EVENT HIGHLIGHTS

End-of-life management and new vehicles design rules as a performance test for the EU circular economy model (April 9)

Speakers: Nicklas Mark, Saudargas Paulius, Matthieu Sara, Blackert Christian, Becker Thomas
Moderator: Bolongaro Kait

On the 9th of April 2025, PubAffairs Bruxelles organised an afternoon of discussion on the end-of-life management and new vehicles design rules as a performance test for the EU circular economy model. The event was also a timely opportunity to discuss the challenges ahead in enhancing the competitiveness of an innovative and resource-efficient European economy, with our distinguished speakers Mark Nicklas, Head of Unit, Mobility, European Commission, DG GROW; Paulius Saudargas MEP (EPP/LT), Rapporteur – Circularity requirements for vehicle design and management of end-of-life vehicles; Sara Matthieu MEP (Greens/BE), Shadow Rapporteur – Circularity requirements for vehicle design and management of end-of-life vehicles and Christian Blackert, COO, TSR Resource. Thomas Becker, Head of Sustainability & Mobility, BMW gave an introductory speech and participated in the panel.

The debate was moderated by Kait Bolongaro, Managing Editor, MLex.

Kait Bolongaro, opened the event by welcoming the audience and introducing the debate’s theme. She emphasised that the automotive sector is a key area for advancing sustainability and resource efficiency within the EU, noting that there are over 280 million vehicles on Europe’s roads and millions are scrapped each year. Kait Bolongaro highlighted that the strategy developed for vehicle recycling could also serve as a blueprint for shaping the circularity of the EU economy as a whole.

She then introduced the panellists and invited Thomas Becker to deliver a keynote speech to set the stage for the panel discussion.

Thomas Becker began his keynote speech by explaining why circularity will matter more to BMW in the future than it has in the past by focusing on the carbon impact of car production and use. He illustrated that, during the era of internal combustion engine vehicles, 24% of a car’s overall carbon emissions over its lifecycle occurred during procurement and production, followed by logistics (2.1%), the group’s production activities (0.9%), road fuel combustion (71.4%) and reuse (1.2%).

Dr Becker subsequently pointed out that the shift towards electric vehicles implies that the supply chain will become the dominant source of emissions, accounting for around 60% of the total carbon footprint before the vehicle is even driven.  He then explained the composition of the carbon footprint of an electric vehicle at the time of sale, highlighting that the largest contributors are the HV battery (39%), aluminium (26%), steel (19%), polymers (8%), other plastics (4%) and electronics (2%). To reduce this footprint, Thomas Becker suggested two main strategies: replacing “grey energy” with renewable energy (e.g., using green electricity and improving steel manufacturing processes) and increasing the proportion of recycled materials, for example, by using 70% recycled aluminium in wheels as it could significantly reduce the overall carbon impact, regardless of the material’s origin.

The speaker also emphasised that managing this process is challenging due to competition among different material groups and the need to balance energy transition efforts with recycling. He highlighted the importance of continuously evaluating where the greatest CO₂ reductions per Euro spent can be achieved in the supply chain and specified that, in recent years, there has been a remarkable degree of innovation across all material categories and, in parallel, energy use and recycling techniques have also improved.

To harness these benefits, BMW has prioritised the use of secondary materials, where feasible, as long as they meet the technical industry standards. He also showcased BMW’s 2021 concept car, which demonstrated that producing a vehicle made entirely from recycled materials is possible from a purely technical perspective, although, at scale, it would remain extremely expensive and production volume would be very limited due to limited recycled material availability, quality and cost. The speaker also explained that certain recycled materials, such as steel contaminated with copper, can cause corrosion, and recycled plastics are easier to use where safety and performance requirements are less stringent. In addition, he remarked that for critical safety components, higher standards of technical quality are necessary.

Dr Becker also addressed the rise in the complexity of vehicle’s materials over the past 20 years, driven prevalently by weight reduction efforts to improve in-use efficiency. This process, he added, has led to more complex material combinations and connection technologies that do not favour recycling practices. He also called for a shift toward mono-material designs and rethinking these complexities to improve recyclability and reduce vehicles’ carbon footprint in the future. Whilst such a transition will take many years, Thomas Becker expressed his confidence that BMW will play a significant role in making disassembly easier, cheaper and faster.

