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Revision of EU legislation on end-of-life vehicles

Environment

This initiative will aim at improving the collection of end-of-life vehicles, their treatment and recycling, and re-use of their components. It will encourage the EU car industry to adopt a more circular model for design and production of cars. This should contribute to the transformation of the automotive sector to adapt to the European Green Deal.

Links

Public consultation

ID: 12633

Lobbying Activity

116 responses

Transport & Environment urges mandatory green steel targets

Transport and Environment (European Federation for Transport and Environment), 28 Nov 2023

Set targets for carmakers to use 10% green steel by 2030, reaching 100% by 2050. Offer financial rewards to drivers who use authorized scrapping centers.
This would help T&E meet its advocacy goal of reducing manufacturing emissions.
Illegal dismantling businesses and exporters of polluting used cars would lose revenue.

Environmental groups demand stronger circular economy rules for vehicles

European Environmental Bureau, 4 Dec 2023

The organization requests material footprint reduction targets for the automotive sector, stronger requirements for vehicle durability and repairability, and separate reuse and recycling targets. They argue the proposal fails to address the trend toward larger, resource-intensive vehicles and focuses too much on recycling over reuse.
This would reduce the environmental impact of vehicle production and resource consumption.
Automotive manufacturers lose flexibility to produce larger vehicles and face higher compliance costs.

Environmental groups demand overhaul of EU vehicle waste rules

European Environmental Bureau, 19 Nov 2020

The EEB calls for a complete overhaul of the ELV Directive through wide-ranging measures to transform the resource-intensive sector toward circularity. They want binding requirements for non-destructive disassembly before shredding, transparent recycling calculation methods across all Member States, and greater attention to vehicle design influencing full life-cycle impacts.
This would shift automotive production toward circular economy principles and environmental priorities.
Car manufacturers face stricter design requirements and compliance costs for dismantling and recycling.

European Carmakers Seek Flexibility on Recycled Content Targets

Association des Constructeurs Européens d'Automobiles, 4 Dec 2023

ACEA requests adjustments to recycled content targets, including acceptance of both mechanical and chemical recycling, special thresholds for legacy substances, and inclusion of pre-consumer recycled content. They oppose mandatory dismantling requirements for certain components and seek clarification on extended producer responsibility obligations, arguing producers cannot be responsible for ensuring compliance of all waste operators without contractual relationships.
This would reduce compliance costs and provide more time to develop recycling infrastructure.
Environmental groups lose stricter circularity standards and faster implementation of recycling requirements.

European carmakers seek flexibility on recycled content requirements

Association des Constructeurs Européens d'Automobiles, 19 Nov 2020

ACEA opposes mandatory recycled content targets for new vehicles, arguing material choices should prioritize CO2 reduction over circularity. They request at least five years implementation time for any new requirements, applying only to new vehicle types. They support automated digital systems for vehicle deregistration.
This preserves their ability to choose lighter virgin materials for CO2 reduction.
Recycling industries lose guaranteed demand for recycled plastics from vehicle manufacturers.

Chemical Industry Urges Broader Circularity Approach for Vehicles

European Chemical Industry Council, 4 Dec 2023

The organization requests recognition of chemical recycling and mass balance methods for recycled content targets, broader definitions beyond closed-loop recycling, and inclusion of bio-based and CO2-based feedstocks. They argue current recycled content targets fail to account for materials replaced during vehicle lifetime and that composite materials should not be penalized.
This would allow chemical recycled feedstock to count toward targets and reduce compliance costs.
Mechanical recyclers lose market share to chemical recycling methods with looser accounting standards.

European steel association urges stricter rules on vehicle scrap exports

The European Steel Association, 4 Dec 2023

The association urges stricter measures to stop illegal exports of high-quality vehicle scrap. They also support mandatory removal of parts to prevent copper from contaminating recycled steel.
This would secure a domestic supply of clean scrap and reduce processing costs.
Car manufacturers and the copper industry could face new financial liabilities for recycling.

Consultation response

The European Steel Association, 19 Nov 2020

The European Steel Association (EUROFER) welcomes the review of the Directive 2000/53/EC on End-of-Life Vehicles (ELVs). The Directive has contributed effectively to the improvement of the management of waste generated by discarded vehicles (ELVs) and to the establishment of ELVs recycling.…

Volkswagen Group urges lower plastic recycling targets for vehicles

Volkswagen Aktiengesellschaft, 4 Dec 2023

Volkswagen requests lowering plastic recycling targets and excluding non-recyclable materials. They propose limiting removal requirements to technically feasible and proportionate components.
Reporting per vehicle type rather than individual units reduces administrative burdens.
Independent repairers lose free access to vital vehicle dismantling and repair data.

Consultation response

ENEL SpA, 13 Nov 2020

Enel SpA, a multinational company in the energy sector and active in the e-mobility value chain, highly appreciates the EC initiative to revise the Directive 2000/53/EC on end-of-life vehicles (ELV) to prevent waste from vehicles, promote reuse, recycling and other forms of recovery of ELVs and…

BMW Group Urges Market-Based Approach to Vehicle Recycling Rules

Bayerische Motoren Werke Aktiengesellschaft, 1 Dec 2023

BMW requests the choice between non-destructive and destructive dismantling to reduce costs. They also advocate for overarching recyclate targets rather than detailed regulations for every specific material.
Avoiding mandatory dismantling and bureaucratic fees would lower operational and compliance costs.
Dismantling companies could lose valuable components if batteries are removed before vehicles are surrendered.

