Study to support the impact assessment for the review of Directive 2000/53/EC on end-of-life vehicles : final report.
Date: 2023-07-12
Institutions: Directorate-General for Environment
Subjects: circular economy, directive (EU), environmental protection, extended producer responsibility, motor vehicle industry, spare part, vehicle, waste disposal, waste recycling

STUDY TO SUPPORT THE  
IMPACT ASSESSMENT FOR THE 
REVIEW OF DIRECTIVE 2000/53/EC 
ON END-OF-LIFE VEHICLES 

Final report 

CONTRACT NO. 07.0201/2020/839200/SFRA/ENV.B.3 
with updates under  
CONTRACT NO. 09.0202/2023/890692/SFRA/ENV.B.3 

Written by Oeko-Institut e.V.: Yifaat Baron, Izabela Kosińska-Terrade, Clara Loew, Andreas Köhler, Katja Moch, 
Jürgen Sutter, Kathrin Graulich, Frederick Adjei  
Mehlhart Consulting: Georg Mehlhart 
June 2023 

STUDY TO SUPPORT THE IMPACT ASSESSMENT FOR THE REVIEW OF 
DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Directorate-General for Environment 
Directorate B - Circular Economy 
Unit B3 
European Commission 
B-1049 Brussels 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

STUDY TO SUPPORT THE  
IMPACT ASSESSMENT FOR THE 
REVIEW OF DIRECTIVE 2000/53/EC 
ON END-OF-LIFE VEHICLES 
Final report 

CONTRACT NO. 07.0201/2020/839200/SFRA/ENV.B.3  
with updates under  
contract no. 09.0202/2023/890692/SFRA/ENV.B.3 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Manuscript completed in June 2023 

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VI 

STUDY TO SUPPORT THE IMPACT ASSESSMENT  
FOR THE REVIEW OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

TABLE OF CONTENTS  

Executive Summary ....................................................................................... XXIX 

1. 

Introduction ................................................................................................... 1 

1.1 

Background: Shortcomings of the current ELV Directive ...................................... 1 

1.1.1 

Intervention Logic .......................................................................................................... 1 

1.2  Methodology of the study ..................................................................................... 2 

1.2.1 

Impact Assessment according to Better Regulation ..................................................... 2 

1.3 

Synopsis of stakeholder activities .......................................................................... 3 

1.3.1  Consultation Strategy .................................................................................................... 3 
1.3.2 
Summary of stakeholder consultations process ........................................................... 5 
1.3.3  Key positions of stakeholders on specific topics .........................................................21 
1.3.4  Data availability ...........................................................................................................38 

2.  Current situation and potential measures ................................................. 40 

2.1 

The circularity of vehicles .................................................................................... 40 

2.1.1 
Introduction .................................................................................................................40 
2.1.2  Current situation .........................................................................................................41 
2.1.3  What is the problem and why is it a problem? ...........................................................94 
2.1.4  Which objective should be achieved? .......................................................................102 
2.1.5  What are the measures to achieve the objective? ...................................................104 

2.2  Missing vehicles ................................................................................................. 149 

Introduction ...............................................................................................................150 
2.2.1 
2.2.2  Current situation .......................................................................................................150 
2.2.3  What is the problem and why is it a problem? .........................................................157 
2.2.4  Which objective should be achieved? .......................................................................159 
2.2.5  What are potential measures to achieve the objective? ..........................................161 

2.3 

Extended Producer Responsibility (EPR) and advanced economic incentives .. 179 

Introduction ...............................................................................................................179 
2.3.1 
2.3.2  Current Situation .......................................................................................................179 
2.3.3  What is the problem and why is it a problem? .........................................................191 

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2.3.4  Which objectives should be achieved? .....................................................................195 
2.3.5  What are the measures to achieve the objective? ...................................................196 

2.4 

Extension of the vehicle categories in scope of the ELV Directive .................... 203 

2.4.1 
Introduction ...............................................................................................................203 
2.4.2  Current Situation .......................................................................................................204 
2.4.3  What is the problem and why is it a problem? .........................................................207 
2.4.4  Which objective should be achieved? .......................................................................222 
2.4.5  What are the measures to achieve the objective? ...................................................224 

3. 

Impact assessment ................................................................................... 233 

3.1 

Circularity ........................................................................................................... 233 

3.1.1  Baseline .....................................................................................................................233 
3.1.2  Policy Options ............................................................................................................234 
3.1.3  Method of analysis applied .......................................................................................242 
3.1.4  Analysis of measures on the design of vehicles and preparation for their being put on 
the market (vehicle level) .......................................................................................................243 
3.1.5  Analysis for steel ........................................................................................................281 
3.1.6  Analysis for copper ....................................................................................................296 
3.1.7  Analysis for aluminium ..............................................................................................311 
3.1.8  Analysis for glass ........................................................................................................327 
3.1.9  Analysis for plastic .....................................................................................................344 
3.1.10  Analysis for electric and electronic components (EEC) .............................................366 
3.1.11  Analysis of measures addressing the treatment of vehicles at EoL: vehicle level ....392 
3.1.12  Comparison of the options ........................................................................................397 
3.1.13  Conclusions and the preferable option .....................................................................409 
3.1.14  Reporting and monitoring requirements ..................................................................411 

3.2  Missing vehicles ................................................................................................. 412 

3.2.1  Baseline .....................................................................................................................412 
3.2.2  Policy Options ............................................................................................................413 
3.2.3  Methodology .............................................................................................................417 
Selection of potential impacts ...................................................................................421 
3.2.4 
Economic Impacts ......................................................................................................421 
3.2.5 
Environmental Impacts..............................................................................................442 
3.2.6 
3.2.7 
Social Impacts ............................................................................................................449 
3.2.8  Comparison of the options ........................................................................................452 
3.2.9  Preferred Policy Option .............................................................................................454 
3.2.10  Reporting and monitoring requirements ..................................................................458 

3.3 

Extended Producer Responsibility (EPR) ........................................................... 458 

Identification of discarded measures ........................................................................458 
3.3.1 
3.3.2  Overview of measures and relation to “missing vehicles” and “circularity”.............459 
3.3.3  Methodology .............................................................................................................460 
3.3.4  Administrative effort / burden of measures for different stakeholders ...................460 
3.3.5  Conclusion .................................................................................................................462 

3.4 

Extension of the vehicle categories in scope of the ELV Directive .................... 463 

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3.4.1  Baseline .....................................................................................................................463 
3.4.2  Policy Options ............................................................................................................467 
3.4.3  Methodology & overview of assumptions ................................................................471 
3.4.4  Analysis ......................................................................................................................472 
3.4.5  Conclusion .................................................................................................................512 
3.4.6  Reporting and monitoring requirements ..................................................................514 

4.  Overarching effects between the fields of action ................................... 515 

4.1 

Impacts of design for circularity on the other fields of action .......................... 515 

4.1.1  On Missing vehicles ...................................................................................................515 
4.1.2  On EPR schemes ........................................................................................................515 
4.1.3  On the Extension of the vehicle categories in scope of the ELV Directive ................516 

4.2 

Impacts of high-quality reuse and recycling on the other fields of action........ 516 

4.2.1  On Missing vehicles ...................................................................................................516 
4.2.2  On EPR schemes ........................................................................................................516 
4.2.3  On the Extension of the vehicle categories in scope of the ELV Directive ................516 

4.3 

Impacts of reduced number of missing vehicles on the other fields of action . 516 

4.3.1  On circularity .............................................................................................................516 
4.3.2  On EPR schemes ........................................................................................................517 
4.3.3  On the Extension of the vehicle categories in scope of the ELV Directive ................517 

4.4 

Impacts of EPR scheme on the other fields of action........................................ 517 

4.4.1  On circularity .............................................................................................................517 
4.4.2  On Missing vehicles ...................................................................................................517 

5.  References ................................................................................................. 518 

6.  Annexes ..................................................................................................... 526 

Annex I: Additions to the report ...................................................................... 527 

6.1 

Detailed current situation of Specific objective 1 (the scope of the Directive) 527 

Scope of the ELVD and road vehicles not in scope of ELVD and their fleet ..............527 
6.1.1 
6.1.2  Argumentation for scope of the assessment ............................................................533 
6.1.3  Material composition of motorcycles, trucks and buses at their end-of-life ............534 
6.1.4  Practise of reuse ........................................................................................................538 
6.1.5  Analysis of exports of vehicles...................................................................................539 
6.1.6  Multi-stage type-approval processes ........................................................................543 

Detailed results of the impact analysis for Specific objective 1 (the scope of the 

6.2 
Directive)........................................................................................................................ 546 

6.2.1 
List for selected impacts ............................................................................................546 
6.2.2  Quantification of material streams ...........................................................................547 
6.2.3  Quantification of impacts ..........................................................................................553 

6.3 

Detailed current situation of Specific objective 2 (circularity) .......................... 559 

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6.3.1  Additional information on materials used in vehicles ...............................................559 

6.4 

Detailed results of the impact analysis for Specific objective 2 (circularity)..... 566 

6.4.1 
Screening measures and separate discarded options ...............................................566 
6.4.2  Additional results of the impact analysis ..................................................................572 
6.4.3  Administrative costs for objective 2: circularity: .......................................................573 

6.5 

Detailed current situation of Specific objective 3 (missing vehicles) ................ 575 

6.5.1 

Facts on extra EU Export ...........................................................................................575 

6.6 

Detailed results of the impact analysis for Specific objective 3 (missing vehicles)
598 

6.6.1 
Screening measures and separate discarded options ...............................................598 
Scenarios for the shift between categories ...............................................................604 
6.6.2 
6.6.3  Overview of key impacts to screen ...........................................................................619 

Detailed current situation of EPR schemes, PROs and fees / taxes applied in the 

6.7 
MS for the management ELVs ....................................................................................... 620 

6.7.1  Questions to the Member States in March 2022 on EPR ..........................................620 
6.7.2  Details for the countries where fees / taxes are mentioned ....................................621 
6.7.3  Details for Member States with Deposit Refund Systems ........................................625 

6.8 

Detailed results of the impact analysis for EPR Scheme and economic instruments
627 

6.8.1 

Screening measures and separate discarded options ...............................................627 

6.9 

Description of the model to calculate the impact assessment (environmental)633 

6.9.1  General description of the model .............................................................................633 
Fleet model ................................................................................................................635 
6.9.2 
6.9.3  Reuse .........................................................................................................................639 
6.9.4  Recycling ....................................................................................................................639 
LCA data .....................................................................................................................640 
6.9.5 

6.10  Ad-hoc contributions to the impact assessment of the EC: Further details on 
economic impacts of measures related to the proposed scope extension .................. 648 

6.10.1  Background ................................................................................................................648 
6.10.2  Measure “Roadworthiness certificate with implication on exports” ........................648 
6.10.3  Measure “Mandatory treatment of additional vehicle categories at ATFs” .............653 
6.10.4  Measure “Advanced waste treatment requirements”..............................................664 
6.10.5  Summary of costs and revenues for ATF treatment and export reductions .............666 
6.10.6  References .................................................................................................................666 

6.11  Ad-hoc contributions to the impact assessment of the EC: Recycled content steel 
in new vehicles .............................................................................................................. 667 

6.11.1  Background ................................................................................................................667 
6.11.2  Supply ........................................................................................................................667 
6.11.3  Demand .....................................................................................................................668 
6.11.4  Comparison of demand and supply for recycled content .........................................678 
6.11.5  Outlook for a more comprehensive study ................................................................679 

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6.11.6  References .................................................................................................................680 

6.12  Ad-hoc contributions to the impact assessment of the EC: Assumptions for the 
impact assessment of the introduction of criteria for the export of used cars ............ 681 

6.12.1  Background ................................................................................................................681 
6.12.2  Abstract .....................................................................................................................681 
6.12.3  Economic impacts ......................................................................................................682 
6.12.4  Environmental impacts and aspects regarding circular economy ............................682 
6.12.5  What tasks need to be performed to establish quantitative modelling covering the 
beforementioned environmental impacts .............................................................................687 
6.12.6  References .................................................................................................................688 
6.12.7  Annex A: EU vehicle emission standards of exported vehicles to selected countries689 
6.12.8  Annex B: Development of EU Emission standards ....................................................692 
6.12.9  Annex C: Development of real world emissions under Euro emissions standards ...696 

Annex II: Assessment of the 3R Directive and its effectiveness .................. 697 

7.  Assessment of the 3R Directive and its effectiveness ........................... 698 

7.1 

Introduction ....................................................................................................... 698 

Study objectives and scope of this report .................................................................698 
7.1.1 
7.1.2  Methodology .............................................................................................................699 
Structure of the report ..............................................................................................700 
7.1.3 

7.2 

The current situation ......................................................................................... 701 

7.2.1  Background to the 3R Directive and its interrelations to the Regulation on Type 
approval and to the ELV Directive ..........................................................................................701 
7.2.2  Main provisions of the 3R Directive and relations to other policies .........................702 
The 3R Type-Approval Process ..................................................................................705 
7.2.3 
7.2.4 
Interrelation of the 3R Directive to the international regulation UN ECE Regulation No. 
133 and to ISO 22628:2002 ....................................................................................................708 

Summary of the main results of the consultation of stakeholders on the 3R Type 
7.3 
approval and its relation to the ELVD ............................................................................ 712 

Evaluation results of the effectiveness of the 3R Directive and its relation to the 

7.4 
ELVD  715 

The origin and objective of the 3R Directive .............................................................716 
7.4.1 
The scope of the 3R Directive ....................................................................................717 
7.4.2 
ELVD design requirements ........................................................................................720 
7.4.3 
ELVD end-of-life requirements ..................................................................................724 
7.4.4 
7.4.5 
Information collected through the 3R Directive processes .......................................728 
7.4.6  Alignment of the 3R Directive with the ISO 22628:2002 ..........................................730 
7.4.7  Alignment and coherence with the UN ECE Regulation 133 .....................................731 

7.5 

Summary of the results ..................................................................................... 732 

Annex III: Stakeholder consultation (synopsis report) ................................. 739 

8.  Consultation Strategy ............................................................................... 740 

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8.1 

8.2 

8.3 

8.4 

Consultation objectives ..................................................................................... 740 

Stakeholders consulted ..................................................................................... 740 

Consultation methodology ................................................................................ 741 

Summary of stakeholder consultations process ............................................... 742 

8.4.1 
Feedback on the inception impact assessment ........................................................742 
8.4.2  Open Public Consultation ..........................................................................................746 
Targeted stakeholder consultation ...........................................................................747 
8.4.3 
Survey in relation to 3R Directive ..............................................................................749 
8.4.4 
8.4.5 
Stakeholder Workshop on 23/24. March 2022 .........................................................750 
8.4.6  Consultation of Member States ................................................................................753 
Follow-up after the workshop and ad-hoc consultation ...........................................755 
8.4.7 

8.5 

Key positions of stakeholders on specific topics ............................................... 756 

8.5.1  Circularity ..................................................................................................................756 
8.5.2  Hazardous substances ...............................................................................................764 
8.5.3  Collection / Missing vehicles .....................................................................................766 
EPR System ................................................................................................................768 
8.5.4 
8.5.5 
ELVD Scope ................................................................................................................769 
8.5.6  3R Type Approval and its relation to the ELVD .........................................................771 
List of documents available to EC in addition to the synopsis ..................................772 
8.5.7 

XII 

 
 
 
 
 
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LIST OF TABLES 

Table 1-1 
Table 1-2 
Table 1-3 

Table 1-4 
Table 1-5 
Table 1-6 

Table 1-7 
Table 2-1 

Table 2-2 

Table 2-3 

Table 2-4 

Table 2-5 
Table 2-6 

Table 2-7 

Table 2-8 
Table 2-9 

Overview of different methods of the project’s consultation strategy 
Number of contributions referring to the topics of review 
Stakeholders invited to interviews held in relation to the 3R Type Approval 
Directive 
Agenda of the stakeholder workshop 
Agenda of Workshop with Member State Representatives 
Overview of composition of Member State representatives registered* for 
the workshop 
Ad-hoc consultation of specific stakeholders 
Material composition of End-of-life vehicles (passenger cars) for 2020 in kg 
after depollution, battery weight excluded 
Distribution of total amount of steel on the different parts of End-of-life 
vehicles (passenger cars) in % after depollution 
Distribution of total amount of copper on the different parts of End-of-life 
vehicles (passenger cars) in % after depollution 
Distribution of total amount of aluminium on the different parts of End-of-life 
vehicles (passenger cars) in % after depollution 
Important metals used EEE (many also of relevance to EEC in vehicles) 
Composition of printed circuit boards according to Schmid (2014), 
concentration in g/kg 
Results of the calculations for unknown whereabouts of vehicles for EU-28 
excl. BG, CY, MT (2008- 2014) and EU27 excl. BG, CY, MT (2015-2019) 
Different reasons for ELVs of unknown whereabouts 
Share of used vehicles exported in 2020 from EU-27 to differently regulated 
countries 

Table 2-10  General Problems and related Objectives 
Table 2-11  Data reporting form: Data on the national vehicle market for M1 and N1 

vehicles 

Table 2-12  Producer Responsibility Organisations and fees supporting the management 

of ELVs identified 

Table 2-13  Overview of units and weights of PTW, buses, lorries and semi-trailers in 

2020 

Table 2-14  Dimensions of material streams from ELV not in scope of ELVD 
Table 2-15 
Table 3-1 

Lorries: Strategies for weight reduction focus on composites 
Analysis of aluminium, steel and two-direction carbon fibre regarding 
stiffness against weight and strength against weight 
Summarising table for the comparison of the non-recyclables’ scenarios 
Routes of treatment for steel under the various scenarios 
Tonnes of steel from collected ELVs assumed to be either reused or 
recycled and losses of the material in the treatment process (in 2035) 
Change in tonnes of materials for recycling comparing to the baseline ["-" 
decrease, "+" increase] (in 2035) 
Credits for Global warming potential (GWP) for each scenario for steel in 
collected ELVs in 2035 to primary production (Mt CO2eq) 
Change in tonnes of materials for recycling comparing to the baseline ["-" 
decrease, "+" increase] (in 2035) 

Table 3-2 
Table 3-3 
Table 3-4 

Table 3-5 

Table 3-6 

Table 3-7 

7 
8 

14 
16 
19 

20 
21 

68 

70 

75 

76 
85 

85 

152 
153 

156 
159 

168 

187 

204 
207 
213 

261 
266 
285 

286 

286 

287 

287 

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Table 3-8 

Table 3-9 

Revenues for steel scrap of potentially higher quality and obtained after 
shredding in mln Euro. Below also a change in mln Euro of these revenues 
comparing to the baseline. 
Change in mio Euro of these revenues comparing to the baseline ["-" 
decrease, "+" increase] 

Table 3-10  Allocation of calculated dismantling time to three materials (steel, copper, 

and aluminium) to avoid double counting. 

Table 3-11  Assumptions to calculate dismantling time for engines for all scenarios of 

Table 3-12 

steel, copper, and aluminium 
Total costs for baseline and additional dismantling costs (as compared to 
the baseline) in mln Euro 

293 
Table 3-13  Number of additional job positions in the ATFs as compared to the baseline  293 
Table 3-14  Summarising table for the comparison of the steel scenarios (the assessed 

impacts are based on the total of ELVs collected in 2035) 

Table 3-15  Routes of treatment for copper under the various scenarios 
Table 3-16 

Tonnes of copper from collected ELVs assumed to be either reused or 
recycled and losses of the material in the treatment process (in 2035) 

Table 3-17  Change in tonnes of materials for recycling comparing to the baseline ["-" 

decrease, "+" increase] (in 2035) 

Table 3-18  Credits for Global warming potential (GWP) for each scenario for copper in 

collected ELVs in 2035 to primary production (Mt CO2eq) 
Table 3-19  Change in tonnes of materials for recycling comparing to the baseline ["-" 

decrease, "+" increase] (in 2035) 

Table 3-20  Revenues for copper scrap of potentially higher quality and obtained after 
shredding in mln Euro. Below also a change in mln Euro of these revenues 
comparing to the baseline. 

Table 3-21  Change in mln Euro of these revenues comparing to the baseline ["-" 

Table 3-22 

decrease, "+" increase] 
Total costs for baseline and additional dismantling costs (as compared to 
the baseline) in million Euro 

307 
Table 3-23  Number of additional job positions in the ATFs as compared to the baseline  307 
Table 3-24  Summarising table for the comparison of the copper scenarios (the 
assessed impacts are based on the total of ELVs collected in 2035) 

Table 3-25  Routes of treatment for aluminium under the various scenarios 
Table 3-26 

Tonnes of aluminium from collected ELVs assumed to be either reused or 
recycled and losses of the material in the treatment process (in 2035) 

Table 3-27  Change in tonnes of materials for recycling comparing to the baseline ["-" 

decrease, "+" increase] (in 2035) 

Table 3-28  Credits for Global warming potential (GWP) for each scenario for aluminium 
in collected ELVs in 2035 to primary production (Mt CO2eq) 
Table 3-29  Change in tonnes of materials for recycling comparing to the baseline ["-" 

decrease, "+" increase] (in 2035) 

Table 3-30  Routes of treatment for wrought aluminium under the various scenarios 
Table 3-31  Routes of treatment for cast aluminium under the various scenarios 
Table 3-32  Revenues for aluminium scrap of potentially higher quality and obtained 

after shredding in million Euro. Below also a change in million Euro of these 
revenues comparing to the baseline. 

Table 3-33  Change in million Euro of these revenues comparing to the baseline ["-" 

Table 3-34 

decrease, "+" increase] 
Total costs for baseline and additional dismantling costs (as compared to 
the baseline) in million Euro 

XIV 

291 

291 

292 

292 

294 
301 

302 

302 

303 

303 

306 

306 

308 
316 

316 

316 

317 

318 
320 
320 

322 

323 

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Table 3-35  Number of additional job positions in the ATFs as compared to the baseline  323 
Table 3-36  Summarising table for the comparison of the steel scenarios (the assessed 

impacts are based on the total of ELVs collected in 2035) 

Table 3-37   Routes of treatment for glass from ELVs in 2035 under the various 

scenarios in shares (%) of total material stream 

Table 3-38  Cost differences between glass processing by dismantling and post-

shredding sorting identified in the studies 

Table 3-39  Summarising table for the comparison of the glass scenarios 
Table 3-40  Main polymer types per application in all types of vehicles: Components 
understood to be larger in volume (and heavier in weight) are specified in 
bold 

Table 3-41  Example of mass distribution intervals of recycled plastic materials per 

application types for a passenger car representing a potential ‘front-runner 
case’. Percentage of recycled content is averaged based on the estimated 
masses of both pre-CR and post-CR 

Table 3-42  Outputs of plastic in tonnes to the 3Rs along the treatment cycle of ELVs 

(data representing 2014) 

Table 3-43  Routes of treatment for plastics from ELVs under the various scenarios 
Table 3-44  Recycled plastics volume generated as compared to the baseline under the 

various scenarios in tonnes 

Table 3-45  Δ € (benefit) / per tonne of recyclates additionally produced compared to the 

baseline and being then integrated in a vehicle 

Table 3-46  Costs and benefits of the scenarios in terms of the difference to the 

baseline, in total  (and in €/vehicle) unless otherwise stated 

Table 3-47  Summary of employment impacts under scenario 1 
Table 3-48  Summarising table for the comparison of the plastic scenarios 
Table 3-49 
Table 3-50  Distribution of critical metal mass in passenger vehicles in the Swiss vehicle 

Fate of critical metals during ELV waste management 

fleet in 2014 - Total mass per average vehicle in gram 
Table 3-51  Materials contained in an inverter and they relative weight in kg/unit 
Table 3-52  Routes of treatment for EEC from ELVs under the various scenarios 
Table 3-53  Average dismantling time of the EEC in minutes for the specified EEC 
Table 3-54 

Tonnes of inverters from collected ELVs assumed to be either reused or 
recycled or sent with hulks to the shredder (in 2035) 
Tonnes of base and precious materials contained in inverters dismantled in 
each scenario that are thus potentially available for recycling (in 2035), 
values are in tonnes and are rounded 

Table 3-55 

Table 3-56  GWP contributions in the baseline and the difference thereto in the various 
scenarios for the specific treatment route (in 2035), values in CO2eq tonnes 
and are rounded 

Table 3-57  Summarising table for the comparison of the EEC scenarios on the basis of 

treatment of the inverter (the assessed impacts are based on the total of 
ELVs collected in 2035) 

Table 3-58  Routes of treatment for complete vehicle under the various scenarios 
Table 3-59  Calculated routes of treatment for all materials in collected ELVs under the 

various scenarios 

Table 3-60  Obtained rates for reuse and recycling and rates for recovery and recycling 

for complete vehicle under the various scenarios 

324 

332 

337 
340 

344 

345 

349 
355 

358 

361 

361 
362 
363 
369 

374 
375 
376 
377 

380 

381 

382 

386 
392 

393 

394 

Table 3-61  Yearly Admin. Costs (AC) for the Waste management sector and MS related 

Table 3-62  Options for comparison of circularity objective 

to reporting (~12 000 ATFs (Elliott et al. 2019), 500 shredders and recyclers)  396 
397 

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Table 3-63  Compiled results of comparison of the options for comparison of circularity 

objective 

Table 3-64  Overview Policy Options and related measures sorted by Objectives 
Table 3-65  Effects of import / export of used vehicles on the level of a yearly DRS fee 
Table 3-66  Exemplary effects of import and export of used vehicles on the EPR fees 

Organisations identified 

Table 3-67  Additional profits (revenues – costs) for ATFs in EU-27 for the Policy 

Options in million Euro compared to Baseline 

Table 3-68  Additional profits (revenues – costs) for shredders in EU-27 for the Policy 

Options in million Euro compared to Baseline 

Table 3-69  Additional profits in EU-27 for car exporters for the Policy Options in million 

Euro compared to Baseline 

Table 3-70  Overview economic impacts in 2040 
Table 3-71  Additional Resources compared to baseline for intra EU recycling in 2040 for 

the different Policy Options 

Table 3-72  Additional Credits compared to baseline for intra EU recycling in 2040 for 

the different Policy Options 
Table 3-73  Refrigerants in air conditioning of vehicles 
Table 3-74  Refrigerants in air conditioning of vehicles 
Table 3-75  GHG Emissions from coolants in million tons CO2eq compared to baseline 
Table 3-76  Additional employees at ATFs in EU-27 for the Policy Options in million Euro 

compared to Baseline 

Table 3-77  Summarising table for the comparison of the options 
Table 3-78  Summarising table for the comparison of the options 
Table 3-79  Overview of impacts of the preferred policy option and the interrelations with 

the preferred measures regards the regulation of the EPR 
Table 3-80  Measures in the context of the EPR regime with impact on the aspect of 

Table 3-81 

missing vehicles 
Initial assessment of measures to identify discarded and short-listed 
measures 

Table 3-82  Material quantities from waste lorries, buses and PTW in 2020 
Table 3-83  Option-related assumptions for the modelling 
Table 3-84  Measures, their relevant impact categories, vehicles specifics in the 

measures and affected stakeholder 

Table 3-85  Material quantities from waste lorries, buses and PTW in 2030 in mio tons 
Table 3-86  Comparison of economic impacts for manufacturers of different vehicle 

categories compared to the baseline (0 = no/little impact, +/++/+++ = low, 
medium, high costs/impact) 

Table 3-87   Admin. Costs (AC) for lorry and PTW manufacturers in Policy Option A 
Table 3-88   Admin. Costs (AC) for all non-passenger car vehicle manufacturers (~30 

companies) in Policy Option B 

Table 3-89  Comparison of economic impacts for EoL stakeholders compared to the 

400 
415 
422 

423 

431 

434 

437 
440 

443 

444 
445 
446 
448 

449 
452 
455 

456 

459 

460 
464 
472 

473 
477 

488 
490 

490 

baseline (0 = no/little impact, +/++/+++ indicates the expected level of 
effects, but not whether positive or negative) 

494 
495 
496 
Lead in waste buses and motor scooters in 2025 and related damage costs  505 
510 
527 

Table 3-90   Yearly Admin. Costs (AC) for the EU dismantling sector (~4 500 ATFs) 
Table 3-91  Calculation of revenue from resale of spare parts 
Table 3-92 
Table 3-93  Comparison of the options for main objective 1 
Table 6-1 
Definition of types of road vehicles 
Table 6-2 
Share of vehicle type in EU 27 (black writing – currently in scope; blue 
writing – currently not in scope) 

532 

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Table 6-3 
Table 6-4 
Table 6-5 
Table 6-6 
Table 6-7 
Table 6-8 
Table 6-9 
Table 6-10  Declaration of trade statistic numbers evaluated 
Table 6-11  Material compositions of example lorries, buses, and L-type approved 

533 
Comparison of data from Eurostat and PRIMES 
Material composition of PTW 1: Data for motor scooter (50 cubic cm engine)  534 
535 
Material composition of PTWs 2 
536 
Material composition of different bus models 
537 
Material composition of different truck models (in kg) 
538 
Overview of (semi-)trailers’ weights 
540 
Extra-EU Export (incl. GB) 
542 

vehicles in kg (Summary of tables in chapter 6.1.3) 

Table 6-12  Quantification of materials out of scope for stock 2020, expected ELVs in 

2020 and expected ELVs in 2030 

Table 6-13  Shares that vehicle categories have in the total sum of material quantities 
from waste lorries, buses and PTW (data for Figure 3-41) 
Table 6-14  Material quantities from vehicles arriving at EoL in 2030 (variant with 40% 

reuse quota) 

Table 6-15  GWP benefits as discussed in chapter 3.4.4.2.2 (in million tons of CO2 

equivalents) 

Table 6-16  Expected losses of material and revenue due to unknown whereabouts and 

Extra EU Exports in 2020 

Table 6-17  Administrative cost (recurrent) according to BRG model, scope extension 
Table 6-18  Administrative cost (one off) according to BRG model, scope extension 
Table 6-19  Prices (Euro) per kilo of HDVs exported from Netherlands 
Table 6-20  Distribution of CM mass in EE devices in an average passenger vehicle. 
Table 6-21 

Initial assessment of measures to identify discarded and short-listed 
measures 

Table 6-22  Administrative costs (recurrent) according to BRG model, circularity 
Table 6-23  Share of used vehicles exported in 2020 from EU-27 to differently regulated 

countries 

Table 6-24  Value of used vehicles exported in 2020 from EU-27 to differently regulated 

countries 

Table 6-25  Export of Used Vehicles to non-EU-Countries in 2020: Numbers and Value 

per Country, Source: Eurostat, COMEXT (download 27.1.2022); 
Compilation: Mehlhart Consulting 

Table 6-26  Regulatory limitations for the import of used vehicles for African countries 

(Source: UNEP (Baskin et al., 2020) 

Table 6-27  Regulatory limitations for the import of used vehicles for Eastern Europe, the 
Caucasus, and Central Asia (Source: UNEP (Baskin et al., 2020) 

Table 6-28  Regulatory limitations for the import of used vehicles for Middle East 

Table 6-29 

(Source: UNEP (Baskin et al., 2020) 
Initial assessment of measures to identify discarded and short-listed 
measures 

Table 6-30  Change in categories of whereabouts for the different scenarios 
Table 6-31  Resources for intra EU recycling in 2025/2030/2040 for the different Policy 

Options 

Table 6-32  Credits for recycling due to shift from export (used and ELVs) to EU 

Table 6-33 

domestic treatment; LCA unit: GWP 100a [1000 t CO2 eq] 
Initial assessment of measures to identify discarded and short-listed 
measures 

Table 6-34  Material composition of End-of-life vehicles (passenger cars) in kg after 

depollution 

547 

548 

550 

551 

553 

554 
555 
557 
558 
563 

568 
574 

578 

579 

582 

587 

589 

590 

600 
614 

615 

617 

629 

635 

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Table 6-35  ELVs available for treatment (PTW, lorries, buses, trailers) 
Table 6-36  Efficiency rates for different materials in ASP + PST and in the material 

Table 6-37 

Table 6-38 

specific recycling processes 
LCA data: Used datasets from ecoinvent 3.8 for primary production of 
materials 
LCA data: Used datasets from ecoinvent 3.8 for secondary production of 
materials 
LCA data: Used datasets from ecoinvent 3.8 for different process steps 
LCA data: Primary production of materials I 
LCA data: Primary production of materials II 
LCA data: Primary production of materials III 
LCA data: Secondary production of materials 
Total Export (used and new) of HDV from EU27 to extra EU27 in 2022 
Total Export (used and new) of trailers from EU27 to extra EU27 in 2022 
Total Export (used and new) of buses from EU27 to extra EU27 in 2022 

Table 6-39 
Table 6-40 
Table 6-41 
Table 6-42 
Table 6-43 
Table 6-44 
Table 6-45 
Table 6-46 
Table 6-47  Average value per vehicle of the intra-EU trade with new vehicles per CN 

code 

Table 6-48  Average number of exportable and non-exportable vehicles depending on 
the average value of the exported HDVs, trailers and buses 
Table 6-49  Methodology and key assumptions for calculating costs and revenues of 

mandatory treatment of additional vehicle categories at ATFs 

Table 6-50  Number of L-category vehicles reaching End of Life 
Table 6-51 
Tonnage of materials of L-category vehicles sent to reuse (baseline) 
Table 6-52 
Tonnage of  materials of L-category vehicles sent to recycling (baseline) 
Table 6-53  Calculated costs at ATFs due to the proposed mandatory treatment of L-

category vehicles at ATFs 
Tonnage of materials of HDVs sent to reuse 

Table 6-54 
Table 6-55  Assumed ATF revenues per material sent to reuse 
Table 6-56 
Tonnage of materials of HDVs sent to recycling 
Table 6-57  Assumed recyclers’ revenues per material sent to recycling 
Table 6-58  Number of HDVs reaching End of Life, being exported and being treated 

new/in addition in EU ATF due to proposed policy option of export 
restrictions 

Table 6-59  Calculated revenues, costs and job creation at ATFs due to the proposed 

mandatory treatment of HDVs at ATFs 

Table 6-60  Calculated revenues of recyclers due to limiting the exports of HDVs 
Table 6-61  Effectiveness rates for policy options and implementation period 
Table 6-62 
Table 6-63  Assumed ATF revenues per material sent to reuse 
Table 6-64 
Table 6-65  Number of buses reaching End of Life, being exported and being treated 

Tonnage of materials of buses sent to recycling 

Tonnage of materials of buses sent to reuse 

new/in addition in EU ATF due to proposed policy option of export 
restrictions 

Table 6-66  Calculated revenues, costs and job creation at ATFs due to the proposed 

mandatory treatment of buses at ATFs 

Table 6-67  Calculated revenues of recyclers due to limiting the exports of buses 
Table 6-68 

Input data for calculating advanced treatment requirements, exemplified for 
separate dismantling of glass windows for increasing the potential of high-
quality glass recycling 

XVIII 

639 

639 

641 

642 
643 
644 
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647 
648 
649 
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650 

651 

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Table 6-69  Calculated revenues, costs and job creation at ATFs and recyclers due to 

the proposed separate dismantling and high-quality recycling of glass 
windows of HDVs for the years 2022 (baseline), 2025, 2030, 2035 and 2040  665 

Table 6-70  Calculated revenues, costs and job creation at ATFs and recyclers due to 

the proposed separate dismantling and high-quality recycling of glass 
windows of buses for the years 2022 (baseline), 2025, 2030, 2035 and 2040  666 
667 
669 

Table 6-71  Scenario for the total mass of ferrous scrap in the EU (preferred option) 
Table 6-72  Scenario for the total mass of vehicles PoM in the EU 
Table 6-73  Quality classes based on max. tolerable proportion of accompanying 

elements 

Table 6-74  Considerations for the model calculations including break down for flat steel 

and long products for vehicles PoM (no variation over years considered) 

Table 6-75  Scenario for the total mass of ferrous products in vehicles PoM in EU 
Table 6-76  Considerations for the model calculations of Oeko Institut including potential 

recycled content rates for steel and cast iron 

Table 6-77  Results for the total mass of potential uptake of recycled steel and iron from 

post-consumer scrap 

Table 6-78  Comparison of total supply and demand for scenario 1 
Table 6-79  Comparison of total supply and demand for scenario 2397 
Table 6-80  Comparison of total supply and demand for scenario 3397 
Table 6-81  Changes in real-world emissions for passenger cars with petrol engine on 

urban roads 

Table 6-82  Changes in real-world emissions for passenger cars with diesel engine on 

urban roads 

Table 6-83  EU Emission standards for passenger cars (Category M) (a); g/km 
Table 6-84  EU Emission standards for light commercial vehicles with <= 1 305 kg 

reference mass (Category N1, Class I),  g/km 

Table 6-85  EU Emission standards for light commercial vehicles with 1 305 – 1760 kg 

reference mass (Category N1, Class II),  g/km 

Table 6-86  EU Emission standards for light commercial vehicles with > 1760 kg 

reference mass max 3 500 kg (Category N1, Class III & N2),  g/km 
Table 6-87  Real emission standards for passenger cars (Category M) (a); g/km 
Table 7-1 
Table 7-2 
Table 7-3 
Table 7-4 
Table 7-5 
Table 7-6 
Table 8-1 
Table 8-2 
Table 8-3 

List of tasks and references to the location of contents in the reports 
Evaluation Matrix 
Type approval provisions and preliminary assessment of the manufacturer 
Definitions in ELVD, 3R Directive, UN ECE 133 and ISO 22628 
Comparison 3R Directive and UN ECE 133 Annex I requirements 
Comparison of the scopes of ELVD and 3R Directive 
Overview of different methods of the project’s consultation strategy 
Number of contributions referring to the topics of review 
Stakeholders invited to main study interviews, and indication of the sections 
to which the study team expected the interviewed stakeholder to contribute 
Stakeholders invited to interviews held in relation to the 3R Type Approval 
Directive 
Agenda of the stakeholder workshop 
Agenda of Workshop with Member State Representatives 
Overview of composition of Member State representatives registered* for 
the workshop 
Ad-hoc consultation of specific stakeholders 

Table 8-4 

Table 8-5 
Table 8-6 
Table 8-7 

Table 8-8 

670 

674 
674 

676 

678 
678 
678 
679 

684 

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718 
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748 

749 
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LIST OF FIGURES 

Figure 1-1  Overview on objectives and specific objectives 
Figure 1-2 

Figure 1-3 

Affiliation of stakeholders (n=61) participating in the public feedback on the 
inception IA 
Affiliation of stakeholders (n=61) participating in the public feedback on the 
8 
inception IA 
Answer to the question “I am giving my contribution as: …” (multiple options)  9 
10 
Key words of main aspects discussed in the written contribution (n=58) 

Figure 1-4 
Figure 1-5 
Figure 1-6  Overview of composition of stakeholder registered* for the workshop 

2 

6 

Figure 2-1 

Figure 2-2 

(n=289) 
Total re-use currently reported by MS as a share to total waste generated. 
Reference year 2019 (* data for reference year 2018) 
Re-use currently reported by MS as a share to total waste generated with 
split on various reported components (according to current reporting 
scheme). Reference year 2019 (* data for reference year 2018) 
Total re-use from ELVs, 2012-2019. 

Figure 2-3 
Figure 2-4  Obtained by MS reuse/recovery and reuse/recycling rates for the ELVs. 

Figure 2-5 
Figure 2-6 
Figure 2-7 

Reference year 2019. 
Total recycling from ELVs, 2012-2019. 
Reported data on ELV treatment, 2019. 
Stages of the ELV waste management and treatment processes performed 
on outputs of each stage. 
Schematical presentation of process of ELV treatment in shredders 
Number of auto shredders per country. 

Figure 2-8 
Figure 2-9 
Figure 2-10  Materials from collected ELVs in EU assumed to be either reused or 

recycled and losses of these materials in the treatment process (in 2020) 
Figure 2-11  Development of total amount of steel in ELVs in the EU from 2020 to 2035 
Figure 2-12  Mass of copper in the end-of-life scrap supply and copper tolerance by 

17 

56 

57 
57 

59 
60 
60 

62 
63 
65 

69 
70 

demanded products between 1950 to 2100 at a global scale (Daehn et al. 
2017a) 

73 
Figure 2-13  Composition of EV and Conventional car 
74 
Figure 2-14  Development of total amount of copper in ELVs in the EU from 2020 to 2035  75 
Figure 2-15  Development of total amount of aluminium in ELVs in the EU from 2020 to 

2035 

Figure 2-16  Simulated future production of wrought and cast aluminium for vehicles, and 

the relative share covered by primary and secondary sources under 
combination of interventions in ELV management and scrap sorting 
(columns) and restrictions in aluminium/auto manufacturing industry (rows). 
(Løvik et al. 2014) 

Figure 2-17  Development of total amount of glass in ELVs in the EU from 2020 to 2035 
Figure 2-18  Total mass of precious metals in new vehicles in EU27+3 from 2000 to 2020 

and as projected in 2021 – 2023 

Figure 2-19  Development of total amount of plastics in ELVs in the EU from 2020 to 

2035 

Figure 2-20  Objective No2 and related specific objectives 
Figure 2-21  Measures addressing Objective 2: Improve circularity in the design, 

production and end-of-life treatment of vehicles and its 4 specific objectives 

77 

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Figure 2-22  Objective 2: Processes and conditions in the treatment of ELV in relation to 

proposed measures 

Figure 2-23  Steel mass flows (in Mt) corresponding to the production of cars and the 

recycling of end-of-life vehicles traced through the 2008 global steel system, 
both current practice and a theoretical closed-loop. 

Figure 2-24  Comparison by copper concentration achievable and estimated relative 

energy and cost of the discussed copper separation interventions. 

Figure 2-25  Unknown whereabouts of vehicles (N1 + N1) in the EU -27 in 2019, 

excluding Bulgaria, Cyprus and Malta 
Input / Output Balance for the national vehicle market 

Figure 2-26 
Figure 2-27  Exitance of PROs in EU27+3 EEA countries 
Figure 2-28  Fees / taxes for the management of ELVs 
Figure 2-29  Material composition of examples of lorries, buses and PTWs compared to 

cars 

Figure 2-30  Extra EU Export of used vehicles for 2010-2021 in numbers. 
Figure 2-31  Buses and lorries of unknown whereabouts. 
Figure 2-32  Growth in the numbers of vehicles 
Figure 3-1  Overview of policy options for circularity objectives 2.1-2.4 
Figure 3-2 

Figure 3-3 

Tonnes of steel from collected ELVs assumed to be either reused or 
recycled and losses of the material in the treatment process (in 2035) 
Credits for Global warming potential (GWP) for each scenario for steel in 
collected ELVs in 2035 to primary production (Mt CO2eq) 

Figure 3-4  Min / max prices for shredder steel, free factory (Germany) 
Figure 3-5 

Figure 3-6 

Figure 3-7 

Figure 3-8 

Figure 3-9 

Tonnes of copper from collected ELVs assumed to be either reused or 
recycled and losses of the material in the treatment process (in 2035) (kg) 
Credits for Global warming potential (GWP) for scenarios for copper in 
collected ELVs in 2035 to primary production (kg CO2eq) 
Tonnes of aluminium from collected ELVs assumed to be either reused or 
recycled and losses of the material in the treatment process (in 2035) (kg) 
Credits for Global warming potential (GWP) for scenarios for aluminium in 
collected ELVs in 2035 compared to primary production (kg CO2eq) 
Credits for Global warming potential (GWP) for scenarios for wrought 
aluminium in collected ELVs in 2035 compared to primary production (kg 
CO2eq) 

Figure 3-10  Credits for Global warming potential (GWP) for scenarios for cast aluminium 

in collected ELVs in 2035 compared to primary production (kg CO2eq) 

Figure 3-11  Tonnage of glass treated in the different routes under each scenario, in kg 
Figure 3-12  Credits for Global warming potential (GWP) of the treatment options for all 

vehicle glass compared to primary production, calculated for all vehicles 
collected as ELVs in 2035 (kgCO2eq) 

Figure 3-13  Comparison of the environmental impacts of dismantling (and recycling) 

versus post shredder recycling (backfilling or construction uses) in % 

Figure 3-14  Potential impact on Climate Change of plastic granulates from different 

feedstock sources, as calculated for the purpose of the JRC analysis. (kg 
CO2 eq. per kg of plastic granulates) 

141 

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Figure 3-15  Average plastics from collected ELVs assumed to be either reused or 

recycled and losses of the material in the treatment process (in 2035), in kg  358 

Figure 3-16  Credits for Global warming potential (GWP) for each scenario for average 
plastic from collected ELVs to primary production (in 2035) in kgCO2 eq. 

Figure 3-17  dismantling rates for vehicle EEC 

359 
375 

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Figure 3-18  Environmental impacts of the four scenarios, in thousands of UBP (eco-

points according to method of ecological scarcity, contribution per process 

Figure 3-19  Mass flows for scenarios for inverters  sent to different treatment routes 

(tonnes) 

Figure 3-20  Credits for Global warming potential (GWP) for scenarios for inverters  

378 

380 

compared to primary production – calculated for all inverters of ELVs 
collected (BEV) in 2035 (tCO2eq) 

381 
Figure 3-21  ATF dismantling costs and revenues from EEC reuse and material sales (€)  383 
Figure 3-22  Tonnes of materials from collected ELVs assumed to be either reused or 
recycled and losses of the material in the treatment process (in 2035) (kg) 

393 

Figure 3-23  Credits for Global warming potential (GWP) for scenarios for the whole fleet 
compared to primary production – calculated for all ELVs collected in 2035 
(tCO2eq) 

Figure 3-24  Total revenue from materials for recycling or recovery in Euro – calculated 

for all ELVs collected in 2035 (1000 Euro) 

Figure 3-25  Model calculations for the change in missing vehicles due to the effects of 

the different policy options 

Figure 3-26  Cost and revenue of ELV treatment in German ATFs 
Figure 3-27  Cost and revenue situation of the illegal dismantling per ELV 
Figure 3-28  Model calculations for the revenues from dismantling activities in Germany 

for ATFs and different illegal actors (in Million €) 

Figure 3-29  Résultat d’exploitation par sous-activité  (moyenne pondérée de l’échantillon 

24 centres VHU) 

Figure 3-30  Profits (revenues – costs) for ATFs in EU-27 for the Policy Options:  a) 
profits from ELVs directed to ATFs;  b) profits from  export of (old) used 
vehicles 

Figure 3-31  Aggregated change in profits for ATFs in million € for the different Policy 

Options 

Figure 3-32  Résultat d’exploitation par sous-activité (Moyenne pondérée del’énchantillon 

7 broyeurs VHU) 

Figure 3-33  Cost and revenues of shredding plants per cost type 
Figure 3-34  Profits for Shredders from ELVs in EU-27 for the different Policy Options 
Figure 3-35  Min / max prices for shredder steel, free factory (Germany) 
Figure 3-36  Profits in EU-27 for car exporters of (old) used vehicles for the different 

Policy Options 

Figure 3-37  Credits in 2040 for recycling due to shift from export (used and ELVs) to EU 

domestic treatment; aggregate; LCA unit: GWP 100a [1000 t CO2 eq] 

Figure 3-38  Lifetime distribution of vehicles 
Figure 3-39  GHG Emissions from coolants for the Policy Options 
Figure 3-40  Combination of measures is required to reduce the number of missing 

vehicles, in brackets the reference to the number of the measure) 

Figure 3-41  Shares that vehicle categories have in the total sum of material quantities 

from waste lorries, buses and PTW 

Figure 3-42  Scenarios addressing objective 1 addition to the baseline 
Figure 3-43  Overview of policy options 
Figure 3-44  Methodological approach for quantification of material streams 
Figure 3-45  Expected material quantities from PTW, buses and lorries arriving at EoL in 

2019 and 2030 in million tons 

Figure 3-46  Material quantities for a powered two-wheeler (type Le3 A2) with with 40% 

reuse in 2030 (top) and 70% in 2030 (down) 

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Figure 3-47  Material quantities for 12 t GVW lorry with 40% reuse in 2030 (top) and 70% 

in 2030 (down) 

Figure 3-48  Material quantities for buses (12 GVW) with 40% reuse in 2030 (top) and 

70% in 2030 (down) 

Figure 3-49  Savings of greenhouse gas emissions through EoL treatment for expected 

number of ELVs in the EU per year (Global Warming Potential) in million 
tons of CO2-eq. with 40% reuse in 2030 (top) and 70% in 2030 (down) 
Interrelations 

Figure 4-1 
Figure 6-1  Overview of different types of L-type approved vehicles according to 

Regulation (EU) No 168/2013 

Figure 6-2  Overview of a literature research of LCA studies in the automotive sector. 
Figure 6-3 
Figure 6-4 
Figure 6-5 
Figure 6-6 

Reuse level of motorized two-wheelers in Finland 
Step 1 of multi-stage type approvals: Base vehicle 
Step 2 of multi-stage type approval: Bodybuilder 
Credits for Global warming potential (GWP) of different treatment routes for 
all windows, as compared to primary production (kgCO2eq) – functional unit: 
all vehicle glass of a typical vehicle (tCO2eq) 
Number of exported used vehicles from EU-27 to non-EU Countries 
Total value of exported used vehicles from EU-27 to non-EU Countries 
Extra-EU exports of used vehicles in numbers and average value for 2020 

Figure 6-7 
Figure 6-8 
Figure 6-9 
Figure 6-10  Extra-EU exports of used vehicles in numbers and average value (zoom) for 

2020 

Figure 6-11  Age of dismantled (RDW_Dismantling LDVs) versus retrieved vehicles 

exported to West Africa. 

Figure 6-12  Relative distribution of mileage of dismantled (RDW_Dismantling LDVs) 

versus retrieved vehicles exported to West Africa 

Figure 6-13  European emissions standards of dismantled (RDW_Dismantling LDVs) 

versus retrieved vehicles exported to West Africa 

Figure 6-14  Global PM2.5 and ozone concentrations in 2010 
Figure 6-15  global PM2.5 and ozone concentrations in 2015 
Figure 6-16  Change in transportation attributed concentration (TAC) PM2.5 and ozone 

and Black Carbon (BC): 2010 to 2015 

Figure 6-17  Transportation attributed fractions (TAF) of PM2.5 and ozone death in 2015 
Figure 6-18  Total number of transportation-attributed PM2.5 and ozone death in 2015 by 

world region 

Figure 6-19  global PM2.5 and ozone concentrations in 2015 
Figure 6-20  Denmark: Pay-out for ELVs and number of ELVs collected 
Figure 6-21  Sales of passenger cars in the EU (2009-2035) 
Figure 6-22  Development of the stock of passenger cars int the EU 
Figure 6-23  EoL Weibull distribution for vehicles 
Figure 6-24  Development of ELVs available for recycling in the EU 
Figure 6-25  Function on the share of non-eligible vehicles per country, depending on the 

distance to the average value of a new vehicle 

Figure 6-26  Cu content in the Fe-scrap and scrap export outside EU 
Figure 6-27  Average mass in running order of new car registrations in the EU and the 

UK by powertrain type 

Figure 6-28  Share of long products in ICV 
Figure 6-29  Share of long products in ICE 
Figure 6-30  Share of metal content in passenger cars 
Figure 6-31  EU vehicle emission standard of retrieved petrol vehicles exported to West 

African countries in the top 12 

XXIII 

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Figure 6-32  EU vehicle emission standard of retrieved diesel vehicles exported to West 

African countries in the top 12 

Figure 6-33  EU vehicle emission standard of retrieved petrol vehicles exported to other 

countries in the top 12 

Figure 6-34  EU vehicle emission standard of retrieved diesel vehicles exported to other 

countries in the top 12 

Figure 8-1 

Figure 6-35  EU vehicle emission standard of retrieved diesel vehicles exported to Lybia 
Figure 7-1 

Timeline of amendments of ELVD, 3R Directive and Directives and 
Regulation on  type approval 
Affiliation of stakeholders (n=61) participating in the public feedback on the 
745 
inception IA 
Answer to the question “I am giving my contribution as: …” (multiple options)  746 
747 
Key words of main aspects discussed in the written contribution (n=58) 

Figure 8-2 
Figure 8-3 
Figure 8-4  Overview of composition of stakeholder registered* for the workshop 

701 

689 

690 

690 
691 

(n=289) 

752 

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DEFINITIONS OF TERMS USED  

Abbreviation 

Full term/ definition 

3R Directive 

Directive  2005/64/EC  on  the  type  approval  of  motor  vehicles  with  regard  to  their 
reusability, recyclability and recoverability 

Art 

ACEA 

ACEM 

ASR 

ATF 

ATV 

BEV 

CE 

CEAP 

CoD 

CRM 

CSDD 

CSS 

Article of a Directive/Regulation 

European Automobile Manufacturers' Association 

European Association of Motorcycle Manufacturers 

Automotive Shredder Residue 

Authorised treatment facility 

All-terrain vehicle 

Battery Electric Vehicle 

Circular Economy 

Circular Economy Action Plan  

Certificate of destruction 

Critical Raw Materials 

Corporate Sustainability Due Diligence Directive 

Chemicals Strategy for Sustainability 

DG ENV 

Directorate-General for Environment 

DPP 

EC 

EEC  

EEE 

ELT 

ELV 

Digital product passport 

European Commission 

Electric and electronic components 

Electric and electronic equipment 

End-of-life tyres 

End of life vehicle 

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Abbreviation 

Full term/ definition 

ELVD 

EoL 

EPR 

ESPR 

EV 

GADSL 

GLARE 

GVW 

GWP 

HDV 

IA 

IMDS 

JRC 

kg 

L 

LCA 

LDV 

M 

MCA  

Misc. 

MS 

N 

NACE 

NRMM 

O 

OEM 

End  of  life  vehicle  Directive;  Directive  2000/53/EC  as  last  amended  by  Directive  (EU) 
2018/849 of 30 May 2018 

End of life or End-of-life  

Extended Producer Responsibility 

Ecodesign for Sustainable Products Regulation  

Electric Vehicle 

Global Automotive Declarable Substance List 

Glass laminate aluminium reinforced epoxy (fibre metal laminate) 

Gross Vehicle Weight 

Global Warming Potential 

Heavy Duty Vehicle 

Impact assessment: the study that this Inception report describes 

International Material Data System 

Joint Research Centre 

Kilograms [unity of weight] 

L-type approved vehicles: Motor vehicles with less than four wheels [but does include light 
four-wheelers]  

Life cycle assessment 

Light Duty Vehicle 

M-type approved vehicles: Vehicles having at least four wheels and used for the carriage 
of passengers  

Metal Content Assumption as defined by Commission Decision 2005/293/EC 

Miscellaneous 

Member State of the European Union  

N-type approved vehicles: Power-driven vehicles having at least four wheels and used for 
the carriage of goods 

Statistical Classification of Economic Activities in the European Community 

Non-road mobile machinery 

O-type approved vehicles: Trailers (including semitrailers) 

Original Equipment Manufacturer. In principle tier 1 and tier 2 suppliers of the automotive 
sector can be also OEMs. However, in this study OEM refers to the vehicle producers. 

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Abbreviation 

Full term/ definition 

OPC 

PAH 

PGM 

PO 

POM 

Open Public Consultation 

Polycyclic aromatic hydrocarbons 

Platinum group metals 

Policy option 

Put on the market 

POP-Regulation 

Regulation (EU) 2019/1021 of the European Parliament and of the Council of 20 June 
2019 on persistent organic pollutants 

PRO 

PST 

PTW 

PVC 

REACH 

REE 

RoHS 

SCIP 

SHF 

SLF 

SME 

SRM 

t 

TOR 

UEA 

UK 

VIN 

WEEE 

WFD 

Producer responsibility organisation 

Post Shredder Technology 

Powered two- and three-wheelers 

Polyvinyl chloride 

Regulation  1906/2007/EC  concerning  the  Registration,  Evaluation,  Authorisation  and 
Restriction of Chemicals (REACH), establishing a European Chemicals Agency (ECHA) 

Rare earth elements 

Directive  2011/65/EU  on  the  restriction  of  the  use  of  certain  hazardous  substances  in 
electrical and electronic equipment 

Database on Substances of Concern In articles as such or in complex objects (Products) 

Shredder heavy fraction 

Shredder light fraction  

Small and medium enterprises 

Secondary raw materials 

Tons [unity of weight] 

Terms  of  reference  (07.0201/2020/839200/SFRA/ENV.B.3)  for  this  project  under 
Framework contract ENV.F.1/FRA/2019/0001 

United Arab Emirates 

United Kingdom 

Vehicle  identification number is  a  unique  code,  including  a serial  number,  used by the 
automotive industry 

Waste electric and electronic equipment 

Waste Framework Directive: Directive 2008/98/EC of the European Parliament and the 
Council of 19 November 2008 on waste and repealing certain Directives, as last amended 
by Directive (EU) 2018/851 of 30 May 2018 

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Disclaimer 
“The information and views set out in this report are those of the author(s) and do not necessarily reflect the 
official opinion of the Commission. The Commission does not guarantee the accuracy of the data included in this 
study. Neither the Commission nor any person acting on the Commission’s behalf may be held responsible for 
the use which may be made of the information contained therein.” 

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Executive Summary  

Abstract 

The “Study to Support the Impact Assessment for the Review of Directive 2000/53/EC1 on 
End-of-Life  Vehicles”  is  to  assist  the  European  Commission  in  developing  the  impact 
assessment  for  the  revision  of  the  End-of-Life  Vehicles  Directive  (ELVD),  also  looking  at 
Directive  2005/64/EC (3RD)2  (amendment  of contract).  It  aims to  address  shortcomings  in 
the  ELVD  identified  in  the  EC  evaluation  report3,  providing  where  possible  quantitative 
information on potential impacts of various policy options compared to the “business as usual” 
scenario.  This  allows  exploring  options  for  the  revision  of  the  ELVD  and  the  3RD  through 
assessing their impacts. The study develops and assesses impacts of the identified policy 
options based on environmental, economic, and social impacts, in line the BRG4. 

Executive Summary  

Introduction and context  

The Directive 2000/53/EC on end-of-life vehicles (ELVD) was adopted in 2000 with the aim 
of preventing waste from vehicles, promoting the reuse, recycling, and other forms of recovery 
of  end-of-life  vehicles  (ELVs)  and  their  components,  and  improving  the  environmental 
performance  of  all  economic  operators  involved  in  the  life  cycle  of  vehicles.  It  sets  out 
measures on waste prevention, the collection and environmentally sound treatment of ELVs, 
sets  targets  for  the  reuse  and  recycling  (85%)  as  well  as  reuse  and  recovery  (95%)  of 
materials and components from ELVs, and includes requirements for providing information 
on components and materials used in vehicles. 
An evaluation of the ELVD was published by the EC on 15 March 2021. It identified various 
shortcomings in the Directive and in its coherence with the corresponding 3R type-approval 
Directive. The ELVD Directive also needs to be reviewed in the light of the orientations set 
out  by  the  European  Green  Deal  and  the  Circular  Economy  Action  Plan,  which  define  an 
ambitious agenda to transform the European economy, based on a modern, competitive, low 
carbon and circular industry, and the recently adopted EU legislation on waste management. 
The general objective of this final report of the “Study to Support the Impact Assessment for 
the Review of Directive 2000/53/ES on End-of-Life Vehicles” is to support the preparation of 
the  impact  assessment  for  a  new  regulatory  framework  for  the  ELVD  conducted  by  the 
European  Commission,  as  well  as  its  coherence  with  the  corresponding  3R  type-approval 
Directive. 

1 Directive 2000/53/ES of the European Parliament and of the Council of 18 September 2000 on end-of life vehicles. See: EUR-Lex - 

32000L0053 - EN - EUR-Lex (europa.eu) 
2 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 and amending Council Directive 70/156/EEC, see 
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32005L0064  

3 COMMISSION STAFF WORKING DOCUMENT 
EVALUATION of Directive (EC) 2000/53 of 18 September 2000 on end-of-life vehicles {SWD(2021) 61 final} 

2 BR-GL-Chapter 3-Impact assessment (europa.eu)  

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Impact assessment framework, methodology, and stakeholder consultation 

The approach to structure this study follows the EC Better Regulation Guidelines5 and the 
Better Regulation Toolbox6, which define a set of key questions that an impact assessment 
(IA) must answer. The study includes the development of policy options (PO) that are to be 
analysed and compared. The IA is focused on measures that should help to solve various 
problems and to achieve the four main objectives ‘comprehensive coverage of the sustainable 
production and dismantling of all relevant vehicles by the Directives’, ‘improving the design 
and production of vehicles to support reuse and recycling’, ‘addressing the problem of the 
ELVs of unknown whereabouts’, and ‘analysis of Extended Producer Responsibility (EPR)’. 
In this regard, the study was structured as follows:  

1.  Problem definition per Objective: identification of the current situation and the main 
problems/shortcomings affecting the ELVD, and who is affected by this. This includes 
their scale, causes, and consequences, as well as the likelihood that they persist in 
the  absence  of  EU  policy  intervention.  Furthermore,  the  problem  drivers  were 
identified. 

2.  Identification of policy options for reviewing the ELVD per Objective: the main general 
measures  that  should  be  pursued  to  address  the  problems  were  identified  for 
improving  the  effectiveness,  efficiency,  relevance,  and  consistency  of  the  ELVD. 
Policy options cover the whole Directive and were presented against the objectives 
for the review of the Directive. 

3.  Analysing the impacts of the different policy actions and providing a comparison of the 
different options: For each measure, different actions were developed that consider 
the  opinion  of  the  European  Commission  and  consulted  stakeholders.  Their  likely 
social,  environmental,  and  economic  impacts  were  assessed.  Finally,  monitoring 
possibilities were outlined. A wide range of possible actions were identified to improve 
the  current  legal  framework.  Based  on  the  detailed  assessments  and  proposed 
choices for actions (sub-measures) per measure, this final report compares different 
sub-measures and concludes in a preferred sub-measure for each measure.  

A stakeholder consultation process was performed to ensure that stakeholders' views were 
sought on all key impact assessment questions and to provide relevant information and data 
for  assessing  the  measures  of  this  study.  In  the  consultation,  industry  associations 
(producers, manufacturers, traders, and recyclers), environmental protection organisations, 
general public, consumers, MS public administration, and other stakeholders (e.g., academia) 
were consulted. In particular, targeted interviews were carried out. Furthermore, a series of 
sectoral consultation meetings and a MS Expert Group meeting were held.  

5 COMMISSION STAFF WORKING DOCUMENT Better Regulation Guidelines, SWD (2017) 350. See: 
https://ec.europa.eu/info/sites/info/files/better-regulation-guidelines.pdf 

6 See: https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-regulationwhy-and-how/better-
regulation-guidelines-and-toolbox/better-regulation-toolbox_en 

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Current situation and potential measures 

Circularity of vehicles  

•  The  CEAP  explicitly  addresses  the  revision  of  EU  legislation  on  ELVs  with  a  view  to 
prevent waste, increase recycled content, promote safer and cleaner waste streams, and 
ensure high-quality recycling. The CEAP inter alia aims at a reduction of waste by linking 
design issues to end-of-life treatment and introducing rules on mandatory use of recycled 
materials  for  the  construction  of  vehicle  components.  Further,  it  imposes  efforts  to 
promote  more  circular  business  models  in  the  automotive  industry.  In  the  context  of 
circularity,  the recently  adopted  Chemicals  Strategy  for  Sustainability  also  strives for a 
safe and sustainable-by-design approach and for non-toxic material cycles. The current 
ELVD needs better consistency with the objectives of the European Green Deal and the 
Circular Economy Action Plan since it does not sufficiently address key areas. 

•  The analysis of the current situation regarding design for circularity (including design for 
dismantling, the presence of hazardous substances, and type approval provisions), re-
use and recycling, market conditions for recyclates, as well as the management of specific 
raw materials in vehicles (e.g. steel, aluminium, copper, glass, neodymium, and PGMs) 
shows that there is significant room for improvements.  

•  The production of vehicles has experienced important changes since the adoption of the 
ELVD 20 years ago. This is especially the case for the increasing use of new materials, 
technologies, and components in vehicles, such as plastics, carbon fibre or electronics, 
which pose challenges for their dismantling, recovery and recycling. In addition, the proper 
dismantling of vehicle parts and materials is becoming increasingly complex. The vehicles 
currently on the market are more difficult to dismantle and recycle than they were in 2000, 
when the ELVD was adopted. The problem is caused by manifold reasons, for example 
too general and vague provisions of the ELV Directive and the associated 3R Directive or 
a  lack  of  incentives  for  car  producers  to  optimise  vehicles  for  improved  end-of  life 
treatment. Without EU intervention, the contribution of vehicle production and dismantling 
to the goals of a circular economy (reuse, repair, and recycling), is expected to decrease. 
•  Policy options related to the problems identified should improve circularity in the design, 
production,  and  end-of-life  treatment  of  vehicles  (objective  2).  More  specific  objectives 
associated with specific life-cycle stages that have been formulated are improve design 
and  production  of  vehicles  to  support  reuse  and  recycling,  increase  the  reuse  and 
remanufacturing rates of parts and components, increase the recycling rates of materials 
and  components,  ensure  transparency  and  a  fair  distribution  of  costs  linked  to  the 
treatment  of  ELVs  along  the  supply  chain,  and  ensure  elimination  of  hazardous 
substances in vehicles. 

•  To achieve the objective, over 20 measures devised to increase the circularity of vehicles 
have  been  developed,  described  (including  expected  outcomes),  and  shortlisted  for 
further assessment (see section on ‘Impact Assessment’ below).  

Missing vehicles  

•  Missing vehicles means that there is an observable difference in the input/output balance 
for  the  European  vehicle  park.  When  comparing  the  stock  and  the  input/output,  it  is 
obvious that the reported output does not reflect the total output. As reported in previous 
studies the gap is between 3 and 4 million vehicles. However, there is evidence that the 
stock is even overreported, which would even increase the number of missing vehicles. 
Reasons for missing vehicles are for example the non-reported export of used vehicle to 
other / non-EU-countries or the treatment in not authorised treatment facilities. 

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• 

In consideration of different studies, the detailed input-output flows for 2019 have been 
updated and calculated for EU-27. The result shows that 10.43 million vehicles exited the 
stock of registered vehicles in EU-27, thereof 6.06 million ELVs were treated within the 
EU, 0.97 million were exported to non-EU countries and the whereabouts of 3.4 million 
vehicles is unknown.  

•  Besides, the Intra-EU trade of used vehicles and ELVs, the definition of end-of-life status, 

and the Extra-EU export of used vehicles and ELVs have been analysed. 

•  The overall problem is that the whereabouts of approximately 30 % to 40 % of the M1 and 
N1 vehicles is not known, and it cannot be proven whether the European legislation is 
applied or not. They could be exported without being reported to customs or registration 
authorities, or simply dumped. To date, it is not possible to assess whether all end-of-life 
vehicles are directed to ATFs. 

•  This results in economic losses for the formal sector and social impacts for informal sector 
workers. In addition, it is believed that (some) of the recyclables will be lost if they are not 
directed  to  legal  facilities.  The  problem  is  mainly  caused  by  manifold  reasons  such  as 
market failures, regulatory failures, and behavioural biases.  

•  The  EU  should  react  since  the  problem  of  missing  vehicles  is  well  known  since  2011. 
However, the problem has not changed and continues to endanger the objective of the 
ELV Directive that all end-of-life vehicles should be depolluted and dismantled in ATFs in 
compliance with the minimum requirements of the ELV Directive.  

•  To  address  the  problem  of  missing  vehicles,  the  three  specific  objectives  have  been 
pointed out: ensure that all ELVs are treated in accordance with the requirements of the 
ELV  Directive,  reduce  levels  of  illegal  dismantling  and  illegal  export  of  ELVs,  and 
enforceable criteria to avoid the export of (used) cars which do not meet roadworthiness 
or minimal environmental standards. 

•  An initial assessment of effectiveness and feasibility was completed based on 20 defined 
measures, with the result that some of the measures are considered unavoidable, others 
are discarded or kept on the agenda for later consideration. The preferred measures are 
described  (including  expected  outcomes)  and  shortlisted  for  further  assessment  (see 
section on ‘Impact Assessment’ below). 

Extended Producer Responsibility  

•  The term EPR is not explicitly mentioned in the current ELVD, but some provisions oblige 
the member States to implement basic obligations for the producers. At the same time 
the  WFD  established  detailed  provisions  for  EPR  schemes  in  Article  8  and  8a  for  all 
wastes. 

•  The  analysis  of  the  current  situation  regarding  the  EPR,  including  stakeholder 
involvement, show that the provisions in the ELVD on the producers’ responsibility for the 
management  of  ELVs  are  limited  when  compared  to  the  obligations  for  producers, 
especially regarding financially contribution.  

•  The  overall  problem  is  the  quality  of  recycling  and  cross  contaminations  for  material 
recycling  since  almost  all  countries  allow  to  segregate  the  mentioned  materials  in  the 
shredding process. More challenging regulations in the context of the Circular Economy, 
aiming for a higher quality recycling, might require more effort at ATFs and results in a 
reduced profit of the ATFs. The market conditions therefore do not allow to internalise the 
costs linked to high quality recycling and re-use of materials from ELVs and the current 
EU regulatory framework does not address this problem either. Besides, the system is 
exposed to strong competition of the illegal sector.  

•  The  problem  is  caused  purely  by  economically  driven  factors.  The  Eu  should  react  to 

make EPR in the ELV sector future-proof.  

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•  To  address  the  problem  of  EPR,  the  objective  should  ensure  transparency  and  a  fair 

distribution of costs linked to the treatment of ELV. 

•  The objective is to contribute financially to the collection, treatment, and recycling of ELVs. 
The measures addressing aspects of the EPR are not assessed as a policy option but 
considered as measures under Policy options regards the sections scope / circularity / 
missing vehicles. Several advanced economic incentives were analysed in discussed.  

Extension of the vehicle categories in scope of the ELV Directive  

•  When analysing the burden and benefits of amending the ELVD, also the question of the 
appropriateness of the vehicle categories in scope occurs. The possibility of extending 
the  scope  to  additional  vehicle  categories  is  sought  to  analyse  the  possibility  of 
incentivising a circular approach in the production and end-of-life treatment of vehicles 
currently outside the scope of the ELVD. Where the necessity and feasibility of extending 
ELVD’s scope to additional vehicle categories is discussed, the question also arises as to 
whether this results in consequences for the scope of the 3R Directive7. 
In the EU, 322 million vehicles were registered in 2020. Currently, by unit, ~83 % of all 
vehicles are within the scope of the ELVD (~74 % Passenger cars (M1 type) and ~9 % 
lorries (N1 type)) resulting in 17% of vehicles (by unit) that are not covered. In terms of 
mass, about 33 % (~159 million tons of the stock) are not covered by the ELVD. Vehicles 
that are not covered are powered two-wheelers (PTW) (L), buses (M2, M3), lorries (N2, 
N3),  semi-trailers  (O),  and  special  purpose  vehicles.  Information  that  provides  an 
overview of the current situation of end-of-life treatment and circularity of vehicles not in 
scope of ELVD is rare.  

• 

•  Though the majority of vehicles is covered by the ELVD, significant gaps by weight remain 
with regards to vehicles other than M1 and N1. Six problems associated with the vehicles 
not covered by the ELVD that have been identified are: the potential to contribute to the 
CE of a large share of vehicles is not exploited yet; missing traceability; no legal incentive 
to  design  for  circularity; current  legal  setup  is  insufficiently  harmonized across the  EU; 
inconsistency between scopes of ELVD and 3R Directive; increase of the total amount of 
vehicles. Problem drivers have been investigated in relation to the market and in relation 
to existing regulation. Acting on EU level means to close regulatory loopholes that exist 
between  EU  MS,  avoid  potential  ‘loss’  of  material  resources  and  to  avoid  leakage  of 
pollutants  where  no  or  unsound  treatment  is  applied,  thereby  contributing  to  a  level 
playing field. 

•  Policy options related to the problems identified should ensure a comprehensive coverage 
of the sustainable production and waste management at EoL (dismantling, sorting, reuse, 
recycling,  recovery,  disposal)  of  all  relevant  vehicles  by  the  ELVD.  This  includes  all 
materials and components of the vehicle. 

•  To achieve the objective, twelve measures devised to extending the scope of the ELVD 
have been developed and described (note: none of them has been discarded at a later 
stage). It is important to note that some of these measures only apply to vehicles that are 
not  yet  in  scope,  some  measures  apply  to  M1  and  N1  already  included  in  the  current 
ELVD, and a third set of measures are being considered as new provisions for M1 and 
N1 as well as for those not yet in scope of the ELVD. 

7 Directive 2005/64/EC 2005 on the type-approval of motor vehicles with regard to their reusability, recyclability and 
recoverability. 

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Impact assessment 

Circularity of vehicles  

The baseline reflects what would happen under a “non-policy-change” scenario without new 
policy intervention, and assuming realistic implementation of existing legislation. Under the 
current ELVD any actions taken by manufacturers to increase the circularity of vehicles are 
voluntary, aside from the prohibition of hazardous substances. Such actions are expected to 
continue  and  to  increase  in  magnitude,  however  at  a  slow  pace.  Achieving  the  reuse  and 
recycling target of 85% is expected to become harder in the following years. 

•  A total of six measures were discarded at initial stages based on a viability check. The 
remaining measures have been shortlisted, analysed and grouped into policy options. A 
bottom-up  approach  has  been  developed  to  allow  an  analysis  at  the  material  level  for 
most  measures  and  in  some  cases  also  at  the  vehicle  level.  Assessed  impacts  were 
compiled to evaluate the policy options in an iterative manner, meaning that after their 
assessment  the  policy  options  were  finetuned  and  related  impacts  compiled  and 
analysed.  

•  Measures included under ‘Policy Option 2.1: Design improvements’ are oriented towards 
the  change  of  the  design  of  vehicles  with  a  view  to  improve  the  substance  content  of 
vehicles and stimulate the market for secondary materials in cases where recycling is not 
sufficiently high. Measures have a high level of prescriptiveness, requiring OEMs to apply 
certain changes to their design over time to ensure compliance. Measures included under 
‘Policy  Option  2.2:  Design 
information,  3R  Type  Approval 
modernisation and circularity strategy’ address information or reporting requirements that 
would require OEMs to make changes in design to comply, however without prescribing 
how the design of vehicles is to be changed. Measures included under ‘Policy Option 2.3: 
Improving  the  treatment  of  vehicles  at  end-of-life’  aim  at  improving  the  quantities  and 
qualities of reuse and recycling through requiring waste management operators to comply 
with certain practices, to achieve certain targets and in some cases to align technologies 
with minimum standards. 

improvements  via 

•  The analysis shows that for some materials, some measures might be more effective than 
others, while some measures may have a low return on investment. In order to address 
this, in a second step a set of feasible measures for each material was identified, which 
was  then  in the  focus  of  the subsequent  assessment  of  the final  policy options.  In this 
regard,  a  detailed  analysis  of  the  materials  steel,  aluminium,  copper,  glass,  plastics, 
electric and electronic components, and non-recyclables has been carried out. Besides 
the different materials, further detailed investigations regarding measures on the design 
of  vehicles  and  preparation  for  their  being  put  on  the market  (vehicle  level), measures 
addressing the treatment of vehicles at EoL (vehicle level), and hazardous substances 
have been carried out.  

Based on the results of the material/component specific analysis, the revised policy options 
were analysed. 

The first policy option shows the lowest costs but also does not provide high benefits. Policy 
option 2 and 3 both lead to significantly higher benefits, with PO 3 being slightly more reaching 
but also at a higher burden. These options in particular raise the amounts of components and 
materials that will be recovered from ELV at end-of-life and to some degree also their quality. 
This is particularly important for allowing a decrease in the dependability of the EU on extra-
EU sources (primary but also secondary in some cases). 

PO 2 is generally more prescriptive, making dismantling of various components obligatory, 
whereas PO 3 uses measures such as recycling targets or PST requirements to allow more 
flexibility as to how the objectives are reached.  

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•  Looking at the analysis for steel and copper, whereas for many categories both PO 2 and 
3 show a similar relation of costs and benefits, it seems that PO 2 leads to higher credits, 
meaning that in general this PO is more effective for copper. However, looking at steel, 
PO 3 is assumed to lead to higher benefits as the quality of steel scrap shall improve and 
increase the range of applications for which it can be used significantly. 

•  For aluminium both PO 2 and PO 3 show that there is a need for more stringent regulation 

however in lack of data the preferred option is inconclusive.  

•  For glass, though PO 2 and PO 3 deliver benefits in the same order, main differences are 

expected in favour of PO 2 due to the reduced complexity of monitoring.  

•  For plastics, GWP impacts are not so high, however the benefits in terms of SRM would 
feed  into  the  manufacture  of  vehicles  and  allow  reducing  the  dependency  on  primary 
materials and thus solving the current market failure. Though POC 3 may suggest higher 
benefits, it will also have higher costs. Whether this is justified or not is hard to say, but it 
could also be considered to apply each of the options at a different sage to develop an 
increasing ambition over time. 

•  All options result in more dismantling of electric and electronic components from vehicles, 
increasing the potential for recycling base materials (Fe, Cu and Al) but more importantly 
also  of  precious  and  critical  metals.  Decisions  on  which  electric  and  electronic 
components (EEC) are to be dismantled depend on the objective. If the main objective is 
to improve the removal of copper impurities from Fe and Al scrap (also increasing copper 
recycling  amounts),  dismantling  could  be  an  alternative  for  cases  where  advanced 
shredding and PST are not applied (more flexible approach). When the objective is also 
to improve the recycling of precious and critical materials, the importance of dismantling 
of  EEC  prior to  shredding  increases  and  in some  cases  certain  sub-components (e.g., 
magnets)  may  also  need  to  be  dismantled  form  components  to  ensure  their  sufficient 
recovery. Though for some materials this has an environmental relevance, for others it 
may be more of a geopolitical decision related to the dependency of the EU for supply of 
certain materials 

Missing vehicles (Objective 3) 

Regarding the aspect of missing vehicles and illegal export the situation and problem were 
manyfold discussed with the Member States at different level for instance it was continuously 
a  topic  in  the  working  group  meetings,  respectively  the  TAC  meeting  for  the  ELVD.  As  a 
baseline scenario it is estimated that the situation of 30% to 40% missing vehicles will persist 
without  any  principal  changes.  As  some  Member  States  are  aiming  to  implement  national 
specific legislation, we consider that the baseline (for the entire EU) will improve regards the 
missing vehicles marginally (-2 %). 

All measures were checked for legal or technical feasibility and effectiveness. The remaining 
measures are shortlisted and are grouped for three policy options, namely Policy option 3A 
Enhanced reporting & enforcement, Policy option PO 3B Interoperable national registers and 
harmonisation, Policy option PO 3C EU wide vehicle registration and export controls.  

