ROP on vehicles is coming - EP adopted proposal for ELV regulation

In response to growing climate challenges, scarcity of raw materials and the move towards a more sustainable production model, the European Parliament has adopted a proposal for new regulations to cover the entire life cycle of vehicles - from design, production and use to disposal.

European Parliament in favour of adopting the ELV Regulation

9 September 2025. The European Parliament has adopted a proposal for new legislation that aims to accelerate the automotive industry's transformation towards GOZ mainly by Reducing the environmental impact of the production and disposal processes of end-of-life vehicles and promoting the sustainability of the car recycling industry in Europe. The new regulations will cover the entire life cycle of vehicles: from eco-design and production to dismantling, recycling and final waste management.

A draft regulation on this issue was proposed by the European Commission in mid-2023. Two years later, work on the draft was initiated by the (EU) Council, which broadened the scope of the proposed legislation and forwarded it to the EP for further work. The next stage of the legislative procedure is inter-institutional negotiations.

The draft End-of-Life Vehicle (ELV) Regulation under consideration provides, inter alia, for the following. creation of a system of extended producer responsibility, setting targets for the use of recycled plastics and clarifying and tightening requirements for the treatment of end-of-life vehicles. The legislation also opens up the possibility of setting future recycling targets for other materials, i.e. steel, aluminium and critical raw materials.

Designing vehicles for recycling and reuse

The ELV Regulation will introduce an obligation for vehicles to be eco-designed to allow, as far as possible, for the disassembly of reparable, re-usable, reconditionable or recyclable components and other subassemblies. It will only apply to components that are technically demountable by authorised dismantling stations. To facilitate identification and recovery, there will also be a obligation to label all parts containing metals, plastics and critical raw materials. In addition, information on the materials used in the production of the vehicle will be included in the digital product passport.

Minimum content of recycled plastics

The regulation will require vehicle manufacturers to use recycled plastics in the design and manufacture of new vehicles. In order to make it easier for entrepreneurs to comply with the new regulations, there is provision for 2-stage, successive increase in minimum levels of recyclate:

• 20% recyclate 6 years from the entry into force of the regulation,
• 25% recyclate 10 years from the entry into force of the regulation.

Targets for the use of steel and recycled aluminium and its alloys are to be set by the Commission at a later date and after in-depth analysis.

In the original version of the draft, which was reviewed by the (EU) Council, a 3-stage implementation of the recycled content targets was planned. However, the EP proposed to tighten these criteria and change from a minimum recycled content after 6 years of the regulation from 15% to 20%. This means that businesses will have less time to adapt their operations to the new regulation and thus to achieve the ambitious target set by the EU. At the same time, it is worth noting that The Commission will be given the power to apply temporary derogations from these objectives in cases where the availability of recycled materials decreases or their price increases dramatically.

Extended producer responsibility - EPR system in the automotive industry

Three years after the regulation comes into force, vehicle manufacturers will be subject to EPR obligations - they will have to cover the costs of collection, recovery and treatment of end-of-life vehicles. They will be able to carry out all these tasks either independently or collectively, i.e. through producer responsibility organisations (PROs). To make it easier for producers to operate in all EU markets, EPR systems for vehicles in individual Member States to be harmonised and standardised.

The financial contributions of manufacturers subject to EPR obligations will be modulated according to, for example, recycling efficiency and the characteristics of vehicles that facilitate their subsequent treatment. Structured in this way ecomodulation of charges is to encourage eco-design and the development of technologies that expand the possibilities for reusing parts and components.

Read also: There will be ROP for textiles. The European Parliament has voted to amend the Directive >>.

New definitions and rules for dealing with vehicle waste

The new EU regulation provides for strict rules on disassembly of certain components prior to the shredding process, with the aim of improving recovery of raw materials and reducing material losses. Shredded waste will be subject to bans on mixing with other types of waste (even made from the same materials) and landfilling. These guidelines will be followed by new monitoring and reporting obligations for producers and recyclers.

Due to the specificity of the waste generated from end-of-life vehicles, extended definitions of recycling, reuse and remanufacturing (refurbishment) will also be introduced.

Export ban on end-of-life vehicles

MEPs are calling for a ban on the export of vehicles that meet the definition of end-of-life. Changes to national vehicle registration procedures will be introduced to enable its enforcement by member states. It is also planned to improving and tightening up border controls and setting up an electronic system to facilitate the work of customs authorities.

There is a definite the distinction between end-of-life vehicles (ELVs) and other vehicles. end-of-life, ELV) and second-hand vehicles. The EU legislator has created clear, exhaustive criteria on the basis of which a vehicle can be considered an ELV. This is important because an end-of-life vehicle becomes waste and it is no longer possible to lose this status (even through repair).

Which vehicles will the ELV regulation cover?

The position adopted by the EP is that the new regulation will cover all vehicles with very few exceptions in the form of special vehicles, vehicles designed and built for use by the armed forces, civil defence, fire and ambulance services, and vehicles of particular historical and cultural interest. A similar approach was proposed by the Council, expanding the catalogue of vehicles to include heavy-duty trucks, two- and three-wheel bicycles and four-wheelers, among others.

A review and possible revision of the entire regulation is scheduled for eight years after the act's entry into force.

Why vehicles? Background to the work on the ELV Regulation

Start of work on legislation to regulate the entire life cycle of vehicles follows the adoption of the European Green Deal, which aims to transform the EU into a climate-neutral closed loop economy. EU authorities have repeatedly stressed that producer responsibility obligations for the entire life cycle of a product will be progressively extended to more categories of goods, starting with those with the greatest negative impact on the environment. Vehicles and the automotive industry as a whole undoubtedly fit into this narrative.

As the EU Council press release reads:

Vehicle manufacturing is one of the most resource-intensive industries. The European automotive sector accounts for 19% of the EU steel industry's demand (more than 7 million tonnes per year), 10% of the total plastics consumption (6 million tonnes per year) and a significant part of the demand for aluminium (42% for all transport equipment, about 2 million tonnes per year), copper (6% for car parts), rubber (65% of production of general rubber products) and glass (1.5 million tonnes of flat glass produced in the EU).

Sources:

1. New EU rules on design, reuse and recycling in the automotive sector, https://www.europarl.europa.eu/news/en/press-room/20250905IPR30178/new-eu-rules-on-design-reuse-and-recycling-in-the-automotive-sector
2. Circular economy: Council adopts position on the recycling of vehicles at the end of their life, https://www.consilium.europa.eu/en/press/press-releases/2025/06/17/circular-economy-council-adopts-position-on-the-recycling-of-vehicles-at-the-end-of-their-life/
3. Proposal for a Regulation of the European Parliament and of the Council on circularity requirements for vehicle design and on management of endof-life vehicles, amending Regulations (EU) 2018/858 and 2019/1020 and repealing Directives 2000/53/EC and 2005/64/EC - General approach, https://data.consilium.europa.eu/doc/document/ST-10092-2025-INIT/en/pdf