The 2024 Annual Activity Report of the Extended Producer Responsibility (EPR) for Waste commission has recently been released, providing key insights into the evolution of waste management across multiple sectors. Over the course of 12 meetings throughout the year, the commission closely examined developments in 11 EPR sectors, including ELVs. This report highlights the latest advancements, challenges, and regulatory updates shaping the landscape of extended producer responsibility in France.
France’s Extended Producer Responsibility (EPR) framework for end-of-life vehicles (ELVs) has undergone significant transformation in 2024, driven by new regulatory measures under the Anti-Waste Law for a Circular Economy (AGEC) and the Climate Law. These changes impact vehicle manufacturers, dismantlers, recyclers, and waste management operators, requiring them to align with stricter sustainability and waste management policies.
Regulatory Framework & Key Developments
Previously, manufacturers were required to establish a network of ELV centers to handle vehicle collection, depollution, dismantling, and shredding at no cost to the last owner. In 2024, approximately 1,700 ELV centers operated across France. However, new regulations have introduced a fully operational EPR system covering passenger cars, vans, motorcycles, and quadricycles, requiring all ELV operators to contract with an approved eco-organization or an individual system.
The Climate Law further mandates that ELV collection must be offered free of charge at the vehicle’s location, with an optional return incentive (financial compensation) to improve collection rates.
Implementation & Industry Response
The EPR framework for ELVs has taken two distinct forms:
Eco-Organization Model – “Recycler Mon Véhicule” (RMV) was officially approved as France’s primary ELV eco-organization, bringing together 17 manufacturers under a non-profit association.
Individual Producer Systems – Around 20 vehicle manufacturers, including Renault, Stellantis, and Volkswagen, opted to establish their own independent ELV management systems.
Key Discussions in the Approval Process
Several critical issues emerged during regulatory discussions:
Financial Support for Recycling – RMV committed to financially support the recycling of non-profitable materials (glass, plastics, foams, and fabrics) required under the new ELV guidelines.
Combatting Illegal ELV Trade – RMV proposed a purchase price of €50–150 for four-wheel vehicles and €20–50 for two-wheelers to discourage illegal ELV dismantling and incentivize legal recycling.
Parts Reuse & Network Participation – RMV requires contracted ELV centers to produce reusable spare parts. However, exceptions were debated for older vehicles unsuitable for dismantling.
Industry Coordination – Given the high number of individual systems, stakeholders discussed the need for a coordinating body to streamline interactions between the eco-organization and independent producer systems. The French government acknowledged the need but noted that current legislation does not mandate such coordination.
Manufacturer-Specific Systems & Debates
Renault, Stellantis, and Volkswagen sought individual EPR approvals, raising industry-wide concerns:
Renault’s Use of INDRA – Renault’s reliance on INDRA (a joint venture with SUEZ) for ELV management sparked concerns about data confidentiality and fair competition. Regulators requested contract revisions to improve transparency.
Cost of ELV Collection – Renault and Stellantis faced criticism for not covering ELV transport costs within a 30–50 km radius of collection centers.
Material Recovery Rights – Stellantis and Volkswagen sought preferential rights to reclaim recyclable materials (metals, plastics) from ELV centers, but waste processors opposed this, arguing it disrupts fair competition.
Lack of Coordination – Volkswagen emphasized the need for greater alignment between the eco-organization and individual systems, though some manufacturers resisted external coordination.
Additional Manufacturer Approvals
Beyond these three major players, 13 other automakers, including Toyota, Nissan, Ford, Tesla, and Honda, received individual EPR approvals through written submissions.
Discussions centered on:
The role of third-party service providers (e.g., INDRA & VALORAUTO) managing multiple producers’ systems.
Concerns over competition laws and potential monopolization in ELV waste processing.
Need for a common digital platform for reporting ELV data to ease administrative burdens on waste operators.
Future Outlook & Industry Impact
The EPR evolution in the ELV sector signals increased regulatory pressure on automakers and recyclers to enhance sustainability, reduce waste, and ensure fair market practices. Key challenges ahead include:
- Harmonizing eco-organization and independent producer systems to simplify compliance.
- Ensuring fair competition in material recovery and spare parts resale.
- Developing centralized data reporting tools to improve industry oversight.
- Enhancing financial support for ELV collection and recycling efforts.
For automakers, waste processors, and recyclers, staying compliant with these new regulations is critical. Businesses must adapt to the evolving EPR landscape, invest in sustainable vehicle lifecycle management, and navigate increasingly complex waste recovery obligations in France.
Source acrobat.adobe.com