It is difficult to assess the impacts of measures and policy options addressing the aspect of 
missing vehicles as is has manyfold reasons and diverse stakeholders are affected. As far as 
the impacts are not directly detectable, we established a model, describing the shifts between 
diverse categories of whereabouts. The distinction of the analysed measures is relevant as a 
shift from one to another has different impacts on different stakeholders. 

Th results of the model calculations for the change in missing vehicles due to the effects of 
the different policy options show that it is very likely that the Policy Option PO 3A is at risk to 
fail in generating substantial improvements regards the share / number of missing vehicles. 

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Policy Option PO 3B provides the tools for cooperation between the MS but a clear method 
for the calculation of the change in the vehicle fleet is missing. Therefore, the current problem 
that  a  comparable  performance  monitoring  by  country  regards  missing  vehicles  is  not 
possible will persist and cause limited incentive to improve the overall situation on missing 
vehicles. While the Policy Option PO C is considered as effective regards the quality of the 
exported vehicles it is most likely that exports of older vehicles (without valid certificate) to 
non-EU Member States will even increase (“last chance”) in the period before the restrictions 
enter into force. For the assumptions regards the shifts between the categories we take into 
consideration  that  the  enforcement  date  will  be  2027  and  the  adverse  effects  will  become 
effective in 2025 and the intended effects become visible in 2030. 

The selection of potential impacts was achieved under consideration of BRG Tool #18.  

To investigate the economic impacts, the affected stakeholders were identified. These are 
ATFs,  used  car  dealer,  shredder  plants  and  recycling  industry,  vehicle  owner,  and  public 
authorities. 

As environmental impacts the following five impacts were identified: 

(1) Resources available for recycling if treated in the EU (resources not lost) 

(2) In the method of life cycle assessments (LCA) credits are granted for recycling 

(3) Less waste in receiving (extra EU) countries 

(4) Illegal treatment might not treat all refrigerants from the air conditioning system and 

all waste oil 

(5) It is expected that the illegal ELV treatment is sending the same amounts of steel, 
aluminium  and  catalytic  converter  to  recycling  and  applies  the  same  effort  for 
separation of spare parts. 

Social impacts were identified as: 

(1)  Employment (additional employment subject to social security contributions) 

(2)  Less air pollutant in receiving countries  

(3)  Better road safety equipment of vehicle fleet in receiving countries 

The comparison of the options 3A, 3B and 3 C was completed according to BRG Toolkit #11. 
The  comparison  highlights  economic,  social  and  environmental  impacts,  their  costs  and 
proportionality to the issue at hand, the benefit/cost ratios and the coherence with other EU 
policy objectives. 

As a result, it is shown that all three policy options have their specific shortcomings and a 
combination  of  measures  is  necessary,  addressing  the  different  reasons  for  the  missing 
vehicles.  In  consequence  the  measures  1.1b,  2.3,  1.2-1.7,  1.9,  2.5,  2.6, 2.7b, and  3.3  are 
selected  for  the  preferred  policy  option.  Several  of  the  measures  addressing  the 
implementation of the EPR have also an effect on the missing vehicle and have been added 
to  the  selection.  In  general,  the  interrelation  with measures  selected to  improve  design for 
circularity  and  measures  selected  to  improved  reuse  and  recycling  will  have  additional 
positive impacts on the number of missing vehicles.  

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Extended Producer Responsibility (Objective 4) 

The  measures  addressing  aspects  of  the  EPR  are  not  assessed  as  a  policy  option  but 
considered  as  measures  under  Policy  options  regards  the  sections  scope  /  circularity  / 
missing vehicles. 

Extension of the vehicle categories in scope of the ELV Directive (Objective 1) 

• 

In the baseline scenario, no provisions on vehicles which are not yet in scope of the ELVD 
are added to the ELVD (or related Directives, i.e., type approval and 3R Directive). 
•  The baseline as well as three options (A, B, C) represent the scenarios between which 
impacts  have  been  compared  in  the  detailed  assessment.  The  three  options,  with 
increasing  level  of  ambition,  are Option  A  “Scope  Extension  of  ELV  legislation  and  3R 
Directive  to  all  type-approved  L,  M,  N  and  O  vehicles  with  information  requirements”, 
Option B “Scope Extension of ELV legislation and 3R Directive to all type-approved L, M, 
N and O vehicles with basic requirements”, and Option C “Scope Extension under ELVD 
and 3R Directive with full application of requirements”. 

•  Option A is not recommended, as it is inherent to the nature of information requirements 
that economic burdens, i.e., costs for reporting and administrative burden, are high but 
benefits are not directly expected (highly inefficient). Compared to the problems described 
and  the  extent  of  impacts  in  the  baseline,  measures  of  Option  A  are  considered  not 
proportionate  (low  effectiveness).  Option  B  is  considered  the  preferred  option.  The 
strongest argument is the cost-benefit ratio (efficiency). Measures result in environmental 
benefits,  namely  benefits  from  heavy  metal  restrictions  and  from  formalised  treatment. 
The total economic burden of Option B is considered appropriate in light of the objective 
it will reach and the problems that it will solve. Sub-options of Option C are assessed as 
generally beneficial provided that data is available to tailor them accordingly to the vehicle 
specifications.  This  suggests  that  these  provisions  might  be  considered  for  the  future. 
Another general finding is that regardless of the option chosen, it is important to align the 
scope of ELVD and 3R Directive.

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1.  Introduction 

1.1  Background: Shortcomings of the current ELV Directive  

An  evaluation  of  the  ELV  Directive  (ELVD)  was  published  on  15  March  2021.  It  identified 
various shortcomings in the Directive and in its coherence with the corresponding 3R type-
approval Directive (Williams et. al 2020). 

The European Commission is now investigating options to revise the current EU rules on the 
ELVs with a particular focus on the identified problem areas, as well as the general alignment 
and coherence of the ELV and the 3R type-approval Directives with the sectoral EU policies 
and legislation.  

Special consideration has been given to the implementation of the Directives,  

• 

• 

• 

to  the  comprehensive  coverage  of  the  sustainable  production  and  dismantling  of  all 
relevant vehicles by the Directives (Objective 1 – Scope),  
to  improving  the  design  and  production  of  vehicles  to  support  reuse  and  recycling 
(Objective 2 – circularity), and  
to the problem of the end-of-life vehicles of unknown whereabouts (Objective 3 – Missing 
vehicles).  

In this respect, the impact assessment is focused on measures that should help to solve the 
various problems and to achieve the three main objectives specified above.  

1.1.1  Intervention Logic  

The  problems  identified  in  the  evaluation  of  the  ELV  Directive  as  well  as  other  aspects  of 
importance  raised  through  other  European  policy  (e.g.,  the  CEAP,  the  Green  Deal,  the 
sustainable Chemicals Strategy) were investigated and developed further. On this basis four 
main objectives were developed as well as specific objectives to be achieved. The results of 
these  investigations  and  the  detail  of  the  various  problems  and  drivers  and  the  objectives 
developed respectively are detailed in Section 2 and its parts. The following figure provides 
an overview of the main and specific objectives tackled throughout this report. 

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Figure 1-1  Overview on objectives and specific objectives 

Objective 1: Ensure a comprehensive 
coverage of the sustainable production and 
dismantling of all relevant vehicles by the 
ELV Directive

no specific objectives defined, all  measures addess the (main) objective

Objective 2: Improve circularity in the 
design, production and end-of-life treatment 
of vehicles

Specific Objective 2.1: Improve design and production of vehicles 
to support reuse and recycling

Specific Objective 2.2: Ensure elimination of hazardous 
substances in vehicles

Specific Objective 2.3: Increase the reuse and remanufacturing 
rates of parts and components

Specific Objective 2.4: Increase the recycling rates of materials 
and components 

Specific Objective 3.1: Ensure that all ELVs are treated according 
to minimum technical and environmental requirements

Objective 3: Ensure that all ELVs are treated 
in accordance with the requirements of the 
ELV Directive

Specific Objective 3.2: Reduce levels of illegal dismantling and 
illegal export of ELVs

Specific Objective 3.3: Ensure that any vehciles exported from the 
EU are roadworthy and meet minimal environmental standards

Objective 4: Ensure that the waste 
management of vehciles at EoL is supported 
where necessary by producers so that it 
remains economically feasible 

Support the increase in quantity and quality of recycling for 
materials for which it is currently only marginally feasible as well as 
for materials which are commonly downcycled in current practice

1.2  Methodology of the study 

1.2.1  Impact Assessment according to Better Regulation 

This study is framed by the methods and guidance related to impact assessment, analysis of 
impacts and stakeholder consultation that are outlined in the Better Regulation and its related 
tools. 

The first step has been the definition of an intervention logic for the Directive, where in relation 
to the various problems identified with its current implementation, objectives were defined that 
have  served  as  orientation  for  the  proposal  and  assessment  of  possible  future  measures. 
Along with the intervention logic, it was also of importance to detail the current situation in 
relation to certain aspects and problems and how this is to be considered in the base-line 
option of a case in which the Directive is not changed, and its implementation develops as it 
would  without  any  interventions.  In  relation  to  the  problems  identified,  it  shall  thus  be 
considered whether the problem and its related impacts are likely to persist in the absence of 
action  at  the  EU  policy  level,  as  well  as  whether  their  scale  is  expected  to  increase  or 
decrease. The starting point for the intervention logic is based on the recently published study 
in support of the Commission’s Evaluation of the Directive (Williams et al., 2020). 

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This  study  foresees  the  development  of  policy  options  (PO)  that  are  to  be  analysed  and 
compared. The policy options address the Directive in relation to the main objectives defined 
for the various problems identified and, in this respect, each of them should propose certain 
measures to solve the problems identified through achieving the objectives specified therein. 
How these measures perform and compare in terms of their costs and benefits is analysed 
later, but the objective is to strive for improving the effectiveness, efficiency, relevance and 
consistency of the ELVD. 

It is followed by the assessment of impacts of the policy options based on the combination of 
the single measures that they consist of. For the purpose of the assessment, the main types 
of impacts are considered as a first step, followed by a characterisation of such impacts and 
as far as possible their quantification in quantitative or at least qualitative terms. This is based 
on  a  review  of  available  data  and  literature  as  well  as  information  to  compiled  based  on 
stakeholder input. On the basis of the assessment of the economic, environmental and social 
impacts conducted, a first comparison at the level of specific objectives is performed. These 
later feed into a final comparison of the options compiled for the Directive as a whole. The 
Better Regulation Guidelines, and in particular Tool #57 on Analytical Methods to Compare 
Options or Assess Performance has been considered in this analysis.  

To address the BRG requirement that ‘all relevant impacts should be assessed qualitatively 
and  quantitatively  whenever  possible.  Quantification  of  impacts  will  not  be  possible  in  all 
cases but it is expected that efforts are [made] systematically’, we will document the effort 
that was undertaken to obtain quantitative data, where only qualitative data is available. 

1.3  Synopsis of stakeholder activities 

Stakeholder consultation is an essential part of any impact assessment and is an obligatory 
part of the process aimed at ensuring that all stakeholders have the chance of providing their 
views so that they can be taken into consideration. See the synopsis of stakeholder activities 
detailed in Annex III.  

1.3.1  Consultation Strategy 

Within  the  preparation  of  the  impact  assessment,  the  consultation  of  stakeholders  aims  at 
capturing the views and ideas of relevant stakeholders, allowing them to provide relevant and 
robust information and data for assessing possible options for a new regulatory framework 
on ELVs, incl. the 3R type approval. The following synopsis report was prepared following the 
better regulation guidelines (Tool 55). It outlines the different steps and consultation activities 
which were conducted to feed into the assessment. 

1.3.1.1  Consultation objectives 

The objective is to ensure that stakeholders' views are sought on all key impact assessment 
aspects. The aim is to collect information from stakeholders in relation to the various problems 
and the measures proposed for achieving the objectives defined for each problem and their 
likely impacts. This information will complement information and data gathered through other 
sources (e.g., literature review, existing policy and position papers, Eurostat data and other 
statistical data sources, etc.). All inputs (data, information, etc.) from the consultation shall be 
incorporated into the impact assessment at appropriate points, i.e., information provided by 
stakeholders shall support the analysis of the problems, identification of options that could 
answer the objectives and their analysis.  

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1.3.1.2  Stakeholders consulted 

Relevant stakeholders were grouped as follows:  

• 

Industry associations (automotive industry (OEMs) for different vehicle types including 
material  and  component  suppliers,  dismantlers  (ATFs),  shredders,  recyclers;  including 
small and medium enterprises). The experience and knowledge of the industry located at 
the  different  life  cycle  stages  is  very  important  to  assess  the  impact  of  the  alternative 
policy  options  because  the  measures  tailored  to  a  specific  life  cycle  stage  have 
interlinkages with other life cycle stages. Industrial operators constitute a well-structured 
sector.  There  are  several  organisations  at  EU  level  that  cover  individual  steps  of  the 
material and component supply, production and different end-of-life management steps. 
These  organisations  and  their members (individual  companies)  are  able  to  convey  the 
different interests and views of their members and to provide important input (e.g., market 
developments and other data and information) for the assessment.  

•  Environmental  protection  organisations,  general  public,  consumers.  The 
contribution of environmental NGOs is of high interest to link the particular case of ELVs 
with  broader  considerations  of  circular  economy,  resource  efficiency,  transboundary 
shipment  of  (hazardous)  wastes,  pollution,  i.e.,  environmental  conditions  of  end-of-life 
management  etc.  End-users  and  consumers  directly  experience  the  impact  of  certain 
measures in their day-to-day life (e.g., amendments in vehicle registration processes, e.g., 
temporary  deregistration  or  repairability,  spare  part  availability  and  costs  of  repair).  Of 
particular interest is the fact that their views go beyond purely technical considerations.  
•  MS public administration. This group consists of government experts from all Member 
States, particularly environmental agencies, national EPR organisations, the registration 
and/or type approval authorities, market surveillance bodies. The experience of national 
administrations related to certain measures and options is highly specific and could be 
relevant.  National  administrations  were  consulted  through  a  survey  and/or  through  the 
participation in the meeting for Member States’ representatives. 

•  Other stakeholders, e.g., academia, think tanks, etc., who may have a good knowledge 
and an interest in alternative options and their analysis and assessment were consulted 
on  specific  issues.  Specifically,  representatives  from  the  United  Nations  Economic 
Commission  for  Europe  (UNECE)  and  the  United  Nations  Environment  Programme 
(UNEP) were consulted on the impacts of European ELV framework revision in relation 
to international agreements. Another stakeholder group consulted in the group of other 
stakeholders  is  that  of  vehicle  insurance  companies  playing  an  important  role  at  a 
vehicle’s end-of-life in the case of accidents. 

Lists  of  stakeholders  to  be  consulted  for  the  impact  assessment  study  in  each  of  the 
consultation activities were provided to the European Commission (EC), aiming at a balanced 
representation of the stakeholder groups and the different stakeholders representing various 
sectors and areas. The list covered EU-wide associations and individual companies; different 
sectors from e.g., manufactures to environmental NGOs. An overview of stakeholders that 
participated in each consultation activity is provided in the sub-sections of the summary of the 
stakeholder consultation below. 

1.3.1.3  Consultation methodology 

For the consultation with various stakeholders, different tools were applied. The table below 
(Table 1-1) summarises the individual consultation methods and provides an overview of the 
overall consultation strategy.  

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In comparison to the initial consultation strategy, the elements of consultation of MS as well 
as the follow-up consultation after the workshop were included as additional consultations. It 
was found that some MS have experiences with legislation addressing problems targeted in 
the  review  of  the  ELVD,  and  questions  arising  on  information  provided  by  stakeholders 
required  additional  contacting  to  clarify  their  contributions.  Furthermore,  the  consultation 
activities  in  relation  to  the  “Study  to  develop  and  assess  options  to  review  Directive 
2005/64/EC (3R Directive) and integration of the results into the impact assessment of the 
ELV Directive are summarized within this synopsis”.  

Please note that contributions received in the context of the public consultations published on 
the ”Have Your Say” web portal cannot be regarded as the official position of the Commission 
and its services and thus do not bind the Commission. Furthermore, the contributions cannot 
be considered as a representative sample of the EU population.  

1.3.2  Summary of stakeholder consultations process 

All consultation activities are summarized in the following. 

For  some  of  the  documentations  of  the  stakeholder  activities,  no  general  publication  is 
intended. However, the European Commission was provided with those documentations of 
stakeholder consultation activities not presented in this Annex, if not indicated differently by 
consulted organisations, i.e. where information was not disclosed. 

1.3.2.1  Feedback on the inception impact assessment 

An  inception  impact  assessment  setting  the  pathway  for  the  revision  of  the  ELVD  was 
published on ec.europa.eu8 and open for public feedback between 22 October 2020 and 19 
November  2020.  The  feedback  received  stemmed  from  61  entries.  47  of  the  participants 
submitted  an  additional  document  along  with  their  contribution.  Submitted  documents  and 
entries on the feedback website were looked at and attributed to the different topics of the 
revision.  

8   https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12633-Revision-of-EU-legislation-on-end-of-life-
vehicles 

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Figure 1-2  Affiliation of stakeholders (n=61) participating in the public feedback on 
the inception IA  

Source: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12633-End-of-life-vehicles-revision-of-EU-
rules/feedback_en (access 16.06.2022) 

Table 1-2 provides input as to the various aspects referred to in the different contributions

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Table 1-1  Overview of different methods of the project’s consultation strategy 

What 

Public feedback9 

Online public 
consultation (OPC) 

Targeted consultation  Stakeholder 

workshop 

Consultation of Member 
States 

How 

Why 

No specific format of 
feedback required, 
additional written 
contributions 
possible 
To explain the 
approach and invite 
them to contribute 

Online Questionnaire 
Survey with the possibility 
to provide additional 
written contributions  

To validate/obtain data 
and information and to 
gain opinions on more 
detailed/specific aspects 

Web conference 
interviews 

2-day online meeting 

Ad-hoc survey and 1-day 
meeting 

To validate/obtain data 
and information and to 
gain opinions on more 
detailed/specific 
aspects 

To discuss specific 
aspects, validate 
findings, gather 
additional evidence 

To inform MS on 
measures and policy 
options, to discuss specific 
aspects, gather additional 
evidence and experiences 
from MS  

Who 

All stakeholders  

How data / 
information was 
used in the impact 
assessment 

Information used to 
structure the OPC 
questionnaire, to 
provide an initial 
overview of 
interested 
stakeholders 

Specific stakeholder 
groups 

Identification of opinions of 
specific stakeholder 
groups; participating 
stakeholders were invited 
to the stakeholder work-
shop; for stakeholders 
invited to the targeted 
consultation, identify 
topics to which the study 
team expected the 
interviewed stakeholder to 
contribute 

Selected key stake-
holders from specific 
stakeholder groups 
Validate assumptions, 
understand the 
situation of selected 
key stakeholders, 
information used for 
identification of 
measures and policy 
options for reviewing 
the ELV Directive, 
information used for 
the impact analysis of 
measures.   

Specific stakeholder 
groups 

Representatives / Experts 
of MS authorities 

Information used for 
revising the measures 
and policy options for 
reviewing the ELV 
Directive, information 
used for the impact 
analysis of measures. 

Learn from experiences of 
MS-specific legislation 
already addressing 
problems targeted in the 
review of the ELVD and 
with regards to the 
measures proposed on EU 
level 

Follow up 
consultation 
activities after the 
workshops 
Written feedback on 
the content presented 
in the workshop and 
written exchange  

To gather evidence 
that was requested in 
the workshop, to ask 
clarification questions 
on feedback, opinion 
and information provi-
ded, to request 
additional data 
Targeted stakeholders 

Used for the impact 
analysis of measures 

9   https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12633-Revision-of-EU-legislation-on-end-of-life-vehicles 

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Figure 1-3  Affiliation of stakeholders (n=61) participating in the public feedback on 
the inception IA  

Source: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12633-End-of-life-vehicles-revision-of-EU-rules/feedback_en 
(access 16.06.2022) 

Table 1-2  Number of contributions referring to the topics of review 

Topics of the review  

No. of contributions referring to the topic 

Missing vehicles 

Illegal exports 

Reporting vehicle fleet 

Reporting reuse – recycling 

Definition recycling 

Separate reuse target 

Material specific material targets 

Data accessibility 

Design for circularity 

Recycled target contents 

EPR system 

ELVD scope 

Coherence – substances 

Coherence – definitions 

47 

37 

24 

21 

12 

33 

31 

27 

24 

27 

22 

14 

11 

12 

The  feedback  can  be  found  on  https://ec.europa.eu/info/law/better-regulation/have-your-
say/initiatives/12633-End-of-life-vehicles-revision-of-EU-rules/feedback_en.  

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1.3.2.2  Open Public Consultation 

The stakeholder consultation was held between 20 July 2021 and 26 November 2021 as a 
public  EU  stakeholder consultation.  It  targeted  all  citizens  and  organisations.  The  EC  sent 
invitations to participate to various parties, including stakeholders identified for this purpose 
by  the  consultants.  The  consultation  was  launched  on  the  EU  public  consultation  platform 
and was publicly available throughout the consultation duration. The consultation took place 
in  the  form  of  an  online  survey  and  enabled two  forms  of  input: (a) through  a  stakeholder 
survey (a shorter questionnaire targeting input from “interested citizens with only a general 
interest in the area of end-of-life vehicles”, 10 questions in total; and a longer questionnaire 
targeting  input  from  individuals  with  “specific  knowledge  and/or  interest  about  end-of-life 
vehicles”, 43 questions in total; and (b) additionally, stakeholders were given the option to 
provide written input, e.g., position papers and evidence/data.  

In  total,  208  participants  took  part  in  the  survey  during  the  consultation  period,  see  their 
affiliation to stakeholder groups in Figure 8-2. Of all the organisations that provided input, two 
organisations provided input to the questionnaire through two representatives each (i.e., two 
questionnaires were completed for these organisations).10  

Figure 1-4  Answer to the question “I am giving my contribution as: …” (multiple 
options)  

22

15

19

Trade union

Public authority

Other

Non-governmental organisation
(NGO)
EU citizen

Ergebnis

Environmental organisation

Consumer organisation

Company/business organisation

Business association

Academic/research institution

6

7

2

1

3

67

66

0

20

40

60

80

A total of 57 stakeholders submitted written contributions in addition to the answers to the 
consultation  survey  questions11.  The  contributions  were  first  screened  to  identify  the  main 
issues that they addressed. The following figure shows how many of the written contributions 
referred to a number of specific issues that were also referred to in the OPC survey and give 
a first indication as to the aspects addressed by stakeholders in this format. 

10   Ministry of the Environment of the Czech Republic, and Galloo (a company from the dismantling and recycling sector incl. 
shredder and PST operators).  

11   One stakeholder submitted 2 times answers to the consultation adding two different written contributions.  

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Figure 1-5  Key words of main aspects discussed in the written contribution (n=58) 

30

25

20

15

10

5

0

Notes: (*) including recycled content target 
The category ‘other’ includes: Handling of hazardous components/waste (n=2); (Recycling of) EV (n=6); Remanufacturing; 
Annex I of the EU Directive 2000/53/EC; batteries in electric cars, carbon footprint requirement; role of insurances; ATFs: More 
controls over ATFs, illegal ATFs are more cheaper, but without environmental standards (n=3); ASR (Automotive Shredder 
Residue); batteries are way more heavy than in the ELVD stated; Removal of tyres, batteries etc.  

Source: Own compilation  

The obtained answers to the questions were processed via Microsoft Excel, written input was 
summarized per topic. A summary of the results is found in Annex III. The complete evaluation 
of answers to the open public consultation is among the material that was provided to the 
European  Commission.  A  summary  report,  all  contributions  and  documents  annexed  to 
contributions can be found in Annex III.  

Identical answers to the OPC were received from 

•  VFSE  Automotive  WG  (organisation  size:  micro),  EuPC  Automotive  Division  (micro), 
PlasFuelSys  (micro),  PLASTIC  OMNIUM  -  CLEAN  ENERGY  SYSTEMS  DIVISION 
(large) 

•  Two different individuals of the Ministry of the Environment of the Czech Republic 
•  DEMONTA  Trade  SE  (organisation  size:  medium)  and  Czech  Association  of  Circular 

Economy (large) 

1.3.2.3  Targeted stakeholder consultation 

A targeted consultation (interviews) was held starting in November 2021. The phase was split 
into two rounds of interviews:  

•  The main study interviews held in the period from 03 November to 03 December 2021. 
In  this  round,  the  consultants  conducted  20  interviews,  see  the  list  of  interviewed 
organisations  in  Table  1-1.  One  additionally  invited  stakeholder  (ANEC  BEUC)  did  not 
participate  due  to  the  questions  being  too  technical  for  the  stakeholder  group  they 
represent.  The  group  of  stakeholders  that  participated  in  the  main  study  interviews 
consisted  of  automotive  manufacturers  for  cars,  trucks,  vans,  buses,  and  motorcycles 
(n=3), suppliers of materials and (second-hand) components (n=6), stakeholders involved 
in  the  EoL  management  (n=7),  and  individual  other  stakeholders  including  a  PRO,  a 
registration  and  international  authority  each,  a  stakeholder  representing  insurance 
companies, and environmental NGOs. 

10 

 
 
 
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• 

Interviews  held  in  relation  to  the  3R  Type  Approval  Directive  in  the  period  from 
17 December 2021 to 07 February 2022. The invited group of stakeholders consisted of 
automotive  manufacturers  (n=5),  type  approval  technical  services  (n=3),  type  approval 
authority/  market  surveillance  (n=2),  international  authorities  and  one  stakeholder 
conducting dismantling trials. Inputs were obtained from 8 out of 12 invited stakeholders 
(a few per written contribution only), see Table 1-3. 

The consultation phase was organised as follows: The interviews were distributed internally 
according to the focus of the respective associations or stakeholders and the work focus of 
the  experts.  The  interviewees  were  initially  contacted  indicating  the  goal and  scope  of  the 
study. When no answer was received, reminders were sent. Date and time for the interview 
were agreed on and consultants provided a web conference tool. An interview guideline was 
sent  to  the  stakeholders  in  advance  of  the  meeting.  Due  to  the  extent  of  the  main  study 
questionnaire, it was accompanied by an indication of the sections to which the study team 
expected  the  interviewed  stakeholder  to  contribute  (see  Table  1-1).  Other  sections  were 
included for transparency, and the interviewees could also contribute to the questions therein. 
Often, answers were received with specification of topics of interest for the stakeholders. In 
some cases, stakeholders responded to topics additional to those planned for the interview 
(not displayed in Table 1-1). Only in some cases, was the whole questionnaire subject of the 
interview. Protocols of results were prepared after the interview and sent for approval to the 
respective interview partner. Together with the approval, consultants asked for the permission 
to  cite  answers  given  in  the  interview  in  the  study  report.  If  rejected,  information  was  not 
included in the report.  

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11 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
STUDY TO SUPPORT THE IMPACT ASSESSMENT  
FOR THE REVIEW OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

x* 

x* 

x* 

x* 

x 

x 

x* 

x 

x 

x* 

x 

x 

(x) 

x 

x 

(x) 

x 

x 

(x) 

x 

x* 

x* 

(x) 

x 

x 

x* 

x 

x 

x* 

(x) 

x 

x* 

x 

x* 

x* 

x 

(x) 

x* 

x 

x 

(x) 

(x) 

(x) 

x 

(x) 

x 

x 

x 

x* 

x 

(x) 

x 

x 

x 

x 

x* 

x 

(x) 

x 

x 

x 

x 

12 

x 

x 

x 

x 

x 

x 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
x 

(x) 

STUDY TO SUPPORT THE IMPACT ASSESSMENT  
FOR THE REVIEW OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

(x) 

(x) 

x 

x 

x 

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(x) 

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13 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
STUDY TO SUPPORT THE IMPACT ASSESSMENT  
FOR THE REVIEW OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

x 

x 

x 

(x) 

(x) 

x 

(x) 

x 

x 

x 

x 

x 

Table 1-3  Stakeholders invited to interviews held in relation to the 3R Type Approval 
Directive 

# 

Organisation name 

Input 
provided  

Details of contact 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

United Nations Economic 
Commission for Europe (UNECE) 

Kraftfahrtbundesamt (Germany) 

Ministère de la Transition 
écologique France 

European Automobile 
Manufacturers’ Association (ACEA) 

BMW (manufacturer) 

VW (manufacturer)  

Porsche (manufacturer) 

Stellantis (manufacturer) 

TÜV Nord (Type approval technical 
service) 

IDIADA (Type approval technical 
service) 

Tech4You (operators of IDIS; 
dismantling trials) 

UTAC (Type approval technical 
service) 

Yes 

No 

Yes 

Yes 

No 

Yes 

Yes 

Yes 

No 

No 

Yes 

Yes 

Aspects of 3R type approval covered under 
the interview in the ELVD IA main study 

Contacted but did not respond 

Interview held on 27.12.21 

Written input provided on 07.02.22 

No answer to various attempts to schedule 
an interview (contacted 10.12.21, reminder 
sent on 27.1. and 10.02.22) 

Interview held on 14.01.22, with Porsche 

Interview held on 14.01.22, with VW 

Interview held on 17.12.21 

Scheduled interview was cancelled by TÜV 
Nord, alternative contact details were sent 
without a response when requesting to 
reschedule the interview 

Written input promised, questionnaire sent 
and response requested by mid-January, 
reminders sent on 27.1. and 10.2.22. No 
answer obtained.  

Interview held on 07.02.22 

UTAC provided additions to the Ministère 
de la Transition écologique, France 

See the positions of stakeholders mentioned in Annex III 

Approved interview documentations were gathered and distributed within the study team in 
order to use input of all interviews for developing the measures in further detail and assessing 
related impacts. The input from the targeted consultation has been taken into consideration 

14 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
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for  the  preparation  of  initial  results  and  the  development  of  initial  measures  that  were 
presented  at  the  sectoral  stakeholder  meetings  as  well  as  the  MS  meeting  (see  sections 
below). 

Though in most cases stakeholders gave their consent to cite information provided through 
the interviews, confirmed interview documentation is not intended for publication itself. The 
documentations are among the material that was provided to the European Commission.  

1.3.2.4  Survey in relation to 3R Directive 

A 3R-Directive-specific survey was conducted with stakeholders on this subject in proximity 
to  interviews  (see  section  before).  The  survey  was  developed  similarly  to  the  interview 
questionnaires for consulting three different stakeholder groups: OEMs, technical services, 
and type approval authorities. For all three groups, questions on the link to the ELVD, on the 
process of type approval and on possible future amendments were identical, a stakeholder 
group-specific set of questions was added to each one. The questionnaire was agreed on 
and is available to the European Commission.  

The survey was distributed to OEMs through requesting the association ACEA to send the 
survey  questionnaire  to  its  members.  The  European  Commission  assisted  in  sending  the 
questionnaire to type approval authorities. The survey was also forwarded to type approval 
technical services that had been initially identified but not interviewed. 

Four Member States participated (3 provided the filled-out survey, 1 provided short input per 
email), and one OEM send a confidential contribution. Additional information was received 
from three more organisations/stakeholder groups  

•  one position paper (from ACEA),  
•  one interview in the main study was used to get specific information on the 3R Directive 

(UN ECE/UNEP), and 

•  one  e-mail  with  additional  explanatory  information  was  received,  in  relation  to  the 
information  provided  in  one  of  the  specific  interviews  (from  MS  representatives  from 
France).  

In the round of written feedback in April 2022 (follow-up after the workshop in March 2022), 
a further written contribution from Germany was received.  

Based on the indication of a lot of stakeholders, most of the information cannot be cited in 
this report as information has been provided on a confidential basis or interview 
documentations have not been confirmed by interviewees.  

The positions of stakeholders are summarised in Annex III. 

1.3.2.5  Stakeholder Workshop on 23/24 March 2022 

In cooperation with the Commission, the contractor prepared the stakeholder workshop and 
the Member States meeting (see the chapter on “consultation of MS” below). All meetings 
were organised as web conferences which were hosted by the consultants. In cooperation 
with the EC, the consultants prepared the agenda and an invitation letter, and the EC invited 
participants.  Stakeholder  contacts  from  the  targeted  consultation  were  provided  by  the 
consultants.  Further  selection  of  invitees  was  done  by  the  European  Commission,  e.g., 
participants of the open public consultation. Associations were invited, but, in comparison to 

15 

 
 
 
 
 
 
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the targeted consultation, more individual companies were present. The contractor prepared 
material  to  inform  participants  on  the  contents  of  the  meeting  which  were  send  around  to 
invited stakeholders beforehand. At the meeting, the contractor gave an input (presentation) 
on the current situation in relation to the problems, the measures under consideration, initial 
results and topics for discussion.  
The  meetings  were  structured  according  to  the  topics.  The  agenda  is  provided  below. 
Meetings were facilitated by the consultant’s team members; minutes were prepared of each 
meeting. 

Table 1-4  Agenda of the stakeholder workshop 

Day 1 - THU 23 March 2022 

  Day 2 – FRI 24 March 2022 

EC: Welcome 

Presentation  

9:00-
9:15 

9:15-
10:45 

Current situation + 
measures for 
Design/Reuse + 
Remanufacturing/Recycling 

11:00 
-12:00 

Analysis method + first 
results for Design/Reuse + 
Remanufacturing/Recycling 

  9:00-
9:15 

  9:15-
10:45 

  11:00 
-13:00 

Presentation 
by the 
consultants, 
clarification 
questions 

Presentation 
by the 
consultants, 
clarification 
questions 

12:00-
13:00 

Discussion on 
Design/Reuse + 
Remanufacturing/Recycling 

Discussion  

  14:00 
-15:45 

EC: Welcome 

Current 
situation + 
measures + 
analysis + 
first results 
for Recycled 
content - JRC 

Current 
situation + 
measures + 
analysis + 
first results 
and 
discussion for 
Missing 
vehicles + 
illegal exports 

Current 
situation + 
measures + 
analysis + 
first results 
and 
discussion for 
Scope 

Wrap up for 
each 
objective 

Presentation, 
clarification 
questions +  
Discussion 

Presentation, 
clarification 
questions + 
Discussion 

Presentation, 
clarification 
questions + 
Discussion 

Presentation  

14:00 
-15:30 

15:45-
16:45 

16:45-
17:15 

Pre-conditions for Design/ 
Reuse + Remanufacturing/ 
Recycling: EPR + Access 
to Information (current 
situation + measures + 
analysis + first results) 
Due diligence;  
Hazardous substances;  
NdFeB magnets.  
Overarching aspects 

Presentation  
Discussion 

  16:00-
16:30 

Presentation  
Discussion  

  16:30-
17:00 

Outlook - EC 

Presentation 

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Figure 1-6  Overview of composition of stakeholder registered* for the workshop 
(n=289) 

3 3

6

8

8

17

61

19

8

19

57

35

45

Automotive manufacturer

Associated industry

EoL management

Authorities (Env)

Authorities (Transport)

Authorities (other)

Automotive supply chain

Environmental NGO

Research

EPR/PRO

Consumer/privates

Note: The category of ”automotive manufacturers” includes manufacturers of all types of vehicles, incl. motorcycles, vehicles 
accessible to disabled people, caravanning industry, to name some. / The category of ”associated industry” includes, among 
others, all (secondary) raw material-related industry stakeholders. / (*) The numbers relate to the registrations for the work-
shop. Due to changing audience during and last-minute requests before the workshop, it was not possible to analyse the 
composition of stakeholders in relation to their actual participation. 

Source: own compilation  

Possibilities of participation in the meeting:  

•  To gather input from a larger audience of stakeholders, and additional interaction tool 
(app called Slido) was used during the workshop to survey the views of the participants 
on certain aspects. Slido questions were answered by participants in the course of the 
presentations of the consultants or in the days following the workshop. 

•  For oral contributions, stakeholders could write in the chat the essence of their comment 

and wait to be requested to speak.  

•  After the workshop, all participants had two weeks to submit additional information and 

data to substantiate their views (see section 8.4.7) 

A summary of discussed aspects per topic can be found in the summary of key positions of 
stakeholders in section 8.5.  
For each of the topics, the consultants took into account aspects that were discussed in the 
meetings, and where (updates of) data was provided, e.g., in relation to the material 
composition of L-type approved vehicles, these were feed into the calculation of impacts for 
the final report. 

The parts of the documentation of the stakeholder workshop not intended for publication 
and provided solely to the EC include: 

•  Participants list; 
•  Minutes of the meeting; 
•  Documentation of the chat of the online meeting; and 
•  Slido results. 

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1.3.2.6  Consultation of Member States 

The consultation of MS consisted of two elements: 

a)  Adhoc survey 

A questionnaire for Member State Experts was prepared covering the four topics:  

•  Management of Shredder Light Fraction (SLF) and Shredder Heavy Fraction (SHF),  
•  Fees or taxes to support recycling of ELVs,  
•  Enhanced Producer Responsibility (EPR) System,  
•  Waste management of other types of vehicles. 

The questionnaire was sent out to the MS in February with most MS sending answers prior 
to the workshop, and a few (2-3) sent afterwards . Answers to the questionnaire were provided 
by  15  MS,  namely  Lithuania,  Belgium,  Ireland,  Estonia,  Slovakia,  Greece,  Malta,  Finland, 
Croatia, Spain, France, Czech Republic, the Netherlands, Sweden, and Germany. Additional 
documents were received from Belgium only.  

As for the processing of the data, it is to be said that no statistical evaluation of responses 
was made, but responses are exemplarily summarised for two of the four topics as follows. 
Where  information  from  the  survey  is  used  in  the  main  report,  it  is  referenced,  and  all 
questionnaires are available to the EC. 

Management of Shredder Light Fraction (SLF) and Shredder Heavy Fraction (SHF). In 
6 MS, the disposal of untreated SLF/SHF in landfills is prohibited. 4 MS prohibit the disposal 
in landfills of fractions from post shredder treatment (PST). 4 MS (in case of BE only Flanders) 
allow to consider untreated SLF for the purpose of road construction, within which 3 consider 
it  as  recycling.  Selected  detailed  responses  showed  that  some  countries  defined  certain 
criteria for acceptance of waste at the landfill that have to be fulfilled (e.g., POP content in the 
residues or that the residues intended to landfill cannot be recycled of incinerated anymore). 
BE  (Flanders)  allows  the  disposal  in  landfills  of  fractions  from  PST,  however  the  costs  for 
disposal are higher than the costs for recycling or thermal treatment. Some countries admitted 
that due to a disposal ban in their countries the recycling rates of ELVs increased.  

Waste management of other types of vehicles. In ES, FR, CZ, BE (Flanders), and LT the 
waste management of motorcycles is governed by specific national legislation? This is not 
the case in SK, EL, MT, FI, HR, NL, DE, SE, and IE. In ES, CZ, BE (Flanders), and LT waste 
management of trucks is governed by specific national legislation. This is not the case in SK, 
EL, MT, FI, HR, FR, NL, DE, SE, IE. Of those that do not have specific national legislation, 
several countries (HR, FI, EL, NL, DE) indicated that the treatment of motorcycles and trucks 
is ensured and/or environmental permits for facilities are requested through general waste 
legislation.  Additional  information  on  waste  management  of  other  types  of  vehicles  was 
provided by 4 MS (LT, BE, CZ, DE). 

b)  Member State Workshop on 31. March 2022 

the  contractor  prepared  a  Member  State 
In  cooperation  with 
Representatives workshop in addition to the stakeholder workshop (see above). The meeting 
was organised as web conferences which was hosted by the consultants. In cooperation with 

the  Commission, 

18 

 
 
 
 
 
 
 
 
 
 
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the  EC,  the  consultants  prepared  the  agenda  and  an  invitation  letter,  and  the  EC  invited 
participants. The same material as for the stakeholder workshop was distributed among MS 
representatives  to  inform  participants  on  the  contents  of  the  meeting  beforehand,  also, 
representatives  of  the  MS  were  invited  to  participate  in  the  stakeholder  workshop.  Thus, 
assuming that MS representatives could inform themselves in the stakeholder workshop as 
well  as  with  the  provided  information,  at  the  meeting,  the  contractor  gave  a  very  short 
additional input (presentation) the problems, the measures under consideration, and topics 
for discussion.  

The meeting was structured according to the topics. Additional three presentations were held 
by Member State representatives from France, Belgium, and the Netherlands. The agenda is 
provided in Table 1-5. Meetings were facilitated by the consultant’s team members; minutes 
were prepared and provided to the European Commission. 

Table 1-5  Agenda of Workshop with Member State Representatives 

9:00-9:30  EC Welcome Mattia Pellegrini (DG ENV), Mark Nicklas (DG GROW), Jade Vetters (DG 

GROW) 

09:30-
09:55 

09:55-
12:30 

13:30-
14:30 
14:30-
15:50 

French EPR Scheme Project for ELVs FR Ministry of Ecology, Sustainable Development and 
Energy: Bruno Miraval 

Objective 2: Circularity: Short presentations by the consultants, clarification questions and 
discussion-Moderation by Gael de Rotalier 

•  Point 2.1 - Design, Oeko: Yifaat Baron 
•  Point 2.1.g: - Recycled content targets for plastic, JRC: Thibault Maury 
•  Point 2.2 - Reuse, Oeko: Izabela Kosińska-Terrade 
•  Point 2.3 - Recycling, Oeko: Izabela Kosińska-Terrade 
•  Point  2.4  -  Transparency  and  fair  distribution  of  costs,  Mehlhart  Consulting:  Georg 

Mehlhart 

•  Point 2.5 - Hazardous Substances, Oeko: Katja Moch 

Objective 1: Scope: Short presentation by the consultants, clarification questions and 
discussion (Oeko: Clara Löw)-Moderation by Jaco Huisman 
Objective 3: Missing vehicles: short presentation by the consultants, clarification questions and 
discussion -Moderation by Jaco Huisman 

•  Point 3.1 -Vehicle tracking; Mehlhart Consulting: Georg Mehlhart 
•  Point 3.2 -Illegal dismantling and illegal exports, Mehlhart Consulting: Georg Mehlhart 
•  Point  3.3  -Criteria  to  prevent  export  of  ELVs.  Short  presentation  by  the  consultants, 

clarification questions and discussion, Mehlhart Consulting: Georg Mehlhart 

The Netherlands approach on exchange of information on vehicle registration with the example 
of EUCARIS, NL Vehicle Authority: Idske Dijkstra  

How Missing ELVs are addressed in Belgium (Flanders) through defined recognition criteria, 
BE The Public Waste Agency of Flanders (OVAM): Lies Verlinden 

15:50-
16:00 

Outlook-EC 

19 

 
 
 
 
 
 
 
 
 
 
 
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Table 1-6  Overview of composition of Member State representatives registered* for 
the workshop 

Austria 

Belgium 

Bulgaria 

CROATIA 

Czech Republic 

Cyprus  

Denmark 

España 

Estonia 

Finland 

France 

Greece 

Germany 

Hungary 

Ireland 

Italy 

  Latvia 

  Lithuania 

  Luxembourg 

  Malta 

  Netherlands 

  Poland 

  Portugal 

  Romania 

  Slovakia 

  Slovenia 

  Sweden 

2 

4 

2 

2 

3 

0 

2 

1 

4 

5 

4 

0 

9 

2 

4 

6 

2 

2 

3 

2 

6 

1 

0 

2 

3 

1 

4 

(*) The number relate to the registrations for the workshop. Due to changing audience and last-minute changes during the 
workshop, it was not possible to analyse the composition o stakeholders in relation to their actual participation. 

1.3.2.7  Follow-up after the workshop and ad-hoc consultation 

Discussions during the stakeholder workshop left open several questions and stakeholders 
were  asked  to  provide  information  on  certain  topics  at  the  end  of  each  meeting.  A  list  of 
associations  and  stakeholder  groups  that  submitted  additional  input  after  the  sectoral 
meetings is given below.  

List of stakeholders sending input after the workshop (n=39) 
•  ACEA/HDVs 
•  ADA 
•  Ademe 
•  BASF 
•  BMW 
•  CLEPA 
•  Copper Alliance 
•  Derichebourg Environment 
•  ECOEURO 
•  ECOS 
•  EEB 
•  EGARA 
•  Estonia (MS) 
•  ETRMA 
•  EuRIC 
•  EUROBAT 
•  EU Aluminium 
• 
FEDEREC 
• 
FEAD 
• 
FNA 

• 
FNADE 
•  Galloo 
•  German UBA (MS DE) 
•  German BMUV (MS DE) 
•  Glass4Europe 
•  Holger Luehn 
• 
INDRA 
• 
JRC 
•  Milan Lauko 
•  Mobilians 
•  OVAM (MS BE) 
•  PGM 
•  PRE 
•  Plastics Europe 
•  POCES 
•  Renault 
•  RWD (MS NL) 
•  Sweden (MS SE) 
• 
• 

TERRA 
Thomas Gardin 

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plus one stakeholders that wished to remain anonymous. 

In addition to other consultation stages, several stakeholders were consulted individually in 
terms  of  specific  aspects  of  interest  for  the  consultants.  A  list  of  individually  consulted 
stakeholders and the topic on relation to which they were contacted is provided below. The 
information provided was used for the impact analysis of measures and policy options. 

Table 1-7  Ad-hoc consultation of specific stakeholders 

Stakeholders 
contacted ad-
hoc 
ADEME 

Contacted 
Person 

Eric Lecointre 

German UBA 

Regina Kohlmeyer 

Contacted in relation to specific topic/s 

•  Material composition of L-type approved vehicles 
• 
• 

Calculation of end-of-life trucks based on the Eurostat stock data 
Exchange  about  an  UBA  report  in  publication:  Impacts  of  illegal 
end-of-life vehicle recycling. Identify the environmental, economic 
and business impacts of the unrecognized dismantling of end-of-
life vehicles and the illegal transfer of end-of-life vehicles and derive 
measures to address potential impacts. 

EURIC / Galloo  

Olivier Francois 

EGARA  

Henk-Jan Nix  

EUROFER 

UNEP 

Lubor Kalafus 

Francois Cuenot 

EU Aluminium 

MS representatives 
of Spain, France, 
Czech Republic, 
Belgium/Flanders, 
Lithuania, Italy 

Benedetta Nucci 
Patrik Ragnarsson 
Christian Leroy 
Fernando J. Burgaz 
Moreno, Bruno 
Miraval, Katerina 
Dostalova, Lies 
Verlinden, Kauzonas 
Mindaugas, Letteria 
Adella 

• 

• 
• 
• 
• 

• 

• 

Exchange of documents related to the STAKEHOLDER WORKING 
GROUP  ON 
2015  REUSE/ 
THE  REVISION  OF 
RECOVERY/RECYCLING  TARGETS  MINUTES  FROM  THE 
PLENARY MEETING OF 17 OCTOBER 2005 on the targets and 
alternative approaches.  

Regards existence and characteristics of EPR schemes across EU 
Regarding post-shredder technologies across the EU 

Copper impurities in steel  

About  an 
internationally unified method for carbon life cycle analysis (LCA) 

to  define  and  develop  an 

international  initiative 

About the  average  weight  of  aluminium  bumper carrier frame for 
the purpose to calculate the GWP for different bumpers. 

legislation 

for  waste  management  of 
About  MS  specific 
motorcycles and/or trucks, e.g., on evaluations on changes in the 
material  flows  of  waste  powered-two-wheelers  /  motorcycles  or 
waste  trucks  and/or  assessments  of  the  ecological,  economic 
and/or social impacts of this regulation at national level 

1.3.3  Key positions of stakeholders on specific topics 

1.3.3.1  Circularity  

Design for circularity 

Statistical OPC 
On  the  question  if  there  should  be  an  obligation  on  vehicle  manufactureres  to  improve 
circularity  characteristics  of  a  vehicle  during  the  design  phase,  all  groups  of  stakeholders 
agreed in over 50% to this question. Support was the lowest (51 %) in the category of the 
automotive manufacturers, where almost 25% did not support this option. The highest support 
was  registered  by  environmental  NGOs  (100%),  waste  management  operators  (93%)  and 
public  authorities  (86%).  For  more  details  please  refer  to  ”Analysis  of  open  public 
consultations” (Oeko-Institut e. V. 2022). 

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Written OPC 
Ten contributions mention the topic of (eco-)design specifically. One of the focus topics is the 
design for dismantlability which various stakeholders would like to see promoted through the 
new  regulation (VEOLIA,  EEB,  Federec,  INDRA,  FNADE)  whereas  others  have  objections 
such as:  

• 

• 

• 

‘Life  cycle  approach  more  efficient  to  promote  circularity  than  imposing  design 
requirements’ (Volvo); 
‘Dismantling  provisions  must  not  impair  the  essential  targets  of  safety,  comfort, 
environmental  performance  such  as  fuel/electricity  consumption,  costs  etc’  (Plastics 
Europe); and  
‘Solutions  on  eco-design 
separation/sorting’ (EuRIC) stating that PST sorting should be taken into account.  

therefore  should  not  be  solely  based  on  manual 

Design  for  circularity  could  be  supported  by  sensor-based  technology  (ECI)  and  free 
knowledge sharing and discussion between recyclers and manufacturers (EuRIC, FNADE; 
see also under ‘data availability’). 

Eco-Design is mentioned in combination with the 3R Type Approval Directive by EuRIC in 
terms of merging ELVD and 3RD; and by Federec and INDRA with regards to ‘practicability 
checks’ of recyclability under the 3R Type approval. Volvo suggests that ‘ELVD should focus 
instead on requiring OEMs to have a strategy to cover the 3 Rs’, which is already part of the 
provisions of Art. 6 of 3R Type Approval Directive.  

Another focus is on the means of eco-design to phase out hazardous substances mentioned 
by VEOLIA. Other stakeholders mentioned hazardous substances under the topics of ‘data 
availability’, in combination with recycled content targets or with regards to ‘coherence’.  

Individual aspects include ethical sourcing as part of material decisions in eco-design (ECI), 
less different polymers (‘there are currently 39 different 1types of basic plastics and polymers 
used to make an automobile’, and a proposal from FEAD to limit the use of non-recyclable 
materials based on The Plastics Industry Trade Association, 2016). 

It  should  be  noted  that  in  their  contributions  some  stakeholders  consider  recycled  content 
targets as part of the 3R targets, and some connect the recycled content targets with the topic 
of (eco-) design.  

Interviews 

Regarding non-recyclable materials, the vehicle manufacturing sector generally pointed out 
the benefit of using such materials for light weighting due to the benefits during the use phase 
in terms of emissions reduction. Stakeholders representing the waste phase referred to the 
obstacle that  large  amounts  of  such  materials raise  for  achieving targets  but  were  against 
their  prohibitions,  explaining  that  this  would  affect  innovation,  whereas  proven  materials 
would increase in use and at some point, suffice to develop manufacturing (with less beneficia 
ones being used shortly and then abandoned). 

ATFs referred to the phenomenon of locking components with digital keys (e.g., window wiper 
motor, injector, inverter, mirror, window motor, navigation, etc.) as a problem, explaining that 
it is an obstacle for reuse as a component removed without the key will not be reusable. The 
information does not have to be free, but the price should not be prohibitive for reuse practices 
of ATFs. This is understood to particularly affect establishments that work with multiple vehicle 
models and brands and that do not have contract with specific OEMs. Vehicle manufacturers 
on the other side claim that the locks are of importance for the safety of vehicles, anti-theft 
and provision of the data could disclose proprietary. It is not clear what type of data would be 
at risk. Components that are interchangeable between models and brands were also raised 

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as  a  type  of  component  where  OEMs  are  reluctant  to  provide  data  (e.g.,  when  the  same 
supplier provides multiple vehicles models and brands with the same component) an where 
this can have an effect on the ability to reuse parts.  

As for IDIS, ATFs said that it contained a lot of information but that the level of detail is not 
always sufficient to support dismantling. Information is not available through IDIS for parts 
with reuse potential (the objective of IDIS is to support quick dismantling – ensuring that the 
component remains functional  is  not  always  in  line  with this  objective).  Though OEMs say 
that such data can be accessed under the RMI (Repair and maintenance information systems 
of the OEMs – each is individual to a certain OEM) ATFs complain about the cost of such 
data.  Here  too,  the  information  does  not  have  to  be  free,  but  the  price  should  be  fair  to 
encourage dismantling for reuse.  

Some stakeholders state that the 3R Directive calculation is too theoretical, recommending 
requiring OEMs to also specify how certain parts can be dismantled. The calculation should 
also reflect the ease or difficulty of recycling a part depending on whether it is a mono-material 
of not.   

Workshop  

During  the  workshop  the  issue  of  compliance  of  automotive  manufacturers  with  diverse 
regulations  was  brought  up  (ACEA).  Thus,  new  regulations  should  consider  the  other 
compliance  demands,  in  particular  for  passenger  safety  and  environmental  protections. 
Vehicles  typically  comply  the  existing  regulations  on  the  day  that  they  are  brought  to  the 
market. The changes in regulations that happen during the vehicle lifetime can be covered by 
post-shredder technologies. 

The  idea  to  combine  the  ELV  aspects  from  the  ELV  Directive  and  the  3R  Directive  into  a 
single regulation was also encouraged (ECOS). Additionally, it was proposed to bring the EU 
ELV  legislation  to  the  level  of  the  United  Nations  when  looking  at  lifecycle  provisions 
(UNECE).  

Definitions 

Statistical OPC  

Most  stakeholders  (56%)  agreed  or  agreed  strongly  that  the  ELV  definition  for  recycling 
should be aligned to that of the WFD as this would support a higher level of material recovery. 
Aside from the automotive producers that were mainly neutral, the majority in all stakeholder 
categories supported an alignment. Only 3% disagreed with this statement, however there 
was also a large share of stakeholders that were neutral (40 individuals) or that did not have 
an opinion (31 individuals) making for a total of 40% together with those that did not specify 
an answer (13 individuals). 

Status of parts to be recycled/remanufactured must be clearly distinguished from waste and 
benefit from same conditions as spare parts. EU should establish a harmonized definition of 
waste and non-waste for reuse/remanufacturing purpose. 

Written OPC 

Coherence with the WFD is referred to in a general way (WEEE AUDITS; CRM Alliance) or 
by  pointing  out  specific  needs,  e.g.,  to  exclude  backfilling  from  the  definition  of  recycling 
(FNADE) or the need for harmonized definitions of waste and recycling in order to prevent 
distortions of competition due to different national implementation (FORS). Also, consistency 

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with the landfill directive is mentioned (Plastics Europe). Definition of when a car becomes an 
ELV was also raised (Febelauto) also in the context of vehicles export (FEDEREC), where it 
should be required to present a valid technical control certificate to authorize their export. 

Interviews 

It  is  generally  agreed  that  the  definition  of  recycling  should  be  aligned  with  the  WFD  to 
exclude backfilling. Many stakeholders do not expect that this will change the achievability of 
the  3R  targets  as  backfilling  operations  are  not  so  common  and  does  not  cover  all 
downcycling  operations.  This  is  particularly  understood  to  be  relevant  for  glass,  which  is 
mainly considered recycled through the post-shredder mineral fraction.  

The  need  to  align  the  definition  of  reuse  with  the  WFD  was  raised  in  relation  to  the  later 
reference to ”preparing for reuse”. Changes to the definition could affect what is considered 
waste and what is considered a product and need to look into how they work with the definition 
of  ”end-of-waste”  to  ensure  that  obstacles  are  not  created  for  shipments  of  used  or 
remanufactured  parts.  A  definition  for  remanufactured  components  should  also  be 
introduced to strengthen how such parts are perceived in comparison to reused ones and to 
ensure that remanufacturing practices fulfil minimum requirements.   

A few stakeholders raised the need to define ELVs as compared to second hand vehicle so 
that the differences between these two categories is clearer and easier to enforce for customs 
to prevent illegal exports. 

Workshop  

As  shared  by  a car  manufacturer  representative (Renault), the  current  legal  definition  of  a 
new  product  does  not  allow  inclusion  of  remanufactured  parts.  This  means  that  a  new 
vehicle currently, in legal terms, may not contain remanufactured elements; the entire vehicle 
must be made new, though perhaps using recycled materials. This legal issue is not specific 
to vehicles. However, from a technical perspective, remanufactured vehicle parts are certified 
as  equivalent  in  functionality  and  reliability/safety/etc.  to  new  parts  and  could  therefore  be 
acceptable for use in new vehicles. This legal limitation restricts the sale of remanufactured 
vehicle  parts  to  the  repairs  market.  Also,  there  is  anyway  a  limited  feedstock  of 
remanufactured parts because the long vehicular lifetime means that the current ELVs do not 
offer many parts for remanufacture. Additionally, the term and definitions of remanufactured 
parts should be included in the 3R Type-approval Directive.  

A definition of differentiating between pre- and post-consumer plastics would be helpful as 
well as applicable definitions of ‘open-loop’, ‘closed-loop’, etc. 

In Belgium, each total technical loss means the vehicle is an ELV, regardless of the price of 
repair in the home country or elsewhere. However, total economic loss is not considered in 
the definition of an ELV; such vehicles may be exported from Belgium as damaged vehicles 
without any special conditions. 

Separate Reuse target 

Statistical OPC 

46% of the participants either agreed or strongly agreed with the implementation of a reuse 
target separately from the recycled target. This included all environmental NGOs, most waste 

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operators (53% of the category) and most public authorities (68% of the category). 22% dis-
agreed or disagreed strongly with this option, with the automotive manufacturing sector most 
often providing these answers (51% of the category). 

On the question on which measures would contribute to increase the reuse of vehicles parts, 
the most common answers were: obligation for repair shops to offer customers used spare 
parts  as  an  alternative  to  new  ones,  obligation  for  ATFs  to  remove  certain  parts  of  ELVs 
before shredding to help increase reuse, obligation for car manufacturers to enable (e.g. the 
ATFs)  unlocking  parts  so  that  they  can  be  reused  and  dismantle,  and  obligation  for  car 
manufacturers to provide the dismantling centres (ATFs) information about which parts can 
be used as identical parts in other models of the manufacturer or even other brands. 

Written OPC 

When asked to explain their views, the more common views in support of a separate reuse 
target were that reuse is higher up in the EU waste hierarchy than recycling, also supporting 
circularity. Others explained that before a part is recycled it could be reused. Specific targets 
were explained to allow monitoring reuse, in relation to the “quantity of pieces reintroduced in 
the market” (an indicator of eco-design, and percentage of reuse and repairability) and as an 
indicator of the “efficiency of treatment operations of the authorized centres”. 

Of  those  that  disagreed  with  such  measures  it  was  explained  that  reuse  was  mainly 
economically motivated (if no one needs a particular spare part it’s better to recycle). Though 
reuse was stated to be important, as reuse is market driven it was questioned if targets would 
increase the amount of reuse. It was also said that vehicles that are recycled are often too 
old (20 years) for re-use of parts as well as mentioning that this was also the case for vehicles 
after  a  crash.  Though  reuse  is  said  to  be  practiced  commonly  by  ATFs,  one  stakeholder 
explained that it may not be reported to “avoid reporting taxable income in the ATFs”. 

Additionally,  separate  reuse  target  worsening  quality  and  safety  risks  witnessed  in  the 
informal refurbished vehicles market. Reuse and recycling should be considered as on par 
equivalents if separate targets for each were to be created. 

Interviews 

Regarding  reuse,  many  stakeholders  spoke  against  the  idea  of  separate  targets  for  reuse 
and recycling, explaining that fulfilment of the one may have negative effects on the other. 
Obligatory dismantling to promote the reuse of parts was explained to create significant costs 
while not ensured that the level of reuse would actually increase. ATFs explained that they 
need  flexibility  to  look  at  the  demand  on  the  market  and  respond  through  deciding  what 
components to reuse and which ones not to. This was due to fluctuations in the demand for 
reused components but also in the quality of components of some models. The example was 
given (EGARA) of the engine, where some models may have frequent malfunctions, in which 
case ATFs would avoid their reuse as a minimum guarantee could not be ensured. In some 
models, malfunctions are very rare, so that dismantling for reuse would result in the engine 
being stored for years, also creating large costs. Rather ATFs explain that measures should 
be considered that increase the demand for reused parts, with ATFs than following suit to 
ensure sufficient supply. 

Workshops 

Participants commented that decisions concerning remanufacturing are of high relevance in 
a circular economy, with such processes being essential for encouraging recycling. However, 
it is not recommendable to strictly consider reuse targets for aspects that may not have market 

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options; ELV parts should not be required to be removed before shredding where there is no 
market for reselling such parts. It could be useful to consider environmental issues, market 
forces and overall demand in the recommendation. 

A  target  for  reuse/  remanufacturing  of  parts  could  potentially  be  helpful.  However,  it  is 
necessary to consider the traceability of parts to know which ones would at all be suitable for 
reuse (as opposed to remanufacturing). It can be noted that the age of a used part may be 
much younger than the vehicle in which it is found. Safety should in particular be considered, 
especially for parts relating to vehicle safety (Romania). 

Material specific recycling targets 

Statistical OPC 

The  most  common  answer  to  this  question  (31  participants  or  15%)  supported  that  the 
establishment of material-specific recycling targets would increase the separate recycling of 
materials addressed by targets, their quality, and revenues from sale of such materials while 
also  increasing  the  costs  of  recycling.  12  %  (24  participants)  answered  that  this  would 
increase separate recycling and secondary material quality while also increasing costs. The 
same share of participants estimate that such targets would only increase the recycling costs. 
From  47  respondents  in  the  automotive  manufacturing  sector,  72%  (34  individuals)  stated 
that this would increase costs, while 51% (24 individuals) state that it would increase separate 
recycling of materials. An increase in separate recycling was supported by all environmental 
NGOs,  85%  (5  individuals)  of  which  also  supported  that  it  would  increase  the  quality  of 
recycled materials. Public authorities supported the four options similar, with between 15 and 
11  individuals  (68-50%)  indicating  the  various  options.  Waste  management  most  often 
indicated  that  this  measure  would  support  separate  recycling  of  materials  (71%)  but  also 
increase the costs (60%). 

The vast majority (64%) of stakeholders agreed that material-specific recycling targets have 
an  impact  on  innovation.  This  was  the  most  common  answer  in  all  stakeholder  categories 
with most categories showing 60-70% agreement. Only 8% were against this, while the rest 
did not have an opinion (23%) or did not answer (5%). 

The most common answer to this question was either no answer (79 individuals or 38%) or 
that material specific recycling targets would lead to an increase in high quality recycling, in 
innovative  recycling  opportunities  and  processes  and  in  innovative  eco-design  of  products 
(59  individuals  or  28%).  The  distribution  of  answers  was  quite  similar  among  stakeholder 
categories. 

Written OPC 

When asked to provide detail on answers, one stakeholder stated that “Targets for the entire 
vehicle proved to be effective. Splitting the target into different material-specific ones should 
be done only for improving the quality of recycling and the effectiveness of the directive. They 
should  not  be  legally  binding”.  Against  the  measure  it  was  said  that  ”some  materials  are 
recoverable but without any outlet / market”. 

Materials  mentioned  in  the  context  of  specific  material  recycling  were  the  Platinum  Group 
Metals (PGMs). For glass and plastics, it was mentioned that the costs of recycling are higher 
than revenues while for electronic components it was assumed that revenues were possible. 
In some cases, it was stated that this would allow a greater separation of certain materials 
prior to shredding, like plastics. 

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Stakeholders provided also further details on the question on ”how material-specific recycling 
targets would impact innovation” and introduced negative (e.g. documentation/monitoring will 
be  impossible:  volume  flows  in  tonnes  range,  versus  quantities  in  milligram  range  to  be 
documented; limits the use new materials, e.g., non-recyclables like carbon fibre composite, 
until a viable solutions has been developed and implemented in Europe) as well as positive 
sides (e.g.: increase of development of post-shredding technologies as well as processing 
technologies of secondary raw materials, increase use of secondary raw materials). 

Interviews 

the 

When asked about the option of introducing separate material targets for reuse, many stake-
holders  explained  that  it  was  difficult  to  comment  on  the  targets  proposed  as  whether  a 
specific  value  was  achievable  depended  on  how 
targets  were  measured 
(EUROMETAUX). If recycling is to be measured based on the actual material that is included 
in  the  composition  of  a  specific  vehicle  or  based  on  a  theoretical  value  would  make  a  big 
difference.  Whether  reporting  is  on  the  total  inputs  of  a  materials,  the  amount  sent  by 
operators for recycling or the amount that is actually recycled affects the achievability of a 
target. Also, for some materials like aluminium, there are big differences in the total content 
between models. Luxury cars will have higher amounts but are also more often exported, so 
that an average value may be difficult to fulfil. For steel it was explained that 90% is already 
achieved. The rate could be increased, however every marginal increase from this level will 
also increase the costs significantly. On tyres, views were raised that the market is still very 
much developing in terms of recycling options. Some outlets could be considered to increase 
the total recycling, but have low acceptability with MS (e.g., rubber turf for playgrounds and 
sport fields): 

Workshop 

Material-specific  recycling  targets  should  be  seen  as  an  addition  to  the  common  targets, 
which are applicable for different actors at different legislative levels. The MS mainly report 
data from dismantlers, shredders and ATFs, data which is collected from different points in 
the recycling process. Ultimately, the recycling quota of the MS is reported, not dismantling 
rates. (Swedish EPA). 

Recycled content targets 

For key positions of stakeholders on a recycled content target content for plastic please refer 
to the respective report by the EC Joint Research Center.  

Statistical OPC 

There was one question on other materials (other than plastic) for which a recycled content 
target  should  be  considered  in  the  OPC.  Though  a  few  materials  were  mentioned  in  this 
respect  by  about  a  third  of  stakeholders  (e.g.,  aluminium,  glass  mentioned,  REE  but  also 
PGMs and steel), a larger share of stakeholders (45%) did not provide input, indicating the 
answers ”none”, ”no opinion” or just skipping the question altogether. 

Interviews 

Regarding recycled content for other materials, for most metals it was explained that recycling 
was already quite high, and that a recycled content target would not change this much but 

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rather  create  competition  between  (high  quality)  uses,  which  will  not  result  in  resource 
savings. Recycled content targets should only be considered where there is a market failure. 
Positive  views  were raised  for  plastics  and  in  some cases  for  glass  and tyres,  where  high 
quality recycling is low and where SRM is less common for use in vehicles 

Data accessibility 

Statistical OPC 

In  the  OPC,  when  stakeholders  were  asked  to  specify  what  kind  of  information  producers 
should provide free of charge to ATF, a large number of stakeholders (41%) specified all of 
the available options, namely, information on: 

•  where  dismantled  components  can  be  reused  (which  vehicle  or  brands,  models,  and 

types).  

•  how to correctly remove parts with digital components and how to appropriately prepare 

them for reuse/ installation. 
the duration / effort for obligatory depollution  
the duration / effort for dismantling components for reuse 

• 
• 

There was furthermore strong agreement (over 70%) that manufacturers should provide such 
information in a fair and non-discriminatory manner and at reasonable prices (if any) to all 
ATFs.  Stakeholders  were  also  asked to  indicate  whether  vehicle  manufacturers  should be 
obliged to provide information on the content of certain substance groups to support plastic 
recycling. Here there was a diversity of answers, with a third having no opinion, but also with 
large support for information obligations on flame retardants (66%), plasticisers (49%) and 
stabilisers (46%). 

Written OPC 

Stakeholders  emphasised  the  importance  of  access  to  information  on  vehicle  contents  for 
dismantling and safe treatment of vehicles. Though some stakeholders stressed the need for 
data at model level, in some cases mentioning IDIS. The option to develop a Digital Product 
Passport was also mentioned as well as the option to use a RFID or a QR code.  

Interviews 

ATFs raise the difficulties that they experience with the availability of various data types. IDIS 
was said to include a lot of information however stakeholders of this sector complain that the 
level of data is not homogenous for all models and makes and that the amount of data on 
how to dismantle specific parts is not always sufficient to support the process. Availability to 
data  on  components  that  are  locked  with  a  digital  key  is  problematic.  Though  data  is 
understood  to  be  made  available  by  OEMs  for  a  cost,  ATFs  explain  that  there  is  no 
harmonised  system  and  rather  that  ATFs  need  to  register  for  multiple  systems,  each  with 
separate  costs.  For  facilities  dismantling  vehicles  of  multiple  brands  (and  also  for  repair 
shops) this makes the use of such data prohibitive as the costs paid for access will depend 
on how often a system is accessed. Access to data on the contents of hazardous substances 
may be available through the SCIP data base, but this is not practical to support removal of 
relevant  parts  during  dismantling.  Data  is  not  available  as  to  the  contents  of  hazardous 
substance at the level of the specific component in a specific model (except data on mercury 
in components that need to be removed or lead in Pb-acid batteries. This is a problem for 
example for substances that are prohibited by the POPs Regulation (e.g., DecaBDE) resulting 

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in the need to send plastics with a risk of containing such materials to incineration as the level 
of content cannot be determined during dismantling for each material part separately.  

Workshop  

The concern was raised that if the method for making data available to ATFs is in the form of 
a digital product passport (DPP), that this would probably not all the 250 million vehicles on 
the road that will take several decades to be treated. Either ATFs would not have data for 
these or IDIS will have to continue working even if it is not any more the solution and no new 
information  is  introduced.  Also,  in  relation  to  the option  of  a  DPP,  it  was mentioned  that  a 
single system would need to be developed, rather than having multiple DPP for the vehicle. 

1.3.3.2  Hazardous substances 

Statistical OPC 

The OPC had two questions on hazardous substances:  

The first on whether the revised ELV Directive should ban hazardous substances in vehicles, 
taking  into  account  that  restrictions  on  hazardous  substances  are  also  specified  in  other 
pieces of EU legislation (notably REACH). 66 of the responding stakeholders (32%) were of 
the  view that  all  substances  in  vehicles should  be  regulated  in the future  under  chemicals 
regulation. The same amount indicated that substances prohibited under ELV should remain 
there, but that future prohibitions should be addressed under chemical legislation. In practice 
this  would  mean  that  for  future  prohibitions,  64%  of  stakeholders  would  prefer  regulation 
under chemical legislation than under ELV. Only 20% (41 individuals) were of the opinion that 
substances in vehicles should continue to be regulated under ELV. For waste management 
operators,  public  authorities,  environmental  NGOs  and  dealers  and  repair  shopped  the 
distribution  between  these  answers  was  similar.  Automotive  producers  had  a  stronger 
tendency  to  support  the  options  where  chemical  legislation  would  be  used  for  future 
prohibitions as opposed to the ELV Directive. The situation was similar for citizens and their 
organisations and “others”. Only 6% had no opinion or did not provide an answer. 

To the second question, which, if any, additional criteria for evaluating exemptions from the 
list of substance prohibitions are necessary to allow a more differentiated assessment, the 
answers were quite variable. This is however also due to the fact that 7 different criteria were 
proposed  as  possible  answers  aside  from  “none”  and  “other”.  Most  combinations  were 
indicated 1-2 times, in some cases having support of 6-9 stakeholders. The most common 
answers were to indicate all criteria (46 individuals or 22%), none (30 individuals or 14%), no 
answer (28 individuals or 13%) and the “Criterion on comparison of the use of the restricted 
substance with that of available substitutes in terms of environmental and health impacts (15 
individuals or 7%). All other combinations received less support. 

Asked to provide additional detail, stakeholders stated that: 

•  No  exemption  to  the  list  of  substance  prohibitions  in  the  ELVD,  except  for  limited 
transition,  if  needed.  Substances  meeting  the  criteria  for  CLP  &  SVHC  under  REACH 
should be banned. The ELVD should allow for additional chemicals to be banned, 

•  The  prohibitions  and  Annex  II  of  ELVD  needs  to  be  aligned  with  other  EU  legislations 

• 

(REACH, RoHS, Batteries) concerning hazardous substances (3 stakeholders), 
impossible to give a "single" answer to this incredibly complicated question: as for flame 
retardant: you prefer the vehicle burn, or the people are exposed to a possible endocrine 
disruptor chemical? the answer is not technical, it is political (courage) 

•  Other criteria mentioned:  

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o  CO2 footprint assessment (2 stakeholders), 
o  To check whether the use of the substance creates a risk impossible to manage or 

prevents recycling, 

o  Full life cycle consideration for the existing substance & substitute (2 stakeholders), 
o  Balanced  approach  for  chemicals  management,  climate  aspects  and  circularity  (2 

stakeholders), 

o  Technical and economic feasibility (2 stakeholders). 

Interviews 

Many  stakeholders  when  asked  about  the  options  of  having  all  prohibitions  under  one 
legislation (ELV or REACH), did not really consider this option. Though certain stakeholders 
prefer  REACH  for  (further)  substance  restrictions  (material  suppliers  and  recyclers),  they 
explain that they would rather leave the exemptions for the four heavy metals under ELV as 
the review mechanism is already established. Vehicle manufacturers were the only ones that 
clearly favoured the alternative of having all restrictions under ELV. Though some general 
statements were made as to costs of the exemption process or the environmental benefit that 
accrued so far from the prohibition of the 4 heavy metals, these were not quantified or e.g. 
explained in relation to how costs break down into specific activities.  

Written OPC 

with regards to the prohibition of hazardous substances, coherence with REACH and CLP 
are  mentioned  in  support  of  less  hazardous  substances  (Anonymous,  FNADE,  Swedish 
Government), reminding to the current obligation for reporting in the SCIP database to assist 
recyclers  with  understanding  if  SVHCs  are  present  or  not  is  also  relevant  here.  (FNADE; 
Plastics  Europe),  for  the  assessment  of  hazardous  substances,  uses  and  exposure  as 
established for the risk assessment under REACH should be considered (Plastics Europe). 
Some stakeholder raised very singular aspects. 

Workshop 

The discussion on the hazardous substances part was surprisingly vivid. Some participants 
stressed in the chat that they prefer REACH as central legislation for substance restrictions 
because REACH became a robust legal instrument, and that this horizontal legislation should 
be referred to in all product legislation that restrict the use of substances due to risks. Also 
the coherence issue was noted to avoid different interpretations of legislative text or different 
content of definitions.  

On the other hand it was argued that so far REACH restriction is however barely covering 
chemicals  in  products  as  until  now  this  only  appears  for  textiles  and  PAH  in  rubber.  A 
participant from NGOs claimed that substances that meet the criteria for SVHC under REACH 
and meet the CLP criteria should be prohibited in the new ELV Regulation for supporting a 
toxic-free environment policy purpose. Other participants however reminded that the "hazard" 
approach  does  not  sufficiently  support  “a  true  circular  economy”  as  contaminants  might 
always remain in materials that are however embedded in the solid material and no health 
problem occurs. For this reason, the participant reminded to the risk approach, with exposure 
scenarios, which, in the case of a vehicle is relatively easy to define.  

Besides, various participants reminded the difficulty of the time span until vehicles reach their 
end-of-life that makes the information on chemicals difficult (“How should the recycler and the 
automotive manufacturer know if they can use the material in a new car?” – “If you start now 
a digital product passport etc. the result will (perhaps) be visible/useful in 20years.”) To solve 

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this problem it was proposed to define specific exemptions not only for spare parts but also 
for recycling material. Participants argued that though this would not be in line with the aim of 
a non-toxic environment of CSS, there is a risk that material will not be recycled because of 
legal risk or additional burden, which makes the circular business unprofitable. 

1.3.3.3  Collection / Missing vehicles 

Statistical OPC 

That a charge applicable to the owner during periods of temporary de-registration would help 
ensure that owners follow their obligation to report any change of ownership or export to the 
authority  was  strongly  supported  by  environmental  NGOs,  waste  operators  and  public 
authorities. Only 11% were against this measure, mostly represented by consumers and their 
organisations  who  would  also  be  the  most  negatively  affected  by  such  a  measure.  A  vast 
majority agreed that better traceability should be established between the EU Member States’ 
registration  systems  on  a  legal  status  of  a  vehicle  until  its  final  deregistration.  Including  a 
roadworthiness test as a condition was considered by the largest number of stakeholders as 
an appropriate measure to overcome the problem of ‘illegal exports’ of ELVs and of exports 
of  ELVS  as used vehicles.  Compliance  with  certain  environmental  criteria  was the  second 
most favoured, followed by conditions on maximum age or on maximum mileage. Among 14 
different  options  for  reducing  the  number  of  missing  vehicles,  over  half  of  the  participants 
(52%)  indicated  a  combination  of  at  least  6  of  the  various  options  which  shows  the  high 
support for the implementation of additional measures to reduce the problems related with 
missing vehicles. A total of 46 participants (22%) did not provide an answer, 17 of which were 
from the automotive producing sector.  

Results of a stakeholder consultation held in the course of the study on the ELVs of unknown 
whereabouts (Mehlhart et al. 2017) can provide additional insights as to the pros and cons of 
the various options. Due to former public consultations on the aspect of vehicles of unknown 
whereabouts, exported vehicles and collection, this OPC did not put a strong focus on this 
topic,  but  only  asked  the  questions  summarized  above.  To  display  a  comprehensive 
stakeholder feedback on the topic, the OPC results from a study in 2016 can be found in the 
following box: 

Excurse: Open Public Consultation in 2016 
The `Public consultation on potential measures to improve the implementation of certain aspects of Directive 
on end-of-life vehicles, with emphasis on vehicles of unknown whereabouts´ was open for twelve weeks from 
29 June to 21 September 2016. 
The objective of this public consultation was to receive the views of stakeholders concerned with the topics of 
the consultation. 
The online survey covers 6 topics below: 
1. Keeping track of vehicles within the EU (intra EU trade); 
2. Methods to achieve more complete reporting on extra EU export and ways to distinguish between 
exporting ELVs vs. used vehicle; 
3. Enforcement techniques to reduce illegal dismantling of ELVs at dealers and repair shops (garages) and 
actions to improve ATF compliance; 
4. Public awareness and incentives for ELV tracking and environmental risks; 
5. Aspects to improve coverage and data quality when reporting on ELVs (possible revision of the 
Commission Decision 2005/293/EC); 
6. Persistent Organic Pollutants (POPs) and ELVs. 