He concluded by showcasing BMW’s pilot recycling facility in Munich, one of the largest in Germany, notably capable of processing 10,000 vehicles annually, well above the national average. He also clarified that recycling methods include using mechanical tools and advanced shredding technologies.

Finally, Thomas Becker highlighted the importance of competition and innovation in recycling technologies, including automated systems versus shredder-based methods, as key drivers toward improving material quality and sustainability.

The moderator thanked Thomas Becker for his keynote speech and kicked off the panel discussion by asking Mark Nicklas about the key legislative initiatives the European Commission plans to propose to advance the circular economy in the EU. She also inquired about the expected timeline for elaborating and presenting the Circular Economy Act.

Mark Nicklas began his response by explaining that, within the framework of the Clean Industrial Deal, the European Commission aims to make industrial production more sustainable, while reducing carbon emissions and enhancing supply security. He emphasised the importance of securing access to materials and resources to avoid dependencies on secondary raw materials.

Mr Nicklas then stated that the EU has been a leader in circularity and highlighted recent regulatory steps, such as the Ecodesign for Sustainable Products Regulation (ESPR), which is already in force and will be followed by a dedicated work plan. Sector-specific rules are expected to come into effect in 2026, he added, along with the Circular Economy Act, also scheduled for 2026. To accelerate the transition, the European Commission plans to hold a Clean Industrial Dialogue on circularity with relevant stakeholders, he clarified. He added that this dialogue will focus on fostering a well-functioning internal market by ensuring the free movement of secondary materials and circular products, as well as establishing harmonised end-of-waste criteria to address fragmentation issues within the EU.

Using the example of battery recycling, Mr Nicklas highlighted the significance of black mass, namely a shredded and processed mixture of materials obtained from recycled lithium-ion batteries. He pointed out that it has been easier to ship black mass from Europe to Asia than across EU member states. Due to safety concerns, he stated, the European Commission has banned its export to non-OECD countries. Conversely, Mr Nicklas stressed the need to remove barriers within the EU’s single market for end-of-life products and secondary raw materials. In this connection, he noted that the European Commission introduced the Automotive Action Plan in March 2025, which aims at speeding up the process of recycling end-of-life vehicles.

The moderator then turned to Paulius Saudargas MEP to ask what circularity requirements were being introduced for vehicle design and manufacturing, and how these were expected to contribute to the EU’s circular economy model.

Paulius Saudargas MEP responded by outlining the relevant provisions emerging from the legislative proposal on circularity requirements for vehicle design and the management of end-of-life vehicles, for which he is serving as Rapporteur. He explained that Article 4 sets out the criteria to regulate the reusability, recyclability and recoverability of vehicles. For example, every new vehicle would be required to be designed and manufactured so as to be reusable or recoverable to a minimum of 90%, and recyclable to a minimum of 85%.

Turning to targets for minimum recycled content in vehicles, MEP Saudargas explained that, under Article 6, at least 20% of the plastic used in each new vehicle should consist of recovered plastic content, sourced from, among others, pre- and post-consumer plastic waste. In addition, approximately 15% of this target would need to be met using post-consumer plastic waste recycled from end-of-life vehicles.

He went on by explaining that paragraph 3 of the same article empowers the European Commission to adopt delegated acts establishing the minimum share of recycled steel required in vehicles, as well as minimum recycled content requirements for aluminium, magnesium, and other materials derived from post-consumer waste to be incorporated into type-approved vehicles.

MEP Saudargas also referred to Article 7, which stipulates that each vehicle belonging to a new type should be designed in a manner that does not hinder the removal of parts and components, as listed in Part C of Annex VII, by authorised treatment facilities. Furthermore, vehicle manufacturers should develop a circularity strategy outlining the actions they would take to comply with their obligations and ensure the circularity requirements are fulfilled.

For new vehicle types, approved manufacturers would also be required to provide waste management, repair, and maintenance operators with unrestricted, standardised, and non-discriminatory access to the necessary information. MEP Saudargas emphasised that such a measure would facilitate access to, and the safe removal and replacement of, various vehicle parts. He concluded by stating that the draft report also proposes that each new vehicle type should be accompanied by a circularity vehicle passport.

The moderator then moved on to ask Sara Matthieu MEP why the automotive sector was particularly relevant for testing the EU’s circular economy ambitions, and where she identified any gaps in the ongoing legislative proposal.

