Germany’s ELV market is under growing strain, with too few vehicles entering authorised treatment, persistent illegal dismantling, and rising demands for traceability and recycled content. LRP Autorecycling argues that stronger enforcement, improved data flows, efficient logistics and closer collaboration across the value chain are critical to making circularity work in practice.
Sophie-Odette Hohlfeld, Project Manager at Germany-based LRP Autorecycling, outlines how Germany’s largest end-of-life vehicle dismantler views the ELV market today. She outlines where the sector is under pressure, from constrained vehicle inflows and uneven competitive conditions to rising demands for traceability, recycled content and regulatory clarity, and why logistics, data and closer collaboration across the value chain will be critical to the future of circular vehicle recycling.
At LRP Autorecycling, part of the MAR Group (Mitteldeutsche Autorecycling Holdinggesellschaft mbH), we process end-of-life vehicles at industrial scale across five authorised treatment facilities in Central and Eastern Germany. Today, the Group combines:
- five authorised treatment facilities (LRP)
- an in-house logistics unit (Autologistik Leipzig GmbH and ALN Logistik) operating Europe-wide
- and a dedicated IT provider supporting dismantling companies and also working with vehicle manufacturers (smoods GmbH).
Our core competencies include vehicle take-back and its associated logistics, environmentally sustainable vehicle recycling, spare parts trading, and the pre-sorting of raw materials for downstream material recovery. This integrated setup gives us a broad and practical view of the ELV sector. That perspective matters because the German market is under growing pressure: too few end-of-life vehicles reliably enter the legal treatment channel, traceability requirements are rising, and the gap between political ambition and operational reality remains significant.
The real bottleneck is the inflow of end-of-life vehicles
The inflow of end-of-life vehicles in Germany is currently one of the sector’s main problems. A major reason is the size of the illegal market. In Germany itself, many vehicles are dismantled by illegal operators, with the resulting spare parts sold on. Unfortunately, this is done without regard for environmentally sound disposal, and all kinds of pollutants are released into the environment. The reason illegal operators are able to act so easily in Germany is the disregard for existing laws. The Certificate of Destruction, which must be issued for every vehicle that has definitively reached end-of-life, is not requested by the German authorities. A vehicle can therefore be deregistered without a Certificate of Destruction and, after a few years, when the data have been deleted from the authorities’ systems, no one will know that this vehicle still exists or where it is.
In our case, most vehicles reach us through workshops and automotive businesses; the rest come from private customers via direct enquiries, referrals and local visibility. The workshop channel works when friction is low: fast pickup, clear paperwork, predictable handling and the ability to issue a verifiable Certificate of Destruction or proof of whereabouts through an authorised treatment facility.
Germany’s dismantling landscape looks stronger on paper than it often is in practice. There are still a large number of certified operators, but the market is highly fragmented and much of it operates at a very small scale. Many dismantlers process only limited vehicle volumes each week, while the number of economically resilient professional operators continues to decline. At the same time, too many end-of-life vehicles still fail to reach documented, authorised treatment.
A 2023 snapshot from the German Environment Agency (UBA) clearly illustrates the structural imbalance: while around 2.3 million vehicles were exported as used cars, only 250,749 domestic ELVs were recorded for treatment in Germany. Including imports, the total number of ELVs accepted was 253,195; the lowest level since records began in 2004.
For compliant ATFs, the consequence is clear: a substantial share of vehicles never reaches the regulated channel. Some are exported, some disappear into undocumented routes, and some are handled outside the standards that proper depollution, documentation and certified dismantling require. As long as that persists, compliant operators remain at a structural cost disadvantage against grey or illegal channels that do not carry the same obligations.
From our perspective, this is why the market is at a turning point. The question is no longer whether Germany has dismantling expertise. It does. The question is whether the system can ensure that ELVs actually arrive where professional treatment and circular value creation can begin.
Why the new EU ELV rules matter on the ground
The regulatory framework for end-of-life vehicles in Europe is now moving into a new phase. In December 2025, the EU institutions reached a provisional agreement on a new End-of-Life Vehicles Regulation. The aim is to tighten the rules around vehicle circularity and end-of-life management, in particular by improving traceability, reducing loopholes in exports, strengthening producer responsibility and increasing the role of recycled materials in new vehicles. From our perspective, this matters because it addresses several of the structural weaknesses that have shaped the ELV market for years.
First, the new framework could help close the “missing vehicles” loop.
The biggest lever here is continuous, enforceable traceability, so that ELVs actually reach authorised treatment facilities rather than disappearing into grey or illegal channels or leaving the country as supposedly used cars. If traceability and export rules are applied consistently, this would directly improve the availability of ELVs in the legal channel.