According to the conclusion from the OPC in 201612, "there is a broad and joint understanding among all 
stakeholders that the current procedures need further improvement to keep track of vehicles and to 

12 Mehlhart et. al (2017) 

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strengthen the requirement to issue and present a CoD. This applies for the provision of evidence on the 
vehicles fate during a temporary de-registration and also applies for fines to owners which do not provide 
statement of whereabouts for such temporary de-registered vehicles. 
Most of the stakeholder support the implementation of economic incentives for instance fees or refund 
systems to ensure that ELVs are delivered to ATFs. Only car manufacturers and importers oppose such 
economic incentives. 
With regard to the extra EU export of used vehicles (some of them possibly to be considered as ELV) the 
proposal to make Correspondents Guideline No 9 legally binding, many stakeholders oppose this proposal. 
Several stakeholders argue that the current version is difficult to apply, and adjustments are needed before 
making the stipulations legally binding. Also, the approach to ban the extra EU export of used vehicles was 
not supported by the stakeholders. Instead, the stricter enforcement of inspections (when exporting) 
cooperation between IMPEL, police and customs services and the adjustment of reporting on waste shipment 
found strong support by all stakeholders. 
With regard to the fight against illegal treatment within the EU the majority of stakeholders acknowledged the 
need for action in particular the need for national/ regional authorities to perform regular inspections of the 
sector (not only ATF and shredders but with a broader scope for garages, repair shops and spare part 
dealers) to identify illegal operations. Comments expressed the concern that improved burden to ATF only 
might even cause adverse effects (more illegal operator) and inspections should carefully focus to support 
legal operating facilities. 
The proposal to establish minimum requirements for such inspection activities is less supported and partly 
rejected by the car manufacturers and importers. Again, proposals to establish economic incentives to 
strengthen the legally operating sector are opposed by the car manufacturers and importers. The proposal to 
improve the reporting mechanism when issuing a CoD and upon arrival of an ELV at ATFs or shredder 
facilities was in general supported, including the establishment of electronic notifications to the registration 
authorities. 
Supporting public awareness for the management of ELVs is considered as relevant by the stakeholders. 
While penalties to car owners not fulfilling their duties are supported by the vast majority of stakeholders, 
incentives based on funds/ deposits are again opposed by the car manufacturers and importers. 
With regard to the very specific questions how to address aspects of the unknown whereabouts in the 
Commission Decision 2005/293/EC the number of contributing stakeholders decreased slightly however 
beyond 100 contributors provided their option accordingly and supported effectively all proposals with a vast 
majority or at least did not oppose.” 
All replies of the stakeholders to the manyfold questions in details can be found in the mentioned report 
“Assessment of the implementation of Directive 2000/53/EU on end-of-life vehicles (the ELV Directive) with 
emphasis on the end-of-life vehicles of unknown whereabouts13” published by the EC in 2017. 

Written OPC 
The topic was of high interest for stakeholders providing written input. Of 57 contributions, 15 
contained  information  or  opinion  on  vehicles  of  unknown  whereabouts,  13  on  (de-
)registration, and additional 6 on reporting. Contributions on these topics were received from 
all stakeholder groups.  

Workshop 

Topics discussed at the workshop following the presentation of the consultants on the topic 
of missing vehicles were the  

•  The suitability of road-worthiness test where various stakeholders have different opinions 

on details of the use of such test, however, it is seen a ”key question”; 

•  ELV  registration  competencies,  e.g.,  a  MS  representative  pointed  out  that  EU-wide 
information exchange (database) on CoDs accessible by the EU registration authorities 
would  be  an  effective  tool,  industry  agreed.  It  was  clarified  that  EUCARIS,  the  data 
exchange mechanism for vehicle data in Europe, does already have a CoD-message in 
place  to  exchange  the  CoD-info  across  Member  States.  EUCARIS  is  used  by  all  EU 
Member States, however the CoD-message is currently not being used;  

13 Mehlhart et. al (2017) 

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•  vehicles  deregistration,  e.g.,  in  relation  to  the  limitations  of  temporary  deregistration, 
harmonized rules, and automotive industry requested that an automatic deletion from the 
registration  systems  after  seven  years  for  example  like  in  some  MS  should  not  be 
continued 
recyclers pointed out to the responsibilities of insurance companies and  
total technical loss status, but also the definition of an ELV compared to used vehicles 

• 
• 

In general, many stakeholders engaged in the debate. Many of the stakeholders participating 
in the debate shared perspectives and experiences from MS, e.g. from Sweden or Germany 
(MS representatives), the Netherlands (stakeholders engages in repair and dismantling and 
EPR), Belgium (representative of the EPR system) or Latvia, Poland, France etc. (recyclers). 
It  was  pointed  out  by  industry  that  national  systems  may  pass  their  competences  and 
jurisdiction to the higher level. Further, a representative of the Dutch EPR said that a good 
cooperation between the Ministry of Environment and Ministry of Infrastructure/transportation 
(etc.) is key […] to be able to monitor ELVs. Another idea presented by stakeholders were 
‘massive  citizens 
to  dispose  your  ELV’  (recycler  + 
legal  way 
manufacturers).  

information  about 

1.3.3.4  EPR System 

Statistical OPC 

In the OPC, most stakeholders agreed that in order to ensure a high quality of recycling, that 
it  is  necessary  to  compensate  the  ATFs  for  their  dismantling  efforts,  which  are  not 
economically  viable  under  the  current  conditions.  This  was  mainly  supported  by  included 
environmental  NGOs  and  consumer  organisations,  waste  management  operators,  public 
authorities, and citizens but also a fair share of automotive producers (32%). When asked in 
more detail, 56% of all stakeholders agreed that producers should compensate the ATFs for 
their dismantling efforts and for appropriate treatment and disposal of these wastes. Here, 
waste management operators were the most prominent in their support of this aspects. 

Written OPC 

A few written contributions addressed Extended Producer Responsibility aspects, some only 
as  a  simple  need  that  has  to  be  implemented  and  others  with  more  elaboration.  Several 
stakeholders explained the purpose of an EPR scheme to be to affect the design of products 
so  that  they  result  in  less  negative  environmental  impacts.  Others  see  the  EPR  scheme 
mainly as a funding opportunity to e.g. to balance costs for dismantling in particularly when 
secondary materials are more expensive than virgin materials, to boost investment in high-
quality  PST  through  economic  incentives.  One  stakeholder  raised  the  concern  that  the 
creation of an EPR monopoly in which producers have power over where finances and ELVs 
end  up  could  end  up  limiting  the  free  and  fair  competitiveness  of  the  current  network  of 
dismantlers and shredders. 

Interviews 

Waste  management  operator  look  at  the  establishment  of  an  EPR  positively,  in  particular 
where  it  is  necessary to  support the financing  of  components  of  materials  that  need  to  be 
dismantled and treated in a way that is not economical. Though EPRs is exist for some MS, 
a  difficulty  was  raised  that  they  are  usually  run  by  OEMs  without  involving  ATFs  in  their 
management. The difficulties in managing funds for a European EPR were raised in light of 
the frequent exports between countries and also the different costs that waste management 

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results in in each country that would make setting a single fee for an EPR fund at EU level 
tricky.   

Workshop 

Participants commented that there are concerns about what entity has authority over EPR 
schemes.  A  few  stakeholders  mentioned  that  funds  have  not  shown  big  advantages  to 
support the economic feasibility of ATFs and stated that the processes that ATFs should treat 
vehicles  and then  producers  have to cover  negative market value  vehicles  is  the  direction 
that  the  EPR  should  develop,  with  it  being  established  in  the  Directive.  In  contrast  it  was 
mentioned  that  funds  were  effective  in  compensating  unprofitable  labour  (material 
dismantling), allowing the dismantler to compete more effectively with the illegal sector and 
being less dependent on enforcement. A few stakeholders raised the aspect of the CoD and 
the need for more enforcement to lower illegal exports leading to less vehicles being treated 
in  the  EU.  The  EPR  was  mentioned  as  an  option  to  address the  problem  of cars  going to 
other continents and not just for ensuring financial feasibility of ELV treatment.  

1.3.3.5  ELVD Scope 

Statistical OPC 

For  almost  all  stakeholder  categories  participating  in  the  OPC,  over  50%  of  the  individual 
answers were in favour of extending the Directive additional vehicles. The highest support of 
this option was given by environmental organisations (100%), public authorities (90.9%) and 
waste management stakeholders (85.7%). On the question which additional vehicles should 
be  included  into  the  scope  of  the  ELV  Directive,  the  majority  was  in  favour  of  adding 
motorcycles  and  trucks  with  a  higher  preference  for  trucks  from  the  waste  management 
operators and a higher preference for motorcycles from the manufacturers.  

Avoidance of environmental harms to the environment thanks to minimum requirements for 
end-of-life treatment, increased resource recovery and increased recyclability were the top 3 
important  advantages  of  extending  the  scope  of  the  ELVD  largely  supported  by  all 
stakeholder  categories.  Individual  stakeholders  explained  that  including  them  in  the  scope 
would increase the  supply of recycled materials and  lead to better  dismantling, that heavy 
vehicles  are  exported  to  a  larger  extent  than  cars  and  reuse  of  spare  parts  is  not  as 
developed. And illegal vehicle dismantling, and unfair competition take place. This should be 
dealt  with  in  the  legislation.  One  third  had  no  opinion  on  disadvantages  of  the  scope 
extension.  The  most  supported  individual  answers  were  that  “These  other  vehicles  (e.g., 
motorcycles and trucks) have features which are different from the vehicles covered by the 
ELV  Directive,  so  that  the  provisions  of  the  ELV  Directive  are  not  adapted  to  these  other 
vehicles”  (62  individuals  or  30%)  and  “Higher  burdens  for  SMEs”  (48  individuals  or  23%). 
Answers were distributed relatively evenly between the various categories. The stakeholders 
themselves  relativised  their  statements  on  disadvantages  when  asked  to  detail:  Though, 
“motorcycles are small, so it will be a lot of work for a very small number of materials”, and 
“trucks  are  big  and  require  specialised  facilities  for  dismantling”,  stakeholders  say  that 
“recycling facilities  are  suitable  for  all  of the  ELVD  scope”. “Today these vehicles  [it  is  not 
clear which] are already treated in authorized facilities even if they are not covered by the 
scope  of  the  Directive.”  Or:  “The  ELV  change  will  result  in  some  system  changes  and 
investment costs. It however involves an investment for the future. If the demand for recycled 
material is successfully established, it will pay itself back.” 

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More than one third of the stakeholders did not have an opinion on / did not know the areas 
where compliance for motorcycles and/or trucks would be difficult, and 15% said there are 
none.  About  20%  support  that  the  following  measures  may  be  difficult  to  comply  with: 
Material-specific  recycling  targets  (45  individuals  or  22%),  reuse  target  (47  individuals  or 
23%), and recycled content target (38 individuals or 18%). 

Written OPC 

Various stakeholders from the motorcycles sector contributed additional information: ACEM 
emphasises  that  the  sector  consists  of  many  SMEs  that  have  no  experience  with  the 
requirements  of  the  current  ELVD.  Besides  the  quantitative  results  from  a  survey  on  the 
numbers  of  recycled  motorcycles  in  Finland,  SMOTO  brings  forward  the  concern  that  the 
common reuse practices could be undermined by the perceived focus of the current ELVD 
on  recycling  rather  than  reuse.  An  anonymous  stakeholder  (motorbike  manufacturer) 
proposes  non-reusable  parts  for  motorcycles  in  addition  to  those  listed  in  Art.  8  of  the  3R 
Type approval Directive for M1 and N114. FORS (a Polish recycling association) speaks for 
the practice of certificates of destruction for end-of-life motorcycles. A recyclability target is 
preferred whereas recycled content targets and reuse targets are explicitly not recommended 
for motorbikes (Eurofer). 

For  trucks,  Swedish  Government  considers  it  important  to  distinguish  between  light  and 
heavy-duty  vehicles.  If  trucks  were  included,  the  Czech  Ministry  of  Environment  sees 
“problems in their size and different composition of materials”. Generally, for new vehicles in 
scope,  the  regulation  should  prevent  the  phenomenon  seen  for  missing  vehicles,  i.e.,  the 
avoidance of the EU end of life treatment requirements (Swedish Governmental Agencies).  

Six  contributions  focus  on  historic  cars  and  motorcycles.  Current  practice  of  exempting 
historic cars should be pursued.  

Interviews 

Relevant interviewees are ACEA and ACEM presenting the manufacturers of trucks and L-
type  approved  vehicles,  and  ANERVI/AETRAC,  EuRIC  and  EGARA  representing  the  EoL 
stakeholders. To describe the status quo of the dismantling of lorries, the main messages in 
the interviews were that lorries are not just bigger cars, that depollution is in practice in some 
MS,  that  lorry  recycling  infrastructure  is  different  in  different  MS,  and  that  ATFs  that  can 
manage a lorry also manages trailers. As for the status quo of EoL treatment of motorcycles, 
it was noted that reuse is important, that L-type approved vehicles have no chassis which is 
relevant for the definition of what is an ELV. Then, a very small number of L-type approved 
vehicles  are  returned  to  recyclers,  and  that  there  is  no  statistics  on  motorcycles,  e.g.,  no 
separate waste code, right now.  

In relation to potential regulation covering additional vehicles, the clear message was sent 
that vehicles different to M1 and N1 vehicles require specific rules, e.g., that the same 3R 
targets could not apply, and that these vehicles potentially require different exemptions from 
heavy metal restrictions (or new substance restrictions). 

14 wheel suspension (front / rear) incl. triple clamp, swing arm and all damping parts, handle bar, all kind/material of rims, sub-
frame, all kind/material of fuel tank 

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Workshop 

Views  differed  on  exemptions  for  hazardous  substances  in  additional  vehicle  categories. 
Vehicle  manufacturers  were  in  favour  of  a  category  specific  Annex  II,  i.e.,  to  review  the 
application of existing Annex II bans per vehicle category. The issue was also brought up in 
relation  to  multi-stage  built  vehicles,  incl.  wheelchair  accessible  vehicles.  There  is  also 
difficulty if more than one vehicle category applies to a vehicle. 

Stakeholders broadly support that it is currently not foreseen to recommend applying the 3R 
Type approval Directive to multi-stage built vehicles.  

In the workshop, various participants of all stakeholder groups commented on the presented 
data and/or provided additional data (on the calculation of the fleet of motorcycles and lorries, 
on  actual  fleet  data  from  Spain  and  Germany,  ).  ACEA  is  currently  performing  a  study  on 
lorry, with results expected in September 2022.  

A representative from the European Environmental Bureau (Environmental NGO) stated that, 
if  the  scope  of  these  Directives  is  currently  being  discussed, the  discussion  should  not  be 
limited to a scope for only on-road vehicles. 

1.3.3.6  3R Type Approval and its relation to the ELVD 

Current  situation.  Questions  were  asked  to  understand  better  the  role  of  type-approval 
technical  services’,  the  type  approval  authorities’,  and  the  OEMs  in  the  process  of  type-
approvals in general as well as the special part of the 3R type-approval in particular. Because 
this is more for the understanding of the current situation, the answers are not summarised 
here. Stakeholder statements were used in Annex II of the main report when describing the 
process. 

Effectiveness.  Type  approval  authorities  state  that  the  Directive  generally  facilitates  the 
achievement  of  the  3R  targets.  This  is  also  supported  by  OEMs.  However,  this  is  not 
supported  with  data.  Stakeholders  are  of  different  opinion  in  relation  to  whether  the  3R 
Directive facilitates “high-quality” recycling. There is no systematic monitoring or studies that 
compare  between  the  targets  reported  in  type  approval  declarations  of  OEMs  for  specific 
vehicle models and between their actual performance at end-of-life. Quantitative feedback is 
scattered:  

•  The  number  of  3R  Type  Approvals  performed  per  MS  varies  largely:  Some  have  not 
performed any TAs since Directive 2005/64/EC came into force (e.g., Latvia, Finland) but 
do  report  on  Regular  TAs  for  second  stage  of  N  vehicles.  Some  perform  3R  Type 
approvals regularly (6-9 per annum). 

•  One authority estimated the costs for the process at “< 0.25 years FTE per each 3R type 

approval” 

•  Some MS collect fees for the TA, and some do not – sum also depends on certificate type 

(0-600 €). 

•  3 of 5 MS agreed that the 3R TA should cover all stages of multi-stage vehicles (2 did not 

answer the question) 

A second cluster of question was asked around the possible future amendments of the ELVD. 
In general, little to no input is provided on impacts of introducing certain measures proposed 
to be changed in the 3R Directive. One stakeholder (stakeholder shall not be named) is of the 
opinion, that the scope of the 3R Directive should be extended to include additional vehicles. 
Reference to the preferred TRL level of recycling technologies accepted in the ISO calculation 
varied widely between 3-4, 6-7 and 9. 

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On the  merge  of  ELVD  and  3R  Directive. Of the  interviewed  stakeholders,  one  is  of  the 
opinion that there is a missing link and missing references between 3R Directive and ELVD. 
No stakeholder clearly indicated that the stakeholder preferred a merge of 3R Directive and 
ELVD or that it would be meaningful, MS that perform 3R Tas were against a merge with ELV. 
At least, two times China was provided as an example where one legal instrument is in place, 
however, the European market would be more diverse according to stakeholders. Looking at 
the  stakeholder  groups  that  provided  their  input  on  this  topic,  it  should  be  noted  that  the 
stakeholders rarely take the perspective of the end-of-life. An ACEA position paper (ACEA 
2022) refers to the positions of the automotive industry in relation to the merge of 3R Directive 
and  ELVD:  ACEA  “call[s]  for  the  current  legal  framework  to  be  maintained.”  Rather  than 
focusing  on  recyclability,  they  would  like  to  see  their  engagement  in  the  field  of  emission 
reductions  during  the  use  phase,  i.e.,  strategies  focusing  on  light  weight,  acknowledged 
framing it Design for Sustainability.15 Another argument put forward (stakeholder shall not be 
named) is that currently, the responsibilities are distributed, i.e., recyclers fulfil the ELVD, and 
manufacturers  fulfil  3R  Directive  requirements.  A  merge  of  the  Directives  producing  a 
legislation  with  joint  responsibilities  could  increase  innovation  times  and  create  longer 
discussion processes.  

1.3.3.7  List  of  documents  available  to  EC  in  addition  to  the 

synopsis 

•  Public feedback 

o  Feedback is available to the EC 
o  Already  online  available  under  https://ec.europa.eu/info/law/better-regulation/have-

your-say/initiatives/12633-Revision-of-EU-legislation-on-end-of-life-vehicles 

•  Online public consultation (OPC) 

o  Export of data from online questionnaire is available to the EC 
o  Stakeholders’ written contributions are available to the EC 
o  Summary report already available under    

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12633-End-
of-life-vehicles-revision-of-EU-rules/public-consultation_en. 

•  Targeted consultation (main study + 3R type approval interviews) 

o  Confirmed interview documentations 
o  Additional studies or written input sent with the interviews 
o  List of confidential or non-confirmed interview documentations 

15 ACEA „want to point out that, necessary new and innovative materials for achieving the ambitious goals for targeted carbon 
neutrality in 2050 for vehicles might not have appropriate recycling technologies on industrial scale available yet.” 

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•  Stakeholder workshop 

o  Analysis of Slido (interactive tool) questions 
o  Documentation of the chat of the online meeting 
o  Lists of attendees (contains personal data) 

•  Consultation of Member States 

o  Answers of MS to ad-hoc survey are available to the EC 
o  List of registrations16 of MS expert workshop (contains personal data) 
o  Documentation of the chat of the online meeting 

•  Follow up consultation activities after the workshops 

Stakeholders’ written contributions sent after the workshop are available to the EC. 

1.3.4  Data availability 

1.3.4.1  Objective 1 (scope) 

The analysis on the possible extension of the scope of the Directive has shown that there are 
many data gaps related to the issues researched for the purpose of the analysis:  

•  For consistency with other EU initiatives, fleet numbers from EU modelling activities, e.g., 
PRIMES, shall be used. This dataset does not include the full picture for category of L-
type approved vehicles and trailers, see Annex I, chapter 6.1.1 on the completeness and 
robustness of existing data. 

• 

•  There is no general comprehensive summary of data on the material composition of 
the vehicles not in scope of ELVD available but only compositions of individual models 
in specific studies, e.g., LCA. Thus, the conclusions drawn in relation to material-specific 
& weight-related aspects not covered by the ELVD are subject to high uncertainties.  
It is not only the case that there is no general comprehensive summary of data on material 
composition,  but  there  is  also  no  specific  data  for  the  different  drivetrain 
technologies. The analysis in this problem area therefore has shortcomings in the sense 
that  only  one  material  composition  is  available  for  calculation  of  material-specific  and 
weight-related conclusions, although data available for the fleet allows to distinguish, at 
least for buses and lorries, between different drivetrains. 

•  As for the end-of-life management of vehicles not in scope, regulation is MS-specific, if 
it  exists,  thus,  reporting  on  ELVs  not  in  scope  of  ELVD  is  not  available  on  EU  level. 
Moreover, the situation is expected to be different in different MS, e.g., due to more or 
less established cultures of repair and reuse, or due to the existence of EoL management 
infrastructure in a MS, e.g., for lorries and buses. In addition, EoL stakeholders may vary 
among the MS. 

•  Data on good practices for circularity of vehicles not in scope of ELD is sporadically 
available, however, does not allow to draw general conclusions on the status of circularity 
for ELV not in scope. 

For this reason, the assessment currently relies heavily on stakeholder statements.  

16 For technical reasons, we have not downloaded a list of attendees in this case. 

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1.3.4.2  Objective 2 (circularity) 

The analysis on possible options to improve circularity in the design, production and end-of-
life  treatment  of  vehicles  has  shown  that  there  are  many  data  gaps  related  to  the  issues 
researched for the purpose of the analysis:  

•  Data  on  the  existing  type  approval  process  is  based  on  input  from  relatively  few 
stakeholders and was often submitted on a confidential basis. This makes quantifications 
challenges and results in many impacts being referred to quantitatively.  

•  Other chemical legislation that regulates substances used in vehicles is also under review 
in parallel to this study. As there is no clarity in how such legislations shall change, the 
analysis relating to hazardous substances is qualitative in nature. 

•  Data  on  costs  and  benefits  related  to  reuse/remanufacturing  of  various  components  is 
only available for few components, making the estimation of impacts of various measures 
difficult. 

•  Data on dismantling costs is only available for a sub-set of vehicle components and limits 
the  possibilities  to  quantify  impacts  at  vehicle  level,  e.g.,  impacts  on  dismantling  or 
subsequent reuse and pre-shredder recycling. In so far, quantifications are provided for 
specific components to provide an indicative quantification, however how this applies at 
vehicle level has uncertainties. 

•  Little data is available about the costs of specific treatment. In particular the lack of data 

on dismantling, shredder or PST treatment. 

•  There are some findings of shredder/PST facilities available, however their outcomes are 

difficult to compare, and, in some cases, they are contradicting each other.  

•  Very little data is available on the capacities of PST plants and their locations in the EU. 

For this reason, the assessment currently relies on single statements or makes assumptions.  

1.3.4.3  Objective 3 (missing vehicles and illegal export) 

The data availability is assessed in 2011 and 2017 in two studies for the EC, coming to the 
conclusion that it is with best effort not possible to find or calculate valid date for the national 
whereabouts of vehicles. And the objective is here to overcome this problem of inadequate 
data. In this case it is that relevant as without these data it is not possible to prove that all 
ELVs are treated according to the requirements of the ELV Directive (and its future revisions) 
and thus jeopardizing or putting in question relevant parts of the legislation.    

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2.  Current situation and potential measures 

2.1  The circularity of vehicles 

2.1.1  Introduction 

In December 2019 the EC published a Communication on the European Green Deal17, which 
among others refers to the heavy linearity of the EU’s industry, which still relies heavily on 
primary  materials  (“only  12%  of  the  materials  it  uses  come  from  recycling),  and  where 
resource  extraction  and  processing  of  materials,  fuels  and  food  contribute  to  “half  of  total 
greenhouse gas emissions and more than 90 % of biodiversity loss and water stress”. The 
document stresses the need to accelerate the shift towards circularity and intends to “support 
and accelerate the EU’s industry transition”. The Communication further refers to some of the 
actions planned as part of the Circular Economy Action Plan (CEAP)18, which are of relevance 
also  to the  automotive  sector  as  is  clear  from  the  following  sections.  This  includes  among 
others: 

•  Support of the circular design of products, 
•  Prioritise reducing and reusing materials before recycling them, 
•  Strengthening of extended producer responsibility, 
•  The  use  of  an  electronic  product  passport to  provide  information  on  a  product’s  origin, 

composition, repair and dismantling possibilities, and end of life handling, 

The Green Deal Communication also states that the EC will “consider legal requirements to 
boost the market of secondary raw materials with mandatory recycled content” among others 
for vehicles. 

The CEAP, explicitly addresses the revision of EU legislation on end-of-life vehicles with a 
view to prevent waste, increase recycled content, promote safer and cleaner waste streams, 
and ensure high-quality recycling. The CEAP inter alia aims at a reduction of waste by linking 
design  issues  to  end-of-life  treatment  and  introducing  rules  on  mandatory  use  of  recycled 
materials  for  the  construction  of  vehicle  components.  For  instance,  the  uptake  of  recycled 
plastics and more sustainable plastics in vehicles is a targeted measure of the CEAP. Further, 
it  imposes  efforts  to  promote  more  circular  business  models  in  the  automotive  industry, 
incentivizing  innovation,  among  others  by  applying  product-as-service  solutions  and 
eliminating  waste  and  pollution.  Changes  towards  more  widely  adopted  innovative  (eco-) 
design  of  products  could  promote  high  quality  recycling  particularly  for  specific  parts  and 
components,  which  should  be  removed  safely  and  treated  properly,  along  with  recycling 
opportunities.  

In the context of circularity, the recently adopted Chemicals Strategy for Sustainability also 
strives for a safe and sustainable-by-design approach and for non-toxic material cycles: “it is 
necessary  to  ensure  that  substances  of  concern  in  products  and  recycled  materials  are 
minimised.  As  a  principle,  the  same  limit  value  for hazardous substances  should  apply  for 
virgin and recycled material”. This could affect in practice the recycling of certain materials, 
in particular those with long lifespan that contain substances that were not regulated at the 
time of production, but which have since then been restricted (legacy substances) and thus 
may still end up in waste streams for many years to come, mixing with cleaner materials. 

17 COM(2019) 640 final 

18 COM(2020) 98 final 

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In the current ELV Directive, design for circularity is addressed by Article 4(1)(b) which, as a 
means  for  promoting  the  prevention  of  waste,  requires  Member  States  to  encourage,  “the 
design  and  production  of  new  vehicles  which  take  into  full  account  and  facilitate  the 
dismantling,  reuse  and  recovery,  in  particular  the  recycling,  of  end-of  life  vehicles,  their 
components  and  materials”.  However,  the  current  ELV  Directive  lacks  coherence  to  other 
legislation regarding the circular economy. Williams et al (2020) summarise in their evaluation 
report on the ELVD, that “many of these provisions are not sufficiently detailed, specific and/or 
measurable. As a result, they have not brought about real improvements at the EU level to 
match  the  expectations  that  the  car  industry  should  truly  become  a  circular  industry”.  The 
Commission staff working document on the evaluation of Directive (EC) 2000/5319, published 
in March 2021, also refers to these limitations, stating that “the ELV Directive needs better 
consistency with the objectives of the European Green Deal and the Circular Economy Action 
Plan. The ELV Directive does not sufficiently address key areas, notably waste prevention, 
including eco-design of cars to facilitate re-use, repair, remanufacturing, and recycling.” 

Williams  et  al  (2020)  further  state  that  “The  provisions  of  the  current  ELVD  on  design  for 
recycling  miss  the  opportunities  to  improve  vehicle  design  and  maximise  the  recovery  of 
valuable resources”. Though it is the intention of the Directive to promote design for reuse 
and  recycling,  the  ELVD  evaluation  study  concludes  that  the  general  formulation  of  this 
measure has not led to it having a significant impact and suggests including more verifiable 
eco-design measures in the directive. (Williams et al, 2020).  

2.1.2  Current situation 

To  better  understand  the  distance  between  how  the  vehicle  sector  is  expected to  develop 
towards circularity and the scope of activities that currently exist in the sector, affecting the 
flows of primary and secondary materials, it is first necessary to look at the current status of 
materials in the current situation. The following sub-sections attempt to shed light on how the 
design  and  end-of-life  waste  management  of  vehicles  affect  the  flow  of  various  materials 
throughout the value chain. The first sections look at this from the perspective of the value 
chain, starting with the design of vehicles and the background for material choices. This is 
complemented  with  a  sub-section  on  Directive  2005/64/EC  (3R  Directive)  which  forms  an 
interface between the design phase and other life cycle phases, in terms of ensuring that any 
legal requirements to design vehicles, with a view to facilitating their waste management, are 
complied with prior to the vehicle being approved for the European market. 

This is followed by a section on reuse and recycling of vehicles, explaining how various ELVD 
provisions have been implemented and what is achieved under in the status quo of waste 
management. To complete the life cycle and seeing as the integration of secondary materials 
in vehicles has a reliance on the amounts and qualities of recyclates resulting from the waste 
management, the market conditions for recycled content in vehicles are detailed. As these 
sections provide only some concrete examples as to specific materials and components, a 
final section provides detail as to the status quo of various materials, their use in vehicles and 
how they are dealt with at end-of life. This background is to allow to better understand the 
problems and shortcomings of the current ELVD and the related 3R Directive and how they 
correspond to the general objective of increasing the circularity of vehicles.   

19 See SWD(2021) 61 final 

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2.1.2.1  Design for circularity 

To promote the prevention of waste (e.g., facilitate recycling and reuse and avoid the need to 
dispose  of  hazardous  waste)  Article  4(1)  of  the  Directive  requires  Member  States  to 
encourage vehicle manufacturers: 

• 

• 

• 

to  limit  the  use  of  hazardous  substances  in  vehicles,  reducing  their  use  from  the 
conception of the vehicle onwards, 
to design and produce new vehicles taking account and facilitating the dismantling, reuse, 
and recovery (in particular the recycling), of ELVs, their components and materials, and 
to integrate an increasing quantity of recycled material in vehicles and other products, in 
order to develop the markets for recycled materials. 

Some Original equipment manufacturers (OEM) are already investigating how to introduce 
more circularity into the automotive business. This serves as a starting point to consider if 
certain measures could lead to broader benefits when applied evenly in new vehicles placed 
on the European market, through the EU type approval process which creates a level playing 
field for all manufacturers.  

For  example,  Renault  tries  to  integrate  more  circularity  through  using  “recycled  and 
recoverable materials” such as recycled textiles in the new Renault BEV model ZOE. They 
also consider how certain vehicle components could be used for other purposes, such as in 
the  case  of  2nd  life  for  batteries.20  Renault  also  refers  to  reconditioning  of  parts  (or 
remanufacturing) to allow their use when repairing other vehicles.  

With  a  look  to  the  future,  BMW21  has  set  an  aim  to  build  a  recycled  electric  car  by  2040, 
referring not only to its composition from recycled materials but also to its being emission free. 
This  is  assumed  to  mainly  refer  to  the  use  phase,  as  it  can  be  understood  that  use  of 
secondary materials would reduce emissions of the vehicle supply chain, but not eliminate 
them  completely. Whereas  BMW  states that  its new  cars  are  currently made  with close to 
30 %  recycled  materials,  the  new  circular-based  approach  should  increase  this  to  50 % 
recycled content. “After the materials reach the end of the product life cycle from the car, the 
aim  would  be  to  reuse  them  once  again  in  another  model  to  create  a  circular  vehicle 
production  chain”.  On  the  use  of  recycled  plastics,  the  company  states  (2021)  that  25 % 
renewable raw materials and recycled plastics were used in the interior of the BMW i3. The 
textile upholsteries are made of up to 100 % recycled polyester, produced using 34 % PET. 
A further 25 % recycled plastics are used in the exterior. 

In  relation  to  reuse,  BMW  claims  that  “by  choosing  remanufacture  –  the  industrial 
processing of used parts to bring them up to the same standards as new parts – 
over the manufacturing of new parts, reductions of 85 percent of the raw material 
and 55 percent of energy can be made”22. Though reuse and remanufacturing of parts 
are practiced in the automotive industry, the scope of this practice and its further potential is 
unclear as is explained in more detail in 2.1.2.2. 

In the search for innovation some trends may contribute to improving the performance of a 
car but need to be considered also in terms of their contribution to circularity and to the total 
carbon footprint of a vehicle. For example: 

20 See further detail here: https://group.renault.com/en/news-on-air/news/circular-economy-moving-up-a-gear/  

21 See further detail here: https://www.energylivenews.com/2021/09/08/a-recycled-car-bmw-says-yes/   

22 See: https://www.bmwgroup.com/en/responsibility/sustainable-stories/popup-folder/circular-economy.html  

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• 

Increased use of lightweight materials in vehicles like composite plastics, carbon-fibre, 
and fibre- reinforced materials may also necessitate more up-to-date eco-design 
strategies to be included in the ELVD. The use of lightweight materials in the BMW i3, 
such as a carbon fibre passenger cell and an aluminium drive module, are said to 
reduce the vehicle weight and thus increase also its range (BMW 2021). However, how 
the recycling of carbon fibre plastics can be ensured in practice or whether a trade-off 
between recyclability and carbon footprint of the vehicle is acceptable is still to be 
investigated. 

•  The increased use of electric components in vehicles has also become prevalent to 
support new functions and to improve performance. Such components often contain 
various critical and precious metals and are thus of interest at the end-of-life stage as 
possible sources for secondary materials. However, it is not clear if such components, 
for example printed circuit boards, are removed from the vehicle prior to shredding as it 
is required for example under the Waste electric and electronic equipment (WEEE) 
Directive. Whether this is just a matter of better design for dismantlability or also 
hindered for other reasons is still to be seen, however electric components are often 
intensive in various valuable and critical raw materials and their recycling would likely 
improve were they removed and sent to separate treatment or reuse. In this respect, 
EGARA (2020) states “What is also necessary is info how to make parts work. Today’s 
parts have a digital component. If the right procedure for digital installation is not 
followed correctly, perfectly good parts are not usable.” 

2.1.2.1.1  Design for dismantling (to support reuse/recycling) 

As  regards  materials  and  parts  that  are  to  be  dismantled  from  an  ELV  when  it  arrives  for 
treatment,  clear  obligations  for  depollution  and  removal  of  certain  parts  and  materials  are 
detailed in Annex I of the ELVD. Section 3 of Annex I of the Directive requires the depollution 
of batteries and liquified gas tanks, potential explosive components, (e.g. air bags), vehicle 
fluids (e.g., fuel, oils, cooling agents) and components containing mercury. Section 4 requires 
removal of catalysts, components containing copper, aluminium and magnesium, tyres, and 
large plastic components (bumpers, dashboard, fluid containers, etc) when these cannot be 
segregated in shredding processes, as well as of glass. Though the term depollution is not 
defined under the ELVD, it is assumed that it requires parts and materials to be separated 
from the vehicle prior to shredding and treated separately. In contrast, the term removal, also 
not defined under the Directive only means that the material needs to be separated from other 
materials at some stage but leaving more flexibility on whether this is prior to shredding or 
not. The directive furthermore does not make a clear relation between the need to depollute 
or  remove  a  component  or  material  and  the  ease  or  economic  feasibility  of  doing  so. 
Additionally,  according  to  the  rules  on  the  monitoring  of  the  reuse/recovery  and 
reuse/recycling  targets23,  data  on  various  materials  from  de-pollution  and  dismantling  are 
reported on a voluntary basis, whereas disclosure of the sum of these materials is mandatory 
(more information on reporting can be found in the chapter 2.1.2.2).  

Though the Directive refers in Article 4(1) to the facilitation of dismantling, it does not give 
much detail as to how manufacturers should do this. Article 8 of the ELVD addresses ‘Coding 
standards and dismantling information’. It requires producers to “use component and material 
coding  standards,  in  particular  to  facilitate  the  identification  of  those  components  and 

23 Commission Decision of 1 April 2005 laying down detailed rules on the monitoring of the reuse/recovery and reuse/recycling 
targets set out in Directive 2000/53/EC of the European Parliament and of the Council on end-of-life vehicles (2005/293/EC). 

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materials which are suitable for reuse and recovery”. Commission Decision 2003/138/EC24 
was published in February 2003 and specifies which nomenclature of ISO component and 
material coding standards should be used for identification of certain plastic and rubber parts. 
However, as in the case of Art. 8, the decision only requires identification of some material 
parts (plastic and rubber). This can make it easier to identify parts of a certain composition 
and above a certain size but does not facilitate their dismantling in terms of specifying the 
time and tools required for supporting this process. 

To address the aspects and obligations established in Article 8, the car industry established 
the  International  Dismantling  Information  System  (IDIS).  IDIS  provides  dismantling 
information to the ATFs free of charge. 26 manufacturers with 79 brands and 3477 models 
and variants use IDIS to provide dismantling information to close to 7000 registered users 
(e.g. ATFs) in 31 languages in 40 countries25. IDIS contains information on components that 
need to be dismantled according to Annex I, section 3 and 4 of the ELVD (see detail below). 
And yet it can be understood that not all ATFs make use of such information. According to 
Elliott et al. (2019) there are around 12.000 ATFs in the EU, whereas from the above, only 
slightly  over  half  are  registered  to  IDIS  and  it  is  not  clear  if  all  of  these  make  use  of  the 
information  contained  within.  In  this  respect  EGARA  (2021)  explains  that  IDIS  only  shows 
information that the platform receives from the producer, and the interface is not always the 
same. “If you need information to access the auxiliary batteries – you need to click in different 
places”.  The  system  is designed  form  the  perspective  of  what  information  the  OEMs  give, 
whereas  according  to  EGARA  it  should  be  made  from  the  perspective  of  the  waste 
management to ensure that the interface is always the same in terms of how date is relayed 
and in terms of the level of detail. IDIS is full of information, but a lot of times the information 
stops at a level of detail that is not sufficient for ATFs. For example, data on a mercury switch 
in a Mercedes model was sought by EGARA. It took a lot of effort to find it in IDIS and the 
information stopped at the level of a dashboard in which the mercury switch was contained. 
That  does  not  help  understand  how  to  depollute  the  component.  Information  needs  to  be 
presented  in  a  more  harmonised  manner,  structured  form  the  perspective  of  the  ATF  and 
what data in needs to allow the ELV to be processed. A further example given by EGARA 
was a vehicle model of an OEM where the copper wiring was mounted so that there were a 
few points that if accessed, would allow pulling the complete wiring relatively simply. However, 
ATFs were not aware if this and it was not applied in dismantling and was not adopted by 
additional producers.  

At  the  same  time,  OEMs  are  also  required  to  provide  repair  and  maintenance  information 
(RMI) to promote the reuse of parts and components. Provision of such information by OEMs 
was  initially  required  under  EU  Regulations  No  715/2007/EC  and  No  692/2008/EC”26  to 
ensure that independent operators have easy, restriction-free, and standardised access to 
vehicle RMI. The European Commission investigated the operation of the system of access 
to vehicle RMI. “The key issues involve challenges for repairers when accessing RMI directly 
from  OEM  websites.  The  wide  variation  in  user  interfaces  and  software  incompatibilities 
cause  great  inconvenience  to  users,  particularly occasional  users  or repairers that  service 
many  different  brands”.  Additional  aspects  mentioned  were  “different  interpretations  by 

24 Commission Decision 2003/138/EC of 27 February 2003 establishing component and material coding standards for vehicles 
pursuant to Directive 2000/53/EC of the European Parliament and of the Council on end-of-life vehicles (Text with EEA 
relevance) (notified under document number C(2003) 620) 

25 See further detail under IDIS Webpage: https://www.idis2.com/index.php, last viewed 28.10.2021  

26 Regulation (EC) No 715/2007 and Commission Regulation (EC) No 692/2008 of 18 July 2008 implementing and amending 
Regulation (EC) No 715/2007 of the European Parliament and of the Council on type-approval of motor vehicles with respect 
to emissions from light passenger and commercial vehicles (Euro 5 and Euro 6) and on access to vehicle repair and 
maintenance information, OJ L 199, 28.7.2008, p. 1 

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stakeholders of certain aspects” (COM/2016/0782 final 2016). As a result of this investigation, 
the requirements that were previously in these Regulations have been consolidated and are 
now detailed under Article 61 of Regulation 2018/858/EU27. This change is aimed to ensure 
easier access and use of RMI information by independent operators, which had struggled in 
the  past  as  information  was  provided  “piece  by  piece”  affecting  its  comprehension  and 
usability. Article 61 specifies in this respect that “Independent operators shall have access to 
the remote diagnosis services used by manufacturers and authorised dealers and repairers”. 
This obligation is not understood to require the provision of such information for free nor is it 
clear  if  this  will  result  in  repair  and  maintenance  information  being  included  on  a  single 
platform to  harmonise  and  simplify the access  of  users to  information. OEMs refer to  RMI 
information  when  asked  whether  information  to  support  reuse  is  available  to  ATFs. 
“Information about removal of parts can be found in the RMI service guides, which can be 
purchased.  A  link  to  all  RMIs  can  be  found  in  IDIS”  (ACEA  2021b).  However,  this  is 
understood not to be practical for ATFs as each OEM has a separate platform for providing 
data on its vehicle models and the use of each platform is membership (cost) based28: For 
an SME ATF that serves vehicles of multiple brands, this is not manageable in terms of costs 
nor in terms of needing personnel to be trained to work with multiple platforms and interfaces. 
In consequence, as in the past, the producers currently provide ATFs with access to RMI with 
the same approach as for any independent operator (e.g. of a repair garage), i.e., at a cost. 
Some ATFs complain about this aspect (cost to the ATFs) and its effect on the removal and 
reuse of parts is not clear.  

There  have  been  some  voices  as  to  the  option  of  using  a  digital  product  passport  for  the 
purpose  of  compiling  information  from  OEMs  for  ATFs29.  This  has  been  discussed  by  the 
Foundation “Stiftung 2°” with companies from various sectors including the OEM Audi. For 
the automotive sector a product passport is said to make sense, seeing as these are complex 
products with over 10,000 different components. It is claimed that developing a digital product 
passport  for vehicles  would  necessitate  billions  of  Euros,  though  it  is  not clear  what  these 
costs refer to, particularly seeing as much of the data already exists (compiled by OEMs) and 
the main effort is thus understood to be one of compiling data in an accessible digital form. 

A  similar  issue  is  that  many  valuable  (electric  and  electronic)  parts  are  coded  and  locked. 
Examples  include  window  wiper  motors,  inverters,  mirrors,  window  motors,  navigation 
systems,  sensors,  ICUs,  ABS  computers  and  others  (EGARA  2021)  Though  this  may  be 
necessary to ensure safe operation, the reuse of such parts requires that an ATF be able to 
unlock them for proper dismantling and that at a repair shop that they can be reinstalled with 
a  key  (and  sometimes  requiring  certain  systems  to  be  reset)  and  locked  to  allow  safe 
operation. As in the case of batteries, without intervention, it is probable that such components 
of  vehicles  will  be  locked  in  the  future.  This  would  limit  reuse  of  these  components  to 
operators with access codes or at least make it uneconomic for other operators. In a study 
performed by EGARA30 20-35 pieces were identified that - when dismantled - cannot be used 
despite being suitable for multiple models and makes. This is also a case in which lacking 
access  to  data  may  hinder  repair  and  reuse  at  least  for  some  economic  operators  (repair 
shops,  ATFs).  It  is  not  clear  if  this  shall  change  following  the  consolidation  of  the  RMI 

27 Regulation (EU) 2018/858 of the European Parliament and of the Council of 30 May 2018 on the approval and market 
surveillance of motor vehicles and their trailers, and of systems, components and separate technical units intended for such 
vehicles, amending Regulations (EC) No 715/2007 and (EC) No 595/2009 and repealing Directive 2007/46/EC 

28 Personal communication with repair shop owner of Y. Baron, January 2022 

29 See article: “Ein digitaler Pass für Pkws” in Frankfurter Rundfunk: https://www.fr.de/wirtschaft/ein-digitaler-pass-fuer-pkws-
91064053.html 

30 See EGARA’s contribution to the inception impact assessment (road map).  

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requirements  under  Article  61  of  Regulation  2018/858/EU  or  other  legal  requirements  like 
those specified in the Data Act to be proposed later this year. 

2.1.2.1.2  Hazardous substances 

The  current  rules  on  hazardous  substances  in  vehicles  are  distributed  over  different 
legislation: The End-of-life vehicles Directive (ELVD) currently prohibits the four heavy metals 
lead, mercury, cadmium, and hexavalent chromium. These substance prohibitions as well as 
the exemption assessment mechanism are laid down in the ELVD in Article 4(2). Accordingly, 
Member States are to ensure that materials and components of vehicles do not contain lead, 
mercury,  cadmium  or  hexavalent  chromium,  unless  exemptions  from  the  prohibitions  are 
listed in Annex II of the Directive. Exemptions can be added to the annex in cases where the 
use of one of these substances is not avoidable (or they can be removed when it becomes 
avoidable (Article 4(2)(b)(II -III)).  

In parallel, the materials used in vehicles and their substance content can also be affected by 
other  legislation  such  as  the  Regulation  1907/2006/EC  concerning  the  Registration, 
Evaluation,  Authorisation  and  Restriction  of  Chemicals  (REACH),  establishing  a  European 
Chemicals  Agency  (ECHA),  and  the  Regulation  (EU)  2019/1021  2019  of  the  European 
Parliament  and  of  the  Council  of  20  June  2019  on  persistent  organic  pollutants  (POP 
regulation).  Under  REACH,  certain  restrictions  in  Annex  XVII  (or  derogations  from 
restrictions) also apply to vehicle components,  e.g., entry  51 on the  four phthalates  where 
motor vehicles have specific provisions. The POP regulation prohibits the manufacturing and 
use of certain industrial chemicals, unintentionally produced chemicals (and certain pesticides 
which are not relevant to vehicles) and also sets waste management provisions with limits for 
the substances in waste. Those limits for e.g., decaBDE in waste streams have influenced 
the recycling of plastic in the past, leading to the disposal of material to avoid decaBDE levels 
above  the  limits.  In  addition,  new  POPs  are  progressively  being  identified  under  the 
Stockholm Convention that may also have relevance in the automotive industry, e.g., PFOA 
(used in motor oils and other automotive parts). 

Besides,  the  notification  requirements  in  the  SCIP  database  also  applies  to  vehicle 
components. SCIP is the database for information on Substances of Concern In articles as 
such or in complex objects (Products) (ECHA 2022) established under the Waste Framework 
Directive  (Directive  2008/98/EC  2008,  WFD).  Articles  containing  a  substance  of  very  high 
concern  (SVHC)  included  in  the  Candidate  List  in  a  concentration  above  0.1%  weight  by 
weight  (w/w)  or  complex  objects  (products)  incorporating  such  articles  placed  on  the  EU 
market have to be notified in the database.  

The Commission has proposed a new Battery regulation in December 2020. The proposal 
incorporates a restriction procedure, aligned to that under REACH and where the assessment 
is carried out by the European Chemicals Agency (ECHA).  

It has to be noted that the various regulations, i.e., REACH, POPs and the Battery regulation 
are currently under revision as well, albeit at different stages.31 

31 See the timeline of the REACH revision under the Chemicals Strategy at: 
https://ec.europa.eu/environment/chemicals/reach/reach_revision_chemical_strategy_en.htm  

A proposal for the revision of the POPs Regulation (EU) 2019/1021, and in particular its Annexes IV and V which determine 
how waste containing POPs must be treated, has been submitted by the European Commission at the end of October 2021 
(https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12411-Hazardous-waste-updated-concentration-
limits-for-chemical-pollutants_en). Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE 
COUNCIL concerning batteries and waste batteries, repealing Directive 2006/66/EC and amending Regulation (EU) No 
2019/1020; COM/2020/798 final; at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52020PC0798  

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Moreover, there are new policy developments in the EU that could influence requirements for 
substances  of  concern  for  increasing  the  circularity  of  vehicles  in  relation  to  the  uptake  of 
recycled material in new productions: The Chemicals Strategy for Sustainability states in this 
respect that “the creation of a well-functioning market for secondary raw materials and the 
transition to safer materials  and  products  is  being  slowed  down  by  a  number  of  issues,  in 
particular  the  lack  of  adequate  information  on  the  chemical  content  of  products  […]  it  is 
necessary  to  ensure  that  substances  of  concern  in  products  and  recycled  materials  are 
minimised.  As  a  principle,  the  same  limit  value  for hazardous substances  should  apply  for 
virgin and recycled material”.  

The  coherence  check  of  the  ELV  Directive  with  the  other  legislation  shows  various 
inconsistencies and areas for possible action related to the provisions on the prohibition of 
hazardous  substances  and  how  these  are  currently  implemented.  These  aspects  can  be 
differentiated into three groups:  

•  one relating to the necessity of prohibiting additional substances and how this is to be 

• 

• 

addressed;  
the second relating to the mechanism for assessing the exemptions from the ELVD 
substance prohibitions and its effectiveness and  
the  third  on  adequate  information  on  the  content  of  hazardous  substances  in 
products to achieve a desired quality and composition of recycled materials.  

In relation to the possible need for prohibiting additional substances in the future, this was 
looked at from the perspective of other pieces of legislation dealing with the production, use 
and recovery of hazardous substances (e.g., RoHS, Batteries, WFD, REACH, POPs) but also 
in  relation  to  new  policy  developments  in  the  EU  (e.g.,  CEAP,  the  interface  between 
chemicals,  products  and  waste  legislation,  the  chemicals  strategy  for  sustainability).  The 
basis for possible future restrictions is already mentioned in the ELVD. The study supporting 
the Evaluation of the ELVD (Williams et. al 2020) states that from “Recital 11 and Article 
4 it can be assumed that additional prohibitions could be justified in cases where 
a decrease or the elimination of substances in ELVs would prevent “their release 
into  the  environment  […]  facilitate  recycling  and  […]  avoid  the  disposal  of 
hazardous waste”.” It further states that it “is apparent that the presence of substances 
aside  from  the  four  heavy  metals  in  waste  may  also  compromise  the  ability  to 
recover  materials  in  the  waste  management  stage.  The  fact  that  additional 
substances  have  been  subject  to  prohibitions  under  other  legislation  (e.g., 
REACH,  RoHS,  POPs)  suggests  that  these  may  have  negative  impacts  on  the 
environment  and  on  waste  management”,  i.e.,  that  additional  prohibitions  may  be 
relevant. This is also supported by the Circular Economy Action Plan (COM(2015) 614 final 
2015)  which  refers  to  the  general  increase  in  the  use  of  plastics  and  its  advantages  for 
vehicles in terms of weight reduction on one side, but also raises concern as to the presence 
of hazardous chemical additives in plastics and how this can pose technical difficulties for its 
recovery.  This  suggests  that  there  may  be  a  need  to  regulate  the  presence  of  additional 
hazardous substances that are used in vehicles, aside from the four heavy metals currently 
prohibited, e.g., certain flame retardants, plasticisers, or surface-active agents such as PFAS. 
This  is  understood  to  be  particularly  relevant  where  such  substances  could  hinder  the 
recovery of materials from ELV in waste management as well as in other practices relevant 
for circularity. Investigations of the prohibition of new substances could consider whether this 
should be done under the ELVD or under a different regulatory framework (e.g., REACH). 
Respectively, it may be necessary to consider how the ELVD is to support this process, by 
clarifying  how  (frequency,  prioritisation  of  certain  substances  for  assessment)  and  against 
which criteria it is to be decided whether additional prohibitions are to be introduced. 

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Under REACH, there is basically the authorisation route and the restriction route to address 
the use of hazardous substances.  

a) Authorisation: Following the inclusion of substances of very high concern in Annex XIV of the REACH, 

companies are required to apply for an authorisation to continue the use of the substance.   
Authorisations under REACH are considered comparable to the ELV prohibitions in terms of all uses of 
a  substance  being  prohibited.  However,  the  current  authorisation  requirements  only  prohibit  the 
manufacture and use of the substances in the EU, but do not cover the presence of the substances in 
imported  articles.  Prohibitions  could  be  circumvented  by  shifting  the  manufacture  of  parts  containing 
prohibited substances to countries outside the EU. This creates an unlevel playing field for the European 
economy. However, REACH allows for a fast track on restrictions for substances included into Annex XIV 
(authorisation list) which are present also in articles.32 

Authorisations under REACH to use the substance for specific applications are granted to producers. 
Though some applications for authorisations have been applied for by OEMs and their suppliers, one 
authorisation  application  can  basically  also  cover  several  applications  of  the  substance  (e.g.,  several 
chromium plating techniques of different types of articles) which is then applicable to several companies 
by a so-called up-stream application. So, vehicle OEMs and their suppliers would not necessarily need 
to apply for an authorisation for use for each application of a prohibited substance individually.  

b) Restriction: Limitations to be imposed on substances used in vehicles (termed substance “prohibitions” 
under  the  current  ELV  Directive),  could  be  included  under  the  restriction  mechanism  (REACH  Annex 
XVII):  REACH  restrictions  prohibit  or  establish  limitations  on  substances  in  specific  applications.  This 
mechanism could be used to transfer substance prohibitions for vehicles to REACH, i.e., a restriction 
would  be  added  for  each  substance  prohibited,  including  derogations  for  specific  applications  where 
exemptions are still needed.  

In this case, the concern is that there is no formalized process to apply for a derogation to the restriction 
nor to regularly review the derogations. However, a comparable process is basically in place, but would 
have  to  be  made  explicit  and  transparent:  Before  restrictions  are  made,  there  is  usually  a  “call  for 
evidence” process of 6 months where the concerned parties provide information that affects the scope of 
the restriction, e.g., on the need for derogations. This information is reviewed during the opinion making 
by RAC and SEAC.  

Though there are a few restriction entries in Annex XVII with a review clause, it is not clear if a restriction 
could be reviewed for scientific and technical progress every few years, as is the case for some of the 
annex II exemptions. Currently, a change in a restriction entry requires a new restriction. To conclude on 
the current stage, REACH restrictions are not well designed for a systematic review process, although 
this is not impossible. It might be possible that the revision of REACH might introduce this improvement.  

Both  routes,  authorisation,  and  restriction,  are  currently  being  revised  and  may  even  be 
merged into one system, with the option for exemptions.  

In  relation  to  the  exemption  assessment  mechanism,  the  effectiveness  of  the  current 
process  was  compared  to  the  RoHS  Directive.  The  RoHS  Directive  was  chosen  for 
comparison because it is part of the waste legislation acquis as is the ELVD, and because it 
includes  substance  restrictions  and  also  has  an  exemption  evaluation  mechanism  with 
similarities to that of the ELVD, though more developed. The comparison showed that various 

32 Article 68(2) of REACH provides for a simplified restriction procedure for substances on their own, in a mixture or in an 
article, which meet the criteria for classification in certain the hazard classes (carcinogenicity, germ cell mutagenicity or 
reproductive toxicity, category 1A or 1B), and could be used by consumers. In such cases, a restriction to consumer use can 
be proposed by the Commission and Annex XVII can be amended by comitology, without the need to follow the process 
defined in Articles 69 to 73 (i.e., without the intervention of ECHA). Such a procedure has been used to restrict the presence 
of a large group of substances in clothing and related accessories, other textiles and footwear.  
(Commission Regulation (EU) 2018/1513. https://eur-lex.europa.eu/legal-
content/EN/TXT/?toc=OJ:L:2018:256:TOC&uri=uriserv:OJ.L_.2018.256.01.0001.01.ENG)  

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aspects could be adjusted in the current exemption assessment process of ELVD to make 
this mechanism more effective and efficient, keeping in mind that also the RoHS Directive is 
under revision.33  

•  Limited duration for exemptions and an obligation to apply for renewal: So far, there are 
no provisions on default duration periods of exemptions under ELV. Under RoHS, each 
exemption  from  the  substance  restrictions  is  specified  with  a  limited  duration.  The 
Directive includes provisions that differentiate between most EEE categories and those 
that  have  longer  design  cycles,  namely,  medical  devices  and  monitoring  and  control 
instruments. The maximum exemption duration for these two categories is set at 7 years 
instead  of  the  5  years  relevant  for  other  categories.  This  does  not  mean  that  shorter 
exemptions  cannot  be  granted,  however, the fact  that the  exemption  is  given  a  limited 
validity means that it will be periodically assessed if the exemption is still needed (see 
next bullet). The only case where exemptions are not limited is the case of spare parts, 
for which RoHS provides a general exclusion (RoHS Article 4) for use of the restricted 
substances in equipment that, at the time placed on the market, benefited from a valid 
exemption. ELV addresses this aspect by referring to the type approval date in relation to 
the expiration date. 

•  Application for exemptions (new, renewals, revoke): There is no standard method for an 
exemption application under ELV. Under the RoHS Directive, when an exemption reaches 
the  end  of  its  duration,  it  automatically  expires.  Where  the  exemption  is  still  needed, 
stakeholders have the possibility of applying for its renewal, a process in which they are 
obliged to compile a dossier providing information and data to substantiate the justification 
for the exemption. This has the advantage that the process of exemption assessment has 
a clearer starting point in relation to what has changed since the past evaluation, and the 
evaluators can focus more on the verification of the grounds for justification. This process 
also  provides  more  certainty  for  stakeholders,  who  can  anticipate  if  and  when  an 
exemption could be evaluated.  

•  The criteria for exemption: The ELV Directive provides one criterion for the assessment 
of  an  exemption,  namely  “if  the  use  of  these  substances  is  unavoidable”.  The  RoHS 
Directive  includes  a  set  of  criteria  for  the  justification  of  exemptions.  It  ensures  the 
coherence with the REACH Regulation as a threshold condition. As a next stage, it not 
only  looks  at  whether  substitutes  have  become  available,  but  also  at  their  reliability. 
Furthermore, it investigates how they compare with the use of the restricted substance in 
terms  of  environmental  and  health  impacts.  In  certain  cases,  consideration  of  socio-
economic  aspects,  LCA  data  and  impacts  on  innovation  or  the  market  availability  of 
substitutes can also be included. These criteria are more elaborate than the ELV criteria 
that only consider if the use of the prohibited substance has become avoidable, creating 
a “black and white” decision process which makes it difficult to integrate possible impacts 
on the environment or on society into the decision process.  

•  Alignment  with  other  legislation:  It  is  noted  that  ELV  and  RoHS  have  a  few  cases  of 
exemptions  which  are  similar  in  scope,  e.g.,  on  lead  in  alloys  (steel,  aluminium,  and 
copper  alloys).  The  alignment  of  the  Directives  in  this  respect  usually  focusses  on  the 
scope of the exemptions. ensuring that differences between the directives in terms of the 
scope  of  such  exemptions  are  only  recommended  in  cases  where  changes  apply 
differently  to  the  vehicles  and  to  EEE  (e.g.,  where  substance  applicability  or  reliability 
requirements may differ, etc. Though there have been efforts along the years to perform 
assessments  of  these  exemptions  in  proximity  (and  in  one  instance  also  as  a  joint 
assessment),  the  fact  that  ELV  only  specifies  a  period  for  the  next  review  and  not  an 

33 Review: Restriction of the use of hazardous substances in electronics; https://ec.europa.eu/info/law/better-regulation/have-
your-say/initiatives/13137-Review-Restriction-of-the-use-of-hazardous-substances-in-electronics_en  

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expiration date does not facilitate further joint assessments which could save resources. 
However, this gives legal certainty to companies because the derogation still applies, and 
so does the possibility of placing on the market. 

The  issue  of  hazardous  substances,  however,  is  not  only  relevant  when  a  substance  has 
been prohibited, but also affects the waste phase in terms of the quality and composition of 
recycled  materials.  This  raises  the  need  of  adequate  information  on  the  content  of 
hazardous  substances  in  products.  The  dismantling  of  cars  containing  complex  (or 
hazardous)  materials  can  lead  to  significant  waste  management  costs  which  reduce  the 
economic  viability  of  ELV  treatment  companies.  This  conflict  was  also  mentioned  by 
stakeholders  during  the  ELV  Stakeholder  Workshop  on  24-25  March  2022  "Material 
Compliance and Circularity".  

It can also lead to a loss of materials, as in the case of plastics contaminated with decaBDE. 
When hazardous substances present in waste are recycled into new materials, these must 
comply with all relevant product legislation (including chemicals legislation) in order to achieve 
end-of-waste status (see art. 6 of the WFD). While the POP regulation has different limits for 
new  and  recycled  products34,  the  Chemicals  Strategy  for  Sustainability  states  that,  as  a 
principle, the same limit value for hazardous substances should apply for virgin and recycled 
material,  although  it  is  also  acknowledged  that  there  may  be  exceptional  circumstances 
where a derogation to this principle may be necessary.  

This  could  not  only  affect  the  contents  of  ELV  prohibited  hazardous  substances  in  ELV 
recyclate in the future, but also the use of other substances, where these have been restricted 
under other legislation or singled out as substances that should not be contained in secondary 
materials. To do this, it is, however, important to have sufficient data on substances used in 
the manufacture at present and in the past, given that by the time a vehicle reaches end of 
life (EoL), it may contain materials that were allowed for use during its production but that 
have since been prohibited. 

The example of the ban of decaBDE, which was used in the past in plastic components of 
cars, shows that the main challenge is to identify the components in which it is contained in 
ELVs and whether these need to be and could be separated before shredding (as the POP-
regulations  requires).  There  is  lacking  consensus  on  whether  such  plastics  need  to  be 
removed  prior  to  shredding  or  whether  the  shredder  can  be  considered  as  a  means  of 
removing  decaBDE  contaminated  streams  from  other  streams.  In  the  latter  case,  streams 
containing decaBDE levels below the POPs Regulation Annex IV threshold could be recycled, 
while  other  streams  would  need  to  be  disposed  of  as  allowed  by  the  POPs  Regulation. 
Stakeholders in the workshop mentioned a recent “characterisation study on the content of 
POP  substances  in  car  shredder  residues  which  demonstrated  that  the  levels  of  POP 
substances are well below the regulatory thresholds set, in a campaign representative for the 
end-of-life vehicle fleet. Furthermore, the POP substances targeted by this study have since 
been progressively substituted in line with the bans in force under the European REACH and 
POP regulations. Regarding brominated flame retardants, their substitution has been carried 
out for many years. Consequently, this should ensure that concentrations of POP substances 
in future material streams from end-of-life vehicles remain below future regulatory thresholds.” 
Whereas it is plausible that the content of PBDEs is decreasing, substances that are newly 
added to the POPs regulation might end up in the waste phase until their substitution.  

34 According to POP regulation, DecaBDE is limited at 10 mg/kg for new products (Annex I) while the limit for waste is 1000 
mg/kg. with a revision clause for 500 mg/kg (Annex IV).  

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As  an  example,  “PFAS”35  were  mentioned  in  the  stakeholder  workshop,  i.e.,  that  they  are 
“impossible  to  detect  and  document”  and  are  therefore  considered  by  practitioners  in  the 
recycling facilities  as  being  impractical  to remove; “so  here the  decision might  be  taken to 
better not recycle because of the additional burden (test + documentation).” 

In  result,  it  is  today  not  possible  for  ATFs  to  identify  parts  or  components  in  a  specific 
individual vehicle that contains decaBDE, for example. Some Member States have discussed 
if  the  ‘positive  list’  of  components  mentioned  in  the  ELVD,  Annex  I  section  4,  might  be 
expanded or if the car manufacturers should be obliged to provide more information on what 
components are worth dismantling (either for high-quality recycling or for reuse).  

In  any  case,  a  separation  before  shredding  is  necessary  for  hazardous  substances  that 
cannot be detected by post-shredding techniques. More generally, availability of information 
on chemicals of concern in vehicle parts is a key determinant. Such knowledge can directly 
influence  their  recyclability  or  reusability.  Insufficient  information  provided  by  vehicle 
manufacturers  to  dismantlers  on  presence  and  localisation  of  (hazardous)  materials  could 
hamper high-quality recycling. 

At the regulatory level, the SCIP database has been established under the Waste Framework 
Directive (WFD), this is the database for information on Substances of Concern in articles as 
such or in complex objects (Products) (ECHA 2022). Companies supplying articles containing 
substances  of  very  high  concern (SVHCs)  on  the  Candidate  List  in  a  concentration  above 
0.1% weight by weight (w/w) on the EU market must submit information on these articles to 
ECHA since 5 January 2021. Thus, with regards to economic impacts, obligations and hence 
economic burden already exist in the form of these notification duties for the SCIP database.  

However,  stakeholders  noted  in  the  interviews  that  the  notifications  in  SCIP  are  not 
scrutinized and thus they questioned the quality of the entries.  

Besides, it is not yet obvious how the data are made available to the ELV waste operators 
who  need to know the  single  parts/components and  their  location  in the vehicle  combined 
with  dismantling  information,  so  as  to  enable  these  operators  to  separate  the  respective 
part/component  for  depollution  purposes.  Input  from  the  stakeholders  also  explained  that 
SCIP in its current form is not expected to contribute to the environmental benefits, since it is 
not  practical  for  waste  management  operators  to  retrieve  information  on  localisation  of 
hazardous substances. 

The automotive industry itself already has a profound information system in the form of the 
International Material Data System (IMDS)36 established in 2000. It is designed to act as an 
easily accessible online system to help vehicle manufacturers and their supply chain to record 
and track substance and material compositions of their components. The system aims not 
only  to  achieve  legal  compliance  but  is  also  an  integral  part  of  the  industries’  quality 
processes. System users today include:  

•  Around forty name-brand manufacturers, representing more than 90 different brands of 

vehicles 

•  More than 120,000 automotive suppliers of materials and components. 

Since its implementation into the automotive processes, IMDS, in conjunction with the Global 
Automotive  Declarable  Substance  List  (GADSL),  has  also  become  the  information  system 

35 In the POP regulation, PFOS and its derivatives have been prohibited since 2009, and PFOA, its salts and PFOA-related 
compounds have been prohibited under the POPs Regulation since 4 July 2020. Additionally, perfluorohexane sulfonic acid 
(PFHxS), its salts and related compounds as well as perfluorinated carboxylic acids (C9-14 PFCAs) are being considered for 
inclusion in the Stockholm Convention and consequent global elimination. 

36 https://public.mdsystem.com/en/web/imds-public-pages  

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used in practice for material declarations on the contents of declarable substances along the 
supply chain in the automotive industry. Furthermore, the GADSL contains more substances 
then the SCIP database. The list of substances which must be declared by suppliers to OEM 
is permanently changing due to GADSL updates to scientific progress. It is important to note 
that a link between IMDS and a single vehicle (e.g., via the vehicle identification number (VIN) 
is not included in IMDS and would be possible only via the part list for each single vehicle 
which is held by the car manufacturer. Today, car manufacturers argue that publication of the 
parts list would violate intellectual property rights. Furthermore, they argue that the parts lists 
(for each single vehicle thus equivalent to globally more than > 90 million vehicles per year) 
are not systematically stored for the full lifetime of each vehicle. 

Half  of  the  answers  of  stakeholders  to  interactive  questions  asked  during  the  stakeholder 
meeting,  indicated  that  OEMs  document  data  on  the  content  of  GADSL  substances  in 
vehicles and components though the parts list of the vehicle.37 The BMW Group explains that 
the “information on the content of GADSL substances in vehicles and components is linked 
to part numbers, not to vehicles; a linkage to the VIN number is seen as an unreasonable 
effort, due to millions of potential variations (and due to the fact that the vehicle owner may 
have changed parts, which cannot be considered)”. The Renault Group also explains that “it 
is possible to extract indirectly a maximizing list of GADSL substances for a given vehicle, 
i.e., a list of substances corresponding to an "envelope vehicle" that would contain the parts 
of all possible versions of a model (i.e., not the exact list of substances actually contained in 
a given vehicle/VIN).”  

The discussion on the improved communication is related to other dynamic threads such as 
the  concept  of  a  Digital  Product  Passport  (DPP).  Under  the  Ecodesign  for  Sustainable 
Products  Regulation  (ESPR),  the  Digital  Product  Passport  shall  eventually  become 
mandatorily applicable for all (priority) products covered under ESPR but can be extended to 
other categories such as vehicles. The idea is that for each product, an individual delegated 
act should define the key elements/ features on the information that a DPP will cover. The 
development of such a DPP will take time as it also requires the inclusion of standardisation 
requests, close consultation with the industry and a synchronisation of different datasets into 
one info channel. There are already industry initiatives in this regard, e.g., Catena X38, that 
work on creating a platform for all contributors in the automotive value chain to digitally trace 
material flows throughout the entire supply chain.  

2.1.2.1.3  Directive  2005/64/EC  type  approval  of  vehicles 
with  regard  to  their  reusability,  recyclability  and 
recoverability 

Considering again the expected increase in the use of new technologies and new materials, 
and the fact that even at present it can be difficult to achieve the ELV reuse and recycling 
targets, it becomes even more important to check that new vehicles placed on the market 
comply  with  design  requirements  developed  to  facilitate  their  EoL  waste  management.  In 
other words, as a condition for putting vehicles on the market, it needs to be ensured that a 
vehicle has been designed with the waste management in mind in a way that facilitates waste 

37 On the Slido question “Is it correct to assume that OEMs document data on the content of GADSL substances in 
vehicles and components through the parts list of the vehicle (i.e., linked to the VIN)?”: 13 individuals answered this 
question. Only a single answer was possible. Almost half of the participants think the assumption is correct. The rest did not 
have an opinion (I don’t know”).  

38 https://catena-x.net/en/  

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treatment  and  achieving  the  reuse  and  recycling  targets  in  order  to  contribute  to  the 
achievement of the objectives of the ELV. With such aspects in mind, Article 7(4) of the ELVD 
required the Commission to revise Directive 70/156/EEC on type approval in order to make 
sure that vehicles “are re-usable and/or recyclable to a minimum of 85 % by weight per vehicle 
and are re-usable and/or recoverable to a minimum of 95 % by weight per vehicle”. To this 
end,  Directive  2005/64/EC39  on  the  type  approval  of  motor  vehicles  with  regard  to  their 
reusability, recyclability and recoverability (3R Directive) was adopted in 2005. 

The 3R Directive ensures that ELVD design requirements (e.g., substance prohibitions) are 
fulfilled and it further increases the link between vehicle design and end-of-life, by requiring 
that the design of a vehicle be investigated to ensure that it will not hinder achievement of the 
ELVD reuse and recovery targets. A vehicle can be denied market access until its design has 
been approved in this respect. In this sense, under the current legislation the 3R Directive 
contributes  to  ensuring  that  new  vehicles  put  on  the  market  are  reusable,  recyclable,  and 
recoverable. It also ensures compliance with the ELVD substance prohibitions and with the 
component marking requirements established in Commission Decision 2003/138/EC.  

As the 3R Directive is part of the general process of type approval and in particular Regulation 
of EU 2018/85840, its functioning is independent from the ELVD. Nonetheless, it is important 
to consider how the two Directives are kept aligned and how this is to be monitored in the 
future. For one, the ELVD Evaluation revealed some incoherencies between the two pieces 
of  legislation.  Though  the  evaluation  of  the  ELV  Directive  showed  that  the  3R  Directive 
2005/64/EC  contributes 
the  reusability,  recyclability,  and 
recoverability of vehicles, it also raised some shortcomings.  

the  demonstration  of 

to 

•  The  ELVD  evaluation  concluded  that  some  of  the  3R  Directive  provisions  are  unclear, 

• 

leaving room for interpretation that can weaken its objectives.  
It is not completely clear to what degree the way that the ELVD end-of-life requirements 
are linked to the 3R Directive supports the putting on the market (PoM) of vehicles that 
will fulfil the waste management obligations. For example, at present, the calculation of 
recyclability  and  recoverability  requires  the  producers  to  submit  a  specification  of  the 
vehicle material breakdown into separate materials (e.g., glass, metals, etc.) and also an 
estimation of the share of material that is reusable, recyclable, recoverable or both. For 
this purpose, a component part is “considered as reusable, recyclable or both based on 
its  dismantlability,  assessed  by  accessibility, 
technology,  and  proven 
dismantling technologies” (ISO 22628: 2002). A part is considered recyclable based on 
its material composition, and proven recycling technologies. This does not differentiate 
however between different qualities of recycling. Thus, for example, as observed in the 
case of glass used in vehicles, the existing method enables referring to glass towards the 
calculation of recyclability as in principle it can be dismantled and there are techniques 
that would allow its recycling. However, in practice, glass is usually separated from other 
materials  through  shredding  activities,  leading  to  only  a  low-quality  recycling  (e.g., 
backfilling,  or  other  forms  of  downcycling)  being  possible.  A  further  example  refers  to 
tyres. The 3R Directive specifies (annex I (6)) that for the purposes of the 3R calculations, 
tyres shall be considered as recyclable, i.e., are counted to 100% towards achieving the 
recycling  target.  However,  in  practice, the recycling  of tyres  is  currently far  form  100% 
material recovery. EuRIC MTR (2022) state that from around 3 million tonne of end-of-life 

fastening 

39 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 and amending Council Directive 70/156/EEC 

40 Regulation (EU) 2018/858 of the European Parliament and of the Council of 30 May 2018 on the approval and market 
surveillance of motor vehicles and their trailers, and of systems, components and separate technical units intended for such 
vehicles, amending Regulations (EC) No 715/2007 and (EC) No 595/2009 and repealing Directive 2007/46/EC 

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tyres (ELT) generated in the EU annually, only ca. 1.3 Mt are recovered as material (most 
as granulate), while 1.2 Mt is sent to energy recovery. 

•  The  lack  of  a  monitoring  mechanism  for  the  3R  Directive  implementation  by  Member 
States and car manufacturers before the introduction of Market Surveillance in 2020, also 
made  it  difficult  to  assess  to  what  degree  the  3R  Directive  promoted  the  circularity  of 
vehicles.  This  may  change  with  the  new  regime  which  includes  market  surveillance 
performed  by  other  MS  than  the  one  providing  the  type  approval  and  obliges  MS  to 
perform at least one annual market surveillance activity for every 40,000 vehicles PoM or 
a minimum of five41.  

•  As part of the assessment of OEM compliance with the 3R Directive, Article 6(3) requires 
manufacturers  to  “recommend  a  strategy  to  ensure  dismantling,  reuse  of  component 
parts, recycling, and recovery of materials. The strategy shall take into account the proven 
technologies available or in development at the time of the application for a vehicle type-
approval”. 3R Directive Article 6(5) clarifies that Type approval authorities, when issuing 
a Certificate of compliance for a vehicle model that is regarded as type approved, need 
to “include the appropriate documentation and describe the strategy recommended by the 
manufacturer…”.  However,  from  an  interview  held  with  Stellantis  (2022)  the  strategy 
provided  by  OEMs  is  understood  to  be  general  in  nature  and  not  necessarily  vehicle 
specific.  When  asked  if  detail  from  this  strategy  feeds  into  dismantling  information 
provided to the IDIS platform, Stellantis clarified that IDIS information, is vehicle specific 
technical  information,  including  e.g.,  practical  information  on  pre-treatment  and 
dismantling of plastic parts or other materials, etc. The purpose of the strategy developed 
for the 3R directive Article 6(3) is explained to be different from the IDIS information and 
not  practical  for  the  dismantler.  The  strategies  aim  is  “to  show  how  we  support  the 
recycling and the process globally – how this is linked with design of the car” so that that 
vehicles will be treated properly. In this respect Stellantis mentions the following points as 
part of the strategy: how the material composition of a car is controlled, the objective of 
integrating  recycled  content,  supplying  operators  (e.g.,  ATFs)  with  pre-treatment  and 
assembly information and innovation considerations of effects of the vehicle composition 
on recycling to ensure recyclability of materials integrated in a vehicle. Another OEM also 
explained that the strategy does not directly relate to the information provided to ATFs 
through IDIS to facilitate waste management. The example was given that whereas the 
OEM’s data for IDIS identifies (and provides data for) plastic components for theoretical 
recycling and dismantling, its strategy is in rather in favour of applying shredder residue 
treatment and recycling technologies in the treatment of vehicles. To summarise, it seems 
that OEMs provide  rather  general  company  strategies  that  do  not  provide  detail  at  the 
level of a single vehicle, despite the 3R Directive requiring “the approval authority shall 
ensure  that  the  data  presentation form  referred  to  in  point  2  [Consultants  addition:  the 
calculation  based  on  standard  ISO  22628:  2002]  is  coherent  with  the  recommended 
strategy annexed to the certificate of compliance referred to in Article 6(1) of this Directive” 
(3R Directive, Annex I (8)). The latter suggests that the strategy should be specific to the 
model being type approved or at least to models intended to be PoM in the same year. A 
more  specific  strategy  is  also  perceived  by  the  consultant  to  be  more  appropriate  for 
demonstrating how the “dismantling, reuse of component parts, recycling and recovery of 
materials” of a type approved model is ensured. 

41 Based on personal communication of Y. Baron with DG GROW colleagues, 19.8.2022. It was also explained that at least 
20% of activities must be emission tests, which would still leave a sufficient margin for performing market surveillance 
activities related to 3R Directive design requirements. 

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2.1.2.2  Reuse and recycling 

The  European  Green  Deal  and  the  Circular  Economy  Action  Plan  emphasise  the  need  to 
promote high quality recycling and facilitate the uptake of recycled materials in new products. 
The need to prioritise the reduction in material use and the reuse of components and materials 
above the recycling of materials and parts is also mentioned. The ELVD also includes various 
provisions to promote the reuse and recycling of vehicle parts and materials: 

•  Article 7 of the Directive requires Member States to ensure that economic operators attain 
specific targets on the share of parts and materials reused, recycled, and recovered from 
a vehicle. As of 1 January 2015, economic operators must achieve a total rate of 85 % 
reuse and recycling of the average vehicle weight and a total rate of 95 % when recovery 
amounts are also accounted for.  
In parallel, Annex I of the Directive specifies a number of parts that must be depolluted as 
well as operations to be caried out to facilitate recycling (see detail under Section 0).   
•  Article 7 also makes a connection between the ELVD and the type approval process of 
vehicles. As a result, Directive 2005/64/EC42 requires type approval authorities to ensure 
that vehicles put on the market can achieve the reuse and/or recycling target of 85 % and 
the reuse and/or recovery target of 95 % by weight of the vehicle. 

• 

And yet, the re-use and recycling of some materials present in ELVs is currently insufficient, 
resulting  in  loss  of  re-usable  and  recyclable  materials.  At  the  moment,  most  vehicle 
dismantlers do not carry out pre-shredder dismantling of materials such as glass, large plastic 
parts, the wiring harness and electronic components, because the low value of the material 
vs.  the  cost  of  removal  means  it  is  not  economically  viable  for  them  and  there  is  no  clear 
obligation in the Directive to remove these parts before or after shredding. For instance, it is 
known that the glass from ELVs can be removed to be recycled, as required by Annex I to 
the ELVD, but dismantling of glass is rarely done by ATFs as the effort is not compensated 
by the revenues for the separated glass and glass is recycled after shredding. At the same 
time, glass producers claim that glass from vehicles can be used for high quality recycling if 
removed  before  shredding.43  As  the  vehicle  producers  do  not  compensate  ATFs  for  the 
economically not viable effort, in almost all MS glass is not separated and instead directed to 
the shredder heavy fraction (SHF) which is (in the best case) used for construction purposes 
or for backfilling. The latter is not considered as recycling by the Waste framework directive 
(WFD), but it is by the ELVD, which is another sign for the outdated definition of recycling in 
the ELVD.  