Sara Matthieu MEP responded that the car industry was one of the main end-users of intermediate products such as plastics, aluminium and steel, making it essential for achieving the EU’s circular economy objectives. She also noted that circularity is a fundamental pillar of the European Green Deal.

Turning to the gaps in the current proposal, she referenced the Clean Industrial Deal and the European Commission’s initiatives concerning the automotive, steel and metals sectors, all of which highlight the importance of increasing the use of secondary materials and spare parts. These measures, she explained, are vital for reducing pressure on natural resources and mitigating climate impacts.

However, MEP Matthieu also highlighted the geopolitical dimension of the issue, mentioning the potential for a trade war between the EU and the US and the vulnerabilities of the EU’s supply chains. In this context, she stressed the urgency of enhancing Europe’s strategic autonomy, especially for the benefit of the European economy and households.

Based on these considerations, she argued that the proposed legislation could serve as a foundational milestone in the EU’s newly updated industrial vision. At the same time, she expressed concern over the recycled content targets set by the European Commission, suggesting that weakening or removing them would be a significant misstep. She cited, for example, the low incorporation of scrap metals into car manufacturing, currently at only 6%, as a reason why higher targets for steel and aluminium are needed.

MEP Matthieu also emphasised the need to improve collection systems, simplify material sorting and create lead markets for high-quality secondary materials. She also referenced an event hosted earlier that day by Lena Schilling MEP, featuring two reports on steel recycling and end-of-life vehicles. In this regard, she remarked that one study by the Öko-Institut found that the EU could reach 25% steel recycling by 2030 and 30% by 2035, which would stimulate demand for, and investment in, recycled steel of high quality. MEP Matthieu advocated for the inclusion of a realistic-but-ambitious recycled steel target in the draft legislation, to be scaled up once the results of the European Commission’s impact assessment become available.

Given the rising demand for critical raw materials in the automotive sector, the moderator asked Thomas Becker the reasons behind this trend and how BMW was preparing its vehicle design and resource strategies in response.

Thomas Becker explained that the circular economy model, beyond its function of reducing carbon emissions, is crucial for minimising the environmental impact of raw material extraction, particularly on biodiversity and for reducing exposure to various supply chain risks, including the conditions of material sourcing and geopolitical dependencies. From his perspective, there is no safer strategy than to embrace circularity from the outset and this is the reason why the BMW Group had developed a multi-layered approach to achieving this objective. However, he also acknowledged that the situation differs depending on the type of material. In the case of plastics, he noted that there is more plastic waste than needed and that it is difficult to process it in a way that guarantees consistent quality standards.

By contrast, for battery materials, he noted that recycling efficiencies of 90–100% are technically possible, but the lack of feedstock, due to the limited number of end-of-life electric vehicles, will remain a challenge. He also stated that aluminium occupies a sort of middle ground as it has an established market and significant economic value, while notable quality constraints still need to be addressed. Dr Becker also expressed confidence that high-quality recycling levels could be achieved for aluminium.

He also reflected on the challenges around steel recycling, emphasising that the issue extended beyond the car industry and pointed out the sector’s vertical perspective, which focuses narrowly on end-products and their treatment. Instead, he advocated for a horizontal approach, which involves analysing material flows, defining minimum performance standards for recycled material classes and setting corresponding expectations for recycling facility operators.

Given that 6.5 million vehicles are scrapped annually in Europe, Kait Bolongaro asked Christian Blackert what happens to these material flows and how efficient the system is at capturing value from end-of-life vehicles (ELVs).

Christian Blackert responded that, from the recycling industry’s perspective, there remains significant room for improvement in the current economic system managing ELVs. Over the past three years, TSR has made significant investments and developed new recycling technologies. One example is a facility that processes post-consumer materials such as end-of-life vehicles into high-quality recycled steel raw materials. Thanks to a copper content of less than 0.1%, these materials can be reused in the production of new vehicles, while maintaining consistently high quality.

He explained that TSR has implemented a similar approach for aluminium, separating aluminium fractions and applying specialised recycling processes to avoid downcycling. Furthermore, he added that using these technologies allows up to 86% of recycled post-consumer aluminium to be used in the production of aluminium body panels for cars.