Second, stronger Extended Producer Responsibility (EPR) could improve the economics of proper treatment.
If part of the financial burden of compliant end-of-life treatment is shifted more clearly onto OEMs, this creates stronger incentives to route vehicles into authorised networks and to design vehicles with dismantling and recycling in mind.
Third, mandatory recycled-plastics content targets could create a more stable demand pull for ELV-derived material.
This is especially important for plastics, where regulatory demand can help turn circularity ambitions into actual market demand for recovered polymers, particularly from closed-loop ELV applications.
For this framework to work on the ground, however, enforcement will be decisive. Export controls must include real checks to ensure that only roadworthy vehicles leave the country as used cars, and that ELVs cannot simply be relabelled to bypass treatment. And illegal operators must face more inspections, meaningful penalties and stronger enforcement capacity; otherwise, compliant ATFs will remain at a structural cost disadvantage.
Why plastics are becoming strategically important
One of the clearest market signals we see today is the growing demand for plastics, especially technical engine-bay plastic components such as covers, housings, ducts and reservoirs. OEMs and Tier suppliers are increasingly interested in these parts because they are relevant for recycling trials, material recovery strategies and future closed-loop applications.
This trend is closely linked to regulation. The expected recycled-content requirements for plastics in new vehicles are making ELV-derived plastics strategically more important across the value chain. In particular, the focus on higher recycled-content shares and closed-loop material use means that dismantlers will play a more important role in ensuring that suitable plastic components are identified, removed cleanly, documented properly and routed into the right recycling streams.
For dismantlers, this changes the role we play. We are no longer only at the end of a disposal chain; we are becoming an upstream raw-material interface for future automotive circularity. But that only works if components can be recovered in a quality-assured and traceable way before they are lost in mixed downstream processing.
How internal traceability already works
At LRP, we can already ensure strong internal traceability. Through our IT setup via smoods, we work with datasets that link parts and material streams back to the source vehicle at VIN level and create a consistent digital audit trail covering identification, categorisation and condition.
Combined with standardised dismantling workflows, trained staff and controlled handling, this gives us a reliable internal basis for reuse, recycling and commercial processing.
The bigger issue is what happens between actors. While internal traceability is already achievable, consistent data exchange across the wider ELV value chain is still not in place. That means end-to-end traceability, from vehicle to dismantler to recycler to OEM or supplier, remains incomplete in real-world cases.
What dismantlers need from OEM data
To dismantle and sort ELVs more intelligently, and to pre-remove high-impact parts before shredding, dismantlers need more reliable and standardised product data. This includes material information at component level, clear part identification and variant information, safety and compliance flags, and, where available, clearer guidance on preferred routes such as reuse, remanufacturing or material recycling.
In return, dismantlers can provide equally valuable feedback to design: which parts are systematically difficult to remove, where contamination risks arise, and how future vehicles could be made more suitable for real-world dismantling.
What’s realistically changing in the next 12–24 months
The short-term future will not be defined by fully integrated, real-time data exchange across the whole industry. What is more realistic is continued progress through pilot projects, publicly funded initiatives and practical use cases that move the sector towards more standardised data exchange. The regulatory push will accelerate that process, especially around traceability, recycled content and circular business models, but the next phase is still one of preparation, standardisation and industrial learning rather than full transformation.
Collaboration as the route to practical circularity
Our role in this market is not simply to process volume. It is to help move the ELV sector away from survival through price competition alone and towards high-quality, traceable circular value creation. That requires operational scale, as well as logistics, data, standardised processes, and closer cooperation across the value chain.
These partner requirements, compliance and predictability for OEMs, consistent volumes and low contamination for recyclers, and reliable availability and fulfilment for the parts market, are exactly why we take a patient, long-term approach. We are building a carefully selected international partner network to scale certified used parts and OEM new parts packages across Europe.
The future of ELV recycling will not be secured by dismantlers alone, nor by regulation alone. It will depend on both enforceable rules that keep ELVs in the legal channel and industrial collaboration that turns those vehicles into traceable parts and materials for reuse and recycling. Europe has the vehicles, the recycling capability, and, increasingly, the regulatory direction. What it still needs is a system that consistently connects those three.
Further Reading on Auto Recycling World
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EU Council and Parliament agree new vehicle circularity and ELV rules
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Portugal’s green-parts programme is improving standards, but enforcement remains the missing link
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Portugal tightens ELV controls as APA puts data, traceability and producer duties under the spotlight
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ELV Plastics: Targets, Tension and Opportunity