Furthermore, under the current ELVD, the recycling targets are not material specific but refer 
to the overall weight of the vehicle. As certain materials (e.g., plastic, glass) account for only 
a  small  portion  of  the  vehicle  weight,  they  are  often  discarded.  There  is  also  no  effective 
enforcement  of  the  existing  separation  or  removal  requirements  (glass,  large  plastic). 
Technically  feasible  and  environmentally  beneficial  high-quality  recycling  (e.g.,  of  glass, 
selected plastics, electronic components) is not established as it is not profitable.      

The  fact  that  the  reporting  of  Members  States  on  their  reuse  and  recycling  targets  is  not 
harmonised furthermore results in non-comparable data on the actual achieved rates of reuse 
and recycling. Today, nearly all Member States report a certain amount of re-use, which is 
the highest level of the waste hierarchy according to the WFD. The level of reuse, however, 
varies strongly across the EU, as the ELVD does not establish a separate target for re-use. 

42 Directive 2005/64/EC on the type-approval of motor vehicles with regard to their reusability, recyclability and recoverability 

43 Bartels, Pieter (2016): ELV glass: Re-cycling or Recovery? 16th International Automobile Recycling Congress IARC 2016. 
FERVER. Berlin, Germany, 15.03.2016. 

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Williams et. Al (2020) reports that the share of reuse of parts and components from ELVs 
varies across the EU, from zero to 33 %, though it is not clear to what degree this reflects 
different reporting practices and to what degree it reflects actual differences in reused parts. 
The  following  graph  illustrates  the  share  of  “re-use”  to  the  total  waste  generated  for  the 
reference year 2019 reported by MS.  

Figure 2-1  Total re-use currently reported by MS as a share to total waste generated. 
Reference year 2019 (* data for reference year 2018) 

Source: own illustration of ELV data in Eurobase (Eurostat online data code: env_waselv), Oeko-Institut  

Reporting  on  various  components  according  to  the  Commission  Decision  2005/297/EC  is 
voluntary, therefore there is no data on each kind of components for re-use from ELV for all 
MS available. The following graph illustrate the share of components for re-use for various 
components.  

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Figure 2-2  Re-use currently reported by MS as a share to total waste generated with 
split on various reported components (according to current reporting scheme). 
Reference year 2019 (* data for reference year 2018) 

Source: own illustration of ELV data in Eurobase (Eurostat online data code: env_waselv), Oeko-Institut  

The change over the years of the total re-use is illustrated in the following figure.  

Figure 2-3  Total re-use from ELVs, 2012-2019. 

Source: own illustration of ELV data in Eurobase (Eurostat online data code: env_waselv), Oeko-Institut  

The current ELVD allows two different calculation methods which cause significantly different 
amounts  of  reuse reported  by the MS. MS  not  using  the metal  content  assumption (MCA) 

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shall calculate reuse (A) on the basis of the subtraction method44, Member States using the 
MCA shall determine reuse (excluding the metal components) on the basis of declarations 
from the authorised treatment facilities. The reuse of metal components will not be displayed 
separately if the MCA is applied but reported together with the metals recycled (in Table 2 of 
Commission  Decision  2005/293/EC).  In  result,  it  is  not  possible  to  compare  the  reuse 
between  MS  applying  the  MCA  and  MS  that  do  not.  In  some  MS  the  reuse  reported  is 
calculated based on subtraction of shredded fraction from the complete vehicle weight, i.e., 
including those fractions depolluted or removed prior to the shredder. However, some of these 
are sent to recycling, i.e., where the part is not fit for reuse or where there is no demand. 

As the target is also a combined target for recycling and reuse, the MS are not encouraged 
to  support  (or  even  monitor)  reuse  separately  (as  it  should  be  when  following  the  waste 
hierarchy).  

Article 7(2) sets out obligatory targets for the reuse, recycling, and recovery of ELVs to be 
achieved by ELV waste operators. The current targets in force are the as follows: 

•  a target of 85% re-use and recycling of the average weight per vehicle and year (meaning 

only the fractions prepared for reuse or recycled), and 

•  a target of 95% reuse and recovery of the average weight per vehicle and year (effectively 
meaning that at least 10% of the fractions not reused or recycled need to be recovered 
while the rest may also be disposed of as waste). 

The following figure illustrate the reuse/recovery and reuse/recycling rates obtained by MS 
for the reference year 2019. An average EU-27 re-use and recycling rate is: 89.6 %, whereas 
3 countries did not reach this target in 2019 (+ 2 countries based on data from ref. year 2018). 
An average EU-27 re-use and recovery rate is: 95.1 %, whereas 6 countries did not reach 
this target in 2019 (+ 2 countries based on data from ref. year 2018). 

As the Member States do not report on the treatment capacities (in particular the information 
of post shredder treatment (PST) plants would be needed), it is also not possible for the EC 
to assess if the reported data on recycling rates is valid or not (more about the shredder and 
PST technologies under 2.1.2.3). To our knowledge, some MSs report high recycling rates 
without having PST plants. However, without PST plants it is difficult (or even not possible) 
to  achieve  such  high  recycling  rates.  Additionally,  the  reporting  data  to  calculate  rates  is 
collected in the diverse stages of treatment process, incl. de-pollution, dismantling, shredding, 
as  well  as  exported  waste.  Countries  can  also  apply  MCA  method  what  excludes 
comparability of data among countries.  

44 The individual vehicle weight (Wi) minus weight of the de-polluted and dismantled end-of-life vehicle (body shell) (Wb) minus 
the weight of the de-polluted and dismantled materials sent for recovery, recycling or final disposal (footnote 4 to table 4 of 
the Commission Decision 2005/293/EC 

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Figure 2-4  Obtained by MS reuse/recovery and reuse/recycling rates for the ELVs45. 
Reference year 2019. 

Source: EC, ELV Statistics Explained 

45 https://ec.europa.eu/eurostat/statistics-explained/index.php?title=End-of-life_vehicle_statistics#Number_of_end-of-
life_vehicles 

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Figure 2-5  Total recycling from ELVs, 2012-2019. 

Source: own illustration of ELV data in Eurobase (Eurostat online data code: env_waselv), Oeko-Institut  

For the majority of countries the share of recycled output from shredders plays a major role 
in  calculating  re-use  and  recycling  rates  (illustrated  on  the  figure  below).  Only  for  few 
countries  does  the  recycling  of  dismantled  components  play  a  significant  role  in  the 
calculating re-use and recycling rates. The share of re-use varies widely among MS.  

Figure 2-6  Reported data on ELV treatment, 2019. 

Source: own illustration of ELV data in Eurobase (Eurostat online data code: env_waselv), Oeko-Institut  

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2.1.2.3  Common treatment of ELVs 

The treatment flow of ELVs seems to be quite similar in EU countries. The process of ELV 
treatment starts with depollution, defined in current ELVD under point 3 in the Annex I. This 
stage covers removal of e.g. batteries and liquefied gas tanks. Further treatment (to promote 
recycling) according to point 4 in Annex I of the ELVD should cover the removal of:  

•  catalysts,  
•  metal components containing copper, aluminium, and magnesium if these metals are not 

• 

segregated in the shredding process,  
removal  of  tyres  and  large  plastic  components  (bumpers,  dashboard,  fluid  containers, 
etc), if these materials are not segregated in the shredding process in such a way that 
they can be effectively recycled as materials, 

•  glass. 

In  practice,  the  dismantling  of  further  components  from  the  ELVs  depends  on  the  market 
demand for the components and the level of revenues that can be obtained by the ATF by 
selling  the  removed  components.  These  revenues  should  optimally  at  least  cover  the 
dismantling costs (depending a lot on the region). Optimally dismantling shall aim to obtain 
components for reuse/remanufacturing. However, when there is no demand for components 
that have already been dismantled, they can be subsequently sent to the recycling process, 
avoiding the shredding process. In some cases, components are removed with the intention 
to  be  sent  directly  to  the  recycler  (e.g.  engines).  This  can  be  the  case  when  the  obtained 
revenue is higher than the one an ATF would get when the component is not removed and 
thus sent to the shredder in the hulk. In reality, removal of glass is not common, mainly due 
to  high  dismantling  costs  and  low  revenue  of  dismantled  material  (more  about  this  in  the 
chapter 2.1.2.5.4).  

At  this  stage,  ATFs  are  to  store  depolluted  parts  or  fluids  as  well  as  components  for 
reuse/remanufacturing or recycling in the appropriate conditions and not causing any damage 
on them.  

Removal of materials from ELVs prior to shredding can maximise their recovery from ELVs. 
It  prevents  mixing  of  materials  at  the  shredding  stage  and  preserves  their  value,  and 
recyclability and reusability properties.  

The  figure  below  illustrates  typical  stages  of  the  ELV  waste  management  and  treatment 
processes performed on the outputs of each stage. 

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Figure 2-7  Stages of the ELV waste management and treatment processes performed 
on outputs of each stage. 

Source: own illustration, Oeko-Institut 

Up to 35% of total mass of ELVs can be removed (according to the data reported by the MS, 
please  see  Figure  2-1)  before  the  vehicle  hulk  is  sent  to  the  shredder.  The  figure  below 
illustrates schematical presentation of typical processes of ELV treating in shredders (details 
might  differ  with  regard  to  dust  treatment  or  sieve  cut)  (Mehlhart  et  al.  2018).  During 
shredding, the vehicle is broken into smaller parts to be sorted the various fractions. The main 
output of the shredder process is quality steel scrap (with high density, high degree of purity 
and predominantly homogenous size) which is separated from the shredded input material 
by magnetic separator. The obtained ferrous stream might still contain non-ferrous pieces, 
causing a certain degree of impurity in stream, e.g., with copper wire from electric motors that 
remains attached to ferrous components in the ferrous stream. These pieces can be removed 
manually  to  obtain  higher-quality  steel  scrap.  The  resulting  ferrous  scrap  is  the  finished 
product of the ferrous stream. Remaining steel scrap can be used directly in metal works to 
produce steel. 

The other fraction obtained after magnetic separation is Shredder Heavy Fraction (SHF) that 
can be additionally classified to several fractions whereas the smallest one (< 10 (15) mm) is 
similar  to  post-shredder  treatment  plant  (PST)  and  treated  together  with  it  (Mehlhart  et  al. 
2018). The biggest fraction (> 100 mm) can be handpicked to remove Al alloys, Cr-Ni-steel-
Fe/Cu composites. The rest is treated in Eddy Current. The outcomes of this process are non-
metallic and metallic fractions, where the last contain mainly aluminium but also Mg, Al, Cu, 
brass,  Zn.  Some  shredding  companies  ship  this  product  to  companies  specializing  in  the 
further separation of these metals, other process these non-ferrous metals through a heavy 
media station46 (high density technic) and sensor-based separation to separate the Al, Mg, 
Cu, brass, Zn and remaining stainless steel. The rest of this process is a non-metallic fraction 
that together with SLF can be further treated in the (PST).  

46 It is a heavy medium such silicon or sand and take advantage of the low density of aluminium, which causes the aluminium 
to float and the other metals to sink. (Brahmst 2006). 

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Figure 2-8  Schematical presentation of process of ELV treatment in shredders 

Source: (Mehlhart et al. 2018) 

Whether the shredder residues are to be disposed, depends on the national regulations. 7 
MS (out of 13) declare that the disposal of untreated SLF and SHF are allowed in their country 
(EU MS ELV IA Survey 2022). In 4 countries it is also allowed to consider untreated SLF/SHF 
for the purpose of road construction (e.g., on landfills). For 3 of those countries this process 
is considered as recycling.  

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Some but not all shredders have integrated post-shredder technology (PST) or separate PST 
on site; other shredders send residues of the shredding process to offsite PST plants while 
some operators send shredder residues without PST for disposal e.g., at landfills.  

The outcomes of PST are ferrous and non-ferrous fractions and fractions for further treatment 
under some recycling operations or for final disposal, e.g. incineration (Mehlhart et al. 2018).  

In 4 MS the disposal in landfills of fractions from post-shredder treatment is not allowed. In 
some  countries  where  disposal  in  landfills  of  fractions  from  PST  is  allowed,  the  costs  for 
disposal are higher than the costs for recycling or thermal treatment. Some countries admitted 
that  due  to  a  disposal  ban  in  their  countries  the  recycling  rates  of  ELVs  increased.  Some 
countries defined certain criteria for acceptance of waste at the landfill that have to be fulfilled 
(e.g. POP content in the residues or that the residues intended for landfill cannot be recycled 
or incinerated anymore). 

The average allocation of the input material to the products of shredding process could be 
(Sander et al. 2020)47: 70 % is allocated to ferrous fraction with Cu-contamination, 11 % in 
SHF, 18.5 % in SLF and less than 0.5 % are losses. 

The composition and purity of the resulting products largely depends on the fraction of items 
that  enter  the  process.  In  practice,  ELVs  are  often  mixed  with  other  materials,  e.g.,  as  an 
outcome  of  eight  surveyed  shredding  companies,  shredded  material  at  these  companies 
consisted  of  45-80 %  automotive,  15-80 %  appliances  and  5-15 %  other  items.  (Brahmst 
2006)  

As demonstrated in several studies untreated SLF contains several percent of residual metals 
with up to 7.8 %, respectively 6.3 % or according to studies performed more than a decade 
ago and up to 11 %. A German study (Sander et al. 2017) on SLF concluded that the recovery 
of  metals  in  SLF  should  be  more  ambitious  and  should  be  targeted  towards  technical 
possibilities. The removal of metal from the shredder light fraction at least to below 1 % metal 
content by means of post-shredder separation is considered to be feasible. In Switzerland, 
such  an  approach  is  already  implemented:  According  to  Article  21  of  the  Swiss  Waste 
Ordinance, metal pieces are to be removed and recycled from the lightest fraction that occurs 
during the comminution of metal-containing waste (light fraction). 

According to (Mc Kenna 2014) a total of 352 “automotive shredders” were operating in the 
EU-28 and Norway in 2014. Most of these were in Italy (62), France (50), UK (47), Germany 
(43) and Spain (31). The remaining 33% of this type of shredder are distributed across 20 
countries. Almost all Member States have at least one shredder for ELVs. The findings of (Mc 
Kenna  2014)  are  not  fully  in  line  with  the  reporting  of  the MS  to  Eurostat: Only  Malta and 
Luxembourg report to Eurostat not having a national shredder (source: Statement of Eurostat, 
18 April 2020). Compliance with BAT and capacity for post-shredder treatment are unknown. 

47 Trials that were performed within the study on two shredder treatment plants. 

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Figure 2-9  Number of auto shredders per country. 

Source: (Mc Kenna 2014) 

2.1.2.3.1  Shredders and PST – standards 

Under  "non-normal  operating  conditions"  in  shredder  facilities  smoke,  dust  and  possibly 
dioxins may be released, e.g., by deflagration and or fire. Such conditions can be caused by 
fuel residues or Li-ion batteries left in end-of-life vehicles. The number of deflagrations varies 
from one shredder site to another. For poorly managed shredders, 50 deflagrations per year 
are reported. An efficiently managed shredder is able to reduce the number of deflagrations 
to one per year. 

The  ELV  Directive  defines  minimum  technical  requirements  for  treatment  operations  for 
depollution of ELVs (Article 6(3) and Annex I (3)) as well as for treatment and for storage, 
which  refer  to  the  dismantling  processes  performed  by  ATFs  (Annex  I  (1)  and  (2)), 
nonetheless no such requirements for shredder processes (incl. post-shredder plants) exist 
in  the  current  Directive.  (Pinasseau  et  al.  2018)  defines  detailed  rules  for  the  operation  of 
shredders  to  minimise  emissions  under  standard  conditions  and  to  minimise  deflagrations 
and fires.  

2.1.2.3.2  Treatment of Persistent Organic Pollutants (POPs) 

As reported in a study funded by ACEA48, for several components of ELVs, diverse literature 
mentions concentrations of POPs (including decaBDE) beyond the allowed 1000 mg/kg. A 
more recent analysis for the German Federal Environmental Agency confirms that decaBDE 

48 Mehlhart et.al (2018): Effects on ELV waste management as a consequence of the decisions from the Stockholm 
Convention on decaBDE; study commissioned and funded by ACEA, the European Automobile Manufacturers Association 

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occurs  in  the  SLF  with  concentrations  beyond  1000  mg/kg49.  A  study  for  the  Norwegian 
Ministry of Environment50 concludes that “The fine and coarse ELV shred fractions however 
contain  medium  levels  of  MCCP  (30  -  210  mg/kg)  and  at  least  occasionally  high  levels  of 
decaBDE (e.g. 1650 mg/kg). Both concentration levels are considered reasonable due to the 
expectable presence of PVC cables containing chloro-paraffins and flame retarded materials 
like textiles or cable tubes. Due to the presence of these pollutants and the fact that these 
shredding materials contain unfavourable mixtures of plastics [… they] are not considered for 
recycling.” 

According  to  the  POP-Regulation  Annex  V,  POPs-containing-components  must  be 
separated:  “Pre-treatment  operation51  prior  to  destruction  or  irreversible  transformation 
pursuant  to  this  Part  of  this  Annex  may  be  performed,  provided  that  a  substance  listed  in 
Annex IV that is isolated from the waste during the pre-treatment is subsequently disposed 
of in accordance with this Part of this Annex. Where only part of a product or waste, such as 
waste equipment, contains or is contaminated with persistent organic pollutants, it shall be 
separated and then disposed of in accordance with the requirements of this Regulation. In 
addition, repackaging and temporary storage operations may be performed prior to such pre-
treatment  or  prior  to  destruction  or  irreversible  transformation  pursuant  to  this  part  of  this 
Annex.” 

Unfortunately, no data is available as to which components containing POPs are contained 
in the individual vehicles reaching end-of-life and as to where these components are located. 
In this  respect,  it  is  not feasible  to  dismantle  such  components  prior  to  shredding  with the 
current level of information. Even if such information were available, such dismantling would 
entail very high dismantling costs.   

Instead, the majority of these POPs are directed to the Shredder Light Fraction (SLF) and, 
when Post Shredder Treatment (PST) is applied, to the granulate with a specific weight > 1.3 
g/cm3, which includes the PVC fraction as well.  

Considering these facts, and according to the current POPs Regulation, it is not allowed to 
dispose of SLF, respectively the PST granulate to which the POPs are intentionally directed 
to.  Not  only  because  the  concentration  of  decaBDE  might  exceed  the  limit  in  the  POP 
regulation, but simply due to the fact that components containing decaBDE are not separated 
before  shredding  (see  underlined  citation  above)  and  thus  the  subsequent  fraction  is 
considered contaminated. However, the POPs Regulation is to some extent not coherent as 
on  the  one  hand  it  requires  dismantling  of  components  containing  POPs  and  on  the  other 
hand it allows by way of derogation in Article 7(4a) that “waste containing or contaminated by 
any substance listed in Annex IV may be otherwise disposed of or recovered in accordance 
with the relevant Union legislation, provided that the content of the listed substances in the 
waste is below the concentration limits specified in Annex IV;52” 

49 Sander et.al (2020) Evaluierung und Fortschreibung der Methodik zur Ermittlung der Altfahrzeugverwertungsquoten durch 
Schredderversuche unter der EG-Altfahrzeugrichtlinie 2000/53/EG, published by Umweltbundesamt UBA Texte 15/2020 

50 Ramboll / Fraunhofer IVV (2021) Environmental Pollutants in Post-Consumer Plastics; study for the Norwegian Environment 
Agency 

51 Shredding is considered as a pre-treatment operation. Shredding is not a final treatment operation but a separation with 
subsequent final treatment (recovery or disposal) operations.  

52 The current “upper level” in Annex IV for the listed PBDE (including decaBDE) is “Sum of the concentrations of 
tetrabromodiphenyl ether, pentabromodiphenyl ether, hexabromodiphenyl ether, heptabromodiphenyl ether and 
decabromodiphenyl ether: 1 000 mg/kg. The Commission shall review that concentration limit and shall, where appropriate 
and in accordance with the Treaties, adopt a legislative proposal to lower that value to 500 mg/kg. The Commission shall 
carry out such review as soon as possible and, in any event, not later than 16 July 2021.” 

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2.1.2.4  Market condition for recyclates (recycled content) 

The  production  of  cars  continues  to  largely  rely  on  primary  materials,  which  have  a  much 
higher environmental footprint than recyclates. To change this, materials need to be recycled 
in larger volumes and or at similar (e.g. equivalent alloy quality) or higher qualities to that of 
the material initially used in the vehicle (e.g., vehicle grade or equivalent). In the context of 
circularity, the recently adopted Chemicals Strategy for Sustainability (CSS) strives for a safe 
and  sustainable-by-design  approach  and  for  non-toxic  material  cycles:  “As  a  principle,  the 
same limit value for hazardous substances should apply for virgin and recycled material”. This 
will affect in practice the recycling of certain materials, in particular those with long lifespan 
that contain substances that were not regulated by the time of production but are currently 
restricted (legacy substances) and that may still end up in waste streams for many years to 
come, mixing with cleaner materials. The related EU polices (CEAP, CSS, etc..) should look 
to complement one another and ensure a smooth interface between chemicals, waste, and 
product policies. 

To further promote the use of secondary materials instead of primary ones, it may also be 
necessary to foster the market for such materials, i.e., in cases where the cost of recycling 
materials at equivalent or higher quality may be prohibitive in light of fluctuations in the market 
price of recyclates. The same counts when the external costs of primary production are not 
properly  reflected  in  the  market  prices  or  when  there  is  lack  of  economies  of  scale  in 
secondary production to compete with primary raw materials. The CEAP inter alia aims at a 
reduction of waste by linking design issues to end-of-life treatment and introducing rules on 
mandatory use of recycled materials for the construction of vehicle components. For instance, 
the  uptake  of  recycled  plastics  and  more  sustainable  plastics  in  vehicles  is  a  targeted 
measure of the CEAP.  

For  example,  for  plastics  and  tyres,  EuRIC  (2022a)  and  EuRIC  MTR  (2022)  refers  to  the 
option of a recycled content target as a means of ensuring the demand of recyclate. This is 
understood to be important to give certainty to waste operators as to the economic feasibility 
of  developing capacities,  in  particular  where there  are  fluctuations  on the  market  prices  of 
virgin materials that could lead to an inconsistent demand for secondary materials.  

As regards the use of secondary metals, most stakeholders do not agree that recycled content 
targets would be needed to support the uptake of secondary raw materials (SRM) nor that 
this  would  promote  more  recycling.  “Metals  are  in  demand  and  are  cost  competitive  as 
secondary  materials.  We  will  need  more  metals  in  the  future  to  fulfil  the  demand  […for 
aluminium]  around  92-95%  is  recycled”  (Eurometaux  21  Feb  2021).  EU  Aluminium  (2022) 
further emphasize the relevance of different qualities of secondary materials. It is explained 
that  with  the  shift  towards  electric  vehicles,  that  the  amounts  of  wrought  alloys  used  in 
vehicles are expected to increase, whereas the amounts of cast alloys used will decrease. 
Without intervention in treatment quality and separation of various alloy types, this and other 
market developments are expected to create a surplus in the supply of low-quality cast alloys, 
which  are  the  result  of  recycling  today,  when  ELVs  are  shredded,  and  aluminium  scrap 
separated therefrom. In this case, all alloys are mixed and the secondary aluminium in terms 
of  quality  (impurities)  can  only  be  applied  for  applications  of  cast  alloys  where  the  quality 
requirements are lower. However the increase in the use of wrought alloys and vice versa will 
create a higher dependency on primary materials if not dealt with in the waste management 
in a way that shall ensure recycling of more wrought alloys. Of an opposite opinion are some 
of the Original Equipment Manufacturers (OEMs) e.g. Volvo and Tesla, which suggest that 
the use of cast and wrought alloys will grow at the same rate (personal communication with 
DG GROW). 

EUROFER explains that increasing recycled content makes sense to stimulate the demand 
for recyclate in cases where there is no market e.g. plastic. However, in the case of metals 

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like steel, EUROFER states that “more primary steel will be needed in another product. Steel 
scrap  might  be  diverted  from  one  product  to  another  without  any  overall  environmental 
benefits” (EUROFER 27.10.21). 

In short, looking at the different materials used in the manufacture of cars and how they are 
treated at end-of-life, suggests that in some cases the current practices may create market 
failures that need to be addressed in the coming years to promote circularity in the vehicle 
sector. To do this, it may be necessary to introduce new measures that affect the design of 
vehicles or their treatment at end-of life (e.g. through technical requirements, administrative 
requirements, etc.). Such measures could help decrease the dependency of the European 
market on the supply of materials for vehicle manufacture from non-EU countries and thus 
increase the general resilience of the Union. 

2.1.2.5  The  current situation  of specific  raw material  in vehicles 

and their waste management 

The sections above provide an overview of the design and waste management of vehicles 
and provide some insights for specific materials. As the material flows are affected by all life 
cycle phases of a vehicle (manufacture, use and EoL), it is difficult to refer to specific materials 
without  providing  a  complete  overview  of  the  situation.  How  the  different  materials  are 
affected by the current legislation and by different policy developments can differ. In some 
cases, a market failure such as the fluctuating costs of virgin plastics can have a significant 
impact on investments in recycling technologies. In others, like glass, the lack of alignment 
with other legislation in terms of the quality of recycling deemed acceptable leads to glass 
being  treated  differently  by  different  branches  at  EoL.  For  this  reason,  an  overview  at  the 
material level is provided in this section for a selection of materials used in vehicles to provide 
more detail to some of the aspects raised above as well as data for the analysis to be carried 
out later on.  

Table 2-1 shows the material composition of passenger cars in 2020 according to the model 
(see  model  description  in  Annex  I.  The  data  from  JRC-RMIS53  on  the  composition  of 
European passenger cars was used for metals, supplemented by data from the Greet model 
(Argonne  2021)  on  North  American  passenger  cars  for  other  materials.  The  percentage 
composition  was  calculated  down  to  the  average  weight  of  ELVs  in  the  EU  according  to 
Eurostat. 

Table 2-1  Material composition of End-of-life vehicles (passenger cars) for 2020 in 
kg after depollution, battery weight excluded 

Material  

Steel 

Cast Iron 

Wrought Aluminium 

Cast Aluminium 

Copper 

Magnesium 

Manganese 

Glass 

53 https://rmis.jrc.ec.europa.eu/apps/veh/#/p/viewer 

ICEV 

 653  

 101  

 40  

 79  

 14  

 5  

8 

 24  

68 

HEV 

 660  

 101  

 58  

 91  

 20  

 5  

8 

 21  

PHEV 

 621  

 96  

 76  

 93  

 23  

 5  

8 

 22  

EV 

 642  

 16  

 108  

 77  

 35  

 1  

7 

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Material  

ICEV 

HEV 

PHEV 

Silver 

Gold 

Nd 

Dy 

Average Plastic 

Rubber 

Glass Fiber-Reinforced Plastic 

Others 

Total 

 0.008  

 0.009  

 0.010  

 0.001  

 0.009  

 0.002  

 0.034  

 0.135  

 0.151  

 0.003  

 0.063  

 0.072  

 159  

 41  

 9  

 5  

 129  

 34  

 4  

 6  

 143  

 38  

 5  

 7  

EV 

 0.013  

 0.002  

 0.159  

 0.075  

 166  

 39  

 5  

 14  

 1 137 

 1 137 

 1 137  

 1 137  

Source: Calculated with data from JRC-RMIS (for metals) and Argonne 2021 (for other materials) and average weight 
according to Eurostat 

Observed trends of use of certain materials in the shift from conventional vehicles to EV based 
on the above table and on available information in general: 

•  Changes  of  use  of  ferrous  metals  in  EV  –  slight  reduction  in  use  of  steel,  significant 

decrease in use of cast iron,  

• 

•  Changes in use of aluminium in EVs in comparison to conventional vehicles – shift from 
cast Al being main type of al alloys to wrought Al being the more significant group of Al 
alloys – mainly attributed to engine.  
Increase in use of copper in EV – in part higher due to battery (excluded in the data shown 
above) and due to the increase in use of power electronics in vehicles. 
Increase in use of critical metals, like rare earths due to magnets in electric engines and 
cobalt due to battery (excluded in the data shown above) or precious metals like gold and 
silver. due to the increase in use of power electronics in vehicles. 

• 

Figure 2-10  Materials from collected ELVs in EU assumed to be either reused or 
recycled and losses of these materials in the treatment process (in 2020) 

Source: Own calculation with data from Euro 7 Impact Assessment, JRC-RMIS and Argonne 2021, see model description in 
Annex I 6.9.2 

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2.1.2.5.1  Steel 

The automotive sector is responsible for the use of 12 % of the steel worldwide. At European 
level, the automotive sector is responsible for the consumption of 16 % of the steel in the EU 
(23.077 million of tons in 2020). (EUROFER 2021a) 

Figure 2-11 shows the development of the total amount of steel from ELVs in the EU from 
2020 to 2035. 

Figure 2-11  Development of total amount of steel in ELVs in the EU from 2020 to 
2035 

Source: Own calculation with data from Euro 7 Impact Assessment, JRC-RMIS and Argonne 2021, see model description in 
Annex I 6.9.2 

On average, 650 kg of steel is used per vehicle. Steel is mainly used in body structure, panels, 
doors and trunk closures for high-strength and energy absorption in case of a crash54, see 
Table 2-2.  

Table 2-2  Distribution of total amount of steel on the different parts of End-of-life 
vehicles (passenger cars) in % after depollution 

Steel  

Body 

Powertrain System (Including BOP) 

Transmission System/Gearbox 

Chassis (w/o battery) 

Traction Motor 

Generator 

Electronic Controller 

Total 

ICEV 

58% 

11% 

3% 

28% 

0% 

0% 

0% 

HEV 

49% 

18% 

5% 

24% 

1% 

1% 

0% 

PHEV 

47% 

20% 

5% 

23% 

2% 

2% 

0% 

EV 

57% 

4% 

6% 

28% 

4% 

0% 

1% 

 100 % 

100 % 

100 % 

100 % 

Source: Calculated with data from JRC-RMIS (total amounts of steel per vehicle) and Argonne 2021 (distribution on the 
different parts) and average weight according to Eurostat, see model description in Annex I 6.9.2 

54 https://worldsteel.org/steel-topics/steel-markets/automotive/ 

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Over  the  last  decades,  previously  used  mild  steel  (with  a  relatively  low  strength-to-weight 
ratio) has been increasingly displaced by various types of conventional high-strength steel 
(HSS),  advanced  high-strength  steel  (AHSS)  as  well  as  alloys  based  on  aluminium  or 
magnesium  alloys  and  polymer  materials.  A  significant  shift  away  from  steel  in  modern 
vehicles  has  been  the  switch  from  cast  iron  to  cast  aluminium  engine  blocks.  According 
stakeholder  communication,  there  is  also  a  shift  from  steel  to  aluminium  expected  in  the 
future. In the model for this study this is not taken into account. This is driven by increasing 
safety demands, light-weighting and manufacturing cost reductions. (Peck et al. 2020) 

According to the American Iron and Steel Institute, on average the steel used in car bodies is 
made with about 25 % secondary material. According to EUROFER, the amount of secondary 
steel used in vehicles (and other applications) is limited in relation to the quality requirements 
of the alloy needed and does not reflect a lack of supply. All steel has at least a little amount 
of secondary material (scrap), which is always included, for metallurgical and thermodynamic 
reasons.  

The amount depends on the intended application and can range between 5-85 %, depending 
on the application in the vehicle (EUROFER 27.10.21): 

•  External  components  –  the  steel  sheet  must  be  relatively  pure  with  no  copper 
contamination. Usually 5-10% scrap will be included, depending on its purity. 30 % is the 
higher  limit  with  20-25%  scrap  already  indicating  very  clean  scrap that  can  be  used  at 
higher shares, but respectively higher recycling costs.  

•  Long parts are used in the internal body (a bar) – here 80-85 % steel scrap can be applied 

as input.  

In other words, though secondary steel can be integrated in large amounts in structural parts, 
parts made of steel sheet have a much lower tolerance to impurities and thus allow integration 
of much smaller share of secondary steel.  

Steel in ELVs is understood to have a high recovery rate – considered to enable above 90 % 
recycling. Higher levels are possible but at higher costs. (EUROFER 2021a) 

EU  wide,  the  commonly  applied  method to treat  steel  are  shredder/PST  facilities  (process 
described under 2.1.2.3).  

Alternatively,  according  to  (Mehlhart  et  al.  2018)  massive  scrap  is  increasingly  treated  by 
scrap shear, not shredders, especially if the scrap is exported to steel plants working under 
lower  environmental  standards  and  producing  lower  level  steel  qualities.  Hence,  big 
shredders (high throughput) are often not economically sensible in many parts of Europe. 

Brokers connect the processors to individual scrap consumers (mills and foundries)55. Scrap 
is classified and sold by grades. The existing classification schemes56 specify the dimensions 
of  the  scrap  piece,  the  origin  of  the  scrap,  and  define  limits  on  impurities  and  residual 
elements,  which  make  a  distinction  into  different  categories,  linked  to  the  compositional 
information  required  by  the  final  product,  e.g.  different  content  of  copper.  The  final 
composition is not typically measured until scrap has been mixed with other raw materials 
and melted. When copper control is critical, the scrap processors can adjust their preparation 
for steel, frequently by hand-picking of copper parts from the line. (Daehn 2019) 

55 Scrap and brokers tend to establish long term relationship and agreements with mills and steel makers. This partnership is 
based on specifications of the mill on the scrap delivered. 

56 Institute of Scrap Recycling Industries (ISRI), EUROFER, Japanese Ferrous Raw Materials Association 

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Most steel scrap contains other metals. If these metals cannot be extracted from the Electric 
Arc Furnace (EAF)57 melt, then they are known as “tramp elements”, e.g., Cu, Ni, Sn, As, Cr, 
Mo, Pb and others. According to (Nakajima et al. 2011) the most important tramp elements 
in steel recycling are copper (Cu) and tin (Sn), both causing hot shortness, a phenomenon 
leading to surface cracking in hot rolling and forming. In the case of copper this phenomenon 
occurs when the concentration of copper is over 0.1 wt % and for tin even at concentrations 
as low as 0.04 wt % (Daehn et al. 2017a). 

Copper  in  end-of-life  scrap  originates  mostly  from  copper  wires  and  motors  in  automotive 
(more  in  following  chapter  2.1.2.5.2).  Tin  is  in  packaging  tinplate  and  makes  up  a  much 
smaller portion of the scrap stream (less than 1 %). In contrary to tin, that can be isolated and 
treated more readily prior to melting, copper is currently the main barrier to producing high 
quality steel from end-of-life scrap.  

Nominal tolerance on the copper concentration in steel defines the applicability of recycled 
steel. Reinforcing bar has a nominal tolerance of 0.4 wt % copper, whereas flat products (e.g. 
steel sheets) have more stringent limits (less than 0.06 wt % copper from drawing steel). The 
copper concentration in ELV scrap (shredded) can be between 0.23 and 0.7 % (Daehn et al. 
2017b).  A  shredded  scrap  sorting  trial  performed  by  ArcelorMittal  demonstrated  the  Cu 
content at 0.6 % (Russo et al. 2011).  

In  recycling  of  steel,  the  commercially  practiced  solution  for  reducing  the  concentration  of 
tramp elements (also copper) in the steel melt is dilution with primary iron source or with less 
contaminated scrap sources (Björkman and Samuelsson 2013). Steelmakers can also modify 
processing. Contamination of copper can also be managed by globally trading scrap for use 
in tolerant applications. However, considering the Cu-contamination in the end-of-life scrap 
in  the  long-term,  extensive  dilution  and  careful  allocation  of  scrap  at  a  global  scale  would 
become increasingly impractical after 2050 (Daehn et al. 2017a).   

Existing models assume that demand for copper-tolerant products is likely to grow at a slower 
rate  than  demand  for  higher-quality  steels.  Additionally,  incoming  scrap  will  have  a  higher 
concentration of copper due to past accumulation. Thus, this will lead to copper excess and 
in consequence to increase of dilution and potentially to accumulation of stocks of unusable 
steel scrap. (Daehn et al. 2017a) 

A further motivation for the removal of copper is also possible increases in the demand for 
copper.  This  can  also  be  related  to  supply  limitations  that  can  occur  due  to  geo-political 
developments such as the case of Ukraine which is a key supplier of copper and which has 
had difficulties in ensuring the supply since the war. 

The figure below illustrates the estimated mass of copper in the end-of-life scrap supply and 
copper that can be tolerated by end-use products from 1950-2100. The figure includes also 
curves varying from the estimated case. By 2050 the total copper in supply shall be about the 
same as the maximum that can be tolerated across all products and to match supply with 
demand.  

57 Electric Arc Furnace (EAF) is commonly used to make steel from scrap. This process leads to around on-third the 
greenhouse gas emissions associated with steelmaking from ore. (Yellishetty et al. 2011. 

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Figure 2-12  Mass of copper in the end-of-life scrap supply and copper tolerance by 
demanded products between 1950 to 2100 at a global scale (Daehn et al. 2017a) 

Legend: Sensitivity curves apply high and low values for copper concentration across all categories, vary the total quantities of 
end-use steel demand and scrap supply across all sectors ±30%, and vary the proportion of the construction sector by ±30% 
(while other sectors decrease/increase by 30%, respectively). 

Source: (Daehn et al. 2017a) 

The  copper  concentration  in  vehicles  will  increase  together  with  the  electrification  of  the 
vehicles (more details in chapter 2.1.2.5.2), if the treatment of vehicles at end-of-life does not 
change to accommodate this situation this trend could influence the Cu-concentration in steel 
scrap recovered from ELVs.  

Nevertheless, (Daehn et al. 2017b) states that the future copper concentration in ELV steel 
scrap  could  be  influenced  by  (a  mix  of)  serious  interventions:  more  disassembly,  better 
shredding,  better  sorting,  chemical  extraction,  increase  in  copper  tolerance,  reduction  in 
copper content in new cars58 supported by policy provisions (for more details please refer to 
chapter 2.1.2.5.2).  

There is also the possibility of intervening in the design of vehicles to promote a reduction in 
copper content in future cars. For example, research into alternative materials for the wire 
harness is looking into aluminium and optical fibres as light weight options59. Implementation 
of such alternatives could affect the design of the vehicle, for example where this results in a 
thicker wire harness and would need to be integrated into design before its implementation 
but could provide relief for the difficulties encountered in steel recovered from should the level 
of copper impurities continue to increase. 

58 For instance, design exist for use of weight-saving aluminium wire harnesses instead of copper wires Daehn et al. 2017a. 
Thus, upstream techniques have the potential to prevent copper from entering the scrap steam. 

59 See for example: https://sumitomoelectric.com/sites/default/files/2022-05/download_documents/sei_id002.pdf and 
https://www.marketsandmarkets.com/Market-Reports/automotive-wiring-harness-market-170344950.html, last viewed 
20.12.2022 

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According to (Nakamura et al. 2014) only 7 to 8 % of recovered car steel is recycled back into 
the automotive sector. (Daehn et al. 2017a) estimate a mass of copper that would be required 
to remove from ELV steel scrap to allow its use in production of main intermediate products 
in cars that require either 0.06 or 0.1 % copper. The authors expect that using ELV scrap for 
the production of new vehicles (a theoretical closed loop) would reduce the amount of iron 
ore required from 136 to 78 Mt, accounting for 32 Mt of fabrication scrap generated in car 
manufacturing.  

(Willman  et  al.  2017)  analysed  the  possible  trends  and  improvements  in  the  steel  scrap 
sorting  process  through  increased  information  about  the  alloy  content  within  the  scrap 
category E40. The results of this thesis conclude that it may be possible to separate alloy 
enriched scrap and purified scrap. In consequence, it is to expect an increase of the market 
value of steel scrap, a decrease of use of virgin materials to produce steel from steel scrap, 
and  a  decrease  of  environmental  impacts  from  production  of  steel  from  steel  scrap.  The 
authors also claim that it is economically beneficial to have a separation between an alloyed 
enriched scrap and a purified scrap for the steel scrap category E40. These products, within 
scrap category E40, contain valuable elements such as Cu, Cr, Ni and Mn that can be treated. 
Thus,  these  economic  profits  could  cover  some  of  the  expenses  from  the  investment  in 
automatic sorting technology. However, the authors defined further required investigations in 
this field to successfully implement possible investment models: more random sampling of 
the scrap flow to obtain more data on alloy content in scrap, more research about a possible 
automatic sorting solution. 

2.1.2.5.2  Copper 

The comparison of the use of copper in electric and conventional cars in Figure 2-13 shows 
that an average amount of 53.2 kg is present in each electric vehicle, while 22.3 kg is the 
average quantity in traditional cars. The increase is mainly related to the use of copper in EV 
batteries (excluded in the figure), electric power control and electric motors.  

Figure 2-13  Composition of EV and Conventional car60 

60 https://www.iea.org/data-and-statistics/charts/minerals-used-in-electric-cars-compared-to-conventional-cars 

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Conventional  cars  have 8-22  kg  of  copper,  hybrid  electric  vehicles (HEV)  contain  approxi-
mately  39  kg,  plug-in  hybrid  electric  vehicles  (PHEV)  use  60  kg,  battery  electric  vehicles 
(BEVs) contain 83 kg, a hybrid electric bus contains 89 kg, and a battery electric bus contains 
369 kg, most of which is used in the battery61.Table 2-3 shows in which parts of the car the 
copper  occurs.  According  to  (Villanueva-Rey  et  al.)  the  wire  harness  is  the  largest  part  of 
copper, ranging from 15  kg to circa 30 kg depending on car size. 

Table 2-3  Distribution of total amount of copper on the different parts of End-of-life 
vehicles (passenger cars) in % after depollution 

Copper  

Body 

Powertrain System (Including BOP) 

Transmission System/Gearbox 

Chassis (w/o battery) 

Traction Motor 

Generator 

Electronic Controller 

Total 

ICEV 

42% 

44% 

0% 

14% 

0% 

0% 

0% 

HEV 

21% 

15% 

24% 

7% 

15% 

15% 

4% 

PHEV 

18% 

15% 

19% 

6% 

20% 

20% 

3% 

EV 

17% 

17% 

18% 

6% 

34% 

0% 

8% 

 100 % 

100 % 

100 % 

100 % 

Source: Calculated with data from JRC-RMIS and Argonne 2021 and average weight according to Eurostat, see model 
description in Annex I 6.9.2 

Together  with  the  increase  of  use  of  EV  vehicles, copper  demand  is  expected  to  increase 
(Betz et al. 2021). However, design exists for use of weight-saving aluminium wire harnesses 
instead of copper wires (Daehn et al. 2017a).  

Figure 2-14 shows the development of the total amount of copper from ELVs in the EU from 
2020 to 2035. 

Figure 2-14  Development of total amount of copper in ELVs in the EU from 2020 to 
2035 

Source: Own calculation with data from Euro 7 Impact Assessment, JRC-RMIS and Argonne 2021, see model description in 
Annex I 6.9.2 

61 https://www.copper.org/publications/pub_list/pdf/A6191-ElectricVehicles-Factsheet.pdf 

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Common practice on recovery of copper is a stepwise process in which first the residues of 
shredder  process  are  separated  (magnetic  separation)  into  two  fractions:  ferrous  and 
shredder  heavy  fractions  (SHF).  The  SHF  contains  most  of  the  non-ferrous  metals,  which 
separation can be done by use of Eddy Current Systems (ECS). The obtained second fraction 
after ECS can be send to PST to treat it further. The potential to remove additional copper in 
the PST relies on the PST equipment or additional eddy current technologies.  

Some components that contain Cu, like wheels, transmissions, and engines may be removed 
prior to shredding for re-use. Others, like wire harnesses, smaller motors that are difficult to 
remove and are not interchangeable with other vehicles remain in hulk and together with steel 
bodies  are  hammer  shredded  and  copper  wires  become  enmeshed  such  that  magnetic 
separation is only partially effective.  

Alternatively, copper-containing parts can be removed manually from ELVs prior to shredding 
(dismantling process), what is more in practice in countries where lower labour costs exist. 
An  alternative  to  hand-picking  is  automatic  dismantling,  however  its  efficiency  depends  on 
the design of a vehicle62 (e.g., convenience of access to the wire harness). 

Alternative  shredding  processes  exist  to  help  sort  copper-rich  pieces  as  well  as  to  more 
precisely  determine  the  composition63  of  a  batch  before  melting,  e.g.  laser-induced 
breakdown  spectroscopy,  X-ray  fluorescence,  neutron  activation  analysis,  or  image 
processing of a conveyor belt of scrap. (Daehn 2019) defines various techniques for copper 
separation and evaluates their potential to remove copper. It also analyses these techniques 
to show that copper could be removed to below 0.1 wt % (enabling the production of high-
value flat steel products). 

2.1.2.5.3  Aluminium 

The amount of aluminium in an average car has increased from 50 kg in 1990 to today’s 151 
kg. The average Al use in today’s vehicle vary from 62 kg in small segments to 610 kg in high 
segments (e.g. Range rover sport). Table 2-4 shows in which parts of cars aluminium occurs. 

Table 2-4  Distribution of total amount of aluminium on the different parts of End-of-
life vehicles (passenger cars) in % after depollution 

Copper  

Body 

Powertrain System (Including BOP) 

Transmission System/Gearbox 

Chassis (w/o battery) 

Traction Motor 

Generator 

Electronic Controller 

Total 

ICEV 

13% 

32% 

15% 

40% 

0% 

0% 

0% 

HEV 

12% 

26% 

8% 

35% 

6% 

6% 

7% 

PHEV 

11% 

25% 

7% 

32% 

9% 

9% 

7% 

EV 

13% 

0% 

9% 

38% 

20% 

0% 

21% 

 100 % 

100 % 

100 % 

100 % 

Source: Calculated with data from JRC-RMIS and Argonne 2021 and average weight according to Eurostat, see model 
description in Annex I 6.9.2 

62 Vehicle design changes could reduce the need for downstream interventions (Daehn et al. 2017a. 

63 The copper concentration of a batch currently might not be definitively known until it is melted and chemically analysed. This 
requires steelmakers be conservative when producing steel with stringent copper limits. This technical limitations could be an 
area for future development. Daehn et al. 2017a. 

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According to JRC-RMIS, in 2016, cast aluminium accounted for an average of 66% of the 
total  aluminium  content  per  vehicle,  extruded  aluminium  11%,  forged  aluminium  5%,  and 
rolled aluminium 18%. 

Experts project that the amount of aluminium could rise to 196 kg by 2025. Other sources 
(Kelly 2018) expect a rise of the aluminium share in a car by weight from 8 % to 16 % between 
2018  and  2028.  The  increase  of  aluminium  in  new  vehicles  will  be  mainly  due  to  wrought 
aluminium, especially series 5000 and 600064 (Kelly 2018). Estimates from (Buchner et al. 
2017)  predict the  amount  of  wrought  aluminium  in  a  vehicle to jump from  40  kg to  150 kg 
whereas the amount of cast aluminium increases slightly from 100 kg to 110 kg. The drivers 
of this development are the electrification65 (Løvik et al. 2014) and the desire for lighter and 
hence  more  energy-efficient  components,  e.g.  aluminium  sheets  (Løvik  et  al.  2014).  The 
expected  increase  of  aluminium  demand  for  semi-finished  aluminium  in  Europe  in  the 
transport  sector  is  55  %66  of  the  overall  aluminium  demand  by  2050  (Circular  Aluminium 
Action Plan67). 

Figure 2-15 shows the development of the total amount of aluminium from ELVs in the EU 
from 2020 to 2035. 

Figure 2-15  Development of total amount of aluminium in ELVs in the EU from 2020 
to 2035 

Source: Own calculation with data from Euro 7 Impact Assessment, JRC-RMIS and Argonne 2021, see model description in 
Annex I 6.9.2 

64 There are seven different alloys commonly used in aluminium manufacturing. Different alloys have different benefits, 
including workability, corrosion resistance, heat treatability, electrical conductivity, strength, and flexibility. The most common 
alloying elements are copper, manganese, silicon, magnesium, silicon, zinc. 5000 series is alloyed with magnesium whereas 
6000 series is alloyed with magnesium and silicon.  

65 Future increase in Al content in battery box, body closures, electric motor housing, body structure and chassis  

66 From slightly more than 5000 in Ktonnes in 2017 to almost 8000 Ktonnes in 2050 

67 https://european-aluminium.eu/media/2903/european-aluminium-circular-aluminium-action-plan.pdf 

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More than 90 % of the metal is recovered after the end of the vehicle’s life cycle and re-used 
to create new aluminium products (European Aluminium68). 

The current recycling process for ELV – shredding and post-shredder sorting – results in the 
production of aluminium scraps containing a mix of alloys (cast and wrought), and sometimes 
small amounts of other undesirable materials. Today, this scrap quality fits the requirements 
of European refiners for recycling into cast alloy ingots, which can be remelted to produce 
parts for the automotive industry. Most wrought alloys are produced from primary aluminium 
and usually contain lower alloying elements. However, the increasing share of wrought alloys 
in  cars  will  increase  the  loss  of  these  alloys  if  recycling  practices  remain  unchanged 
(European  Aluminium69). Without  intervention,  the  automotive  sector  will  turn  from  a  net-
consumer of aluminium scrap into a net producer in near future. This will lead to surplus scrap 
that cannot be used in recycling (Løvik et al. 2014).     

For aluminium it can be understood that recycling results in a fraction (termed zorba) which 
has a high Al content but is also rich in impurities as it is a mix of different alloys. It can be 
applied in higher amounts in alloys which are more susceptible to impurities (e.g., used for 
casting). However, to enable use in alloys with higher quality specifications, dismantling would 
need to be improved: aluminium parts would need to be sorted prior to shredding for example 
into  cast  alloy  parts  and  wrought  alloy  parts.  Eurometaux  (Eurometaux  21  Feb  2021) 
mentions  bumpers,  doors  and  the  engine  block  as  parts  of  relevance  for  removal  prior  to 
shredding. This statement is in line with the Circular Aluminium Action Plan70.  

Another option to reduce the amount of surplus mixed scrap are intelligent sorting systems 
(ISS).  These  comprise  x-ray  transmission  (XRT),  x-ray  fluorescence  (XRF),  and  laser-
induced breakdown spectroscopy (LIBS). None of these ISS have been adopted on a large 
scale and more research is required. However, their efficiency has been tested on a small 
scale with LIBS being the most promising candidate. Alloys from the series 3000, 5000, 6000 
and 7000 can be separated from cast aluminum with rates of recovery and purity all larger 
than 96 % (Kelly 2018). 

The following graph from (Løvik et al. 2014) gives an overview of the potential of alloy sorting, 
better dismantling by comparing the amounts of primary and secondary, as well as cast and 
wrought  aluminum  in  different  scenarios  in  the  automotive  sector.  Of  special  interest  is 
whether, and if so, when the surplus scrap appears. The first line reflects the current practice 
of de-magging (reducing the amount of magnesium in the scrap) and without using scrap from 
safety-relevant components71. Frame a.1 shows a business-as-usual scenario. It shows the 
onset of a scrap surplus in 2025 which will make up 28% or about 6 Mt of scrap by 2050. 
Other studies estimate the global surplus scrap to be 5.4 million tons by 2030 and 8.7 million 
tons by 2040 (van den Eynde et al. 2022). The occurring of the surplus scrap can be delayed 
to 2033 by a higher rate of dismantling (b.1) and 2047 by alloy sorting via LIBS assuming an 
efficiency  of  90  %  and  a  uniform  false  ejection  to  all  other  alloy  groups  (c.1).  The  fourth 
scenario (d.1) of high dismantling additionally to alloy sorting only shows a slight improvement 
compared to c.1 where there is low dismantling. The second line of plots shows the positive 
effect of using scrap from safety-relevant components in any of the four discussed scenarios. 
Due to the high standards for safety-relevant components, using scrap in its production would 
require an effort for intensified coordination between the players involved in their production. 

68 https://www.european-aluminium.eu/about-aluminium-in-use/automotive-and-transport 

69 https://www.european-aluminium.eu/media/3172/irt-m2p-executive-sum-20210412-final.pdf 

70 engines, heat exchangers, doors, bonnets, fenders, bumpers and gearboxes 

71 Today safety-relevant components (wheels, space frame nodes, etc.) are made from primary material. Allowing secondary 
aluminium into these components is deemed possible but only in case of close collaboration of manufacturers and foundries 
and refiners regarding their respective intern alloy specifications. 

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At the bottom, it was investigated under which circumstances the controversial72 practice of 
de-magging  could  be  stopped.  Magnesium  increases  the  strength  of  an  alloy  and  is  more 
common in wrought aluminum, especially series 5000 and 6000 (Zhu et al. 2021). For this 
reason, de-magging efforts should in fact be intensified while trying to reduce the downsides 
of the procedure such as reducing the use of chlorine (Løvik et al. 2014).  

Figure 2-16  Simulated future production of wrought and cast aluminium for 
vehicles, and the relative share covered by primary and secondary sources under 
combination of interventions in ELV management and scrap sorting (columns) and 
restrictions in aluminium/auto manufacturing industry (rows). (Løvik et al. 2014) 

Legend: The pictures display the amounts of different types of aluminium (cast/wrought and primary/secondary) as a function 
of time in different scenarios. Especially, it becomes apparent under which circumstances surplus scrap, that cannot be used 
in recycling, can be avoided. 

Source: (Løvik et al. 2014) 

72 Demagging is controversial due to the chlorine that is released in the process. Moreover, the high value of magnesium and 
the costs of the procedure make it financially desirable to minimize the extent of demagging. 

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The simulations of (Løvik et al. 2014) make out a trend for the share of magnesium in mixed 
shredded scrap increasing whereas the share of copper and silicon will decrease, all due to 
the increase of wrought over cast aluminium. (Zhu et al. 2021) emphasize the importance to 
investigate  the  composition  of  the  mixed  shredded  scrap  in  order  to  determine  the 
requirements for an intelligent sorting system. They conclude that at least series 5000 and 
6000 must be separated from the scrap in order to allow for automotive body sheet production 
without extensive dilution with primary material. 

A shift in alloy as it happened in bumper technology from series 7000 to 6000 could potentially 
hamper the recycling process and could not be justified solely based on alloy properties but 
availability would also need to be taken into account (Løvik et al. 2014). 

Multiple sources like (Løvik et al. 2014) and (van den Eynde et al. 2022) have shown the likely 
occurrence  of  surplus  scrap  of  aluminium  in  near  future  in  the  transport  sector,  to  a  large 
extent  due  to  the  electrification  and  the  desire  for  light-weight  components.  One  option  to 
mitigate the problem in the short-term is to intensify dismantling by removing parts made from 
different alloys before shredding. Furthermore, intelligent alloy sorting systems are required 
in order to avoid the occurrence of surplus scrap. To this end, further investigation is needed 
to  implement  such  systems  on  a  large  scale.  Of  special  importance  is  close  cooperation 
between the dismantlers, companies, and manufacturers to maximize the use of secondary 
aluminium while maintaining high quality standards. An emphasis needs to be on research 
on whether the required properties for a certain component can be achieved with different 
alloys that are more commonly found in secondary aluminium and on the possibility to recycle 
scrap from safety relevant components. From an economical point of view, the incentive to 
maximize the share of secondary material will increase when its availability increases, that is 
when there is already surplus scrap. However, hoping to avoid surplus scrap, the previously 
proposed  measures  should  be  incentivized  additionally,  be  it  financially  or  through 
regulations. From an environmental perspective, the advantage of secondary over primary 
aluminium  is  evident:  1 kg  of  recycled  aluminium  can  be  produced  with  9.2 MJ  of  energy, 
compared to 144.6 MJ for primary aluminium (van den Eynde et al. 2022) and emissions drop 
to 5 % when using recycled aluminium (Zhu et al. 2021). 

2.1.2.5.4  Glass 

Figure 2-17 shows the development of the total amount of glass from ELVs in the EU from 
2020 to 2035. 

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Figure 2-17  Development of total amount of glass in ELVs in the EU from 2020 to 
2035 

Source: Own calculation with data from Euro 7 Impact Assessment, JRC-RMIS and Argonne 2021, see model description in 
Annex I 6.9.2 

Glass is used in vehicles for windows (windscreen, side and back windows and sunroofs) and 
mirrors. Laminated glass is used for the windscreen and back window and tempered glass 
for side windows (see detail in annex 3.3.1.1). The percentage of glass used in vehicles is 
constant within the entire automotive industry and said (Intertek RDC & OVAM 2013?)to be 
in the range of 2.5 - 3% of the reference-weight of a vehicle: The individual weights are in a 
range of 10-20 kg for windscreens, 2-5 kg for each side window and 3-10 kg for rear windows, 
globally 20-40 kg altogether. According to Glass for Europe (2022a) automotive glazing parts 
increasingly  integrate  other  materials  than  glass  to  fulfil  extra  functions,  such  as  plastic 
interlayers for laminated safety and acoustics, ceramic inks for design, silver printing electrical 
connectors and sensors, encapsulation materials, fixing clips, and even solar PV modules in 
electric or hybrid cars, which means that recycling (after dismantling) requires the sorting of 
materials.  

There are different methods to dismantle glass from a vehicle. Intertek RDC & OVAM (2013?) 
presents different methods, explaining the differences in terms of time consumed, logistics 
and the amount of glass typically removed (see in particular section 2.3 on “Dismantling of 
automotive  glass  on  ELV”  and  table  2  in  (Intertek  RDC  &  OVAM  2013?)).  Where  glass  is 
dismantled and sorted, it can be used for manufacturing new glass. Glass for Europe (2022a) 
estimates that replacing 1.2 t raw materials by 1 t of cullet saves a total of 625 kg of CO2 
emissions: 310 kg CO2 at the manufacturing site (process emissions) and 315 kg CO2 by the 
non-production of primary raw materials. Thus, Glass for Europe members look for ways to 
continuously  increase  their  use  of  cullet.  As  explained  in  the  following,  it  can  however  be 
understood that  the  use  of  ELV  glass  cullet  is more relevant for the manufacture  of  some 
types of glass than for others.  

Ferver  states  that  requirements  in  automotive  industry  standards  and  safety  requirements 
mean that the quality of glass is critical for it to be allowed for use in vehicles. “The global 
demand of the glass industry for used/ recyclable automotive glass is rather high since it is a 
rather pure waste stream (assuming the glass is separated pre-shredder). While it is possible 
to recycle glass from vehicles (flat glass) back into new flat glass, this is not standard; most 
flat glass is recycled into packaging. Conversely, packaging glass cannot be recycled for flat 

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glass  because  of  its  impurities  (colours,  etc.).”  (FERVER  and  Denuo  2022).  FEAD  (2022) 
states  that  there  are  no  technical  limitations  to  recycling  the  front  and  rear  windows  into 
container  glass  (or  equivalent).  However,  detailed  data  as  to  the  cost  and  technical 
practicability of recycling glass into flat glass was not made available during the course of this 
study. In this regard, Glass for Europe (2022b) contend that an assessment of the recyclability 
potential  could  be  useful  for  the  ELV  Directive  review  but  is missing  when  it  comes to flat 
glass. They explain that because of the very high purity of flat glass cullet (e.g., ELV cullet), 
it is subject to fierce competition among all glass sector producers. It is especially sought after 
by container glass and glass fibre producers. 

However, according to Glass for Europe (2022a), automotive glass pieces are rarely removed 
from  vehicles  before  ELVs  are  shredded.  Consequently,  most  automotive  glass  does  not 
enter the (high quality) recycling route. It is further understood from stakeholders (Glass for 
Europe  2022a;  Intertek  RDC  &  OVAM  2013?)  that  there  is  not  a  technical  limitation  for 
recycling of ELV cullet into container glass or fibre glass but that this is mainly limited by the 
supply of such cullet, i.e., by the fact that glass is often not removed from ELV. Though in 
some cases the glass is missing from the vehicle when it arrives at the ATF due to accidents 
or  breakage  during  the  transport  of  the  ELVs  ,  the  main  reasoning  for  glass  not  being 
dismantled  is  understood  to  be  financial  as  the  costs  (dismantling,  logistics  and  transport 
costs)  are  higher  than  the  revenue  retrieved  by  ATFs  for  the  cullet.  According  to  EGARA 
(2021) the cost to transport the glass is higher than the cost of it on the market (ca. 30 €). 

There  is  very  little  data  as  to  the  amounts  of  glass  that  are  removed.  OVAM  (2012?) 
performed an analysis of the legislation and practice in other European countries in the past 
that shows that selective glass removal is not widely applied. At the time, glass removal was 
practiced  in  six  member  states:  the  Netherlands,  Austria,  Poland,  Portugal  and,  to  some 
extent, Spain, and Sweden. In two out of these six countries – the Netherlands and Poland – 
dismantlers  receive  an  allowance  for  glass  removal  alone,  or  for  the  complete  depollution 
process and dismantling of the ELV. The OVAM (2012?) report also mentioned that in France 
and Hungary the legal obligation to remove glass was approved at around the same time, but 
the consultants are aware that in Netherlands the obligation to remove glass is no longer in 
force and it is possible that there have been other changes. Only some data is available as 
to the amounts of glass removed in specific EEA countries: 

Italy – EGARA (2021) stated that glass dismantling is practiced in Italy. 

• 
•  France  –  According  to  Deloitte  &  ADEME  (2019b)  very  little  glass  is  removed  from 
vehicles  at  ELV  centres,  while  most  of  it  is  sent  with  the  hulk  to  the  shredder  which 
generally does not enable its recycling at high quality. 12% are reported as recovered at 
ATFs (meaning reused or recycled) and 60% is sent for material recovery at shredders 
and 28% is stored (it is not clear what the destiny of stored glass is). Moreover, in the full 
report it is stated that “Removal of glass for recycling remains limited and concerns on 
average national only 6% of the mass of glass present in an ELV (i.e. approximately 2 kg 
of glass extracted per ELV on average for recycling)” (Deloitte & ADEME 2019a). 

•  Netherlands – EGARA (2021) stated that glass dismantling was practiced in NL until 10 
years ago. According to Maltha Glasrecycling, a recycler of both flat and hollow glass in 
the Netherlands, “only a few dismantling companies in the Netherlands supply car glass 
for  processing  at  Maltha.  Most  car  glass  in  the  Netherlands  still  ends  up  in  the  large 
residual waste flow, which is used for things such as a base material for road construction” 
(ARN 2022a). 

•  Norway  -  In  2021,  122,212  CoDs  were  issued  for  vehicles  associated  with  the  EPR 
Autoretur. In its annual report, it was reported that 122 tonnes of glass were dismantled 
with 60 sent to reuse and 62 to recycling auto (AUTORETUR 2022). Assuming that there 
are  30  kg  of  glass  per vehicle  would  mean that glass  was removed from  around  4000 
vehicles, probably with the aim of reuse (e.g., when removed together with a door).  

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To conclude it is assumed that in 2020 the situation is similar and that there are only a handful 
of countries where glass dismantling is practiced. 

When glass is not dismantled, it remains in the vehicle and is sent to the shredder with the 
vehicle  hulk.  Though  the  “treatment  operations  in  order  to  promote  recycling”  specified  in 
Annex I of the ELVD refer to the removal of glass, there are no conditions for the quality of 
recycled glass, meaning that shredder operations qualify for the recycling of this material. It 
is  noted  that  though  shredders  accept  vehicles  with  glass,  it  accelerates  the  wear  of  the 
shredder. There is no data as to respective financial costs, but in an ARN article (ARN 2022b), 
the shredder company HKS is cited, stating “As a shredder, we prefer to receive end-of-life-
vehicle shells without glass”. It is explained that in the Netherlands, ATFs can register with 
ARN  as  glass  dismantlers,  in  which  case  HKS  only  accepts  ELVs  without  glass  from  that 
company but giving a higher pay-out for the hulks. It is understood that ARN arranges the 
transport of glass in such cases from the ATF to a glass recycler, meaning that the transport 
costs are carried by the Netherlands EPR. 

During shredding, the vehicle is broken into smaller parts and sorted first to shredder heavy 
fraction (SHF) and shredder light fraction (SLF) which go through further treatment stages. 
The glass is diverted to the mineral fraction which is a residue of the various sorting processes 
and includes glass, sand, and rust. The mineral fraction is usually used as a filling material in 
backfilling  or  construction.  Such  uses  are  considered  as  material  recovery  but  basically 
remove the glass from the material cycle and can thus be considered of a lower recycling 
quality as compared to use of the cullet in manufacture of flat glass, container glass and glass 
fibre.  Nonetheless,  as the  definition  of  the  ELVD  does  not  exclude such operations, these 
uses are accounted for in the MS reporting on fulfilment of the Directive target for reuse and 
recycling. 

In this respect it can be understood that in the current situation, the share of vehicle glass 
reused or recycled at higher quality is very low. The main obstacle for increasing the recycling 
of such glass is not the lack of demand but rather the limited supply, as in most cases the 
glass  is  not  dismantled  from  the  vehicle  prior  to  shredding,  limiting  the  applicability  of  the 
resulting  recycled  fraction.  As  for  increasing  circularity  of  glass  in  vehicles  (closed  loop 
recycling), this may be technically possible, but seems to be more costly, given that ELV cullet 
can be used for other high-quality uses that are more relaxed regarding the glass quality. 

2.1.2.5.5  Critical raw materials (CRM) and precious metals 

According  to  data  on  the  RMIS  portal  developed  by  JRC73,  magnesium  (Mg),  manganese 
(Mn),  molybdenum  (Mo),  niobium  (Nb)  and  silicon  (Si)  are  used  as  alloying  elements  for 
different types of steel, aluminium alloys, and magnesium alloys. Permanent magnets used 
in  traction  motors  contain  neodymium  (Nd),  dysprosium  (Dy),  terbium  (Tb)  and  other 
elements.  Catalytic  converters  reducing  exhaust  emissions  depend  on  metals  such  as 
platinum (Pt) and palladium (Pd). Electronic devices contain a large variety of rare metals, 
such as palladium (Pd), neodymium (Nd), dysprosium (Dy), copper (Cu), gold (Au), and silver 
(Ag), as well as other elements. The mass of electronic devices varies with heavier and often 
more luxurious cars at the higher end. Electrical and electronic devices (labelled EE system), 
power electronics and battery management systems (BMS) are key components of a vehicle 
that contain silver, which is used often in combination with gold and other precious metals on 
printed circuit boards. The use of silver and gold in vehicles increased until 2007 due to an 
increase in the number of electric and electronic components (EEC) in all vehicles (Figure 
2-18).  

73 See: https://rmis.jrc.ec.europa.eu/apps/veh/#/p/new_vehs, last viewed 20.8.2022 

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From 2007 onwards, the level of silver and gold per vehicle stabilized. The use of electrical 
and electronic devices in cars continues to increase, but this is considered to be mitigated by 
miniaturization  and  integration  of  functions.  Metals  are  also  required  for  other  EV  specific 
components, for example, battery casings, battery management systems, power electronics 
(inverters, converters, on-board chargers, and controllers) and drive motors (e.g. induction). 
The  reduction  of  combustion  engines  and  catalytic  converters  leads  to  less  use  of  metals 
needed for these components in the vehicle fleet between 2006 and 2023. However, the use 
of copper, silver, gold, silver, palladium, neodymium, and dysprosium increases between 25% 
and  1700%  in  this  period.  These  increases  can  be  attributed  to  various  degrees  to  the 
introduction of EVs and other technology changes.  

Figure 2-18  Total mass of precious metals in new vehicles in EU27+3 from 2000 to 
2020 and as projected in 2021 – 2023 

Source: Raw Materials in Vehicles (RMIS): https://rmis.jrc.ec.europa.eu/apps/veh/#/p/new_vehs 

Data from a study performed in Switzerland (Restrepo et al. 2017) is assumed to reflect the 
situation of critical raw materials and precious metals in vehicles at present and in the future, 
as the vehicle fleet in Switzerland is considered similar to that of the EU. Among others the 
study  investigated  the  content  of  CRMs  in  various  vehicle  components  with  a  view  to 
understand the total amounts of these materials used in vehicles. Restrepo et al. (2017) infer 
from  their  calculation  of  the  stock,  flows  and  distribution  of  critical  metals  in  embedded 
automotive electronics, that passenger vehicles in Switzerland contain a significant stock of 
critical metals. In comparison to critical metals in household and consumer electronics, the 
vehicle fleet in stock contained (as of 2014) similar amounts of neodymium (Nd) (mostly found 
in magnets) and approximately one fifth of the silver (Au) in WEEE. However, the mass flow 
of critical metals in ELV is only a fraction of that of critical metals in WEEE, because vehicles 
tend to  have  a  longer  lifetime  than  EEE.  The  authors  assume  that  “the  amounts  of  critical 
metals in ELVs are likely to rise over the coming decades”. The reason for this forecast is that 
the amount of embedded electronics in vehicles is bound to increase further and that newer 
generations of cars contain more critical metals intensive EEC. Larger amounts of rare earth 
metals  (REE)  are  expected  to  be  used  as  electric  vehicles  contain  REE-rich  electric  drive 
motor/generator  instead of  conventional  starter motor  and  alternator. Moreover,  integrated 
electronic  control  systems  are  expected  to  contain  more  precious  metals  than  the  EEC 
contained in older vehicles.  

Printed  wiring  boards  (PWB)  are  also  understood to  be  relevant  components  in relation  to 
their  contents  of  CRM  and  precious  metals.  PWB,  also  such  used  in  vehicle  electronics, 
typically consist of a rigid glass fibre plate base that contains a flame retarded resin (FR4). In 
addition,  small  flexible  PWBs,  which  can  be  integrated  into  other  components  such  as 
sensors, consist of a polyimide film. The PWB is lined with thin copper strips that serve as 

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electrical  conductors  between  the  individual  electronic  components.  The  latter  include  a 
variety of metals, some of which are critical or precious metals.  

The  following  table  gives  a  rough  overview  of  the  components  in  which  the  respective 
elements are found in EEE. This information is also assumed to be applicable for the most 
part for electric components used in PWB of vehicle. 

Table 2-5  Important metals used EEE (many also of relevance to EEC in vehicles) 

Metal 

Main applications in EEE 

Ag 
Au 
Pd 
Pt 
Ru 
Cu 
Sn 
Sb 
Co 
Zn 
Se 
In 
Ta 
Al 

Contacts, switches, solders, heat conductor 
Bonding wire in integrated circuits, contacts 
Multilayer capacitors, connectors 
Hard disks, thermocouples, fuel cells 
Hard disks, plasma displays 
Cables, wires, connectors, heat sink, 
Solders 
Flame retardants in plastics 
Rechargeable batteries 
Solders, capacitors, heat sinks 
Electro-optic devices, solar cells 
LCD glass, solders, semiconductors 
Capacitors 
Heat sink,  

Source: (Böni et al. 2014) 

The UBA ORKAM report (Groke et al. 2017) refers to various sources as to the elements 
contained in a vehicle PWB. All sources are dated 2014 and earlier. Data for PWBs from 
vehicles are reproduced below: 

•  PWBs contain antimony trioxide (Sb2O3) as a synergist flame retardant. Based on 5 ICE 
vehicles and 14 hybrids an average of 1,300 mg/kg was estimated (range: 540-2100 for 
ICE and 30-5300 for hybrids).  

•  Du et al. (2014): 0.1 % neodymium was found in circuit boards (vehicle dismantling tests). 
•  Cullbrand & Magnusson (2012, p. 37): refer to rhodium (<0.01 g) in circuit boards of the 
brake system and engine system) and to indium, neodymium, and palladium for PWBs 
(no values referred). 

•  Rodrigo & Castells (2004) refer to 16 % copper, 0.05 % silver, 0.03 % gold and 0.01 % 

palladium in PWBs, however, values are not car specific. 

•  Schmid (2014) refers to various elements in PWBs from vehicle models from 2010-2013 
(see  table  below),  values  for tantalum  fluctuate and  were thus  considered  to  have  low 
reliability. 

Table 2-6  Composition of printed circuit boards according to Schmid (2014), 
concentration in g/kg 

Source: Reproduced from (Groke et al. 2017) 

Partially in contrast to this predicted increase in use of CRMs are statements of vehicle 
manufacturers. ACEA contends that new studies from one OEM for vehicles of model year 
2020 show, that the content of gold, palladium, antimony, and tantalum in electronic control 
units has decreased significantly since the last study from the same OEM for model years 

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2010-13. This might be the result of miniaturisation and the attempt to reduce expensive 
materials like precious metals. (ACEA 2021a) 

As to EoL, during the waste management of vehicles, only some CRM and precious metals 
are recovered in a way that allows their use in EEC or in other vehicle components:  

•  Dismantling of the platinum group metals (PGMs) contained in the catalytic converter is 
supported  by  a  dismantling  obligation  in  Annex  I(4)  of  the  Directive  as  well  by  a  high 
market value of these materials, as explained in section 2.1.2.5.7 below.  

•  Though antimony is not recovered as a separate material, it is recycled together with the 
lead that is contained in starter batteries, and thus allows to recover a large amount of 
antimony from vehicles (CEWASTE Consortium 2021). This is however not the case when 
antimony is used as a synergist flame retardant in certain vehicle plastics and in PWBs 
(Baron et al. 2020). Even when such components are dismantled from vehicles, it is not 
common practice to recycle the antimony from these uses.  

•  The same is true for other CRMs that are applied in PWBs but also in other EEC. Though 
in some cases, like that of neodymium magnets, the lack of recovery is also related to a 
general lack of recycling capacities (see section 2.1.2.5.6) (also a matter of economies of 
scale as at present the amounts of the EV drive motors arriving at end-of-life is still small). 
In  many  cases,  such  materials  are  not  recycled  as  the  components  in  which  they  are 
contained are not dismantled prior to shredding, whereas their recovery from ASF is not 
economically feasible. In an interview held in the course of this study, Eurometaux (21 
Feb  2021)  explains  this  in  part  being  due  to  most  CRMs  being  contained  in  small 
quantities in vehicles. Requirements for retrieving a very small amount of a material (the 
case  for  many  CRM)  may  mean  that  more  energy  needs  to  be  applied,  creating  more 
emissions. The fact that shredders are not always ELV dedicated, but rather operate with 
mixed  waste  (ELVs  but  also  for  example  E-waste  such  as  white  goods)  makes  the 
recovery of small volume fractions like CRMs even more complex and dilutes the fractions 
in cars further. 

Andersson  et  al.  (2019)  conducted  an  analysis  of  the  technological  innovation  system 
framework of valuable metals in printed wirings boards (PWBs) that are contained in ELVs 
treated in Sweden. Vehicle electronics (i.e. PWBs) were found to contain a variety of precious 
(gold,  palladium,  silver)  and  minor  metals  (e.g.  gallium,  tantalum).  They  conclude  that 
recycling  of  precious  metals  from  PWBs  found  in  ELV  is  economically  challenging  as  the 
current business models in the ELV recycling industry are focussed on the recovery of bulk 
metals (e.g. FE, Al, Cu).  

The recovery of CRM is hampered by both internal and external factors in the ELV recycling 
industry. Next to the external factors, i.e., unfavourable market prices for recycled metal and 
long-term price trends, innovations in CRM recycling are hampered by the industry`s lacking 
capability and goals, as well as a policy framework that does not sufficiently incentivize and 
boost  CRM  recycling  from  ELV.  To  improve  the  recycling  of  minor  metals  from  PWBs 
contained  in  ELV  Andersson  et  al.  (2019)  recommend  learning  from  the  WEEE  recycling 
system.  In  WEEE  dismantling,  long-term  investments  have  been  made  in  automated 
treatment  facilities  that  are  larger  and  more  efficient.  Moreover,  the  costs  of  dismantling 
WEEE are partially compensated by additional financing based on the EPR system, which 
relieves dismantlers of the financial risks arising from the increasing complexity of materials 
and  structures  and  fluctuating  market  prices  for  secondary  raw  materials.  The  authors 
suggest a set of policy interventions that mitigate the innovation blocking factors of the ELV 
recycling industry by supporting capability building in the recycling industry, aiming at building 
new value chains. (Andersson et al. 2019) 

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Under the WEEE Directive (Annex VII), printed circuit (or wiring) boards must be dismantled 
if their surface is greater than 10 square centimetres. Such components are thus removed 
and treated separately. Due to the integrated design of PWBs, the electromotive components 
are  usually  soldered  together  on  a  more  or  less  densely  populated  PWB  surface.  It  is 
therefore hard to recover individual components from PWB. The standard recycling practice 
is thus to send the PWBs in their entirety to the copper recovery process. In copper recycling, 
the PWBs and all components on them are metallurgically treated in a copper smelter. In this 
process,  all  organic  materials  (plastics)  burn  while  copper  and  other  metals  (except  iron, 
nickel, etc.) are melted and removed. Many precious metals such as silver, gold and PGM 
pass into the molten copper, which serves as a carrier metal. REE, on the other hand, do not 
pass  into  the  molten  copper  but  remain  in  the  slag,  which  is  normally  disposed  of.  The 
recovered copper contains other metals as impurities. Therefore, the raw copper is subjected 
to  electrochemical  refining. 
is 
electrolytically dissolved at the anode and deposited in pure form at the cathode. The cathodic 
copper  is  the  refined  end  product  of  the  recycling  process  and  can  be  sold.  Other  metals 
contained in the raw copper remain in the electrolytic bath either in dissolved form or as anode 
slimes.  From  there,  they  can  be  recovered  and  refined  through  further  hydrometallurgical 
processing. 

In  this  hydrometallurgical  process, 

the  raw  copper 

As  PWB  in  ELV  are  thought  to  contain  roughly  a  similar  inventory  of  the  critical  materials 
contained in WEEE PWB (see Reuter, M. et al (2013)), the above-mentioned recycling route 
for WEEE PWB is also assumed suitable for the recycling of PWB from ELVs. 

2.1.2.5.6  Neodymium 

According to the RMIS data74, the rare earth elements neodymium and dysprosium are mainly 
found in permanents magnets (PM) that are used in actuators (small motors) in all vehicle 
types and in traction motors in EVs. ICEVs still dominate the use of neodymium in the period 
between 2006 and 2023, but the introduction of EVs adds significantly to the use in the later 
years. This indicates that future quantities of neodymium are linked to PM traction motors for 
e-mobility, but that all types of vehicles will contribute, assuming no radical changes in vehicle 
designs. 

