ASSESSMENT OF THE DRAFT ELV DIRECTIVE AND A COMPARISON WITH THE CURRENT SITUATION IN TÜRKİYE
The EU’s draft End-of-Life Vehicles (ELV) Directive sets stricter rules on reuse, traceability, recycled content and producer responsibility. However, Türkiye’s current framework still lacks clear technical definitions, digital tracking systems and structured reuse standards. Bridging these gaps will be essential for aligning national practice with the Directive’s circular economy ambitions.
The EU’s draft End-of-Life Vehicles (ELV) Directive signals a tougher, more circular approach to vehicle design and end-of-life treatment, expanding scope, tightening traceability, strengthening extended producer responsibility (EPR) and putting reuse on a firmer footing alongside recycling. Günay Dar, ÖTASAD Chairman, Beker Recycle General Manager, and a member of the TOBB Waste and Recycling Industry Council, assesses the proposed changes and compares them with Türkiye’s current framework, outlining gaps, opportunities, and priority actions.
The draft End-of-Life Vehicles (ELV) Directive of the European Union introduces significant innovations in line with the principles of environmental protection, resource efficiency, and the circular economy. These innovations and updates entail substantial changes and new obligations across key areas, including scope, definition, reuse, recycling targets, responsibilities, traceability, and ELV dismantling processes.
In this article, I aim to briefly address the above-mentioned topics, which are of particular importance, and to evaluate their implications, compare them with the current situation in Türkiye, and outline the actions required.
SCOPE
With the new draft, the scope of the Directive has been significantly expanded. In addition to passenger cars and light commercial vehicles, certain categories of heavy-duty vehicles are also brought within scope.
Electric and hybrid vehicles, batteries, and electronic components (particularly lithium-ion batteries) are explicitly emphasized.
While the existing ELV Directive primarily focuses on the collection, recovery, and disposal of vehicles to mitigate their environmental impacts, the Draft ELV Directive adopts a broader perspective. It incorporates circular economic approaches, such as reuse, refurbishment, repair, and redistribution, not only of vehicles but also of their components and parts.
Current Situation in Türkiye
In addition to the ELV Regulation, the scope has been expanded through the ELV Notification, which covers trucks and buses and specifies the necessary infrastructure requirements. Through TOBB, standards have been introduced to determine the capacity conditions of licensed sector operators (ELV dismantling and treatment facilities). In the last quarter of 2025, preparatory work was initiated to include L-category vehicles in the regulation in addition to N1 and M1 categories. However, the amendments related to scope expansion have not yet been implemented in practice.
Given the high number of commercial vehicles in Türkiye, expanding the scope would yield significant benefits for the environment and the sector.
DEFINITION
ELV is defined as “a vehicle that is no longer usable, has reached the end of its economic or technical life, is irreparable, or has been relinquished by its owner for reuse as parts, waste treatment, or disposal.”
The phrase “technically irreparable” refers to situations in which a vehicle can no longer be repaired in a safe, economically viable, and sustainable manner, based on technical criteria, such as ’severe engine damage, chassis damage, or battery failure’.
Reusable parts are defined as “parts, modules, or components that can be reused in another vehicle or application without losing their functionality after being removed from the vehicle.”
Current Situation in Türkiye
The ELV definition is limited to “vehicles that are not economically repairable,” which does not adequately serve the purpose in practice. It is of critical importance that the definition incorporates technical criteria alongside economic indicators.
Accordingly, clear standards and technical criteria for “ELV/Total Loss” classification must be established, and the procedures and principles governing reusable parts must be clearly defined.
REUSE
The existing Directive contains very limited provisions on the reuse of parts and is largely recycling-oriented.
The Draft Directive introduces explicit rules to support the reuse, refurbishment, and repair of parts and components, thereby increasing economic and environmental benefits. Reusable parts are positioned as a priority within the circular economic framework.
Under “recovery and separation obligations,” a wider range of components, including electronic modules, plastic parts, and motor windings, must be mandatorily dismantled. Parts are required to be tested and labelled not only in terms of quantity or volume, but also with respect to their reuse and refurbishment potential.
The accountability framework is expanded to require vehicle manufacturers to provide part-related information and traceability throughout the entire lifecycle, from production to recycling (including certified parts management, registration systems, and traceability).
Under the obligation of “dismantlability and identifiability,” manufacturers are required to design vehicles in a manner that facilitates easy dismantling. Mandatory part marking and identification (e.g., QR codes, RFID, product identifiers) will enable dismantling facilities to determine part compatibility with specific vehicle models.
