"The agreement reached in the trilogue negotiations on the End-of-Life Vehicles (ELV) regulation is an important step towards a more circular automotive industry. The new regulations are intended to strengthen the reuse and recycling of vehicles as well as the recovery of valuable raw materials.

At the same time, the revision of the End-of-Life Vehicles Directive has reached a considerable scale—accompanied by significant red tape for companies. With the announced 'Environmental Omnibus' the European Commission has signaled its intention to reduce excessive bureaucracy and regulation. This principle of simplification should also be consistently applied to the End-of-Life Vehicles Directive. The complexity of the regulatory requirements became clear during the trilogue negotiations. Despite the agreement reached, key issues remain unresolved, and further technical discussions are pending.

A key element of the new regulations is the introduction of binding quotas for the use of recycled plastics in new vehicles: 15% after six years, 25% after ten years, of which at least 20% must be in closed loops, i.e. directly from end-of-life vehicles.

The VDA generally supports the objective of the regulation, but it is still too early for a final assessment. Numerous questions remain unanswered—for example, regarding the recognition of different recycling technologies or the practical implementation of reliable proof of origin. We are particularly critical of the closed-loop requirement: it places considerable demands on the economic efficiency and organization of material flows and restricts the necessary flexibility of companies. Only with sufficient scope for action, the environmental targets can be achieved without jeopardizing vehicle safety or stifling innovation. We also reject an automatic requirement to impose recycled content quotas on all material flows. Instead, incentives should be examined—for example through the European Fleet Regulation.

The automotive industry is already investing extensively in the circular economy—beginning with circular design, repair and return concepts, and up to the remanufacturing of components. A key prerequisite for further strengthening the automotive circular economy is that existing, individually structured manufacturer networks remain viable through contractual relationships. Only in this way, companies can reliably meet their high quality and due diligence obligations.

For the commercial vehicle sector, the ELV regulation offers the opportunity to gain valuable experience in a circular economy. However, simply transferring it to body and trailer manufacturers would entail existential risks. Potential exemptions for SMEs also fall short and fail to address the sector's structural complexity. For the relevant VDA-organized companies, which primarily operate in individually manufactured small series and limited production runs, targeted support measures are needed regarding the return for disposal and the costs. Specific guidance from the member states is essential in this area.

Now it's crucial that the implementation of the regulation promotes innovation, enables value creation and creates practical solutions for all stakeholders in the value chain."