95 % of EVs use rare earth magnets containing traction motors; quantities required worldwide 
will grow from 5,000 tonnes in 2019 to up to 70,000 tonnes per year by 2030. Considering the 
European EV automotive market, in 2020 1.4 million cars were put on the market, requiring 
2,000  tonnes  of  NdFeB,  with  an  average  of  1.5  kg  of  NdFeB  per  car.  In  2030,  when  it  is 
estimated  that  7.3  million  EV  will  be  placed  on  the  market,  10,400  ton  of  NdFeB  will  be 
required. (Gauß et al. 2021) 

Normative  requirements  developed  by  the  CEWASTE  Consortium  (2021)  foresee  the 
removal of NdFeB magnets prior to shredding operations to facilitate their separate collection 
and  treatment.  In  the  final  treatment,  the  requirements  prescribe  either  recycling  the  REE 
contained in the magnets or a process for recycling waste NdFeB magnets into new ones. 
Though  technologies  have  been  developed  for  the  recycling  of  such  magnets,  capacities 
currently do not exist in the EU.  

Apart from collection and pre-treatment approaches, no recycling process for REE magnets 
has been established in the western world. The collected wastes are sold to China and Japan 
for metallurgical recycling. If REE-bearing motors enter shredding, this leads to lowered and 
inefficient  recovery  of  some  of  the  contained  metals.  Especially  the  cost  intensive  REE 
magnets can hardly be separated by mechanical techniques due to their magnetic properties. 

74 See source 73. 

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They usually count towards the iron fraction (magnetic separation) although a considerable 
share is disseminated over the other fractions, dust, and ferrous equipment parts. The REEs 
that  enter  iron  or  steel  recycling  are  transferred  to  the  slags  during  smelting  due  to  their 
ignoble character. In order to direct the magnets into a dedicated REE recycling, the motors 
must  be  extracted  prior  to  shredding  and  dismantled  down  to  the  rotor/stator  level.  After 
dismantling,  the  surface-mounted  permanent  magnets  and  integrated  permanent  magnets 
have to be removed from the rotor. (Elwert et al. 2017) 

As long as there are no stocks of separated magnets, there will be little motivation to develop 
recycling  capacities,  but  without  such  capacities  there  is  also  little  interest  to  remove  and 
store  magnets.  A  long-term  material  based  recycled  content  target  could  be  helpful  in 
promoting  the  development  of  such  capacities  in  the  EU,  though  it  is  possible  that  a 
component-based recycling target for NdFeB magnets would achieve a similar effect. 

2.1.2.5.7  Platinum group metals (PGM) 

The  platinum  group  metals  (PGM)  are  applied  in  automotive  catalytic  converters.  These 
components have a high market value and can be assumed to always be dismantled from 
the vehicle and treated separately. In fact, according to (EGARA 2021), in some cases “cars 
with  no  catalysts  arrive  at  the  dismantler  as  the  owner  cuts  it  out  and  sells  it  himself”.  As 
catalysts are used in conventional vehicles but not in EV, it is expected that the demand for 
PGM for their manufacture will decrease. An Oeko-Institut study (Oeko-Institut e. V. 2021) 
estimated that the consumption of the platinum group metals (PGMs) for automotive catalytic 
converters will fall sharply by 2035 for vehicles on the German market. In a scenario where 
only EVs are registered in Germany in 2035, consumption was said to drop to zero. As PGMs 
from automotive catalysts represent an important secondary metal source through recycling, 
the recovered PGMs can be used to supply material for future applications such as fuel cells 
and the hydrogen infrastructure in the medium term. This trend is expected throughout the 
EU due to the shift from ICE to EV, as is also reflected in the RMIS data. 

2.1.2.5.8  Plastic 

Figure 2-19 shows the development of the total amount of plastics from ELVs in the EU from 
2020 to 2035. 

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Figure 2-19  Development of total amount of plastics in ELVs in the EU from 2020 to 
2035 

Source: Own calculation with data from Euro 7 Impact Assessment, JRC-RMIS and Argonne 2021, see model description in 
Annex I 6.9.2 

Plastic  production  in  Europe  was  57.8  million  tonnes  in  2019  (EU28+NO/CH)  with  the 
automotive  sector  in  3rd  position  in  terms  of  consumption  of  plastics, representing  around 
10% of the plastics demand and accounting for 5.1 Mt of plastics consumed per year. In the 
last  two  decades the  plastic  content  has  increased  in  new  ICE  vehicles placed  on  the  EU 
market from around 12% to around 16% on average. It is expected that future ELVs reaching 
ATFs  around  2030-2035  will  have  the  plastic  composition  of  the  vehicles  produced  in  the 
previous years, i.e. ranging from 13 to 16% for BEV and equivalent ICEV, respectively (HEV 
and PHEV have the same plastic composition as ICEV) (Maury et al. 2022). 

EuRIC (2022a) explains that modern cars contain several plastic parts and components (e.g., 
dashboards,  bumpers,  handles,  buttons,  casings,  ceiling  fabric,  seats,  seat  belts,  airbag, 
carpeting,  etc.).  The  use  of  plastics  in  the  car  manufacturing  industry  presents  several 
advantages, such as a vehicle mass reduction, which leads to lower fuel consumption and a 
decrease in emissions of Green House Gasses (GHG). Plastics are furthermore explained to 
have  several  important  technical  properties,  “such  as  impact  strength,  thermal  insulation, 
noise reduction, and corrosion resistance”. 

There are currently about 39 different types of basic plastics and polymers used to make an 
automobile.  The  most  common  ones  (approx.  74%  of  the  plastic  used  in  cars)  are 
polypropylene (PP) (35%) (e.g., bumpers, cable insulation carpet fibres, etc.), polyurethane 
(PU) (19%) (e.g., foam seating, insulation panels, suspension bushings, cushions, electrical 
compounds, etc.), polyamides (PA) (11%) (e.g., battery casings, brake hoses, oil sumps, etc.) 
and  polyvinyl  chloride  (PVC)  (9%) (e.g.,  instrument  panels,  electrical  cables,  pipes,  doors, 
etc.). A variety of other plastics and polymers, including engineering plastics, are also used 
and  combined  for  other  automotive  parts  (e.g.,  acrylonitrile  butadiene  styrene  (ABS), 
polystyrene (PS), polyethylene (PE), polyoxymethylene (POM), polycarbonate (PC), acrylic 
(PMMA), etc.). (EuRIC 2022a)  

According to EuRIC (2022a), assuming that an average car weighs 1,300 kg and that plastics 
content represents 12-15% of its mass (50% of car volume), this amounts to 150-200 kg of 

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plastic  per vehicle,  and this  is  expected  to  increase  in  the  coming years due  to  a  growing 
demand from the market for high-performance, lightweight and fuel-efficient, safe vehicles. 

At EoL, some plastics are dismantled from the vehicle before it is sent to the shredder. This 
is in line with the Directive requirements (Annex I(4)), that requires the removal of larger parts 
(dashboard, bumper, fluid containers) when these cannot be segregated in the shredder to 
allow  effective  recycling.  However,  it  seems  that  the  main  motivation  for  dismantling  is 
potential  reuse,  whereas,  once  removed,  larger  components  will  be  sorted  according  to 
composition and sent to separate recycling. 

•  According to EGARA (2021) bumpers are understood to be dismantled and separated 
into  different  fractions  according  to  compositions  before  being  sent  to  recyclers.  This 
however does not apply to bumpers with foam filling for which it was explained that these 
can be dealt with in the mechanical separation. The consultants assume that bumpers 
are often removed due to their potential for reuse, as the front and back of the vehicle are 
often  damaged  during  accidents,  providing  a relevant  market for reuse. In their  annual 
report  on  ELVs  for  the  year  2017,  ADEME  (Deloitte  &  ADEME  2019)  reports  that  on 
average 3.14 kg of polypropylene bumpers were removed per vehicle in that year, 3.13 
kg  of  which  were  sent  to  recycling  and  the  rest  to  recovery.  In  total  3,562  tonnes  of 
polypropylene bumpers were sent to recycling in 2017. A further 0.65 kg per vehicle was 
dismantled in parts sold for reuse per vehicle. 

•  Though interest was raised in the past regarding the dismantling and separate recycling 
of the fuel tank, this is understood not to be practiced. Until 2000 the tanks in the EU 
market  were  produced  from  mono  layer  HDPE,  especially  for  diesel  cars.  After  the 
introduction  of  Euro  5  the  production  changed  to  a  multilayer  construction  to 
accommodate new requirements on fuel contents and storage. Older mono-layer tanks 
are assumed to already have left the material cycle for the most part, most having been 
incinerated. Mechanical recycling of multilayer fuel tanks does not ensure sufficient purity 
of HDPE (>99%) and thus does not allow the use of such recyclate for producing new 
tanks. (KAUTEX TEXTRON GMBH & CO. KG 2022) FEAD (2022) agrees that fuel tanks 
are not dismantled for the sake of separate recycling. ADEME (Deloitte & ADEME 2019) 
reports that on average 1.32 kg of polyethylene fuel tanks were removed per vehicle in 
that year, 1.31 kg of which were sent to recycling and the rest to recovery. In total 1,489 
tonnes of polyethylene fuel tanks were sent to recycling in 2017. A further 0.47 kg was 
dismantled  in  parts  sold  for  reuse  per  vehicle.  Considering  the  above  information,  the 
consultant assumes that these were mono-layer fuel tanks placed on the market prior the 
shift to multilayer to comply with Euro 5. 

ADEME (Deloitte & ADEME 2019) further reports the following types of plastics to have been 
dismantled for reuse or recycling in 2017: 

•  Polypropylene – other parts: 0.49 kg per vehicle were sent to recycling; in total 559 tonnes 
of polypropylene (other parts) were sent to recycling in 2017. A further 2.60 kg per vehicle 
was dismantled in parts sold for reuse. 

•  Polyethylene – other parts: 0.06 kg per vehicle were sent to recycling; in total 72 tonnes 
of polyethylene (other parts) were sent to recycling in 2017. A further 0.30 kg per vehicle 
was dismantled in parts sold for reuse. 

•  Polyurethane foam: 0.01 kg per vehicles was sent to recycling; in total 15 tonnes of PU 
foam were sent to recycling in 2017. A further 1.18 kg per vehicle was dismantled in parts 
sold for reuse. 

•  Polyamides: = kg per vehicle is specified as dismantled and sent to recycling, but this is 
assumed  to  be  due to  the  rounding  of  the  number  as  it  is  also  specified  that  in  total  2 
tonnes of polyamides were sent to recycling in 2017. A further 0.59 kg per vehicle was 
dismantled in parts sold for reuse. 

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•  ABS, PVC, PC, PMMA, PS, etc.: 0.02 kg per vehicle; in total 26 tonnes of these materials 
were sent to recycling in 2017. A further 1.30 kg per vehicle was dismantled in parts sold 
for reuse. 

Though this makes up for only 7.09 kg/vehicle for reuse and 5 kg/vehicle of plastic dismantled 
and sent to recycling (Deloitte & ADEME 2019), it gives an overview of what types of plastics 
may be dismantled for reuse or recycling (in some cases sent to separate recycling). Looking 
at the quantities it is assumed that the main motivation for dismantling plastic parts is to allow 
their sale for reuse (the report mentions that in France in 2017 over 300 dismantlers did not 
engage in dismantling for reuse) whereas plastic then sent by the ATF to recycling (assumed 
without shredding) are a result of components that were not sold in the end for reuse or what 
were damaged during dismantling and could not be reused.  

FEAD  (2022)  state  that  though  most  polymeric  materials  in  vehicle  can  be  recycled  with 
simple mechanical processes if correctly separated, the presence of many different polymers 
is a challenge to recycling. 

According to EuRIC (2022a) the development of mechanical and thermal recycling of plastics 
from Automotive Shredder Residue (ASR) in the EU stems directly from the ELV Directive 
which  imposes  high  weight-based  recovery  targets,  namely  85%  of  material  recovery  and 
10% of energy recovery. State-of-the-art post-treatment technologies enable the recovery of 
ELV  plastics’  fractions  which  are  then  separated  per  polymer  using  different  separation 
technologies,  such  as  sink-float75  tanks  (i.e.,  density  separation),  or  laser  and  infra-red 
systems  used  to  separate  plastics  based  on  colour.  The  final  recycling  steps  consist  in 
shredding and extrusion, which results in the production of post-industrial pellets by polymer-
types  meeting  industry  specifications  for  their  re-incorporation  into  new  cars.  In  addition, 
polymers containing volatile and solid contaminants that need to be thoroughly extracted in 
order  to  produce  high-quality  re-granulate  suitable  for  reuse,  are  re-processed  by  special 
vacuum  degassing  extruder  modules.  The  increasing  complexity  of  multi-material  vehicle 
design has created several challenges for vehicle recycling. For example, the wide variety of 
plastics used in automobiles (incl. a large number of resins, different additives, etc.), or the 
presence of reinforced plastics (containing fillers such as glass fibre, carbon fibre and glass 
beads) that are difficult, if not impossible, to recycle. Mainly due to those challenges and the 
lack of incentives to encourage an increased demand of recycled plastics in the automotive 
sector,  only  polymers  present  in  higher  amounts  (e.g.,  PP,  ABS,  PS)  are  currently  being 
recycled. […] Technical plastics recyclers have proven for the last decade that the technology 
to  recycle  the  most  commonly  used  polymer  types  (PP,  PE,  PS,  ABS)  in  ELVs  is  mature 
enough to deliver the quality required by the car industry at a competitive price except if oil 
prices drop significantly. 

Plastics Europe (2022) explains that the quality of the output from recycling is essential for 
replacement of materials from primary feedstock. Looking at the effect of the long use phase 
of vehicles on polymer quality (such as polymer chain length reduction), Plastics Europe sees 
mechanical recycling as an important part of EoL treatment but does not think it can provide 
a sufficient amount of high-quality material to secure the quality demand from the automotive 
sector  especially  should  a  post-consumer,  closed-loop  system  be  foreseen.  Chemical  and 
mechanical recycling can be complementing technologies to jointly enhance the circularity of 
plastics in the automotive sector. 

75 PRE (2022) refers to innovative processes to separate fractions containing PBDEs from the mainstream, such as the 
sink/float technology. This technology is explained to enable the separation of e.g. plastics containing POPs form plastic free 
ones. 

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A few vehicle manufacturers report on the use of recycled plastics in their vehicles (or plans 
for its integration), referring among others to PP used for shielding, wheel arches and other 
parts and PUR used for foam of seats. Nonetheless such practices are understood not to be 
widespread. 

2.1.2.5.9  Rubber 

Rubber is used in a wide range of vehicles interiors76 and exteriors77 made entirely or with a 
considerable share of this material. The highest share of rubber contained in vehicle is used 
in tyres. Tyres have a mixed composition of carbon black, elastomer compounds, steel cord, 
fibre, in addition to several other organic and inorganic components. Natural rubber used to 
produce tyres, has been recognized as a CRM by the EU.  

The most common way of treating end-of-life tyres (ELTs) is their material recovery. Currently, 
rubber from tyres is recycled to qualities that are not equivalent to vehicle grade, however this 
appears to be a result of available recycling technologies. The materials with larger particle 
sizes, i.e., whole tyres shredded into rubber chips, are well suited for typical applications in 
civil  engineering.  The  smaller  materials,  granulates  and  powder,  are  used  in  the  industrial 
products,  compounds  in  bitumen  or  varnish.  Examples  of  use  of  granulated  rubber  are 
synthetic turfs fields, where the rubber usually is mixed with a polyurethane resin and casted 
into a mould in order to obtain panels with the desired dimensions. However, recently, the 
European Committee for Risk Assessment (RAC) has presented the proposal for a complete 
ban of the use of rubber granulates in artificial turfs to limit the release of microplastics in the 
environment.  Also,  the  European  Chemicals  Agency  (ECHA)  has  indicated  health  risks 
associated to the exposure to rubber granulates through skin contact, inhalation, or ingestion. 
The  risk  was  mainly  related  to  the  presence  of  polycyclic  aromatic  hydrocarbons  (PAHs) 
within  rubber  granulate  derived  from  ELTs.  It  was  considered  as  very  low  based  on  the 
concentrations  of  PAHs;  however,  it  was  decided  that  starting  from  August  2022  the 
maximum  concentration  of  PAHs  in  granulates  and  mulches  used  in  artificial  turfs  or 
playgrounds will be limited to 20 mg/kg78.  

About 20 % of the output of the ELTs treatment process are “not clean textile fibres”, which 
contain variable percentages of 40-60 % in weight of rubber residues. Currently, works are 
ongoing to improve the treatment process of tyres in order to obtain “clean textile fibres”. New 
treatment processes would increase the amount of obtained rubber powder as well as enable 
application  of  ELT  fibres  in  the  industrial  sector  as  the  compound  in  plastic  and  modified 
asphalts.  Energy  recovery  is  an  important  and  valuable  form  of  exploiting  used  tyres. 
According to ETRMA79, energy recovery of ELTs includes 75 % by weight of ELTs sent to 
cement kilns as the energy fraction of co-processing.  

In respect of the above, potential targets for rubbers shall depend on the recycling definition 
as  well  as  on  the  progress  in  design  of  tyres  to  facilitate  their  remanufacturing  (retreat  of 
tyres). Currently, work on future recovery of tyres is in progress. Its development needs to be 
monitored  (new  treatment  technologies  and  improved  retreat  process)  to  consider 
introduction of new provisions. A review clause would be envisioned to allow complementing 
targets in the future for rubber, similarly, like for glass. However, setting of this provision would 

76 E.g. body seals, bumpers, wheel arches 

77 E.g. acoustics, carpets, pedal covers 

78 Reduction of around 80 % in comparison to the previous limit. 

79 https://www.etrma.org/wp-content/uploads/2020/09/Copy-of-ELT-Data-2018-002.pdf  

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require in-depth analysis if chemical recycling could account as recycling for tyres. A similar 
approach should be applied for textiles.  

2.1.2.5.10  Non-recyclables 

The term “non-recyclables” refers to materials used in vehicles which, at least at the time the 
vehicle  is  put  on  the  market,  cannot  yet  be  considered  to  be  recyclable.  This  raises  the 
question of how recyclability is to be defined, in particular as vehicles have a relatively long 
lifetime and thus it is often argued (e.g., by OEMs) that even if a material is not yet recyclable 
at  the  time  a  new  vehicle  is  introduced,  it  could  be  by  the  time  it  arrives  at  EoL  waste 
management.  

Currently the provisions in the 3R Directive requiring the demonstration of dismantlability and 
recyclability refer to “proven technologies”80,81. ISO 22628 defines “proven technologies” in 
the  introduction  as  follows:  “Recyclability/recoverability  rates  depend  on  the  design  and 
material properties of new vehicles, and on the consideration of proven technologies — those 
technologies  which  have  been  successfully  tested,  at  least  on  a  laboratory  scale,  in  this 
context”. This level of maturity of the technology is sometimes referred to as its technology 
readiness level (TRL)82 and a laboratory scale level is considered to be level 4, whereas the 
establishment of a technology on the market is considered to be at level 9. In other words, 
the legislation currently assumes that if a technology is available that is capable of recycling 
a material and is at laboratory level or higher, that the material can be considered recyclable. 

And yet, ELV waste operators raise concern that in some cases, materials that are allowed 
for  application  in  vehicles  when  put  on  the  market  despite  a  low  TRL  of  the  recycling 
technology are still not recyclable when the vehicles reach EoL. This is raised for materials 
like composite plastics, reinforced plastics (EGARA 2021) and coco fibres, cellulose fibres 
(i.e. plant-based fibres) (EuRIC 2022b). EuRIC (2022b) explain that plant based fibres are 
argued as being “green”, but in fact you mix something which is melting and something with 
is  not  melting.  Such  materials  create  difficulties  in  PP  recycling.  EuRIC  also  refer  to  the 
practice of gluing of plastic parts. The glued parts cannot be separated, e.g. PP glued with 
ABS, as there is no de-gluing mechanism. Such practices also hinder recycling. 

Though composites and reinforced plastics are currently used in only few vehicles in large 
amounts, it is assumed that their use could increase, as many of them are used to reduce the 
vehicle weight (EGARA 2021). 

According to Maury et al. (2022) the use of new and more composite materials, such as glass 
(GFRP) or Carbon fibre reinforced plastic (CFRP) has been expanding rapidly in recent years 
due  to  their  contribution  to  reduce  weight,  design  flexibility  and  competitive  mechanical 
properties compared to metals, such materials were included for instance up to 49% in the 
BMW i3 body structure . However, a wider use of composite materials as well as multi-layer 
materials is not expected to increase too much in the future: this is mainly due to their limited 
economic added value. Such declaration was also confirmed by consulted OEMs. 

80 Recital (8): treatment of end-of-life vehicles. The manufacturer should therefore recommend a strategy for the treatment of 
end-of-life vehicles and should provide details thereof to the competent body. This strategy should be based on proven 
technologies, which are available or in development at the time of applying for the vehicle approval. 

81 Article 6(3): 3. For the purpose of paragraph 1, the manufacturer shall recommend a strategy to ensure dismantling, reuse of 
component parts, recycling and recovery of materials. The strategy shall take into account the proven technologies available 
or in development at the time of the application for a vehicle type-approval. 

82 HORIZON 2020 – WORK PROGRAMME 2014-2015 General Annexes Page 1 of 1 Extract from Part 19 - Commission 
Decision C(2014)4995 G. Technology readiness levels (TRL); 
https://ec.europa.eu/research/participants/data/ref/h2020/wp/2014_2015/annexes/h2020-wp1415-annex-g-trl_en.pdf  

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It is possible that the use of GFRP and CFRP will not increase in the future, however other 
materials  currently  not  used  in  vehicles  could  be  introduced  with  similar  difficulties  in 
recycling, creating similar problems. This appears to particularly be relevant for materials that 
could be applied for light-weighting of the vehicle, as these tend to be used in larger amounts 
so as to achieve a significant reduction in vehicle weight. As the use of light-weight materials 
can  be  expected  to  have  a  positive  effect  on  vehicle  emissions  during  the  use-phase,  the 
question is how these balance against increased emissions at EoL.  

2.1.3  What is the problem and why is it a problem? 

2.1.3.1  Description of the problem 

Design 

Design for dismantling 

Changes are observed in the manufacturing of vehicles that contribute to the complexity of 
vehicle waste management.  

For  ICE  vehicles,  this  is  related  to  the  general  need  to  reduce  emissions,  but  in  electric 
vehicles, weight reduction is also important to reduce the total vehicle weight to compensate 
for the heavier traction batteries. As a consequence, an increased use of plastics and new 
materials for which recycling capacities are not sufficiently developed or at times do not yet 
exist, affects the general recyclability of vehicles and could result in a heavier dependency on 
primary materials.  

In  the  assembly  of  vehicles,  the  use  of  more  adhesives  instead  of  mechanical  bonding 
technologies  (e.g.,  screws)  and  sealants  makes  the  dismantling  of  vehicle  parts  more 
complicated. This affects in the worst case the likelihood that parts will be dismantled and 
subsequently can lead to a decrease in reuse or less dismantling for separate recycling. For 
example, vehicle glass which was embedded in the past with retractable rubber profiles is 
more often glued into place, making dismantling more time intensive or resulting in material 
losses when the glass is broken.  

Even in cases where manufacturers apply new technologies to facilitate better dismantling, 
for example for a quick dismantling of the copper intensive wire harness, information on the 
most efficient method of dismantling does not always reach ATFs and thus does not lead to 
expected results. With the increase in electrification and automatization, there is an increase 
in  the  integration  of  electric  and  electronic  components,  intensive  in  precious  and  critical 
materials. Some of these are locked with digital keys for different reasons, which when not 
accessible to dismantlers and repair shops prohibit their reuse. Concern has also been raised 
as to the safe dismantling of Li-Ion batteries, which shall become more common with increase 
in electric vehicles and for which the little experience with dismantling suggests time intensive 
dismantling. It is not clear if potential problems here stem from lacking information and training 
for ATFs or form the experience yet to be gained.  

Over time, the contribution of the production and dismantling of cars to the ambitions of the 
Green Deal, in particular to the circular economy objectives of reuse, repair and recycling is 
expected to decrease without intervention.  

Hazardous substances 

The  aim  of  the  ELVD,  according  to  its  recital  11,  is  to  reduce  and  control  hazardous 
substances  in  vehicles  in  order  to  prevent  the  release  of  these  substances  into  the 

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environment, to facilitate recycling and to avoid the disposal of hazardous waste. The ELVD 
has anticipated important issues of the CSS, but at some points, the ELVD needs adaptations, 
e.g., in order to ensure the protection of the environment and human health.  

Regarding the extent of hazardous substances, the ELVD restricts the four heavy metals lead, 
mercury, cadmium and hexavalent chromium. However, no additional substances have been 
added since its adoption in 2000, whereas under REACH restrictions of substances used in 
vehicles and that also apply to them have been added. This refers to another problem in this 
area, i.e., that current rules on hazardous substances in vehicles are distributed over different 
legislation. It was expressed by stakeholders that this is burdensome to follow.  

The presence of hazardous substances in ELV waste fractions can result in loss of re-usable 
and recyclable materials, can obstruct the waste management of vehicles (e.g., decaBDE), 
or limit the use of recyclates that result from treatment processes (e.g., when lead is present 
in recycled alloys above a certain level). So far, insufficient information is provided by vehicle 
manufacturers  to  dismantlers  on  the  presence  and  localisation  of  (hazardous)  materials, 
which hampers high quality recycling.  

3R Type approval 

The  type  approval  process,  that  aims  at  ensuring  that  the  reuse,  recycling,  and  recovery 
targets can be achieved at the EoL of a vehicle, through the submission of a calculation of 
these  parameters  is  too  simplified.  In  accounting  for  recyclable  quantities,  it  does  not 
differentiate  between  the  actual  amounts  that  can  be  recycled  for  a  specific  material  (i.e., 
consideration  of  efficiency  losses  of  the  waste  management)  but  rather  assumes  a  digital 
approach that a material is either recyclable (accounted for as 100% towards the target or 
not.  A  material  is  considered  to  be  recyclable  when  the  technology  readiness  level  of  its 
recycling is at laboratory scale or above. Though vehicles have a relatively long lifetime, it is 
observed  that  in  some  cases,  particularly  when  a  material  is  not  commonly  used,  that  its 
recyclability  does  not  necessarily  change  by  the  time  that  vehicles  arrive  at  the  waste 
management,  hindering  the  actual  achievement  of  targets.  Furthermore,  though  the  3R 
Directive refers to the target of reuse and the calculation method of the type approval process 
refers  to  indicators  as  to  whether  a  component  can  be  considered  as  reusable  or  not,  in 
practice little heed is taken to the actual reusability of components in the process. Though it 
is  difficult  to  assume  the  actual  reuse  of  components  from  ELVs  as  this  is  subject  to  the 
demand  on  the  market,  the  fact  that  the  availability  of  information  on  dismantling  is  not 
considered as part of the process means that the potential for reuse is not investigated and 
may be too low.      

Existing provisions on the removal of parts to promote reuse and recycling (Article 6(3) and 
Annex (I) of the ELV Directive) are not sufficiently clear to ensure removal of materials before 
shredding in a way which would maximise recycling and re-use. In some cases, this results 
in components no being removed despite marginal feasibility of dismantling and either hinders 
the reuse of components or results in a loss of materials that could otherwise be recycled in 
higher amounts or with higher quality. The provisions also do not refer to all components or 
materials, the dismantling of which could result in higher reuse and recycling rates(or higher 
recycling  qualities).  In  this  sense,  the  potential  of  vehicles  on  the  EU  to  contribute  to  the 
circular economy is not exploited.  

For example, looking at the data on average vehicle composition:  

•  Glass removed from ELVs (ca. 30 kg or 3% of the vehicle weight) is often “lost” as filling 
materials  instead  of  being  recycled  into  new  glass  as  its  dismantling  and  separate 
recycling is not economically feasible.  

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•  Even  though  around  90%  of  the  average  150  kg  of  aluminium  used  in  a  vehicle  are 
recycled, this is done after the shredder, resulting in a mix that can only be used for cast 
alloy applications due to the level of impurities as well as losses to the steel fraction.  
•  The  low  efficiency  of  the  removal  of  copper  from  the  shredded  fraction  results  in  high 
impurities in steel and aluminium that at worse case affect the range of applications for 
which secondary steel can be used. 

To summarise, the recycling of materials, used in significant amounts in ICEs and expected 
to increase in use in EVs, is not always optimal. In some cases, this results in a lesser quality 
of  recyclates  like  aluminium  and  glass,  in  lower  recovery  of  materials  like  copper  and 
aluminium due to losses to the steel fraction. 

Market conditions for recyclates 

The recycling of some of the materials contained in vehicles in significant (rubber in tyres) or 
increasing amounts (see above, plastic and magnets due to electrification) can be considered 
a loss of material when they are not recycled at EoL in sufficient quantities and thus hinders 
circularity. In some cases, market failure may affect the likelihood of the recycling to improve. 
In others, the current market situation may hinder the development of recycling technologies 
as there is a lack in certainty regarding the market for secondary materials and this affects 
investments in the further development of appropriate waste management. For example: 

•  For both plastics, the fluctuations in the prices of virgin materials create uncertainties as 
to  the  future  demand  for  recycled  plastics.  As  waste  operators  are  uncertain  as  to  the 
returns  on  investments  in  improving  the  recycling  processes,  the  market  supply  of 
recyclates  form  ELV  origin  remains  low.  Subsequently  OEMs  hesitate  to  use  such 
recyclates as they need a stable and sufficient supply in terms of amounts and quantities 
for them to be considered in the design of a vehicle. 

•  For rubber, the level of recycling is currently only around 50%, however R&D of future 
recycling technologies is not sufficiently advanced to be able to determine what types of 
recycling  could  lead  to  high  quality  recyclates.  As  chemical  recycling  technologies  are 
also considered in this regard, the uncertainty as to their accreditation for recycling adds 
to uncertainties. As explained in section 2.1.2.5.9, there are also a number of proposals 
made by the ECHA which could affect the allowed content of PAHs in rubber granulate 
(recyclate)  or  its  future  use  altogether  in  the  manufacture  of  certain  goods  due  to  its 
potential to release microplastics. Such proposals add a further level of legal uncertainties 
related to the potential use of recycled rubber granulate. 

•  Rare  earth  containing  magnets  which  are  increasingly  used  in  vehicles  due  to 
electrification of the fleet and the shift to EVs are currently not recycled. This is related 
the  fact  that  recycling  capacities  currently  do  not  exist  in  the  EU,  however  as  such 
components  are  currently  not  dismantled, the  stock  of magnets  that  could  be  recycled 
also does not support the development of such capacities, and it is not clear when it will. 
Nonetheless, REE are considered to be critical materials in terms of their supply, and the 
fact that they are not recycled contributed to the dependency on primary materials that 
are sourced from outside the EU.   

2.1.3.2  Description of the problem drivers 

Problem drivers with a nature of regulatory failures can be summarized as follows:  

The ELVD does not address the design of vehicles in a way that is sufficient to facilitate the 
waste management of ELVs:  

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•  The definition for dismantling information in article 2(13) refers to “all information required 
for the correct and environmentally sound treatment of end-of life vehicles”. The definition 
does  not  require  information  to  be  made  available  in  a  harmonised  way,  resulting  in 
information on dismantling of parts for reuse being provided on multiple platforms (e.g., 
RMI) and OEMs providing different levels of detail in information they provide (e.g., in IDIS 
where  at  least  there  is  a  single  platform).  Article  8(3  &  4)  further  requires  dismantling 
information  to  be  made  available  that  is  needed  by  ATFs  to  comply  with  the  ELVD 
provisions  with  a  view  to  achieving  the  3R  targets.  It  is  also  specified  that  appropriate 
information  concerning  dismantling,  storage  and  testing  of  components  which  can  be 
reused  should  be  provided  upon  request.  Whereas  OEMs  provide  information  on 
components  with  depollution/dismantling  obligations  (annex  I  (3  &  4)  free  of  charge 
through IDIS, information relating to components which can be reused is only provided 
through individual RMI platforms of the OEMs for varying costs. Lacking harmonisation 
and in some cases, costs considered to be inappropriate result in some ATFs regarding 
information  as  unavailable  (particularly  the  smaller  ones  that  treat  a  high  variety  of 
vehicles of different OEMS) and decreasing the number of components reused.     

•  Article 4(b) requires MS to promote vehicle design that facilitates the waste management 
of  vehicles,  however,  is  too  vague  on  the  type  of  activities  that  this  should  result  in. 
Consequently, vehicle design may result in inclusion of materials or use of fastening and 
assembly technologies that hinder reuse and recycling of ELVs.  

•  Article 4(c) requires MS to promote the integration of an increasing quantity of recycled 
materials, with a view to developing the market for such materials, however the provision 
is vague and in result we see that the market for recycled content is not well developed 
for all materials recycled form vehicles (e.g., plastic and tyres where market failures hinder 
the  improvement  of  recycling  technologies  to  begin  with,  but  also  materials  with  high 
recycling  quotas  like  steel  and  aluminium,  where  the  quality  of  recyclates  limit  their 
applicability in for use in vehicles.  

The ELVD has a limited scope in regulating hazardous substances.  

•  The  general  provisions  in  Article  4(1)(a)  only  focus  on  environmental  impacts  of 
hazardous  substances  in  vehicles,  but  the  protection  of  human  health  should  also  be 
covered there.  

•  The  ELVD  since  its  publication  in  October  2000 only  restricts  four  heavy  metals  (lead, 
mercury,  cadmium,  or  hexavalent  chromium).  Although  additional  restrictions  of 
substances are understood to be intended in principle, there are no provisions specifying 
the process for the restriction of other substances. Consequently, additional substance 
restrictions were not introduced under ELVD.  

•  The provisions on dismantling information are not sufficient to achieve dismantling and 
segregation  of  waste.  As  a  consequence,  insufficient  information  provided  by  vehicle 
manufacturers to dismantlers on the presence and localisation of (hazardous) materials 
hampers high-quality recycling.  

The current rules on substances in vehicles are distributed over different legislation. These 
refer to different criteria in relation to the prohibition of substances and derogations therefrom 
and  are  based  on  different  procedures  for  prohibiting  new  substances  or  for  obtaining 
derogations from existing prohibitions, creating inconsistencies and burden for stakeholders. 

The current legislation of substances in vehicles may not address all substances that should 
not be used in vehicles. 

The scope of waste management operations as specified in the ELVD does not sufficiently 
promote circularity: 

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•  The  ELVD  definition  for  recycling  under  Article  2(6)  is  not  consistent  with  principles  of 
“end-of-waste” and “preparation for reuse” applied in other waste legislation and leads to 
uncertainties as to the legal status of components processed for reuse, in particular as to 
whether the shipment of such components is to be considered as shipment of a product 
or  of  waste.  The  ELVD  also  does  not  define  remanufacturing  and  remanufactured 
components,  here  too  creating  leal  uncertainties  as  to  the  legal  status  of  such 
components, e.g., when shipped. 

•  The definition of recycling in Article 2(7) of the ELV Directive has a lower ambition level 
than the definition in other waste legislation and allows accounting for the recycling targets 
with amounts of material that have been downcycled. 

New technologies have emerged since the adoption of the ELVD. For example, the share of 
electric  vehicles  is  increasing  on  the  market,  related  to  the  need  to  reduce  emissions. 
However, the composition of EVs differs from that of ICE vehicles and it is not clear whether 
this could result in difficulties in achieving the 3R targets or if the current practices of ELV 
waste management would be sufficient to treat the electric ELV in a manner appropriate to 
support the circularity of the market and reduce the reliance of vehicle manufacture on primary 
materials.  This  is  in  particular the  case  for  aluminium,  where  an  increased  use  of  wrought 
alloys is expected that at present would not be recycled to an equivalent quality. This is also 
the case where non-recyclable materials are used in large quantities for weight reduction and 
where  this  results  in  insufficient  recycling  at  EoL.  In  this  respect  such  technology 
developments may result in some cases in conflicts between regulations, e.g., between the 
need to reduce weight and energy consumption/km vs. the need to ensure recyclability at a 
time when the use phase is the dominant phase for environmental impacts of vehicles. 

The problem drivers with a nature of market failures can be summarized as follows:  

The  way  that  ELVD  addresses  the  use  of  recycled  content  has  not  led  to  sufficient 
developments in the market of secondary materials sourced form ELVs: 

•  Article 4(c) requires MS to promote the integration of an increasing quantity of recycled 
materials, with a view to developing the market for such materials, however the provision 
is vague and in result we see that the market for recycled content is not well developed 
for all materials recycled from vehicles. For example, for plastic and tyres market failures 
exist that hinder the improvement of recycling technologies to begin with. In areas where 
materials used in vehicles are recycled to a high degree, such as steel and aluminium, 
the quality of recyclates limit their applicability for use in vehicles and insofar limits the 
level of circularity (closed loop). 

•  The 3R Type approval process is aimed at ensuring that vehicles placed on the EU market 
can  comply  with  the  3R  targets.  Vehicles  have  been  placed  on  the  market  in  the  past 
despite  the  containing  large  amounts  of  materials  understood  to  have  had  a  limited 
recyclability  (e.g.,  the  BMW  i3  and  other  vehicles  making  use  of  large  volumes  of 
composites and/or of reinforced plastics. It is not clear whether the type approval process 
of  such  vehicles  showed  their  compliance  with  the  3R  targets  or  not.  However,  OEMs 
claim that use of such materials have a benefit during the use phase as they result in a 
reduction in vehicle emissions. However, the current type approval process does specify 
that in cases where the targets may not be met that derogations could be possible under 
specific conditions. This could hinder the market entrance of vehicles that have significant 
environmental benefits e.g., related to other than EoL phase, without it being reviewed 
whether such benefits would set-off related costs of non-recyclables at EoL.  

•  The  ELV  does  not  provide  a  definition  for  remanufacturing  and  remanufactured 
components,  creating  an  unlevel  playing  field  for  remanufacturers  that  have  different 
practices regarding the scope of remanufacturing processes applied to a component, the 

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conditions of warranty on the same component sourced from different remanufacturers. 
This also affects the competitiveness of such components with reused ones and with new 
ones. 

•  Article  7  of  the  ELVD  sets  targets  for  reuse,  recycling,  and  recovery  of  materials  from 
ELVs. The current reporting on the achievement of these targets is insufficient to allow a 
comparison  of  the  level  of  compliance  in  the  various  MS.  Where  MS  have  different 
interpretations as to which fractions are to be accounted for towards reuse, recycling, and 
recovery (e.g., backfilling) this results in an unfair playing field. As the provision of some 
types of information is voluntary (e.g., level of reuse), for some aspects it is not possible 
to obtain an overview whether the level of compliance is sufficient or not. Furthermore, as 
MS report on the volumes of materials sent to recycling (e.g., inputs), the results do not 
sufficiently  reflect  whether  materials  are  recycled  efficiently,  i.e.,  with  limited  losses  of 
material.  Finally,  the  cumulative  reporting  of  reuse  and  recycling  disincentivises  waste 
avoidance  and  re-use  of  components  and  materials,  as  achieving  a  minimum  level  of 
reuse is not required, resulting in some ATFs not dismantling parts for reuse at all (e.g., 
Deloitte & ADEME (2019) report that over 300 ATFs in France did not dismantle parts for 
reuse in 2017). 

•  The environmentally favourable dismantling of components for re-use or recycling before 
the shredding of ELVs is not profitable for many components. This can be related to the 
market  value  of  the  component  or  material  at  hand  or  the  level  of  logistic  costs  (for 
example, glass is rarely recycled as the costs of dismantling and logistics are not set-off 
by revenues from the sale of glass cullet to recyclers). The ELVD only requires removal 
of materials or components in the few cases specified in annex I (3 & 4) and even then, it 
is not always clear what level of recycling is considered sufficient to alleviate the necessity 
of  re-shredder  dismantling.  As  results,  ATFs  only  dismantle  other  materials  and 
components when this is anticipated to result in a profit. Furthermore, it is uncommon for 
financing to compensate non-profitable activities is provided, e.g., through EPR schemes. 
Consequently, the  level of  reuse  of  some  components  can  be  expected to  be  low  and 
recycling of some materials is carried out with losses in quality (e.g., glass aluminium) or 
quantity (e.g., precious, and critical metals. 

•  As the 3R targets and their reporting do not always promote the high-quality recycling of 
materials, where post shredder treatment is not profitable and where the targets can be 
complied with without advanced PST, capacities are not developed or not developed to 
the  level  of  the  best  available  technology  by  all  MS.  In  parallel,  though  some  MS  are 
understood to have developed higher capacities than is required to accommodate their 
own needs (e.g., NL), this does not ensure that the full potential of existing capacities is 
realised. 

The  problem  drivers  with  a  nature  of  lacking  enforcement  can  be  summarized  as 
follows:  

•  Article 7(4-5) requires the European Union to amend Directive 70/156/EEC so that the 
type approval process ensures that vehicles put on the EU market are design so that they 
can comply with the ELVD 3R targets and so that parts dismantled for reuse do not give 
rise to environmental or safety hazards. This provision led to the introduction of the 3R 
Directive and the related 3R type approval process. The process has a dynamic link to 
the exemptions form substance prohibitions listed under Annex II of the ELVD ad in such 
it  is  considered  that  vehicles  placed  on  the  market  comply  with  the  ELV  substance 
prohibitions. Nonetheless, despite market surveillance requirements, exchange with type 
approval authorities and type approval service provides clarifies that at least in some MS 
states that are involved in 3R type approvals, there is no monitoring as to the effectiveness 
of the type approval procedures and the level to which they indeed ensure that the 3R 

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targets can be complied with by vehicles placed on the market. Consequently, at least in 
a few cases (e.g., BMW i3) it seems that vehicles have been placed on the market with 
large amounts of non-recyclable materials. 

•  Article 6 requires facilities active in the treatment of ELVs to be authorised to do so and 
sets minimum requirements to ensure the safe and environmentally sound operation of 
such facilities (ATFs) as well as specifying how certain treatments should be performed. 
The article requires MS to perform yearly inspections of such facilities, and to ensure that 
facilities  active  in  the  specified  treatment  types  confer  to  conditions  and  requirements. 
However, illegal activities continue to be common, resulting for example in ELVs arriving 
at ATFS after removal e.g., of the catalytic converter, and in sales of parts for reuse that 
have been removed illegally. The enforcement is understood to be too low, and this results 
in unfair competition and reduced financial stability for ATFs. 

•  As  part  of  the  reporting  stipulated  in  the  ELVD,  Article  6  of  the  annex  of  Commission 
Decision  2005/293,  requires  MS  to  report  to  the  Commission  on  results  of  shredder 
campaigns  that  they  perform  to  conclude  on  output  of  end-of-life  vehicle  streams  of  a 
shredder.  There  is  however  no  specification  of  how  often  such  campaigns  should  be 
carried out nor as to whether they should apply to all shredders in a MS or only to a sub-
set of these. In consequence, not many MS report on such activities and it is assumed 
that shredder campaigns are not performed very often and possibly n some MS not at all. 

2.1.3.3  Key players and affected population 

The most relevant stakeholders affected include the following: 

• 

Illegal treatment facilities may not comply with the environmental standards and with ELV 
obligations  set  for  ATFs.  This  can  lead  to  environmental  pollution.  However,  as  illegal 
operators  do  not  comply  with  various  requirements,  they  have  lower  operational  costs 
than  ATFs,  creating  an unfair  playing field  and affecting  the  economic  vitality  of  ATFs. 
This is in particular relevant in cases where the illegal operators remove components that 
can retrieve profits (catalytic converter but also components for reuse) and then dump the 
vehicle, resulting in ATFs being required to complete the vehicle waste management. A 
similar case occurs when repair shops (legal and illegal) remove components for reuse 
without the relevant authorisation and permits, or when vehicle owners engage in such 
activities.  

•  As it cannot be ensured that components are removed properly in the above cases, when 
components  are  sold  for  reuse,  this  can  end  up  having  a  negative  impact  on  vehicle 
owners  who  purchase  components  from  unauthorised  entities  and  have  bad  a  bad 
experience  (i.e.,  component  malfunction  after  a  short  period  combined  with  lacking 
guarantee). Subsequently this can affect the market for reuse (and thus again the ATFs 
reuse business) when consumers get the impression that reused parts are unreliable. 
•  Citizens (vehicle owners) may further have unnecessary costs when the repair of a vehicle 
is performed through replacement of malfunctional components with new ones, as they 
have  not  been  informed  of  the  alternative  of  using  a  reused  or  remanufactured 
component. 

•  ATFs  have  difficulties  to  comply  with  the  depollution  and  removal  requirements  and  to 
achieve the reuse and recycling targets while remaining profitable. In particular, achieving 
higher recycling rates or higher qualities of recyclate can depend on the dismantling and 
separate recycling of some components. When such processes must be applied to fulfil 
the 3R targets, this can affect the profitability of ATFs. 

•  The  non-removal  of  certain  materials  and  parts  from  ELV  may  affect  the  quality  of 
recyclates that can be obtained from shredders, meaning a potential loss of materials or 
material quality as well as possibly affecting the revenues of shredders. For example, the 
non-removal of copper can affect the quality of steel scrap when not properly removed in 

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subsequent advanced shredding or PST. The maintenance costs of shredding facilities 
may increase when large amounts of glass or magnets are left in the vehicle hulk sent to 
shredding. 

•  Recyclers  could  incur  a  loss  in  revenues  when  certain  materials  are  not  sufficiently 
removed  from  scrap  or  when  the  level  of  PST  does  not  allow  sufficient  separation  of 
certain  fractions.  This  can  be  related  to  lower  amounts  of  scrap  made  available  for 
recycling processes, but also to higher impurities in available scrap that impact the quality 
of recyclates and thus also retrievable revenues.  

•  The presence of hazardous substances as impurities or at higher levels in ELV recyclates 
may result in downcycling or in some cases even requiring disposal, indirectly meaning a 
loss  of  potential  secondary  material  and  that  more  primary  materials  will  need  to  be 
extracted for use in new vehicles. The latter is often associated with energy costs and 
environmental impacts and in some cases also leads to a higher dependency of the EU 
on exports for supply of material resources. 

2.1.3.4  Why should the EU act? 

Remedying  some  of  these  problems  is  necessary  in  some  cases  to  allow  fulfilling  the 
objectives  of  EC  policies  like  the  Green  Deal,  the  CEAP  and  the  Sustainable  Chemicals 
Strategy, i.e., reducing the dependency on primary materials and increasing circularity as a 
means of reducing green-house gas emissions, primary raw material extraction, biodiversity 
loss and water consumption.  

The lack of coherence of the 3R Directive with the ELV in some cases and the shortcoming 
of the process of 3R Type approval result in vehicles being placed on the market that may 
not comply with the 3R targets. In particular, the process does not ensure that vehicles are 
designed to allow reuse of components, neither in terms of their dismantlability, e.g., when 
their assembly makes the reuse of a component impossible as it cannot dismantled without 
damage.  

Furthermore, in relation to the problems described above, in many cases it is observed that 
some MS have developed practices that support the waste management more successfully 
than others. This leads to higher reuse and/or recycling rates in some cases, to recycling of 
higher quality in others (e.g., glass), while also enabling ATFs to remain profitable in some 
cases.  Not  adopting  such  practices  at  the  EU  level  will  lead  to  growing  differences  in  the 
implementation of the ELV among the MS and may also affect the profitability of ATFs over 
time  and  lead  to  an  uneven  playing  field  (e.g.,  MS  where  backfilling  is  accounted  for  as 
recycling  as  opposed  to  those  where  it  is  not,  MS  that  require  glass  removal  prior  to 
mechanical treatment where secondary glass also means higher dismantling costs, etc.).   

The  efforts  towards  the  circular  economy  objectives  in  relation  to  reuse  and  recycling  will 
increase where the presence of hazardous substances in vehicles has a negative effect on 
their waste management. Thus, managing and minimizing hazardous substances in vehicles 
is  at  the  same  time  a  contribution  to  the  objectives  set  out  in  the  Sustainable  Chemicals 
Strategy for  a toxic-free environment  as  well  as  for the  Circular  Economy. It  is  particularly 
important to ensure that recycled materials can achieve requirements related to the content 
of hazardous substances, in line with the Sustainable Chemicals Strategy which “sets out as 
a  principle  that  the  same  limit  value  for  hazardous  substances  should  apply  for  new  and 
recycled  materials  with  derogations  in  only  exceptional  and  justified  cases”. While  it  is 
acknowledged that the achievement of this objective depends on the availability of suitable 
sorting and decontamination processes and whether, with these limitation, safe and fit-for-
purpose  materials  can  be  produced,  it  is  expected  that  future  EU  activities  in  relation  to 
substances of concern in vehicles may contribute to achieving the above-named objectives. 

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Taking the current ELVD as a baseline, it is expected that it does not contribute to a further 
reduction of additional hazardous substances in vehicles. Although this has been reached by 
restrictions  under  REACH,  legal  clarity  needs  to be  established  as to the  legislation  under 
which  the  further  substance  restriction  can  be  expected.  Multiple  legislations  are  more 
burdensome to follow and comply with for stakeholders, in particular for SMEs and also for 
MS authorities. Besides, multiple legislation can also result in inconsistencies in some cases. 
In each exemption, ELVD, for example, refers to the continued validity of the exemption to 
spare parts, whereas the availability of spare parts is addressed differently in REACH83). 

Generally  speaking,  for  a  long  time,  the  EU  has  been  the  legislative  body  addressing 
hazardous  substances/substances  of  concerns.  In  consequence,  regulation  of  hazardous 
substances  in  vehicles  is  perceived  a  continuous  task  for  the  EU,  especially  against  the 
background of ongoing EU activities on other chemical legislations. 

2.1.4  Which objective should be achieved? 

The European Commission (2019) Green Deal generally refers to industry’s still being “too 
‘linear’,  and  dependent on  a  throughput  of  new materials  extracted, traded  and  processed 
into goods, and finally disposed of as waste or emissions”. Promoting more circular business 
models  by  linking  design  issues  to  end-of-life  treatment,  considering  rules  on  mandatory 
recycled content for certain materials of components, and improving recycling efficiency were 
mentioned  as  a  focus  for  the  revision  of  the  ELVD  in  the  Circular  Economy  Action  Plan 
(European  Commission  2020a).  Various  EU  policies  make  clear  that  in  order  to  solve  the 
problems detailed above, it is essential to Improve circularity in the design, production 
and end-of-life treatment of vehicles. This is seen as the primary objective in common to 
the above problems, which can be broken down into secondary objectives in relation to the 
various life-cycle stages of a vehicle. 

The design stage of a vehicle determines not just its functionality but also the materials and 
components from which it is composed and how they are assembled in relation to each other. 
Vehicle design has a significant effect not just on the use phase, but also on the end-of-life of 
the  vehicle,  determining  to  a  large  extent  what  components  and  materials  will  be  readily 
dismantlable  to  allow  their  reuse  and/or  their  recycling.  Currently  it  is  considered  that  the 
design of vehicles does not sufficiently support their waste management at EoL, resulting in 
the  rate  of  reuse  and  high-quality  recycling  not  reaching  their  full  potential:  OEMS  apply 
assembly techniques that make it harder to dismantle components and materials for reuse 
and recycling. In some cases, this impression may be tied to insufficient data made available 
on the composition, localisation, and dismantling method of components. In others it is due 
to  increased  application  of  materials  that  hinder  dismantling  (and  thus  also  reuse  and 
recycling) like glues and sealants or materials that are non-recyclable or for which the existing 
recycling  practices  do  not  enable  high  quality  recycling  without  the  dismantling  of  certain 
components.  

Vehicle design will also affect the amounts of recycled content that can be integrated into a 
vehicle  as  material  specifications  related  to  composition,  grade  of  purity  and  performance 
requirements will often determine whether certain secondary materials can be applied instead 
of  primary  ones.  This  in  turn  affects  the  market  demand  for  recycled  materials  and  may 
determine  to  what  degree  waste  management  operators  are  willing  to  invest  to  ensure  a 
supply of secondary materials in larger quantities or of higher materials grades and quality. 
In this respect, the Green Deal specifies the need to develop legal requirements to boost the 

83 In restrictions, spare parts should be addressed when relevant, since the restriction report addresses articles that were 
placed on the market before entry into force and spare parts produced after that. For both, derogations can be considered.  

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market  of  secondary  raw  materials  with  mandatory  recycled  content  in  the  vehicle  sector 
(European Commission 2019). This is particularly relevant in cases where there is a market 
failure that affects the relations of supply and demand of secondary materials, e.g., due to 
fluctuation cost of primary ones. The first sub-objective thus relates to the design phase of a 
vehicle and is aimed to “Improve design and production of vehicles to support reuse and 
recycling”. 

The ELVD is identified to contribute too little to the elimination and/or reduction of hazardous 
substances in vehicles. Furthermore, the regulation of hazardous substances in vehicles is a 
patchwork of different legislations, mainly including chemical legislation. In cases where the 
use of hazardous substances in vehicles cannot be avoided, ELVD (nor other legislation like 
the provision for notification to SCIP under the Waste Framework Directive) does not ensure 
that recyclers have enough information on hazardous substances to allow depollution when 
this can lead to an increase in recycling amounts and/or qualities. A second sub-objective is 
thus to “Ensure elimination of hazardous substances in vehicles”, which is also related 
to the design of vehicles. As such, it contributes to minimising the impact of end-of life vehicles 
on the environment. The elimination of hazardous substances in vehicles is treated as a sub-
objective  under  the  main  objective  2,  since  a  reduction  of  hazardous  substances  allows 
increasing circularity, e.g., in relation to the recycled content, in relation to the prevention of 
(hazardous) wastes or with regard to increasing the quality of recycled material. 

Before a vehicle is placed on the market, it needs to be ensured that its composition, but also 
the assembly of its parts will facilitate the reuse and recycling of the vehicle at reasonable 
cost,  respectively  cost  to  be  covered  by  the  producers.  This  process  is  performed  as  a 
compliance check through the 3R Directive. The 3R Directive currently does not effectively 
ensure that the design of vehicles ensures that reuse of components is possible. Though it 
considers the vehicle composition to decide of the 3R targets can be complied with, it does 
not take into account material losses, thus considering a distorted picture of the recyclability 
and recoverability of vehicles. In some cases, the use of certain materials in the vehicle may 
further raise conflict between the use phase and the EoL phase, in terms of certain materials 
having a high contribution to weight, and subsequently emissions, despite a high recyclability 
and vice versa. The process of 3R type approval which ensures the compliance of the vehicle 
with  the  targets  on  reuse,  recycling  and  recovery  must  thus  be  able  to  strike  a  balance 
between costs and benefits of certain materials throughout the life cycle of the vehicle when 
conflicting  interest  may  affect  material  choice.  However,  currently  despite  considering 
whether a material is recyclable or not, there is no method to ensure that prioritisation of the 
waste phase will not have adverse impact in the use phase.   

At  the  end-of-life  stage,  the  economic  competitiveness  of  reuse,  repair  and  high-quality 
recycling of vehicles needs to be increased. Currently, there is unfair competition between 
ATFs and repair and treatment operators not authorised to dismantle components for reuse. 
Vehicle owners are also not sufficiently aware of the possibility of using reused components, 
meaning that the demand is too low to support more dismantling for reuse. It is also important 
to ensure that there is certainty as to the legal status of reuse or remanufactured components 
to eliminate possible obstacles to reuse. In turn, an increase in the rate of reuse will mean 
that less primary materials will be needed to manufacture new replacement components for 
repair, contributing to the circularity of vehicles. To support circularity related to reused parts, 
the third sib-objective is thus to “Increase the reuse and remanufacturing rates of parts 
and components”. 

Looking at the recycling of vehicles, though some materials are recycled at high quantities, 
current  treatment  practices  often  compromise  the  quality  of  scrap  and  thus  limit  the 
applicability of secondary materials in vehicle applications. In other cases, common treatment 
sometimes leads to difficulties in the separation of material fractions after shredder operations 
and thus limits the amounts of secondary material that can be generated and thus the market 

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for such materials and their competitiveness with primary ones. The 3R targets of the ELVD 
and in particular their monitoring does not incentivize high quality recycling and further affect 
the  circularity  of  vehicles.  Thus,  the  fourth  objective  is  to  improve  the  recycling  rates  of 
materials and components contained in cars.    

The primary and secondary objectives are summarised in the following figure. 

Figure 2-20  Objective No2 and related specific objectives 

Objective 2: Improve circularity in 
the design, production and end-of-
life treatment of vehicles

Specific Objective 2.1: 
Improve design and 
production of vehicles to 
support reuse and 
recycling

Specific Objective 2.2: 
Ensure elimination of 
hazardous substances in 
vehicles

Specific Objective 2.3: 
Increase the reuse and 
remanufacturing rates of 
parts and components

Specific Objective 2.4: 
Increase the recycling 
rates of materials and 
components 

2.1.5  What are the measures to achieve the objective? 

The  following  sections  details  a  number  of measures  devised  to  increase  the  circularity  of 
vehicles. Different measures have been developed for each of the above objectives and feed 
into  the  primary  objective  of  circularity.  To  support  some  of  these  measures,  it  is  also 
necessary to develop the way that the EPR obligation is implemented for vehicles. These are 
specified in 2.3.5 but are referenced where relevant.  

An overview of the measures proposed, and the related specific objective follows. 

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Figure 2-21  Measures addressing Objective 2: Improve circularity in the design, 
production and end-of-life treatment of vehicles and its 4 specific objectives 

a) OEM voluntary pledges campaign to increase circularity

b) EC non-binding guidelines on how to improve circularity in vehicles

Specific Objective 2.1: 
Improve design and 
production of vehicles to 
support reuse and recycling

c) Obligation for OEMs to develop and implement strategy for increasing the circularity of vehicles

d) Provisions for improving the relation between the 3R Type approval process and ELV waste 
management performance

e) Option for OEMs to submit life cyle data as part of 3R type approval process

f) Obligatory reporting requirements on the use of materials that affect dismantling and recyclability 
to faciltate idnetification of incompatible practices

g) Establishment of mandatory recycled content targets for materials used in cars

h) Obligatory due diligence for materials used in vehicles

i) Set out an obligation for OEMS to provide additional information on composition of cars

Specific Objective 2.2: Ensure 
elimination of hazardous 
substances in vehicles

a) Restriction of substances in vehicles

b) Improved communication on hazardous substances in the automotive value chain

Specific Objective 2.3: 
Increase the reuse and 
remanufacturing rates of parts 
and components

a) Clarify definition of re-use in the ELV Directive vs re-use and preparing for re-use in the Waste 
Framework Directive 

b) Introduce a definition of remanufacturing and specific provisions to support remanufacturing 

c) Voluntary activities of OEMs and supply chain to promote application of reused/ remanufactured components

d) Voluntary activities of Member States to promote circularity

e) Establish provisions to support the market of used spare parts

f) Set up a separate (monitoring) target for re-use/preparation for re-use/remanufacturing (for some 
parts or by weight compared to overall weight of ELV) 

a) Align definition of “recycling” with the WFD

b) Making it mandatory to remove certain parts/components before shredding to encourage their recycling

Specific Objective 2.4: Increase 
the recycling rates of materials 
and components 

c) Set material-specific recycling targets

D) Regulate shredder/post shredder facilities to ensure high quality/quantity of materials obtained for 
recycling and to improve final treatment process

e) Increase (?) current recycling targets and/or ban disposal or landfilling of waste from ELVs 

f) Revision of Commission Decision 2005/293/EC on the circularity aspects

Source Own illustration  

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2.1.5.1  Measures  to  achieve  specific  objective  2.1:  Improve 
design  and  production  of  vehicles  to  support  reuse  and 
recycling 

2.1.5.1.1  2.1.a)  OEM  voluntary  pledges  campaign 

to 

increase circularity 

To  motivate  OEMs  to  increase  circularity,  the  European  Commission  shall  establish  a 
platform  for  holding  campaigns  where  OEMs  shall  be  invited  to  voluntarily  commit  to 
improving  the  circularity  of  vehicles  through  changes  in  design  and  production.  For  this 
purpose, the European Commission will target different areas where the circularity of vehicles 
can be addressed and improved through design changes. In cooperation with the automotive 
sector  (producers,  waste  management),  sector targets  will  be  set for  each  of  these  areas, 
also  referring  to  a  timeline  for  achieving  the  target.  Subsequently,  for  each  such  area  a 
campaign will be launched inviting individual OEMs and their suppliers to commit to voluntary 
actions that will contribute to achieving the mutual target.  

This  measure  is  proposed  to  be  initiated  at  the EU  for  two reasons.  First,  development  of 
similar initiatives has been possible up till now at national level, however even if this is the 
case, the contribution to circularity has not been sufficient. Furthermore, the OEMs are active 
at European (and actually at global) level. Activity on a European basis will ensure that any 
achievements apply to vehicles placed on the market in all MS. 

At the initial phase, it is recommended to perform a survey for collecting information on the 
current state of play. Individual operators (OEMS, suppliers, waste operators) will be asked 
to participate by submitting confidential data. This data will be aggregated to establish the 
current status of various circular practices ad to set targets for a mid-term timeline (e.g. five 
years).  

On this basis, campaigns will be held on the platform, inviting OEMs and suppliers to commit 
(i.e., to pledge) to achieving a certain share of the mutual target within the five-year timeframe.  

The following areas are to be targeted in this manner:  

(i) 

(ii) 

Increase the rate of materials used in new vehicles, which are easy to re-use and 
recycle: In this respect, materials are to be targeted that increase the durability of 
parts  (i.e.,  increasing  potential  for  reuse)  and/or  that  can  be  recycled  at  high 
efficiency and with no or minimum loss in quality (i.e., no downcycling) with the 
current  capacities  of  the  ELV  waste  management  value  chain.  The  ELV  waste 
operators  shall  be  consulted  for  this  purpose  in  the  identification  of  relevant 
materials and in the consideration of targets together with representatives of the 
automotive manufacturing sector that can be achieved in the mid-term.  

Apply composite or materials for which no recycling/re-use is currently possible 
only when justified from a life cycle perspective: Materials which have a negative 
impact  on  the  achievability  of  the  ELV  recycling  targets  shall  be  identified  in 
cooperation with the automotive producers and the respective waste management 
sector. For such materials, the sector shall pledge to investigate impacts along the 
life  cycle,  use  such  materials  only  where  use  benefits  set-off  EoL  costs  and  to 
provide funding for developing recycling capacities within a mid-term timeframe. 

(iii) 

Increase the rate of recycled materials used in new vehicles: Together with the 
automotive manufacturing sector the current amounts of recycled materials used 
in the vehicle sector shall be established for e.g., steel, aluminium, copper, REE 
magnets, plastic (specific polymers), glass, rubber. For each of these materials, 

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(iv) 

targets  (sector  amounts)  for  the  mid-term  shall  be  considered  and  set  for 
increasing the amount of recycled content in vehicles. 

Develop  remanufacturing  as  part  of  their  production  process:  OEMs  and  their 
suppliers shall be asked to report on the current level of use of remanufactured 
parts in the production of new vehicles and of “as good as new” spare parts. A 
target shall be set to increase the use of remanufactured parts, identifying specific 
components where the potential for remanufacturing is high and mainly depends 
on the  level  of  demand. OEMs  and their  suppliers  will  commit to  apply  a larger 
share  of  remanufactured  parts  instead  of  new  parts  for  repair  but  also  in  the 
assembly of new vehicles. 

At the end of the five years, economic operators that have made a pledge will be asked to 
report on its implementation. On this basis it shall be elicited to what degree the set targets 
were  achieved.  If  this  practice  results  in  a  significant  achievement  of  the  set  targets,  new 
campaigns  shall  be  considered  and  performed  on  a  routine  basis.  In  areas  where  the 
campaigns  do  not  lead  to  significant  results,  the  EC  shall  take  action  to  introduce  the 
obligatory measures, in the legislation in which appropriate, i.e., under the ELVD, the 3RD or 
both. 

Expected  outcome:  though  stakeholders  could  be  expected  to  participate  in  the  pledge 
campaigns, there is a risk that only some OEMs would actually make pledges that are beyond 
what  they  are  already  doing  (frontrunners  and  potentially  a  few  additional  OEMs).  In  that 
sense, there is a risk that this measure would not reach all OEMs, nor the majority, leading 
only partial improvements in circularity. A further risk is that unless the EC (and possibly other 
actors of the sector like waste operators) promote such campaigns on a routine basis (e.g., 
every few years) that the impact shall only occur in the first years and afterwards subside, 
again leading to only partial improvements. Furthermore, the measure provides insufficient 
confidence that key specific objectives will be achieved, this is particularly the case for item ii 
and iii due to the complex nature of economic impacts. 

2.1.5.1.2  2.1.b)  EC  non-binding  guidelines  on  how  to 

improve circularity in vehicles 

The  Commission  will  develop  and  publish  a  document  with  recommendations  on  best 
practices  for  improving  the  circularity  of  vehicles.  Due  to  the  relevance  of  circularity  to 
environmental  performance,  it  is  proposed  to  develop  a  document  of  Best  Environmental 
Management Practices (BEMP) with focus on establishing circularity in the automotive sector. 
The document shall be developed based on consultation with frontrunners in the sector as to 
their circularity practices. It shall be developed in a similar format to EU Eco-Management 
and Audit Scheme (EMAS) BEMP documents, explaining the relevant actions, their expected 
achievements,  expected  relation  of  costs  and  benefits  of  the  action,  potential  cross-media 
affects  to  be  avoided,  benchmarks,  etc.  The  document  shall  be  adopted  as  a  non-binding 
guideline for improving circular design and production of vehicles and shall be updated from 
time to time according to technical and scientific progress. The document should focus on:  

•  Design practices that support dismantling (through shortened dismantling time, increased 
dismantlability with common ATF tools, avoidance of damage to component removed or 
its surroundings), 

•  Design  practices  that  support  high  quality  recycling  (through  the  use  or  avoidance  of 
certain materials or the mass of materials used in parts that are commonly removed prior 
to shredding), 

•  Environmental management practices that encourage exchange of information between 

designers and dismantling facilities. 

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A few existing studies prepared by JRC84 could provide a starting point for such guidelines. 

Expected outcome: Similar guidance documents like EMAS exist for other sectors, however 
it is not clear to what degree they are actually applied and thus also not to what degree they 
lead  to  benefits.  The  understanding  that  the  development  of  such  guidelines  could  be  a 
lengthy process, requiring involvement of various stakeholders also means that any impacts 
to  derive  will  incur  somewhat  in  delay.  Though  this  measure  could  support  more 
communication  between  manufacturing  and  waste  management  sectors,  considered  a 
benefit, the range of its actual impacts remains unclear, and it is therefore assumed to be less 
effective than other proposed measures. 

2.1.5.1.3  2.1.c)  Obligation 

to  develop  and 
for  OEMs 
implement a circularity strategy for increasing the 
circularity of vehicles 

As  explained  in  section  2.1.2.1.3,  Article  6(3)  of  the  3R  Directive  currently  requires 
manufacturers to “recommend a strategy to ensure dismantling, reuse of component parts, 
recycling and recovery of materials […]”. The consultants understand “to ensure dismantling, 
reuse of component parts, recycling and recovery of materials” to mean that on the one side 
there needs to be a strategy for vehicles to be designed in a way that supports the dismantling 
of  certain  components  and  on  the  other  side,  also  a  strategy  for  developing  methods  for 
dismantling  that  ensures  that  reuse  and  recycling  can  take  place  at  the  ATF  in  an 
economically  feasible  way.  However,  in  practice,  even  if  strategies  refer  to  design  for 
dismantling, they do not include detailed information.  

Article 6(5) clarifies that competent bodies acting in the name of Type approval authorities 
and issuing a Certificate of compliance for a manufacturer, need to “[…] describe the strategy 
recommended by the manufacturer […]”. Annex I(8) of the 3R Directive further requires that 
Type approval authorities checking the 3R calculation in a type approval submission “shall 
ensure  that  the  data  presentation  form  referred  to  in  point  2  [the  completed  Annex  A  to 
standard  ISO  22628:  2002]  is  coherent  with  the  recommended  strategy  annexed  to  the 
certificate of compliance referred to in Article 6(1) of this Directive.” Though the latter article 
seems to clarify that the strategy needs to apply at least in part at vehicle level, according to 
stakeholders  (Stellantis  2022;  VW/Porsche  2022)  strategies  developed  by  OEMs  in  this 
respect are quite general. OEMs explain that the information provided in such strategies on 
the  dismantling  of  vehicle  components  at  EoL  is  different  from  dismantling  information 
provided to IDIS and quite general in nature. However, the information provided to IDIS only 
concerns  components  addressed  under  Annex I  (3  &  4)  of the  ELVD  and  in  consequence 
dismantling of other materials and components is not always economically feasible and thus 
not  necessarily  performed.  This  affects  the  level  of  circularity  of  vehicles.  To  increase  the 
circularity of vehicles further, it is thus proposed to require OEMs to develop a more detailed 
circularity strategy. This is proposed to replace the current 3R Directive Article 6(3) provision 
to improve compliance. Alternatively, it could be included as a separate strategy in either of 
the two legislations.  

Taking  consideration  of  the  general  objective  of  vehicle  circularity  and  of  other  measures 
proposed in this study, the strategy addressed in this measure should include both elements 
regarding the OEMs  strategy for  increasing the circularity  of  its  vehicle fleet  in  the  mid-  to 
long-term  (5-10  years)  and  details  on  actions  planned  in  the  short  term  in  specific  vehicle 

84 JRC Report (2020): Sustainable use of Materials through Automotive Remanufacturing to boost resource efficiency in the 
road Transport system (SMART); JRC /2917) report:  Best Environmental Management Practice for the Car Manufacturing 
Sector  

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types  to  be  submitted  for  type  approval  over  the  next  two  years.  In  this  way,  the  strategy 
would both set commitments for future development of vehicle models by the OEM, while also 
already showing the first steps of implementation in vehicles to be type approved in the short 
term. This is of relevance as in some cases, strategic development can no longer take place 
at the level an already type approved vehicle, as changes to its assembly and composition 
would  require  the  type  approval  to  be  revised.  This  is  for  example  the  case  for  any 
commitments to increase the use of recycled content. The OEM can commit to increase the 
level over a period of time, but once a vehicle is type approved, the level is assumed to remain 
constant in any vehicles put on the market covered by the specific type approval. In some 
cases, however strategic development would require ensuring or at least promote that certain 
things take place at EoL. For example, if non-recyclables are to be used in large amounts in 
a  vehicle  type  proposed  for  type  approval,  the  OEM  should  have  a  strategy  in  place  to 
promote that at EoL of the respective vehicles, recycling capacities will have developed to 
ensure that the 3R targets can be met. In such cases, detail at vehicle level is relevant as to 
the  use  of  such  materials,  however  proposing  steps  that  promote  the  development  of 
recycling capacities is to be addressed at general fleet level, also as some materials may be 
used in multiple vehicle types. The following thus outlines an OEM circularity strategy referring 
to minimum information requirements at both the level of the vehicle fleet and at the level of 
single vehicle types. 

A provision shall be included in the future legislation on 3R Type approval, requiring OEMs 
to  develop  and  implement  a  strategy  for  increasing  the  circularity  of  their  vehicles.  The 
strategy is to be submitted every two years to the 3R Type approval authority/ies in the MS 
in which the OEM performs the type approval of its vehicle types and to the competent body 
nominated  by  the  MS  to  perform  the  preliminary  assessment  of  the  manufacturer,  its 
extension of validity or renewal. Insofar, the strategy shall be checked by the competent body 
bi-annually as part of the preliminary assessment and the revision of the subsequently issued 
certificate of compliance. Additionally, the 3R Type approval authority shall ensure that the 
information submitted for the type approval of a vehicle type is in line with both the general 
strategy and with specific strategy detailed for that specific vehicle type in the strategy.  

The strategy proposed here will need to be developed generally for the vehicle fleet of the 
OEM and specifically for all vehicle types approved in the two years prior to its submission, 
in  relation  to  minimum  information  requirements  specified  in  annex  to  the  type  approval 
legislation. The annex could be updated from time to time, should the need arise to adapt the 
requirements  in  scope  and/or  in  ambition.  It  shall  be  obligatory  to  submit  the  first  strategy 
within 2 years of the entry into force of the legislation and to update it every 2 years.  

The  provision  shall  refer  to  an  Annex,  detailing  minimum  information  requirements  to  be 
addressed  in  the  strategy.  The  Commission  shall  initiate  a  revision  of  the  information 
requirement  annex  in  any  case  that  provisions,  in  the  ELVD  and/or  in  the  3R  Directive, 
affecting  vehicle  design  are  changed  in  a  way  that  would  require  an  update  of  the  valid 
information requirements in scope and or ambition level In the updating of their strategies, 
OEMs will need to consider any amendments included in the Annex up to 12 months prior to 
publication  of  the  strategy  as  to  the  minimum  information  requirements.  The  following 
requirements are proposed to be included in the first information requirement annex: 

Elements to be addressed in the OEM “Strategy for increasing the circularity of vehicles” (at 
vehicle fleet level as a general strategy:  

•  General  considerations  on  the  composition  of  vehicles  for  increasing  the  share  of 
recyclable materials. As a minimum OEMs shall explain the criteria and methods that they 
apply  to  consider  whether  to  use  materials  with  low  recyclability  (or  unestablished 
recycling). This shall include explanation of methods applied to compare environmental 
impacts related to such material in the various vehicle life cycle phases (e.g., life cycle or 

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carbon footprint balance validation methods). Strategies shall also be detailed application 
of which ensures that components composed of such materials can be separated from 
the  waste  fraction  at  EoL  to  avoid  contamination  of  other  fractions,  i.e.,  dismantling 
consideration for components or available treatment technologies that ensure separation 
and sorting of such materials from shredded fractions.  

•  General considerations on the composition of vehicles for increasing the share of recycled 
content used in vehicles. As a minimum, in the first strategy document, OEMs shall report 
on the total amount of recyclables used in the construction of their vehicles, how this is 
allocated  between  various  materials  and  example  components  where  such  materials 
have been introduced. In addition, OEMs shall set a target for the next 5 years as to the 
increase in use of recycled materials that is planned in their vehicle fleet. Values referred 
to shall reflect an average for the vehicles to be placed on the market by an OEM in the 
next 5 years and not the “best in class” in this respect in their product portfolio, 

•  Considerations on the assembly and dismantling of vehicles that support the removal of 
vehicle components and materials and facilitate reuse and/or high-quality recycling. As a 
minimum, OEMs shall report on changes that they have introduced in their vehicle design 
in the last 3 years to promote dismantling of material components with a high potential for 
reuse  and  or  for  improved  recycling  (quality  or  quantity)  when  removed  prior  to 
mechanical treatment processes. This should include as minimum detail on components 
for which dismantling obligations exist (see related measure in section 2.1.5.4.2) or for 
which  ATFs  have  reporting  obligations  on  reuse  (see  related  measure  in  section 
2.1.5.3.6). OEMs shall also be required to report on how they ensure that such information 
reaches  ATFs  and  what  feedback  mechanisms  they  have  introduced  to  allow  input  of 
such stakeholders to flow back into the considerations of their vehicle design. 

Furthermore, elements to be addressed in the first version of the OEM “Strategy for increasing 
the  circularity  of  vehicles”  shall  include  planned  actions  at  the  level  of  vehicle  types  to  be 
approved in the following two years in relation to the following aspects:  

•  General  considerations  on  the  composition  of  vehicles  for  increasing  the  share  of 
recyclable  materials:  OEMS  shall  be  required  to  declare  for  which  models  to  be  type 
approved in the next 2 years, more than 10 kg of materials will be used for which recycling 
capacities do not exist at the time of type approval. In addition, OEMs shall be required to 
detail how they intend to promote the recycling of such materials within 7 years of market 
entry of the respective type approved vehicles.   

•  General considerations on the composition of vehicles for increasing the share of recycled 
content used in vehicles: For each vehicle type planned to be type approved in the next 
two years, OEMS shall detail the minimum rate of recycled content used in the vehicle 
type in general and the specific rate of recycled content used for any material for which 
obligatory recycled content targets have been introduced under the ELV legislation.   
•  Considerations on the assembly and dismantling of vehicles that support the removal of 
vehicle components and materials and facilitate reuse and/or high-quality recycling: As a 
minimum, OEMs shall detail practices applied in vehicle types to be approved in the next 
two  years  to  support  the  economically  feasible  dismantling  of  components  for  which 
dismantling obligations exist (see related measure in section 2.1.5.4.2) or for which ATFs 
have reporting obligations on reuse (see related measure in section 2.1.5.3.6). 

Expected outcome: It is assumed that this measure could lead to benefits over time, as on 
one side it shall become more apparent what practices OEMs apply to improve circularity and 
shall drive OEMs to improve performance over time and on the other side it should improve 
the understanding of type approval authorities of the relation between material composition 
and component assembly and the role that these two aspects play in achieving the 3R targets. 
The minimum information requirements shall allow ensuring that aspects are addressed for 
which provisions have been introduced, like recycled content targets or provisions to ensure 

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recyclability  of  non-recyclables.  In  these  cases,  the  strategy  shall  serve  as  a  type  of 
declaration of conformity. In other cases, reporting on minimum level and existing practices 
and strategies shall allow a better understanding of OEM efforts towards circularity applied 
on a voluntary basis. In other words, though the strategy would be obligatory, it has a high 
level  of  flexibility  for  implementation  in  terms  of  definition  of  information  requirements  and 
subsequently  how  OEMs  prioritise  certain  aspects  over  others  (or  certain  materials).  This 
could lead to a more efficient implementation for OEMs in terms of the proportion between 
investment in actual improvements of vehicles and benefits in circularity that this results in. 

2.1.5.1.4  2.1.d)  Provisions 

relation 
between  the  3R  Type  approval  process  and  ELV 
waste management performance. 

improving 

the 

for 

Declarations  on  fulfilment  of  the  reuse,  recycling,  and  recovery  (3R)  targets  submitted  by 
vehicle  manufacturers  and  checked  by  approval  authorities  (through  the  technical 
services/competent bodies) as part of the 3R Type Approval process do not always reflect 
the achievable rates of the 3Rs at end-of-life. To address shortcomings and to further facilitate 
waste management in achieving the targets, changes are to be introduced in the process. 
These shall address how to take into consideration limitations in the predictability of treatment 
for  certain  materials  at  end-of-life  with  the  objective  that  results  of  the  3R  calculation 
performed  as  part  of  the  3R type  approval  process  are  closer to  the  actual  level  of  reuse, 
recycling  and  recovery  that  is  achievable  at  the  vehicle’s  EoL.  Additionally,  information 
requirements shall be introduced into the 3R Type approval application85 for data needed for 
developing  fee  modulation  as  part  of  EPR  schemes  and  for  data  that  must  be  made 
accessible to waste management operators (see data accessibility obligations under measure 
2.1.i in section 0) to facilitate waste management. 