Regarding “Parts Dismantling and Distribution Networks,” Member States are expected to establish authorized networks for the extraction, storage, and marketing of reusable parts. The ELV process must be carried out by licensed dismantling facilities that are also authorized to sell the recovered parts.
Above all, the technical suitability of batteries and electrical components (lithium-ion battery modules and e-motors) for reuse is to be assessed, with separation for remanufacturing and support for the “second life” concept.
Under labelling and information-sharing requirements, digital access must be provided for each part, including material composition, production date, compatibility information, and recycling/reuse suitability.
While the Draft ELV Directive encourages the use of reusable parts, it also introduces restrictions and conditions in certain cases to mitigate risks related to safety, environmental performance, and traceability. Safety-critical components (such as airbags, brake hoses, and seat belts) are generally prohibited from reuse or subject to very stringent testing requirements. Batteries and modules may only be reused if tested and documented. High-voltage electrical components (e.g., inverters, e-motors) may be reused only following mandatory certification and safety testing. Fuel system components must be inspected due to leakage and safety risks.
Under “consumer safety and liability,” reused parts placed on the market must clearly indicate their origin and be supported by technical documentation and warranty provisions.
Components Not Recommended for Reuse
The reuse of safety-critical components is generally discouraged or prohibited, including the following:
- Airbags, seat belts, crash sensors, ABS/ESP control units, and steering wheels or columns exposed to impact.
- Components containing hazardous substances (e.g., lead, mercury, cadmium, chromium) should not be reused.
- Damaged high-voltage system components in electric vehicles, such as lithium-ion battery modules with fire risk, inverters, connectors, and HV cables, must be subject to strict inspection if reuse is considered.
- Destroyed components such as punctured fuel tanks, gas-filled shock absorbers, and catalytic sections of exhaust systems are excluded from reuse.
According to the draft ELV Directive, the repair or reuse of safety-critical components, such as airbags and seat belts, is generally prohibited or subject to very strict restrictions. Such components are classified as single-use, non-repairable, high-risk safety equipment, and, as a rule, their repair or second use is not permitted. Reuse of safety systems (e.g. airbags and seat belts) is only possible where they have been tested and approved by the manufacturer.
According to the draft ELV Directive, the reuse of main structural components of vehicles, such as the body (body-in-white) or the chassis (load-bearing structure), is not absolutely prohibited; however, it is subject to very stringent technical, safety and traceability criteria.
Current Situation in Türkiye
Reuse practices for parts (including insurance-returned parts and parts replaced during repairs) exist; however, there is a need for system-wide registration, traceability, labelling, standardized criteria, and the publication of clear reuse procedures and principles.
Regarding parts that must not be reused, technical guidelines in Türkiye indicate that such parts are non-repairable and may not be sold as second-hand; however, in practice, no general system of restrictions, monitoring or control is in place. Specifically, there is a clear need for the explicit identification and publication of parts and components that must not be reused.
In particular, the recycling process for EV batteries, including storage, pre-treatment, processing, and recovery, must be clearly defined. Standards for facilities, machinery, certification, and the reuse of batteries from ELV-status EVs (total loss, fire-damaged, flood-damaged) must be established.
RECYCLING TARGETS
The Draft Directive requires that new vehicles contain at least 25% recycled plastic material at the production stage, with the possibility of setting more advanced sustainability targets for steel, aluminum, and critical raw materials.
Current Situation in Türkiye
Based solely on ELV sources, achieving this ratio appears challenging, as Türkiye’s annual ELVs count averages approximately 5,000 vehicles. Most of these, primarily insurance-based ELVs, are reused as spare parts.
However, the required ratios could be achieved by including parts replaced during vehicle repairs (including insurance-returned and warranty-replaced parts) within the regulatory framework.
Additionally, planning mechanisms such as scrappage schemes or Special Consumption Tax (SCT) incentives could significantly increase recyclable material content by classifying approximately 10 million vehicles aged 20 years or older as ELVs based on environmental or legal non-compliance (e.g., emissions and safety).
RESPONSIBILITY
Financial Responsibility
Under Extended Producer Responsibility (EPR), manufacturers are responsible for all processes, including collection, transportation, separation, digital labelling, and reporting. These obligations may be fulfilled directly or through authorized Producer Responsibility Organizations (PROs).
Collection Network
The Draft ELV Directive includes provisions regulating the establishment of collection networks for both ELVs and parts replaced during vehicle repairs.
The obligation applies to vehicle manufacturers (OEMs), authorized distributors, authorized repair services, and recycling/dismantling facilities.
