The European Council adopted its negotiating position on a sweeping reform of end-of-life vehicle regulations on Tuesday. It strives to embed circularity principles into automotive design and recycling.
The draft law, part of the EU’s Green Deal, mandates recycled plastic targets in new vehicles, expands scope to trucks and motorbikes, and tightens export controls to curb waste dumping. Paulina Hennig-Kloska, Poland’s environment minister hailed it as resounding success. “The end-of-life vehicle regulation is a game-changer for Europe,” she said. “It cuts waste, curbs our reliance on critical raw materials from abroad, and drives our car industry into the heart of the circular economy. With the Council’s position, this legislation will not only boost the competitiveness of our car and recycling industries but also slash red tape to a minimum.“
Under the Council’s position, the design of all new cars, vans, heavy trucks, motorbikes, and quadricycles must allow for easy removal and recycling of parts. Producers must submit “circularity strategies” by vehicle category—not per model—to minimise administrative burdens. This includes special-purpose vehicles like ambulances and mobile cranes, although vintage cars restored for road use gain exemptions. A so-called digital circularity passport will track materials, aligning with existing EU product databases.
Closing loopholes
Recycled plastics will face binding quotas, with future targets possible for steel, aluminium, and critical minerals post-feasibility studies. Temporary derogations are permissible if recycled material shortages or price spikes occur—a concession to industry concerns.
To prevent ELVs from vanishing into informal markets, sellers must prove a vehicle isn’t scrapped during ownership transfers, excluding private sales except online transactions. The rules redefine ELVs to exclude culturally significant or restored vehicles, addressing collector concerns.
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Export controls aim to stop the EU becoming a used-car dumping ground. Automated customs checks for roadworthiness are to leverage the MOVE-HUB platform to link national registries. “Missing vehicles”—those illegally scrapped or shipped abroad—have long undermined recycling rates, with just 50 per cent of EU ELVs officially processed in 2023.
Producer accountability expanded
Extended producer responsibility regimes now cover the full treatment chain for trucks and motorbikes, not just collection. Manufacturers must fund transport from collection points to recycling facilities and cover costs for orphan vehicles (those with defunct producers) based on market share. Non-EU producers must prepay recycling fees when placing vehicles on the bloc’s market.
This legislation will not only boost the competitiveness of our car and recycling industries but also slash red tape to a minimum. Paulina Hennig-Kloska, Poland’s environment minister
Treatment facilities face stricter rules: depollution (removing fluids, batteries) must occur within set timelines, and shredding ELVs with other waste is banned unless output meets purity standards. Storage protocols are defined to prevent environmental leaks.
Minimum recycled content
The general approach proposes a three-stage approach to the target for a minimum percentage of recycled plastic content in vehicles, to ensure substantial, but realistic, circularity benefits:
- 15% by 6 years after the entry into force of the regulation
- 20% by 8 years after the entry into force of the regulation
- 25% by 10 years after the entry into force of the regulation
The automotive sector, which consumes 19 per cent of EU steel (7m tonnes/year), 10 per cent of plastics (6m tonnes), and 42 per cent of aluminium in transport (2m tonnes), will need radical redesigns. While recyclers welcome guaranteed material streams, carmakers warn of upfront costs. “This isn’t just about recycling—it’s rethinking how every bolt and panel is made,” said a Brussels-based auto lobbyist.
Implications and criticism
The Council’s push for per-category rather than per-model circularity strategies eases compliance, but critics argue it risks vague, unambitious plans. “Without model-specific targets, producers might game the system,” cautioned an NGO campaigner.
Another critic, The European Environmental Bureau (EEB) has said that while the Council made some cosmetic improvements, it failed to remedy missed opportunities in the initial proposal. The NGO asserts the proposal watered down key provisions, despite the calls by environmental organisations, consumer groups and the industry.
EEB has said that the Council’s position:
- fails to address the unsustainable material use and footprint of the sector by decreasing the number of cars, and reversing the trend to “ever bigger” vehicles;
- still focuses on recycling while ignoring the strategies of durability, reuse and repair, which aim to extend the lifespan of cars
- insufficiently implements the Polluter Pays Principle, neglecting the upper levels of the waste hierarchy and creating an unfair double regime for non-EU countries receiving used vehicles from the EU.
Broader context
The ELV update replaces the 2000 ELV Directive and 2005 3R type-approval rules, folding them into Regulation (EU) 2018/858. It reflects the EU’s bid to lead in circular tech—a market projected to be worth €2tn globally by 2030. With 95 per cent of a vehicle’s materials technically recyclable but under 30 per cent currently reused in new cars, the regulation aims to close loops while cutting 12.3m tonnes of annual CO₂ emissions from metal production.
As Ms Hennig-Kloska noted, the law’s success hinges on balancing ambition with flexibility. For the EU’s 13.8m-strong automotive workforce, it marks both a blueprint for sustainability and a test of competitive resilience. With China and the U.S. investing heavily in circular supply chains, Europe’s ability to marry regulation with innovation will shape its industrial future.
Trilogue negotiations with the European Parliament will begin once MEPs finalise their position. Key battlegrounds include the scope of recycled material targets and EPR cost-sharing. The Parliament previously pushed for stricter due diligence on exported used cars, which the Council’s automated checks only partly address.