The  following  requirements  are  to  be  introduced  into  the  3R  Type  approval  (regardless  of 
whether it remains an individual legislation or whether it is merged into the future legislation 
for ELVs). Requirements are to be introduced in a way that will allow possible updates from 
time to time to align with technical progress (e.g., in an annex or through a delegated act):  

• 

In the calculation of the potential reusability and recyclability of materials: 
o  The recyclability rate (Rcyc) calculation is to be revised, introducing additional elements 
to those required under the ISO Standard 22628 EN, as it is not clear if the EC could 
initiate and successfully change the ISO standard86. The following is to be required of 
the calculation: To be considered recyclable, a component part or material shall be 
linked to a proven recycling technology: 
  For  materials  for  which  recycling  capacities  of  ELV  fractions  are  established 
(Technology Readiness Level of 8 and above) at the time of the Type Approval 
submission,  the  material  will  be  considered  100%  recyclable  except  in  the 
following cases: 

85 Alternatively, and as far as not feasible to introduce it under the 3R type approval, such monitoring might also be established 
under EPR Regime. 

86 ISO Standard 22628 EN is an international standard. It is also applied, e.g., for the international type approval process 
which could adopt EC 3R Type approval changes but may also remain unchanged. Should it the ISO standard not be 
revisable to accommodate changes to the 3R Type approval, the calculation method could be kept, adding to the level of 
detail that needs to be included in the calculation for example through an annex. This is understood to still be in line with the 
general calculation method given in the ISO standard.  

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o  The recyclability of tyres is to be calculated as 50% of the tyre weight to 

reflect material losses during use and the actual level of recycling currently 
achievable.  

o  Values could be specified in the future for additional materials where there is 
evidence that process inefficiencies result in an actual recycling efficiency 
which is significantly below 100%. 

o 

o 

  Where recycling capacities are not yet established for ELV fractions: 

o  0% will be considered, where recycling technologies are at a TRL < 4;  
o  50% will be considered where recycling technologies are at a TRL of 4-5; and  
o  80% will be considered where recycling technologies are at a TRL of 6-7. 
In  the  specification  of  reusability  and  recyclability  of  materials  and  components 
removed at the dismantling stage (mD), the calculation will include a break down into 
components  and  materials  that  can  be  dismantled  to  be  reused,  remanufactured 
and/or recycled: 
  Components that can potentially be reused or remanufactured: as a minimum all 
components specified under ELVD Annex I (4) and/or in the list of components for 
which  dismantling  method  and  time must  be  provided  to the  EPR  scheme  (see 
details under Section 0 and Section 0) are to be listed, specifying for each: the 
weight, the composition, the dismantling method (fastening technology + proven 
dismantling technology87) and the dismantling time 

  Components  that  can  be  dismantled  and  recycled  separately  to  achieve  higher 
recycling  qualities  or  quantities:  as  a  minimum  all  components  and  materials 
specified  under  Annex  I  (4)  will  be  included  in  this  list,  specifying  for  each:  the 
weight,  the  composition,  the  material  composition,  the  proven  dismantling 
technology (see footnote 87) and the dismantling time.  

In the case that the calculation shows that the RRR targets cannot be achieved, the 
type approval will be declined, unless life cycle data (carbon footprint data) submitted 
as part of the 3R Type approval application shows that the use of materials with a TRL 
below  8  contributes  to  a  decrease  in  impacts  in  the  use-phase  that  sets-off 
environmental losses of these materials in the waste phase. This is further detailed 
under measure 2.1.e under Section 2.1.5.1.5) 

•  The 3R Type Approval shall cover all stages of multi-stage vehicles type approval (e.g., 

N1, trucks, caravan):  
o  The OEM shall be responsible for the 3R Type Approval of the base vehicle and any 
further components that are  part  of the vehicle  that the OEM  intends to put  on the 
market.  

o  Any economic operator that intends to put an altered base vehicle (that has been 3R 
type  approved  by  an  OEM)  on  the  market,  will  be  obliged  to  submit  a  3R  Type 
Approval  for  all  alterations  of  the  vehicle  (components  and  parts  integrated  and  or 
attached to the vehicle and any changes made in the base vehicle). 3R Type approval 
of all stages of the vehicle to be put on the market shall be a condition to the type 
approval of a vehicle based on Regulation 2018/858/EU.  

To support the enforcement of the 3R Type approval, and in particular the technical know-
how of 3R Type approval authorities, the Commission will have dismantling and shredding 
tests performed for at least 5 vehicle types approved in that year (1 vehicle of each type). 

87 ISO Standard 22628 EN specifies criteria for the consideration whether a component is to be considered as “reusable” 
and/or “recyclable”. These include among others the fastening technology and the proven dismantling method for reusable 
components and the proven dismantling technology for recyclable parts. It is thus assumed that for such aspects, where lists 
of proven technologies are not mutual, that a common understanding of these exists and could be used as a basis for 
updating. 

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Two alternatives are envisioned here in terms of how such tests could be performed and in 
relation to what stage of type approval.  

•  Alternative 1:  

o  Every year, five vehicle types newly placed on the market will be selected to be 
dismantled and shredded. A single vehicle of each type will be submitted to this 
exercise. This could be performed by the Joint Research Centre or through an 
external contractor. 

o  The test will document the dismantling of each vehicle and analyse the information 
to estimate the achievability of the 3R targets at EoL. For this purpose, the party 
shall apply methods specified in the type approval submission for the dismantling of 
components. Tools specified in such information shall only be applied if they are 
tools commonly used by ATFs. The party performing the test will document the parts 
dismantled (time of dismantling, tools used to support the task, composition of part). 
On this basis, the party will then estimate the probable route of treatment of each 
component dismantled.  

o  To estimate the route of treatment for the remaining vehicle, it will then be sent to a 
shredding facility that will be required to provide data as to the route of treatment of 
resulting fractions (for each material, the amounts sent to recycling, material losses, 
and amounts of resulting recyclables, amounts sent to energy recovery or other 
recovery, and amounts landfilled).  

o  On the basis of all collected data, and comparison with the type approval data, the 
party will estimate the accuracy of the submission. This will be performed also in 
relation to different scenarios of the waste management in the MS in which the 
vehicle is being dismantled – i.e. low/moderate/high share of dismantling combined 
with different levels of shredding and PST).  

o  A report documenting the annual results of dismantling tests will be shared with 3R 
Type Approval authorities to support their knowhow. It shall include references to 
each of the vehicle cases and where possible recommendations as to how to 
critically review the 3R type approval submission or proposals for its further 
improvement. In cases where the results will show that the Type Approval was 
wrongly approved, the certificate will be withdrawn. 

•  Alternative 2 for dismantling and shredding tests: 

o  As  part  of  the  type  approval  of  a  vehicle  type,  OEMs  shall  be  required  to  have  a 
dismantling and shredding test performed for 1 vehicle per each vehicle type to be 
approved. Results of the test shall be submitted to the type approval authority together 
with the type approval application. The test is to be performed by an independent ATF 
(which  does  not  have  other  contractual  relations  with  the OEM  and  which  services 
vehicles of multiple types and brands) and is to be supervised and documented by a 
type approval service provider.  

o  The  performing  ATF  will  dismantle  the  vehicle  based  on  methods  prescribed  for 
dismantling of components and materials specified by the OEM in the type approval 
application  and  shall  record  the  time  of  dismantling  needed  for  each  component. 
Where  methods  are  not  specified,  common  practice  dismantling  methods  shall  be 
applied, specifying times for any additional components and materials for depollution 
or removal obligations exist under ELVD Annex I(3 & 4). For components that have 
been dismantled, the ATF shall consider the revenue that it could expect to retrieve 
e.g., from components sold for reuse or from parts sent to separate recycling and shall 
specify components for which it considers that the dismantling method prescribed I 
snot economically feasible.  

o  To estimate the route of treatment for the remaining vehicle, it will then be sent to a 
shredding facility that will be required to provide data as to the route of treatment of 
resulting fractions (for each material, the amounts sent to recycling, material losses, 

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and  amounts  of  resulting  recyclables,  amounts  sent  to  energy  recovery  or  other 
recovery,  and  amounts  landfilled).  Should  the  dismantling  and  shredding  test  data 
show that the dismantling of a certain component is not economically feasible, such 
data shall be passed to the EPR scheme to feed into future fee modulation. 

It  is  probable  that  at  the  time  of  type  approval,  that  OEMS  have  only  produced  prototype 
versions  of  the  vehicle  as  mass  production  will  have  not  yet  started.  This  results  in  some 
advantages  and  disadvantages  for  each  of  the  alternatives  proposed  above.  Alternative  A 
has the advantage that the dismantling test is performed on a vehicle that is already produced 
in series production and could thus be more accurate in terms of results. However, if through 
this test, it shall be discovered that the vehicle actually does not comply with the 3R Type 
approval, the type approval would have to be withdrawn and all vehicles placed on the market 
recalled,  at  high  costs.  Alternative  B  performs  the  test  prior  to  the  type  approval.  Should 
limitations to the type approval be identified, it would not be approved, prior to the vehicle 
reaching mass production, saving respective costs. Nonetheless, at this stage, a prototype of 
a vehicle may be less representative of the actual vehicle, with the consequence that the type 
approval  may  still  result  in  vehicles  placed  on  the  market  that  are  not  optimal  in  terms  of 
dismantling  and  fulfilment  of  the  3R  targets.  Nonetheless,  this  option  would  support  the 
provision of test based dismantling times of specific components to be considered in EPR fee 
modulation,  which  may  be  more  representative  than  times  that  the  OEM  would  provide 
independently.     

Expected outcomes: The method proposed for revising the calculation of the 3Rs in the 
respective Type Approval process is expected to allow better control of the actual recyclability 
of vehicles, particularly considering the increasing trend towards use of light-weight materials. 
The combination of a lower recycling value in the calculation of materials for which recycling 
is not established with the option of providing LCA data to justify the use of such materials 
when  it  hampers  waste  management  is  assumed  to  provide  more  flexibility  for  the 
development of innovative materials. In parallel it is to ensure that vehicles that make use of 
such materials without an actual reduction of emissions or fuel/electricity consumption during 
the use phase are denied market access. Though the new calculation differs from the current 
one,  the main  additional  burden  for OEMs  is  expected  in  relation to  the  provision  of more 
detailed  data  on  components  and,  in  cases  where  it  applies,  life  cycle  data.  However, the 
provision  of  dismantling  methods  and  times  for  components  is  assumed  to  allow  a  better 
integration  of  the  reuse  objective,  without  requiring  OEMs  to  forecast  which  parts  will  be 
reused  in  practice.  This  will  increase  the  availability  of  information  on  dismantling  of 
components with a reuse and/or recycling potential and could support such practices in the 
future.  Provision  of  life  cycle  data  will  turn  the  process  of  compliance  checking  for  such 
materials into a black and white decision and is considered to ensure that the use of non-
recyclable materials in large quantities will be limited to cases where this reduces the total 
negative environmental impacts of a vehicle despite higher impacts at EoL. In this sense, the 
measure is expected to facilitate ELV waste management and may also increase the use of 
recyclable materials in vehicles. 

The main concern of this measure is that any changes to the 3R Type Approval process may 
affect  the  coherence  with  the  international  UN  ECE  Regulation  133  and  transboundary 
movements of vehicles between the EU and other countries. This could require a withdraw 
from this Regulation and have consequences for vehicles that were formally considered to 
comply with the EU legislation on 3R Type Approval though approved elsewhere. Extending 
the scope of the 3R Type Approval beyond the base-vehicle stage to multi-stage vehicles is 
expected  to  create  a  significant  burden  for  economic  operators  that  are  involved  with  the 
manufacture  of  multi-stage  vehicles  and  who  have  up  till  now  only  been  involved  in  the 
general Type Approval process. Such operators include many SMEs which may be affected 
more heavily. In parallel, it is not clear how many multi-stage vehicles are put on the market 

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in large series, i.e., market volumes that would not be excluded anyway from the 3R Type 
Approval  due  to  Article  3(c)88  of  Directive  2005/64/EC  on  the  3R  Type  approval.  The 
combination  of  these  aspects  could  mean  that  impacts  for  various  actors  and  for  the 
environment could differ for various vehicle categories. 

It is hard to anticipate whether the obligatory dismantling and shredding tests will actually lead 
to an increase in the knowhow of the type-approval authorities and facilitate the identification 
of vehicles that will not comply with the 3R targets and for which a type approval may not be 
justified.  As  only  5  model  vehicles  will  be  dismantled  per  year,  it  could  be  that  any 
improvements to the type approval process and to the vehicles that make it to market will be 
very gradual in development, making for a more modest contribution to increased circularity.   

2.1.5.1.5  2.1.e) Option for OEMs to submit life cycle data as 
part of the 3R type approval process to justify the 
use  of  materials  where  recycling  is  not  yet 
established  

Article  7  of  Regulation  2019/631/EU89  on  CO2  emission  performance  standards  for  new 
vehicles  requires  the  Commission  to  evaluate  the  possibility  of  developing  a  common 
methodology for the assessment and the consistent data reporting of the full life-cycle CO2 
emissions of certain vehicles placed on the Union market at latest by 2023. The Commission 
is considering the development of such proposals; however, this is expected to mainly focus 
on vehicle CO2 emissions. In a study performed in this context, reference to the EoL mainly 
refers to battery related aspects. 

In parallel, it is however observed that certain materials that are hard to recycle are applied 
in vehicles to generate environmental benefits during the use phase, however it is not always 
clear if such benefits indeed justify the impacts on the EoL of vehicles. 

The intention of this measure is to enable the use of life cycle data as evidence in the 3R 
Type approval process to justify the use of non-recyclable materials at the time a vehicle is 
POM. Such data could support a future 3R Type Approval where the use of certain materials 
hinders waste management but also results in a significant reduction in environmental impact 
during the use phase which compensates for not achieving the recycling targets at EoL. To 
ensure that life cycle data for different vehicles is comparable, a standardised method for the 
calculation and compilation of such information would need to be developed. This could be 
developed as Product Environmental Footprint (PEF) rules for vehicles that would need to be 
applied  for  preparing  self-declarations  for  submission  at  the  type-approval  stage  or  as  a 
guidance  document.  The  development  of  an  LCA  method  that  may  be  pursued  under 
Regulation 2019/631/EU could also include elements addressing non-recyclable materials at 
EoL, to make sure that when the method is followed, resulting data can be used in all cases 
of  EU  legislation  that  requires  provision  of  life  cycle  data.  The  focus  is  expected  to  be  on 
comparisons between costs and benefits related to the use of a specific material in the use 
phase and EoL phase (though manufacturing should not be excluded). Though currently it 
would be sufficient for a comparison to be performed based on a total carbon footprint (CO2 
equivalents), in the future, as the market advances towards a larger share of renewables in 

88 Initially based on Directive 70/156/EEC, vehicles produced in small series is considered to apply in cases where less than 
500 (M1, N1, O1 and O2 vehicles) or 250 vehicles (other types of motor vehicles and trailers except mobile cranes for which 
20 vehicles applies) are to be put in the market in a MS an can thus be exempted from the Type Approval process. 

89 Regulation (EU) 2019/631 of the European Parliament and of the Council of 17 April 2019 setting CO2 emission 
performance standards for new passenger cars and for new light commercial vehicles. This aspect is also addressed for 
trucks under Regulation 2019/1242. 

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the energy mix, it will become more relevant to focus on energy consumption as the weight 
of emissions decreases as will the consumption of fuel.  

It is assumed that at least two years would be needed to develop PEF rules or a guidance for 
vehicles  and  possibly  longer.  OEMs  would  be  consulted  with  as  part  of  the  development 
process and are understood to be in the position of contributing to this process, seeing as 
many OEMs already use life-cycle-analysis to model the environmental performance of new 
vehicles. This shall also allow time for training type approval authorities so that in the case of 
submission of such data, the way that it is reviewed by authorities is harmonised across all 
MS. 

After the publication of the PEF rules or guidance, a transition period shall be provided, after 
which 3R type approval (and POM) of vehicles that are expected not to fulfil the 3R targets 
(3R Type Approval calculation) shall be conditioned with the submission of life cycle data that 
shows  that  such  materials  provide  significant  environmental  benefits  that  outweigh  their 
environmental costs. 

Type  approval  authorities  will  need to  critically  review  the  life  cycle  data  as  part  of  the  3R 
Type Approval process and to consider if it can be considered as sufficient justification for an 
approval. This should allow consideration of how vehicles placed on the market using non-
recyclable material may affect the achievement of targets when they become ELVs and are 
brought  for  treatment  to  an  ATF.  Vehicles  could  either  be  denied  market  access  (Type 
Approval) when the life cycle data does not support the finding that environmental benefits of 
the material outweigh its environmental costs. An alternative could also be to require OEMs 
to  take-back  such  fractions  and  ensure  their  reuse  or  recycling  as  a  condition  to  Type 
Approval. 

Expected outcome: A condition to the implementation of this measure is the development of 
a  method  for  preforming  comparisons  of  life  cycle  data  in  cases  where  there  are  non-
recyclables  that  hinder  achievement  of  the  reuse  and  recycling  targets.  In  this  sense,  any 
impacts that are to incur will only be expected after a transition period goes by that allows the 
development  of  such  a  methodology.  It  shall  probably  also  be  necessary  to  train  Type 
Approval  authorities  so  that  they  know  how  to  review  such  data  critically,  which  would  be 
essential for the measure to have an effect. Though it could be said that requiring OEMs to 
provide life cycle data in such cases could add to the burden of the type approval process, it 
can be understood that many OEMs already perform LCAs of their vehicles as a whole or of 
specific  components  for  internal  use.  In  this  sense,  it  is  assumed  that  developing  such 
ongoing efforts for use as part of the 3R Type Approval should be feasible. Furthermore, as 
the  measure  is  suggested  as  an  option  for  proving  the  benefits  of  using  non-recyclable 
materials  in  cases  that  could  otherwise  result  in  the  3R  Type  Approval  being  denied,  it  is 
assumed that OEMs would only make use of this option when they are convinced that the 
use of the material is indeed justified due to benefits it provides during use.     

2.1.5.1.6  2.1.f) Obligatory reporting requirements on the use 
of materials that affect dismantling and recyclability 
to facilitate identification of incompatible practices 

The presence of certain materials in shredded fractions can hinder the recycling of certain 
materials, limit the quality of recycled ones, or hinder the achievement of the 3R targets. The 
way that a part of a material is assembled in a component or in the vehicle also affects the 
potential for repair, reuse, and recycling. Obligations are thus to be included in the Directive 
to  promote  the  use  of  materials,  components  and  parts  that  facilitate  repair,  re-use, 
remanufacture  and/  or  recycling  and  to  discourage  the  use  of  those  that  hinder  such 
operations. It is observed that the use of a specific material and/or fastening technique in the 

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assembly of one component may be beneficial (or at least not harmful) but that it can hinder 
reuse  and  recycling  in  other  cases.  Thus,  rather  than  prohibiting  the  use  of  certain 
components,  materials  or  techniques,  the  focus  would  be  on  developing  a  feedback 
mechanism  that  ensures  that  information  on  how  certain  design  elements  affect  EoL  is 
communicated  and  integrated  into  the  design  process.  To  this  end,  feedback  is  to  be 
facilitated  both  between  different  departments  of  an  OEM  (designers  of  the  model  and  its 
components and those dealing with type approval or performing internal dismantling tests) 
and between OEMs and waste management operators. 

OEMs would be required to report every few years on:  

•  materials and fastening or assembly techniques that have been included in vehicle 

• 

• 

designs,  
the feedback mechanisms applied to raise awareness of waste management operators 
as to the need to apply certain methods or to use certain tools to achieve suitable 
dismantling of components for reuse or for separate (pre-shredder) recycling (e.g., 
training, provision for data as to material composition, method of dismantling etc. in IDIS 
or in similar platforms. 
the feedback mechanisms (internal and external) established to learn about the 
experience with such parts during the EoL phase (e.g., dismantling tests performed 
internally when a model is introduced to market or in relation with type approval as well 
as actual experience with vehicles at EoL),  

•  a summary of the input that has been collected through such feedback mechanisms in 

the reporting period and how these have been applied in decisions about vehicle design 
and use of certain materials or fastening and assembly technique. This should also 
include conclusions as to materials and assembly/fastening techniques that will no 
longer be used or that will only be applied when certain conditions apply. 

Expected outcome: This measure is expected to facilitate more feedback between the design 
and EoL stage of vehicles with a view to allowing quicker identification of methods that hinder 
reuse and recycling and those that do not. Though it can be assumed that some OEMs may 
be more advanced in such practices (at least internally or at regional level), input from waste 
management stakeholders suggests that for the most part, there is still insufficient exchange 
with waste operators. This refers both to cases where the latter conclude that certain materials 
or techniques hinder waste management but also cases where OEMs make efforts towards 
dismantling  to  which  waste  operators  remain  largely  unaware.  The  first  stages  of 
implementation  require  rather  to  establish  a  feedback  mechanism  that  allows  information 
flows  in  both  directions and  that  ensures that  information  is  used  to  improve  design  (or to 
improve EoL activities). Establishing such a system may not lead to benefits in the short term 
but is rather expected to allow progressive improvements, first mainly in communication but 
later  on  leading  to  design  changes  and  improved  reuse  and  recycling.  Routine  monitoring 
could  also  allow  development  of  guidance  on  best  practices  in the  future  or  practices that 
should be avoided.       

2.1.5.1.7  2.1.f) Obligatory reporting requirements on the use 
of materials that affect dismantling and recyclability 
to facilitate identification of incompatible practices 

The presence of certain materials in shredded fractions can hinder the recycling of certain 
materials, limit the quality of recycled ones, or hinder the achievement of the 3R targets. The 
way that a part of a material is assembled in a component or in the vehicle also affects the 
potential for repair, reuse, and recycling. Obligations are thus to be included in the Directive 
to  promote  the  use  of  materials,  components  and  parts  that  facilitate  repair,  re-use, 

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remanufacture  and/  or  recycling  and  to  discourage  the  use  of  those  that  hinder  such 
operations. It is observed that the use of a specific material and/or fastening technique in the 
assembly of one component may be beneficial (or at least not harmful) but that it can hinder 
reuse  and  recycling  in  other  cases.  Thus,  rather  than  prohibiting  the  use  of  certain 
components,  materials  or  techniques,  the  focus  would  be  on  developing  a  feedback 
mechanism  that  ensures  that  information  on  how  certain  design  elements  affect  EoL  is 
communicated  and  integrated  into  the  design  process.  To  this  end,  feedback  is  to  be 
facilitated  both  between  different  departments  of  an  OEM  (designers  of  the  model  and  its 
components and those dealing with type approval or performing internal dismantling tests) 
and between OEMs and waste management operators. 

OEMs would be required to report every few years on:  

•  materials and fastening or assembly techniques that have been included in vehicle 

• 

• 

designs,  
the feedback mechanisms applied to raise awareness of waste management operators 
as to the need to apply certain methods or to use certain tools to achieve suitable 
dismantling of components for reuse or for separate (pre-shredder) recycling (e.g., 
training, provision for data as to material composition, method of dismantling etc. in IDIS 
or in similar platforms. 
the feedback mechanisms (internal and external) established to learn about the 
experience with such parts during the EoL phase (e.g., dismantling tests performed 
internally when a model is introduced to market or in relation with type approval as well 
as actual experience with vehicles at EoL),  

•  a summary of the input that has been collected through such feedback mechanisms in 

the reporting period and how these have been applied in decisions about vehicle design 
and use of certain materials or fastening and assembly technique. This should also 
include conclusions as to materials and assembly/fastening techniques that will no 
longer be used or that will only be applied when certain conditions apply. 

Expected outcome: This measure is expected to facilitate more feedback between the design 
and EoL stage of vehicles with a view to allowing quicker identification of methods that hinder 
reuse and recycling and those that do not. Though it can be assumed that some OEMs may 
be more advanced in such practices (at least internally or at regional level), input from waste 
management stakeholders suggests that for the most part, there is still insufficient exchange 
with waste operators. This refers both to cases where the latter conclude that certain materials 
or techniques hinder waste management but also cases where OEMs make efforts towards 
dismantling  to  which  waste  operators  remain  largely  unaware.  The  first  stages  of 
implementation  require  rather  to  establish  a  feedback  mechanism  that  allows  information 
flows  in  both  directions and  that  ensures that  information  is  used  to  improve  design  (or to 
improve EoL activities). Establishing such a system may not lead to benefits in the short term 
but is rather expected to allow progressive improvements, first mainly in communication but 
later  on  leading  to  design  changes  and  improved  reuse  and  recycling.  Routine  monitoring 
could  also  allow  development  of  guidance  on  best  practices  in the  future  or  practices that 
should be avoided. 

2.1.5.1.8  2.1.g)  Establishment  of  mandatory 

recycled 

content targets for materials used in cars  

Provisions  are  to  be  included  in  the  future  legislation  of  3R  for  specific  materials  used  in 
vehicles  requiring  that  a  minimum  share  of  the  material  used  is  of  secondary  sources. 
Requirements shall be specified per material as a recycled content target to be reached within 
a given timeframe and could also refer additional parameters to be complied with such as the 

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origin of secondary materials (e.g., pre-consumer vs. post-consumer; ELVs vs. other end-of-
life product streams).   

Mandatory recycled content targets under consideration include:  

• 

• 

• 

targets for plastic (scenarios developed by JRC (Maury et al. 2022) and considered in the 
analysis performed in this study: 
o  Mandatory targets for OEMs to declare on plastic recycled content in vehicles POM, 
o  Mandatory targets of plastic recycled content contained in vehicles POM: 

  Achieving 25% recycled content by 2030 and 30% by 2035… 
  Achieving 30% recycled content by 2030 and 35% by 2035… 

target for neodymium magnets and possibly other CRMs : here a limiting factor is the time 
needed for collection and recycling to establish a reliable supply as secondary materials 
for use in vehicles. A target could be considered in the long term (e.g., within 10 years) 
and will probably need to start low and increase gradually. Targets could address a certain 
element (e.g., neodymium) of NdFeB magnets or the use of recycled magnets. This may 
also depend on how recycling practices will develop. This is being looked into by a further 
JRC study to be completed at the beginning of 2023. 
In addition, targets for CRMs gallium, magnesium, tantalum may still be explored in future 
studies.  

•  A  target  for  glass  could  be  considered  in  the  future,  if  the  effect  of  other  measures 
designed  to  promote  high  quality  recycling  of  glass  is  insufficient  (e.g.,  excluding 
backfilling  form  recycling,  obligations  for  ATFs  to  dismantle  glass  prior  to  shredding 
operations,  recycling  target  for  glass).  Furthermore,  though  a  recycled  content  target 
might affect the quality of glass recycling, its investigations would probably require more 
data to conclude on technical feasibility than is currently available. In this respect, a review 
clause could be included in this provision, requiring an investigation on the recycling of 
glass  and  the  use  of  recycled  glass  in  the  manufacture  of  new  vehicles.  Should  this 
investigation show that there is room to further support the demand of recycled glass, a 
target could be added in the future. 

•  A similar situation is apparent for tyres. High quality recycling is currently understood to 
be the exception rather than the norm, whereas it is expected that the recycling of rubber 
form tyres will develop significantly in the coming years. Here too, an investigation would 
require  more  data  to  conclude  on  technical  feasibility  than  is  currently  available.  The 
option should be reconsidered in the future. 

2.1.5.1.9  2.1.h) Obligatory due diligence for materials used 

in vehicles 

The manufacture of vehicles and vehicle components makes use of numerous materials of 
both primary and secondary nature. Some of these are sourced from countries (outside the 
EU)  where  the  local  governing  conditions  and/or  the  level  of  performance  of  mining  and 
processing  facilities  may  not  ensure  the  provision  of  human  rights,  the  health  of  workers 
and/or of nearby residents, or the prevention of adverse impacts on the environment. Where 
the manufacture of vehicles has a high dependency on material sourcing from such countries, 
this can contribute to adverse impacts on society and on human health and the environmental. 
To prevent such impacts, vehicle manufacturers could be required to perform due diligence 
when sourcing materials to produce vehicles and their components from high- risk countries. 
This can be related either to primary materials that are sourced from conflict-affected or high-
risk areas or to secondary materials sourced from countries that do not ensure a minimum 
level of environmental performance and/or of minimum social working conditions.  

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At horizontal level, in relation to the sourcing of minerals from conflict-affected or high-risk 
areas, Regulation 2017/821/EU lays down supply chain due diligence obligations for Union 
importers of tin, tantalum and tungsten, their ores, and gold originating from such areas. The 
sourcing  of  e.g.,  tin,  tungsten,  tantalum,  niobium  and  gold  minerals  and metals  for  vehicle 
manufacture  would  be  addressed  through  this  Regulation,  making  an  ELV  obligation 
redundant. 

In some cases, there may be other materials used in vehicles sourced from countries that do 
not ensure that the sourcing and processing of such materials is environmentally and socially 
sound. For such cases, due diligence obligations could be included in the Directive, similar to 
those currently proposed for the new regulatory framework for batteries. This would include 
a  provision,  laying  down  obligations  for  OEMs  to  perform  due  diligence  on  the  supply  of 
certain materials (primary and secondary), and to declare on the risk of occurrence of adverse 
impacts and on strategies for their mitigation. Declarations on such actions, including third 
party verification would need to be made available to authorities as part of the type-approval 
process and for MS inspections. A list of materials (e.g., REE) for which this is to be obligatory 
would be included in the future legislation for vehicles, also specifying thresholds for each 
material  as  to  the  amount  of  use  contained  in  a  vehicle  above  which  the  obligation  would 
comply.  The  annex  would  be  updated  continuously,  in  relation  to  the  thresholds  and  if 
necessary, also as to the materials specified therein.  

There is also a need to consider the requirements set out in the Corporate Sustainability Due 
Diligence Directive. The CSDD is a horizontal legislation that focusses more generally on the 
behaviour of companies and addresses the entire value chain for all goods and services. It 
will  implement  the  due  diligence  requirements  of  the  proposed  Batteries  regulation  by 
introducing a value chain due diligence related to raw materials (and goods and services) that 
are not covered in the Batteries Regulation. Both build on the OECD due diligence guidance, 
making implementation coherent.  

Expected outcome: It is currently not clear which materials could be addressed through a due 
diligence obligation to be included in the future ELV legislation. Materials addressed under 
other legislation (or in focus of future sectoral legislation such as the Batteries Regulation) 
are not used in large amounts in vehicles.  

In parallel, the European Commission has published a tender90 to review the functioning of 
Regulation 2017/821/EU, which towards 2026 could both lead to adaptations in future due 
diligence requirements as well as in the materials for which such requirements are necessary.  

2.1.5.1.10  2.1.i)  Set  out  an  obligation  for  OEMS  to  provide 

additional information on composition of cars 

The availability of information or lack thereof plays a large role in the decisions of ATFs as to 
the waste management of vehicles. Easy access to data on the location of certain materials 
and substances or as to how certain components can be dismantled efficiently so that the 
component can be reused, often tip the decision if to remove certain parts or to send them 
with the rest of the vehicles for shredding and PST. Two alternatives are under consideration 
as to how to ensure the accessibility of data to waste management operators. 

90 Call for tenders TRADE/2022/OP/0001 “Study to review the functioning and effectiveness of Regulation (EU) 2017/821 (due 
diligence obligations for importers of tin, tantalum, tungsten and gold from conflict-affected and high-risk areas” 

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•  Alternative 1: As has been the approach of the current ELVD, the future legislation for 

ELVs or the future 3R legislation will specify for which types of information it is obligatory 
for OEMS to provide data and will include elements as to the harmonisation of the 
format in which data is to be provided. This will leave open to OEMs to decide how the 
information is to be provided to waste operators (e.g., elaboration of IDIS, access upon 
request to systems that currently use other stakeholders (IMDS, RMI) or development 
and access to new systems). Information to be made accessible to EPRs shall be 
submitted as part of the 3R Type approval process or to the EPR directly.  

•  Alternative 2: All relevant information shall be submitted by OEMs and their suppliers to 
a digital product passport for vehicles and made accessible to relevant actors (e.g., 
3R Type approval authorities, EPR schemes, ATFs). Here the format is predetermined 
leaving less room for OEMs to decide what method of data provision is the most 
appropriate to comply with requirements while limiting the burden thereof. 

Since  vehicles  have  a  relatively  long  lifecycle,  providing  information  retroactively  for  cars 
already on the market, will be important to ensure that provisions related to e.g., dismantling, 
lead to benefits in the low and mid-term. It is not clear if such requirements could be included 
for older vehicles (for example the 3R directive only applies to new vehicles) but this should 
be investigated. The ELVD currently includes Article 8(4)91, which is understood to require 
manufacturers  to  provide  ATFs  with  information  to  support  reuse,  regardless  of  a  vehicle 
being new or not. It is thus to be seen if such requirements could be included in the future 
legislation of ELVs, for example as part of EPR obligations. 

In  both  cases,  the  type  of  information  to  be  made  accessible  and  any  minimal  format 
requirements on its provision will affect both the cost of the preparation and submission of 
data for OEMs and its usability by ATFs, subsequently determining the range of impacts that 
increased  data  availability  will  have  for  the  ELV  waste  sector.  The  following  types  of 
information shall be considered for inclusion in any provisions on the obligatory provision of 
data: 

•  dismantling time and dismantling method of components with potential for reuse and/or 
remanufacturing (delegated act defining the scope), shall be provided free of cost and in 
a harmonised way (see section 2.1.5.3.6 for preliminary list), 

•  dismantling  time  and  dismantling  method  of  components  with  for  which  there  are 
depollution obligations (Annex I (4)) shall be provided free of cost and in a harmonised 
way  

•  dismantling time and dismantling method of components which are obligatory to dismantle 
(e.g., current Annex to the ELVD, possibly to be amended e.g., by a delegated act) for 
promoting reuse and/or recycling shall be provided free of cost and in a harmonised way. 
Components shall be referred to (see section 2.1.5.3.62.1.5.4.2 for preliminary lists) that 
have  a  high  potential  for  reuse  but  also  a  higher  value  when  recycled  separately, 
including:  
o  components that contain a minimum mass of certain materials for which removal prior 

to shredder enables higher quality recycling (e.g., aluminium, copper, glass), 

o  components  for  which  separate  treatment  of  sorted  fractions  will  allow  targeting 
materials  that  it  is  not  economically  feasible  to  target  in  PST  (e.g.,  electric  and 
electronic components and printed circuit boards, tyres), 

91 4. ELVD, Art. 8(4): “Without prejudice to commercial and industrial confidentiality, Member States shall take the necessary 
measures to ensure that manufacturers of components used in vehicles make available to authorised treatment facilities, as 
far as it is requested by these facilities, appropriate information concerning dismantling, storage and testing of components 
which can be reused”. 

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o  components containing materials that cannot be recycled at the time placed on the 
market (e.g., carbon enforced plastics, composites) – could be facilitated through a 
reference to TRL < 9. 

•  digital keys, also referred to as “Smart Access Control solution” and information as to the 
dismantling  method  for  components  using  digital  keys  shall  be  provided  through  a 
reasonable procedure, at a reasonable price and in a harmonised way.     
information on the substance content of any component shall be made accessible free of 
cost  and  in  a  harmonised  way,  for  any  substance  or  material  that  was  suspected  or 
identified as a hazardous substance or that was on the EU list of critical raw materials at 
the time of the type approval of the vehicle.  

• 

The future legislation for ELVs shall include a provision specifying for what types of data it is 
obligatory for OEMs to provide information and specifying any additional obligations in terms 
of the  systems  used to provide  data  and minimum requirements  as to  the  format  in  which 
data is to be provided.  

It is possible that for some types of data, the ratio of costs and benefits of various actors may 
be uncertain in the analysis to be performed in this impact assessment and also that this ratio 
may change in the future in light of developments in the design and waste management of 
vehicles.  There  should  therefore  be  an  option  to  update  the  list  of  data  to  be  provided.  In 
some cases, the provision may also refer to voluntary provision of certain data types, requiring 
the  Commission  to  revisit  the  decision  within  a  certain  period,  to  reconsider  whether  an 
obligatory  provision  would  increase  environmental  benefits  or  lead  to  more  efficient  waste 
management (e.g., reducing the height of necessary EPR compensations). 

Expected outcome: Much of the information referred to above is already collected by OEMs 
for their own use or for provision to car dealers and/or ATFs. In some cases, information is 
provided for a fee, in others it is provided freely to certain actors or not at all. The main difficulty 
in the current situation is related to certain data not always being accessible to ATFs which 
could facilitate an increase in reuse or recycling were the data available. In some cases, this 
is a result of a lack of harmonisation or of certain actors not making use of platforms already 
available. In any case the measure will target an increase in the effectiveness of the existing 
mechanisms. Though this is expected to result in costs for OEMs and benefits for actors that 
would have access to data, the starting point is not at zero but rather at a point where OEMs 
already collect and compile data (at a cost), considering how to manage its availability.   

2.1.5.2  Measures  to  achieve  specific  objective  2.2:  Ensure 
elimination of hazardous substances in vehicles 

2.1.5.2.1  2.2.a): Restriction of substances in vehicles 

This  measure  deals  with  defining  the means  to  generate  specific  limitations/restrictions  on 
substances  used  in  vehicles.  The  expected  mechanism  should  be  able  to  deal  with  the 
existing restrictions of the four heavy metals as well as with the exemption mechanism. At the 
same time, it should cover the restriction of additional substances.  

The  objective  of  this  measure  is  to  provide  legal  certainty  about  the  currently  restricted 
substances and their exemption, and the procedure for future substance restrictions and the 
exemptions mechanism.  

Furthermore, it should allow to restrict further substances in vehicles. This is relevant against 
the background that there is a general increase in the use of plastics, for example, due to its 
advantages for vehicles in terms of weight reduction. However, the use of plastics also raises 
concern as to the presence of hazardous chemical additives in such materials and with regard 

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to the question as to how far this can pose technical difficulties for their recovery. Concerns 
on additives also apply to other materials such as rubber or textiles, though possibly used in 
lower amounts in these materials. This suggests that there may be a need to regulate the 
presence of additional hazardous substances that are used in vehicles, aside from the four 
heavy metals currently prohibited, e.g., certain flame retardants, plasticisers or surface-active 
agents such as PFAS. 

Three variants of this measure can be distinguished, these shall be treated as policy options. 
Thus, the detailed description of the measures can be found in the description of the policy 
options in chapter 3.1.4.8.2. For this measure, three alternative policy options are:  

POLICY OPTION 1A – RESTRICTIONS AND EXEMPTIONS UNDER REACH 

POLICY OPTION 1B – RESTRICTIONS AND EXEMPTIONS UNDER REVIEWED ELVD 

POLICY OPTION 1C – HYBRID APPROACH 

2.1.5.2.2  2.2.b:  Improved  communication  on  hazardous 
substances in the automotive value chain  

This  measure  addresses  the  communication  needs  at  the  end  of  life  of  vehicles  on  the 
hazardous  substances  to  allow  improved  reuse  and  recycling  by  sorting  (out).  An 
improvement in the communication on hazardous substances in the automotive value chain 
would  also  contribute  to  the  elimination  of  hazardous  substances  in  material  fractions 
generated  by  the  ELV  waste  management  sector.  There  are  information  systems  in  place 
covering the details on material composition, however, the missing element is the availability 
of the information at waste treatment facilities on the one hand side, and the information for 
dismantling on the other side. Thus, there is a need for additional dismantling information for 
recyclers in addition to the current information provided by SCIP or GADSL in IMDS.  

This proposed measure is to introduce an obligation – to be added to the ELVD – that the 
information on the content of substances with hazardous classifications or substances under 
assessment for classification needs to be documented along the value chain. Should a need 
for depollution arise, the information on the content of hazardous substances would need to 
be made available to treatment facilities in a way that the information is linked to  

•  single parts/components,  
• 

the location of the parts/components in the vehicle combined with dismantling information 
and  
to safe use instructions for dismantling and recycling processes.  

• 

This  communication  would  enable  the  dismantling  prior  to  shredder,  combined  with 
subsequent decisions on whether to sort out components or materials, from the material flow, 
for disposal due to their content of hazardous substances (as is the case for parts containing 
the POP decaBDE) or to sort out such components or materials to allow their diversion to 
specific  treatment  that  allows  controlling  the  content  of  hazardous  substances  (e.g., 
separating  aluminium  wrought  and  cast  alloys)  or  eliminating  it  from  the  general  material 
stream.  

The  improved  communication  could  be  envisaged  according  to  three  possible  information 
schemes:  

•  Via  the  SCIP  database as  a  centralised  European  Database:  The  SCIP  database  was 
recently established to collect information from companies on the contents of Substances 
of very High Concern of the REACH Candidate list in articles supplied to the EU market. 
These notification requirements under the SCIP database for SVHC comprise a current 
obligation and can be considered as the baseline.  

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• 

In order to serve as a measure on improved communication, the SCIP database would 
need further development and adaptations. 

•  Via  an  industry-driven  system,  e.g.,  based  on  GADSL/IMDS:  The  Global  Automotive 
Declarable  Substance  List  (GADSL)  was  developed  to  facilitate  communication  and 
exchange of information regarding the use of certain substances in automotive products 
throughout  the  supply  chain.  The  list  only  covers  substances  that  are  expected  to  be 
present in a material or part that remains in a vehicle at the point of sale. The GADSL 
specifies  not  only  substances  that  are  prohibited,  but  also  substances  that  are  under 
assessment and could potentially be regulated in the future. In this sense, the GADSL 
covers substances beyond those, for which the use is to be notified to the SCIP database. 
In order to serve as a measure on improved communication, the GADSL/IMDS would also 
need further development and adaptations. 

• 

•  Via a Digital Product Passport (DPP), which is most likely based on a decentralised IT 
architecture,  as  defined  in  the  Proposal  for  a  Regulation  establishing  a  framework  for 
setting  Ecodesign  requirements  for  Sustainable  Products92  (ESPR).  The  information 
requirement  on  substances  of  concern93  is  depicted  in  the  text  box  below.  The 
information  might  be  made  available  via  different  manners.94  Due  to  the  complex 
composition of vehicles, a DPP or an access to the information via the VIN number on a 
website  or  an  application  seems  to  be  the  most  appropriate  form  of  communication. 
However, a concrete development is still underway and so far not in place.  

Proposal for a Regulation establishing a framework for setting Ecodesign requirements for 
Sustainable Products (ESPR): 

Article 7 Information requirements 

[…] 

5.  The  information  requirements  referred  to  in  paragraph  1  shall  enable  the  tracking  of  all 
substances of concern throughout the life cycle of products, unless such tracking is already 
enabled  by  another  delegated  act  adopted  pursuant  to  Article  4  covering  the  products 
concerned, and shall include at least the following: 

(a) the name of the substances of concern present in the product; 

(b) the location of the substances of concern within the product; 

(c) the concentration, maximum concentration or concentration range of the substances of 
concern, at the level of the product, its main components, or spare parts; 

(d) relevant instructions for the safe use of the product; 

(e) information relevant for disassembly. 

92   COM(2022) 142 final 

93  

94  

https://ec.europa.eu/info/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-
requirements/sustainable-products/ecodesign-sustainable-products_en  

The recent Proposal for a Regulation establishing a framework for setting ecodesign requirements for sustainable 
products introduces an additional criterion for substances of concern if a substance “negatively affects the re-use and 
recycling of materials in the product in which it is present.” (COM(2022) 142 final)  

The following are mentioned in Article 7: (a) on the product itself; (b) on the product’s packaging; (c) in the product 
passport referred to in Article 8; (d) on a label referred to in Article 14; (e) in a user manual; (f) on a free access website 
or application.  

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2.1.5.3  Measures to achieve specific objective 2.3: Increase the 
rates  of  parts  and 
remanufacturing 
re-use  and 
components contained in cars    

The  ELV  Directive  contains  general  provisions  which  prioritise  reuse  and  recycling  over 
recovery and disposal. Such objectives are in line with the circular economy model that aims 
to maximise the reduction of waste and reuse of materials. However, the evaluation results95 
raised the need to better align the ELV Directive with the objectives of the European Green 
Deal  and  the  Circular  Economy  Action  Plan.  In  this  respect,  the  ELV  Directive  does  not 
sufficiently address waste prevention routes such as reuse, including eco-design of cars to 
facilitate re-use, repair and remanufacturing. The potential to increase re-use is not realised.  

The following described measures thus aim to facilitate re-use and remanufacturing. 

2.1.5.3.1  2.3.a)  Clarify  definition  of  re-use  in  the  ELV 
Directive vs re-use and preparing for re-use in the 
Waste Framework Directive  

Under Article 2(6) of the ELV Directive ‘reuse’ means any operation by which components of 
end-of life vehicles are used for the same purpose for which they were conceived.  

The Waste Framework Directive96 (Article 3(13)) adopts a different approach:  

‘re-use’ means any operation by which products or components that are not waste are used 

again for the same purpose for which they were conceived.  

Therefore, the WFD includes a definition for “Preparing for re-use” (see below) which is also 
included in the waste hierarchy (Article 4 of the WFD). According to Article 3(16) of WFD:  

‘preparing for re-use’ means checking, cleaning or repairing recovery operations, by which 

products or components of products that have become waste are prepared so that they can 
be re-used without any other pre-processing.  

This term does not appear in the ELV Directive. Components of a vehicle that has reached 
the waste phase (became an ELV) can be used for reuse. There is a lack of clear definition 
on the status of these components as if they shall be considered as waste or not. If yes, the 
definition of “reuse” according to ELVD is not aligned with the WFD, thus the components 
that have reached the waste phase can be used for reuse, whereas in the WFD this is enabled 
through their “preparing for reuse”. Components that are considered as waste, their shipment 
for  re-use  or  remanufacturing  is  more  challenging  (e.g.,  higher  transport  costs,  higher 
administrative burden). 

Additionally,  the  “reuse”  definition  in  the  ELVD  as  well  as  in  the  WFD  clearly  define  that 
component meant for reuse shall be used again for the same purpose for which they were 
conceived.  This  excludes  remanufacturing  in  some  manner  (please  refer  to  the  following 
section 2.1.5.3.2). 

In practice, vehicle components can be removed for re-use from the vehicle: 

95 Commission staff working document evaluation of Directive (EC) 2000/53 of 18 September 2000 on end-of-life vehicles, 
SWD(2021), European Commission, 2021 

96 Consolidated text: Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on waste and 
repealing certain Directives (02008L0098 — EN — 05.07.2018 — 003.002) 

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•  During the use phase:  

o 

o  Parts are removed either in a garage or by a private person and are directly installed 
in another vehicle. In this case they do not reach the waste stage. Assuming that the 
used parts are used for the same purpose for which they were designed. 
In other cases, a broken component is removed from a vehicle that is in use and this 
product is shipped by a garage to an operator (remanufacturer) that tests and pre-
processes the component as necessary97 so that it can be sold as a used or 
remanufactured component (for description of the remanufacturing process see 
2.1.5.3.1). It is assumed that at least in most cases these components will be re-
used for the same purpose for which they were initially designed (e.g., an engine is 
reused as an engine, though maybe in a different model).   
In the case of faulty parts that are tested and pre-processed, some parts could also 
be used for other purposes than those for which they were designed. This is the 
case of EV batteries, where it is not clear of “second use” as an energy storage 
system would be in line with the WFD definitions. Should there be similar situation 
for other parts, the situation may need to be clarified. 

o 

•  During the end-of-life stage: parts are removed at an ATF from an ELV, meaning that 

they reached the waste stage. These ELV components are collected in the ATF’s scrap 
yard and can be sold to private persons, to an economic operator (repair shop) for reuse 
or for remanufacturing (see Section 2.1.5.3.2).  

In  the  frame  of  ongoing  impact  assessment  of  WFD,  the  adjustment  of  the  definitions  on 
“reuse”  and  “preparing  for  reuse”  as  well  as  introduction  of  “remanufacturing”  in  this  legal 
document are under consideration. Thus, it is to consider align all these definitions in both 
legal acts. Nevertheless, aligned existing and new definitions require clear definition, so that 
components for reuse and remanufacturing:  

•  do not reach the waste stage; 
•  do  not  necessarily  need  to  be  used  for  the  same  purpose  for  which  they  were  initially 

designed (after remanufacturing). 

Thus,  components  removed  from  the  ELVs  would  be  classified  as  waste  by  introducing  a 
provision specifying that “the ELV components (products and core) shipped for re-use and 
remanufacturing shall not be considered as waste to avoid obstacles with their national and 
trans-national shipments”. Moreover, these components might be used for other purpose for 
which they were conceived. 

Additionally, it is suggested to assess the possibility to introduce a special customs code for 
re-used  and/or  remanufactured  goods,  so  as  to  remove  trade  barriers  and  improve  global 
movement of remanufactured and directly reused vehicle components. 

Expected  outcome:  Clarity  on  the  status  of  removed  components  from  the  vehicle  will 
facilitate their transport for reuse and remanufacturing by limiting administrative burdens of 
their shipment (also trans-national). It is expected that more components will be reused or 
remanufactured as well as their service life being extended. 

2.1.5.3.2  2.3.b) Introduce a definition of remanufacturing and 

specific provisions to support remanufacturing  

Remanufacturing is a manufacturing process which typically involves:  

97 This process is called remanufacturing in a number of studies and technical documents. So far, a definition of such 
processes does not exist in the EU legislation. More under the following measure. 

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•  dismantling of a product,  
•  cleaning, restoring and replacing its components as necessary,  
• 

testing the individual parts and the whole product.  

The  product  obtained  after  remanufacturing  is  expected  to  have  at  least  the  same 
performance as the original performance specification (like-new) or better. Additionally, the 
remanufactured product usually comes with a warranty. 

There  exist  numerous  definitions  of  remanufacturing,  inter  alia,  widely  recognised,  is  a 
definition  provided  by  the  British  Standards  Institution’s  BS  8887-2:2009  Terming  and 
Definitions,  as  part  of the  ‘MADE’  series  of  standards (Design for Manufacture,  Assembly, 
that 
Disassembly  and  End-of-life  processing).  The  BS  8887-2  definition  states 
remanufacturing is the process of:  

Returning a product to at least its original performance with a warranty that is equivalent or 

better than that of the newly manufactured product.  

This definition is accompanied with further notes: 

Note 1. From a customer viewpoint, the remanufactured product can be considered to be the 

same as the new product. 

Note 2. Remanufacturing may not use repaired or reconditioned parts.  

Note 3. With respect to remanufacture: 

- manufacturing effort involves dismantling the product, the restoration and replacement of 

components and testing of the individual parts and whole product to ensure that it is within 
its original design specifications; 

- performance after remanufacturing is expected to be at least to the original performance 

specification; and 

- any subsequent warranty is generally at least equal to that of new product. 

The remanufacturing process is applied in many industrial sectors, inter alia, automotive parts 
such as car engines and components. Both terminology and practice in this area may differ 
slightly between products and sectors. It has been observed that the lack of a definition may 
result in barriers to international trade, as products and core98 are sometimes considered as 
waste, rather than potentially high value input into a (re-) manufacturing process99. 

In 2016, six leading associations100 that are part of the automotive production sector reached 
a  common  understanding  as  to  basic  definitions  associated  with  their  industry.  The 
associations have converged on the following definitions101:  

98 A used part intended to become a remanufactured product 

99 Remanufacturing Market Study, A report by the partners of European Remanufacturing Network (ERN), November 2015 

100 The European Association of Automotive Suppliers (CLEPA), Motor & Equipment Remanufacturers Association (MERA), 
Automotive Parts Remanufacturers Association (APRA), Automotive Parts Remanufacturers National Association (ANRAP), 
European Organisation for the Engine Remanufacture (FIRM) and Remanufacture Committee of China Association of 
Automobile Manufactures (CPRA) 

101 Remanufacturing Associations Agree on International Industry Definition, International agreement an important milestone in 
further development of a growing industry, Frankfurt, September 2016  

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Remanufacturing process: Remanufacturing is a standardized industrial process102 by which 

cores are returned to same-as-new, or better, condition and performance. The process is in 
line with specific technical specifications, including engineering, quality and testing 
standards. The process yields fully warranted products. 

Core: A core is a previously sold, worn or non-functional product or part, intended for the 
remanufacturing process. During reverse logistics, a core is protected, handled and 
identified for remanufacturing to avoid damage and to preserve its value. A core is not 
waste or scrap and is not intended to be reused before remanufacturing. 

In addition, European associations had previously agreed to the following definition applicable in 

Europe: 

Remanufactured part: A remanufactured part fulfils a function which is at least equivalent 
compared to the original part. It is restored from an existing part (CORE), using 
standardized industrial processes in line with specific technical specifications. A 
remanufactured part is given the same warranty as a new part, and it clearly identifies the 
part as a remanufactured part and states the remanufacturer. 

Currently,  a  new  ISO  “Technical  product  documentation  —  Design  for  manufacturing, 
assembling,  disassembling  and  end-of-life  processing  —  Part  2:  Vocabulary”103  is  under 
development.  It  is  planned  that  remanufacturing  definitions  will  also  be  addressed  in  this 
document.   

The above clarifies that there are different options for the definition of remanufacturing and 
also processes underway to harmonise the definitions used by various actors. To support the 
practice  of  remanufacturing.  The  Commission  should  introduce  a  definition  into  the  legal 
regulations.  Ideally,  this  definition  should  be  in  the  line  with  ISO  standards  and  definitions 
converged by the automotive sector. As a minimum, the definition should refer to the general 
process  steps  that  remanufacturing  can  include  and  to  minimum  warranty  needing  to  be 
identical to that of a new part.  

the  remanufacturing  process:  The 

At  present,  components  removed  from  ELV  could  be  classified  as  waste,  adding  to  the 
administrative  burden  of 
legal  ambiguity  over 
remanufacturing varies among different jurisdictions particularly around shipment of products 
and cores considering them as waste, rather than as potentially high value inputs into a (re-
)manufacturing process. The transport of waste is significantly costlier and more restrictive 
(or in some cases even prohibited). Changes are necessary in EU regulation to recognize 
the differences between cores and waste, thus: the ELV components (products and core) 
shipped for remanufacturing104 shall not be considered as waste to avoid obstacles with their 
trans-national shipments.   

The  future  legislation  of  ELVDs  is  to  introduce  provisions  to  facilitate  the  dismantling, 
appropriate sorting at the source, packaging, labelling (for reuse and remanufacturing) and 
transport of used components intended for this practice. For this purpose:  

•  Article 8 is to be amended, requiring OEMs to provide ATFs with information on how to 
remove components with a high reuse and remanufacturing value from the vehicle without 
damage  to  the  component.  Article  6  will  be  amended  to  oblige  ATFs  to  ensure  the 

102 An industrial process is an established process, which is fully documented, and capable to fulfil the requirements 
established by the remanufacturer. 

103 ISO/DIS 8887-2 Technical product documentation — Design for manufacturing, assembling, disassembling and end-of-life 
processing — Part 2: Vocabulary 

104 Intended to become a remanufacture product 

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appropriate  packaging,  labelling  and  transport  of  any  components  targeted  for 
remanufacturing processes, 

•  A list of components with high potential for re-use and remanufacturing is to be introduced 
into  Annex  I  (or  an  alternative  legal  communication)  and  referred  to  in  any  obligations 
related to provision of data on the dismantling of parts (more about this under 2.1.5.3.6).  

These  provisions  shall  be  aligned  if  needed  with  requirements  for  the  classification  of 
components according to new definitions in ELVD and WFD and with respective requirements 
of the Shipment Regulation.  

The  amended  ELVD  shall  also  allow  monitoring  the  type  and  share  of  used  or 
remanufactured  components.  This  obligation  will  be  introduced  into  Article  9  and  into 
respective  legal  documents  (on  the  reporting  methodology)  requiring  MS  to  report  on  the 
extent of reuse and remanufacturing in their Member State. This is to be facilitated through 
the general requirements for ATFs to report on components dismantled and sent for reuse as 
parts or to remanufacturers. The provision is to be combined with the reporting on ‘direct re-
use’ and ‘overall re-use’ of vehicles’ components (more about this under 2.1.5.3.6). 

Specific provisions shall support use of reused and remanufactured components either in 
the repair of vehicles instead of newly manufactured parts or in the construction of new (or 
remanufactured) vehicles. There are further issues with use of remanufactured parts:  

1. that the terms and definitions of remanufactured parts should be included in the 3R Type-
approval Directive if it remains an independent Directive, and  

2. that a new category of vehicle – ‘remanufactured’105 in addition to ‘new’ and ‘used’ – may 
need to be considered together with their definitions.  

However, as shared by a car manufacturer representative, the current legal definition of a 
new product does not allow inclusion of remanufactured parts. This means that legally, at 
present a new vehicle may not contain remanufactured elements; the entire vehicle must be 
made from new components, though these can use recycled materials. This legal issue is not 
specific to vehicles. This legal limitation restricts the sale of remanufactured vehicle parts to 
the repairs market. 

On the other hand, from a technical perspective, remanufactured vehicle parts are certified 
as  equivalent  in  functionality  and  reliability/safety/etc.  to  new  parts  and  could  therefore  be 
acceptable for use in new vehicles.  

The other challenge is that there is a limited feedstock of remanufactured parts because of 
the  long  vehicle  lifetime  meaning  that  the  current  ELVs  do  not  offer  many  parts  for 
remanufacture. 

For electric vehicles (EVs), the motor and batteries often have longer lifetimes than the vehicle 
itself, while the technology of other components and materials is still evolving. However, for 
EVs, even though the motors may be recovered (since 2013), they cannot easily be installed 
in  new  vehicles  because  of  developments  in  weight,  size  and  power.  EV  batteries  from 
Renault  are  already  in  their  third  generation  and  upgrading  an  older  vehicle  with  newer 

105 The consultants are not aware of references to “remanufactured vehicles”. This concept exists for EEE, such as refurbished 
electric devices (e.g., mobile phones, computers) but also medical devices and electron microscopes that, like vehicles, are 
complex devices with long design phases. Though one could say that a used vehicle repaired with remanufactured parts 
could be considered to adhere to this concept, in the refurbishment of medical devices, equipment would be considered as 
such when not just remanufactured parts have been used to repair faulty ones, but when the responsible economic operator 
has checked the vehicle for functionality and ensured that any repairs or updating of software has been carried out to ensure 
that it is “as good as new” in terms of functionality and thus also in terms of warranty. This concept is thus considered to be 
different from a standard used vehicle and to have additional advantages for the consumer. 

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technology (e.g., a newer battery) raises type-approval issues and requires other parts to be 
exchanged. 

In the latter issue, the proposed new category ‘remanufactured vehicle’ would have a different 
pricing scheme from the other categories. And then another issue would arise with how to 
handle vehicles that are primarily new except for a remanufactured engine, i.e., only one or 
few remanufactured parts.  

The demand for a ‘remanufactured’ category could be investigated and then the legal and 
technical issues would need to be discussed and resolved. Overall, the issue of how to more 
broadly use and encourage remanufactured vehicle parts is seen as stemming from restrictive 
legal definitions. Since in some countries it might not be allowed to use spare parts in the 
construction of new vehicles, the provision shall consider that fact.  

The  other  burden  in  use  of  remanufactured/used  components  to  repair  damaged  vehicles 
(barely new one) is warranty issue. For some Member State, the role of vehicle warranties 
that is given by the OEM or by the economic operator that places the new vehicles on the 
market is not fully document. Based on the feedback from stakeholder during the workshop, 
the  warranty  might  be  declined  or  shortened  once  damaged  vehicle  is  fixed  with 
used/remanufactured component.  

Expected  outcome:  Introducing  correct  definition  will  promote  remanufacturing  and  help 
distinguish  it  from  practices  that  do  not  achieve  a  minimum  quality.  Moreover,  as  already 
listed in the expected outcome for measure 2.2.a about clarifying the definition of re-use etc., 
clarity on the status of removed components from the vehicle will facilitate their transport for 
reuse and remanufacturing by limiting administrative burdens of their shipment (also trans-
national). It is expected that more components will be reused or remanufactured as well as 
their service life being extended. A possible limitation of use of remanufactured components 
may  occur  in  the  case  of  their  application  in  broken  newly  manufactured  vehicles  and  in 
construction of new vehicles since this issue is not legally clarified and for some OEMs is not 
considered  as  an  option  (due  to  definition  of  new  vehicle).  However,  as  described  above, 
whether it would be possible to have an entire car from remanufactured parts is rather unclear. 
Additionally,  some  components  of  ELVs  cannot  easily  be  installed  in  new  vehicle.  These 
technical  burdens  possibly  significantly  influence  the  option  to  use  remanufactured/used 
components in new vehicles.  

2.1.5.3.3  2.3.c)  Voluntary  activities  of  OEMs  and  their 
suppliers to promote the application of reused and 
remanufactured components  

EU product classification, which would distinguish between remanufactured, used and newly 
manufactured  components  could  help  increase  the  awareness  of  consumers  to  the 
applicability of such components and subsequently will potentially increase the demand for 
partly or fully reused or remanufactured components. The vehicle production sector should 
be encouraged to develop a clear classification of such components into the groups, based 
on the identity of the manufacturer (e.g., OEM, third party), process specifications (e.g., new 
manufacture,  cleaning,  testing,  repairs)  and  the  quality  specification  (e.g.,  warranty).  The 
classification could be used on marketed components through the labelling of products, also 
distinguishing  between  components  manufactured  by  authorised  operators  and  those 
marketed by illegal facilities. Such a scheme could distinguish between:  

•  newly manufactured OEM components,  
•  newly manufactured supplier (not OEM) components,  
• 

remanufactured components,   

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• 

reused components processed by an ATF. 

Expected  outcome:  Clear  differentiation  between  various  levels  of  reuse  should  assist 
consumers  in  purchase  decisions  for  replacement  parts  and  in  the  long  run  could  also 
promote the application of used parts in new vehicles (i.e., or in remanufactured vehicles). 
The possible limitation of use of remanufactured components might occur in case of newly 
manufactured vehicles since in some of the Member States it might not be allowed to use 
such components in the construction of new vehicles. However, labelling of components of 
ATFs etc. could help tackle the problem of illegal sales.  

2.1.5.3.4  2.3.d)  Voluntary  activities  of  Member  States  to 

promote circularity 

To  support  circularity,  the  future  legislation  of  ELVs  shall  refer  to  activities  that  MS  are 
encouraged  to  embark  on  as  a  means  (Good  Participatory  Practices)  of  supporting  the 
circularity of vehicles, including the following: 

• 

• 

• 

• 

Introduce incentives or financial benefits (e.g., reduction of VAT rate on labour costs for 
employees or reduction of taxes) for products that contain remanufactured products or for 
remanufacturing operations, 
Introduce criteria into green public procurement guidelines that promote the use of reused 
and remanufactured components, for example: 
In  relation  to  vehicle  services:  criteria  that  favour  insurance  policies  of  vehicles  that 
commit to the use of reused/remanufactured parts when available, 
In relation to the purchase of vehicles: criteria that favour of vehicles assembled with a 
minimum share of remanufactured parts (i.e., remanufactured vehicles). 

Expected  outcome:  Good  Participatory  Practice  may  have  an  added  benefit  of  raising 
employee awareness to reuse and remanufacturing practices. However, implementation of 
Good Participatory Practice rules is an individual decision of MS.  

2.1.5.3.5  2.3.e) Establish provisions to support the market of 

used spare parts 

Though various components have a high potential for re-use and remanufacture, ATFs (as 
also  repair  shops  and  garages)  will  only  dismantle  and  prepare  for  reuse  components  for 
which they observe there to be a sufficient market demand. In some cases, the demand is 
related to the quality of a component (e.g., there is low demand for components that have 
very few malfunctions as they do not need to be repaired and for components that have many 
malfunctions  as  the  ATF  cannot  guarantee  minimum  warranty).  But  for  most  components, 
demand could be increased by ensuring that consumers are aware of the option of reused 
and  remanufactured  components  as  alternatives  to  new  ones  and  as  to  their  related 
advantages (reduced costs).  

The  goal  of  this  measure  is  to  increase  the  market  demand  for  used  and  remanufactured 
components. This is possible when: 

•  The  price  of  used  components  is  significantly  lower  than  that  of  newly  manufactured 

components. 

•  The price of used components, which is linked to a market demand, can cover the costs 

of dismantling and any operations performed to enable reuse/remanufacturing.  

•  There  is  easy  access  for  the  consumers  to  the used  and  remanufactured  components 

(i.e., through repair shops and garages).   

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•  The situation of components being offered on the market by unauthorised dismantlers can 
be eliminated (these are often offered at lower prices as the economic operators perform 
illegal dismantling and have lower operation costs than those of ATFs). 

As part of its Circular Economy legislation106, France established an obligation to increase 
the demand for reused/remanufactured components in 2018: car repair shops must make an 
offer  to  repair  a  vehicle  with  used  components  in  parallel  to  the  offer  to  repair  it  with  new 
components.   

There  are  also  a  few  examples  of  insurance  companies,  which  voluntarily  opted  for  a 
proactive  policy  for  a  sustainable  management  of  ELVs95.  This  includes,  for  example,  the 
establishment  of  partnerships  between  an  insurance  company  in  France and  a  network  of 
qualified  ATF  and  repair  companies,  to  increase  application  of  reused/remanufactured 
components. For this purpose, the insurance company has been requesting every partner to 
systematically dismantle economically irretrievable vehicles older thar 8 years and vehicles 
technically  irretrievable (i.e.,  classified  by the  insurance  company  as  a “total  loss”  after  an 
accident). Dismantled used components from these vehicles can then be proposed by the 
company  to  its  insurance  policy  holders  to  repair  their  vehicles  in  cases  that  the  repair  is 
performed  under  an  insurance  policy.  The procedure  assumes that the partners  dismantle 
mainly  economically  valuable  components.  Since  the  majority  of  irretrievable  vehicles  are 
vehicles after collision accidents, the insurance company mainly deals with components such 
as bodywork, doors, and optical elements. Since 2012, the insurance company managed to 
increase  the  application  of  used  components  systematically  every  year,  so  that  the  initial 
target to repair 10 % of the 300 000 insured vehicles with re-used components by 2022 was 
already  achieved  in  2020.  Aside  from  the  environmental  benefits  of  this  practice,  it  has 
additional economic and social advantages, as it allows offering lower insurance policy costs 
to vehicle owners that agree to repair their cars with used spare parts (in cases of insured 
repairs). 

Currently,  there  are  no  legal  restrictions  on  the  online  sales  of  used  components.  Lack  of 
such  restrictions  promotes  illegal  facilities,  since  the  used  components  from  non-legal 
operators  can  be  offered  for  sale  at  lower  prices  than  the  those  offered  by  authorised 
facilities107. The goal with this measure is to promote legally operating treatment operations. 
For this purpose, in some countries, the authorities will need to set up partnerships with online 
sales websites to ensure that used components sold through the webpage are only sourced 
from licensed ATFs108.   

The possible provisions to be added to the future legislation of ELVs to support the market of 
used components are: 

•  To increase the demand for used components on the market:  

o 

o 

Introduce  an  obligation  in  the  future  legislation  of  ELVs  that  car  repair  shops  must 
provide  customers  with  an  offer  to  repair  a  vehicle  with  used/remanufactured 
components alongside offers to repair the vehicle with new components. 
Introduce  an  obligation  for  insurance  companies  to  offer  car  owners  discounted 
policies  if  they  agree  that  repairs  are  performed  with  reused/remanufactured  parts 
when these are available 

•  To effectively ban the online sales of used components by illegally operating facilities 

(as also by private individuals): 

106 Arrêté du 8 octobre 2018 relatif à l’information du consommateur sur les prix et les conditions de vente des pièces issues 
de l’économie circulaire dans le cadre des prestations d’entretien ou de réparation des véhicules automobiles 

107 ATFs must comply with the ELV minimum standards which increases the operating costs of such facilities. 

108 Example between the UK authorities and eBay: Environment Agency joins forces with eBay to stop illegal vehicle breakers 

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o  Enable traceability of the origin of reused components offered for sale by introducing 
an obligation for retailers (including online sales) to provide the vehicle identification 
number (VIN) together with the components details at the point of (online) sale.  
Introducing an obligation to provide the registration number of the dismantler together 
with the components details at the point of (online) sale.  

o 

Expected outcome: The market for reused components is dynamic – increasing demand is 
assumed to provide more flexibility to ATFs to decide on components to be dismantled as 
opposed to measures for increasing supply which could result in a high burden for storage 
without significant impact on the actual reuse/remanufacturing of components. Measures for 
insurance companies may only be implementable through national legislation. Strengthening 
the  market  demand  for  reused  components  will  increase  the  profitability  of  dismantling 
relevant components. Provisions on online sales will reduce sales of used components from 
illegally operating facilities, increasing profitability of legally operating ones.  

2.1.5.3.6  2.3.f) Set up a separate (monitoring) target for re-
use/preparing for re-use/remanufacturing 

Currently, the  ELV  Directive  addresses  reuse  and  recycling  under  a  combined  target.  The 
share  of reuse reported by  the  Member  States varies  between  zero  and more  than  30 %, 
possibly caused by different reporting methodologies. 

In the OPC as well as during the targeted consultations, the opinions of stakeholders on the 
implementation of a separate reuse target were divided. A significant number of stakeholders 
did not support a separate target but rather indicated the following measures as a means of 
contributing to the reuse of vehicle parts: 

•  Obligations for repair shops to offer customers used components as an alternative to new 

ones. 

•  Obligations  for  ATFs  to  remove  certain  components  of  ELVs  before  shredding  to  help 

increase reuse. 

•  Obligations  for  car manufacturers  to  enable (e.g., the  ATFs)  unlocking  components  so 

that they can be reused and dismantled. 

•  Obligation  for  car manufacturers to  provide the dismantling  centres (ATFs)  information 
about  which  components  can  be  used  as  identical  parts  in  other  models  of  the 
manufacturer or even other brands. 

Among stakeholders that supported the idea of implementation of separate reuse tartes, the 
majority of them was for introducing these targets for specific vehicle components such as 
the  combustion  engine  and  car  headlights  instead  of  implementation  of  a  separate  reuse 
target by weight of the reused components compared to the weight of the vehicle.  

A common stakeholders’ opinion is that the reuse of specific components is market driven. 
Additionally,  imposing  mandatory  dismantling  of  about  20  years  old  vehicle  components 
where there is no market for reuse would not be economically viable. A requirement to remove 
components  for  reuse  from  ELV  might  increase  only  operation  costs  for  the  ATFs  (time-
intensive removal and storage of removed parts) and have no additional benefits if there is 
no demand for these components. As manufacturers would have to pay for this expenditure, 
the price for dismantling at end-of-life would in the end be shifted to consumers through the 
sales  price  of  new  vehicles,  as  well  as  it  would  impact the  positive  value  of  ELVs  (EuRIC 
(2022c)). 

Various  actors  claim  that  the  removed  components  could  be  counted  towards  recycling 
instead of for a reuse target (for more information please refer to measure point that refers to 
2.1.5.4.2).    

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Considering the above opinions, there are two possible options that could be implemented 
together  or  separately  (preferably  together)  to  improve  share  of  ELVs  components  for 
reuse/remanufacturing/preparing for reuse by setting out:  

Adding an annex to the future legislation of ELVs with a list of components that are relevant 
for  reuse  and  remanufacturing.  This  list  will  be  referenced  in  the  type  approval  for  the 
obligatory  provision  of  information  by  OEMs  on  the  dismantling  time  and  method  (see 
2.1.5.1.4). This list shall be revised and updated from time to time. Obligatory reuse targets 
could  be  set  for  these  parts  in  the  future  if  the  rate  of  reuse  remains  low,  i.e.,  we  do  not 
propose a target for specific components at this point, under the assumption that the measure 
for increasing the market will suffice but include the option for adding such targets in the future 
if in the reporting (see below) it is observed that the level of reuse is lower than it could be 
expected  to  be.  We  would  like  to  confirm  that  this  is  in  line  with  the  EC  options.  Possible 
condition for the removal of components for reuse might be also the age of the vehicles, e.g., 
15 years.  

A yearly reporting obligation of a list of removed spare parts together with a declaration as 
to the shares (total number per part and respective shares of operation) of these parts which 
were prepared for re-use/sold for reuse or remanufacture/ recycled in that year. All removed 
components should be detailed and not only those listed in the annex referred to under point 
1. Obtained information will allow a better understanding of the potential for reuse and how it 
is  influenced  by  measures  that  affect  market  demand.  It  will  also  help  in  the  future  in  the 
revision of the list of removed spare parts for reuse as well as to set out the targets (point 1). 
Introduction  of  the  yearly  reporting  list  for  removed  parts  will  also  require  revision  of 
Commission Decision (please refer to point 0). 

The following preliminary list of components is to be considered for this purpose:  

•  Engines (combustion and electric)  
•  Rear and front lights  
•  Bumpers 
•  Tyres 
•  Gear box 
•  Alternator 
•  Exterior mirrors 
•  Doors 
•  Fenders 
•  Clutch 
•  Brake callipers 

Expected  outcome:  Harmonising  monitoring  will  allow  understanding  the  actual  volume  of 
reuse  in  different  MS  and  will  enable  the  comparability  of  monitoring  data.  Additionally, 
combination of both sub-measures assumed to result in a more significant impact. However, 
separate  reporting  on  components  sold  for  reuse/remanufacturing  could  create  a  relevant 
burden for ATFs if it cannot be linked to list of sales, thus it requires developing of an effective 
reporting list. 

2.1.5.4  Measures to achieve specific objective 2.4: Increase the 
recycling rates of materials and components contained in 
cars    

Despite  general  provisions  to  require  recycling,  the  ELV  Directive  does  not  sufficiently 
address this waste management route, including through the eco-design of cars to facilitate 
recycling. The potential to increase recycling and ensure a level playing field for high quality 

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recycling is not realised. The following section thus details measures under consideration to 
increase the rate of recycling of vehicle materials and more importantly to promote their high-
quality recycling. 

2.1.5.4.1  2.4.a) Align definition of ‘recycling’ with the WFD 

The  ELVD  defines  recycling  as  the  reprocessing  in  a  production  process  of  the  waste 
materials for the original purpose or for other purposes but excluding energy recovery. Energy 
recovery means the use of combustible waste as a means of generating energy through direct 
incineration with or without other waste but with recovery of the heat. 

In this sense, the ELVD definition for recycling excludes energy recovery but does not exclude 
backfilling, as is the case under the Waste framework Directive (WFD). This results in some 
MS  including  shredder  heavy  fraction  (SHF)  used  for  backfilling109  operations  in  the 
accounting  to  show  compliance  with  the  ELVD  reuse  and  recycling  target.  This  statistical 
inclusion  as  recycled  material  is  not  in  line  with  the  Waste  framework  Directive  (WFD) 
definition  of  recycling  and  results  in  an  unfair  comparison  on  the  achieved  targets  in  the 
various MS. It also means that there is an untapped recycling potential in the MS that report 
backfilling in this context.  

In the OPC most stakeholders (56%) agreed that the ELV definition for recycling should be 
aligned to that of the WFD as this would support a higher level of material recovery. Aside 
from  the  automotive  producers  that  were  mainly  neutral,  the  majority  in  all  stakeholder 
categories supported an alignment. Only 3% disagreed with this statement, however there 
was also a large share of stakeholders that were neutral (40 individuals) or that did not have 
an opinion (31 individuals) making for a total of 40% together with those that did not specify 
an answer (13 individuals). 

Towards this end, it is essential to align the ELVD with the WFD definition for ‘recycling’. The 
WFD definition for recycling should replace the current one. The WFD definition reads (Article 
3(17)): 

‘recycling’ means any recovery operation by which waste materials are reprocessed into 
products, materials or substances whether for the original or other purposes. It includes 
the reprocessing of organic material but does not include energy recovery and the 
reprocessing into materials that are to be used as fuels or for backfilling operations; 

This  would  also  mean  that  any  future  decisions  to  take  place  under the  WFD  as  to  which 
technologies count towards recycling would automatically apply also under ELV. 

It  is  important  to  note  that  some  shredder  output  fractions  are  used  for  road  surfacing  in 
landfills  or  for  filling  underground  mines.  Some  countries  consider  these  operations  as 
recycling, as this shredder output fraction replaces a new / non-waste material.  

Expected  outcome:  Increase  of  coherence  with  WFD.  To  allow  MS  to  be  able  to  prove 
compliance with future recycling targets, in some cases (e.g., where backfilling is applied or 
other  treatment  methods  that  result  in  downcycling)  they  may  need  to  promote  the 
implementation (in some cases also development) of other treatment methods that would be 
classified as recycling. Depending on how the alignment of the definition ‘recycling’ with WFD 
is  performed  (only  backfilling  or  also  other  downcycling  treatments)  it  will  either  have  a 

109 Article 3(17a) of the amended WFD (Directive 2018/851) defines backfilling as “any recovery operation where suitable non-
hazardous waste is used for purposes of reclamation in excavated areas or for engineering purposes in landscaping. Waste 
used for backfilling must substitute non-waste materials, be suitable for the aforementioned purposes, and be limited to the 
amount strictly necessary to achieve those purposes 

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marginal  affect  (exclusion  of  backfilling)  or  will  potentially  lead  to  higher  quality  recycling 
(exclusion of all downcycling treatments). In MS in which downcycling has been accounted 
for as complying with the targets, this is likely to require investments in the development of 
alternative treatment routes. 

2.1.5.4.2  2.4.b)  Making  it  mandatory  to  remove  certain 
parts/components  before  shredding  to  encourage 
their Reuse and recycling 

The typical treatment of ELVs, after their collection, usually includes the following steps:  

•  de-pollution of relevant components and materials (referred to in Annex I (3)) from ELVs 

in an ATF: 
o 

final treatment (final treatment) of depolluted fractions by dedicated recyclers, 

•  dismantling of relevant components (Annex I (4)) from ELVs in an ATF; 

o  preparation for reuse of relevant components, sometimes including remanufacturing, 
o 

recycling of removed and sorted fractions by dedicated recyclers, 

•  shredding of depolluted ELVs in a shredder facility (not always ELV dedicated)  

o 

resulting outputs (after shredding) are either disposed of or treated in post-shredder 
technology (PST) facilities.  

