Modernising the existing framework set out by the ELV Directive and the 3R type-approval Directive, adopted in 2000 and 2005 respectively, the ELVR is designed to support the transition to a more circular automotive sector, marking – as the European Commission has described it – an important step towards a more resilient, sustainable and competitive European economy.
Covering vehicle design, production, collection and end-of-life treatment, the ELVR aims to strengthen circularity in the automotive sector by improving resource efficiency, increasing the recovery and reuse of valuable materials, and enhancing the environmental performance of vehicles throughout their life cycle.
“The new End-of-Life Vehicles Regulation sets a new European standard for how vehicles should be designed, produced and recovered," said Jessika Roswall, commissioner for environment, water resilience and a competitive circular economy at the European Commission. "This is about more than recycling – it is about securing critical materials and making our automotive sector truly circular."
She added: "Every car that is dismantled, every tonne of steel, aluminium, copper or plastic that is recovered, is a step towards a more resilient Europe.”
Mandatory recycled content targets
The ELVR sets out mandatory targets for the use of recycled materials in new vehicles over the next decade. Plastic content in new vehicles must include at least 15% recycled material from post-consumer plastic waste from September 1, 2032, rising to 25% from September 1, 2036. The European Commission is also required to establish minimum recycled content requirements for steel and aluminium, with those obligations applying no later than August 14, 2033.
Delivering a presentation on ELVR compliance at the European Association of Automotive Suppliers' (CLEPA) Materials, Regulations and Sustainability Event in May, Oliver Schmid, senior engineer for circular economy at Hyundai, urged everyone to begin asking their suppliers about recycled content as soon as possible.
"These mandatory targets focus only on post-consumer content, so whatever you do currently with pre-consumer or post-industrial content is helpful for carbon footprint but is not helpful for the targets," he clarified.
Schmid also touched on an important part of the ELVR: the mirror clause. This measure is designed to prevent manufacturers from meeting the ELVR's recycled content targets using imported recyclate produced to weaker environmental, health or waste management standards than those required in the EU.
From August 14, 2030, recycled content produced in countries outside the EU can count towards the targets only where the recycling installation meets requirements equivalent to those set out in the ELVR.
Schmid noted that the mirror clause means the origin of recycled material will become increasingly important for globalised automotive supply chains. He urged suppliers to examine where materials currently come from and where recycled content will come from in future, including further upstream in their supply chains.
In addition to this, there is a separate closed-loop requirement, mandating that at least 20% of recycled plastic used to meet the ELVR's targets come from ELVs or vehicle components removed during a vehicle's life cycle. This is intended to ensure that a proportion of recycled material used in new vehicles comes directly from the automotive waste stream, helping to create a more circular automotive sector.
Schmid encouraged OEMs and tier-one suppliers to work with material manufacturers as early as possible about whether or not they're able to supply "the quantities and quality needed over the whole product lifetime".
He warned that the availability of suitable recycled material could prove a greater challenge than its price, with suppliers needing to ensure a stable supply of the required quality and quantity throughout a product's seven-year lifetime.
The need to understand material origin also points towards a greater requirement for supply chain transparency, Schmid indicated, although he stressed that this should not necessarily mean full supply chain disclosure.
Greater OEM responsibility for ELVs
As well as targets for recycled content used in new vehicles, the ELVR also sets out targets for the recovery of materials and components from ELVs. From January 1, 2030, at least 95% of an ELV's weight (excluding batteries) must be reused or recovered, while at least 85% must be reused or recycled. These targets are calculated by average weight per vehicle and year.
From January 1, 2032, the regulation will also require a yearly target for the recycling of plastics from ELVs of at least 30% of the total average weight of plastics contained in ELVs.
And from September 1, 2032, new vehicle types must be designed to allow at least 85% of their weight to be reused or recycled and at least 95% to be reused or recovered.
As per the ELVR, OEMs will have extended producer responsibility (EPR) for vehicles they make available on the market in the EU from September 1, 2029. This extended responsibility includes the obligation for manufacturers to ensure that vehicles they've put on the market are collected and treated at end-of-life in accordance with the ELVR, and that waste management operators treating ELVs meet the targets for the proportion of an ELV being reused, recycled or recovered.
In accordance with the regulation, vehicle producers must finance part of the costs of collection and treatment of ELVs necessary to comply with the ELVR, in particular obligations aimed at ensuring higher quality of secondary raw materials retrieved from vehicles. The regulation notes that producers' costs should take into account the revenue generated by recyclers and other waste operators from selling used parts and recovered materials. Authorities will monitor these costs and producer contributions to ensure the financial burden is shared fairly across the industry.
Additionally, the ELVR requires producers' financial contributions to cover the cost of public awareness campaigns to increase ELV collection, the establishment of a system for issuing and transferring certificates of destruction, and the collection and reporting of data to the relevant authorities.
The European Commission has said that by making producers responsible for the end-of-life phase of the vehicles they place on the market, the framework creates incentives for more sustainable vehicle design and helps ensure that high-quality collection, dismantling and recycling systems are properly financed.
Introduction of a Digital Circularity Vehicle Passport
From September 1, 2032, every vehicle placed on the EU market will be required to have a Digital Circularity Vehicle Passport. This passport must be accessible free of charge to the vehicle owner and operators involved in the vehicle's repair, maintenance, reuse, remanufacturing, recycling and other end-of-life treatment.
Each Digital Circularity Vehicle Passport must contain the following information: instructions on safe removal and replacement of parts and materials; information on substances of concern; recycled content information; and the vehicle's official spare parts catalogue.
This is something Léa Dégardin, European public affairs director at Mobivia, stressed the importance of at the CLEPA event in May. She described some OEMs' lack of openness to sharing data with the independent aftermarket as a significant challenge and called for "fair and non-discriminatory access to data and in-vehicle information" – data that she said is necessary to offer even the most basic of services.
"We have difficulty today to obtain certain spare parts from some OEMs; some of them are using this as a pretext to not sell spare parts to us and sometimes there are even coded spare parts," Dégardin said. "So there is really a concrete example of unfair competition for us as an independent automotive aftermarket player."
Ultimately, the introduction of the Digital Circularity Vehicle Passport could help improve access to information for independent aftermarket operators, potentially creating a more level playing field with OEM workshops. Greater access to information could also support greater reuse, repair and recycling of vehicles and components.
The passport is also part of a wider shift towards greater data collection and supply chain transparency under the ELVR. Schmid highlighted the need for manufacturers to collect information across the supply chain to ensure ongoing compliance, while noting that industry systems such as IMDS and Catena-X are amongst the tools available to help manage and share the required data.
Tighter export controls for used vehicles
The ELVR also tightens controls on used-vehicle exports, ensuring that from September 1, 2031, only roadworthy vehicles can be exported outside the EU. The aim is to prevent ELVs from being exported as used vehicles and subsequently escaping the EU's requirements for their treatment. This is intended to reduce the leakage of ELVs from the EU's circular economy, and help retain recovered materials and components within its regulated waste treatment and recycling systems.
Automotive Logistics' take
The ELVR highlights, above all, the need for firms to map their supply chains and work more closely with upstream suppliers to ensure alignment with regulatory requirements. End-to-end supply-chain visibility will be critical to complying with regulations such as the ELVR and EU Forced Labour Regulation (EUFLR), while collecting and analysing the right data will help firms identify potential compliance risks as new requirements take effect.
