T&E position paper on the End-of-life Vehicles Regulation

The automotive sector accounts for a significant share of material consumption in the EU, particularly for steel (17%), plastics (10%), with the transport sector as a whole accounting for 40% of all aluminium use. Increasing circularity is crucial for a more efficient use of these materials, and a growing interest has emerged for this topic in the EU. The Draghi report from September 2024 highlighted the untapped economic and strategic potential of increasing the circular use of raw materials in Europe. It also concluded that the automotive sector would benefit from adopting new and advanced standards in vehicle recycling and recycled material rates. Furthermore, European Commission President Ursula von der Leyen aims to create lead markets, including for clean steel, as part of the EU’s Clean Industrial Deal. T&E has in its green steel study how the automotive sector is perfectly placed to be that lead market.

Materials are a big contributor to cars’ embedded emissions (between 16 and 30% for steel and iron; 27-30% for aluminium depending on whether the vehicle has an internal combustion or electric powertrain). At the same time, decarbonising energy intensive sectors such as steel is high on the political agenda, so adding a firm demand route will make these investments viable and help commercialise technology faster.

In addition, improving the treatment and recycling of end-of-life vehicles (ELVs) represents an opportunity to access more reusable and recyclable materials. However, circularity in the automotive sector remains low and thus requires an updated regulatory framework to ensure more supply and crucially demand for quality recycled materials in the automotive sector.

In this context, T&E welcomes the proposal for a new ELV regulation, and supports the objectives of the Commission. The new text aims at improving the collection of ELVs, increasing the quality and quantity of recycled, remanufactured and reused material from ELVs and their use in the production of new vehicles, as well as preventing the leakage of environmentally damaging and unsafe used vehicles to third countries.

Still, several improvements need to be made:

• A mandatory target for green steel (covering both scrap and green primary steel) in new cars of 40% should be introduced by 2030, rising to 75% in 2035 and 100% in 2040.

• This should be coupled with quality requirements limiting copper contamination to 0,06% on secondary steel coming from ELVs to increase the supply of high quality scrap steel that can be reused in new cars. The current EC proposal only requires a feasibility study on possible recycled content targets to be conducted 23 months after the entry into force of the Regulation.

• A similar mandate should be introduced on aluminium in new vehicles: The Commission should already begin work on an impact assessment on green aluminium targets (covering both scrap and primary production) and adopt green aluminium mandates for new cars under secondary legislation no later than 12 months after entry into force of the regulation.

• The requirement for dismantling parts and components such as batteries, engines, or catalytic converters among others prior to shredding in Annex VII-C should be expanded to cover additional materials, including:

  • Some small Electric and Electronic Equipment. This will help avoid contamination of materials, thus increasing the availability of high quality automotive grade scrap.

  • Mono-material aluminium components with a weight above 5 kg - which should be sorted between cast and wrought aluminium.

• The proposal to require used vehicles intended for export to prove their roadworthiness is an important and necessary provision to reduce environmental and safety risks in importing countries. T&E proposes that, in addition, a Euro 4 limit on vehicles exported to third countries be introduced from 2028 ownards, moving to a 5 year vehicle age limit from 2035 onwards. This will further reduce the flow of old, polluting vehicles to third countries. Since most vehicles sold in 2030 are expected to be electric, setting a 5 year age limit on vehicle exports from 2035 will accelerate the uptake of cleaner and zero emission vehicles in these countries and allow them to leapfrog more complex combustion technologies (Euro 5, 6 and 7).

• Collection of ELVs - currently lagging in the EU - should be improved by introducing new financial incentives for owners to bring their ELV to an Authorised Treatment Facility by requiring Member States to establish a national Deposit Refund Scheme (DRS) in an effort to improve vehicle collection.

Finally, the proposed Circularity vehicle passport should include more information, such as material composition (including share of recycled content per material) and carbon footprint. It should also be merged with other passports, such as the battery passport and vehicle environmental passport; and be made available by 2027, instead of 7 years after the entry into force of the Regulation as proposed by the Commission, which would be in 2033 at the very earliest.

To find out more, download the position paper.