German Car Industry Urges Open Circular Economy Standards

Verband der Automobilindustrie, 23 Nov 2023

VDA demands an open circular economy allowing chemical recycling and post-industrial waste. They advocate for harmonized international standards instead of unique European regulations. Redundant reporting requirements for circular strategies should be eliminated to reduce bureaucracy.
Using global standards would protect competitiveness and reduce unnecessary bureaucratic costs for manufacturers.
National regulators lose the ability to control recycling market prices through state intervention.

Consultation response

Verband der Automobilindustrie, 18 Nov 2020

The Association of the Automotive Industry (VDA) represents more than 600 companies in the automotive industry -manufacturers of motor vehicles and their engines, set-ups, installations, containers and vehicle parts and equipment -which produce in Germany. The automotive industry is the…

Consultation response

Wirtschaftskammer Österreich, 19 Nov 2020

Die Wirtschaftskammer Österreich bedankt sich für die Gelegenheit zur Initiative „Überarbeitung der AltfahrzeugeRL 2000/53/EC“ Stellung zu nehmen.

Neste urges non-fossil plastic targets for end-of-life vehicles

Neste Oyj, 2 Dec 2023

Neste requests non-fossil targets to move away from virgin plastics. They argue for including chemical recycling and mass balance credits to provide manufacturers with more flexibility.
This would increase market demand for Neste's specific renewable and chemically recycled feedstocks.
Traditional plastic manufacturers face losing market share to renewable and recycled material competitors.

Eurometaux Advocates REACH Alignment for New Vehicle Regulations

EUROMETAUX, 4 Dec 2023

The association requests using REACH for substance assessments to ensure a coherent regulatory approach. They support mandatory component dismantling before shredding to maximize the quantity of metals recovered. Furthermore, they demand that non-EU recycling facilities meet strictly equivalent environmental standards.
Streamlined regulations and mandatory dismantling would reduce compliance overlaps and secure raw materials.
Non-EU recycling operations face stricter market entry barriers if they lack equivalent standards.

Consultation response

EUROMETAUX, 19 Nov 2020

The non-ferrous metals industry is one of key suppliers for the automotive sector. Metals are present in the car body (e.g. aluminium), car battery (e.g. lead, lithium, nickel, cobalt, copper), catalytic converter (e.g. platinum, palladium) or motor (e.g. copper) to name just a few applications.…

European Aluminium calls for mandatory dismantling of car components

European Aluminium AISBL, 1 Dec 2023

The group requests mandatory dismantling of aluminium components before shredding to ensure high-quality recycling. They also suggest adding specific alloy codes to circularity passports to help operators segregate materials.
Better recycling processes would reduce the industry's reliance on imported virgin materials.
End-of-life operators face increased complexity and costs from mandatory pre-shredding dismantling requirements.

Consultation response

European Aluminium AISBL, 13 Nov 2020

In the context of the revision of the End of Life Vehicle Directive European Aluminium would like to share its top priorities. The following points are focusing on issues that can improve the recycling of End of Life Vehicles (ELVs) in general and the recycling of aluminium from these vehicles in…

German insurers demand repair standards for electric car batteries

Gesamtverband der Deutschen Versicherungswirtschaft e.V., 4 Dec 2023

The association urges the EU to set standards for repairing electric vehicle batteries on a component basis. They argue that requiring manufacturers to allow repairs instead of full replacements is essential for sustainability.
Standardized repair procedures would significantly reduce the high cost of insurance claims for batteries.
Car manufacturers would be forced to redesign battery systems and provide specific repair procedures.

Deutsche Umwelthilfe Demands Stricter EU Circularity Rules for Cars

Deutsche Umwelthilfe e.V., 4 Dec 2023

The organization calls for mandatory durability standards and immediate recycled content targets for vehicles. They demand a ban on software that restricts independent repairs and third-party parts.
Stronger regulations fulfill their mission of promoting resource efficiency and protecting consumer interests.
Automobile manufacturers would lose control over repair services and face higher production costs.

SUEZ backs ambitious circularity targets for vehicle recycling

SUEZ Group, 4 Dec 2023

SUEZ supports ambitious circularity targets but insists that the recycling closed loop must not give priority access to producers. They request that producer responsibility schemes remain financial rather than operational to avoid disrupting waste management. Additionally, waste operators should retain ownership of all spare parts and components.
This approach secures SUEZ's role in the recycling market and its control over valuable materials.
Vehicle manufacturers would lose direct control over recycled material supplies and waste management logistics.

Consultation response

Volvo Car Corporation AB, 4 Dec 2023

Overall, Volvo Cars welcomes the Commissions proposal to revise the End-of-life Directive and Directive on the type-approval of motor vehicles regarding their reusability, recyclability and recoverability, published on 13 July 2023. The proposal aims at increasing the sustainability and circularity…

Plastics Europe urges binding targets for recycled automotive plastics

Plastics Europe, 1 Dec 2023

They propose specific recycling targets for car parts and want recognition for newer recycling technologies. They also request that all types of plastic used in cars be included.
These rules provide investment security and create new markets for plastic manufacturers.
Environmental groups and citizens lose when hazardous legacy chemicals are recycled into new vehicles.

German steel industry urges flexible approach to vehicle recycling quotas

Wirtschaftsvereinigung Stahl, 4 Dec 2023

The association questions fixed recycled content quotas for steel, suggesting a flexible sliding scale based on material origin. They also want chemical regulations handled primarily through the existing REACH framework.
Applying their own classification system would allow the industry to maintain existing production standards.
Environmental advocates may lose if mandatory recycling targets for steel are weakened or delayed.

