#GuestColumn: The End-of-Life Vehicles Regulation Nears the Finish Line in the EU
The European Commission published its proposal for a Regulation on the Circularity Requirements for Vehicle Design and on Management of End-of-Life Vehicles in 2023. At the end of last year, a provisional agreement on the regulation was reached between the Commission, the Member States, and the European Parliament. In this article, Eini Lemmelä, Senior Specialist at the Finnish Ministry of the Environment, explains the objectives and timetable of the regulation.
Text: Eini Lemmelä, Ministry of the Environment
At present, the End-of-Life Vehicles Regulation is expected to be formally adopted and enter into force no earlier than spring 2026. The regulation will begin to apply two years after its entry into force. In addition, several of its requirements will be subject to longer transition periods.
Increased Demand for Recycled Materials
The regulation will boost demand for recycled materials by introducing requirements for their use in new vehicles. Six years after the regulation enters into force, at least 15% of the plastic by weight contained in type-approved passenger cars and vans must consist of recycled plastic. Ten years after entry into force, this requirement will increase to 25%.
The recycled plastic must originate from waste generated by products that have been placed on the market, and 20% of the recycled plastic must come from end-of-life vehicles or vehicle parts.
The Commission will later assess whether these requirements should be extended to other vehicle categories and whether requirements should also be introduced for the use of other recycled materials, such as recycled steel and aluminium, in vehicles.
Easier Replacement and Removal of Vehicle Parts
The regulation also requires vehicles to be designed and manufactured so that certain components can be replaced or removed for reuse or recycling. This requirement also applies to vehicle batteries and battery packs. It will enter into force six years after the regulation takes effect and will apply most extensively to passenger cars and vans.
For other vehicle categories covered by the regulation, such as trucks, buses, and motorcycles, the requirement will apply to a smaller number of components.
Vehicle manufacturers will also be required to provide information on the replacement and removal of components. In the future, manufacturers will not be allowed to hinder the removal or replacement of components through software updates.
The regulation will also introduce a Digital Circularity Vehicle Passport, which must contain, among other things, information on component removal and components containing certain hazardous substances.
Changes to Extended Producer Responsibility
As a result of the regulation, extended producer responsibility (EPR) and waste management requirements for end-of-life vehicles will be expanded beyond passenger cars and vans to include, among others, trucks, buses, trailers, motorcycles, and mopeds.
The producer responsibility provisions of the regulation differ to some extent from Finland’s current EPR rules.
To fulfil their producer responsibility obligations, producers may enter into agreements with authorised treatment facilities. Such agreements must be fair, transparent, and non-discriminatory.
Supervisory authorities will be required to monitor the costs of collecting and treating end-of-life vehicles, the revenues of waste management operators, and producer fees in order to ensure a fair allocation of costs.
The regulation also introduces new criteria for the modulation of producer fees.
A further new element is the producer’s obligation to cover waste management costs when a vehicle becomes an end-of-life vehicle in a Member State other than the one where it was originally placed on the market, provided that no producer has been designated in that Member State. In the case of passenger cars and vans, this obligation will rest with the vehicle manufacturer.
New Requirements for the Treatment of End-of-Life Vehicles
The regulation requires operators treating end-of-life vehicles to remove specific components for reuse and recycling. Components with potential for reuse, refurbishment, or remanufacturing must be removed in a way that prevents their destruction. Exceptions may be allowed under certain conditions.
Batteries contained in end-of-life vehicles must also be removed. Under the Batteries Regulation, waste batteries from end-of-life vehicles must be delivered to battery producers or waste management operators designated by them for treatment.
Components removed from end-of-life vehicles that are suitable for reuse, refurbishment, or remanufacturing will not be considered waste. Batteries are an exception, as they remain subject to the Batteries Regulation.
Recycling Targets Remain Largely Unchanged
The existing reuse and recycling targets for end-of-life vehicles will remain unchanged, although vehicle batteries will be excluded from the calculations.
Three years after the regulation enters into force, the following annual targets will continue to apply based on the average weight of end-of-life vehicles:
- At least 85% must be reused or recycled.
- At least 95% must be reused or recovered.
The regulation also introduces a new plastic recycling target. Five years after entry into force, 30% of the plastic by weight contained in end-of-life vehicles must be recycled annually.
Certain plastics, such as plastics classified as persistent organic pollutant (POP) waste, are excluded from this target.
These targets will apply only to passenger cars and vans.
The regulation also contains requirements concerning the collection, storage, and shredding of end-of-life vehicles.
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