect for a year. This is shocking and does not promise much for the integration and implementation of the VR.

Technician working with an electric vehicle battery during vehicle dismantling — *Image credit: Envato Elements*

As said, the VR is published. But we are still far from effective implementation. A lot of negotiation and lobbying will be necessary to realise the rights that the Regulations provide us. We (ATFs and EGARA) need to cooperate and align with partners who share our interests and insights to maximise the positive effects these Regulations can have for our industry.

The BR and VR have many obligations and limitations, but they also provide many advantages that we need to claim at all costs. We will keep you posted.