Consultation response

Wirtschaftsvereinigung Stahl, 17 Nov 2020

Die Wirtschaftsvereinigung Stahl begrüßt die Anstrengungen der Kommission, die Altfahrzeugdirektive, auch im Hinblick auf die Anforderungen durch die Elektromobilität, zu reformieren. Die Kommission betrachtet dabei drei Optionen: • Verbesserung der Umsetzung und Durchsetzung der…

ECOS Demands Tougher Eco-design and Faster Vehicle Recycling Rules

Environmental Coalition on Standards, 4 Dec 2023

ECOS demands a double legal basis to permit stricter national waste laws and tougher eco-design standards. They advocate for faster implementation timelines and including all road vehicles, like motorhomes, in the regulation.
These changes would ensure more robust environmental protections and high-quality recycling standards.
Vehicle manufacturers would face higher production costs and more stringent technical requirements.

Consultation response

E-MOBILITY EUROPE, 4 Dec 2023

AVERE - the European Association for Electromobility welcomes the European Commissions proposal to revise Directive 2000/53/EC on end of-life vehicles and Directive 2005/64/EC on the type-approval of motor vehicles with regard to their reusability, recyclability and recoverability and to transform…

Consultation response

Veolia Environnement, 19 Nov 2020

Veolia welcomes the revision of the ELV Directive as a way to increase the contribution of ELV management to the circular economy in line with the Green Deal and the Circular Economy Action Plan. The ELV Directive has been instrumental in better managing vehicles once they become waste and Veolia…

Toyota Motor Europe urges flexible car recycling rules

TOYOTA MOTOR EUROPE, 4 Dec 2023

Toyota asks for a clearer methodology and inclusion of pre-consumer waste in recycling targets. They request a five-year lead time for new design requirements to match development cycles. The company argues producers should only finance contracted waste operators to ensure efficiency.
These changes would lower compliance costs and align regulations with automotive production cycles.
Independent recycling facilities would lose guaranteed financial support from car manufacturers for processing vehicles.

European tyre industry urges EU to avoid double regulation

European Tyre & Rubber Manufacturers' Association, 4 Dec 2023

The association wants tyre requirements managed under ecodesign laws rather than vehicle regulations to prevent overlapping rules. They call for consistent definitions to ensure retreaded tyres are not treated as waste.
This provides the industry with regulatory certainty and supports the commercial tyre retreading market.
Existing recycling programs lose millions in revenue due to inconsistent fee collection systems.

Sitra urges EU-wide data space for vehicle recycling

Suomen itsenäisyyden juhlarahasto, 27 Sept 2023

Sitra recommends establishing an EU-wide data space to monitor vehicle recycling and locate missing vehicles. They suggest using decentralized data architectures instead of a single unified IT system. They also support using vehicle passports to track and recover critical raw materials.
Using Sitra's Finnish model as the EU standard would validate and export their technology.
International raw material exporters lose influence as the EU reduces its import dependency.

Consultation response

European Tyre & Rubber Manufacturers' Association, 19 Nov 2020

The European Tyre & Rubber Manufacturers’ Association (ETRMA) and its members count around 4.300 companies in the EU, employing directly 360.000 people. We have strong presence in the EU and candidate countries with 93 tyre-producing plants and 17 R&D centres. EU production is estimated in 5.1…

European Copper Institute seeks stronger rules for vehicle recycling

International Copper Association Europe, 4 Dec 2023

The group urges prioritizing the dismantling of copper wiring and stronger EU-level export controls. They support excluding copper from recycled content targets and seek exemptions from specific chemical restrictions.
The industry would recover billions in value by securing more recycled copper.
Third-country processing centers lose business as the EU prioritizes automated domestic sorting.

Consultation response

International Copper Association Europe, 19 Nov 2020

The European Copper Institute (ECI) welcomes the opportunity to comment on the European Commission’s inception impact assessment on the End-of-Life Vehicles (ELV) Directive. One of the missions of ECI is to promote the sustainable use of copper in electric vehicles. One of the goals of the…

Consultation response

European Recycling Industries' Confederation, 19 Nov 2020

EuRIC strongly welcomes the Inception Impact Assessment on the revision of Directive 2000/53/EC on end-of-life vehicles (ELVD) and its main objectives to increase the contribution of the automotive sector to the circular economy and to ensure that the ELVD is adapted to the current and future…

Consultation response

Plastics Recyclers Europe, 19 Nov 2020

Plastics Recyclers Europe (PRE) represents the interest of the plastics recycling industry. Several of PRE members are specialized in treating the shredder light fraction resulting from the ELV treatment to produce plastics recyclate for use in the traditional plastics compounding and converting…

Stegra proposes near-zero steel for EU vehicle recycling targets

Stegra (formerly H2GS AB), 4 Dec 2023

Stegra proposes allowing near-zero steel based on primary raw materials to meet mandatory content targets. They recommend the Commission adopt the IEA definition to avoid disrupting industry standards.
This allows their low-carbon primary steel to satisfy demand where recycled scrap supply is insufficient.
Post-consumer scrap suppliers face competition if primary steel substitutes for mandatory recycled content targets.

