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EU’s New End-of-Life Vehicles Regulation Extends Circularity Rules From Vehicle Design to Recycling

The EU’s new End-of-Life Vehicles Regulation (Regulation (EU) 2026/1738) moves automotive circularity beyond the scrapyard and into vehicle design, manufacturing, and supply-chain management. With phased requirements beginning in 2028, companies must prepare for recycled-content targets, digital vehicle passports, expanded producer responsibility, and tighter export controls.

7 min readN. Nguyen
unsplash image arMJkQaY1Fk

The directly applicable EU Regulation introduces phased requirements for recycled content, vehicle design, producer responsibility, digital documentation, material recovery and used-vehicle exports.

- The European Union (EU) has adopted a new End-of-Life Vehicles Regulation that will reshape how vehicles are designed, manufactured, documented and treated after they leave the road.

Regulation (EU) 2026/1738 entered into force on 13 August 2026. Most provisions will apply from 1 September 2028, when the new framework begins replacing the End-of-Life Vehicles Directive and the Reusability, Recyclability and Recoverability (3R) Type-Approval Directive. Major requirements will then phase in through 2036.

The distinction between entry into force and application is important. The Regulation is now part of EU law, but the existing directives continue to apply during the transition through August 2028. Companies must therefore maintain compliance with current requirements while preparing for the new system.

The Regulation responds to substantial gaps in the management of end-of-life vehicles (ELVs). According to the European Commission, between 10 million and 12 million vehicles reach the end of their lives in Europe annually, but only about 6 million to 7 million are reported as being treated.

The new framework seeks to retain more materials within the European economy, improve the quality of recovered resources and prevent ELVs from leaving the EU under the label of used vehicles.

“The new End-of-Life Vehicles Regulation sets a new European standard for how vehicles should be designed, produced, and recovered,” said Jessika Roswall, European Commissioner for Environment, Water Resilience, and a Competitive Circular Economy.

From waste treatment to lifecycle regulation

The current End-of-Life Vehicles Directive already establishes EU requirements concerning vehicle collection and environmentally sound treatment. It restricts certain hazardous substances and sets targets for reuse, recycling, and recovery.

The separate 3R Type-Approval Directive already addresses the reusability, recyclability, and recoverability of new vehicles as a condition of EU market access.

The new Regulation consolidates and modernizes those regimes. It retains their existing foundations but reaches considerably further into vehicle design, manufacturing, supplier information, recycled-material use, component removal, digital traceability, and producer financing.

New vehicles will have to be designed to facilitate dismantling, repair, reuse, recycling and recovery. Manufacturers will also have to provide information supporting the removal and replacement of components during a vehicle’s useful life and its treatment at end of life.

The obligations primarily fall on manufacturers, but their effects will extend through the automotive value chain. Component suppliers will be asked for more detailed material data; dismantlers will need usable component-removal information; and recyclers will be expected to recover higher-quality secondary raw materials.

Mandatory recycled-plastic content

The Regulation introduces mandatory recycled plastic content for new vehicles:

  • At least 15% from September 2032; and

  • At least 25% from September 2036.

A portion of that recycled plastic must come from ELVs, supporting a closed-loop market in which material recovered from vehicles returns to automotive production.

The rules include a mirror-clause concept for imported recycled material. As reported by Recycling International, qualifying material imported from outside the EU will have to be treated under conditions equivalent to European requirements.

Those final requirements differ from figures considered during the legislative negotiations. PlasticsToday reported an earlier European Parliament position involving a 20% overall target and a 15% share derived from ELVs. The adopted Regulation instead establishes the phased 15% and 25% minimums.

The Regulation also establishes a framework for recycled-content requirements for steel and aluminium. European Commission-established targets are expected to apply from September 2033.

Stronger recovery and treatment requirements

New treatment requirements will begin applying in September 2029. The rules address manual and mechanical treatment intended to improve the recovery of steel, aluminum, copper, and rare-earth elements.

Priority components and materials will need to be identified before vehicles are shredded. Manufacturers must provide technical information supporting component removal and high-quality material recovery.

The Regulation also reinforces the role of authorized treatment facilities (ATFs). These facilities issue certificates of destruction and perform essential traceability, depollution, and treatment functions.

Digital reporting will become more prominent through electronic certificates of destruction, electronic recordkeeping, and information exchange among national authorities.

