Member States fall short of steering the automotive industry on a circular path 

Governments voted on a proposal to revise and merge the outdated  End-of-Life Vehicles Directive and the 3R Type-Approval Directive into a single Regulation on Circularity Requirements on Vehicle Design and on Management of End-of-Life Vehicles.

The proposal aims to strengthen the EU single market while improving the circularity of the automotive sector and reducing the environmental impacts associated with the design, production, use, and end-of-life treatment of vehicles. 

The extended scope of the regulation to cover more vehicles, and the inclusion of specific measures such as a Circularity Vehicle Passport (CVP), an EU-wide Extended Producer Responsibility (EPR) system to hold manufacturers accountable, and new requirements on the reuse of parts, components’ recycled content, better collection and improved treatment at the end of a vehicle’s life, were intended to steer the automotive sector towards decarbonisation and circularity.  

However, while the Council made some cosmetic improvements, it failed to remedy several missed opportunities in the Commissions initial proposal, and watered-down key provisions, despite the calls by environmental organisations, consumer groups and industry alike. 

Notably, the Council’s position:  

• fails to address the unsustainable material use and footprint of the sector by decreasing the number of cars and reversing the trend to ever bigger vehicles; 

• still focuses on recycling while ignoring the preferable strategies of durability, reuse, and repair, which aim to extend the lifespan of cars – particularly important after the exclusion of vehicles under the Ecodesign for Sustainable Products Regulation (ESPR); 

• insufficiently implements the Polluter Pays Principle, neglecting the upper levels of the waste hierarchy and creating an unfair double regime for non-EU countries receiving used vehicles from the EU.

Fynn Hauschke, Senior Policy Officer Circular Economy and Waste, European Environmental Bureau (EEB):  

“Member States keep dodging the elephant in the room: the ever-increasing size and number of cars on roads is driving up the automotive sector’s material use and environmental footprint. Without tackling this in the type approval process and requiring carmakers to build durable and repairable vehicles from the start, the regulation won’t put the sector on a greener path.” 

Barbara Metz, Managing Director, Environmental Action Germany (Deutsche Umwelthilfe – DUH):  

“The anti-recycling cartel, for which the European Commission fined the automotive industry by 458 Million Euro, has shown that VW, Mercedes, BMW need stricter rules when it comes to circular economy. The position of the EU Council on the vehicles regulation shows that the environment ministers of the member states are bowing to the will of the car industry. Actual producer responsibility requires to oblige all producers without exceptions to join a producer responsibility organisation that charges sufficiently high fees to enable high-quality recovery of critical raw materials and other valuable materials. Additionally, these fees must be modulated in such a way that producers with particularly environmentally harmful vehicles must pay significantly higher fees.” 

NOTES TO EDITOR 

• EEB feedback to the European Commission: “Opportunities and roadblocks in the proposal for a new EU regulation on vehicle design and end of life” (2023) 

• Joint statement by environmental organisations, the insurance sector, consumer organisations, the automotive aftermarket, and the repair community concerning repair and repair-related design aspects (2025) 

• Joint statement by glass producers, non-ferrous metal industry, and environmental organisations regarding measures to support the reuse of components and high-quality recycling of materials from end-of-life vehicles (2025) 

• Joint statement by environmental organisations, think tanks, and recycling industry to boost the use of recycled steel in the automotive sector (2025) 

• Joint statement by waste management and recycling industries, automotive suppliers, and environmental organisations in support of ambitious recycled content targets for plastics (2024)

About the EEB  

The European Environmental Bureau (EEB) is Europe’s largest network of environmental citizens’ organisations, standing for environmental justice, sustainable development, and participatory democracy. It represents over 185 members in over 41 countries. 

Website: www.eeb.org

About DUH 

Environmental Action Germany (Deutsche Umwelthilfe – DUH) is a recognized German environmental and consumer protection organization, which has been campaigning for resource conservation and consumer interests since 1975. DUH is politically independent, non-profit and it campaigns on a national and European level. It is renowned for its role in uncovering the Diesel Scandal and in establishing a deposit system for non-refillable beverage containers in Germany. Within its Department Circular Economy, DUH promotes waste prevention, responsible consumption, and a sustainable economy.  

Website: www.duh.de/englisch

About ECOS 

ECOS – Environmental Coalition on Standards is an international NGO with a network of members and experts advocating for environmentally friendly technical standards, policies, and laws. We ensure the environmental voice is heard when they are developed and drive change by providing expertise to policymakers and industry players, leading to the implementation of strong environmental principles.  

Website: www.ecostandard.org

Contact

If you have questions, please contact:

Alison Grace
Senior Press & Communications Manager at ECOS
alison.grace@ecostandard.org
+32 493 19 22 59

ECOS – Environmental Coalition on Standards is an international NGO with a network of members and experts advocating for environmentally friendly technical standards, policies, and laws.