Mr Blackert agreed with Thomas Becker on the need to develop standardised and professionalised systems across the entire supply chain. He also stressed that an excessive number of vehicles at the end of their life cycle are currently being lost across Europe, representing a major missed opportunity. In his view, to strengthen Europe’s resilience, especially as the Old Continent lacks natural resources, it is vital to maximise the use of end-of-life materials.

He also highlighted that TSR currently operates a three-tier network of 100 plants across Europe and is prepared to expand this infrastructure to increase material supply for the automotive sector. The company also plans to take similar steps for aluminium and plastics, despite the associated high investment costs, he stated. He added that, if sufficient market demand were established for quality standards in recycling, for example, for minimum recycled content requirements for steel, this would be beneficial for the entire supply chain. Kait Bolongaro opened a second round of the panel discussion by asking Mark Nicklas what, from a regulatory perspective, was the primary objective of the proposed regulation on the vehicle life cycle, and how it differed from previous policy instruments in this area.

Mark Nicklas explained that the primary aim of the proposed regulation was to enhance circularity within the automotive value chain in order to support decarbonisation, improve the resilience of supply chains and foster innovation. He stated that the regulation builds upon two existing directives: the 3R Type Approval Directive which tackles the reusability, recyclability and recoverability of motor vehicles and the End-of-Life Vehicles Directive.

The new proposal seeks to consolidate these frameworks into a single regulation that applies a value-chain approach, starting from the legal design phase of vehicles. This includes specific attention to the removability of batteries, electric motors and critical raw materials, which are often lost if not designed for easy disassembly.

Mr Nicklas highlighted a second key dimension: recycled content in vehicle design. He pointed out that the automotive industry is the largest consumer of aluminium and the second-largest consumer of steel in the EU. While the European Commission has not yet completed its impact assessment for these two materials, he assured the audience that work was being accelerated to set recycled steel content targets.

On the recycling side, he acknowledged that although a large volume of materials is currently being recycled, the quality of those materials remains insufficient for use in vehicle manufacturing. This is the reason why the Commission continues to advocate a value-chain perspective, which is essential to promote the production of high-quality recycled materials that meet industry standards.

Another crucial issue addressed in the regulation is the problem of missing vehicles, estimated at nearly 3 million per year. These vehicles do not reach authorised treatment facilities, and instead are either exported to third countries or end up in unauthorised facilities, leading to significant losses of valuable materials for the European economy.

In conclusion, Mr Nicklas emphasised that a major difference between the proposed regulation and the existing legislative instruments lies in the shift from directives to a regulation. This change aims to avoid fragmentation in the application of rules across Member States, as previously seen under the directive-based framework. The regulation is therefore designed to ensure a harmonised, single-market approach, enhancing the freedom of movement and alignment of circularity criteria across the EU.

The moderator then turned to Sara Matthieu MEP to ask which challenges needed to be addressed to ensure that recycled materials could be effectively used in the production of new vehicles, particularly in light of evolving legislation on chemical usage.

In response, Sara Matthieu MEP reiterated the importance of ensuring the high quality of recycled materials. With regard to high-grade steel, she emphasised the need to avoid copper contamination, noting that this affects not only the quality of the steel but also the value of the copper itself, as approximately 5 to 8 kilograms of copper per vehicle are currently being lost. To address this, she called for mandatory dismantling of copper-rich components, alongside the adoption of the most advanced sorting technologies.

She then turned to the issue of chemicals, referencing an ongoing debate about whether the REACH Regulation should address the chemical substances in vehicles, or whether a separate list of substances of concern should be established for the European Commission to monitor. MEP Matthieu pointed out that, since the adoption of the original End-of-Life Vehicles (ELV) Directive in the 1990s, the EU had not imposed any additional bans on hazardous substances in vehicles.

In this connection, she proposed that a targeted list of chemicals, relevant to the automotive sector, could be introduced in a similar manner to that used in the Batteries Regulation. This shift, she argued, would be more effective than relying solely on REACH, which she described as a valuable but slow-moving instrument, often too broad in scope to act in a timely and product-specific manner.

Finally, MEP Matthieu stressed the need to avoid exemptions for specific components and spare parts, in order to eliminate toxic substances from the vehicle lifecycle entirely and avoid placing further burdens on the recycling industry.

The moderator asked Paulius Saudargas MEP for his views on the advantages and disadvantages of introducing sector-specific recycled content targets in the automotive industry.