Consultation response

Fédération Internationale de l'Automobile, 19 Nov 2020

The FIA European Bureau welcomes the European Commission’s ambition to adapting the end-of-life vehicles (ELVs) rules to the objectives set out in the European Green Deal, as well as to considering the technological advances. FIA European Bureau invites the European Commission to further consider…

Soft drink industry urges closed-loop recycling for end-of-life vehicles

Union of European Beverages Association, 2 Oct 2023

The industry suggests focusing on closed-loop recycled content and ensuring sectors have priority access to their own recycling feedstock. They want to discourage the automotive sector from using recycled material that could be reused in its original application.
This protects their supply of recycled food-grade plastic from being diverted by the car industry.
Car manufacturers would lose a cheap source of recycled plastic needed for their own targets.

MOL Group urges flexibility in EU vehicle recycling rules

MOL Hungarian Oil and Gas Company, 2 Dec 2023

MOL Group argues for pre-consumer recyclate recognition and flexible national waste systems. They suggest replacing strict model-specific requirements with broader manufacturer-to-manufacturer loops. They also propose delaying plastic recycling targets to ensure technical and commercial feasibility.
This would reduce operational expenses by avoiding complex tracking and cross-border transport costs.
Environmental goals are undermined by the request to delay plastic recycling targets for years.

FIGIEFA urges EU to mandate repairability in car design

FIGIEFA - Fédération Internationale des Grossistes, Importateurs & Exportateurs en Fournitures Automobiles / International Federation of Automotive Distributors, 1 Dec 2023

FIGIEFA recommends the introduction of a general 'repairability by design' requirement for vehicles. They also seek to ensure fair competition between vehicle manufacturers and independent operators.
This would preserve the market share of independent distributors and repair shops.
Car manufacturers lose control over repair data and part replacement fees.

Waste industry group FEAD urges faster car recycling rules

FEAD, 4 Dec 2023

FEAD requests reducing the transition period for vehicle types to three years. They also advocate for setting clear collection targets for end-of-life vehicles. The group wants flexible dismantling rules based on market demand and feasibility.
Flexible rules and better access to materials would boost their commercial profitability.
Car manufacturers may face higher fees to fund increased recycling and dismantling costs.

Italian SME Federation Urges Support for Transition to Circular Vehicle Rules

Confartigianato Imprese, 7 Nov 2023

The organization requests timeline harmonization between producers and waste managers, specific training programs for SMEs, clear guidelines for repair shops on updating vehicle circularity passports, and measures to avoid excessive costs and bureaucratic burdens on small businesses.
This would give SMEs adequate time to adapt business models and avoid penalties for impossible-to-meet targets.

Consultation response

FEAD, 18 Nov 2020

FEAD, the European Federation for Waste Management and Environmental Services, welcomes the Revision of Directive 2000/53/EC on End-of-Life Vehicles as part of the new CEAP and the Green Deal. Historically, the vehicle composition is changed and is shifted towards light materials such aluminum and…

French insurers oppose scrapping cars based on repair costs

Fédération Française de l'Assurance, 4 Dec 2023

France Assureurs argues only technical criteria should define an end-of-life vehicle. They request removing economic criteria that force functional cars to be scrapped.
This allows insurers to manage rising repair costs and support the reused parts sector.
Low-income households lose the ability to keep functional cars with minor cosmetic damage.

ADAC welcomes EU vehicle recycling and digital certificate rules

Allgemeiner Deutscher Automobil-Club e.V., 13 Nov 2023

ADAC supports the regulation to reduce missing vehicles through improved traceability and digital certificates of destruction. They request including motorcycles and trucks in all requirements while ensuring exemptions for historic vehicles. Furthermore, they advocate for maintaining a 50km maximum distance for vehicle return points to assist consumers.
Members benefit from reduced administrative burdens and better availability of recycled spare parts.
Vehicle owners may face higher costs for technical assessments to prove roadworthiness.

Covestro urges flexible plastic recycling targets for EU vehicles

Covestro AG, 4 Dec 2023

Covestro proposes a 20% post-consumer recycled plastic target supplemented by 5% circular materials. They demand immediate acceptance of chemical recycling using a mass balance credit model. They also seek clearer definitions to ensure diverse recycling technologies are recognized.
Broadening targets to include circular feedstocks would benefit Covestro's specialized polymer portfolio.
Adhesive producers face unfair market disadvantages if labeled as obstacles to recycling.

Glass for Europe advocates for closed-loop automotive glass recycling

Glass for Europe, 4 Dec 2023

They want a clear definition of dismantling to ensure high purity and non-contamination standards. The group proposes prioritizing closed-loop recycling that returns automotive glass specifically to the flat glass sector. They also advise against listing specific sub-sectors allowed to recycle automotive glass.
These changes ensure the industry receives the pure materials required for manufacturing.
Other recycling sectors might lose access to high-quality glass waste streams.

Consultation response

Mazda Motor Logistics Europe N.V., 4 Dec 2023

Mazda Motor Europe supports the ambition of the European Green Deal to achieve a climate neutral, clean and circular economy by 2050. Already today, the car industry is committed to developing vehicles sustainably so that they can deliver exceptionally high recycling rates when reaching the end of…

Novelis urges mandatory recycled aluminum targets for cars

Novelis Europe, 4 Dec 2023

Novelis seeks immediate, ambitious recycled content targets for aluminum in vehicles. They also advocate for better tracking and dismantling of heavy car components.
Mandatory targets would increase demand for the company's high-recycled-content aluminum.
Car manufacturers would bear the financial burden under mandatory producer responsibility schemes.

Battery association EUROBAT urges removal of battery rules

Association of European Automotive and Industrial Battery Manufacturers, 9 Nov 2023

EUROBAT requests removing battery substance restrictions from the proposed vehicle circularity regulation. They suggest moving lead battery reviews to the Batteries Regulation to ensure consistency.
This would reduce administrative burdens and eliminate risks of overlapping, contradictory regulations.

