Anyone who wants to know how the European Commission plans to promote the circular economy for vehicles, their parts, and components should take a look at the July 2023 proposal for an EU End-of-Life Vehicles Regulation. While the Council, the Parliament, and the Commission have already agreed, for example, on an EU Ecodesign Regulation, a Waste Shipment Regulation, and a Critical Raw Materials Act, the issue of an EU End-of-Life Vehicles Regulation will not be back on the table until after the European elections—and thus in the second half of 2024.

With the proposed regulation, the Commission not only aims to put a stop to the export of vehicles no longer roadworthy to third countries, but also sets requirements for design, production, and take-back and recycling structures. However, for “Reuse,” “Repair,” “Remanufacture,” and “Recycle” to become the “new normal,” we need requirements that are, on the one hand, practical and, on the other hand, actually contribute to the goals of the circular economy. The proposed regulation does not yet achieve this in all respects.

Our five “must-dos” for an EU End-of-Life Vehicles Regulation

#1 Establish the EU End-of-Life Vehicles Regulation as the foundational legal act for vehicles: Following the conclusion of the legislative process for the EU Ecodesign Regulation, it is clear that vehicles do not fall within its scope. This helps avoid duplicate regulation. We need harmonized, interlinked regulations within the EU single market with clear responsibilities and legal certainty for the individual stakeholders.

#2 Consider potential interactions with regulatory measures from other legislation: Different pieces of legislation sometimes address the same material flows. Measures such as a mandatory minimum percentage of recycled material are already part of various other regulations. However, different legislation sometimes addresses the same material flows. Therefore, we need a holistic view of the market. Only in this way can we establish measures that are both implementable and effective in advancing the circular economy

#3 Define component removal requirements with a sense of proportion: Requirements for removing components must, as a general rule, be technically feasible and reasonable and proportionate in terms of the effort involved. For cable harnesses, for example, the regulation must more clearly specify which parts must be or can be removed.

#4 Design documentation and reporting requirements to be smart and streamlined: We must ask ourselves what information we actually need for what purposes and how we can avoid duplication. Specifying the exact time of contaminant removal is an example of an unnecessary documentation requirement in the Commission’s proposal.

#5 Establish legally sound (contractual) frameworks between manufacturers and waste management operators: If properly structured, extended producer responsibility is an effective and appropriate means of ensuring that vehicles, their components, and parts are returned to the value chain. The term “manufacturer” encompasses not only vehicle manufacturers but also importers and dealers.

This last aspect also holds entirely new potential for business models aimed at circular value creation in the automotive industry, as examples from the startup scene demonstrate. With its platform, the startup ContainerGrid enables manufacturers to operate return systems on a scalable basis, thereby tapping into material cycles cost-effectively and efficiently. The central operator of a cross-border return system for end-of-life vehicles uses ContainerGrid to ensure, in compliance with legal requirements, that local requirements for vehicle recycling processes are met throughout the complex chain of waste management operators. Conversely, the system operator specifies in advance the certified quality of the resulting recycled material for its remanufacturing processes.

> “By operating such a return service—whether top-down to its suppliers, the retail sector, or across its own plants—a manufacturer can consolidate its recycling management across divisions or regions over the long term and intelligently link it to its goals for sustainable material procurement,
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> says ContainerGrid co-founder and CEO Aron Handreke.