In response, Paulius Saudargas MEP stated that such targets would bring clear environmental benefits, notably by encouraging the use of post-consumer materials, reducing waste and pollution and lowering carbon emissions. He argued that these measures would support greater circularity within the automotive supply chain, contribute to the efficient use of energy, and reduce dependency on raw materials, such as petroleum for plastics.

He further noted that the introduction of these targets would incentivise manufacturers to innovate and invest in end-of-life vehicle (ELV) recycling technologies. In doing so, companies could also enhance their reputation, particularly among environmentally conscious consumers, by demonstrating corporate environmental responsibility.

MEP Saudargas also highlighted the potential geopolitical dimension of such targets, framing them as a strategic response to challenges such as US trade tariffs and China’s increasing presence in the European market. He suggested that EU manufacturers, already aligned with high environmental standards and ahead in implementing circular practices, could gain a competitive advantage and strengthen the EU’s position in global markets.

However, he also acknowledged several technical and economic challenges. One concern he expressed related to recycled content that may not always meet the necessary quality or safety standards, particularly for structural or safety-critical components. For example, recycled steel may fall short of the stringent requirements for use in engine parts or chassis, he stated.

Regarding recycled plastics, MEP Saudargas raised the issue of material degradation. Recycled plastics often originate from end-of-life products and undergo reprocessing, which can further degrade the material’s properties. He noted that aged or reprocessed plastics may fail to meet performance requirements, especially for heat-exposed or load-bearing parts, due to the shortening of polymer chains and risk of contamination with each recycling cycle. He added that the presence of mixed polymers in waste streams can lead to incompatibility issues, posing further risks. He also cited painted parts, such as bumpers, as problematic, since paint removal remains a technical obstacle in the recycling process.

On the premise that modern vehicles increasingly use composite plastics, the moderator asked Thomas Becker how such material choices affect recyclability, circularity, and vehicle design.

Thomas Becker responded that this trend, along with the challenges it presents, had led the BMW Group to recalibrate its approach, balancing the carbon impact of the supply chain, the consequences for recyclability and the overall carbon footprint. He noted that this had resulted in different outcomes compared to decisions that might have been made a decade earlier.

Addressing the issue of dismantling, he introduced the concept of a “carbon core”, referring to structurally integral vehicle parts that cannot be dismantled. This process, he argued, is behind BMW concerns about some of the proposed dismantling requirements. While supportive of dismantling where feasible, the speaker maintained that shredding technologies should be recognised as a legitimate and acceptable alternative in such cases.

Turning to plastics, Dr Becker stated that, from a carbon emissions perspective, BMW would not aim to meet the recycling quotas currently proposed. He questioned the necessity for detailed sub-quotas, such as those specifying shares of post-consumer and post-consumer automotive plastics, suggesting that a more flexible approach would be preferable.

In his view, regulatory focus should be on the environmental impact delivered by the material, rather than rigid quota categories. He therefore advocated for a framework that allows for greater flexibility, competition and choice among recycling pathways, as these would better support innovation and more effective carbon reduction in the final EU regulatory design.

The moderator asked Christian Blackert whether more thorough dismantling and dedicated automotive recycling could significantly improve the quality of secondary raw materials.

Christian Blackert responded with an example from TSR’s recent activities, highlighting the company’s acquisition in 2024 of LRP, one of Germany’s largest authorised treatment facilities (ATFs) for car dismantling. Together, he explained, TSR and LRP are developing a high-functioning dismantling system in which end-of-life vehicles undergo a largely mechanical recycling process. Additionally, while acknowledging that certain components, such as fuel tanks, may require manual dismantling, he emphasised the need to scale up mechanical processing to increase the recycling efficiency and material quality.

The moderator then invited Mark Nicklas to explain how circular economy policies could enhance transparency and optimise recycling processes without disrupting existing market structures.

Mark Nicklas outlined two critical dimensions from a policy-making perspective: first, high-quality recycling requires clearer separation of components within waste streams. For example, if electronic components cannot be removed, they cannot be recycled, meaning critical raw materials are lost. Secondly, he underscored the importance of designing vehicles with recyclability in mind, including thoughtful material choices that facilitate downstream processing. These considerations, he argued, are essential to ensuring system-wide circularity.

Turning to the issue of vehicle exports, the moderator asked Paulius Saudargas MEP what measures were being considered to regulate the export of used and end-of-life vehicles (ELVs) from the EU to third countries.