Digital Circularity Vehicle Passport

A Digital Circularity Vehicle Passport (DCVP) is expected to become mandatory in 2032.

As described by Circularise, the DCVP will serve as an access point for information needed by manufacturers, repairers, dismantlers, recyclers, and regulators. It will contain or link to repair and dismantling instructions, recycled-content declarations, hazardous-substance information, spare-parts data, and directions for removing and replacing components.

The DCVP turns supplier information into a central compliance requirement. Manufacturers will need traceable material and component data from multiple tiers of their supply chains rather than relying solely on finished-vehicle records.

Expanded producer responsibility

The Regulation strengthens extended producer responsibility (EPR) by requiring producers to contribute to the cost of collecting and treating the vehicles they place on the market.

The approach is intended to ensure that treatment systems are properly financed while creating an economic incentive for manufacturers to design vehicles that are easier to repair, dismantle, and recycle.

Waste-management operators will also have an observer role in the governance of producer responsibility organizations, according to Auto Recycling World.

More vehicles and tighter export controls

The Regulation will expand to additional vehicle categories—including motorcycles, lorries, buses and trailers—from September 2031.

Roadworthiness requirements for exported used vehicles will also apply from September 2031. Only roadworthy vehicles may be exported outside the EU, helping authorities distinguish legitimate second-hand vehicles from ELVs being exported as products.

The export rules could have effects beyond Europe because automotive manufacturing, vehicle resale and recycled-material markets operate through global supply chains.

“Global vehicle platforms and global material supply chains mean global impact,” Recycled Materials Association (ReMA) President Robin Wiener said.

Industry welcomes direction but watches implementation closely

Recycling organizations broadly support stronger recycled-content requirements, improved traceability, and tighter export controls. However, they warn that secondary legislation and market conditions will determine whether the Regulation produces viable circular-material markets.

The European Waste Management Association (FEAD) welcomed the limitation of qualifying recycled content to post-consumer plastic waste, arguing that it will support actual collection, sorting, and recycling.

Recycling Europe has called for reliable demand signals that justify investment in sorting and recycling capacity. The Spanish Federation for Recovery and Recycling (FER), meanwhile, has warned that prescriptive dismantling and metal-separation requirements could impose substantial costs on treatment facilities without proportionate environmental benefits.

Meanwhile, the European Environmental Bureau (EEB) and Environmental Action Germany (Deutsche Umwelthilfe or DUH) welcomed the Regulation’s circularity tools but argued that lawmakers weakened important provisions. Their concerns include recycled-plastic ambition, producer responsibility for exported vehicles, and the Regulation’s failure to confront rising material consumption associated with larger vehicles.

Key compliance dates

Date Regulatory milestone
13 August 2026 Regulation entered into force.
1 September 2028 Regulation generally begins to apply; the existing End-of-Life Vehicles and Reusability, Recyclability and Recoverability Type-Approval Directives apply until then.
September 2029 New vehicle-treatment requirements begin.
September 2031 The Regulation expands to motorcycles, lorries, buses and trailers.
September 2031 Roadworthiness requirements begin for exported used vehicles.
September 2032 A minimum of 15% recycled-plastic content applies to new vehicles.
2032 The Digital Circularity Vehicle Passport and related design and information requirements are expected.
September 2033 European Commission-established recycled-content requirements for steel and aluminium are expected.
September 2036 Minimum recycled-plastic content rises to 25%.

Although the principal dates extend into the next decade, manufacturers cannot wait for the final deadlines. Vehicle-development cycles, supplier qualification, recycling-capacity investments and digital-data systems all require years of preparation.

The Regulation’s central change is therefore not any single percentage or deadline. It is the decision to make vehicle circularity a shared obligation extending from the design office to the dismantling facility—and across every company supplying the system in between.

Jurisdictions

  • EU
  • Europe

Topics

  • End of Life
  • Vehicles
  • Motorcycles
  • Automobiles
  • Cars
  • EPR
  • Recycling
  • Digital Product Passport
  • Recycle content
  • Post consumer recycled content (PCR)
  • Plastics
  • Circular economy
  • Chemical restrictions

Tags

  • End of Life
  • Vehicles
  • Motorcycles
  • Automobiles
  • Cars
  • EPR
  • Recycling
  • Digital Product Passport
  • Recycle content
  • Post consumer recycled content (PCR)
  • Plastics
  • Circular economy
  • Chemical restrictions

Regulatory Status

Final rules