The EU’s new End-of-Life Vehicles Regulation entered into force on 13 August, marking a major overhaul of how vehicles are managed at the end of their lives.
The new regime marks a fundamental shift after almost 26 years under the EU’s 2000 End-of-Life Vehicles Directive, which set targets for the collection, treatment and recycling of end-of-life vehicles, but left much of the organisation of that process to the existing network of treatment operators and national systems.
The new rules, on the other hand, instead of largely regulating what happens once a vehicle reaches the treatment system, put producers at the centre of managing that process – placing greater obligations on them for ensuring vehicles are collected, traced and properly dismantled.
The industry has broadly welcomed the overhaul, but says the real test will be whether its new responsibilities can be turned into a workable system linking manufacturers, dismantlers and recyclers.
“The new End-of-Life Vehicles Regulation represents a significant evolution of the framework for vehicle circularity in Europe,” a spokesperson for European Automotive Manufacturers Association (ACEA) told Automotive Logistics.
“From an industry perspective, however, we would not expect the entire reverse-logistics network to be rebuilt from scratch,” the spokesperson said, explaining that Europe already has a mature network of authorised treatment facilities and established recycling processes, and manufacturers have long provided dismantlers with information to support the safe treatment of vehicles.
“The priority should therefore be to adapt and strengthen existing systems rather than create parallel structures,” the spokesperson added.
The European Association of Automotive Suppliers (CLEPA) echoed that view, arguing that the ultimate challenge is not to build a new system.
“The physical network of dismantlers, treatment facilities and shredders are already extensive and doesn't need rebuilding,” the CLEPA press office told Automotive Logistics.
“What's missing is a new pre-shredding layer – systematic removal of components for reuse and remanufacturing before shredding – which not all dismantlers are yet equipped or incentivised to do or have,” CLEPA added.
Make every vehicle count
The most significant structural change in the regulation concerns the traceability of vehicles, commented Anja Helsen, communication manager at Belgian ELV management organisation Febelauto.
“The long-standing problem of ‘missing vehicles’ – illegally scrapped or exported – is now being tackled through stricter export controls: only roadworthy second-hand vehicles may leave the EU, and once a vehicle is classified as an end- of-life vehicle, it may no longer be legally exported or resold as second-hand,” Helsen explained.
In conjunction with the parallel directive on vehicle registration and the future digital circular vehicle passport, this will formalise and digitise cross-border flows, which are currently often informal, Helsen added.
From fragmented scrapyards to centralised ELV hubs
The new rules could also begin to dismantle one of the defining features of Europe’s ELV industry: decades of fragmentation, as collection and treatment volumes are expected to increasingly concentrate in larger, specialised hubs.
The mandatory removal and recycled-content rules in the regulation will certainly favour larger, tech-intensive hubs, Helsen said.
“There will be a gradual shift away from small family-run businesses that manually depollute and dismantle end-of-life vehicles towards large-scale, specialised and digitalised hubs,” Helsen added.
Yet the industry is far from true centralisation as regulatory landscape remains largely fragmented.
CLEPA, in particular, points to 25-plus national implementations that can leave pan-European operators navigating different permitting, data and traceability rules – while the ELV regime must also be aligned with other EU legislation to prevent the same parts being classified differently from one regulatory framework to another.
OEMs move downstream
The new rules are pushing OEMs deeper into the end-of-life chain – from financing collection and treatment to actively managing the recovery and reuse of vehicles, parts and materials. Most major manufacturers are already moving in this direction, developing their own systems, partnerships and digital tools to manage increasingly complex reverse flows.
For example, Renault is already building the kind of closed-loop reverse chain that the new rules are designed to strengthen, according to Juliette Faucon, corporate communication manager for Renault Group.
Renault Group’s circular-economy subsidiary The Future is Neutral, developed with SUEZ, handled the collection and dismantling of more than 400,000 end-of-life vehicles in 2025, Faucon revealed. Its network connects vehicle dismantling with parts reuse, remanufacturing and material recovery.
In France, Renault operates its own producer-responsibility system through INDRA, a network specialising in the collection and recycling of end-of-life vehicles, while in other European markets it works with local dismantlers or producer-responsibility organisations, Faucon said.
The focus is increasingly on keeping valuable components in circulation. EV batteries, for example, are assessed and repaired where possible before being sent to second-life or recycling routes. Renault’s GAIA battery centre has repaired more than 18,000 traction batteries since 2012, while its Autoloop platform helps dismantlers manage battery collection and traceability, Faucon added.
BMW Group, in turn, organises the collection and recovery of end-of-life vehicles through national take-back schemes and authorised partners across Europe, commented Jochen Diernberger, BMW Group sustainability spokesperson.
“Our approach is guided by a clear principle: to retain the highest possible value of components and materials for as long as possible,” Diernberger said, explaining that reuse and remanufacturing preferred to recycling where technically and economically feasible.
“To achieve this, the BMW Group continuously develops its capabilities and partnerships across the entire lifecycle of high-voltage batteries," he added. "This includes battery diagnostics, concepts for reuse and remanufacturing, as well as the recovery of valuable raw materials.
Battery hubs take shape
The shift downstream is becoming even more complex with EV batteries, which require specialised handling and could drive a new network of regional collection, storage and processing hubs.
As one of the consequences of the ELVR adoption, the industry expects the emergence of regional battery-processing hubs that can aggregate volumes efficiently and reduce transport distances for end-of-life batteries, according to Maiju Daniel-Huhtaniska, communications and marketing manager at Fortum Recycling & Waste.
“At the same time, cross-border flows will remain necessary, as large-scale recycling and refining facilities require significant volumes to achieve economic viability,” Daniel-Huhtaniska said.
In practice, Daniel-Huhtaniska continued, the earlier stages of the value chain, such as collection, dismantling and pre-processing, are likely to become increasingly localised, while black mass refining and battery materials production will remain concentrated in a limited number of specialised facilities.
Battery storage and the safety infrastructure represent the most pressing bottleneck, Febelauto’s Helsen said. Battery stock at dealers is already growing faster than safe storage space allows.
Today only a small fraction of Febelauto’s partner network – around 10 of more than 100 facilities – meets this ATF+ standard, allowing them to handle electric ELVs.
“As the number of end-of-life EV batteries increases, the number of ATF+ will also need to increase. We are already raising awareness of this amongst our centres,” Helsen said.
From a European competitiveness perspective, keeping battery materials within Europe and establishing reliable regional recycling capacity will become increasingly important as demand for critical battery metals continues to grow, Daniel-Huhtaniska emphasised.