The scope includes ELV-derived parts, parts replaced during repairs, and components replaced under warranty.
Producers or authorized organizations are responsible for collecting, monitoring, and assessing the reuse potential of these parts.
In setting up the collection network, the technical objectives are to establish nationally accessible collection points (e.g., at least one center per city/region), provide free-of-charge drop-off rights, integrate the network with a digital tracking system, label collected parts via a digital passport system and make them visible within the system, and ensure their integration and traceability for recovery targets.
EPR (Extended Producer Responsibility)
Extended Producer Responsibility (EPR) is an environmental policy approach under which producers are held responsible not only for the environmental impacts of products during manufacturing, but throughout the entire life cycle of the product.
EPR is a system that assigns responsibility for the collection, recycling, and disposal of a product to the producer once its useful life has ended. EPR aims to reduce waste at the source, promote the design of products that are suitable for recycling, increase recovery rates, ensure producers assume environmental responsibility, and reduce the burden of waste management on public resources. EPR applies to packaging, electrical and electronic equipment (EEE), tyres, motor vehicles (within the scope of ELV), batteries and accumulators, and, in some countries, furniture and textiles (in some countries).
Under the EU’s draft ELV Regulation, vehicle manufacturers will not only be responsible for producing vehicles but will also be financially and organizationally accountable for the processes of vehicle end-of-life treatment, dismantling, recycling and reuse of vehicle components.
Role of Recycling Companies
Authorized Treatment Facilities (ATFs) are responsible for treatment and recovery processes.
However, they are not legally responsible for financing collection networks; the financial burden rests with manufacturers under the EPR principle.
Recycling companies act as implementers rather than cost bearers.
National authorities are obliged to establish monitoring and support mechanisms to prevent recycling companies from being placed at an economic disadvantage.
Current Situation in Türkiye
Legal frameworks governing EPR, including authorized organizations, should be supported by additional notifications and implementation guidelines.
Given economic conditions and existing structures, it is deemed appropriate to establish collection networks at the metropolitan or regional level rather than on a province-by-province basis.
It is also critical to register parts replaced during repairs within a national data system, label them at the source, and establish digital passports to ensure traceability.
TRACEABILITY
The Draft ELV Directive introduces clear obligations for registration, digital tracking, and reporting of both waste parts and reusable components, aiming to ensure transparency, traceability, and environmental compliance throughout post-dismantling processes.
Manufacturers must establish comprehensive record systems covering vehicle design, components, plastic content, critical raw materials, and usability reports.
Part Tracking and Documentation (Digital Passport). Part tracking and documentation should be implemented through a digital data system for reused parts. Information such as the production date, previous use, and technical condition of parts must be recorded in the digital system. Through this system, it should be possible to track which part was used in which vehicle, at what time, and in what status. After evaluation, each part should be integrated into the process under one of the following categories: reuse, remanufacturing, refurbishment, recycling, or disposal. The process must be documented and recorded digitally. The reuse of a part is only possible if its digital traceability is ensured.
ELV dismantling and treatment facilities, manufacturers and economic operators are obliged to report data regarding reused parts and disposed waste to the competent authorities.
Digital Product Passport (DPP)
The draft ELV (End-of-Life Vehicles) Directive foresees the implementation of a Digital Product Passport (DPP) for batteries and reusable parts. This system is designed for part tracking, reuse, recycling and sustainability purposes. Its objectives are to ensure traceability of parts, facilitate reuse and recycling, provide information on hazardous substances, and establish data transparency among economic operators.
Information to be included in the DPP:
- Unique identifier (serial number, QR/RFID)
- Manufacturer name, address, and production date
- Part type, model number, and weight
- Material composition (percentages of critical raw materials, plastics, metals, glass, etc.)
- Hazardous substances and RoHS compliance
- Reusability status
- Recycling data (material separability, ease of dismantling, recommended methods)
- Repair information (technical manual links, dismantling/repair schematics)
- Energy and performance data for batteries (capacity, cycle count, State of Health)
- Certificates/test results
- Waste codes
- Legal warnings (ADR, CLP, REACH);
- QR code/data access for authorized operators (cloud, API)
- Data updatability by manufacturers as well as insurance companies, repair services, and dismantling facilities.
Parts subject to mandatory DPP implementation:
- High-risk and high-value components
- High-voltage batteries (EV/hybrid)
- Motors, inverters, electronic control units
- Catalytic converters, seat belt systems
- Parts containing hazardous substances (e.g., airbags)
- Components with high reusability potential, such as headlights, mirrors, doors, wheels, and multimedia units.
