Spain’s vehicle dismantling sector is being asked to deliver circular economy outcomes without a functioning Extended Producer Responsibility system. Joaquín Cenit Ferrer argues that unless manufacturers properly fund end-of-life vehicle treatment and authorised operators can compete on fair terms, the new European ELV Regulation risks repeating the failures of the past.
Joaquín Cenit Ferrer, Manager of Desguace Suspiro S.L. in Granada, discusses why Spain’s vehicle dismantling sector continues to operate without an effective Extended Producer Responsibility system, the financial burden this places on authorised treatment facilities, and why the new European End-of-Life Vehicle Regulation will only succeed if proper funding and fair market conditions are put in place.
I have spent years in this sector. Long enough to know when something is not working, even when everyone pretends that it is.
In Spain, the legal obligation for vehicle manufacturers to take responsibility for the end-of-life stage of their products has existed for more than twenty years, stemming from European Directive 2000/53/EC and implemented through Royal Decree 1383/2002. Today, those obligations are set out in Royal Decree 265/2021 and Law 7/2022. They are written down, signed and published in Spain’s Official State Gazette.
What does not exist, and has never existed, is a legal system that genuinely works. Neither an individual system nor a collective one. No model has ever operated in the way the law requires.
The public authorities themselves are trying to correct this situation, despite the fact that the vast majority of authorised vehicle treatment centres are unaware of it and of the consequences this has for the treatment of end-of-life vehicles (ELVs). There is even pressure to maintain the current system, based on the supposed positive value or zero cost of vehicles, which does not reflect reality and has been sanctioned at European level, through information that creates fear among business owners and ridicule towards those who expose the reality.
As a result, we have continued to bear the entire cost, largely in silence.
But there is one consequence of this absence that almost nobody is willing to state clearly: without an Extended Producer Responsibility system that genuinely works, everything required by the new European Regulation is, in practice, impossible to deliver.
And not because authorised treatment facilities do not want to do it. It is because nobody works for free.
The circular economy is an excellent model on paper. Depolluting a vehicle, separating its materials, recovering its parts, and managing hazardous waste legally and traceably all involve real costs. There are costs for staff, facilities, training, audits and time.
For years, authorised treatment centres in Spain have borne those costs alone, without vehicle manufacturers contributing financially to that value chain as required by law.
Extended Producer Responsibility exists precisely to ensure that these costs do not fall solely on the operator at the end of the chain. It should support the development of new technologies to help treat the most difficult materials and discourage the unfair competition that causes ELVs to disappear from the legitimate system.
It exists so that the party manufacturing the vehicle finances the environmentally sustainable treatment of vehicles and their components.
That is what the law says.
That is what has never happened, under any model, whether individual or collective.
And while this gap remains, the reality is this: between 2019 and 2025, more than 1.5 million vehicles were administratively deregistered in Spain without passing through an authorised treatment centre.
The vehicles disappear from the register; nobody knows with certainty what happens to them, and those of us operating with all the required guarantees process fewer than 600,000 vehicles per year.
Someone should explain where the rest are.
And someone should be asking why the legal system is unable to absorb them.
The answer, at least in part, is economic.
If the compliant operator carries all the costs while the illegal or non-compliant operator carries none, the market is inevitably distorted. This is not a problem of willingness or environmental awareness. It is a problem of incentives.
Now comes the new European End-of-Life Vehicle Regulation, with a genuinely new requirement in light of the European decision that sanctioned vehicle manufacturers and their European association for creating a cartel aimed at avoiding the payment of treatment costs to facilities: contracts must be established according to transparent, objective and non-discriminatory criteria.
With around 1,400 authorised centres in Spain, this should be delivered through collective systems that strengthen and improve the market and guarantee free access for authorised treatment centres. It should also ensure coverage not only across the whole national territory, but that no vehicle is left outside the authorised treatment system.
That is progress.
But it will become another dead letter, just like what came before it, if it is not accompanied by a funding system that makes the work being demanded of us economically viable.
The circular economy is not a statement of intent. It is a business model.
And no business model works when one part of the chain works without being paid, absorbs costs that others avoid, and is then expected to compete on an unequal footing.
What we are asking for is not a privilege.
We are asking for what was already written into law to be enforced.
For the producer to take responsibility.
For the system to be funded as it should be.
And for the rules to be the same for everyone.
Until that happens, talking about the circular economy in vehicle recycling is, to a large extent, talking about a promise that somebody always postpones until tomorrow.
Joaquín Cenit Ferrer is Manager of Desguace Suspiro S.L. in Granada and a member of the Andalusian Vehicle Dismantlers Association.
Further Reading on Auto Recycling World
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The automotive recycling system and extended producer responsibility: why Europe needs all stakeholders at the table
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ELV Forum launched to shape workable EPR rules
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Spain’s ELV sector prepares for EU Regulation
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European ELV Regulation approved: a historic step for circular vehicle recycling
