The German Recycling and Waste Management Association (bvse) considers the European Parliament's position on the ELVR to be problematic.

According to the bvse Federal Association for Secondary Raw Materials and Waste Management, the amendments to the EU End-of-Life Vehicles Regulation (ELVR) proposed by the Parliament threaten to significantly undermine the Commission's original goals of strengthening the circular economy in the automotive sector. ‘Instead of really promoting the circular economy, there is a risk that important goals will be watered down,’ warns bvse CEO Eric Rehbock. ‘Recycling rates are being lowered, definitions broadened and key control mechanisms watered down. This significantly weakens the incentives to actually return post-consumer plastics from end-of-life vehicles to the cycle.’
 
The bvse is particularly critical of the reduction in the recycled content quotas for plastics and the possibility of fulfilling half of these quotas with production waste. Production waste was technically easier to recycle and readily available on the market, while post-consumer plastics from end-of-life vehicles remained difficult to market. If manufacturers can meet the quotas with production waste, there will be no pressure to design vehicles for recycling and to recycle post-consumer materials, according to the association. This would defeat the actual purpose of the directive. In addition, the bvse is calling for the inclusion of a so-called mirror clause to prevent distortions of competition: Recyclates from third countries should only be counted towards the quota if they are subject to the same requirements and verification obligations as within the EU. The association considers voluntary self-declarations or non-binding commitments to be insufficient. Only through independent testing and defined audits in accordance with European standards can fraud and market distortion be prevented.
 
The bvse also sees a need for improvement in the area of extended producer responsibility. On the one hand, the bvse believes that car recyclers should receive financial compensation for the legally required dismantling of vehicle parts even without contracts with car manufacturers. In addition, the association is calling for equal co-determination of the recycling industry in the structures of the manufacturer organisations envisaged by Parliament. Another key concern of the bvse is the traceability of end-of-life vehicles, for which the association is calling for stricter requirements than those envisaged by Parliament.
 
The bvse considers the European Parliament's proposals to be generally unsuitable for promoting a sustainable circular economy in the automotive sector and calls on legislators not to water down the European Commission's original requirements. ‘Only if manufacturers are consistently obliged to use post-consumer recyclates in new vehicles and market conditions are fair can the End-of-Life Vehicles Regulation contribute to a functioning circular economy,’ said Rehbock.
 
Sources:

• bvse press release (16.9.2025)
• Photo: © Documerica / Unsplash (Symbolbild)