Consultation response

Association of European Automotive and Industrial Battery Manufacturers, 19 Nov 2020

With this position paper, EUROBAT would like to provide its expert input on the Inception impact assessment on the End-of-Life Vehicles Directive. Timing: the proposal is severely delayed First of all, we regret that the proposal is considerably delayed compared to the own Commission legal…

ICCT urges mandatory recycled steel targets for all vehicles

International Council on Clean Transportation, 4 Dec 2023

The group recommends setting a minimum recycled content for steel in production. This minimum share should be based on postconsumption scrap rather than fabrication scrap. They encourage to include all types of road vehicles in all provisions.
This would achieve their goal of significantly abating emissions from vehicle manufacturing.
Primary steel producers will lose demand as industry shifts away from virgin materials.

JLR Urges Longevity Focus in New Vehicle Recycling Rules

Jaguar Land Rover Limited, 4 Dec 2023

JLR suggests prioritizing vehicle longevity through reuse and remanufacturing rather than focusing primarily on recycling. They request that post-industrial and chemical recycling count toward mandatory recycled content targets.
Broadening the definition of recycled content helps the company meet targets despite quality shortages.
Consumers may experience reduced vehicle quality and noise issues from mandatory dashboard dismantling.

Semiconductor industry urges flexibility in new vehicle recycling rules

European Electronic Component Manufacturers' Association, 4 Dec 2023

The association requests easier criteria for chemical exemptions and a clear process for new ones. They also argue that semiconductor plastics should be exempt from recycled content targets to ensure safety.
This would allow manufacturers to maintain high-performance standards while avoiding unfeasible recycling mandates.
Environmental groups lose the strict regulatory hurdle requiring all criteria for hazardous material exemptions.

Japan Business Council urges realistic targets for vehicle recycling

Japan Business Council in Europe, 1 Dec 2023

The organization demands achievable timelines and practical targets for using recycled materials. They argue that including industrial waste and bio-based plastics is necessary to meet requirements.
This would lower costs and reduce the technical burden on manufacturers.
Environmental groups lose as the circularity of consumer waste recycling is weakened.

European Plastics Converters seek flexible recycled content rules

European Plastics Converters Association, 1 Dec 2023

The association requests including pre-consumer waste and chemical recycling to meet the 25% recycled content target. They urge prioritizing open-loop recycling over closed-loop mandates to ensure material availability. Additionally, they propose a broader plastic definition to include thermosets and avoid overlapping chemical regulations.
Expanding the types of allowed recycled materials reduces compliance costs and production risks.
The environment loses if industry prioritizes factory scrap over harder-to-recycle used vehicle waste.

Italian SME group urges EU flexibility on vehicle recycling

Confederazione Nazionale dell'Artigianato e della Piccola e Media Impresa, 6 Nov 2023

They advocate for a directive to maintain flexibility during national implementation. The group also opposes fees for accessing technical repair and dismantling information.
Existing dismantling facilities would avoid significant new administrative costs and technical investment requirements.
New collection point operators may face barriers entering the vehicle waste market.

Platform for Electromobility urges harmonized EU vehicle recycling rules

Platform for Electromobility, 4 Dec 2023

They support a harmonized regulatory framework and an export ban on non-roadworthy vehicles. The group seeks alignment with battery laws to avoid administrative redundancy via merged digital passports. They also seek incentives for low-carbon materials and consumer demand for sustainable EVs.
This would reduce their compliance costs by preventing duplicative reporting requirements for batteries.
Exporters of old cars lose revenue because of the ban on non-roadworthy vehicles.

Natural Mineral Waters Europe urges protection for bottle recycling loops

Natural Mineral Waters Europe aisbl, 2 Oct 2023

NMWE calls for the EU to prioritize closed-loop recycling for all products. They request priority access to their own recycled material to meet legal targets.
Securing their own materials allows beverage producers to meet mandatory EU recycling obligations easily.
The car industry loses access to easy recycled materials, ending their ability to free-ride.

Waste-to-energy plants urge energy recovery for non-recyclable vehicle parts

Confederation of European Waste-to-Energy Plants, 19 Nov 2020

The organization advocates for maintaining energy recovery for waste streams that cannot be reused or recycled. They also call for solid methodologies in recycled content calculations and updated legal definitions.
This ensures waste-to-energy plants continue receiving materials that are unsuitable for recycling.
Alternative fuel producers may lose access to waste streams if recycling definitions exclude fuel production.

BDE supports new EU car recycling rules with less bureaucracy

BDE Bundesverband der Deutschen Entsorgungs-, Wasser- und Kreislaufwirtschaft e. V., 4 Dec 2023

The association supports mandatory recycled plastic quotas and a digital vehicle passport. They demand removal of gas tanks before shredding to prevent explosions. They also oppose excessive reporting requirements and too many delegated acts.
The rules create a market for recycled plastics and curb illegal dismantling.
Exporters lose the ability to sell non-roadworthy vehicles as used cars abroad.

PowerShift urges more ambitious circularity targets for end-of-life vehicles

PowerShift - Verein fuer eine oekologisch-solidarische Energie- Weltwirtschaft e.V., 4 Dec 2023

PowerShift calls for binding minimum quotas for vehicle component reuse and higher recycling targets. They recommend extending the regulation's scope to include larger vehicles and motorcycles. They also advocate for 'design for disassembly' to ensure parts are easily removed and replaced.
The proposed measures would help achieve the organization's mission of reducing global primary raw material consumption.
Vehicle manufacturers would lose flexibility in design and face higher production and recycling costs.