Paulius Saudargas MEP confirmed that missing vehicles, many of which are suspected to be illegally exported to unauthorised facilities or “grey zones”, represent a major challenge. The proposed regulation aims to address this by introducing clear distinctions between used and end-of-life vehicles. Indeed, he noted, according to Article 37, vehicle owners must declare whether a vehicle qualifies as end-of-life when transferring ownership, whereas Article 38 stipulates that exports of used vehicles are permitted only if they are roadworthy and do not qualify as ELVs, based on criteria in Annex I.

MEP Saudargas also argued that end-of-life vehicles should not be exported to third countries. He also emphasised the need for harmonised roadworthiness criteria across EU Member States, to prevent countries with less stringent standards from becoming export loopholes, thereby undermining the single market.

Continuing on the theme of recyclability and circularity, the moderator asked Sara Matthieu MEP to identify any additional circularity strategies that could bolster Europe’s economy, resilience and competitiveness.

Sara Matthieu MEP stressed that circularity is not solely about closing material loops, but also about extending the lifespan of European products and raw materials. She justified her amendments to the regulation to support repairability, aligning with long-term environmental and economic objectives. However, she also warned that technological evolution is making repair increasingly difficult. Modern vehicle designs often hinder dismantling, spare parts are less available, and electronic components dominate, factors that collectively reduce repairability compared to the past.

She also criticised strategies by non-European manufacturers that deliberately obstruct repair, thereby threatening the sustainability of the European automotive supply chain. To counter this, she advocated for regulations to extend spare parts availability, prevent design features that block disassembly or reuse, and mandate software update guarantees to ensure vehicle longevity and functionality. She further supported eco-modulation, extended producer responsibility (EPR) fees, and repairable battery designs.

To empower consumers, MEP Matthieu called for the creation of a vehicle repair index, which would clearly indicate which models are designed to last, enabling informed choices aligned with circularity principles.

The moderator asked Thomas Becker what responsibility the automotive sector bears in aligning its business model with the circular economy goals, and how EU policy could support innovation without compromising competitiveness.

Thomas Becker emphasised the importance of allowing for a choice between individual and collective recycling systems, referring to an ongoing discussion within the Council of the EU. He argued that business-led initiatives had already demonstrated their capacity to deliver tangible results in this area.

On the matter of quality and export restrictions, Dr Becker expressed his support for proposals to make car exports more restrictive, as part of broader circularity efforts. However, he also voiced concern over the level of prescriptiveness in the proposed regulation. Specifically, he called for greater flexibility in the minimum dismantling requirements, suggesting that a more adaptable framework would better support industry innovation.

He concluded by reaffirming the importance of advancing circularity and urged the automotive sector to scrutinise its own environmental footprint more closely. Ultimately, he asserted that the most relevant metric should be the amount of CO₂ emissions avoided, arguing that this should guide both sectoral efforts and the efficient use of consumer spending.

The moderator then turned to Christian Blackert to explore the practical challenges faced by the recycling industry in meeting the new circularity targets, particularly regarding chemical content and material traceability.

Christian Blackert replied that TSR did not foresee major obstacles, provided that several key conditions were met: strengthening the Certificate of Destruction (COD) system, preventing ELVs from leaving the single market, and setting clear quality requirements. He referenced TSR’s ongoing work in steel, aluminium and plastic recycling, and confirmed the company’s willingness to invest in further technological development.

At the same time, he emphasised that strong and consistent demand from the automotive industry was critical. TSR, he noted, was actively engaged in dialogues with industry stakeholders to jointly identify and overcome challenges. In conclusion, Blackert encouraged stakeholders to view the proposed ELV Directive as a strategic opportunity, not as a burden, for improving circularity across the sector.

As the final round of the panel discussion, the moderator asked each panellist what actions should be prioritised over the next twelve months to ensure the success of the proposed regulation in supporting Europe’s circular economy.

Thomas Becker highlighted the need to accelerate technology development, citing ongoing collaborations with universities such as Sciences Po in France and RWTH Aachen in Germany. These institutions are working alongside practitioners to devise innovative methods that can improve recycling quality and reduce costs, he specified. He also called for greater EU support for such initiatives to foster scalable improvements across the sector.

