Highlights of ECOS recommendations on ELV Directive revision

Over the past years, several EU legal tools on products and waste have increasingly integrated considerations relating to ecodesign, toxic-free environment, sustainable sourcing of raw materials and optimised resource use. These should be better reflected in the European End-of-Life Vehicles (ELV) Directive and Directive on motor vehicle reusability, recyclability and recoverability – so-called 3R type-approval Directive.

As a follow-up of the European Stakeholder Workshop in the context of the impact assessment for the revision of these Directives, we have selected eight key highlights of ECOS recommendations for these reviews:

1. Single merged Regulation. A Regulation has the potential to set harmonised rules across the single market, reduces the risks of fragmented national implementation, and will apply to all vehicles placed on the EU market.
2. EU legislation coherence. Key definitions, such as recycling, reuse and remanufacturing should be aligned with the EU Waste Framework Directive and the new Battery Regulation. Requirements on removability should also support those developed in the Battery Regulation.
3. Reliable recycling rate calculation. The recycling rate is never 100% as there will always be process losses and some level of material quality degradation. The minimum technology readiness levels to be considered towards reuse/recycling targets should also be at demonstration stage.
4. Reduced carbon and environmental footprints. Vehicles should not only be designed and manufactured to optimise their performance, durability and safety, but also to minimise their carbon and environmental footprints.
5. Substance and technique prohibition. Substances that meet the CLP (‘Classification, Labelling and Packaging’) and SVHC (‘Substances of Very High Concern’) criteria under REACH should be banned, and information should be passed throughout the vehicle life cycle.
6. Mandatory and trustworthy recycled content targets. Recycled content targets should only concern post-consumer waste and be based on a proportional allocation of the recycled content through mechanical recycling, supported by strong third party certification.
7. Digital Vehicle Passport. The new European Vehicle Regulation should require cars to be placed on the market together with a digital vehicle passport to improve traceability across their value chain.
8. Minimum requirements for tyres. The new European Vehicle Regulation should also be coherent with the recent efforts to tackle microplastics coming from different sources, namely tyres.

Read all the highlights here.