Motorcycle manufacturers urge specific exemptions in vehicle recycling rules

Association des Constructeurs Européens de Motocycles, 4 Dec 2023

ACEM calls for including all light vehicles in the regulation for consistency. They propose a sector-specific annex and exemptions for small series manufacturers.
This would protect the competitiveness of smaller producers and allow for necessary materials.
Environmental groups lose as exemptions allow continued use of hazardous materials in production.

Lead industry urges removing battery restrictions from ELV law

International Lead Association, 22 Nov 2023

The association requests that restrictions on battery substances be removed from the ELV Regulation. They want the 2025 lead exemption review moved into the EU Batteries Regulation.
This would prevent regulatory overlap and eliminate uncertainty for battery producers.

Consultation response

ASOCIACIÓN ESPAÑOLA DE FABRICANTES DE AUTOMÓVILES Y CAMIONES, 4 Dec 2023

The Spanish Automobile Manufacturers' Association (ANFAC) is firmly committed to advancing the EU towards a modern, resource-efficient, and competitive economy. We welcome the European Commission's Proposal for a Regulation on circularity requirements for vehicle design and on management of…

Consultation response

Czech Automotive Industry Association, 4 Dec 2023

The Association of the Automotive Industry of the Czech Republic (AutoSAP) and its members support the objectives of increasing the use of recycled materials and reducing the consumption of primary materials in production, as well as the proper handling of end-of-life vehicles. This is already…

Consultation response

VinylPlus, 4 Dec 2023

VinylPlus supports the high level of ambition shown by the European Commission in the End-of-Life Vehicles Regulation proposal. To reach the target, the recognition for chemical recycling, operating in a complementary manner to mechanical recycling, as well as a separate additional circular…

Japanese Automakers Seek Delay in EU End-of-Life Rules

Japan Automobile Manufacturers Association, Inc. European Office, 1 Dec 2023

The organization requests a minimum five-year lead time for new vehicle designs to ensure technical feasibility. They also recommend managing recycled plastics in their entirety rather than tracking specific categories like post-consumer waste. Finally, they argue that producers should not be held financially responsible for the recycling targets of independent waste operators.
This would preserve the cost-competitiveness of their vehicles and avoid complex, expensive material tracking systems.
Waste management operators would lose guaranteed cost compensation and face more direct government oversight for recycling targets.

French waste industry backs mandatory recycled content for vehicles

Fédération Nationale des Activités de Dépollution et de l'Environnement, 29 Nov 2023

The group supports mandatory recycled content but asks for a four-year implementation delay. They also oppose a ban on mixing different waste types during the shredding process.
This proposal would secure a steady supply of raw materials for European recyclers.
Vehicle producers could lose exclusive rights to purchase high-quality recycled plastic resins.

Consultation response

Fédération Nationale des Activités de Dépollution et de l'Environnement, 18 Nov 2020

The Revision of Directive 2000/53/EC on end-of-life vehicles will lead to update this current legislation to economic reality and to improve coherence with the aims of the Green Deal and the Circular Economy Action Plan. FNADE members, as key players of recycling but also of the waste treatment…

Consultation response

Critical Raw Materials Alliance, 18 Nov 2020

The Critical Raw Materials Alliance (CRM-A) represents primary producers, traders and associations of raw materials that the European Commission has determined to be critical to the European economy (CRMs). The CRM-A has closely examined the Commission’s plan to review the ELV Directive and…

Consultation response

Confederation of the European Bicycle Industry ASBL, 4 Dec 2023

CONEBI Position on Commission Proposal for a Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles CONEBI, the Confederation of the European Bicycle Industry, representing the EU Bicycle, Pedal Assist E-Bike, Parts and Accessories Industries, would like…

Consultation response

LKQ Europe, 30 Nov 2023

Please find enclosed LKQ Europe's response to the consultation.

Consultation response

Fédération Internationale des Véhicules Anciens, 30 Nov 2023

FIVA is following with interest the proposal by the European Commission on End-of-life Vehicles (ELVs) COM/2023/451 final. FIVA welcomes the introduction of the historic vehicle definition as provided by the Roadworthiness Testing Directive 2014/45/EU, as well as the exemption of historic vehicles…

Consultation response

ALPLA Werke Alwin Lehner GmbH Co KG, 4 Dec 2023

The ALPLA Group, with its headquarters in Hard, Austria, and 190 locations with 23,300 employees in 46 countries worldwide, is one of the leading companies in plastic conversion. We develop and produce innovative rigid plastic packaging solutions, while ensuring that our products become lighter,…

Consultation response

European Precious Metals Federation, 4 Dec 2023

Please find the European Precious Metals Federation input in the document attached.

Consultation response

Polyolefin Circular Economy Platform, 4 Dec 2023

PCEP (the Polyolefin Circular Economy Platform), brings together actors from across the polyolefin value chain, united in our common mission to drive the transition to a circular economy for polyolefins - the most commonly used family of plastics. 71.4% of plastics packaging in Europe is made of…

Consultation response

DERICHEBOURG ENVIRONNEMENT, 4 Dec 2023

DERICHEBOURG, a European player in automotive recycling DERICHEBOURG is a family-owned group, created in 1956 by entrepreneurs who were aware of the recovery potential of metal waste. Particularly present in France and Europe, with a dense territorial network, the group produced 6 million tons of…

Essenscia urges REACH priority in EU vehicle recycling rules

Fédération belge des industries chimiques et des sciences de la vie, 3 Dec 2023

The federation requests using existing REACH rules for chemicals instead of new regulations. They also want recognition for chemical recycling and open-loop systems.
This would prevent regulatory duplication and help the industry meet recycling targets.

