Mediaroom

CLEPA has published a new position paper addressing the proposed End-of-life Vehicle Regulation (ELVR), a significant legislation for the automotive supply industry. This regulation is set to advance a circular economy and support decarbonisation efforts. While CLEPA supports the Commission’s aim to expand the scope of the ELVR, we recommend clarifying certain drafted articles to provide businesses with greater certainty and ensure seamless implementation of the legislation. Additionally, harmonising ELVR with other applicable policies, such as the Critical Raw Materials Act (CRMA), Batteries Regulation, Waste Framework Directive, and other environmental and chemicals legislation, will be essential for the industry.

The position paper provides a comprehensive overview of challenges and offers key recommendations from the European automotive supply industry. It outlines our priorities for the proposal, currently under discussion within the European institutions:

• Technology-neutral recycled content targets: Achievable and aligned with the EU’s decarbonisation goals, these targets are an effective circularity measure. To ensure the production of newly type-approved vehicles, the Commission should assess the availability of recycled plastics after the adoption of the Regulation to determine the necessity of a more flexible approach to the origin of secondary plastic feedstock.
• Harmonised calculation methodology for recycled content: We urgently call for EU-harmonised rules for calculating and verifying chemically recycled content using chain of custody (e.g. mass balance approach).
• Addressing legacy substances: ELVR must tackle the issue of accumulated legacy substances, aligning with other relevant automotive substance legislation.
• Streamlined information requirements: Clear reporting thresholds and requirements are essential for effective compliance.
• Acknowledging the role of remanufacturing: The regulation should better recognise remanufacturing and its operators. We recommend adopting the industry-agreed definition of “Remanufacturing” and defining the different activities during the treatment process separately in Article 3.
• Removal of parts for reuse or remanufacturing: This process should remain driven by market demand and ecological feasibility.