Manuel Kindelán, General Director of SIGRAUTO, the Spanish Association for the Environmental Treatment of End-of-Life Vehicles, discusses the EU’s forthcoming Regulation on circularity requirements for vehicle design and end-of-life management, now in its final approval phase. Expected by late 2025, it will drive the automotive sector toward greater circularity and sustainability.
More than two years have passed since the European Commission launched its proposal for a “Regulation on circularity requirements applicable to the design of vehicles and the management of vehicles at the end of their life”, to establish a harmonized, directly applicable framework across the European Union that covers the entire vehicle life cycle; from design, production, and use to end-of-life management.
Following the general agreement reached by the European Council in June and the adoption of the European Parliament’s position in September, the file is now in the so-called trilogues, a negotiation process between the Commission, Council, and Parliament intended to reach a common text. If the timetable is met, final approval could take place toward the end of 2025. However, its full implementation will extend over time due to the complexity and scope of the new framework.
The Regulation will repeal Directives 2000/53/EC and 2005/64/EC and consolidate, in a single directly applicable text, the requirements concerning both the circular design of vehicles and their end-of-life management. It is worth noting that Directive 2000/53/EC on end-of-life vehicles has, for more than two decades, served as a success story in European environmental policy, achieving very high rates of reuse, recycling, and material recovery, while promoting the creation of an efficient network of authorized treatment centers and shredding facilities.
The new Regulation does not start from scratch. It builds on these achievements to go a step further, expanding its scope to the entire vehicle life cycle and introducing more ambitious design and traceability requirements to promote circularity.
Key topics in the trilogues
At present, the positions of the Parliament and the Council differ significantly in several areas, so the outcome of these negotiations will determine the Regulation’s true scope. Among the main points of debate are:
- Minimum recycled plastic content.
The Commission proposed that 25% of the plastics in new vehicles should come from recycling six years after the Regulation enters into force, with 25% of this amount coming from end-of-life vehicles (closed-loop recycling). Parliament and Council agree on the principle but differ on percentages and timelines, advocating for a more gradual introduction that reflects the actual availability of recycled plastics on the market.
- Extending the recycled content requirement to other materials such as steel, aluminum, and critical raw materials.
The debate here centers on technical feasibility, costs, and calculation methodology, which will likely be specified later through delegated acts from the Commission.
- Design requirements for circularity.
The proposal introduces an obligation to have a circularity strategy and a digital vehicle passport containing information about the vehicle’s composition and traceability. However, the required level of detail still needs to be defined, whether it should apply at the brand, type, or individual vehicle level, as well as the specific data it must include.
- Extended Producer Responsibility (EPR).
EPR will be strengthened and harmonized at EU level. Discussions focus on how to structure these responsibility systems—collective or individual —and how to integrate them with existing national schemes.
- Mandatory removal of parts at Authorized Treatment Facilities (ATFs) before shredding.
There is significant debate not only about which parts must be removed but also whether their removal should depend on their potential for reuse, remanufacturing, or reconditioning. Differences also exist over which components may remain in the vehicle if it can be demonstrated that shredding and post-shredding processes can recover materials as effectively as manual or semi-automated removal at the ATF.
- Requirements for shredding.
Positions differ on the conditions under which end-of-life vehicles can be shredded together with other waste. The main discussion focuses on quality criteria to be established for certain fractions obtained after shredding.
- Export controls.
The goal is to prevent the export of vehicles that, in practice, should be classified as waste but are instead exported as used vehicles. The trilogues must clearly define what is meant by an “end-of-life vehicle” and how to ensure effective traceability throughout the chain.
A regulation with a complex timetable
One aspect often overlooked outside technical circles is that the Regulation’s approval will not mark the end of the process, but rather the beginning of a new phase. The text includes numerous elements that the European Commission must later develop through delegated and implementing acts, mainly dealing with:
- calculation methodologies,
- information formats,
- technical design requirements,
- circularity indicators,
- recyclability criteria,
- and additional recycled-content targets.
These acts will be crucial to determining how the Regulation’s obligations are applied in practice. Some will be adopted shortly after the Regulation enters into force; others will require prior studies and public consultations, delaying their implementation for several years.
In addition, different provisions of the Regulation will take effect on different timelines: some after two or three years, while others, such as minimum recycled-content requirements, may apply only after six or even ten years. This will require phased adaptation planning and continuous dialogue with EU institutions.
The result will be a staggered and complex regulatory calendar, with multiple implementation phases and milestones that the industry will need to monitor closely.
The role of SIGRAUTO: monitoring, participation, and preparation
The sectoral associations that comprise SIGRAUTO, representing producers, authorised treatment facilities (ATFs), shredders, and post-shredding facilities, have been and will continue to be deeply involved in monitoring this legislative process. Over the coming months, in addition to presenting their positions during the trilogues to all three institutions, they will closely follow the Commission’s work on the delegated and implementing acts.
It will be essential for the industry to maintain active and coordinated participation, since experience shows that, beyond the Regulation’s main text, the technical details that determine real-world application are decided in these complementary acts. Therefore, associations must stay alert to every public consultation, provide technical input, and defend practical solutions that ensure circularity without undermining industrial competitiveness.
At the same time, companies must begin to adapt their design, manufacturing, traceability, and end-of-life management processes progressively according to the established timelines. This is not merely about complying with a legal obligation but about preparing for a structural transition toward a more circular and resilient production model.
Conclusion
We are at a crucial moment. The Regulation on circularity requirements and end-of-life vehicle management will shape the evolution of the European automotive sector in the coming decade. Its final content will depend on the agreements reached in the trilogues, but even after its adoption, the regulatory process will continue through delegated and implementing acts detailing how the new circularity principles will be applied.
It will be a long and demanding process, requiring continuous involvement from sectoral associations, coordination between administrations and companies, and careful planning for the implementation of each measure according to its timeline.
Only through such sustained engagement can we ensure that the transition to circularity results in effective, balanced regulation capable of strengthening the competitiveness of Europe’s automotive industry.
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