Consultation response

Glass Fibre Europe, 1 Dec 2023

Glass Fibre Europe, representing the continuous filament glass fibre manufacturing industry in Europe, welcomes the European Commission proposal to review the End-of-Life of Vehicles Directive. To our industry, it stands clear that glass fibre reinforced (GFR) composites must be sustainable to be…

Consultation response

MAIF, 23 Nov 2023

MAIF, Frances 6th largest motor insurer, is a pioneer in the re-use of car parts. As such, MAIF : 1. Welcomes the measures concerning the recyclability of vehicles, but would like to see greater consideration regarding the reparability of parts / 2. Stresses the importance of making repair data…

Consultation response

Beryllium Science & Technology Association, 22 Sept 2023

The Beryllium Science and Technology Association (BeST) represents the manufacturers, suppliers and users of beryllium metal, beryllium containing alloys and beryllium oxide ceramics in the EU market. BeST has the objective of promoting sound policies, regulations, science and actions related to…

Consultation response

Hazardous Waste Europe, 18 Nov 2020

As a federation representing hazardous waste operators present on the whole chain, from collection to final treatment, ELVs are not directly our core business. Nonetheless, our commitment to ensure non toxic material cycles and limit the dispersion of pollutants in the environment grant us some…

Consultation response

European Advanced Carbon and Graphite Materials Association, 18 Nov 2020

The European Carbon and Graphite Association (ECGA) is the representative association of EU carbon and graphite producers, including a wide variety of specialty graphite and carbon products for applications ranging from electric motors to modern battery technology. Graphite and carbon materials…

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MAIF, 17 Nov 2020

Le nouveau plan d’action pour une économie circulaire, publié le 11 mars 2020, met au cœur de la stratégie de la Commission européenne la gestion des déchets et, plus précisément, le traitement optimal des véhicules hors d’usage (VHU). MAIF, société d’assurance mutuelle, 6ème assureur automobile…

Consultation response

Fédération Internationale de Motocyclisme, 4 Dec 2023

The Fédération Internationale de Motocyclisme (FIM), welcomes the opportunity to comment on the the European Commission's proposed revision of the End-of-Life Vehicle (ELV) Directive, a crucial piece of legislation that impacts not only the motorcycle industry but all road users. While we endorse…

Consultation response

European Caravan Federation, 4 Dec 2023

The ECF supports the move to a better environmentally friendly industry and is working with its partners on many aspects to improve this including the materials used in the manufacture to enable a reduction in our effect on the environment. However, we feel the inclusion of trailers in the…

Consultation response

Confederatia Patronala Concordia, 19 Nov 2020

Concordia Employers Confederation is endorsing the position of the European Automobile Manufacturers’ Association (ACEA) to support the European Commission’s initiative to ensure a better consistency with the objectives of the Green Deal, including the Circular Economy Action Plan and the European…

Consultation response

Polska Izba Ubezpieczeń, 4 Dec 2023

Polish Chamber of Insurance (PIU) supports proposed solutions aimed at systematizing requirements related to circular system of vehicle design stage and managing wrecks. We certainly endorse the goal of the proposal, which is to improve the quality of vehicles in the secondary market, encourage…

French automotive SMEs urge realistic recycling goals and implementation time

Fédération Nationale de l'Automobile, 4 Dec 2023

The organization requests a narrower definition of end-of-life vehicles and longer implementation timelines. They also advocate for harmonized recycling targets that are technically achievable for small companies.
This would protect small recyclers from excessive costs and avoid restrictive manufacturer-imposed requirements.
Large vehicle manufacturers would lose control over the independent car repair and recycling networks.

Consultation response

Asociación Española para el Tratamiento Medioambiental de los Vehículos Fuera de Uso, 1 Dec 2023

From the Spanish Association for the Environmental Treatment of End of life Vehicles (SIGRAUTO) constituted in 2002 and formed by the Spanish Association of Automobile Dismantlers and Recycling (AEDRA), the Spanish Association of Automobile and Truck Manufacturers and Importers (ANFAC) and the…

Consultation response

Stena Recycling Holding Ab, 21 Nov 2023

See attached document. Kind regards Carl Hagberg

Consultation response

Federation of European Motorcyclists' Associations, 17 Nov 2020

The Federation of European Motorcyclists’ Associations (FEMA) thanks the European Commission for the opportunity to give its vision on the revision of the End-of-life Vehicles Directive (2000/53/EC). In FEMA’s view, the current Directive succeeded in preventing waste from vehicles, the reuse of…

Consultation response

TecPart - Verband Technische Kunststoff-Produkte e.V., 4 Dec 2023

TecPart unterstützt das überragende Ziel der EU, einen CO2-neutalen Kontinent bis 2050 zu erreichen. Dazu zählen in hohem Maß die Nutzung der Sekundärrohstoffe und die damit verbundene Kreislaufwirtschaft. Demzufolge ist jegliche Rezyklatquote mit dem Maßstab der CO2-Reduzierung zu belegen. Dabei…

Consultation response

bvse-Bundesverband Sekundärrohstoffe und Entsorgung e.V., 4 Dec 2023

Beigefügt erhalten Sie die gemeinsame Verbändestellungnahme von - bvse-Bundesverband Sekundärrohstoffe und Entsorgung e.V. - BDSV - Bundesvereinigung Deutscher Stahlrecycling- und Entsorgungsunternehmen e.V. - Verband Deutscher Metallhändler e.V. (VDM)

Consultation response

Fédération Européenne des Recycleurs de Verre, 3 Dec 2023

Please find enclosed the feedback of the European Federation of Glass Recyclers (FERVER) to the consultation of the Commission.

