What happens to motorcycles at the end of their life? Unlike cars, they’re often dismantled with care, and their parts reused to keep other bikes running, a quiet, informal circular economy that has long existed in the motorcycling world. But as Europe revises its End-of-Life Vehicles (ELV) Regulation to include L-category vehicles for the first time, it’s vital that the law reflects the unique design, use, and lifecycle of motorcycles.
As Francesco Fenoglio, Public Affairs Officer, ACEM – European Association of Motorcycle Manufacturers, explains, the motorcycle industry supports the regulation’s goals, but warns that copying car-based rules without adaptation risks missing the mark. Motorcycles aren’t cars, and it’s time EU legislation recognised that.
Have you ever wondered what happens to motorcycles at the end of their life?
Often, they’re carefully dismantled, with parts finding new life in other motorcycles. Parts like catalytic converters, wheels, and batteries are accessible and replaceable with relative ease, keeping them running and extending their time on the road. This informal circularity has long been part of the motorcycling sector, but now, things are set to change. For the first time, the revision of the End-of-Life Vehicles (ELV) Regulation proposes extending its scope to include L-category vehicles: mopeds, motorcycles, tricycles, and quadricycles, aligning environmental objectives with the evolving mobility landscape.
As ACEM, the European Association of Motorcycle Manufacturers, we fully support this direction, and our industry is ready to contribute. But to get this right, the law must treat motorcycles not as scaled-down cars, but as the distinct, diverse, and efficient vehicles they are.
Design for circularity with realistic expectations
The nature of motorcycles makes them inherently more “open” in design than cars. Many components are already exposed and modular, easing disassembly. That’s why we support applying provisions on removability and part treatment (like those in Articles 8, 11, 12, 30 and 31 of the draft ELV Regulation) to motorcycles, provided they are tailored to our vehicles’ specific structure.
A copy-paste approach won’t work. The annex that lists car parts for mandatory removal cannot simply be applied to motorcycles. We propose a dedicated annex reflecting the parts that are both valuable and realistically removable from L-category vehicles within the given timeframe. These include batteries, wheels, tires, and catalytic converters. Attempting to remove deeply embedded electronics or mandate full battery disassembly at the cell level would create safety risks and unjustified costs, especially for SMEs.
We must acknowledge complexity where it exists. For example, dismantling electric drive motors or accessing proprietary electronics raises questions about cybersecurity, safety, and liability. These are not trivial concerns; they require time, clarity, and collaboration across the entire value chain.
Five years to get it right
Industry needs time to adjust. That’s why we strongly support the European Commission’s proposed 60-month lead time for new vehicle types. A five-year window is not a delay – it is a necessity. Vehicle development cycles span several years. New models being designed today will enter the market just as these requirements come into force. Condensing this timeline would disrupt planning and undermine compliance efforts.
Our support for many provisions of the Regulation hinges on preserving this lead time. Without it, even the most well-intentioned requirements could become counterproductive.
Information sharing must be fair and safe
As an industry, we are committed to supporting dismantlers and recyclers. We already provide repair and maintenance information in accordance with Regulation 168/2013. We are also open to expanding data sharing to improve dismantling, provided it respects intellectual property rights and cybersecurity, and occurs on fair commercial terms.
Information sharing must not become a liability trap. Manufacturers often integrate third-party components over which they have no ownership of software or architecture. Holding OEMs responsible for how these components are reused, especially in retrofitted or repurposed vehicles, goes beyond reason and law.
Fairness, not fragmentation
Inclusion must be comprehensive and coherent. We support extending ELV obligations to all L-category vehicles, including mopeds and tricycles, not just a select few. Fragmenting the regulation by excluding certain categories would only create enforcement gaps and a patchwork of national rules.
At the same time, small series manufacturers should be exempt, as they are in other vehicle categories. Fairness in regulation means recognising when one-size-fits-all simply doesn’t fit.
Market-driven sustainability
Europe rightly wants to lead on sustainability. So does our industry. But to succeed, environmental ambition must be paired with economic realism. Dismantlers, recyclers, and manufacturers must work together in a system that rewards cooperation, not blame. Sharing information, improving traceability, and ensuring legal clarity around producer responsibility are all part of that.
Let’s build a framework that promotes market-driven sustainability, where circularity, safety, and competitiveness go hand in hand. Motorcycles aren’t cars, and the ELV Regulation must be designed accordingly. We’re ready to ride this road – if the rules are fit for the journey.
