POSITION PAPER
DECEMBER 2023

THE END-OF-LIFE OF VEHICLESREGULATION AND GFR COMPOSITE PARTS
An enabling framework to glass fibre reinforced (GFR) composite parts
reuse and recycling
Glass Fibre Europe, representing the continuous filament glass fibre manufacturing industry in Europe,
welcomes the European Commission proposal to review the End-of-Life of Vehicles Directive. To ourindustry, it stands clear that glass fibre reinforced (GFR) composites must be sustainable to be part ofour future. While the environmental benefits of GFR composites used in vehicles are incomparable, inparticular their contribution to the reduction of vehicles’ weight and emissions, progresses must be doneon their end-of-life treatment. In that respect, the European Commission proposal can be a gamechanger.
Our industry firmly supports the European Commission proposal and the new measures proposed thatwill push for the reuse of GFR composite parts and the deployment of recycling solutions; in particular,
the introduction of a specific target for plastics applicable to composites, the mandatory removal ofcertain automotive parts and the introduction of an Extended Producer Responsibility to ensure propercollection and treatment of the vehicles.
While the European Commission proposal correctly addresses major hurdles to the reuse andrecycling of end-of-life vehicles, we believe that the proposal can further promote these objectives
for the GFR composites parts. In particular, the Legislator could consider:
1. Extending the list of mandatory removal parts to cover additional GFR composites parts invehicles either for reuse or to avoid contamination for recycling. The proposal currently
covers only dashboards and printed circuit boards with a surface area larger than 10cm²,
while GFR composites are present in many more applications (see listing in the textbox, p.2).
2. Correcting the proposal with the updated information on recycling technologies available
today for composites.
3. Make the legislation future proof considering the recycling technologies under development
for GFR composite parts, in particular for close loop recycling.
4. Correcting a factual mistake in the European Commission proposal. The glass composition(soda lime silicate glass) of automotive glass (windshields, rear and side windows) is notcompatible with the continuous filament glass fibre standards (ASTM D578 for E-glass).
Therefore, the text should be adapted to incentivise automotive glass recycling into glass ofsimilar composition.

GFR composites in automotive parts
Glass fibres are used to reinforce plastics in automotive parts. Car manufacturers have increasingly
been using GFR composite parts to meet stringent new emissions regulations, improve the performanceof the cars, and offer electric vehicles. This is reflected in the significant growth of GFR composites intransport applications over the last decade. Based on a recent statistics report 1, the global composites
market in transportation has increased from 2.3 Mt in 2010 to 2.8 Mt in 2021, and it is expected tofurther increase to 3.7 Mt in 2027 and become the first market segment for composites in volumes.
These increased volumes call for an adaptation of the waste management schemes for the end-of-life
treatment of vehicles in Europe and set up of systems to dismantle, collect, reuse, repurpose andrecycle.
1 JEC, 2023, JEC Observer: Overview of the global composites market 2022-2027, January.

GFR composites can be found in a large number of vehicle parts (see text box, below). Innovations in
the glass fibre industry have made possible the development of a vast array of products offeringsignificant advantages in use, such as lightweighting, design flexibility, resistance to fire / chemicals /corrosion or changes in temperatures, soundproofing and durability.
One of the main features that makes glass fibre’s reinforcement a material of choice in the automotive
sector is its contribution to the reduction of the weight of the vehicle. This helps increasing theenergy efficiency in vehicles (fuel or electric) on the road and reducing emissions. Glass fibre is also
instrumental to the production and deployment of light-weight electric vehicles. In thisapplications area glass fibre is used for battery casing, to lower weight, while providing fire protection,
underbody protection and optimum temperature conditions within the battery. Glass fibres are alsopresent in thermoset plastic housings of electrical vehicle charging stations to make them robust.
The benefits of using GFR composites are well known from car manufacturers and the increasing
ambition for emissions reductions in the automotive sector has further incentivised their use. Eventually,an electric vehicle is a vehicle using more GFR composites.
Where can GFR composites be found in vehicles?
GFR composites are present in a large number of parts present in all vehicles or in parts which are
specific to combustion engine or electric vehicles: dashboard, front end, central arm rest, door
modules, headlamp reflector, hatchback, seat structures, frames, noise engine shielding parts, heatshields, pillars, headliners, airbag covers, roof frame, timing belt and V belt, rear shelves, sparewheel cover, PA air intake manifold, radiator caps, cylinder head (e.g. valve rocker, cam) covers,
clutch disks, brake pads, fuel tank locking cover, printed circuit boards, and battery casing and coverin electric vehicles.

