Automotive Parts Remanufacturers Association Europe
APRA Europe
APRA is the only global association that has been representing the interests of automotive remanufacturing companies since 1941.
ID: 233702643888-01
Lobbying Activity
Response to Circular Economy Act
6 Nov 2025
APRA Europe Statement on the EU Circular Economy Act Public Consultation As APRA Europe, we represent, through our members, approximately two-thirds of the workforce in the European automotive remanufacturing industry. We strongly welcome the European Commissions initiative to develop a Circular Economy Act, which we consider a vital step toward achieving the EUs environmental and sustainability goals. We would like to take this opportunity to highlight several key considerations that we believe are essential for the success of this initiative: 1. Comprehensive Inclusion of R-Strategies The Circular Economy Act should explicitly recognize and promote the full spectrum of R-strategies, including re-use, re-purpose, repair, refurbishment, and remanufacturing. These strategies are critical to extend product lifecycles, reducing waste, and conserving resources. 2. Hierarchy of Circular Actions We propose that the Act clearly defines that new products must be designed and intended for re-use, re-purpose, repair, refurbishment, and remanufacturing before considering recycling or disposal at end-of-life. This hierarchy ensures that higher-value circular strategies are prioritized. 3. Alignment with the Critical Raw Materials Act To meet the objectives of the Critical Raw Materials Act, the Circular Economy Act should emphasize avoiding recycling and disposal for as long as possible, thereby maximizing the retention of embedded value and reducing dependency on virgin raw materials. 4. Supply Chain Collaboration and Sustainability Reporting Circularity can only be achieved through cooperation across the entire value chain. Therefore, we recommend that the ecological benefits of circular practices be transparently reflected in the sustainability reporting of all stakeholders involved. 5. Support for Green Public Procurement Within the framework of green procurement, we advocate for the prioritization and support of used and remanufactured products. This will not only stimulate demand for circular products but also reinforce market confidence in their quality and reliability. 6. Free Movement of Used Parts within the EU and FTAs A key enabler of circularity is the unhindered movement of used parts intended for re-use, re-purpose, repair, refurbishment, and remanufacturing. We urge the Commission to ensure that such movement is safeguarded within the EU and incorporated into relevant Free Trade Agreements (FTAs). We appreciate the opportunity to contribute to this important consultation and remain committed to supporting the EUs transition to a circular economy that is both sustainable and competitive. APRA Europe
Read full responseResponse to Revision of EU legislation on end-of-life vehicles
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 operators and repair and maintenance operators. This request should be extended to the group of remanufacturers of automotive parts. 2. The request to mandatory dismantle specific parts category at end of life for remanufacturing. A prioritization of further use of this dismantled parts in line with the waster hierarchy, in favor for reuse and remanufacturing before recycling is missing. 3. The clarification that certain categories of parts should not be further directly reused. A constraint that certain categories could be used for remanufacturing should be added. 4. The guideline how to assess the fitness for Remanufacturing. 5. The clarification that parts and components removed from an end-of-life vehicle, which are suitable for reuse, remanufacturing, or refurbishment, should not be considered waste. 6. The attempt to define remanufacturing on an EU wide level. This definition should respect the automotive sector specific requirements mainly as the ELV-R is a automotive sector specific regulation. 7. The clear guideline how to label parts removed from vehicles to be reused, refurbished, or remanufactured. An applicable guideline how to label remanufactured Parts when they are traded in the market would be welcome. 8. The request to the Member States to adopt incentives to promote Remanufacturing. 9. The approach to establish penalties for violations on regulations on trading used vehicles and used parts. Trade limitations should be explicit not valid for remanufactured new parts and components.
Read full responseResponse to Initiative on EU taxonomy - environmental objective
3 May 2023
APRA Europe, the Automotive Parts Remanufacturers Association Europe, welcomes the Commissions draft Delegated Act on the Taxonomy for the four remaining objectives. Automotive remanufacturers see the need for recognizing the contributions of their activities in the domains of aftermarket, circularity and remanufacturing. We welcome the presence of NACE Code C29 in category 5.3 (Preparation for re-use of end-of-life products and product components) and category 5.4 (Sale of second-hand goods). Sale of second-hand or remanufactured components are crucial activities for extending the lifetime of a vehicle and allow for considerable energy and resource savings. Further, NACE Code C29 should be listed in category 5.1 (repair, refurbishment and remanufacturing) to give recognition to the remanufacturing activities of vehicle components. These activities prevent the exploitation of virgin materials and the emissions related to the processing of such materials. For these reasons, the repair, refurbishment and remanufacturing of automotive components should be an eligible activity and should follow the same screening criteria as the in-scope activities.
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