„Companies within the German automotive industry are international leaders—including with regard to the circular economy—and, through their innovations, they set global standards. Particularly against the backdrop of geopolitical developments and growing challenges, innovations and investments in this field constitute a key building block for enhanced resilience. The VDA therefore supports, in principle, the Federal Government’s National Circular Economy Strategy as well as the Action Program presented today.

At the same time, however, it is also evident that the strategy, in its current form, does not yet adopt a holistic approach: the circular economy encompasses more than just recycling. To unlock its full economic potential, it is necessary to consider every facet of the circular economy—including, for instance, the practice of remanufacturing. This process involves the industrial refurbishment of a used product such that it subsequently functions and can be utilized once again as if it were 'like new.' This method combines significant potential for value creation with a clear environmental benefit. To foster the development of these circular flows, the Federal Government should consider implementing support measures.

A central focus of the proposed measures lies on digitalization. Crucially, it must be ensured that no new bureaucratic burdens are imposed on businesses—a risk currently emerging, for instance, with the Digital Product Passport. Instead, the Federal Government should prioritize measures that are simple to implement; for example, alongside the announced digitalization of vehicle registration, it should also enable the digitalization of vehicle deregistration. This would have a positive impact on the automotive circular economy.

Unfortunately, a crucial aspect remains unaddressed in the current draft of the National Circular Economy Strategy: the necessary linkage between the circular economy and chemicals legislation. The currently applicable REACH Regulation provides neither for general exemptions for spare parts nor for the consideration of material cycles in the context of substance restrictions. Consequently, spare parts would have to be completely redesigned—and their authorizations renewed—following every substance restriction. This process would simply not be economically viable. Current regulations within chemicals legislation impede the ability to repair automotive products and thus also key aspects of a holistic circular economy. Against this backdrop, the VDA advocates for a targeted revision of the REACH Regulation in order to reduce bureaucracy, enhance legal certainty, increase transparency, and foster the circular economy—without compromising the high level of protection for human health and the environment.“