Consultation response

Trailer Industrie Verband e.V., 1 Dec 2023

The TIV industrial association - The Trailer Industrie Verband e. V. (TIV), founded in 2015, represents the interests of manufacturers of O1 and O2 trailers (up to 3,500 kg maximum authorized mass, caravans excluded) and their suppliers. The association has its headquarters in Berlin. It currently…

Consultation response

Sveriges MotorCyklister, 1 Dec 2023

Hej! Härmed vill jag skicka in Sveriges Motorcyklister (SMC) bidrag till EU:s Förordning om uttjänta fordon och typgodkännande. SMC ser positivt att det finns ett proaktivt arbete för att förbättra miljöarbete och återvinning av olika fordonslag och strategiska komponenter. Tyvärr är motorcyklar…

Consultation response

Fédération Européenne des Recycleurs de Verre, 19 Nov 2020

Please find our feedback attached. We remain at your disposal for further answers on youur questions bska@ferver.eu mronquetti@ferver.eu

Consultation response

Zero Waste Alliance Ireland, 4 Dec 2023

Vehicle production, use and disposal is associated with negative environmental impacts at every stage, and sometimes with negative social impacts. Tackling the problem of end-of-life vehicle waste is challenging and Zero Waste Alliance Ireland welcomes the effort of the EU Commission to address…

Consultation response

European Group of Automotive Recyclings Associations, 4 Dec 2023

See attached document.

Consultation response

Stiba, 4 Dec 2023

See attachment.

Consultation response

Stowarzyszenie Forum Recyklingu Samochodów, 4 Dec 2023

Stowarzyszenie Forum Recyklingu Samochodów (FORS) z siedzibą w Warszawie jest największą i najstarszą polską organizacją pozarządową reprezentującą branżę recyklingu pojazdów wycofanych z eksploatacji. Zrzeszamy prawie 200 członków, z czego większość stanowią przedsiębiorcy prowadzący stacje…

Consultation response

Automotive Parts Remanufacturers Association Europe, 4 Dec 2023

The Automotive Parts Remanufacturers Association [APRA] appreciate the new ELV-R with a clear target to support Automotive Remanufacturing. We as association highly support: 1. The request to collect relevant data out of design and development of a vehicle and to share them with waste management…

Consultation response

Združenie autorizovaných spracovateľov starých vozidiel, 2 Dec 2023

Pripomienky a návrhy sme spracovali do priloženého PDF dokumentu.

Consultation response

ASOCIACIÓN ANDALUZA DE DESGUACES, 1 Dec 2023

Although we agree with some measures, we believe that it is necessary for this proposal to be successful that it is necessary to modify part of its content, and for this Royal Decree 265/2021 of 13 April, on end-of-life vehicles published by Spain could be a good example. We attach a document with…

Consultation response

Scholz Recycling Polska sp. z o.o., 1 Dec 2023

Response regarding the proposed Regulation on End-of-Life Vehicles, Scholz Recycling Polska input. Please find the attached file.

Consultation response

Dansk Autogenbrug, 30 Nov 2023

Dansk Autogenbrug (DAG), the Danish business association for auto recyclers, welcomes this proposal. This space only allows us to draw attention to matters which we assess will not sufficiently contribute to the fulfilment of the regulation or may work to the disadvantage of the efficiency of our…

Consultation response

Luftförorenings- och klimatsekretariatet, 27 Nov 2023

Overall, AirClim strongly supported the adoption of ambitious measures to tackle the continuing problem of 'missing vehicles'. AirClim also supports stricter requirements on the export of used vehicles, to avoid used vehicles which are not roadworthy, generate air pollution and present health risks…

Consultation response

Stowarzyszenie Forum Recyklingu Samochodów FORS, 19 Nov 2020

Przegląd Dyrektywy 2000/53/EC, która była przyjęta jeszcze w XX wieku, jest od dawna oczekiwany przez środowisko recyklerów. Cieszymy się, że trwają prace zmierzające do znowelizowania przepisów Dyrektywy a także, że w ocenę Dyrektywy są zaangażowani wszyscy operatorzy ekonomiczni, odpowiedzialni…

Consultation response

European Group of Automotive Recyclings Associations, 19 Nov 2020

See attachment

Consultation response

Suomen Romukauppiaiden Liitto ry / Finnish Scrapdealers Association, 19 Nov 2020

The Finnish Scrapdealers Association welcomes the Revision of Directive 2000/53/EC on end-of-life vehicles (ELV) as part of the new Green Deal. We support the goals of the ELV Directive and call for measures linking the ELV Directive with the objectives of the Plastics Strategy and adapting it to…

Consultation response

ASOCIACIÓN ANDALUZA DE DESGUACES, 19 Nov 2020

The Andalusian Association of Scrap yards, (AAD) presents the suggestions to modify the Directive translated into English

Consultation response

Openbare Vlaamse Afvalstoffenmaatschappij, 18 Nov 2020

In annex the feedback of Belgium on the Inception Impact Assessment for the revision of the ELV Directive.