Reuse and recycling of GFR automotive parts
GFR composites are long-lasting materials designed to be sustainable, and they can be further reused.
The durability of GFR composite parts makes these perfect candidates for reuse provided they
are properly collected and sorted before the car is shredded. GFR composites parts are alreadycollected and reuse to offer alternatives to new parts. However, these practices remain individual
initiatives by certain operators. These initiatives could be further encouraged provided that the GFR
composite parts suitable for reuse are clearly identified in the regulation, designs facilitating theirremoval are promoted and that their dismantling is made mandatory before shredding.
GFR composites parts can be reused, and they can be recycled. As highlighted in a recent reportby the Joint Research Centre 2 , several recycling technologies are mature and available for GFR
composites recycling – namely mechanical recycling, pyrolysis, and co-processing in cement. The glass
fibre industry is actively involved in projects to bring other technical solutions (recycling processes ortechnologies) to maturity. The Grail for the glass fibre industry is to achieve close loop recycling withrecycled glass fibres replacing virgin raw material in the batch. These solutions will also offer potential
synergies with the polymers industry (e.g. pyrolysis, gasification or solvolysis of polymers).
As well as for the reuse, the proper collection and sorting is a crucial step to recycling, not the least tolimit the contamination of the material. This step is particularly relevant for close-loop recycling solutions
which will be increasingly important in the future. The glass fibre manufacturing process is extremely
sensitive to variations in the composition of the batch and impurities should be strictly avoided to preventthe generation of glass waste in the installation.The Legislator can support the reuse and large-scale
deployment of recycling solutions by adapting its legislative framework to include material specifictargets, in particular for non-hazardous lightweight materials. Should the regulatory framework focus
remain on the total weight of vehicle objective only, the regulatory incentive will remain on the recyclingof heavy material only and an opportunity missed for the collection, sorting and reuse/recycling ofcomposites parts.
About Glass Fibre Europe – EU Transparency Register n°635608817518-09.
Glass Fibre Europe, founded in 1987, is the voice of the European continuous filament glass fibre industry. It is
composed of 8 companies: 3B the fibreglass company, Envalior, FYSOL SAS, Johns Manville, Nippon Electric
Glass, Owens Corning, Valmiera Glass, and Saint-Gobain Vetrotex. Glass Fibre Europe represents all the majorproducers of continuous filament glass fibre in Europe.

2 Joint Research Centre, 2023, Towards a better definition and calculation of recycling, JRC131531.

Glass Fibre Europe : The End-of-Life of Vehicles and GFR Composite Parts, December 2023.

Appendix: Recommendations for the End-of-Life of vehicles regulation
Proposed adaptations to the European Commission proposal
Glass Fibre Europe is willing to support the Legislator to contribute making the end-of-life of vehicles
regulatory framework conducive to Glass Fibre Reinforced (GFR) composites reuse or recycling.
While very positive on many aspects, the proposal made by the European Commission can befurther improved by making full use of the mandatory removal and Extended Producers
Responsibility (EPRs) requirements for GFR composites parts. In particular, the Legislator should
consider the following improvements to the proposal:
1.

2.

3.

4.

5.

6.

Keep GFR composites covered under the plastic definition (Article 3 (9)): The inclusionof GFR composites in the plastic definition is crucial to preserve the incentive to collect, sortand deploy recycling solutions for GFR composites. Regulation (EU) No 10/2011 could beconsidered for replacing the legal basis used for the plastic definition in the proposal,
considering that it includes the reference to additives or other substances (like GF) which
may have been added.
Further support the reuse of parts and components via the “Circularity Plans” (Annex
IV Part A and Part B): The waste hierarchy in the EU Waste Framework Directive shouldbe the guideline to the “Circularity Plans” and measures for waste prevention and preparing
for re-use further promoted. In particular, the “measures to address the challenges posedby the use of certain materials and techniques” should be decided considering their impact
on all targets set in the regulation, starting from reuse. For instance, a durable and resistantmaterial will make mechanical shredding more demanding, but the same properties cancontribute extending the lifetime of a vehicle and make it a better candidate for reuse.
Remove from the “Circularity Strategy” (Annex IV Part A and Part B) the references
to “fibre-reinforced materials” and “composite plastics” wrongly used to exemplify
materials which hamper easy removal or make recycling very challenging: GFRcomposites parts do not hamper the removal of other parts or make recycling very
challenging. Some parts made out of GFR composites are in fact already listed in the Annex
VII Part C of the proposal for mandatory removal (i.e. dashboard and printed circuit boards)
to facilitate their reuse, remanufacturing or refurbishment. GFR composite parts can also
be recycled provided there are well collected, sorted and treated. As recognised by theEuropean Commission Joint Research Centre in a recent report (2023) 1, 3 recycling process
for composites are already at TRL9 and other processes are currently under development
and expected to be brought to technological maturity in the coming years.
Remove from the Extended Producer Responsibility (EPR) (Article 21 point 1 e) thereference to “composite plastics” wrongly used to exemplify materials which preventa high-quality recycling process: GFR composite parts do not prevent a high-quality
recycling process. GFR composite parts can be dismantled for reuse or recycled if properly
collected and sorted (as other materials). Therefore, it is not justified to penalise financially
car manufacturers using GFR composite parts.
Include additional GFR composite parts to the list of “Mandatory removal of partsand components” (Annex VII Part C): GFR composite parts are durable and long-lasting,with a lifetime potentially exceeding the one of vehicles. Some of these parts can also beeasily dismantled after road hazard and find a market for parts replacement. In addition,
their separate collection could contribute limiting their contamination which is a major hurdle
to certain recycling processes in particular close loop recycling. Therefore, further
consideration should be given to include additional GFR composite parts to the ones alreadylisted in the proposal (i.e. dashboards and printed circuit boards with a surface area larger
than 10 cm3). A list of GFR composite parts to be considered for a revised mandatory
removal (Annex VII Part C) is available on page 2 of this position paper.
Amend the Treatment Requirements “Specific treatment requirements of theremoved parts, components and materials” (Annex VII part F) to automotive glass tomake these compatible with the glass compositions: The composition of automotive
glass cullet (soda lime glass cullet) is not compatible with the composition of the continuous
filament glass fibre composition (as defined in standards ASTM D578). Therefore, thereference to “fibre glass” should be removed from the annex and replaced by a reference
to recycling “into glass products which have a technically compatible glass composition”.

1 Joint Research Centre, 2023, Towards a better definition and calculation of recycling, JRC131531.

Glass Fibre Europe : The End-of-Life of Vehicles and GFR Composite Parts, December 2023.