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The EU Vehicle Regulation: How can we ensure resource efficiency during the lifecycle of vehicles?

Protocol of the DUH web-conference 19th May 2025 

On 19 May 2025, Deutsche Umwelthilfe (DUH) hosted a web conference titled “The EU Vehicle Regulation: How can we ensure resource efficiency during the lifecycle of vehicles?”. The conference provided expert insights and debate on revising the EU Vehicle Regulation, covering ecodesign, parts reuse, Extended Producer Responsibility, missing end-of-life vehicles, and legal frameworks, highlighting opportunities and challenges for improving resource efficiency in the automotive sector. 

 

The EU Vehicle Regulation: How can we ensure resource efficiency during the lifecycle of vehicles? p two
Image credit: Shutterstock

The participation of more than 80 stakeholders, including political decision-makers, scientists, industry representatives, and civil society organizations, highlighted the growing relevance of resource efficiency in the automotive sector. In the event, topics such as ecodesign, vehicle repair, reuse of vehicle parts, “missing” EoL-vehicles, Extended Producer Responsibility (EPR) systems, dismantling, recycling and legal enforcement were intensively discussed.

After welcoming words from the Managing Director of DUH, Barbara Metz, Sara Mathieu (MEP, Group of the Greens/European Free Alliance) delivered a political keynote on her perspective of the EU Vehicle Regulation to address resource efficiency. 

She pointed towards the great need for action in the vehicle sector to establish an ambitious EPR regulation and generally achieve environmentally friendly mobility behavior, e.g. through the promotion of car sharing and smaller cars. At the same time, she also drew attention to the fact that it is currently difficult to win majorities for these necessary steps due to more conservative voices in the EU. Improvements are particularly necessary at the beginning of vehicles’ life, in the design to improve repairability, reusability and recyclability. The vehicle passport will be an important tool to improve consumer transparency. For an effective treatment at the end of life, the problem of the “disappearing” vehicles has to be solved. She also emphasized the relevance to set recycled content targets for vehicles, particularly a target of 25 percent for plastics. Modern technologies for dismantling and recycling are available, so that such targets are well achievable. Particularly, the planned vehicle regulation must find solutions to hold manufacturers accountable in an efficient and robust system for EPR. 

In this context, she referred to the “Anti-recycling cartel” of vehicle manufacturers, which was penalized by the EU Commission. According to Ms. Mathieu, ecomodulation is an important tool for achieving change in the vehicle industry. Finally, she expressed concern about impending weakening in regulation, for example regarding currently discussed changes to the Commission’s draft, but also beyond it, e.g. in the context of weakened CO2 fleet limits.

In the first block of the event, Giulia Caroli (Junior Technical Officer at European Waste Management Association (FEAD)) presented key provisions to improve the resource efficiency of vehicles from the perspective of the private resource and waste management industry. According to FEAD, the minimum recycled content target for plastics of 25 percent must be maintained within 72 months after entry into force, with an interim target of 20 percent within 48 months. Biobased plastics and pre-consumer plastic waste should be excluded from these targets to avoid false progress and delays in circular economy. FEAD stressed the need for independent oversight of producers and PROs to prevent market distortions and calls for including the entire recycling value chain—from ATFs to recyclers—in EPR schemes. 

In addition, FEAD claimed that setting recycled content targets for steel and aluminum is vital and that vehicle collection can be improved through consumer incentives, such as connecting the ending of insurances to a proper disposal.

Joachim Bruck (CEO of ClaimParts) presented the platform “ClaimParts” as an example of how the reuse of vehicle parts can contribute to a more sustainable and efficient circular economy in the automotive sector. He pointed out that there are very problematic developments regarding the decreasing reparability of vehicles and that these developments have to be stopped. The reuse of parts as spare parts has considerable environmental benefits in comparison to newly produced spare parts, e.g. by reduced CO₂ emissions and improved repair conditions through lower repair costs and better availability of spare parts. A major current problem, however, is that many end-of-life vehicles are lost to the used parts market because they go through unofficial end-of-life channels. Joachim Bruck, furthermore, pointed out the importance of networking insurers, recyclers, and workshops through digital platforms. In this context, real-time access of workshops for used parts and smart interfaces with ERP and retail or distribution systems are key. Spare parts reuse can, thus, play a crucial role in improving resource efficiency.

