Circular vehicles: The case for ambitious targets on repair and recycled content
By Until now, vehicles have been a model for repairability, often in operation for decades. This is rapidly changing due to overly restrictive vehicle design requirements that prevent more sustainable options, more electronic components, and less access to low-cost spare parts. How could a new EU regulation help the automotive sector make a U-turn?
In Europe, the number of households that own a passenger car rises every year. Most drivers are aware of the immediate pollution coming out of their exhaust, but how often do we consider the environmental impacts of the materials used to build the vehicle itself?
Vehicles are made from raw materials like steel, rubber, plastics, aluminium, glass, and textiles — more if they are electric and powered by a battery. These all have a carbon footprint with far-reaching impacts on the environment.
The European Commission wants to improve the sustainability of the automotive sector with its proposed Regulation on Circularity Requirements for Vehicle Design and the Management of End-of-Life Vehicles (ELVR). Done right, this law has the potential to significantly reduce the consumption of resources, extend vehicle lifespans, and strengthen Europe’s strategic autonomy.
How can policymakers make sure that circularity in vehicle manufacturing and end-of-life treatment is embedded in this new law? Repairability and recycled materials are the answer.
Repairability: The key to longevity and cost savings
Historically, consumers in Europe have kept their cars going for many years by repairing parts that are broken. This is changing due to increasing design restrictions that hinder sustainability, more electronic components, and limited access to spare parts.
Repairs are now more complicated — and more costly — making it more expensive for consumers, insurers, and independent repair services alike. This also contributes to rising levels of waste in the environment.
To reverse this worrying trend, the ELVR needs to:
- Ensure a modular design that makes repairs and component replacements easier
- Make spare parts available at fair, non-discriminatory prices (including for critical parts like electric vehicle batteries)
- Ban anti-repair practices, such as part-pairing, which forces consumers to buy parts from the manufacturer, instead of affordable, refurbished alternatives
- Guarantee software updates for at least 20 years
The repairability of electric vehicle (EV) batteries is particularly crucial because they represent up to 40% of a vehicle’s total value. It is wasteful to have to replace an entire battery pack just because one of its modules or cells needs to be fixed. EV batteries contain many strategically important critical raw materials, which must not be needlessly discarded.
To reinforce the ELVR and make electric vehicles more sustainable, monitoring methods to track the ‘state of health’ of EV batteries should also be standardised. For more on this, see our battery report.
Recycled content: Closing the loop on plastics
The push for circularity must also extend beyond repairability. Plastics account for a significant portion of the materials used in vehicles, yet their recycling rates are alarmingly low.
The proposed ELVR sets a 25% target for recycled plastic content in new vehicles, with at least 25% of this coming from end-of-life vehicle (ELV) plastics. If upheld, this target will help to drive demand for recycled materials, reduce reliance on virgin plastics, and stimulate investment in recycling infrastructure.
To make this goal a reality, the ELVR must:
- Uphold the 25% recycled plastic target in new vehicles, with a long-term goal of raising it, and ensure it includes only post-consumer waste and not post-industrial scrap or biobased plastics
- Accelerate the implementation timeline, requiring compliance within 48 months instead of allowing excessive delays
- Ensure regulatory stability by preventing loopholes or revisions that could weaken the incentives for automakers to invest in recycled materials
Circularity begins with design
The draft ELVR is currently being debated in the European Parliament — and the process is moving fast, with a rapporteur report published in February 2025. We expect to see final negotiations begin between EU institutions before the end of 2025.
Unfortunately, there are concerning signals in the rapporteur report, which favours an approach focusing more on the end-of-life of vehicles than on repair. This regulation must follow the waste hierarchy, which prioritises prevention, repair, and reuse over recycling and disposal. This will ensure its environmental success and align it with other EU legislation, such as the Battery Regulation and the Ecodesign for Sustainable Products Regulation (ESPR).
Circularity begins with design. If vehicles are not designed for repair, with parts that can be easily replaced, they cannot be effectively reused or recycled, which will unnecessarily use more materials. Vehicles are not covered by any other EU law when it comes to repair, replaceable parts, and software longevity, so a strong ELVR is vital.
If lawmakers take the right road, we could be driving towards sustainability in no time — but there may be some bumps along the way.