The removal of parts from ELVs prior to shredding is a precondition for increasing their rate 
of reuse. It also supports higher quality recycling in some cases, e.g., where it is not feasible 
to  recycle  a  certain  fraction  after  shredding  (e.g.,  neodymium  magnets)  or  where  such 
recycling is limited in the quality of secondary raw material that it can achieve due to a high 
level  of  impurities  (e.g.,  aluminium).  The  ELV  Directive  sets  out  minimum  technical 
requirements for treatment of ELVs to promote reuse and recycling (Article 6(1) and (3) and 
Annex I(4)) that are not sufficiently precise and thus have limited effect on reuse95 and on the 
quality of recycling operations. To begin with Annex 1(4) requires the removal of components 
to “promote recycling”. Though this can indirectly support reuse in some cases, reuse is not 
specified as the objective. Furthermore, currently provisions do not mention at which stage of 
the treatment the removal of certain components (e.g., catalysts and glass) should take place 
(meaning that shredding can be used to remove them from other fractions), thus limiting the 
possible  output  fractions.  The  conditions  set  for  other  specified  materials  and  parts,  e.g., 
metal  components,  tyres  and  large  plastic  components,  enable  shredding  as  long  as  the 
material can be “effectively recycled”, however without setting criteria so that downcycling is 
not prohibited. Additionally, the list of parts/materials to be removed before shredding is rather 
limited. Stakeholders have mentioned additional parts for which removal prior to shredding 
enables  reuse  or  higher  quality  recycling  such  as  electric  and  electronic  components, 
engines, and others. In these cases, the decision to remove is rather motivated by economic 
considerations  (market  prices  for  materials,  available  dismantling  equipment  and  labour 
costs) as well as legal differences between MS. Elaborating the existing provisions, to include 
additional  components  and  clarifying  when  removal  is  to  be  performed  prior  to  shredding 
would increase the potential for reuse110 and for high-quality recycling.  

In  the  OPC  the  vast  majority  (67%)  of  stakeholders  agreed  that  the  ELV  Directive  should 
require the removal of certain parts from ELVs prior to shredding to promote their high-quality 
recycling.   

110 Some dismantled components can be readily reused, while others require remanufacturing to be performed to enable 
reuse. 

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Nevertheless, during the stakeholder workshop, some stakeholders stated that dismantling is 
not always required for high-quality recycling. It was raised that post shredder treatment can 
also achieve high recycling levels. This depends on the facility and technology applied, since 
the PST are not established evenly across the EU and though there may be technologies that 
can achieve high recycling levels, this will only deliver results where such technologies are 
indeed applied.  

Resulting  from  the  research  and  feedback  from  stakeholders,  this  measure  would  only  be 
relevant for some components and materials. To give few examples:  

For glass some studies show that dismantling and separate recycling could lead an increase 
in  circularity  due  to  an  improvement  in  the  quality  of  recycled  material  and  supposedly 
respective environmental impacts. Dismantling and separate recycling however have been 
said  to  not  be  economically  viable,  mainly  due  to  the  transport  costs.  However,  there  are 
countries that do this (required by law in the past, supported with financial compensations, 
etc.) and thus it is assumed that the environmental benefits set off the economic costs (i.e., 
the practice is not far from economic viability).  

In some cases, components, for example those mainly composed of steel, can be dismantled 
prior to the shredder, but an initial analysis (presented at workshop) of specific components 
suggests  that  this  does  not  lead  to  a  significant  benefit  in  terms  of  the  share  recycled 
(environmental gains), whereas the dismantling and transport will at times make sense (e.g., 
at times of high market price for primary steel) and at times will not due to market fluctuations. 
In other words the proportionality of the measure for steel will be volatile as is the market. 
FEAD (2022) confirms that “separate recycling of steel components (prior to shredder) would 
have a small impact on the quality of steel” that is recycled.  

For aluminium, obligatory dismantling will make sense for some components (depending on 
size, dismantling effort and effect on quality of recyclate) but not for all. This is for example 
the  case  today  for  wheels  (in  the  past  cast  alloys  were  used  but  nowadays  for  weight 
reduction more technical cast as also wrought alloys are used): they are dismantled from ELV 
and sent directly to recycling and their value is comparable to the value of primary aluminium 
(European  Aluminium  2022).  When  it  comes  to  aluminium  components,  according  to 
(European Aluminium 2022), it is already common and best practice to dismantle wheels and 
engines  before  shredding  and  to  recycle  them  separately.  Obligations  to  dismantle  the 
following  components  would  support  high-quality  recycling:  bumpers,  engines,  heat 
exchangers, wheels, mono-material aluminium components separated into cast and wrought 
alloy with a weight above 10 kg. 

In this regard, to ensure that certain parts are removed prior to shredding, provisions in the 
future legislation for ELV should be revised so that it is clear for which components removal 
is to take place prior to shredding. Furthermore, the list of components for which this is already 
obligatory  should  be  extended.  The  following  preliminary  list  of  components  is  to  be 
considered for this purpose:  

•  Windshield, rear and side windows composed of glass 
•  Engines, 
•  Main wiring harness (copper) and other large mono-material copper components, 
•  Electric  and  electronic  components  above  a  certain  size  (some  copper  and  precious 

metals), 

•  Mono-material aluminium components with a weight above 10 kg, requiring the separate 
collection  and  treatment  of  cast  and  wrought  aluminium,  e.g.  bumpers,  engine  block, 
wheels, heat exchangers, 

•  NdFeB magnets when the engine is not prepared for reuse/remanufacturing (still to be 

reviewed). 

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•  Materials  benefiting  from  a  derogation  from  compliance  with  the  ELVD  and  3R  Type 
approval Directive provisions on the reuse, recycling and recovery targets, in cases where 
the material cannot be recycled at EoL.  

For components already specified in annex I (4), revisions are to be considered to ensure 
that  removal  is  performed  prior  to  shredding  and  where  relevant  to  specify  separate 
treatment, for example: as big plastic parts (e.g., bumpers, dashboard), tyres, glass (e.g. front 
and back windshield), catalytic converter system, batteries, airbags… 

It may also become necessary to add in the future components that might have a negative 
effect on the residues of shredder/PST fractions. 

Removal  of  parts  from  ELVs  prior  to  shredding  is  not  just  a  precondition  for  high-quality 
recycling but can also contribute to increasing the reuse rate. It should thus also be possible 
to  revise  the  list  of  parts/materials  to  be  removed  before  shredding  from  time  to  time, 
particularly should the market situation (demand for components for re-use) suggest that the 
removal of additional specific parts should be promoted (please refer also to point 2.1.5.3.6 
in regard to the list of components that are relevant for reuse and remanufacturing). In parts 
removed for reuse, they will be checked by the ATF to decide whether they can be prepared 
for  reuse  (depending  on  condition  and  market  demand)  or  whether  it  is more  beneficial  to 
send them to separate treatment (e.g., the value of steel scrap sold to a recycler can be higher 
at times than the value per kg of ELV scrap sold to a shredder). As an example, an engine 
removed prior to shredding will be checked to decide if it is fit for reuse. In cases of low market 
demand or bad condition, it may be sent for recycling instead of reuse. According to one of 
the  stakeholders,  dismantling  of  such  engines  –  despite  additional  costs  –  would  be 
economically viable, since the revenue for the ATF is often higher when the engine is sold 
directly to the smelter than when it is sold to the shredder facility.  

Nonetheless,  the  provision  to  remove  some  components/materials  prior  to  shredding  may 
increase the operating costs for ATFs, where the revenues generated from these activities 
are not offset by their costs. This should be addressed as part of an EPR scheme to support 
the treatment of ELVs and the prevention of waste (see proposed measures under section 
0).   

Expected outcome: Prioritising dismantling of components with a high potential for increasing 
quality  and/or  quantity  of  recyclates  will  increase  availability  of  secondary  materials  and 
probably  also  their  use  in  the  manufacture  of  new  vehicles.  Additionally,  measures  will 
contribute to reuse where components have potential for both reuse and recycling. Increased 
dismantling and sales of separate fractions will increase complexity of ATF logistics and could 
affect their profitability. 

2.1.5.4.3  2.4.c)  Set  material-specific  recycling  targets  for  a 

selection of materials  

Many different materials are used in cars, but their treatment at end-of-life differs. Steel, alumi-
nium  and  copper  are  recovered  to  a  large  extent,  but  other  materials  are  not.  As  certain 
materials, such as plastic and glass, account for only a small portion of the vehicle weight, 
they are often discarded and/or only recovered after shredding, leading to a reduced quality 
of  the  recovered  material.  Rare  earth  elements  (REEs)  are  used  for  permanent  magnets, 
platinum group metals (PGMs) for catalytic converters and printed circuit boards, gallium for 
lighting  equipment  and  integrated  circuits,  magnesium  and  niobium  for  metal  alloys,  and 
natural rubber for production of tyres. Electric and electronic (EE) systems in vehicles also 
contain e.g., precious metals, gallium, tantalum, and REE.  

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Since  at  present  the  ELVD  sets  out  an  annual  common  (for  all  materials)  recycling  target 
based on the average weight of the vehicle, not all the materials used in vehicles are subject 
to the same high standard of recycling. While high-quality recycling can often be technically 
feasible  and  environmentally  beneficial  (e.g.,  of  glass,  selected  plastics,  electronic 
components), it is not performed in cases with low or lacking profitability. In some cases, this 
is due to the low efficiency of the technologies applied for recycling (also lack of advanced 
shredding and post shredding technologies) but in others it can also be connected to lacking 
pre-treatment (dismantling and sorting) of ELV components prior to shredding, to allow higher 
quality input materials for specific recycling processes. 

The main goal of the proposed measures is to promote an increase in the quality of resulting 
recycled materials together with the increase of the amount of recycled material as opposed 
to  forms  of  treatment  of  a  lower  hierarchy  like  energy  recovery,  backfilling  or  disposal. 
Additionally,  the  material-specific  recycling  target  should  also  consider  the  materials  and 
components  dismantled  from  the  ELV  before  shredding  for  reuse,  remanufacturing,  and 
recycling.  

An  effective  way  to  ensure  high-quality  recycling,  is  to  introduce  a  provision  in  the  future 
legislation of ELVs that would allow considering only recycled waste for the reporting on 
the  recycling  target.  In  other  words,  recycling  targets  would  be  accounted  for  on  the 
recyclates level, i.e., considering the mass recovered after recycling operations.  

A similar approach was applied in the Packaging and packaging waste Directive, where only 
“the weight of packaging waste recycled shall be calculated as the weight of packaging that 
has  become  waste  which,  having  undergone  all  necessary  checking,  sorting  and  other 
preliminary  operations to  remove  waste  materials  that  are  not targeted  by  the  subsequent 
reprocessing  and  to  ensure  high-quality  recycling,  enters  the  recycling  operation  whereby 
waste materials are actually reprocessed into products, materials or substances”. It has also 
been applied to the WFD. 

The definitions of “calculation point” and “measurement point” relevant for reporting of data 
on waste have been recently introduced through delegated acts, for instance in the amended 
Commission Decision of 22 March 2005 (Article 2)111: 

(d)  

‘calculation point’ means the point where packaging waste materials enter the recycling 
operation whereby waste is reprocessed into products, materials or substances that are not 
waste, or the point where waste materials cease to be waste as a result of a preparatory 
operation before being reprocessed; 

(e) 

‘measurement point’ means the point where the mass of waste materials is measured with 
a view to determining the amount of waste at the calculation point. 

It is proposed to introduce similar definitions into the future legislation of ELVs (or in a revision 
of Commission Decision 2005/293/EC).  

It would also be needed to specify the calculation points in this document that are applicable 
to  certain  ELV  waste  materials  (e.g.,  glass,  plastic).  Doing  so  will  require  further  analysis 
before their publication in, e.g., an Annex to the legislation or delegated act. Therefore, the 
introduction of the calculation point approach might need to be performed stepwise. Together 

111 Commission Decision of 22 March 2005 establishing the formats relating to the database system pursuant to Directive 
94/62/EC of the European Parliament and of the Council on packaging and packaging waste (2005/270/EC)  

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with the definitions of the calculation and measurement points, the possibility of application 
of ‘average loss rates’112 shall be introduced in the ELVD.  

Additionally, to avoid down-cycling, it shall be required to set up a provision defining the 
quality  of  obtained  recycled  material,  which  is  of  high  importance  especially  for  glass 
(among  the  selected  materials  for  which  it  is  recommended  to  define  material-specific 
recycling targets). In this regard, the recycled glass shall be of a quality that can be applied 
to produce glass products. In contrast, the definition of output of the recycling process for the 
plastics is still unclear since plastics can be chemically recycled (further detailed below).  

Setting up the provision that recycling targets apply at the recyclates level, will subsequently 
most probably result in a decrease of the current total rate of re-use and recycling as well as 
re-use and recovery targets. Together with the material specific targets, these targets should 
also consider the efficiency of the recycling operation.   

A new calculation methodology requires in-depth recognition of the outcomes from shredder 
and post-shredder facilities, which are sent further on to the recycler. As addressed under the 
measures  in  section  2.1.5.4.4,  there  is  a  need  for  standardizing  the  shredder  and  post-
shredder technology and to obtain in-depth information on their capacities and input/output 
flows. Together with the introduction of the term ‘calculation point’ into the legislation, it will 
be required to assess the share of ELVs (broken down into selected materials) in the obtained 
recyclates but also in the residues of shredder/PST facilities that enter recyclers. This would 
probably have a high level of administrative burden (e.g., how to allocate parts or materials 
from ELVs). One possibility is to introduce a calculation approach on how to allocate the input 
materials that enter shredder/PST facilities to their outputs, to assess the weight of materials 
sent  to  recycling  operations.  Where  it  is  not  possible  to  assess  the  recycling  losses,  the 
‘average loss rates’ shall be applied.  

At  present,  new  recycling  technologies  are  under  development  and  their  recycling 
feasibility is still not clear. For instance, current studies indicate several ELV waste fractions 
as potential candidates for chemical recycling, e.g., polyurethanes (PUR) mostly used in car 
seats  and  granulates  from  tyres.  It  is  of  high  importance  for  the  Commission  to  study  the 
technical and economic feasibility of chemical recycling in the context of ELV waste materials, 
however these technologies must still evolve further to allow considering what outputs they 
will  result  in  and  how  this  could  be  accounted for  in  the  fulfilment  of the ELV  targets.  The 
further  development  of  this  recycling  technology  and  its  successful  applicability  for 
shredder/PST  outcomes  could  contribute  towards  the  increase  of  the  share  of  recycled 
materials, towards their energy recovery or disposal (in case it will not be banned).   

New calculation rules will also require adjustment of the existing reporting scheme since 
recycling  operators  will  be  obliged  to  monitor  and  report  on  recycled  materials.  This  will 
possibly require additional effort and time to implement.   

Insofar the specification of this measure relies to some degree on the other measures to be 
implemented and how they may contribute to high-quality recycling for the various materials 
used in vehicles. This includes the measures: alignment of the ‘recycling’ definition (measure 
2.3.a), setting up mandatory removal prior to shredding/PST (measure 2.3.b), regulation of 
shredder/  post-shredder  facilities  (measure  2.3.d)  as  well  as  common  recovery/recycling 
targets and ban disposal (measure 2.3.e).  

Resulting  from  the  research  and  feedback  from the  stakeholders,  there  is  a  need to 
conclude  what  is  the  best  approach  (which  measure  or  which  combination  of 

112 Delegated act of 31.08.2021 supplementing Directive 2008/98/EC of the European Parliament and of the Council with 
regard to rules for the calculation and verification of the weight of materials or substances which are removed after a sorting 
operation and which are not subsequently recycled, based on average loss rates for sorted waste. 

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measures)  for  each  considered  material.  The  following  figure  illustrates  processes  and 
conditions in the treatment of ELV in relation to the various measures and how they could 
relate to the monitoring of compliance with recycling targets and the calculation/measurement 
point.  The  diagram  makes  a  first  specification  of  which  measures  are  considered  to  be 
relevant  for  which  of  the  selected  materials.  It  also  includes  possible  calculation  and 
measurement  points  for  either  recyclates  or  fractions  to  be  recycled  as  well  as  a  possible 
reporting point for components to be reused.  

As already mentioned in the previous section (2.1.5.4.2), for some materials dismantling and 
separate  recycling  could  be  expected  to  have  a  significant  contribution  to  improving  the 
quality of their recyclates and a recycling target could be seen as an alternative measure that 
is less prescriptive as to how improvements are reached. Where recycling is already relatively 
efficient, like steel, a recycling target could increase the share of recycled material. However, 
it  is  not  clear  if  the  relation  of  costs  and  benefit  would  be  proportional.  Material-specific 
recycling targets could be of benefit for aluminium. However, splitting the targets for wrought 
and  cast  aluminium  shall  not  be  introduced,  since  monitoring  of  these  targets  will  not  be 
possible, i.e., the separation of cast and wrought aluminium after shredding is not performed 
in practice and it is not possible with the currently available analytic instruments to determine 
the % of wrought or cast aluminium in mixed fractions. The same is true for plastics (either in 
general or for specific polymers), textiles and rubber. However, setting up the targets for these 
materials  might  require  further  studies  on  the  feasibility  of  chemical  recycling  for  these 
materials  as  well  as  technological  developments.  Nevertheless,  in  this  case,  it  may  be 
possible to introduce the specific targets stepwise, so that in the second step after a few years 
the targets would be revised considering the new technological standards. In other words, 
different materials would be affected differently by the introduction of a recycling target, and 
even  where  this  is  not  implemented,  reporting  on  achieved  amounts  will  need  to  apply  a 
suitable method for ensuring that it reflects the actual treatment of vehicles and its circularity. 

Figure 2-22  Objective 2: Processes and conditions in the treatment of ELV in 
relation to proposed measures 

Source: own illustration 

Looking at the figure above, setting targets in relation to the calculation point could promote 
reuse  and  recycling  at  higher  quality.  Introduction  of  calculation/measurement  points  for 
materials  not  under the specific targets,  could  also  improve  comparability  of reported  data 
among EU-countries and thus can be seen as an alternative sub-measure to setting a target 

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together with the monitoring method. The intended calculation point for materials for reporting 
on  actual  recycling  should  refer  to  the  recyclates  obtained  after  recycling  (losses  are 
excluded). However, it would also be possible to apply ‘average loss rates’ in case where no 
data on recyclates is available. For instance, for glass the measurement point would require 
subtracting the average loss rate (ALR) from the amount reported for dismantling. 

At present material specific targets are under consideration as follows: 

•  Glass – 70% recycling of a quality acceptable for container glass or equivalent,  
•  Plastic – 30% as of 2030 based on the introduction of the calculation point principle, or 

40% is the current reporting scheme is retained. 

Expected outcome: Material-specific targets could promote high-quality recycling. However, 
their feasibility needs to be verified with for each material separately, considering also other 
measures 
results.  The 
calculation/measurement  point  when  applied  on  its  own  shall  increase  comparability  of 
reported data, also generating data that could be used in the future to see where recycling 
targets should be considered for additional materials.  

that  could  be  more  efficient 

in  achieving  similar 

2.1.5.4.4  2.4.d) Regulate shredder/post shredder facilities to 
ensure  high  quality/quantity  of  materials  obtained 
for recycling and to improve final treatment process 

After depollution and dismantling, mechanical treatment of ELVs takes place in shredders of 
metal waste. The input materials are crushed into smaller material components. Afterwards, 
the  obtained  smaller  pieces  are  separated  into  metallic  and  non-metallic  fractions.  Typical 
process steps in a shredder are: 1. delivery, reception, and acceptance, 2. pre-sorting and 
pre-treatment, 3. pre-sorting, shredder technology, 4. post-shredder processes, and 5. end-
of-pipe abatement techniques (Pinasseau et al. 2018).  

The main output of the process is quality steel scrap (with high density, high degree of purity 
and predominantly homogenous size) which can be used directly in metal works to produce 
steel.  The  other  obtained  fractions  are  shredded  non-ferrous  fractions  (containing  other 
metallic products) and Auto Shredder Residues (ASR) containing the subfractions Shredder 
Light  Fraction  (SLR)  and  Shredder  Heavy  Fraction  (SHF).  These  fractions  can  be  further 
treated to recover as much material as possible and to minimise the amount of waste sent for 
disposal.  

The possible further treatment of mixed non-ferrous output may be separation, for example 
by eddy current separations, metal-sensing or by dense media separation.  

The  ASR  fractions  can  be  further  treated  in  post-shredder  technology  (PST)  plants.  Such 
further treatments of the mixed non-ferrous fraction and the ASR fraction can take place in 
integrated plants or separate (centralised) plants.  

As  demonstrated  in  several  studies  untreated  SLF  contains  several  percent  of  residual 
metals,  representing  up  to  7.8 %,  respectively  6.3 %  (Sander  et  al.  2020)  or  according  to 
studies performed more than a decade ago even 11 % (Duwe and Goldmann 2012). 

Regarding  the  SLF  a  joint  presentation  of  Ökopol  and  Umweltbundesamt  (Germany) 
concluded (Sander et al. 2017):  

“Typical  disposal  routes for the  shredder  light  fraction  are  energy recovery  or  incineration, 
backfilling,  the  use  as  landfill  construction  materials,  or  landfilling.  In  the  case  of  these 
disposal  routes,  functional  recycling  of  the  recyclable  materials  is  mostly  not  carried  out. 
Therefore,  a  limitation  of  the  contained  recyclables,  in  particular  of  the  metals,  seems 
appropriate.” 

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A possible maximum metal content for shredder residues, which are destined for backfilling/ 
landfill  construction,  energy  recovery/  incineration  or  final  disposal/landfill  sites,  should  be 
ambitious in order to recover as many metals as possible as secondary raw materials, and 
should orient themselves to the technical possibilities. The removal of metal from the shredder 
light fraction at least to below 1 % metal content by means of post-shredder separation (Tabel 
et al. 2011; Sander et al. 2017) is considered to be feasible. 

In Switzerland, such an approach is already implemented: According to Article 21 of the Swiss 
Waste Ordinance113, metal pieces are to be removed and recycled from the lightest fraction 
that occurs during the comminution of metal-containing waste (light fraction).” 

On  the  other  side  copper  content  in  steel  scrap  destined  for  recycling,  is  considered  an 
impurity of steel and may affect the portfolio of applications in which secondary steel can be 
applied (EUROFER 27.10.21). Copper content in shredder/PST deliverables is considered 
an  impurity  also  for  fraction  rich  in  aluminium.  Similar  to  steel,  Eurometaux  state  that  the 
dismantling of components with copper prior to shredding would allow secondary aluminium 
of higher purity. Impacts of copper removal related to dismantling of EEC and its contribution 
to  purity  of  the  aluminium/steel  fraction  are  mentioned  shortly  under  the  impact  analysis 
section for EEC see section 3.1.10. 

Thus, this measure aims to set up a threshold on the maximum Cu-contamination on steel 
scrap, as main outcome from shredder/PST processes, could lead to higher quality secondary 
steel and aluminium as well as higher quantity of copper for recycling.  

As outlined in the chapter 2.1.2.5.1 the Cu-contamination in steel varies and ranges between 
0.2 to 0.7 wt %. Galvanized cold rolled coil require less than 0.06 % copper. The bards, tubes 
and wire rods allow up to 0.1 % copper. These are the main intermediate products in cars. 
High  Cu-contamination  requires  dilution  with  virgin  material  or  steel  scrap  with  lower  Cu-
content. A theoretical closed-loop of ELV steel scrap (Figure 2-23) was analysed by (Daehn 
et al. 2017a) “using ELV scrap for the production of new vehicles would reduce the amount 
of iron ore required from 136 to 78 Mt, accounting for 32 Mt of fabrication scrap generated in 
car manufacturing.” However, the closed-loop in automotive could be possible only when the 
Cu-contamination in steel scrap would decrease significantly (at the global scale this would 
require removing of 0.19 Mt of copper, assumed based on 2008 data).  

113 VVEA: Verordnung über die Vermeidung und die Entsorgung von Abfällen (Abfallverordnung, VVEA) vom 4. December 
2015. Switzerland.  

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Figure 2-23  Steel mass flows (in Mt) corresponding to the production of cars and 
the recycling of end-of-life vehicles traced through the 2008 global steel system, both 
current practice and a theoretical closed-loop. 

Legend: In the closed loop, indicated by dashed flows, ELVs are not used for reinforcing bar production. The red numbers 
represent technical interventions along the supply chain to achieve a closed loop: (1) more disassembly, (2) better shredding, 
(3) better sorting, (4) chemical extraction, (5) increase tolerance, and (6) reduce copper content. 

Source: (Daehn et al. 2017a) 

According  to  (Daehn  et  al.  2017b)  about  80 %  of  the  original  copper  can  be  removed  in 
magnetic  separation.  However,  alternative  practices  exist.  For  instance,  Sicon  claims  to 
reduce  the  output  of  their  improved  shredding114  to  0.1 %  of  copper  concentration.  The 
following  figure  (Figure  2-24)  illustrate  effectiveness  (copper  concentration  achievable)  to 
qualitative energy/cost for various technologies to separate copper. It also shows the scale 
of development of introduced technologies. Some of them are applicable copper separation 
routes from the steel melt not applicable by the shredder operation. Other, like high density 
shredding, O2/Cl2 gas are technics for copper separation from solid scrap, however not all 
might  be  possible  to  be  applied  by  shredder  facility  (this  statement  would  require  further 
analysis). The most common separation methods and the methods that are in practice under 
certain conditions are not necessary the most efficient ones and can be actually also quite 
costly (quite high qualitative energy/cost). Methods that show higher efficiency (lower copper 
concentrations achievable) that seem to be not too costly need still scale-up development115. 
Thus, it would be recommended to introduce the limit on copper contamination in steel scrap 
(excluding homogenous steel that contains alloyed copper) stepwise and with transition time. 

114 High density shredding, which produces 40-50 mm pieces more regular in shape than the about 100 mm pieces from 
today’s low density shredding. 

115 Detail description of existing Cu-removal methos are in (Daehn 2019). 

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According to the European Steel Scrap Specification116 that defines aimed analytical content 
of E40 steel scrap (output from the shredder), the aimed Cu-content is 0.25 %117. Additionally, 
sorting trials performed by ArcelorMittal with X-ray sorting machine (QXR TITECH) prove that 
it is possible to obtain Fe fraction with Cu-contamination lower than 0.25 % (obtained 0.209 
%) from the shredded scrap with original Cu-contamination in a level of 0.655 %.    

Thus, it seems technically achievable to set up a first threshold for average copper content of 
0.25 %,  which  after  several  year  could  decrease,  while  in  the  meantime  technology  could 
develop.  Nevertheless,  it  is  possible  to  obtain  the  level  of  0.25 %  also  due  to  improved 
dismantling. IRSID-USINOR & CTRA Study and presentation from ArcelorMittal118 show that 
improved  sorting  dismantling  of  parts  that  contain  copper  prior  to  shredding  significantly 
influence  Cu-content  after  shredding  of  the  dismantled  ELV  (see  further  details  in  the 
description  of  scenario  3  “Mandatory  dismantling”  under  impact  analysis  of  steel,  section 
3.1.5.2.4). 

Additionally, an introduction of such provision would require also development of monitoring 
methods  of the  concentration  of  tramp  elements in  solid  scrap  since there  are  no  nominal 
limits for this concentration (Daehn et al. 2017a). Institute of scrap recycling industries (ISRI) 
classifications do not classify the max. level of Cu in ferrous scrap119.   

Figure 2-24  Comparison by copper concentration achievable and estimated relative 
energy and cost of the discussed copper separation interventions. 

Source: (Daehn et al. 2017a) 

116 http://ehrhardt-recycling.de/wp-content/uploads/2017/05/Stahlschrott-Sortenliste-Englisch.pdf 

117 The values retained for the analytical contents are those which have been experienced in real terms in the various 
countries of the European Union and are achieved by scrap yards working normally with standard methods and standard 
equipment. 

118 Russo, Philippe, Bollen, Jan, presentation on “Scrap for Decarbonized Steels” from ArcelorMittal, IARC – July 5th 2022 

119 http://www.scrap2.org/specs/20/  

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Under "non-normal operating conditions" smoke, dust and possibly dioxins may be released, 
e.g.,  by  deflagration  and  or  fire.  Such  conditions  can  be  caused  by  fuel  residues  or  Li-ion 
batteries  left  in  end-of-life  vehicles.  The  number of  deflagrations  varies from  one  shredder 
site to another.  

For  poorly  managed  shredders,  50  deflagrations  per  year  are  reported.  An  efficiently 
managed shredder is able to reduce the number of deflagrations to one per year (Pinasseau 
et al. 2018). The BREF Document for Waste Treatment (2018) defines detailed rules for the 
operation  of  shredders  to  minimise  emissions  under  standard  conditions  and  to  minimise 
deflagrations and fire.  

Currently, the ELV Directive defines minimum technical requirements for treatment operations 
for depollution of ELVs (Article 6(3) and Annex I (3)) as well as for treatment and for storage, 
which refer to dismantling processes performed by ATFs (Annex I (1) and (2)), nonetheless 
no such requirements for shredder processes (incl. post-shredder plant) exist in the current 
Directive.   

Measure:  

In this regard, the ELV Directive should introduce mandates for the EC to establish (e.g. by 
means of e.g. delegated act):  

•  1) minimum operation requirements for shredder plants (regards implementation of the 
BREF standard, monitoring of explosions and dust emissions and application of measures 
to control input streams with the aim to minimise explosions to not more than once per 
year),  

•  2) if 3 deflagrations per year are exceeded, the operating licence must be suspended until 
an optimised operating plan, including input quality control, is submitted to the licensing 
authorities.   

•  3) minimum requirements for shredder/PST plants (regards technical concept and output 
qualities e.g., limiting the metal content of untreated SLF envisaged for disposal to 1% 
metal content). 

•  4) national reporting obligations on: 
o  national capacities of PST and  
o 

information on input/output flows, including information on the final use and indication 
of  how  much  of  the  input  materials  comes  from  Auto  Shredder  Residues  (ASR)  in 
cases where plants treat multiple waste streams.  

Additionally,  the  profitability/economic  viability  of the  operation  of  PST  is hampered  by  the 
volatility  of  market  conditions  for  the  output  streams.  It  is,  however,  necessary  to  ensure 
removal  of  substances  such  as  PVC  or  plastics  containing  flame  retardants  such  as 
decaBDE. In cases where PST are not economically viable, the operators of the PST plants 
shall have two options how to deal with the output materials: 

• 
• 

to sell them to recyclers, or 
to request the EPR Scheme to take care of the output materials. Here two further options 
are under consideration, where the operator of the PST could offer the EPR scheme to 
take care:  
o  only of selected output streams or  
o  of all output streams. 

Such requirements are to be linked to the measures described under section 0. 

Expected outcome: Sub-measure should reduce losses of residual metals while ensuring a 
minimum level of performance of PST operations. Fractions that reach PST plants may differ 
in quality due to the techniques applied by shredders and may affect the effectiveness of this 
measure. 

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2.1.5.4.5  2.4.e)  Increase  (?)  current  re-use  and  recycling 
targets and/or ban disposal or landfilling of waste 
from ELVs  

Originally it was contemplated to increase the common reuse and recycling target to 90% by 
2025  and  to  95%  by  2030.  However,  for  the  purpose  of the assessment,  it  is  proposed  to 
keep the targets unchanged, due to the fact that a higher recycling quote might not be in line 
with the main goal of ensuring higher-quality recycled materials. The provision indicated in 
section 2.1.5.4.3 proposing an approach in which recycling targets refer to the recyclates level 
(calculation  point)  could  make  achieving  the  current  re-use  and  recycling  targets  more 
challenging for MS once the new calculation rules are applied. Thus, to ensure high-quality 
recycled  material,  it  is  proposed  not  to  increase  the  common  targets  at  this  time.  Final 
conclusions  as  to  recommended  targets  should  be  based  on  the  outcome  of  the  impact 
assessment.  

Additionally, it is proposed to introduce a ban on landfilling. 

Ban of disposal or landfilling  

The  profitability/economic  viability  of  the  operation  of  PST  is  hampered  by  the  volatility  of 
market  conditions  for  the  output  streams.  It  is,  however,  necessary  to  ensure  removal  of 
substances such as PVC or plastics containing flame retardants such as decaBDE. 

According  to  the  POP-Regulation  (Annex  V),  POPs  containing  components  must  be 
separated.  

Diverse  studies  report  concentrations  of  PBDE120  (as  addressed  by  the  POP  Regulation) 
beyond 1000 mg/kg for several components of ELVs.  

Due  to  the  lack  of  information  on  components  containing  POPs  in  specific  vehicles 
dismantling of components containing high concentrations of PBDE is not feasible. Even if 
information would be available, it is unrealistic to dismantle all these small components where 
POP might be included. 

Today,  the  majority  of  materials  (e.g.,  from  textile,  wiring  harness)  containing  PBDE  are 
directed to the Shredder Light Fraction (SLF), and when Post Shredder Treatment (PST) is 
applied,  to the  granulate  with  a  specific  weight >  1.3  g/cm3 (or >  1.2  g/cm3  different from 
plant to plant) which includes the PVC fraction as well. DecaBDE occurs at least occasionally 
in the SLF with concentrations beyond 1000 mg/kg.  

According to POP Regulation (Annex V Part 1), disposal on landfills is not mentioned as a 
permitted option for disposal or recovery.  

Article 7(4) of the POP regulation offers conditions for derogation. As mentioned above, SLF 
(if not further treated e.g., in PST) and PST granulate with a specific weight > 1.3 (or 1.2) 
g/cm3 are occasionally at risk not to comply with the conditions for derogations.  

Shredder fractions containing PBDE are not treated in compliance with the POPs Regulation, 
possibly  leading  to  the  landfilling  of  such  fractions  and  accumulation  of  POPs  in  the 
environment. 

120 Including decaBDE 

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To ensure a consistent implementation of this aspect, it makes sense to introduce a ban on 
the  disposal  of  ELV  post  shredder  fractions  to  landfills  and  a  ban  on  material  recycling  of 
these fractions for  

a) the entire SLF, if not sent for further treatment to PST, and  

b) the output fractions of PST with a specific weight of > 1.3 g/cm3. 

A ban of landfilling and material recycling of these fractions will have different effects:  

If  landfilling  and  material  recycling  is  not  allowed,  the  SLF  (respectively  the  PST  fraction 
mentioned) will be directed to waste incineration (D10) or energy recovery operations (R1) or 
to chemical recycling. Considering the high caloric value of these fractions such treatment is 
energy efficient and all these treatment options are higher in the Waste Treatment hierarchy.  

However, there remains the risk that, if higher costs occur for the waste management of the 
fractions which are banned from landfilling and material recycling, that operators of shredders 
/ PST plants seek to minimise these fractions and direct the POPs to other (non-regulated) 
fractions.  If  landfilling  (and  backfilling)  will  be  banned  for  all  wastes  generated  from  the 
treatment of ELVs this effect can be avoided and make the separate recovery target obsolete 
(i.e., the distinction between landfilling and recovered fractions will no longer be needed).  

It  will  simplify  the  operation  of  the  shredders  as  they  do  not  need  to  prove  that  POPs 
concentrations in the output fraction are below the “upper level” displayed in Annex IV of the 
POPs Regulation.  

On a common disposal ban of untreated shredder residues or of treated shredder residues 
or  of  PST  residues,  which  contain  hazardous  substances,  OVAM  (2022)  think  a  transition 
period of 3 years is necessary. 

Indicative outlook of impacts 

A revised recycling definition (excluding backfilling) and a ban of landfilling / material recycling 
for the mentioned fractions will have relevant effects on the disposal routes e.g., a study121 
on the state of the art of treatment of hazardous substances in plastics and their impact on 
disposal  provides  first  insights  on  the  current  disposal  routes  for  Auto  Shredder  Residue 
(ASR) in Germany:  

• 

“Shredder heavy fraction (SHF):  
o  plastic content of SHF: 3.6-21.8% (1,550-9,400 t);  
o 

recycling: 100% (43,000 t);  

•  Shredder light fraction (SLF):  

o  plastic share of SLF: 28-50% (27,660-49,400 t);  
o  material  recycling  (mainly  as  mineral-rich  fraction  in  mining  backfill  and  landfill 

construction, in small parts mechanical recycling): 54% (15,000-26,660 t);  
•  Energy recovery (waste incineration / RDF): 38 % (10,500-18,70 t) (10.500-18.770 t);  
•  Landfilling: 8 % (2,200-3,950 t)”. 

Expected outcome: Shredder fractions containing PBDE are not treated in compliance with 
the POPs Regulation, possibly leading to the landfilling of such fractions and accumulation of 
POPs in the environment. The ban removes ambiguity as to routes of disposal that comply 
with the POPs Regulation and will lead to treatment of POP containing fractions at a higher 
hierarchy (energy recovery rather than disposal). 

121 Polcher et.al (2020): Sachstand über die Schadstoffe in Kunststoffen und ihre Auswirkungen auf die Entsorgung; Publisher: 
BMU Bundesministerium für Umwelt, Naturschutz und nukleare Sicherheit (Germany).  

by Umweltbundesamt UBA Texte 15/2020 

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2.1.5.4.6  2.4.f)  Revision 

of  Commission  Decision 

2005/293/EC on the circularity aspects 

The  reporting,  performed  according  to  Commission  Decision  2005/293/EC  laying  down 
detailed rules for the monitoring of the reuse/recovery and reuse/recycling targets, does not 
provide sufficient evidence on the recycling rates achieved.  

This is due in particular to the fact that the Commission Decision provides for different (non-
comparable) options for calculating the recycling rate, that Member States do not interpret 
some terms of the Directive in a uniform way and that the current reporting requirements do 
not require information on the PST capacities available in each Member State. 

Considering these aspects, the Commission Decisions should be revised as follows:  

• 

Introduce  a  common  methodology  (in  contrast  to  the  current  situation  where  different 
methodologies  can  be  applied)  for  the  calculation  of  the  reuse  and  recycling  targets, 
making the results comparable across the EU.  

•  Revision of the existing common methodology on how to perform a shredder campaign, 
by  reflecting  on  the  numerous  shredder  campaigns  done  in  the  meantime  and  also 
reflecting  on  the  experiences  in  France,  Belgium  and  the  Netherlands  to  monitor 
continuously the shredder (and sector) input / output. 

•  Provision  of  a  definition  of  Post  Shredder  Treatment  (PST)  including  minimum  quality 
requirements for certain output streams and reporting on established and used capacities 
of such PST plants (see details in section 2.1.5.4.4 above).  

•  Reporting on vehicle fleet and annual registrations and de-registrations is addressed in 

section 2.2.5.1.9 at page 166. 

Most of the above-mentioned aspects are addressed in detail in a proposal for the revision of 
Commission Decision 2005/293/EC which was discussed with the Member States in 2018. A 
report is available to the EC with all detailed comments from the Member States122. 

Depending  on  the  new  measures  proposed  for  implementation,  appropriate  monitoring  of 
progress  towards  other targets  with  the  aim  of  improving  circularity (e.g.,  recycled  content 
targets,  material  specific  recycling  targets  and/or  requirements  for  the  reporting/measur-
ing/calculation points, reporting on components prepared for reuse and/or remanufacturing 
rates, monitoring of PST plants) might also be included in the reporting requirements.  

Expected  outcome:  Harmonisation  of  reporting  method  will  help  clarify  the  possible 
accounting for certain fractions and could help promote practices that lead to higher quantities 
and qualities of recycled materials as well as a higher level of harmonisation between MS in 
the future. Inclusion of monitoring on additional aspects will increase the burden of reporting 
for waste operators.  

2.2  Missing vehicles 

This section addresses unreported and/or illegal treatment of ELVs, unreported and/or illegal 
export of used vehicles or ELVs. 

122 Mehlhart, G.; Hay, D. (2019): Assessment of the comments of the Member States in relation to the draft proposal for the 
amendment of Commission Decision 2005/293/EC, commissioned by the EC DG Environment as an amendment to contract 
No 07.0201/2015/723374/ETU/ENV.A.2.  

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2.2.1  Introduction 

Missing  vehicles  means  that  we  observe  difference  in  the  input  /  output  balance  for  the 
European vehicle park. We know the number of new vehicles placed on the market very well. 
Next, we have information on the size of the vehicle park (the stock), the actual registered 
vehicles. Eurostat provides information on the number of vehicles exported from the EU27 
and  data  (as  reported  by  the  Member  States  to  Eurostat)  on  the  ELVs  treated  in  ATFs. 
Comparing  the  stock  and  the  input/output,  it  is  obvious  that  the  reported  output  does  not 
reflect the total output in reality. As reported in previous studies the gap is between 3 and 4 
million vehicles and the situation has not altered since a decade when the first study for this 
issue was commissioned by the EC. 

The gap might have different reasons: 

•  Not all exported vehicles are reported  
•  Not all ELVs treated domestically are reported 

Other reasons, including the following, are assessed by previous studies as not likely and not 
contributing significantly to the gap:  

•  new registered vehicles are overreported and  
• 
imported used vehicles are overreported 
•  Vehicles are not registered any more (deregistered) and stored (e.g. by car dealers) but 

not exported nor scrapped.  

Regarding  the  stock  (size  of  the  current  EU27  vehicle  park)  it  must  be  said  that  there  is 
evidence that the stock is even overreported (too many vehicles are considered as registered 
e.g. in Poland) and this would even increase the number of missing vehicles.  

More  details  on  the  findings  from  previous  studies  and  the  environmental,  social  and 
economic  concerns  connected  with  the  high  number  of  missing  vehicles  are  provided  in 
section ‘2.2.2 Current situation’. 

The problem of illegal exports shall be assessed in this chapter as well. Illegal export does 
not necessarily contribute to the number of missing vehicles. For example, it is observed that 
a relevant number of vehicles are officially exported even though they are to be considered 
as waste (end-of-life vehicles) according to the guidance prepared by the correspondents of 
the Waste Shipment Regulation123. According to the findings from the evaluation of the End-
of-Life Vehicles Directive, this is not simply a problem of national enforcement, but rather a 
problem of legislation, as the current conditions are not enforceable in practice.  

2.2.2  Current situation 

2.2.2.1  Missing vehicles 

A  number  of  studies  have  assessed  the  issue  of  ELVs  of  unknown  whereabouts.  Each  of 
these studies has had a different focus:  

• 

‘End of life vehicles: Legal aspects, national practices and commissioned recommenda-
tions for future successful approach’ (Schneider et al. 2010), commissioned by the 

123 Used vehicles exported to Africa: A study on the quality of used export vehicles (2020). Netherlands Human Environment 
and Transport Inspectorate, Ministry of Infrastructure and Water Management. available at: 
https://www.ilent.nl/binaries/ilt/documenten/rapporten/2020/10/26/rapport--used-vehicles-exported-to-africa/RAPPORT-
+Used+vehicles+exported+to+Africa.pdf. 

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European Parliament; ‘End of life vehicles: Legal aspects, national practices and 
commissioned recommendations for future successful approach’ (Schneider et al. 
2010), commissioned by the European Parliament; 
‘European second-hand car market analysis’, (Mehlhart et al. 2011), commissioned by 
the European Commission (DG CLIMA); 
‘Compliance promotion initiative to assess the implementation of Directive 2000/53/EU 
on end-of-life vehicles with emphasis on the end of life vehicles of unknown where-
abouts’ (Mehlhart et al. 2017), commissioned by the European Commission (DG ENV). 
‘Supporting the Evaluation of the Directive 2000/53/EC on end-of-life vehicles’ (Williams 
et. al 2020), commissioned by the European Commission (DG ENV). 

• 

• 

• 

All these studies identified shortcomings in the registration and de-registration procedures in 
several countries, making it difficult to identify the correct number of ELVs generated in each 
Member State.  

In the context of the Compliance promotion initiative (Mehlhart et al. 2017), a comprehensive 
stakeholder involvement was included and a discussion of potential measures to overcome 
the problem of missing vehicles.  

In  line  with  the  methodology  applied  for  DG  Environment  in  previous  studies  mentioned 
above, we have updated the detailed input-output flows for 2019 and calculated it for EU-27 
instead  for  EU-28.  As  displayed  in  Figure  2-25,  10.43  million  vehicles  exited  the  stock  of 
registered  vehicles  in  EU-27  (sum  of  the  red,  green  and  yellow  arrows  to  the  right  of  the 
figure), thereof 6.06 million ELVs were treated within the EU, 0.97 million were exported to 
non-EU countries and the whereabouts of 3.4 million vehicles is unknown.   

Figure 2-25  Unknown whereabouts of vehicles (N1 + N1) in the EU -27 in 2019, 
excluding Bulgaria, Cyprus and Malta 

Concept: Oeko-Institut 
Sources: Eurostat: reported ELVs, extra-EU import and export, vehicle stock and new registrations only for BG, CY, MT; 
ACEA: vehicle stock and new registrations (excl. BG, CY, MT) 

The table below displays estimates of how many vehicles are of unknown whereabouts each 
year in the EU. It is apparent that the situation has not substantially altered from 2008 to 2017. 

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Table 2-7  Results of the calculations for unknown whereabouts of vehicles for EU-28 
excl. BG, CY, MT (2008- 2014) and EU27 excl. BG, CY, MT (2015-2019) 

Unknown whereabouts 
in million vehicles 

ELVs treated (Eurostat) 

Share of unknown 
whereabouts of total  

2008 

2009 

2010 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019  

4.1 

3.4 

3.4 

3.8 

3.5 

3.7 

4.7 

* 

3.2 

3 

2.8 

3.4 

6.3  

9.0 

7.4 

6.8 

6.3 

6.3 

6.2 

6.1 

4.8 

5.3 

6.1 

6.1 

39% 

 27% 

32% 

36% 

36% 

37% 

43% 

* 

40% 

36% 

31% 

36% 

Source: 2008-2014 (EU-28): (Mehlhart et al. 2017) 
2016-2019: update for EU27 for this report 
2015: break in series 

Efforts were made to model the amount of ‘missing ELVs’ per Member State (Mehlhart et al. 
2017). This analysis would potentially be very interesting as it would show if Member State 
specific approaches on vehicle deregistration and export, such as those pursued e.g. by the 
Netherlands  (online  deregistration  of  ELVs  (post  CoD),  by  ATFs  and  no  export  without  a 
roadworthiness certificate) were effective. However, the approach was a model calculation, 
which  required  multiple  assumptions  for  each  Member  State  (on  vehicle  stock  and  age  of 
removal etc.) to be made. The results were not felt to be robust enough to demonstrate the 
effectiveness of measures such as those established in the Netherlands and Denmark. 

From this analysis, it appears that the ELVD does not deliver the expected result of ensuring 
that all ELVs are treated according to the minimum requirements established by the Directive. 
To what extent this is an ‘administrative issue’ only and to what extent hazardous liquids and 
components  are  released  into  the  environment  is  not  known.  A  number  of  measures  to 
overcome  these  shortcomings  are  listed  in  the  study  commissioned  by  the  EC  in  2016 
(Mehlhart et al. 2017).  

Article  5(3)  of  the  ELVD  does  not  effectively  ensure  that  the  last  owner  of  the  end-of-life 
vehicle has to deliver it to an ATF in exchange for a Certificate of Destruction (CoD). Article 
5(3) says:  ‘Member  States  shall  set  up  a  system  according to  which the  presentation  of  a 
certificate of destruction is a condition for deregistration of the end-of life vehicle.’ Obviously, 
this  paragraph  is  understood  that  a  CoD  is  one  option  for  deregistration  and  others  might 
apply like export, stolen vehicle or use on private ground. Additionally, several member states 
also apply a kind of ‘indefinite’ off-road notification with automatic deregistration after a certain 
time but without further follow up of change in ownership.  

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ELVs of unknown whereabouts can occur for a number of different reasons, including export 
or  non-reported  treatment  as  displayed  in  Table  2-8.  For  each  of  the  reasons  the  legal 
situation and the environmental concerns are assessed in the following table. 

Table 2-8  Different reasons for ELVs of unknown whereabouts 

Legal situation 

Environmental concern 

Reason for 
unknown 
whereabouts ELV 

Non-reported export 
of used vehicle to 
non-EU-countries 

The export of second-hand vehicles is 
permitted under European law, but 
failure to declare is a breach of the 
obligation to report to the customs 
authorities. 

Non-reported export 
of used vehicle to 
other EU Member 
State 

Export of ELVs to 
non-OCED countries 

In some importing countries, import 
bans apply to used vehicles with 
different characteristics. Thus, 
undeclared exports could also violate 
the regulations of the destination 
country. 

Currently there is no obligation in force 
to report to the vehicle register of origin 
the re-registration in the country of 
destination.  

In the context of the car registration 
procedure there is a request to the 
register of origin if the car is stolen or 
other police information is registered. 
However, this communication is not 
necessarily introduced in the register of 
the country of origin. 

If the used vehicle is near to EoL, 
hazardous components might be 
harming the environment in the 
near future if not treated 
according to the minimum 
requirements applicable in the 
EU. 

No direct environmental concern 
as long as treated in registered 
ATFs and shredders  

Inappropriate treatment of 
hazardous waste might cause 
environmental harm. Illegal 
transfer might cause clean-up 
cost and compensation to the 
receiving country by the country of 
origin 

No concern if the ATF operates 
according to its permits. The risk 
of environmental pollution is 
higher in non-ATFs compared to 
ATFs 

Clear infringement of European law 
(Waste Shipment Regulation). 

No concern if the ATF operates 
according to its permits 

Legal situation in EU differs by MS. For 
most MSs the export is not illegal. 

The risk of environmental pollution 
is higher compared to ATFs 

Unlikely option as the number of vehicles of unknown whereabouts is simply 
too high, vehicles would be visible. 

Source: (Williams et. al 2020) 

2.2.2.2  Intra-EU trade of used vehicles and ELVs 

Trade  statistics  for  intra-EU  trade  on  used  vehicles  are  of  limited  value  as  a  much  of  the 
shipments are not reported according to the reporting thresholds applied for intra EU trade. 
Thus the statistics often underestimate the trade by 50% and more (Mehlhart et al. 2017). 

153 

Non-reported export 
of ELVs to other EU 
Member State. 
Treatment in the 
receiving MS in ATF 
or non-ATF. (Even if a 
CoD is issued, it is 
not forwarded to the 
country of origin.) 

Non-reported 
treatment in ATFs 
(While it would be 
possible, no CoD is 
issued) 

Treatment in not 
authorised treatment 
facilities 

Increase of ELVs / de-
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For the intra EU trade a distinction of ELVs from used vehicles is relevant on the one hand 
for  statistics  but  also  for  the  correct  application  of  shipment  documents  carried  with  the 
transport according to the Waste Shipment Regulation. The criteria must not necessarily be 
the same as the criteria for extra EU export (see below), as the treatment requirements within 
the  EU  are  basically  equivalent.  However,  it  remains  an  enforcement  aspect  as  many 
transports were observed in the past, where vehicles which cannot be repaired in the country 
of origin passed the inner European borders without waste shipment documents. 

2.2.2.3  Definition of end-of-life status 

The current ‘Correspondents Guidelines No 9’ on shipment of waste vehicles to the Waste 
Shipment  Regulation,  defines  criteria  for  the  differentiation  between  second-hand  vehicles 
and ELVs. However, the current ‘Correspondents Guidelines No 9’ is not legally binding.  

Additionally, the findings of the study supporting the evaluation of the ELV Directive (Williams 
et. al 2020) shows, that the current Correspondents’ Guidelines No 9 on shipment of waste 
vehicles is not practical for application by custom authorities and that it needs to be revised 
(e.g. it needs to harmonise the interpretation of terms such as ‘repair at reasonable costs’). 
Furthermore, past efforts indicate that customs authorities are not able to assess each used 
vehicle intended for export since the number of (officially) exported used vehicles of around 
1 million is simply too high to perform the inspection for each of these cars. Available staffing 
capacity is far from sufficient to conduct such inspections, and Customs argues that there are 
numerous other priorities for enforcement by Customs officers. 

Some Member States have established national implementations and enforcements so that 
there are a number of best practices for preventing illegal export of ELVs as used vehicles.  

As of 1 January 2020, following the amendment of the wording of Article 103(1) of the Italian 
Road  Traffic  Act,  the  new  procedure  for  deregistration  following  permanent  export  abroad 
came into force. The cancellation of the vehicle for definitive export abroad must be carried 
out before the actual export. Following the recent amendment to Article 103 of the Highway 
Code  introduced  by  Law  no.  120  of  11/9/2020  (in  force  since  15/9/2020),  it  is  no  longer 
required  that  the  vehicle  has  been  inspected,  with  a  positive  outcome,  at  least  6  months 
before the date of the request for cancellation. The new provisions stipulate that, at the date 
of the cancellation request, the vehicle must have a valid roadworthiness test. 124 

Austria issued a decree in 2015 that for the export of vehicles that are not roadworthy and 
operationally safe, the exporter need to demonstrate either an expert opinion or a domestic 
"certificate on the reparability of a vehicle" to prove that it is not an end-of-life vehicle.125 

Ireland has issued in 2019 the 3rd version of a guidance for exporters and customs authorities 
and  has  set  out  some  procedures  for  the  enforcement  of  Guidance  Note  9  of  the  Waste 
Shipment Regulation. The exporter must provide either a National Car Test (NCT) certificate 
or a specific certificate for used vehicles (or used spare parts for vehicles) showing that they 
are in working order. These documents must be prominently displayed on the outside of the 
vehicle (or spare part) in question, without the need to unpack any items. If a vehicle's NCT 
certificate  has  been  expired  for  more  than  two  years,  the  vehicle  is  considered  waste. 

124 Home page ACI: https://www.aci.it/i-servizi/normative/codice-della-strada/titolo-iii-dei-veicoli/art-103-obblighi-conseguenti-
alla-cessazione-della-circolazione-dei-veicoli-a-motore-e-dei-rimorchi.html, accessed 3 February 2022 

125 Österreich: Erlass zur Altfahrzeugverordnung Stand: April 2015 https://www.wko.at/service/umwelt-energie/Erlass-
AltfahrzeugeVO-Stand-April-2015.pdf  

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Vehicles  for  which  a  Certificate  of  Destruction  (CoD)  has  been  issued  are  automatically 
classified as waste.126 

2.2.2.4  Extra-EU export of used vehicles and ELVs 

As long as an exported used car or (illegally) exported end-of-life vehicle is reported in the 
statistics, its fate is no longer unknown.  

However, the export of used vehicles might be problematic as: 

• 

•  ELVs might be falsely declared as used vehicles. The extra-EU export of ELVs to non-
OECD countries is illegal127. If such export of ELVs is detected, exporting countries 
might be responsible for (environmental) damages caused and obliged to take back 
such vehicles at their own cost. 
If not limited at all, the export of (old) used vehicles will cause in the receiving countries 
a higher volume of (hazardous) waste per use (km driven) compared to the import of 
new (or younger used) vehicles. Developing countries are not necessarily prepared to 
handle such waste in an environmental sound manner.  
Import of (old) used vehicles possibly without roadworthiness certificate or with not 
functioning exhaust treatment (dismantled catalytic converters) delays the effects of 
more advanced emission standards and health risk for the population in the receiving 
countries persist for a longer period. 

• 

•  The importation of (old) used vehicles delays the introduction of advanced road safety 
equipment in receiving countries, and as a result, unnecessary injuries and fatalities in 
accidents continue to occur.  

•  Last but not least, resources recovered through reuse and recycling are lost for the EU.  

As recently reported by two studies128,  129 80 percent of the investigated exported vehicles 
were  below  Euro  4  emission  standard  and  most  of  the  vehicles  did  not  have  valid 
roadworthiness  certificates  or  fail  to  comply  with  the  emissions  standard.  For  instance, 
catalysts were dismantled before export. The majority of export vehicles to African countries 
are older than ten years and the peak is between sixteen and twenty years. The Dutch study 
concludes: “The desk study shows that the group of vehicles exported to West Africa is quite 
similar to the group of vehicles dismantled in the Netherlands concerning age, euro emission 
class,  and  mileage.”  In  result  these  vehicles  contribute  to  critical  air  pollution  and  to  a 
decrease  in  road  safety  in  developing  countries.  More  findings  of  these  studies  about  the 
current characteristics of the export of used vehicles are displayed in in Section 6.5.1 “Facts 
on extra EU Export” in Annex 1. 

The same studies investigated in the status of import regulations of countries receiving used 
vehicles. When looking for the most relevant export markets (of used vehicles) for the EU, 
Africa  and  Eastern  Europe,  the  Caucasus,  and  Central  Asia,  5  countries  out  of  82  have 
established an import ban for used vehicles. 17 importing countries have defined a minimum 
level regards the emission standard and 28 importing countries have established age limits 
for the import of used vehicles.  

126 Dublin City Council / National Office TFS (October 2019) A GUIDE FOR THE SHIPMENT OF USED VEHICLES, USED 
VEHICLE PARTS AND USED ELECTRICAL AND ELECTRONIC EQUIPMENT: Version 3 

127 According to the Basel Convention and the Waste Shipment Regulation 

128 Baskin, J. et al. (2020), Used vehicles and the Environment. A Global Overview of Used Light Duty Vehicles: Flow, Scale 
and Regulation, published by United Nations Environment Programme (UNEP), 10/2020 

129 Netherlands Human Environment and Transport Inspectorate, Ministry of Infrastructure and Water Management (2020): 
Used vehicles exported to Africa: A study on the quality of used export vehicles 

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After  the  completion  of  the  above-mentioned  studies  the  Economic  Community  of  West 
African States (ECOWAS130) adopted on 5 September 2020 a Directive131, limiting the import 
of  used  vehicles  to  those  with  a  minimum  Euro  4/IV  emission  standard.  The  age  limit  for 
importing vehicles into the ECOWAS region is 5 years for light duty vehicles, two-wheel motor 
vehicles, tricycles and quadricycles and 10 years for heavy-duty vehicles. A period of 10 years 
is granted to countries that have not yet adopted these age limits to gradually comply. In result 
11 additional countries introduced import limitations for the first time and another 4 countries 
increased the level of limits.  

Table  2-9  below  displays  the  number  of  receiving  countries  in  total  and  the  number  of 
countries which have an import ban, very good, good, or at least any regulation in force for 
the import of used vehicles. In addition, it displays in the last column to the right the share of 
vehicles exported to these countries.  

The conclusion is that 43 receiving countries in Africa, Eastern Europe, the Caucasus, Central 
Asia and Middle East have an import ban, very good or good regulations in force and these 
countries represent 55% of the exported used vehicles from the EU27 in 2020. 

Table 2-9  Share of used vehicles exported in 2020 from EU-27 to differently 
regulated countries 

Countries  mentioned 
as destination 

Share of the total number 
of EU-27 export in 2020 

Total  export  to  Africa  and  Eastern  Europe,  the 
Caucasus, Central Asia and Middle East 

Ban of import of used vehicles 

Good, very good regulated or the import of used 
vehicles is banned (UNEP 2020) 
Good, very good regulated or the import of used 
vehicles is banned (UNEP 2020) + ECOWAS 
Countries 
At least any regulation for the import of used 
vehicles by age or emission class (including 
ECOWAS Countries) 

82 

5 

29 

43 

59 

91% 

0.4% 

29% 

55% 

82% 

Source: UNEP 2020; Eurostat: COMEXT (download 27.1.2022); for more details see section 6.5.1 “Facts on extra EU Export” 
in Annex 1.  
Very good (UNEP 2020): a used LDV Euro 5 or more emission standard adopted and / or age limit of 3 years or below; 
Good (UNEP 2020): a used LDV Euro 4 emission standard adopted and/or age limit of 4 or 5 years. 

More details regard the import regulations in the receiving countries are displayed in Section 
6.5.1.2 “Regulations for the import in receiving countries and share of used vehicles directed 
to these countries” in Annex I.  

In  the  context  of  the  stakeholder  involvement,  the  representatives  of  UNEP  and  UNECE 
explained that it is difficult to the receiving countries to enforce the import limitations as it is 
(most) likely that each imported vehicle will find its market in the receiving countries. Thus, 
cooperation and support by the exporting countries is required to support import limits. 

130 Members of ECOWAS: BENIN, BURKINA FASO, CABO VERDE, CÔTE D'IVOIRE, The GAMBIA, GHANA, GUINEA, 
GUINEA BISSAU, LIBERIA, MALI, NIGER, NIGERIA, SENEGAL, SIERRA LEONE, TOGO 

131 Directive C/Dir.2/09/20 relating to the harmonization of the limits of gas and exhaust particle emission for light and heavy 
vehicles, two wheel vehicles, tricycles and quadricycles within the ECOWAS region. 

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2.2.3  What is the problem and why is it a problem? 

2.2.3.1  Description of the problem 

As outlined in the previous chapter on the current situation in section 2.2.2, the whereabouts 
of around 30 % to 40 % of the M1 and N1 vehicles is not known. They might be exported 
without  reporting  to  the  customs  authorities  or  treated  without  reporting  to  the  registration 
authorities  or  simply  dumped.  To  date  it  is  not  possible  to  assess  whether  all  ELVs  are 
directed to authorised treatment facilities (ATFs) or not. Instead, there are concerns about 
environmental  impacts,  losses  of  potential  recyclables  if  not  directed  to  legal  treatment 
facilities,  economic  losses  for  the  formal  sector,  and  social  impacts  for  informal  sector 
workers.  

In  this  respect,  the  problem  is  not  a  unique  (partial)  aspect  where  it  is  possible  to  assess 
which  metrics  (e.g.  economic  losses,  negative  environmental  impacts)  are  caused  by  the 
problem. It is rather a general problem that currently for 30 to 40% of the vehicles it cannot 
be proven whether the European legislation is applied or not.  

Additional environmental and social risks exist for the countries of destination in the event of 
illegal export from the EU.  

2.2.3.2  Description of the problem drivers 

The problem is caused by manifold reasons: 

•  Market  failure/  Regulatory  failure:  In  many  Member  States  vehicle  owners  have  no 
benefits and no penalties apply if the vehicle is scrapped without sending a CoD to the 
registration authorities.  

•  Regulatory failure: Several Member States apply a system of temporary deregistration, 
often in combination with an automatic deregistration after a certain number of years. In 
combination  with  unregistered  transfer  to  the  next  owner,  it  is  difficult  to  track  vehicle 
ownership in the registers. 132.  

•  Behavioural  Biases:  Vehicle  owners  are  not  aware  that  it  is  important  to  inform  the 

vehicle register if they export a vehicle. 

•  Regulatory  failure:  Repair  costs  differ  across  Europe.  Damaged  or  old  cars  are 
transferred to MS with cheaper repair cost. At the country of destination not all transferred 
vehicles  are  repaired,  but  several  are  used  for  spare  parts  only  (=ELV).  In  result  the 
shipment  
o 

(used) vehicles become ELVs but are not reported to the vehicle register in the MS of 
origin (absence of information sharing between EU MS), 

o  did not comply with the stipulations of the Waste Shipment Regulation.  

132 For instance in Germany, motor vehicles can be decommissioned by deregistration. Since March 1, 2007, this official act 
has been called " Außerbetriebsetzung" (decommissioning). In addition to the name, the period has also changed, and is now 
7 years. The official seal is removed from the license plates when the vehicle is taken out of service. Only after the 7 years 
have expired does the operating license expire and the registration certificate part II (formerly: vehicle letter) loses its validity. 
A full expert opinion (e.g. from TÜV or Dekra) is then required for re-registration. If the vehicle is re-registered within 7 years, 
proof of a valid roadworthiness inspection is sufficient. The roadworthiness inspection is therefore only due if it was required 
within the out-of-service period. Further requirements for re-registration: Neither the owner nor the registration district may 
have changed. As mentioned in “Jahresbericht Altfahrzeuge 2019 (Umweltbundesamt 2021) 9.325.269 vehicles are reported 
for "Außerbetriebsetzung" (temporary or not temporary) and 3.117.208 thereof are considered as permanently deregistered, 
the last based on a study for the year 2017. Insofar the figure for the permanently deregistered vehicles is not known from 
registration/statistics, but derived by studies and assumptions only.   

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•  Regulatory failure: as mentioned by EuRIC and some Member States in the context of 
the Evaluation of the ELV Directive (see Report published in 2020), insurance companies 
apply auctions for the residual value of individual vehicles but also bulk auctions with a 
mix of several damaged vehicles. Many of these vehicles are total economic losses or 
even  total  technical  loss.  Most  insurers  do  not  verify  that  such  vehicles  are  delivered 
exclusively  to  ATFs  and  that  CoDs  are  issued  for  vehicles  with  economic  total  losses 
respectively  total  technical  loss.  It  might  be  connected  to  the  principle  agent  problem. 
While the issue was regularly highlighted by stakeholders of the ATF sector as a relevant 
aspect  no  detailed  data  on  the  volume  of  vehicles  dealt  with  such  (bulk)  auctions  is 
available. 

•  Regulatory  failure:  No  obligation  applies  to  ATFs  to  issue  a  CoD  and  send  it  to  the 
registration  authorities  of  the  Member  State  where  the  ELV  was  last  registered 
(respectively to a central point of the national register).  

•  Market  failure/  Regulatory  (enforcement)  failure:  For  legal  and  illegal  garages,  not 
being ATFs, it is economically attractive to make use of spare parts of ELVs and dismantle 
the ELV for direct shredding without passing an ATF and without issuing a CoD. 

•  Regulatory  failure:  No  obligation  exists  that  used  spare  parts  can  be  offered  to  the 

market only by demonstrating the origin of that part (VIN and CoD). 

•  Regulatory  failure:  Shredding  facilities  are  not  obliged  and  not  willing  to  check  if 
depolluted,  dismantled  (and  compressed)  vehicles  are  de-registered  and  if  a  CoD  is 
issued accordingly. Shredding facilities also accept shear scrap that contains (parts from) 
end-of-life vehicles without asking where the scrap came from.  

•  Market  failure/  Regulatory  (enforcement)  failure:  A  demand  exists  in  developing 
countries  for  used  vehicles  from  EU  and  prices  paid  by  the  final  users  of  such  used 
vehicles are higher than the prices paid in EU. Inspection capacities and enforcement of 
environmental  requirements  are  weak  in  many  developing  countries.  In  result  the 
environmental and road safety standard (as defined in the type approval) are not enforced 
accordingly.  

•  Regulatory failure: For the purpose of cross border trade, distinction of used vehicles 
and  ELVs  is  defined  by  a  ‘Correspondence  guidance  No  9’.  Member  States  are  not 
obliged to apply this guidance. Customs services in the Member States do not have the 
capacity (it is unrealistic to have such capacity) to apply the guidance for each vehicle.    

2.2.3.3  Key players and affected population 

In the following we identify roughly the key players and first assumptions by what and how 
they are affected. More detailed economic, environmental and social impacts for the listed 
stakeholders are discussed and displayed in section 3.2. 

• 
Illegal garages might cause environmental pollution and might employ staff informally.  
•  ATFs compete with illegal garages and illegal exporters – which may be capable to pay 

higher prices as they do not comply with all legal requirements.  

•  Citizens, not taking due care what is happening to their vehicle might receive higher prices 

• 

for their ELV when it is sold to non-ATFs.  
Insurances might get higher residual revenues for vehicles with total economic loss if they 
do not care who buys a vehicle with total economic loss. 

•  Due to illegal export and treatment by illegal and legal garages not being ATFs the ATFs 
have  less  turnover  than  expected  and  ATFs  business  might  be  less  profitable  /  not 
profitable. 
Illegal export limits the turnover of shredders and the generation of recyclable fractions. 

• 

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•  Companies  shipping  used  vehicles  to  another  EU  Member  State  or  to  third  countries, 
which sometimes derive important revenues from this activity which would be affected by 
export restrictions. 

2.2.3.4  Why should the EU act? 

The overarching problem of not being able to demonstrate that 30-40% of ELVs are treated 
in  accordance  with  ELVD  requirements  calls  into  question  the  success  of  ELVD.  For  the 
future,  ATFs  and recyclers fear that  the  informal  sector  will  a  fortiori  fail  to meet  the  more 
demanding  requirements  outlined  in  the  circular  economy  section,  thus  jeopardizing  the 
circular economy aspects addressed in the ELVD revision.  

At least since 2011, the problem of missing vehicles has been well known to member states, 
and  the  issue  has  been  prominently  addressed  at  numerous  meetings  and  conferences. 
However, the problem has not changed and continues to jeopardise the objective of the ELV 
Directive  that  all  end-of-life  vehicles  should  be  depolluted  and  dismantled  in  ATFs  in 
compliance with the minimum requirements of the ELVD.  

In the study for the European Commission (Mehlhart et.al 2017), various measures to address 
the  problem  were  outlined  and  discussed  with  stakeholders.  In  this  context,  almost  all 
stakeholders were in favour of action at the EU level. 

As demonstrated in the past MS fail to address the issue by themselves and regards intra 
EU-cross  border  trade  (e.g.  definition  of  ELV  and  cross-country  reporting  obligation  and 
cooperation Member States cannot solve the problems by themselves.  

Last but not least the aspect of exports of ELVs or used vehicles with similar characteristics 
than ELVs to non-OECD countries is an issue which cannot be addressed at national level 
but at level of the European Union (as a trade union) only. 

2.2.4  Which objective should be achieved? 

The objectives are directly converting the problems to a positive perspective as displayed in 
Table 2-10 below.  

Table 2-10 General Problems and related Objectives 

• No proof that all ELV generated are treated according to minimum technical and environmental 

requirements;

Problem in the 
Member State

• Economic losses for the formal sector, and social impacts for informal sector workers; 
• Concerns that (a part of) recyclables are lost if not directed to legal facilities, including concerns that 
the informal sector will not comply with more challenging requirements as outlined in the section  on 
circularity

• Evidence available that all ELVs are treated according to minimum technical and environmental 

requirements;

• ELVs are being fed into the formal sector, and the informal sector is being pushed back . This 

contributes to better treatment in particular if more chanllenging objectives shall be achieved as 
discribed under the related Circularity chapter. 

Specific 
Objective 1

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• Difficult distinction between used vehicles and ELVs causing problems in 
the application of the WShipR and responsibilities of the last owner (e.g. in 
case of total loss)

Problem from 
intra EU trade

• Improved traceability in the shipments of used cars and ELVs to ensure 
that vehicles are not shipped to another MS for the purpose of 
dismantling them in breach of the EU legislation
• Clear and practical appilcable defintion of ELV is in force and applied.
• The proximity principle (Art 16 of WFD) for the treatment of ELVs is 
applied, cross border shipment of ELVs is applied in case of technical 
need only; 

Specific 
Objective 2

•Environmental health and social risks for the countries of 
destination caused by (old) used vehicles imported;
•Financial risks for the Member States of origin in the event of a 
complaint by the recipient country (WShipR). 

•No (non-depoluted) ELVs are exported to non OECD countries; 
Rules of the Basel Convention and WShiR applied
•No used vehicles exported which would generate environmental 
adverse impacts in the receiving countries 

Problem from 
extra EU trade

Specific 
Objective 3

Source: Own illustration 

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2.2.5  What are potential measures to achieve the objective? 

In  the  following  we  will  introduce  and  explain  measures  addressing  the  above-mentioned 
objectives.  Subsequently  we  will  conduct  a  first  initial  assessment  on  effectiveness  and 
feasibility with the result that some of the measures are considered as inevitable, others are 
discarded or kept at the agenda for later consideration. 

2.2.5.1  Potential measures to achieve Specific Objective No 3.1: 
Ensure that  all  ELVs  are  treated  in  accordance with  the 
requirements of the ELV Directive  

2.2.5.1.1  Provide economic incentives for the last owner of 
an  end-of-life  vehicle  to  deliver  it  to  an  ATF  and 
report  the  certificate  of  destruction  (CoD)  to  the 
administration 

The EU legislation may require Member States to ensure that there are economic incentives 
for the last owner of an end-of-life vehicle to deliver it to an ATF and receive a CoD in return.  
Tree alternative options might apply for such incentives:  

a)  Link the (end of the) payment of insurance133 schemes to provision of CoD;  
b)  Link the end of administrative fees to provision of CoD; 
c)  Member States set up other financial incentives (premium / pay out) for last owners 

to hand over ELVs to ATFs, possibly as part of EPR scheme. 

We distinguish to levels regards this measure: 
Level A:  Member States shall report on incentives in force to strengthen the effectiveness 
of the CoD. Level A is considered as a low level of intervention, driving attention to 
this kind of instruments. 

must 

demonstrate 

Level B:  Member States shall demonstrate that they implemented one of the three options 
above. If a Member State wishes to choose alternatives to the above two options, 
it 
effectiveness.  
The  reasoning  for  this  option  is  that  detailed  regulations  for  insurances  or  the 
details of administrative fees (what level and by when they start and end) and also 
premium pay out systems are typically considered as objects of subsidiarity. Insofar 
it is not possible and not meaningful to establish detailed rules which and how such 
incentives  are  applied.  Instead,  the  Member  States  have  more  choices  to 
implement  the  most  appropriate  for  their  national  system,  but  at  least  some 
measures (not explicitly specified) of equal effect to the listed shall be established. 

better 

equal 

or 

Comment to Option a) and b) other options to terminate an insurance against civil liability in 
respect of the use of motor vehicles might be Demonstration of an export-sales contract or 
statement  that  the  vehicle  is  used  exclusively  on  private  property.  There  is  a  risk  that 
fraudulent  contracts  are  presented  to  the  insurance  companies  and  the  vehicle  is  instead 

133 DIRECTIVE 2009/103/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 16 September 2009 relating to 
insurance against civil liability in respect of the use of motor vehicles, and the enforcement of the obligation to insure against 
such liability 

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delivered to an illegal dismantler at a higher profit than if offered to an ATF. Such cases are 
known  for  the  Netherlands134  where  the  assumption  is  that  around  30  000  ELVs135  are 
reportedly exported but remain in the Netherlands and are treated in substandard treatment 
facilities instead. This demonstrates that a mix of measures is required and not one measure 
alone can address the general issue of missing vehicles.  

Comment to Option c) 
as demonstrated above the level of such premium is in Norway and Denmark around € 300 
and the German study confirmed that the illegal sector has higher benefits compared to ATFs 
of about 250 € to 300 € per ELV. As long as the premium is too low, it will not have a sufficient 
effect as demonstrated in Figure 6-20 at page 626.  

In  2019  the  French  ADEME  published  a  comprehensive  report  on  a  global  overview  of 
incentive  schemes  aiming  to  bring  ELVs  through  authorised  processing  channels136.  The 
report describes in detail the systems in Denmark, the Netherlands, in Spain and the Czech 
Republic.  
Reportedly there was a reflection conducted on an implementation of a bonus for the recovery 
of ELV in legal sector (to compensate for the gap of economic competitiveness with illegal 
sector). France did not establish such bonus due to a lack of consensus on its funding137 

134 Janet Kes & Pieter Kuiper (2016): De-registration and monitoring of ELV’s in NL; Presentation at the STAKEHOLDER 
WORKSHOP organised by the EC: ASSESSMENT OF THE IMPLEMENTATION OF DIRECTIVE 2000/53/EU ON END-OF-
LIFE VEHICLES (THE ELV DIRECTIVE) WITH EMPHASIS ON THE END-OF-LIFE VEHICLES OF UNKNOWN 
WHEREABOUTS; Date: 21 November 2016 

135 In average for 2015 – 2019 the Netherlands report 190 000 ELV generated. Following this assumption 30 000 more are 
treated in the Netherlands (= ca. 15%).  

136 ADEME (Eric LECOINTRE), Deloitte Développement Durable (Alexis LEMEILLET, Radia BENHALLAM, Antoine HENRY, 
Marie FILLION, Rafael BASCIANO), In Extenso Innovation Croissance (Victoire ESCALON, Beatriz BERTHOUX). 2019. 
Final report: Global Overview of Incentive Schemes aiming to bring ELVs through Authorised Processing Channels. 119 
pages. 

137 Meeting of the expert group on waste on 1 June 2018 Directive 2000/53/EC on end-of-life vehicles (ELV):  

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2.2.5.1.2  Alignment of the terms of the ELV Directive with the 
terms  of  Directive  1999/37/EC  on  registration 
documents  

“Registration” shall be used in compliance with Directive 1999/37/EC, Article 2: “registration” 
shall mean the administrative authorisation for the entry into service in road traffic of a vehicle, 
involving the identification of the latter and the issuing to it of a serial number, to be known as 
the registration number. 
Comment: the term is needed in the context of the reporting on the national vehicle park / 
fleet.  

“Suspension” shall be used in compliance with Directive 1999/37/EC, Article 2: “suspension” 
means a limited period of time in which a vehicle is not authorised by a Member State to be 
used in road traffic following which – provided the reasons for suspension have ceased to 
apply– it may be authorised to be used again without involving a new process of registration. 
Comment: A suspension is initiated by the competent authorities of registration of a Member 
State for any reason, for instance if a vehicle does not comply with vehicle requirements for 
use  on  public  roads.  The  term  might  be  needed  for  the  completeness  of  reporting  on  the 
national  vehicle  park. It  is  also  mentioned  here for  completeness (and  distinction  from  the 
other terms). 

“Cancellation  of  a  registration”  shall  be  used  in  compliance  with  Directive  1999/37/EC, 
Article  2:  “cancellation  of  a  registration”  means  the  cancellation  of  a  Member  State’s 
authorisation for a vehicle to be used in road traffic.  
Comment: we need this term for the list of conclusive reasons for (permanent) cancellation. 
In the discussion the term of ‘(permanent) deregistration’ is often used as synonym for the 
same  purpose.  However,  as  the  term  permanent  cancellation  of  a  registration  is  already 
established in Directive 1999/37/EC138 it is meaningful to make use of the existing definition 
and avoid confusion in the future. 

2.2.5.1.3  Introduction  of  new  definition: 

“temporary 

deregistration”  

“Temporary deregistration”: based on a request (not ex officio) of the vehicle holder and/or 
owner a vehicle is temporarily not permitted to be used in road traffic. 
Comment: The definition was discussed by DG ENV with DG MOVE and proposed by DG 
MOVE in 2016/2017. The explanation “not ex officio” expresses that it is not an authority but 
e.g. the owner/holder of the vehicle which asks for a temporary deregistration. Insofar it is 
different from the term suspension. The term “temporary deregistration” is mentioned in recital 
17 of the current ELVD139. However, the term not addressed in any article of the current ELVD 
nor is the term defined in the current ELVD. “Temporary deregistration” is typically applied by 

138 Directive 1999/37/EC Article 3a(3): ‘In the event that the competent authority of a Member State receives notification that a 
vehicle has been treated as an end-of-life vehicle in accordance with Directive 2000/53/EC of the European Parliament and 
of the Council ( 1 ), the registration of that vehicle shall be cancelled permanently and information to that effect shall be 
added to the electronic register.’ 