Building on this, Christian Blackert stressed the importance of constructing a more resilient circular ecosystem within Europe and strengthening the European recycling industry. For him, the coming year should mark a turning point in laying the infrastructure and industrial foundation necessary to meet the regulation’s goals.

Mark Nicklas expressed hope that, within this timeframe, the European Parliament and the Council would reach an agreement on the final text of the proposed regulation—one that maintains a high level of ambition while remaining practicable for implementation. Concurrently, he looked forward to witnessing on-the-ground innovation from both the automotive and recycling industries, paving the way for early adoption and compliance.

Sara Matthieu MEP also emphasised the importance of retaining the regulation’s ambition, arguing that this approach is in the EU’s strategic, environmental, and economic interest. She encouraged the automotive sector to view the regulation as an opportunity to strengthen its competitive edge over third-country manufacturers. Additionally, she suggested that the proposed regulation could serve as a protective instrument for European car makers, shielding them from unfair competition by promoting technological advancement and circular practices.

Wrapping up the panel discussion, Paulius Saudargas MEP affirmed his commitment, as co-rapporteur, to guiding the legislative file to success. He stressed the importance of engaging all relevant stakeholders, particularly those from across the automotive supply chain—from manufacturers to recyclers, including SMEs—to ensure the regulation is both effective and inclusive.

The Q&A session covered the following issues: possible courses of action for the EU to ensure recycled materials from cars meet quality standards for reuse; how would the European Commission ensure alignment between the Circular Economy Act and specific regulations for the automotive sector; the lessons to be drawn from the implementation gaps in previous circular economy initiatives, and how these should inform the new Circular Economy Act; the rationale behind the proposal to include carbon fiber among the harmful substances under Article 5(4) of the proposed regulation and, regarding recyclability, how to strike a balance between current low recyclability levels, future technology developments and the contribution to decarbonisation by loosening vehicles’ weight; ways to encourage the growth of the reused car components’ market from a consumer’s standpoint and the position of car manufacturers on the matter; possible proposals to establish the dismantling level of glass components in vehicles which account for a high level of ambition and for economic carefulness; the rationale behind the intention to lower the level of post-consumer waste in newly approved vehicles in the proposed regulation; the role which biobased plastics could play in the next European Commission’s legislative initiatives based on the European Parliament’s commitment in the field; possible ways for the European Commission to deal with complexity in technology developments for vehicle components and how it affects their recyclability; the issue of repairability of vehicles within the scope of the proposed regulation; the removal of components such as copper wires during dismantling and the implications for vehicles’ design.

Do you wish to know more about the issues discussed in this debate? Then check out the selected sources provided below!

European Commission, ‘Proposal for a Regulation of the European Parliament and of the Council on circularity requirements for vehicle design and on management of end-of-life vehicles’

European Commission, ‘Clean Industrial Deal’

European Commission, ‘Industrial Action Plan for the European automotive sector’

European Commission, ‘A European Steen and Metals Action Plan’

European Commission, ‘Circular economy’

European Commission, ‘REACH Regulation’

Eur-Lex, ‘Regulation (EU) 2024/1781 of the European Parliament and of the Council of 13 June 2024 establishing a framework for the setting of ecodesign requirements for sustainable products’ (Ecodesign for Sustainable Products Regulation)

Eur-Lex, ‘Directive 2005/64/EC of the European Parliament and of the Council of 26 October 2005 on the type-approval of motor vehicles with regard to their reusability, recyclability and recoverability’ (3R-type approval Directive)

European Commission JRC Publications Repository, ‘Towards recycled plastic content targets in new passenger cars and light commercial vehicles’

European Parliament ENVI-IMCO Committee Joint Draft Report on the proposal for a regulation of the European Parliament and of the Council on circularity requirements for vehicle design and on management of end-of-life vehicles’

European Parliament Legislative Observatory, ‘Circularity requirements for vehicle design and management of end-of-life vehicles’

Institut Mobilités en Transition, ‘CAR TO CAR STEEL – Potential of End-of-Life Vehicle deep-dismantling and use of  copper depolluted steel scrap to decarbonize automotive flat steel production’

Öko-Institut, ‘Boosting the use of recycled steel in the EU automotive industry under the ELV Regulation’

Sandbag, ‘Towards a minimum recycled steel content in passenger cars: setting an initial target’

International Council on Clean Transportation, Closing the loop: Improving automotive steel recycling for a circular economy