EU lawmakers have agreed a new Regulation merging ELV and 3R rules, adding a Circularity Vehicle Passport, EU-wide EPR and recycled-content requirements. But EEB and DUH say industry pressure watered it down: recycled plastics cut to 15% after six years, key treatment and export controls delayed, and little to drive smaller, repairable vehicles.
Early on 12 December, EU lawmakers struck a political agreement on new rules meant to make the automotive sector more circular, but the deal falls short of its promise, warn the European Environmental Bureau (EEB) and Environmental Action Germany (Deutsche Umwelthilfe, DUH).
The text agreed last night updates and merges the outdated End-of-Life Vehicles Directive and the 3R Type-Approval Directive into a single Regulation on Circularity Requirements on Vehicle Design and on Management of End-of-Life Vehicles [1]. It was billed as an opportunity to strengthen the EU single market, boost circularity and cut the environmental impacts of how cars are designed, built, used, and treated at the end of life.
EU Council and Parliament agree new vehicle circularity and ELV rules
The regulation introduces promising tools, including a Circularity Vehicle Passport, an EU-wide Extended Producer Responsibility (EPR) system, minimum recycled content requirements, and stronger rules on parts reuse and vehicle collection and treatment. In principle, these measures could help drive genuine decarbonisation and circularity. However, environmental organisations had already warned [2] that the negotiations started from a weak foundation that failed to confront the sector’s biggest challenges.
Key gaps included:
- No action to reduce the number and size of vehicles, a major driver of unsustainable material use;
- continued prioritisation of recycling over more effective strategies such as durability, reuse, and repair;
- and insufficient measures to hold producers accountable for used vehicles exported outside the EU.
Caving to pressure from the automotive industry, negotiators further weakened the proposal. Lawmakers slashed recycled plastic content targets from 25% to 15% six years after entry into force, postponing the 25% requirement until a decade after the regulation takes effect. At the same time, mandatory treatment requirements were diluted, and key provisions, including safeguards against the export of old, non-roadworthy and polluting vehicles, were delayed.
The agreement now awaits formal approval by both institutions.
Fynn Hauschke, Senior Policy Officer Circular Economy and Waste at the EEB, said:
“This deal is a textbook case of political backsliding under industry pressure. Instead of steering the automotive sector towards fewer, smaller, and more repairable vehicles, EU lawmakers chose to recycle old mistakes. By weakening key circularity requirements and scaling back ambition on recycled plastics, they’ve missed a crucial opportunity to put the automotive sector on a truly circular path.”
Barbara Metz, Managing Director at DUH, said:
“It is scandalous that the agreed vehicle regulation contains such weak requirements for producer responsibility in the automotive sector. The anti-recycling cartel uncovered by the EU Commission this year shows that manufacturers must be subject to effective requirements to meet their recycling and reuse obligations. To reduce the environmental impact of cars over their full life cycle, manufacturers must be obligated to use resource-saving designs, ensure reparability, and invest sufficiently in reuse and high-quality recycling of end-of-life vehicles.”
Further reading on Auto Recycling World
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ELV plastics: targets, tension and opportunity
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Will Europe’s new ELV rules work for ATFs, or against them?
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The End-of-Life Vehicle Regulation is in its final approval phase — what next?
