On 17 June, EU environment ministers adopted their position on the revised ELV Regulation, with some progress on circularity, especially through support for mandatory recycled plastic targets and improved ELV traceability. However, weaker targets and missed opportunities on metals risk slowing momentum when Europe should be turning decarbonisation into a driver of growth and competitiveness.
While the inclusion of a mirror clause for imports and the requirement for third-party audits of installations producing recycled plastic content material – whether in the EU or abroad – is a welcome step toward fairer competition and traceability, these improvements are overshadowed by a weakening of core obligations.
Lowering the recycled content target from 25% to 15% is a step backwards. It contradicts the Regulation’s stated objectives: a 30% ELV plastic recycling target is set for 60 months, yet only 3.75% recycled content from ELV plastics in new vehicles is required after 72 months. This inconsistency risks undermining both credibility and investor confidence.
“Today, 80% of plastics from end-of-life vehicles are still landfilled or incinerated. This will not change without binding targets that drive both supply and demand. Higher recycling rates can only be achieved if car manufacturers commit to using recycled plastics in new vehicles—circularity must be a shared responsibility across the value chain,” said Maria Vera Duran, EuRIC’s Senior Technical Manager.
While we acknowledge that the scope of the recycled content targets remains as proposed by the Commission, the reduction in ambition sends the wrong signal to recyclers, manufacturers, and investors. Maintaining the 25% recycled plastic target from post-consumer waste —including the 25% closed-loop share—would have sent a clear, coherent signal to scale up investment in circular value chains for plastics.
Regarding ELV treatment, we strongly welcome the preservation of a technology-neutral approach, which allows recyclers to continue innovating. We also stress that quality requirements for recycled metals should be driven by customer specifications, not set in law, to reflect market realities and avoid unintentional barriers to circularity.
The absence of mandatory recycled content targets for metals, particularly for steel, represents a missed opportunity. Without clear demand-side signals, the introduction of stricter quality requirements risks being decoupled from guaranteed uptake in new vehicles.
Moreover, while we welcome the efforts to address the issue of ‘missing vehicles – including the clarification in the general approach that customs controls verifying the export of only roadworthy vehicles should be fully automated – we stress the need for strong enforcement to ensure that ELVs remain in Europe, preserving valuable resources for the European circular economy.
Looking ahead, we urge policymakers not to miss the opportunity to make the ELV framework truly circular – one that secures feedstock, supports recycling, encourages innovation, and delivers on Europe’s climate goals.
Source euric.org
