The automotive recycling system and extended producer responsibility: why Europe needs all stakeholders at the table

Europe’s automotive EPR schemes will only deliver credible circularity if governance includes recyclers and waste operators alongside producers and PROs. When decision-making is concentrated, cost-cutting can trump real environmental performance, and consultations risk becoming box-ticking. Shared PRO governance, observer seats or an independent, regulated oversight body can improve transparency, fairness and operational realism across the ELV chain.

As Europe advances its transition toward a circular economy in the automotive sector, with the End-of-Life Vehicles Regulation currently underway, the governance of Extended Producer Responsibility (EPR) schemes has become a key issue. What is at stake is not only the effectiveness of recycling systems but also their transparency, fairness, and long-term credibility. Across the waste management sector, a growing request is emerging: EPR governance works best when all actors in the value chain, not only producers, have a seat at the table.

While producers and Producer Responsibility Organizations (PROs) undeniably play a central role, the current concentration of decision-making power can lead to choices that prioritise cost reduction over environmental performance. Waste management companies, recyclers, and Authorised Treatment Facilities carry out recycling operations every day, yet in several systems, they are consulted only occasionally, if at all. This imbalance raises an important question: Is consultation alone enough to ensure fair and strategic decisions?

A more collaborative model already exists in parts of Europe, where waste management representatives participate as observers on the boards of PROs. This approach has proven that involving waste operators does not create conflicts of interest. On the contrary, it brings the view and knowledge of all stakeholders in the value chain. Experience shows that shared governance can be both transparent and efficient, strengthening trust across the entire recycling chain.

Broader participation is widely seen as essential to developing industrial strategies that support recycling rather than simply minimising costs. For many stakeholders in the sector, the key question is no longer whether waste management operators should be involved, but how to ensure their participation in a way that maintains balance, neutrality, and environmental ambition and avoids conflict of interest.

The risks of excluding key actors are real. When governance structures concentrate power in too few hands, the systems become more vulnerable to non-transparent practices and decisions that may not reflect operational needs. Without proper representation or oversight, annual consultations risk becoming a formal exercise rather than a meaningful dialogue.

This is why FEAD supports the inclusion of waste management representatives in the governing bodies of PROs, or, as an alternative, the establishment of an independent advisory and monitoring body involving waste management operators, which will ensure the necessary know-how in terms of recyclability of products and their end-of-life treatment. The monitoring powers and advisory capacity of this body should be duly regulated. Its consultation must be mandatory, and any report or recommendations it may issue under any of its competences must be legally binding for PROs.

Whether through shared governance, observer roles or independent oversight, the goal is the same: to ensure that EPR systems operate in a credible, transparent and accountable way.

Europe’s circular economy ambitions rely on collaboration. No single group – producers, recyclers, or waste operators – can deliver them alone. The most successful EPR systems will be those that recognise the value of every link in the chain and reflect this in their governance. As discussions continue across the EU, the message from industry practitioners is clear: when everyone is represented, recycling works better – for the environment, for the economy, and for society.

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 of investments into the economy every year.

For more information, please contact: info@fead.be