The Implementation of EPR Under French Law: Consequences for ATFs

France’s Extended Producer Responsibility (EPR) system for end-of-life vehicles (ELVs), set for 2025, shifts responsibility to manufacturers, impacting Authorized Treatment Facilities (ATFs). This regulation aims to combat illegal ELV disposal while introducing mandatory contracts with eco-organisms or producers. Morgane Batteria, End-of-Life Vehicle Manager at MOBILIANS, discusses how the organization is working to protect ATFs’ interests, ensuring fair agreements and safeguarding operational flexibility in this evolving regulatory landscape.

MOBILIANS: Driving French Mobility

MOBILIANS represents a complete mobility ecosystem of 180,000 companies and 560,000 employees, in touch with business realities and established in every region of France. These companies are involved in the day-to-day mobilitý of the French: trade, maintenance and repair of vehicles and motorized two-wheelers, rental, distribution of fuels and new energies, recycling, and all innovative mobility services to users.

Among these key players, MOBILIANS represents ATFs and remanufacturers. In addition, MOBILIANS is actively engaged in the process of revising European regulations, particularly through its participation in the EGARA association (European Group of Automotive Recycling Associations).

Implementation of EPR: Strengthening Accountability in Vehicle Recycling

In France, through the AGEC Law (anti-waste for a circular economy) of February 10, 2020, the legislator has created a new ELV-EPR (extended producer responsibility) system. This means that the producer is responsible for the vehicle he has put on the market until the end of its life. The primary aim of this system was to curb the illegal sector, which sees 1/3 of all ELVs disappear every year. The actual implementation of the ELV-EPR system was due to take place on January 1, 2024, but given its complexity, this has been postponed to 2025.

Prior to the introduction of this EPR system, MOBILIANS had drawn up several proposals. A number of these proposals have been enshrined in French law :

ATFs are the only entities authorized to issue declarations of purchase for destruction (DAD) and declarations of intent to destroy (DID).

• Manufacturers cannot prohibit the dismantling and sale of reused parts.
• Free communication of parts listings to ATFs.
• Definition of the notion of “complete ELV”, including the traction battery.
• Provisions to ensure that the relationship between producers and ATFs does not: lead to the exclusivity of the ATF to the benefit of a producer or producer group; prohibit the ATF from reselling, with a view to reuse or recovery, all or part of the dismantled parts of an ELV (…); require the ATF to accept only certain makes or models of ELV; prevent the development of a commercial identity specific to the ATF. Currently, ATFs operate under a prefectural decree system. With the introduction of EPR, this prefectural decree will gradually be replaced by mandatory contracts to be signed with:

• One or more eco-organisms = a group of producers.

AND / OR

• One or more individual systems = a single producer.

A reminder of how an EPR system works:

Signing contracts between ATFs and eco-organism / individual systems

Since April 2024, there has been only one approved eco-organism in the ELV-EPR sector: “Recycler mon véhicule” (RMV). RMV was created by manufacturers belonging to the Chambre syndicale internationale de l’automobile et du motocycle (CSIAM). As of February 2025, 38 manufacturers are members of the eco-organism.

Signing a contract with RMV enables ATFs to collect and process all makes and models of vehicle. What’s more, the RMV contract leaves a great deal of freedom to ATFs. It is, therefore, advisable to sign this contract to ensure that ATFs can continue to produce and sell their parts and materials with complete freedom.

To date, 13 manufacturers, sometimes representing several brands, have obtained approval for their individual systems (Stellantis, Renault, Volkswagen, Toyota France, Nissan…). Furthermore, several additional individual systems are in the process of being approved.

 Some of the contracts on offer contain clauses that may appear complex or restrictive for ATFs. MOBILIANS works actively with producers to adjust these clauses. When modifications are made, amendments are drawn up. We do not advise against signing these contracts; we simply recommend that ATFs carefully evaluate the advantages and disadvantages before committing.

Visit Mobilians