FEAD says future ELV Regulation recycled-content targets for steel and aluminium must focus on post-consumer materials recovered from genuine waste streams, including end-of-life vehicles. The association warns that including pre-consumer industrial scrap would weaken circularity, dilute investment incentives and risk rewarding material loops that already function without new policy support.
Following its adoption in June, the new EU End-of-Life Vehicles Regulation (ELVR) is advancing the debate on recycled content requirements for steel and aluminium in vehicles. In line with Article 6 of the Regulation, the Joint Research Centre (JRC) launched a feasibility study in April to assess the possible introduction of such targets, gathering input from stakeholders across the automotive, metals, and recycling value chains.
For FEAD, the European Waste Management Association, the recycling industry strongly supports the development of recycled content requirements, provided they genuinely strengthen circularity and create demand for materials recovered from end-of-life vehicles (ELVs).
A key issue for recyclers is the definition of ‘recycled content’. FEAD believes that recycled content targets should focus exclusively on post-consumer waste streams. Including post-industrial or pre-consumer scrap risks weakening the environmental objective of the legislation by rewarding material flows that are often already reintegrated into manufacturing processes and do not face the same collection, dismantling and treatment challenges as end-of-life materials.
In addition, the inclusion of pre-consumer waste would increase administrative burdens for both recyclers and manufacturers without delivering additional circularity benefits. Focusing instead on post-consumer waste would help target material streams that are currently less valorised and have greater potential for circularity improvements.
By contrast, post-consumer steel and aluminium recovered from ELVs require complex recycling operations and significant investments in collection, sorting, shredding and recovery infrastructure. Recycled content targets should therefore incentivise the use of secondary raw materials originating from genuine waste streams, in line with the principles of the circular economy.
Mandatory recycled content targets can also help create long-term market demand for recycled metals, supporting investments in recycling technologies and strengthening Europe’s resource security. As the automotive sector is one of Europe’s largest consumers of steel and aluminium, increasing the use of recycled post-consumer materials would contribute to reducing dependency on primary raw materials while lowering environmental impacts.
At the same time, FEAD underlines the need for harmonised methodologies and traceability rules. Clear definitions, verification systems and calculation methods will be essential to ensure a level playing field and avoid greenwashing or inconsistent reporting across the value chain.
FEAD also stresses that any future targets must remain technically and economically feasible. The JRC study should carefully assess market realities, material availability, recycling capacities and technical constraints linked to automotive-grade steel and aluminium.
As Giulia Caroli, Junior Technical Officer at FEAD, states:
“Recycled content targets can become a powerful market driver for circularity in the automotive sector, but only if they effectively support the recycling of post-consumer waste. The new Regulation should incentivise the use of materials recovered from end-of-life vehicles, rather than rewarding established industrial scrap loops that already function today.”
For FEAD, the ongoing JRC work represents an important opportunity to strengthen Europe’s circular economy framework and ensure that recycled content targets effectively support high-quality recycling, industrial resilience and long-term investment in the recycling sector.
FEAD is the European Waste Management Association, representing the private waste and resource management industry across Europe, including 21 national waste management federations and 3,000 waste management companies. Private waste management companies operate in 60% of municipal waste markets in Europe and in 75% of industrial and commercial waste. This means more than 500,000 local jobs, fuelling €5 billion in investment in the economy every year.
For more information, please contact: info@fead.be
Further Reading on Auto Recycling World
- FEAD Welcomes the Adoption of End-of-Life Vehicles Regulation as a Step Forward for European Circularity
- European ELV Regulation Approved: A Historic Step for Circular Vehicle Recycling
- The ELV-R Regulation’s Impact on the Plastic Industry
- Mandatory Recycled Content Quota: A Double-Edged Sword in the Quest for Circularity and Competitiveness