At the end of the first block, Andrea Kostrowski (Expert Circular Economy at DUH) presented the need for more ambitious provisions in the EU Vehicle Regulation from the perspective of an environmental and consumer protection NGO. DUH emphasized the automotive sector’s high resource use – both from combustion engine vehicles, which have the highest impact during the use phase due to fossil fuel consumption, and electric vehicles, which drive up demand for critical raw materials. She highlighted the importance of applying the waste hierarchy, prioritizing prevention, reuse, repair and design improvements—to reduce environmental impact. Against the background of the “anti-recycling cartel” she pointed towards a more robust EPR system throughout Europe, where producers have to join collective producer responsibility organisations and pay EPR fees depending on the quantity placed on the market and the environmental performance of their products. Additionally, DUH calls for mandatory ecodesign rules, stronger repairability requirements, promotion of (preparation for) reuse and ambitious recycled content targets. Overall, product responsibility in the vehicle sector should also be more closely aligned with the regulation of other products, such as batteries.

In the second block during the podium discussion, Sara Mathieu emphasized that strong, binding rules are needed to improve vehicle repairability, reduce resource use, and avoid loopholes, especially as car production consumes vast raw materials and repair has become more difficult due to complex design and software. In particular, investing in public transport, active mobility, and urban planning is essential in order to reduce resource use and other negative environmental effects. Voluntary commitments from industry are clearly evaluated as ineffective from Sara Mathieu, as experience from other legal fields has shown. She voted for robust and clear regulation according to the principle “simplification without deregulation”.

Marieke Hoffmann (DUH) stressed that the biggest impact on resource protection comes from changing mobility habits, e.g. using more public transport and smaller cars, and improving ecodesign and repair.

On reparability, she warned that rising repair difficulties jeopardize the well-established vehicle repair structures and called for a “right to repair” which also involves independent repair operators in order to guarantee stable and well-affordable repairs. She also proposed several measures which may be implemented into the vehicle regulations to promote smaller cars, e.g. ecomodulation or obligations for member states to take national measures.

Regarding the reuse of spare parts, Joachim Bruck explained that a major obstacle to reusing vehicle parts is the high diversity and complexity of components as well as the whole vehicle design, which makes dismantling and reuse of parts difficult, e.g. for batteries contained in electric vehicles. He emphasized the need for more standardization and an improvement of dismantlability without compromising car quality.

To the question of whether the recycling market is ready to improve dismantling and post-shredding to boost material recovery, Giulia Caroli answered that improving recycling requires aligned design rules (e.g. good removability of batteries), economic incentives to support proper dismantling, depollution and recycling technologies in Europe, as well as a Digital Product Passport and a better marking of critical raw materials.

Regarding the role of insurances to optimize resource efficiency during the lifecycle of vehicles, Oleksandra Hrendey, Senior Policy Advisor at Insurance Europe, explained that using spare parts from accident vehicles can boost sustainability and that insurers may play a key role in this context. As a positive example, Allianz increasingly uses reused parts in case of accidents and requires that the reused parts installed

have to match the age and quality standard of the accident car. Additionally, in Sweden, insurers actively prioritize reused parts. However, nationally adapted regulations are needed to optimize the availability, costs and quality of reused parts in practice. Ms. Hrendey also pointed out that general repair conditions must be improved. For example, it is unacceptable that the whole battery of an electric vehicle is often exchanged because EV batteries are often not repairable. 

The EU Vehicle Regulation: How can we ensure resource efficiency during the lifecycle of vehicles? p

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