Within the Digital Product Passport (DPP) to be established under the draft ELV Directive, the vehicle identification details of the vehicle to which the part belongs must also be included.
The vehicle information required in the Digital Passport includes:
- Brand (manufacturer)
- Model name
- Production year
- Chassis number (VIN)
- Engine number (physical production serial number of the engine block, ECU, etc.)
- OEM part number (Original Equipment Manufacturer number)
- Part name/description (general name and function of the part)
- Location where the part was installed in the vehicle (optionally)
This Data should be integrated into the system via QR codes, RFID tags, or cloud-based data connections.
It should be designed to be readable using handheld terminals at ELV facilities or repair workshops.
Under the draft ELV Directive, parts replaced under warranty are not necessarily required to be destroyed or disposed of immediately; rather, their evaluation for reuse, refurbishment, or remanufacturing is encouraged.
Considering the overall approach of the draft ELV Directive and the EU Digital Product Passport (DPP) policies, parts replaced during repair, particularly those replaced under warranty or under an insurance policy, should be tagged with a digital passport if they are assessed as suitable for reuse.
Within the framework of the draft ELV Directive and the broader EU environmental legislation, a waste management plan must be prepared for parts replaced during repair, and these parts must be documented and recorded accordingly.
Current Situation in Türkiye
The legal framework for ELV recycling processes in Türkiye is largely aligned with EU legislation. However, during implementation, particularly in relation to inventory creation, recording, and system integration (notably for reusable parts, insurance-returned parts, etc.), there is a lack of detailed standard procedures. It is considered necessary that these procedures be explicitly defined in both the legislation and the implementation drafts, be subject to enforcement and inspection, and be supported by the dissemination of best-practice examples. The realization of this process is expected to eliminate informal economic practices and reduce associated fiscal losses.
ELV DISMANTLING
The draft ELV Directive (new EU regulatory proposal) clearly defines the mandatory depollution and parts dismantling processes for ELVs.
According to the draft ELV Directive, upon arrival at a licensed facility, the following parts and fluids must be removed/collected:
- All fluids (oil, fuel, brake fluid, coolant, air conditioning refrigerant, etc.) must be stored to prevent leakage and then disposed of or recovered.
- Battery – due to the presence of hazardous chemicals, it must be processed separately.
- Airbags, gas generators, and seat belt pretensioners – these must be safely removed due to the risk of explosion.
- Catalytic converters – as they contain valuable metals, they should be recovered or reused.
- Tyres and wheels – tyres should not be treated as mixed waste and must be collected separately.
- Glass (windshield, side windows, rear window) – automotive glass is laminated and requires separate processing and separation.
- Electronic control units (ECUs) and sensors – due to valuable electronic content, they should be removed for potential reuse.
- Sensitive metal components – components containing copper, aluminum, and rare metals should be dismantled without damage.
According to the draft ELV Directive, parts that are suitable for reuse must be dismantled from the vehicle. This dismantling must take place after the vehicle arrives at an Authorized Treatment Facility (ATF) and prior to the shredding process. Reusable parts must be identified, classified, and removed before the vehicle enters the shredder; their functional condition must be tested, and they must be labelled and segregated for reuse.
Current Situation in Türkiye
The Ministry of Environment has introduced a requirement that ELVs be photographed upon arrival at treatment facilities and that these images be uploaded to the Ministry’s integrated environmental system. This practice has prevented the unlawful issuance of disposal forms based solely on paperwork, rather than on the physical delivery of ELVs to facilities.
However, the storage and dismantling processes for electric vehicles at facilities need to be fully defined. The treatment process for EVs and EV batteries classified as ELVs (e.g., total loss, fire-damaged, or flood/water-damaged vehicles) should be established, including facility infrastructure and machinery/equipment standards.
Considering the approximately 10 million vehicles in operation that are 20 years old or older, it is important to plan the gradual classification of these vehicles as ELVs over time (e.g., through scrappage schemes or SCT reduction incentives) based on environmental or legal non-compliance issues (such as emissions and safety). In addition to environmental benefits, this process is expected to generate approximately 20 million tons of raw materials, yielding significant economic impacts and benefits.
Further Reading on Auto Recycling World
- EU Council and Parliament agree new vehicle circularity and ELV rules
- Will Europe’s new ELV rules work for ATFs, or against them?
- Preparing for EPR for HDVs: What the data means for recyclers
- Portugal tightens ELV controls as APA puts data, traceability and producer duties under the spotlight