139 DIRECTIVE 2000/53/EC, recital (17): ‘This Directive does not prevent Member States from granting, where appropriate, 
temporary deregistrations of vehicles.’ 

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dealers when they keep used vehicles on private grounds before selling them but also can 
be applied by private person for any reason defined in the national legislation. It is necessary 
to  define  the  term  as  it  is  necessary  to  define  some  obligations  for  the  owner  /  holder  of 
vehicles during the time of temporary deregistration.  
In absence of a well-defined term, the term (temporary/ indefinite) off-road notification is often 
used as synonym for (temporary/ indefinite) deregistration. 

2.2.5.1.4  Introduce at EU level a conclusive list of conditions 
for  permanent  cancellation  of  the  registration 
including  regulations  for  how  to  apply  “temporary 
de-registrations”  (and  in  addition  to  cars  that  are 
deregistered after COD)140  

Conclusive list of reasons for permanent cancellation of the registration141:  

a)  CoD submitted to national vehicle register,  
b)  Submission of a police report demonstrating that the vehicle is stolen and missing,  
c)  Documents demonstrating that the vehicle is exported,  
d)  Exemptions upon specific request: e.g. a vintage vehicle is stored in a (private) kind 
of  Museum:  accompanying  documents  demonstrate  the  conditions  where  and  how 
the vehicle is stored. 

Management of temporary deregistration: 

i. 

ii. 

Prohibition  of  “automatic”  permanent  cancellation  of  the  registration  after  a  certain 
period of temporary deregistration (or (indefinite) off-road notification).  
The  use  on  private  ground  shall  not  be  a  reason  for  permanent  cancellation  of  the 
registration but it shall fall under temporary deregistration. 

iii.  Require  the  owner  of  a  vehicle  to  report  changes  in  ownership  to  the  registration 

iv. 

authority during temporary deregistration. 142 
A monthly administrative fee (at minimum to recover the related administrative effort) 
is charged for the entire duration of the temporary deregistration. 

By legal reasons not all of the above-mentioned aspects might be not regulated by the new 
ELV Regulation but by other revisions as for instance in the context of the Roadworthiness 
legislation under DG MOVE supervision.  

If  so,  it  might  be  an  option  to  establish  in  the  new  ELV  Regulation  at  least  a  requirement 
Alternatively,  a  requirement  could  be  established  for  the  owner  of  a  vehicle  which  is 
“temporarily de-registered” to report changes on the ownership of the vehicle in question to 
the  registration  authority.  The  owner  of  such  vehicles  should  provide  information  on  the 

140 Elements to be considered:  

Criteria for a MS to apply permanent cancellations of registrations - a) Certificates of Destruction (CoD), b) proven export of a 

vehicle, c) proven theft of a vehicle, d) official declaration from the owner that the vehicle is no longer available for re-
registration 

141 The current Directive 2000/53/EC refers constantly to the undefined term “deregistration”. To be consistent with the 
proposed definitions in the text box here the term “permanent cancellation of the registration” is applied. 

142 The owner of such vehicles should provide information on the details of the new owner, so that this new owner can be 
clearly identified and recorded in the national register of the country where he is established. The aim of this measure is to 
avoid that vehicles which are “temporarily de-registered” are transferred to owners who would dismantle or export it illegally. 

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details of the new owner, so that this new owner can be clearly identified and recorded in the 
national register of the country where he is established.  

The aim of this measure is to avoid that vehicles which are “temporarily de-registered” are 
transferred to owners who would dismantle or export it illegally. However, if such (separated) 
clause shall be established in the new ELV Regulation it is necessary to establish at the same 
time the definition for “temporary deregistration” as described in the chapter before. For the 
purposes of the Impact Assessment dealt with later in this report, all proposals in this section 
will be taken into account, regardless of the area of law in which they are implemented. 

2.2.5.1.5  Obligations for dismantlers /recyclers to check and 

report on ELVs / CoDs 

Requirement  that  ATFs  issue  a  CoD  for  each  dismantled  vehicle  through  an  electronic 
notification procedure to the registration authority along with the delivery of the CoD to the 
last owner (hardcopy or electronic statement).  

Obligation  for  shredders  to  not  accept  bulks  of  vehicle  carcasses  or  shear  scrap  that 
apparently comes from end-of-life vehicles without accompanying copy of CoDs. Shredders 
should be able to assess the VIN number at the delivered bulks (as it is the regulation in the 
Netherlands). 

2.2.5.1.6  Improve  the  exchange  of  information  between 
national registration authorities including obligation 
for MS to provide reasons for de-registration. 

a)  Member States shall include information in their national register on the reasons for 

which a vehicle is permanently removed from their register, and make this information 
accessible to other MS.  
These reasons shall be limited to: 

 Dismantling of a car considered as an ELV at an Authorized Treatment Facility 
(ATF), upon presentation of a Certificate of Destruction (CoD); 
 export of a vehicle, upon presentation of relevant export document; 
theft of a vehicle, upon presentation of police report; 
Exemptions upon specific request: e.g. a vintage vehicle is stored in a (private) 
museum 

b)  Establishment of an electronic notification procedure between MS when a CoD is issued 

for a vehicle last registered in another Member State. The MS where the CoD is issued 
but the vehicle was not registered (respectively not registered the last) is obliged to 
inform the Member State where the vehicle was last registered. MS shall jointly 
establish a data exchange, making it possible to submit such information and to search 
by VIN for a vehicle, when the last owner (respectively country where the vehicle is 
been registered last), cannot be detected from accompanying (respectively missing) 
registration documents 

c)  Set up an obligation for Member States authorities to provide access to their national 

registers respectively make available to authorities (e.g. registration authorities, customs 
services, police) in all other Member States to verify information on vehicles 
registered/de-registered from their register, including the motives of vehicle de-
registration.  
This would allow authorities in one Member State to retrieve information pertaining to 
one vehicle present on its territory and check what its status is in another Member State. 
This would also increase traceability of vehicles which are moved in large number 

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between Member States during their use phase and sometimes for the purpose of their 
dismantling at their end-of-life phase. This is key for the purpose of reducing the number 
of “missing vehicles”, but also for the functioning of “extended producer responsibility 
schemes” whereby car manufacturers would assume additional obligations for the 
dismantling of end-of-life vehicles, including where these ELVs are treated in a MS 
different from the one where the vehicle was first put on the market. Exchange of 
information should be made possible through the use of the Vehicle Identification 
Number (VIN) and provide information on the brands of the vehicles concerned.  

The  aim  of  these  measures  is  to  increase  transparency  on  the  de-registration  of  vehicles, 
which is a serious obstacle today to track “missing vehicles”. This information should also be 
directly accessible by national authorities responsible for the implementation of the EU rules 
on end-of-life vehicles. 

By legal reasons not all of the above-mentioned aspects might be not regulated by the new 
ELV Regulation but by other revisions as for instance in the context of the Roadworthiness 
legislation under DG MOVE supervision. 

For the purposes of the Impact Assessment dealt with later in this report, all proposals in this 
section  will  be  taken  into  account,  regardless  of  the  area  of  law  in  which  they  are 
implemented. 

2.2.5.1.7  Include  Vehicle  Identification  Number  (VIN)  in 

customs declaration  

For extra-EU export: registration of the exported vehicle VIN and obligatory information of the 
MS  of  origin  (the  MS  where  the  vehicle  was  last  registered)  on  the  export.  This  measure 
enables spot checks / cross checks between the export files and the vehicle registers e.g. 
whether  the  vehicle  is  already  considered  waste  (CoD  issued),  mentioned  as  stolen  or 
regards  information  on  the  emission  level  /  age  /  roadworthiness  certificate  as  far  as 
registration paper are not accompanying the export of the vehicle. Once digitalisation is more 
advanced and interfaces between the export data and registration data are available the cross 
check can be done as standard procedure.  

2.2.5.1.8  Establish EU vehicle registration database-system 

Either  extract  /  link  to  the  national  registers  or  build  up  a  new  database,  with  the  aim  to 
generate  a  data  base  which  can  address  the  complete  life  phase  of  each  single  vehicles, 
including first registration of new vehicles, import to EU of used vehicles, change in ownership 
across  EU,  temporary  deregistration  (off  road  notification)  including  change  of  ownership 
during  this  phase  export,  extra  EU  export  of  used  vehicles,  permanent  cancellation  of  a 
registration,  proof  of  depollution  and  recycling  by  CoDs.  In  addition,  there  are  aspects 
registered such as stolen vehicle, economic total loss of the vehicle, technical total loss of the 
vehicle and the status of the roadworthiness certificate. 

2.2.5.1.9  Improve  reporting  obligations  on 

the  current 

vehicle market and the ELVs on their territory 

The current mandate in the ELV Directive does not explicitly require Member States to report 
on the vehicle fleet and the details of changes in the vehicle fleet.  

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The current Commission Decision 2005/293/EC (2005/293/EC 2005) requires the Member 
States to complete the tables 1-4 and to report in addition on “the current national vehicle 
market and the end-of-life vehicles on their territory”. However, this last aspect is not detailed 
further  in the  Commission  Decision.  Eurostat’s  guideline143  tries to  specify details  on  what 
shall be reported under this aspect; however, Eurostat’s guideline is not legally binding and 
only a minority of Member States have replied according to the proposed approach.  

Since  reporting  on  the  national  vehicle  stock  and  changes  in  stock  is  a  prerequisite  for 
verifying that all ELVs are transferred to ATFs, such a mandate should be introduced in the 
Directive/Regulation. The aim is to overcome the current situation where currently for 30-40% 
of the vehicles it is not possible whether they are treated according to the requirements of the 
ELVD. Today reporting on the stock is not harmonised and guided by an informal Eurostat 
document  only.  To  improve  the  reporting  with  this  regard  it  is  important  that  the  diverse 
national Ministries necessarily involved in such reporting are encouraged to cooperate. As 
the current stipulations are not that concrete for instance the Ministries of interior (or transport) 
often  ignore  the  request  of  the  Ministries  of  environment  to  support  them  in  the  reporting. 
When the reporting obligations become more concrete by this measure, the need for national 
and international cooperation becomes more evident.  

The details could be implemented through an Annex (if agreed upon in time) or delegated act 
(if more time is needed for preparation). 

The proposal for the Directive or Regulation is as follows:  

Member States report on the national vehicle stock and detailed changes from one year to 
the next in the total number of vehicles registered, new registrations, imports and exports of 
used vehicles, temporary de-registrations and permanent de-registrations. 

The purpose of this reporting is that a) Member States demonstrate that all ELVs are directed 
to ATFs and b) to overcome the current situation where it is for a large number of vehicles 
unknown whether they are exported or treated as ELV (without CoD issued). 

The  European  Commission  communicated  possible  reporting  details  to  Member  States  in 
2018. Some MS mentioned that it might become difficult to collect the data, other questioned 
whether the current (version 2018) ELVD includes a mandate to make it mandatory to answer 
such  questions.  As  more  and  more  ELVs  are  shipped  across  the  EU  this  shall  also  be 
included in the reporting obligations as also discussed with the Member States in 2018. The 
detailed proposal and comments of the Member States on the proposal can be found in the 
report “Assessment of the comments of the Member States in relation to the draft proposal 
for the amendment of Commission Decision 2005/293/EC”144. The table below refers in most 
details to this proposal with a few adjustments in the terminology.  

143 How to report on end-of-life vehicles according to Commission Decision 2005/293/EC, Revision by Eurostat: 17 December 
2019 

144 Mehlhart, G.; Hay, D. (2019): Assessment of the comments of the Member States in relation to the draft proposal for the 
amendment of Commission Decision 2005/293/EC, commissioned by the EC DG Environment as an amendment to contract 
No 07.0201/2015/723374/ETU/ENV.A.2.  

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Table 2-11 Data reporting form: Data on the national vehicle market for M1 and N1 
vehicles 

Reference year (n) 
Certificates of destruction (CoDs) issued for domestic ELVs  

CoDs issued for vehicles, not registered in the reporting country 
Permanent cancellations of registration 

ELVs imported for treatment (excluding transit) 
Total ELVs treated in the reporting country  

(A) New vehicles placed on the national market:  

(1) Registered for the use on public roads for the first time  

(2) not registered (not for the use on public roads) 

(B) Import of used vehicles:  

(1) from other EU Member States and re-registered for the use on 
public roads  

(2) from non-EU countries and re-registered for the use on public 
roads 

Number per year,  
during the reference year 

(3) not re-registered (not for the use on public roads) 

Estimation possible 

Numbers on the 31 
December of the 
reference year (n) 

Numbers on the 31 
December of the 
previous year (n-1) 

Change in stock =  
year (n) – year (n-1) 

(C) Change in vehicle stock 

(1) Stock of vehicles 
registered for the use on 
public roads 
(2) Temporarily de-
registered vehicles  
(3) Suspended vehicle 
registrations 
Total = Σ(C) 

Number per year,  
during the reference year 

(D) Export of used vehicles:  

(1) to other EU Member States and re-registered for 
the use on public roads 
(2) to non-EU countries and re-registered for the use 
on public roads 
(3) other exports of used vehicles, not re-registered for 
the use on public roads or unknown if re-registered in 
the country of destination 

(E) Domestical ELVs treated, proven by issued CoD:  

(1) domestical ELVs treated domestically 
(2) domestical ELVs exported for treatment  

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Accompanying notes to the data reporting form: 
For  the  terms:  “registration”,  “cancellation  of  a  registration”,  “suspension”  pls  refer  to 
COUNCIL  DIRECTIVE  1999/37/EC  of  29  April  1999  on  the  registration  documents  for 
vehicles. 
The terms “temporary deregistration” and “Certificate of destruction” is defined in Article [to 
be completed one the articles are drafted in detail] of the revised ELV legislation.  
The  term  “permanent  cancellation  of  the  registration”  means  that  one  of  the  following 
situations apply: a) CoD issued to national vehicle register, b) proven theft of a vehicle, c) 
proven  export  of  a  vehicle,  d)  Exemptions  upon  specific  request:  e.g.  a  vintage  vehicle  is 
stored in a (private) kind of Museum: accompanying documents demonstrate the conditions 
where  and  how the  vehicle  is stored.  The  use  on  private  ground  shall  not be  a reason for 
permanent cancellation of the registration but it shall fall under temporary deregistration. 
Data from intra-EU foreign trade statistics are, due to the reporting thresholds, not reliable for 
reporting on this intra EU export of used vehicles. Instead, data shall be available from the 
national vehicle registration authority using data exchange based on Article 5(2) of Directive 
1999/37/EC. 
For the data on export to non-EU countries data from foreign trade statistics shall be used as 
an additional source to the data provided by the national registration authority.   
The submission of the data shall be accompanied by a quality report on methods used for the 
collection  of the  data,  the  data sources  and their  quality.  As  far  as  the  quality  report  does 
disclose  problems  with  data  sources  and  quality,  the  report  shall  outline  how  the  Member 
State proposes to overcome the identified problems.  

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2.2.5.1.10  Establish  collection  target  based  on  the  reporting 

obligations on the national vehicle market  

As mentioned during the stakeholder involvement one challenge, hampering proving that all 
ELVs that are domestically generated are treated according to the EU requirements is the 
lack of cooperation between the Ministries of Environment, in charge for the enforcement of 
the ELVD, and the Ministries in charge for the vehicle registration procedures, the last often 
with the Ministry of interior of Ministry of transport. Establishing a reporting obligation (see 
measure  before)  might  not  enough  stimulus  to  overcome  the  problems  is  cooperation.  A 
distinct target, where the collection of the data is inevitable to prove compliance is easier to 
communicate on pilots and EU infringement procedures too. 

Based on the before mentioned definitions for the reporting form the collections rate shall be 
calculated as follows:  

Collection rate = Σ(E) / (Σ(A) + Σ(B) – Σ(C) – Σ(D)) 
The indices refer to the reporting table before where  
Σ (A) = New vehicles placed on the national market 
Σ (B) = Import of used vehicles 
Σ (C) = Change in vehicle stock 
Σ (D) = Export of used vehicles 
Σ (E) = Domestical ELVs treated 

The Figure 2-26 below displays the relation of the before mentioned categories. 

Figure 2-26 

Input / Output Balance for the national vehicle market 

Level of the collection target: Article 5 (2) of the current ELVD stipulates that “Member States 
shall also take the necessary measures to ensure that all end-of life vehicles are transferred 
to authorised treatment facilities.” This implies, that 100% of the generated ELVs should be 
collected.  

However, there is no explicit monitoring with this regard included in the current ELVD. The 
challenge for MS to demonstrate achievement of the collection target is related to data on 
export and import. In particular the data for intra EU trade is by far not complete and MS must 
establish new procedures to collect data accordingly. Interoperability of the diverse national 
registers – possibly supported by EUCARIS (see chapter 2.2.5.1.6) would be a strong support 
to complete the data accordingly. For a target it must be considered that stock effects and 
enforcement  effects  might  apply,  making  it  challenging  or  impossible  to  achieve  100% 
collection rate when following the calculation rules.  

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2.2.5.2  Potential measures to achieve Specific Objective No 3.2: 
Reduce  levels  of  illegal  dismantling  and  illegal  export  of 
ELVs 

2.2.5.2.1  Exchange  on  MS  best  practice 

implementation  and  enforcement 
inspection campaigns) 

(national 
incl.  sector 

Such  exchanges  were  continuously  maintained  by  the  European  Commission  in  the 
framework of working group meetings. Here, Member States presented practices, such as: 

•  Germany  (TAC  ELV  2015):  Elaboration  of  proposals  to  improve  data  about  the 

whereabouts of end-of-life vehicles 

•  Germany (WG ELV 2016): German study on vehicles of unknown whereabouts 
•  Denmark (WG ELV 2016): Improving ELV collection rates in Denmark- a story about a 

changed marked 

•  Finland (WG ELV 2016): Finnish Guidance on POPs waste and pre-treatment of ELVs 
•  Portugal (WG ELV 2016): the EPR system Valorcar 
•  Germany  (EC’s  Stakeholder  meeting  2016-11-21):  Flashlight  of  practice  in  Germany: 

REGINA – making use of re-registration information to clarify used vehicle exports 

•  France  (EC’s  Stakeholder  meeting  2016-11-21):  Ways to  fight  against  illegal  sites  and 

illegal activities of end-of life vehicles 

•  Netherlands (EC’s Stakeholder meeting 2016-11-21): De-registration and monitoring of 

ELV’s in NL 

•  UK (EC’s Stakeholder meeting 2016-11-21): Illegal dismantling 
•  UK  (EC’s  Stakeholder  meeting  2016-11-21):  Registration/Deregistration  Procedures  in 

UK 

•  Poland (WG ELV 2017): Legalization of vehicles from crimes 
•  Germany  (WG  ELV  2017):  ELVES  and  ELV  Recycling  in  Ireland  Discussion  about the 

role of online car marketplaces /online salvage car auctions 
Ireland (WG ELV 2017): ELVES and ELV Recycling in Ireland 

• 
•  France (WG ELV 2017): ELV Reporting: Which organisation in France? 
•  Germany (WG ELV 2107): Results of the German ELV shredder trial of 2016 
•  Germany (Expert Meeting ELV 2021): ELV Treatment: Current cost and revenue situation 

of German ATFs 

However, most of the Member States did not change their approach (e.g. regards inspections) 
or legislation substantially with the aim to address the aspect of missing vehicles and only 
few  Member  States  can  provide  detailed  data  on  the  whereabout  of  all  used  vehicles  and 
ELVs.  One  basic  problem  is  that  such  changes  are  not  exclusively  in  the  domain  of  the 
participating representatives of TAC meetings (almost all from Ministry of Environment and/or 
Environmental  agencies),  while  changing  e.g.  registration  procedures  is  the  task  of  other 
Ministries in the Member States.  

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2.2.5.2.2  Voluntary  campaigns  on  export  of  ELVs  with  a 
focus  on  the  current  guidelines  on  distinction 
between  ELVs  and  second-hand  vehicles  (waste 
shipment correspondents’ guidelines No9) 

Today for three countries detailed studies on export are known: 

•  A  study  commissioned  by  the  German  UBA  in  2006  titled  “Improving  precious  metal 
cycles: analysis of export flows of used cars and electrical (electronic) equipment at the 
Port of Hamburg”145.  

•  A  study  commissioned  by  the  Dublin  city  council,  in  charge  for  this  export  in  Ireland, 
updated in 2019 the Guide for the shipment of used vehicles, used vehicle parts and used 
electrical and electronic equipment.  
In  2020,  the  Dutch  authorities146  published  a  report  on  inspection  at  the  harbour  in 
Amsterdam and additional desk research on the characteristics of the exported vehicles.  

• 

The costs for these studies are not yet known, but we expect them easily to exceed several 
10 000 € each.  

Despite  these  activities  no  other  voluntary  inspections  respectively  reports  on  such 
inspections  are  known  to  us.  Most  likely  road  police  in  cooperation  with  customs  services 
from time to time perform spot check inspections of shipments, but no systematic approach 
with this regard is reported. 

As long as such investigations remain voluntary, we do not expect that MS will spend more 
attention on this aspect, as the inspections capacities are in general limited, and many other 
aspects need to be addressed by the relevant authorities in charge. 

2.2.5.2.3  Effective  Deposit  Refund  Scheme  (DRF) 

for 

vehicles. 

Denmark  and  Norway  have  established  a  premium  payment  system  when  the  ELV  is 
delivered by the last owner to an ATF. The premium in Norway is NOK 3000. -(approximately 
€ € 288) and is provided to the last owner upon demonstration that a CoD is issued147. Vehicle 
owners pay upon the first registration 2 400 NOK to the government for a deposit. 

The premium in Denmark is 2200 DKK (approximately € 286) 148. The vehicle owners pay 85 
DKK (ca. 11 €) per year and per registered vehicle into the DRF Scheme. 

Both systems are managed by public authorities. More details on the existing systems can 
be found in chapter 6.7.3 of Annex I 

145 Verbesserung der Edelmetallkreisläufe: Analyse der Exportströme von gebraucht-Pkw und –Elektro(nik)geräten am 
Hamburger Hafen. (Buchert et al. 2007) 

146 Used vehicles exported to Africa: A study on the quality of used export vehicles (2020). Netherlands Human Environment 
and Transport Inspectorate, Ministry of Infrastructure and Water Management. available at: 
https://www.ilent.nl/binaries/ilt/documenten/rapporten/2020/10/26/rapport--used-vehicles-exported-to-africa/RAPPORT-
+Used+vehicles+exported+to+Africa.pdf. 

147 Siri Sveinsvoll (2019): The Norwegian ELV System, presentation 

148 Deloitte Consulting (September 2016): Udredning af skrotningsgodtgørelsens incitamentsstruktur ( 

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Preliminary results of a German study indicate that the illegal sector would have in different 
scenarios higher benefits compared to ATFs of about 250€ to 300€ per ELV149. Insofar the 
three sources demonstrate that almost the same level of premium is necessary to make it 
attractive to the last owner to provide the ELV to an ATF instead to the illegal sector.  

If a premium of €300 for each CoD presented would be paid to the last owner, this would be 
a very effective way of ensuring that more ELVs are supplied to ATFs rather than to the illegal 
sector. The funds for paying the premium could be collected when new cars are sold or during 
the use phase. 

The main risk is that implementation is hampered by missing information for other 24 national 
markets than the three (DK, NO, DE) mentioned above and subsequent discussions about 
the correct level of a premium. There might be also needs to adjust the premium from time to 
time with adverse effects as observed in Denmark when the premium was reduced between 
2014 and 2017 to 1500 DKK.  

A premium charged on the sale of new cars would increase the cost of new cars, as well as 
used cars, because the prices of old used cars would also include the premium payment as 
a markup on the market price. 

For the assessment the following measure is considered: 

Member States are encouraged to apply Deposit Refund Schemes either managed by public 
authorities or as a part of the EPR obligations. MS shall report on the level of the premium 
and why it is deemed sufficient / effective. 

2.2.5.2.4  European-wide deposit refund scheme for vehicles 
supervised by a single European body  

MS or OEMs are obliged to pay into a European fund a minor amount per year for vehicles 
registered for the use on public roads (alternative: for each new vehicle placed on the market 
in the EU). The European fund pays out a fixed amount to the last owner of a vehicle when it 
becomes an ELV, and a CoD is issued. 

Comment The European approach is more just for the Member States which import a high 
share of used vehicles. All car drivers pay the same fee, and all last owners get the same pay 
out.   

Risk:  Fraudulent  issuance  of  CoDs,  e.g.  for  vehicles  that  are  in  fact  exported  to  non-EU 
countries.  The  approach  requires  strict  rules  for  registration  and  deregistration  and  tough 
penalties for fraudulent cases. 

A (new) European authority must be assigned for this purpose and equipped with staff and 
equipment. 

149 Regina Kohlmeyer (Umweltbundesamt): ELV Treatment: Current cost and revenue situation of German ATFs; preliminary 
results presented to the ELV Expert Group Meeting (online) on 28 June 2021. 

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2.2.5.2.5  Binding criteria for a distinction of used vehicles / 
ELVs,  based  on  existing  waste  shipment 
correspondents’  guidelines  and 
looking  at 
examples  of  practices  in  some  MS  (i.e.  Austria’s 
legislation  according to  which  a  damaged vehicle 
that  is  considered  a  total  economic  loss  is  to  be 
considered an ELV) 

a)  Transformation  of  the  Waste  Shipment  Correspondents’  Guidelines  No  9  on  waste 

vehicles into a binding document (such as an annex to the ELV Directive); 

b)  Explicitly  define  (e.g.  in  the  context  of  the  definition  of  end-of-life  vehicles)  that  a 
vehicle that is considered an economic total loss (in the country of origin) is considered 
waste. Consequently, vehicles considered to be economic total losses must be offered 
to  ATFs  and  the  Waste  Shipment  Regulation  must  be  applied  to  cross-border 
shipments of such economic total loss vehicles. If intermediary brokers are involved, 
these  brokers  must  prove  to  the  last  owner  of  a  total  loss  vehicle  that  the  final 
destination  is  an  ATF.  This  could  also  help  avoiding  that  insurance  companies  sell 
“economic total loss cars” to unscrupulous operators, as they would be forced to hand 
over  these  cars  (deemed  ELVs)  to  ATFs,  even  when  the  cars  are  not  shipped  to 
another country but sold in the same country. 

2.2.5.2.6  Definition  of  minimum  requirements  for  sector 
inspections:  oblige  MS  to  set  up  and  notify 
inspection  plans  +  extend 
inspection 
requirements  to  all  economic  operators  in  the 
sector (not ATFs only, but operators suspected to 
conduct illegal dismantling as well).  

the 

All  Member  States  are  required  to  conduct  once  a  year  a  campaign  to  have  physical 
inspections of the sector, meaning a) ATFs, b) repair garages not registered as ATFs and c) 
known/suspected  illegal  operators  not  registered  at  all.  The  campaign  shall  cover  at  least 
10% of all sites/facilities each year. The campaign shall also cover inspections on at least 
three different days per year on which unannounced used/end-of-life vehicle transports are 
focused, as far as known along the known land transport routes and harbours with the aim to 
inspect  shipment  documents  and  compliance  with  the  Waste  Shipment  Directive  and  the 
definition of ELVs distinguished from used vehicles. 

The Member States shall submit a report on the concept / design of the inspection campaign 
and the findings/results to the EC. The EC shall prepare a report drawing conclusions from 
these reports accordingly.  

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2.2.5.2.7  penalties  for  operators  of  illegal  dismantling  and 
illegal 
to 
shredding  or 
dismantlers  and 
(and  electronic 
for  dealers 
platform)  dealing  with  dismantled  (used)  spare 
parts from non-authorised facilities. 

for  selling  an  ELV 

Regards this measure we distinguish to levels: 

Level 1 
Member States are encouraged to establish fines and penalties for  

a)  The owners in case of breach or regulations/rules how to manage ELVs  

b)  illegal dismantling and shredding or for selling an ELV to illegal dismantlers. 

c)  dealers (and electronic platform) dealing with dismantled (used) spare parts from non-

authorised facilities. 

Level 2 
As is the case in other pieces of EU law150, the future legislation on ELV would foresee that 
Member  States  are  required to  establish  effective,  proportionate and  dissuasive  penalties 
corresponding to breaches of the requirements under the ELV legislation, especially for:  

a)  owners who bring their ELV to non-authorised facilities. 

b)  illegal dismantling and shredding or for selling an ELV to illegal dismantlers. 

c)  dealers (and electronic platform) dealing with dismantled (used) spare parts from non-

authorised facilities. 

For both levels the following reporting obligation shall apply 

Member  States  shall  report  by  31.12.2025  once  on  the  fines  and  penalties  applied  in  this 
context to the EC. The EC will prepare a report on the received information with the aim to 
share best practices among the Member States.  

150 See for example Article 50 of Regulation 1013/2006 on shipment of waste 

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2.2.5.3  Potential measures to achieve Specific Objective No 3.3: 
Establish enforceable criteria to avoid the export of (used) 
cars  which  do  not  meet  roadworthiness  or  minimal 
environmental standards 

2.2.5.3.1  Action  at 

international 

that 
roadworthiness  (and  others)  become  criteria  for 
export of used vehicles 

to  support 

level 

There are no reasons preventing the EC from acting more proactively in this regard at the UN 
and UNECE level. 

We expect the measure to have low to zero impacts at EU level (exempt some effort for the 
EU Commission in the respective UN, UNEP, UNECE institutions). However, it is important 
for the effectiveness in the receiving countries. The aim is to encourage other exporters like 
United States, UK and Japan to follow the request of Ms. Andersen, Executive Director of 
UNEP,  which  said  in  2020  “Developed  countries  must  stop  exporting  vehicles  that  fail 
environment  and  safety inspections  and  are  no  longer  considered  roadworthy  in their  own 
countries, while importing countries should introduce stronger quality standards”. 

2.2.5.3.2  Promote  enforcement  actions  by  MS  through  EU 
funding  and  EU  enforcement  actions  against 
environmental crime 

There are no reasons preventing the EC from supporting implementing measures, e.g. under 
IMPEL,  in  particular  support  for  export  controls. In the  past,  several IMPEL  activities  have 
addressed  the  Waste  Shipment  Regulation151;  it  appears  that  such  activities  can  be 
strengthened with focus on ELVs. 

2.2.5.3.3  (Extra-EU) Export restrictions for used cars linked 
to valid roadworthiness certificate; Import rules of 
receiving countries for age and emission level shall 
be respected 

More and more countries importing used vehicles from the EU are introducing regulations to 
limit such imports by age and emission standard in order to avoid negative impacts of these 
imported  vehicles  on  air  quality,  road  safety  and  pollution  from  improper  disposal.  For 
instance,  the  Economic  Community  of  West  African  States  (ECOWAS152)  adopted  in 
September 2020 a Directive to limit the import to those vehicles with a minimum Euro 4/IV 
emission standard and established an age limit of 5 years for light duty vehicles respectively 
10 years for heavy-duty vehicles. Several other receiving countries, but by far not all, have 
similar restrictions in force.  

151 See: https://www.impel.eu/topics/waste-and-tfs/  

152 Members of ECOWAS: BENIN, BURKINA FASO, CABO VERDE, CÔTE D'IVOIRE, The GAMBIA, GHANA, GUINEA, 
GUINEA BISSAU, LIBERIA, MALI, NIGER, NIGERIA, SENEGAL, SIERRA LEONE, TOGO 

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As  mentioned  by  UNEP  and  UNECE  it  is  difficult  to the  receiving  countries  to  enforce the 
import  limitations  as  it  is  (most)  likely  that  each  imported  vehicle  will  find  its  market  in  the 
receiving countries. Thus, cooperation and support by the exporting countries is required to 
support import limits. 

Ms. Andersen, Executive Director of UNEP, said “Developed countries must stop exporting 
vehicles  that  fail  environment  and  safety  inspections  and  are  no  longer  considered 
roadworthy in their own countries, while importing countries should introduce stronger quality 
standards” 

First discussions indicate that setting definitive conditions for export of all used vehicles linked 
to emissions or age would be at risk to not comply with WTO. 

In result the proposed measure is twofold: first implementing a clear criterion for a calid road-
worthiness certificate as a condition for the export and secondly drawing attention of the Euro-
pean customs service to the criteria of the importing countries to consider them in the spot 
checks (risk-based approach). 

1. Exporters exporting used vehicles to extra-EU countries must demonstrate that the vehicle 
to be exported is in possession of a valid roadworthiness certificate. 

2. Customs services and other control/inspection authorities of the MS shall, when drawing 
up  their  risk-based  approach  for  controlling  the  export  of  used  vehicles,  pay  particular 
attention to the measures adopted by importing countries on the conditions for import of used 
vehicles,  especially  limitations  based  on  age  or  compliance  with  air  emissions  like  Euro 
emissions standards. 

The effects will be presumably as follows: 

Old cars with similar characteristics to ELVs that cannot be repaired in the EU at a reasonable 
cost will not be exported but scrapped in the EU. This will affect the business model of ATFs 
in two ways: a) more ELVs will be transferred to ATFs, b) less revenue from the export of 
used vehicles, which is often also a business of ATFs (e.g. via specialized intermediaries).  

The market for (very) cheap vehicles in the receiving countries will decline, cost for mobility 
will increase. As seen in other counties with import bans/limitations, the fleet will get younger, 
and the emission level will decline, and road safety will improve. 

The market for spare parts from old vehicles in the receiving countries will persist. ATFs will 
separate more spare parts for export in non-EU countries.  

Does it make a difference whether all the three criterial (emission standard / age / valid 
roadworthiness certificate) apply or if only one applies or a set of two? 

Figure 6-11 in Section 6.5.1.3 in Annex I displays findings of a Dutch Study in 2020 on the 
age  and  periodic  roadworthiness  test  of  exported  vehicles  from  the  Netherlands  to  West 
Africa (and separately for Morocco) compared to ELVs treated in the Netherlands.  

Surprisingly even relatively young, exported vehicles in the categories younger than 10 years 
have a high share of vehicles without valid roadworthiness certificate or a certificate which 
expires  in  less  than  one  month.  In  total  around  15%  of  the  vehicles  exported  from  the 
Netherlands to West Africa have a valid roadworthiness certificate. Unfortunately, the reasons 
for  this  observation  are  unknown:  whether  the  cars  need  repair  beyond  the  current  value 
(economic total loss) or by other reasons it is not worth to apply for a renewed roadworthiness 
certificate, or whether it would be possible to renew the certificate at reasonable cost, at least 
for the younger vehicles. Considering the last aspect, we assume that at least 30% to 40% of 
the vehicles (double than displayed in the Dutch report) will have or may get a roadworthiness 
certificate. 

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Regards the age we take from the same figure in Annex I that possibly 25 to 50 out of ~6000 
exported vehicles to West Africa are younger than 6 years (representing a share of less than 
1%).  This  is  in  contrast  to  the  situation  in  Morocco,  where  around  75%  of  the  exported 
vehicles  are  younger  than  6  years.  This,  of  course,  reflects  Moroccan  regulations  on  the 
import of used vehicles, which may not be older than 5 years153. 

Concluding on the effects of export limitations (e.g. maximum age for export is 5 years) is not 
strait forward as we must expect that the exporters will adopt their business to the new rules 
of export and focus more on younger vehicles. Without considering this adoption effect one 
would assume that with the implementation of export restrictions less than 1% of the current 
export would be exported to West Africa. Considering the demand in the receiving countries 
and  the  adoption  of  the  import  business  we  might  consider  for  a  limitation  to  5  years  a 
reduction by 60% to 80% of the exports.   

153   Unfortunately, it is not possible to derive from time series for Morocco’s import of used vehicles the impact of the 
introduction of the 5 years threshold as Morocco supports since a very long period the development of its own vehicle 
production and support this with regulations / agreements and import taxes. Thus, there is no sudden break detectable in the 
import data (of Eurostat). 

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2.3  Extended  Producer  Responsibility  (EPR)  and  advanced 

economic incentives 

This section addresses the current situation, the problems (if any) and its drivers, why action 
on EU level might be needed and potential measures under an EPR regime.  

Other advanced economic incentives as  

•  Green Public Procurement, which might include circularity aspects in the future,  
•  Deposit  Refund  Schemes  (DRF),  which  might  be  under  EPR  regime  or  under  public 

systems, 
Incentives and penalties in particular to strengthen the relevance of the CoD. 

• 

2.3.1  Introduction 

While the term EPR is not explicitly mentioned in the current ELVD some provisions oblige 
the member States to implement basic obligations for the producers. At the same time the 
WFD established detailed provisions for EPR schemes in Article 8 and 8a for all wastes.  

2.3.2  Current Situation  

2.3.2.1  ELV Directive 

The ELV Directive does not explicitly introduce the term EPR but sets out provisions on the 
role of producers (e.g., car manufacturers) in respect to the collection of ELVs, as well as on 
making dismantling information available for each new car, as reflected in the box below: 

Main requirements for vehicle producers under the ELV Directive: 

Article 2(13): 

‘Dismantling information’ means all information required for the correct and environmentally 
sound  treatment  of  end-of  life  vehicles.  It  shall  be  made  available  to  authorised  treatment 
facilities  by  vehicle  manufacturers  and component  producers  in  the form  of  manuals  or  by 
means of electronic media (e.g. CD-ROM, on-line services). 

Article 5(4): 

Member States shall take the necessary measures to ensure that the delivery of the vehicle 
to an authorised treatment facility in accordance with paragraph 3 occurs without any cost for 
the last holder and/or owner as a result of the vehicle's having no or a negative market value. 

Member States shall take the necessary measures to ensure that producers meet all, or a 
significant part of, the costs of the implementation of this measure and/or take back end-of 
life vehicles under the same conditions as referred to in the first subparagraph. 

Article 8(3): 

Member  States  shall  take  the  necessary  measures  to  ensure  that  producers  provide 
dismantling information for each type of new vehicle put on the market within six months after 
the  vehicle  is  put  on  the  market.  This  information  shall  identify,  as  far  as  it  is  needed  by 
treatment facilities in order to comply with the provisions of this Directive, the different vehicle 
components and materials, and the location of all hazardous substances in the vehicles, in 
particular with a view to the achievement of the objectives laid down in Article 7. 

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Article 8(4): 

Without prejudice to commercial and industrial confidentiality, Member States shall take the 
necessary  measures  to  ensure  that  manufacturers  of  components  used  in  vehicles  make 
available  to  authorised  treatment  facilities,  as  far  as  it  is  requested  by  these  facilities, 
appropriate  information  concerning  dismantling,  storage  and  testing  of  components  which 
can be reused. 

According  to  the  last  evaluation  report154  ,  all  Member  States  without  exception  have 
transposed  into  national  law  the  provision  that  the  delivery  of  the  vehicle  to  an  ATF  must 
occur without any costs for the last holder/owner.  

The WFD provides more details regards the implementation of EPR schemes.  

2.3.2.2  Waste Framework Directive 

In March 2022 the EC submitted a survey on EPR aspects to the Member States. Out of 14 
replies 13 states that that they have established an EPR system for ELVs in the MS. 10 out 
of 14 MS also stated that the EPR system is in compliance with Article 8a155 of the WFD.  

Details of Article 8a of the WFD:  

Art 8a(1)  

MS shall 

d)  define the roles and responsibilities of actors involved, incl. producers, PROs, re-use 

and preparing for re-use operators and waste operators; 

e)  set waste management targets, at least quantitative targets as laid down in the ELV 
Directive  and  set  other  quantitative  targets  and/or  qualitative  objectives  that  are 
considered relevant for the EPR scheme; 

f)  ensure that a reporting system is in place for products placed on the market and data 
on  the  collection  and  treatment  of  waste  resulting  from  those  products  specifying, 
where  appropriate,  the  waste  material  flows,  as  well  as  other  data  relevant  for  the 
purposes of point (b); 

g)  ensure equal treatment of producers of products. 

154 Commission staff working document (15.3.2021): Evaluation of Directive (EC) 2000/53 of 18 September 2000 on end-of-life 
vehicles. For details see page 57 ff.  

155 Article 8a is introduced by Directive (EU) 2018/851 of the European Parliament and of the Council of 30 May 2018 

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Art 8a(2) 

MS shall take measures  

• 

• 

to ensure that waste holders are informed about waste prevention measures, centres for 
re-use and preparing for re-use, take-back and collection systems;  
to create incentives for the waste holders to assume their responsibility to deliver their 
waste into the separate collection systems in place, notably, where appropriate, through 
economic incentives or regulations. 

Art 8a(3) 

MS shall take measures to ensure that producers / PROs  

a)  has  a  clearly  defined  geographical,  product  and  material  coverage  without  limiting 
those  areas  to  those  where  the  collection  and  management  of  waste  are  the  most 
profitable; 

b)  provides  an  appropriate  availability  of  waste  collection  systems  within  the  areas 

referred to in point (a); 

c)  has the necessary financial means or financial and organisational means to meet its 

EPR obligations; 

d)  puts  in  place  an  adequate  self-control  mechanism,  supported,  where  relevant,  by 

regular independent audits, to appraise: 

i. its financial management, including compliance with the requirements laid down in 

points (a) and (b) of paragraph 4; 

ii. the quality of data collected and reported in accordance with point (c) of paragraph 

1 of this Article and with the requirements of Regulation (EC) No 1013/2006; 

e)  makes publicly available information about the attainment of the waste management 
targets referred to in point (b) of paragraph 1, and, in the case of collective fulfilment 
of EPR obligations, also information about: 

i. its ownership and membership; 

ii. the financial contributions paid by producers of products per unit sold or per tonne 

of product placed on the market; and 

iii. the selection procedure for waste management operators. 

Art 8a(4) 
MS shall take measures to ensure that the financial contributions paid by the producer to 
comply with its EPR obligations: 

a)  cover  the  following  costs  for  the  products  that  the  producer  puts  on  the  market  in  the 
Member State concerned:  

•  costs of separate collection of waste and its subsequent transport and treatment, including 
treatment necessary to meet the Union waste management targets, and costs necessary 
to meet other targets and objectives as referred to in point (b) of paragraph 1, taking into 
account the revenues from re-use, from sales of secondary raw material from its products 
and from unclaimed deposit fees, 

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•  costs of providing adequate information to waste holders in accordance with paragraph 

2, 

•  costs of data gathering and reporting in accordance with point (c) of paragraph 1. 

This  point  shall  not156  apply  to  extended  producer  responsibility  schemes  established 
pursuant to Directive 2000/53/EC157, 2006/66/EC158 or 2012/19/EU159; 

b)  in the case of collective fulfilment by PROs, are modulated, […] by taking into account their 
durability,  reparability,  re-usability  and  recyclability  and  the  presence  of  hazardous 
substances, …; and 

c)  do not exceed the costs that are necessary to provide waste management services in a 
cost-efficient way. Such costs shall be established in a transparent way between the actors 
concerned. 
Derogation  to  depart  from  point  a)    anyhow  explicitly  not  applicable  for  the  ELV 
Directive 

Art 8a(5): Governance and authorised representative 

•  MS shall establish an adequate monitoring and enforcement framework with a view 
to ensuring that producers and PROs implement their EPR obligations, including in 
the  case  of  distance  sales,  that  the  financial  means  are  properly  used  and  that  all 
actors involved in the implementation of the EPR schemes report reliable data. 

•  Where,  in  the  territory  of  a  MS,  multiple  organisations  implement  PROs,  the  MS 
concerned shall appoint at least one body independent of private interests or entrust 
a public authority to oversee the implementation of EPR obligations. 

Article 14: Costs 

1.  In  accordance  with  the  polluter-pays  principle,  the  costs  of  waste  management, 
including  for  the  necessary  infrastructure  and  its  operation,  shall  be  borne  by  the 
original waste producer or by the current or previous waste holders. 

2. Without prejudice to Articles 8 and 8a, Member States may decide that the costs of 
waste management are to be borne partly or wholly by the producer of the product 
from which the waste came and that the distributors of such product may share these 
costs. 

While  Article  8a(4)  point  a)  of  the WFD  excludes the  Producers  from the  compensation  of 
compliance cost, Article 5(4) of the ELV Directive (the “lex specialis”) requires the Member 
States  to  “take  the  necessary  measures  to  ensure  that  the  delivery  of  the  vehicle  to  an 
authorised treatment facility […] occurs without any cost for the last holder and/or owner as 
a result of the vehicle's having no or a negative market value. Member States shall take the 

156   The reasoning is that the detailed provision for (compliance) cost compensation are elaborated in the “lex specialis” as 
mentioned subsequently. The detailed provisions for the ELV sector are displayed in the previous section ELV Directive. 

157 ELV Directive 

158 Battery Directive 

159 WEEE Directive 

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necessary measures to ensure that producers meet all, or a significant part of, the costs of 
the  implementation  of  this  measure  and/or  take  back  end-of  life  vehicles  under  the  same 
conditions as referred to in the first subparagraph.”  

Despite the intent of WFD Art 8a of placing the waste management costs for Batteries, WEEE 
and ELV on the producer, for ELV it is insufficiently clear how the compliance costs shall be 
distributed between the producers and the ATFs.  

Producers argue that the costs for depollution and dismantling are covered by revenues from 
the  reuse  of  components  and  recycling  of  materials  and  producers  feel  that  it  is  not  their 
responsibility  to  combat  illegal  activities.  Producers  call  the  system  a  joint  responsibility 
system of producers and recyclers.  

ATFs  argue  that  they  are  exposed  to  illegal  competitors  who  do  not  have  to  cover  all 
depollution, dismantling and disposal efforts, some of them operate informally at substandard 
facilities  with  informally  employed  staff.  Regarding  the  economic  conditions,  EGARA,  the 
European Group of Automotive recycling associations has developed a tool on the costs and 
revenues of ATFs160, which demonstrates that currently the ATFs are highly dependent on 
revenues from metal scrap and revenues from separated catalytic converters:   

• 

• 

If these revenues for steel and catalytic converters drop under a certain level, the ATFs 
are not profitable.  
If the market value of recyclables from the catalytic converters is high, ATFs experience 
that ELVs arrive without catalytic converters, reducing the revenues for ATFs.  

•  And if the steel scrap prices are high, the illegal sector competes with ATFs by offering to 
the last owner higher prices for their ELVs and in result ATFs receive less ELVs during 
such period 

Thus both, low but also high revenues for metal and scrap catalytic converters and depolluted/ 
dismantled  vehicles  is  not  always  beneficial  to  the  ATFs  and  the  economic  situation  is 
instable.  

Many ATFs – in particular the smaller ones - simply survive by performing a combination of 
activities  like repair  (garage)  activities,  export  of  valuable  vehicles,  selling  spare  parts  and 
recyclables that generate revenues.  

Other Stakeholders, including Member States, are concerned that the environmental benefits 
of recycling glass, large plastic parts and copper from the wiring harness and the separation 
of electronic components is hampered by unprofitable economic conditions and costs to ATFs 
which are not recovered by the producer.  

160 Results / compilation of a survey of EGARA: delivered to the EC during a (virtual) meeting in February 2021   

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2.3.2.3  Economic situation of the sector 

Two Member States carried out studies on the economic situation of ATFs:  

• 

In 2015, a consortium of Terra SA - Deloitte - BioIS carried out a study for Ademe on the 
economic evaluation of the ELV treatment chain in France161. The study identified a 
representative sample of 25 ELV centres and 7 approved shredders in metropolitan 
areas. These sites were surveyed and interviewed regarding their costs. This work 
revealed a weighted average loss for ATFs of 23.90 € per ELV. However, there was a 
significant variation in the results, which ranged from -225.20 €/ELV to +109.80 €/ELV 
for the sample. Approximately 40 % of the ATFs in the sample had a loss on their ELV 
activities. The result of the ATFs activity is particularly positive for ATFs whose share of 
ELV turnover is greater than 75 % of the company's total turnover, the result being 
negative on average for companies whose ELV turnover represents less than 75 % of 
the company's total turnover. For shredders the cost for the shredding of ELV is difficult 
to separate as all the shredders in the sample shred other scrap as well. The study 
reports fewer disparities in the results for the shredders compared to ATFs: the range of 
economic balance for ELV shredders results in 0.8 €/t ELV as a weighted average (from 
-29.8 €/t ELV carcasses to +27.2 €/t ELV). The ELV shredder activity is loss making for 
3 out of 7 shredders. The operating result for all activities is negative for 2 shredders. 
•  Germany is carrying out a study on the current cost and revenue situation of German 

ATFs. Preliminary results were presented during the ELV Expert Group meeting on the 
28 June 2021. The presentation concludes that ATFs are not profitable without spare 
part reclamation. Additional costs would occur for dismantling of glass and plastics 
which wouldn’t be recovered by revenues for the separated materials. The illegal sector 
would have in different scenarios higher benefits compared to ATFs of about 250 € to 
300 € per ELV162.  

Stakeholders also mention that additional burdens for the ATFs (e.g., the obligation to carry 
out more intensive dismantling for better quality recycling) will result in a shift to the illegal 
sector as long as the costs of the additional effort are not recovered e.g., from the producers. 

For  more  details  on  the  economic  situation  of  ATFs  and  related  studies  in  France  and 
Germany, please refer to section 3.2.5.4 

As  it  became  obvious  during  the  stakeholder  involvement the  economic  viability  of  PST  is 
mainly  driven  by  the  national  regulations/cost  for  landfilling.  In  countries  which  have 
restrictions  for  landfilling  (either  regards  the  maximum  TOC  or  a  landfill  tax),  PST  is 
economically  viable,  in  contrast  to  countries  where  it  is  allowed  to  landfill  the  shredder 
residues for 20 € per ton. In the last countries, it is not profitable to invest in PST. For the 
details on the current restrictions for landfilling please refer to CEWEP163. 

In addition, Member States, which carried out comprehensive compliance inspections in the 
sector, are concerned about the costs of such inspections and would like compensation for 
these costs. 

161 ADEME (2015): TERRA SA – DELOITTE – BIOIS - EVALUATION ECONOMIQUE DE LA FILIERE DE TRAITEMENT DES 
VEHICULES HORS D’USAGE – 2015 – Synthèse. 40 p. 

162 Regina Kohlmeyer (Umweltbundesamt): ELV Treatment: Current cost and revenue situation of German ATFs; preliminary 
results presented to the ELV Expert Group Meeting (online) on 28 June 2021. 

163 https://www.cewep.eu/wp-content/uploads/2021/10/Landfill-taxes-and-restrictions-overview.pdf, accessed 21 June 2022 

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2.3.2.4  Existing Producer Responsibility Organisations 

The clauses in the current ELVD do not require explicitly the establishment of “EPR Systems” 
in  the  meaning  of  individual  or  collective  Producer  Responsibility  Organisations  (PRO). 
Instead 1:1 implementation in the MS is sufficient if the OEMs established contracts with a 
(sufficient) number of ATFs where these ATFs confirm that they take back all ATFs offered 
to them “without any cost for the last holder” according to Article 5(4) first subparagraph, and 
also considering that the delivery of end-of life vehicles is “not fully free of charge if the end-
of life vehicle does not contain the essential components of a vehicle, in particular the engine 
and  the  coachwork,  or  contains  waste  which  has  been  added  to  the  end-of  life  vehicle.” 
according to Article 5(4) third subparagraph.  

Considering  the  implementation  report  (published  in  2016)  164,  all  Member  States  without 
exception  have  transposed  the  provision  that  the  delivery  of  the  vehicle  to  an  ATF  has  to 
occur without any costs for the last holder/owner. At least 19 Member States have limited the 
guarantee of free take-back by the condition that the vehicle contains the essential parts and 
that  no  waste  has  been  added.  In  most  cases,  the  wording  of  the  national  legislation  is 
identical or very similar to paragraph 3 of Article 5(4).164 

To understand the current implementation in the MS better, the EC submitted in March 2022 
a  questionnaire  to  the  MS  on  EPR  schemes.  14  Member  States  replied  with  details 
accordingly. As displayed in Figure 2-27, PROs are identified for 13 Member States while for 
other 5 Member States different sources mentioned the existence of PROs, but we were not 
able to identify them. For 2 of the 5 Member States the existence of national public funds is 
reported.  For  7  Member  States  it  is  reported  that  no  PRO  is  established  but  the  Member 
States rely solely on individual producer responsibility. For 5 Member States no information 
is available. As the ELVD is applicable in the EEA countries Iceland, Norway and Lichtenstein 
too, the following figures refer to EU27+3 EEA countries. More details on the names of the 
PROs and the sources are displayed in Table 2-12 where UK and Switzerland are displayed 
in addition for information purposes.  

Figure 2-27  Exitance of PROs in EU27+3 EEA countries 

EU27+3 with PROs (collective
schemes) identified

National Public Funds

5

EU27+3 where PROs are
mentioned in sources but not
identified so far

according different sources
no PRO

7

no information

13

3

2

Source: see Table 2-12 more below 

164 ARGUS (2016): Implementation of Directive 2000/53/EU on end-of-life vehicles (the ELV Directive) with emphasis on the 
end-of-life vehicles with unknown whereabouts: Summary report on the implementation of the ELV Directive for the periods 
2008-2011 and 2011-2014 (“Lot 2”) 

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2.3.2.5  Member  States  where  fees  or  taxes  are  established  for 

the management of ELVs 

The questionnaire submitted in March 2022 to the MS investigated the existence of taxes / 
fees  for  the  management  of  ELVs.  As  displayed  in  Figure  2-28  below,  we  identified  11 
Member States with fee/ taxes, including those which had a fee / tax in the past and which 
announced a fee for the future. For 13 Member States no fee applies and for 6 Member States 
no information is available. For an overview on the kind and level of fees please refer to Table 
2-12 below.  

In theory a fee modulation could be applied for collective PRO systems. To our knowledge 
such fee modulation is not applied in any of the EU27+ 3 countries. 

More details on the different approaches in the MS and for some MS also the development 
over  time  in  displayed  in  Annex  I  under  chapter  6.7  on  “Detailed  current  situation  of  EPR 
schemes, PROs and fees / taxes applied in the MS for the management ELVs” at page 620 

Figure 2-28  Fees / taxes for the management of ELVs 

6

13

11

with fee or tax (incl "in the
past" & "annuced for 2023")

without fee or tax

no information

Source: see Table 2-12 below 

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Table 2-12 Producer Responsibility Organisations and fees supporting the management of ELVs identified  

Management of EPR / existing 
PRO 

fee 

infor-
mation 

fee / tax for management of ELVs 

AT 

BE 

BG 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

OECAR 
Österreichische Shredder 

Febelauto 

Bulgarian Recycling Company AD 

Ecobulcar 

 No information 

no PRO; the fund is managed by 
the State Environmental Fund 
(Czech Republic): 

no PRO 

Stena / Dansk Bil-Retur 

Eesti Autolammutuste Liit 

EDOE  

no PRO (but SIGRAUTO)  

No 

No 

No 

No 

No 

No 

OECAR in 2022: the fee for producers is € 3.10 per vehicle placed on the market; minimum per 
brand and year: € 500, maximum per brand and year is € 15.500 each plus VAT. 

Österreichische Schredder in 2022: the fee for producers is € 1.50 per vehicle placed on the 
market, plus annual lump sum of € 100. The fees are used for the management of the PRO. 

According to its own understanding febelauto's network covers all (!) ATFs in Belgium and 
Luxembourg. Febelauto does explicitly not take the responsibility of the importer for free take 
back nor recycling quota. 

No 

Vehicle owners pay the recycling fee pay when registering used vehicle. The fee is determined 
by compliance with the emission limits:  

CZK 3 000 (app. 120 €) if the emission limits EURO 2, 

CZK 5 000 (app. 200 €) if the emission limit values EURO 1, 

CZK 10 000 CZK (app 400 €) in if non-compliant with a) and b). 

The fee is paid to support the collection, treatment, recovery and disposal of ELVs and their 
parts, for infrastructure development and for support of alternative fuel vehicles. 

Car users pay 85 DKK (ca. 11 €) per year and per registered vehicle. 
Pay-out of 2200 DKK (ca. € 286) to the last owner when handling out to ATF and receiving a 
COD 

Source 
at end of 
table 

WWW 

1) 

WWW 

WWW 

2) 

1) 

1) 

1), 3) 

2) 
1) 
1) 

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Management of EPR / existing 
PRO 

fee 

infor-
mation 

fee / tax for management of ELVs 

FI 

Suomen Autokierrätys Oy 

FR 

no PRO 

No 

HR 

Environmental Protection and 
Energy Efficiency Fund 

HU 

No pro but Car Rec  

No 

IE 

ELVES 

IT 

LT 

LU 

LV 

MT 

NL 

no PRO 
GIA 
AGIA 
1 PRO + x Individual 

1 PRO + x Individual 

ARN 

No 

No 

No 

No 

No 

The joining fee is 300 € for those producers who has imported 49 or less cars / previous year, 
600 € for 50-99 imported cars; 1200 € for 100-199 imported cars; 1500 € for 200-999 imported 
cars and 2000 € for 1000 or more imported cars. The amount of annually subscription fees 
varied in 2014 from minimum 3,20 €/car for those producers who imported more than 3000 
cars/year to maximum 18,92 € for those who imported ten or less cars/year. These annually 
subscription fees cover mainly the administration costs of PRO. 
France adopted recently and amendment to its legislation. To be seen whether this will cause 
the establishment of PROs and a fee. 
Management fee to Croatian Environmental Protection and Energy Efficiency Fund, in the 
amount of 600 HRK/1000kg (approx.€ 800/1000 kg). 
The Fund covers the costs of the entire ELV management system and ensures the fulfilment 
of the prescribed objectives of reuse/recovery/recycling: 
a) Compensation for the last owner when handing over an ELV to ATFs. the pay-out (for a 
complete ELV) is 1000 HRK/1000 kg (ca € 130/1000 kg). or an incomplete ELV the pay-out is 
500 HRK/1000 kg (ca. € 66/1000 kg); 
b) Compensation for the collector - for collection, storage, and transport of ELVs to ATFs: 150-
450 HRK/1000 kg (≈ € 20-60/1000 kg) depending on the distance between the pick-up point 
and ATF; in the case of transport distance of more than 150 km: the fee amounts to 0,80 
HRK/km/t (≈ € 0,105/km/t) of vehicles transported. 

Ireland announced for 2023 fees of 20 € per unit (one-time payment). If a Producer were to self-
comply, registration fees would be paid to local authorities. The fees paid to the PRO ELVES 
are used to support the operation and objectives of their operation – improving the processing 
of ELVs in Ireland, primarily ensuring ELV reuse, and recovery targets are met and delivering 
public awareness around the correct way to scrap a vehicle. 

The fee was in 2002 45 € and declined to 30 € per vehicle in 2022. Based on the fee ARN 
today organises, monitors and continually optimises disposal and processing of end-of-life 

188 

Source 
at end of 
table 

1) 

4) 

1) 

WWW 

1) 

5)  

1) 

2) 

2) 
1) 

1) 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
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Management of EPR / existing 
PRO 

fee 

infor-
mation 

fee / tax for management of ELVs 

PL 

2005 -2015: National Fund for 
Environmental Protection and Water 
Management 

PT 

Valorcar 

no PRO 

Bilretur / Bil Sweden 

No 

Auto Recycling + 3 individual 

RO 

SE 

SI 

SK 

IS 

NO 

Autoretur 

LI 

UK 

CH 

2 PROs  

Stiftung Auto Recycling 

No 

No 

No 

No 

No 

No 

Source 
at end of 
table 

6) 

3) 

2) 
1) 

-/- 

vehicles. All of the almost 300 partners in the recycling chain can function optimally through a 
fair distribution key. The details of the distribution are not known. 

From 2005 to 2015 all natural persons placing vehicles on the Polish market, as well as smaller 
importers, were required to pay a charge of PLN 500 (just under 110 €) for each vehicle. The 
manufacturers and importers marketing large quantities of vehicles (those who were required 
to ensure the vehicle collection network) were exempt from the duty. The funds were deposited 
by the National Fund for Environmental Protection and Water Management. In 2016 the fund is 
abolished.  

The financial provision for each vehicle placed on the national market for the first time and 
covered by the current ELVD (M1 and N1 vehicles) is for new and used vehicles 1.2 €. For 
used vehicles produced (first registered) before 3/Feb/2010 the Financial Provision is 5,0 per 
vehicle 

PRO Autorecycling is charging its members with 24 € per vehicle. Not all producers/importers 
entered the PRO; individual systems are existing in parallel. 

1), 2) 

A)  Recycling fee: In 2009 the stakeholders agreed upon a long-term risk sharing model 

in dependence of the scrap prices (in case of low scrap prices ATFs receive 
compensation form EPR). The agreement also addresses specific long distance 
transport cost from ATFs to shredders. A recycling fee of 62,50 NOK (8 EUR) must 
be paid to the Producer Organisation. 

B)  Car owners pay upon first registration 2 400 NOK to the government for a deposit; 

Pay-out to the last owner when ELV is delivered to ATF: 3 000 NOK (approx. € 288). 

-/- 

2), 7) 

-/- 

2) 
WWW 

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Sources:  

1) MS Q 22: Replies of 14 Member States to a questionnaire in March 2022, not published 

2) BIO IS 2014: BIO Intelligence Service (2014): Development of Guidance on Extended Producer Responsibility (EPR), Commissioned by European Commission – DG Environment 

3) EU WG ELVD: 2016-11-22: Presentation at the EU Working Group on ELVs held the 22 November 2016 in Brussels, not published 

4) EU WG ELVD 2022-03-11: Presentation at the EU Working Group on ELVs held the 11 March 2022 in Brussels, not published 

5) ADA: personal information from Associazione Nazionale Demolitori Autoveicoli, via Henk Jan Nix (EGARA) 

6) EGARA 2021: personal information from Henk Jan Nix (EGARA) 

7) S. Sveinsvoll (2019): Siri Sveinsvoll (NBF – Norwegian Car Dismantler Association): The Norwegian ELV System: Presentation at the 4th international conference recycling of vehicles in 
the country and abroad “practice and experience” 18-20 September 2019.

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2.3.3  What is the problem and why is it a problem? 

2.3.3.1  Description of the problem  

Currently in most countries the so called “shared responsibility” is applied, where Producers 
Currently in most countries the so called “shared responsibility” is applied, where Producers 
demonstrate (either individually or jointly in a PRO) the compliance with the requirement that 
ELVs are taken free of charge back from the consumer by contracts with ATFs confirming the 
free take back. Details of contracts with ATFs, e.g. whether there is compensation for ATFs, 
are  usually  not  disclosed.  From  diverse  stakeholders  it  is  known  that  the  free  take  back 
declarations are issued by ATFs without or with marginal compensation for the ATFs. This 
system  is  based  on  the  assumption  that  it  is  economically  feasible  to  comply  with  the 
requirements of the ELV Directive without cost compensation by Producers. 

Currently this is possible as:  

•  Recyclers achieve the required recycling rate by applying the definition of recycling in the 
ELVD which allows (in contrast to the WFD) to account backfilling as recycling or declare 
landfilling of the mineral fraction as a recycling operation as mineral shredder residues 
are used for road construction purposes at landfills. 
In the ELVD the “point of calculation” is not defined (in contrast to the recycling targets of 
the WFD and the PPWD). As a result, it is not known at which point in the recycling chain 
the mass is accounted for recycling and whether additional losses apply after this point 

• 

•  The current ELVD requires a limited amount of removal in order to promote recycling: 

• 

• 

• 

removal or catalysts, 

removal  of  metal  components  containing  copper,  aluminium  and  magnesium  if 
these metals are not segregated in the shredding process,  

removal  of  tyres  and  large  plastic  components  (bumpers,  dashboard,  fluid 
containers, etc), if these materials are not segregated in the shredding process in 
such a way that they can be effectively recycled as materials, 

• 

removal of glass. 

These stipulations do not consider the quality of recycling and cross contaminations 
for  material  recycling  and  almost  all  countries  allow  to  segregate  the  mentioned 
materials  in  the  shredding  process.  This  applies  for  glass  as  well,  even  if  it  is  not 
explicitly mentioned that glass can be separated in the shredder as well. Electric and 
electronic components are not considered for removal in the current ELVD (Annex I, 
Section 4, Treatment operations in order to promote recycling) 

More  challenging  regulations  in  the  context  of  the  Circular  Economy,  aiming  for  a  higher 
quality  recycling,  might  require  more  effort  at  ATFs.  Such  effort  might  be  as  such  not 
economically viable and cannot be covered by revenues or would reduce the profits of the 
ATFs  (which  would  reduce  the  competitiveness  of  ATFs  with  the  illegal  sector).  New 
developments like accidental electric vehicles and the removal (and storage) of EoL Batteries 
are expected to be not economically viable too, at least during the next ten years when only 
a limited number of EV will occur as ELVs. 

While we are of the opinion that Article 8a of the WFD is applicable for ELVs as EPR schemes 
exist, the awareness to comply with these minimum requirements is limited. 

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The  current  system  is  not  future-proof  and  currently  only  economically  viable  reuse,  and 
recycling is conducted165.  

In addition, the system is exposed to strong competition of the illegal sector. Such competition 
will become more relevant if the ATFs are exposed to more challenging requirements.  

In March 2022, several producers are exposed to anti-trust investigations in the ELV sector. 
The reasoning for the investigations is not known to us yet and to what extent its related to 
the (current) producer responsibility requirements. 

Conclusion on this section: 

The provisions in the ELV Directive on the producers’ responsibility for the management of 
ELVs are limited when compared to the obligations for producers in other sectors to contribute 
financially  to  the  waste  management  phase  of  their  products,  pursuant  to  the  Waste 
Framework  Directive  and  other  EU  waste  legislation  (for  example  electric  and  electronic 
equipment, batteries or packaging) where financial provisions are specified explicitly.  
This  has  an  impact  on  two  important  elements  linked  to  the  implementation  of  the  ELV 
Directive (the collection of ELV and the recycling/re-use rate of materials from ELVs). 

•  First, while the car manufacturers have in many MS contributed to ensure that systems 
are in place to ensure the collection of ELV in accordance with the provisions of the ELV 
Directive, their involvement to address the problems of “missing vehicles” has remained 
limited. This is in contrast to other economic sectors where producers, usually through 
EPR  schemes,  play  an  important  role  in  making  sure  that  waste  deriving  from  their 
products are properly collected and reported as such to the competent authorities.  
•  Second,  the  absence  of  clear  provisions  in  the  ELV  Directive  on  the  responsibility  of 
producers hampers the transition of the automotive sector to a circular economy.  

This leads to a situation where: 

•  The economic viability of the ELV dismantling/recycling sector is fragile and hardly allows 
them to meet the current targets on recycling and re-use set out in the ELV Directive and 
do not provide an economic incentive to properly depollute and dismantle relevant parts; 
there is limited interest for car manufacturers to consider the recyclability/re-usability of 
the materials that they are using for the production of vehicles, nor on the quantity and 
quality of recycling fractions like steel, aluminium and copper/ EEC / non-ferrous.   

• 

In addition, there is no incentive for the dismantling/recycling sector to dismantle, recycle or 
re-use  materials  or  components  like  plastics,  electronics  or  glass,  as  these  operations 
generate costs which cannot be covered through the revenues resulting from the sale of these 
materials  and  components.  As  a  result,  the  rate  of  recycling  or  re-use  of  these  materials 
remains very low 

The environmental benefits (expressed in credits for reduced CO2 eq emissions for recycling) 
are displayed for instance for glass in Figure 3-12 demonstrating a potential credit for better 
management of glass of around 140 000 t CO2 eq in 2035. The environmental and economic 
impacts for other materials regard higher recycling rates and / or higher quality of the recyclate 
are discussed in section 3.1 on the impacts of measures addressing circularity. 

165 Reuse of parts (and sells for remanufacturing) contribute to the profits of ATFs. Regards the complete economic situation of 
ATFs pls refer to section 2.3.2.4 Existing Producer Responsibility Organisations at page 89 

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Furthermore, even for materials which are accounted as fully or nearly fully recycled under 
the ELV Directive (steel and non-ferrous metals), there is no incentive to perform high-quality 
recycling, such as ensuring that steel or aluminium scrap from shredding contain minimum 
levels of contamination by other metals (i.e. copper). This reduces the value of such steel or 
aluminium scrap and the possibility to use them in a number of applications.  

The lack of profitability of the dismantling/recycling sector jeopardises the attainment of the 
objectives of the ELV Directive and would be an obstacle to the attainment of more ambitious 
targets designed to ensure a higher recovery of all materials in ELVs, a better quality of the 
recyclates and subsequently lower environmental impacts in further downstream treatment.  

The  market  conditions  therefore  do  not  allow  to  internalise  the  costs  linked  to  high  quality 
recycling and re-use of materials from ELVs and the current EU regulatory framework does 
not address this problem either. 

Some Member  States  have  enacted measures  to  oblige  car manufacturers to  cover  some 
costs linked to the implementation of the ELV Directive, either through the establishment of 
fees  paid  to  the  administration  or  the  establishment  of  producer  responsibility  schemes. 
These measures are mostly focusing on the obligations under the ELV Directive to ensure 
the collection of ELV and their delivery to ATF. They do not address the costs linked to the 
compliance of obligations linked to the dismantling and recycling/re-use of materials, parts 
and components of ELVs.  

There is therefore currently no harmonised approach at the EU level which would ensure the 
financial  profitability  of  comprehensive  and  high-quality  recycling  and  re-use  of  materials, 
parts and components from ELVs.  

2.3.3.2  Description of the problem drivers  

Market failure: The current system is purely economically driven. Insofar the dismantlers and 
recyclers must assess the risk of investments in high quality recycling and volatile prices for 
recyclables. So even if the investment is profitable today, it might be discarded as too risky 
due to unclear expectation on volatile revenues for recyclates. The market conditions (high 
investment  causing  fixed  costs,  volatile  prices  of  scraps,  competition  with  prices  of  virgin 
materials…) make it challenging for dismantlers/recyclers to perform recycling in line with the 
current targets and in consequence environmental costs are not internalised. This prevents 
getting to higher quality and more quantity of materials recycled in the future.  

Market failure: As soon as political ambitions regard CE will increase (or prices for steel / 
Aluminium/catalytic  converters  drop  significantly)  the  system  of  the  “shared  responsibility” 
between Producer and recycler is at risk to become unprofitable business for ATFs. In this 
case, it is likely that ATFs seek to escape their obligations and began to behave illegally (and 
it is not always possible to have inspection or supervision by public authorities) and illegal 
operators (avoiding all economically not attractive operations) will become more attractive to 
the last owner as such operators will be able to pay a higher compensation to the last owner, 
compared to the fully compliant ATF.  

Regulatory failure: Today there is no clarification which compliance cost shall be covered 
by the producers in such a way that gap between compliant and non-compliant operations is 
sufficiently bridged. 

Regulatory failure: The current definition of recycling is too lenient, even not at the level of 
the Waste Framework Directive (WFD). More advanced criteria, beyond the WFD, regards 
the  quality  of  the  recyclate,  with  the  aim  to  avoid  downcycling,  are  not  established  in  the 
current ELV Directive. In consequence and in combination with the not defined contribution 

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of producers to the compliance costs, the dismantlers and recyclers have no incentives or 
ambition to improve quantity or quality of recycling. 

Regulatory failure: Lack of proper EPR provisions in the ELV legislation as for instance the 
often-mentioned  lack  of  clear  responsibility  on  who  shall  cover  which  compliance  cost 
(producer / dismantler/recycler)  

Market failure/regulatory failure: The potential to improve efficiency and effectiveness in 
terms  of  high-quality  recycling  through  two-way  information  exchange  and  improved 
cooperation is not being realised due to a lack of incentives (or legal requirements):   

•  Producers miss  to  learn from  dismantler/shredder to  design  the  vehicles for  reuse  and 
recycling,  avoiding  unnecessary  dismantling/repair  effort  and  avoiding  cross 
contaminations in recycling fractions. 

•  ATFs do not have access to information on reuse (digital key) and remanufacturing and 
on components worth for dismantling for recycling as profitable revenues from high quality 
recycling can compensate the dismantling effort. 

•  Cooperation  between  recyclers  and  producers  is  rare  when  it  comes  to  developing 
improved recycling technologies and infrastructures to increase the quantity and quality 
of recycling, especially in the case of new recycling capacities and technologies for newer 
lightweight materials and electric powertrains.  

•  Producers  are  not  aware/do  not  respect  the  need  of  long-term  perspective  for  high 

investment in advanced recycling technology. 

Currently, such exchange is limited to information on parts which are legally to be dismantled 
(IDIS information). A distinct definition on minimum information exchange / cooperation can 
gain the potential for reuse and recycling mentioned above. Such exchange would make it 
attractive to act as a legal operating ATF and also attractive for OEMs, as it might reduce the 
compliance cost to be compensated. 

2.3.3.3  Key players and affected population 

Directly  involved  as  stakeholders  of  EPR  schemes  are  producers  and  ATFs  and  also 
shredders  as  far  as  it  comes  to  more  advanced  quality  requirements  for  the  shredder 
output/PST.  Public  authorities  might  be  involved  in  the  governance  or  supervision  of  the 
collective/individual PROs. The affected population are all vehicle users, depending on the 
level  of  required  compliance  and  in  consequence  the  compliance  cost,  which  are 
subsequently most likely added to the price of the product. 

2.3.3.4  Why should the EU act? 

The  EU  established  in  2018  the  WFD  Art  8a  the  general  minimum  requirements  for  EPR 
schemes that have been established before 4 July 2018. These EPR schemes shall comply 
with Article 8a by 5 January 2023. The ELV sector is excluded from Art 8a (4a) and the current 
ELV Directive (lex specialis) established in 2000 thus much before the WFD does not specify 
how the producers shall contribute to the compliance with the targets. The current regime is 
purely  economically  driven,  disregarding  advanced  environmental  requirements  (circular 
economy/high quality recycling), contributes strongly to the illegal dismantling sector166 and 
is  missing 
the  producers  and 
dismantlers/recyclers.  

to  provide  specifications 

the  cooperation  of 

for 

166 See sections on “missing vehicles”: no incentives apply to register as ATFs and report CoDs, instead illegal operators have 
an economic advantage of around 300 € per ELV. 

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Product and waste management legislation like the WEEE Directive (2012), the Packaging 
Directive (2018) and the draft for the Batteries Regulation, considered as lex specialis in the 
WFD Art 8a too, elaborate in much more details on the responsibility of the Producers.  

As  (used)  vehicles  and  ELVs  are  traded  across  the  EU,  discrepancies  in  the  EPR 
requirements  for  Producers  on  the  one  hand  and  ATFs  and  shredders  on  the  other  hand 
would cause unintended shipments between Member States which would violate the principle 
of proximity (art 16 WFD).  

Therefore,  and  to  establish  economically  a  level  playing  field  (similar  rules  applying  to  all 
economic  actors  in  the  EU  single  market  with  similar  EU  rules  on  the  protection  of  the 
to  support 
environment 
dismantling/recycling and similar support to dismantling/recycling sector) it is necessary that 
the basic rules for the cooperation of producers and the ELV sector and the obligations of the 
MS in this regard are defined at EU level.  

(so  similar  contributions 

from  OEMS  across 

the  EU 

2.3.4  Which objectives should be achieved? 

The  EPR  Scheme  for  ELVs  shall  become  future-proof  and  support  the  CE  including  high 
quality recycling and enable investments of the recycling sector which are, under the current 
situation, considered as too risky.   

The specific objectives are to support higher quantity and quality of recycling and re-use in 
the automotive sector (so higher rate of recycling, especially for materials where it is currently 
low,  and  higher  quality  of  recycling  for  other  materials  currently  officially  accounted  as 
recycled, but too often with low quality). 

Other elements of the EPR shall trigger the design of new vehicles for CE. 

More specific objectives are to ensure transparency and a fair distribution of costs linked to 
the treatment of ELV, in line with the polluter-pays principles (specification of WFD Arts 8a 
(4a)) 

Specification of other elements of Art 8a WFD in the lex specialis as for instance rules for the 
fee modulation (Art 8a (4b)) or governance aspects (Art 8a (5)) and others. 

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2.3.5  What are the measures to achieve the objective? 

The measures are grouped as follows:  

1)  Specifications  of  the  General  minimum  requirements  (WFD  Art  8a):  Obligations  for 

Member States how to establish EPR schemes 

2)  Specifications  of  the  General  minimum  requirements  (WFD  Art  8a):  Obligations  for 

Producers: 

a) 

to support better collection, 

b) 

to support high quality recycling, 

c) 

to support design for recycling,  

3) Advanced European EPR  

4) Other advanced economic instruments / incentives 

2.3.5.1  Specifications  of  the  General  minimum  requirements 
(WFD  Art  8a):  Obligations  for  Member  States  how  to 
establish EPR schemes  

1.1 The new ELV legislation will set out an obligation for all MS to establish national EPR 
schemes  in  compliance  with  WFD  Article  8/8a  and  will,  for  some  aspects  provide 
specifications 

1.2 MS shall report on implementation of the minimum requirements (WFD Art 8 and 8a) 

and the specific requirements under the new ELV Regulation.  

Reasoning: No sufficient evidence available whether and how the MS established the 
minimum and specific requirements for the ELV EPR schemes.  

1.3 Member States shall appoint an independent competent authority (clearing house) to 
monitor  the  compliance  with  the  minimum  requirements  addressed  in  the  WFD  Art 
8/8a  and  the  other  requirements  added  by  the  “lex  specials”  for  ELVs.  Such 
independent  competent  authority  shall  also  monitor  the  average  effort  for  the 
obligatory compliance operations and the revenues from these obligatory compliance 
operations  and  to  define,  as  necessary,  financial  compensation  of  compliance 
operation to ATFs (the last applicable only if the measure compliance cost offsetting 
is  established)  and moderate  the  implementation  of  the  fee  modulation Reasoning: 
this is a specification of WFD Article 8a(5) and Art 8a (4b) 

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2.3.5.2  Specifications  of  the  General  minimum  requirements 

(WFD Art 8a): Obligations for Producers 

2.1  Producers to be responsible for the collection of vehicles at holder’s premises167 and 

abandoned vehicles free of charge for the last holder. 

Reasoning: specification of WFD Art 8a(3) point (b). 

2.2  Producers  to  cover  the  costs  for  communication/awareness-raising  campaigns 

designed to improve the collection of ELV 

Reasoning:  re-introduction  of  the  Art  8a  (4a),  second  dash:  currently  this  aspect  is 
excluded  for  the  ELV  Directive,  but  shall  be  re-introduced  by  the  revised  ELV 
Regulation 

2.3  Producers  responsible for the  establishment  of a  notification/  reporting system  for 

ELV, CoD and final cancellation of the registration as explained in measure  

a) 

“Obligations  for  dismantlers  /recyclers  to  check  and  report  on  ELVs  /  CoDs” 
(page 165) 

b)  Support  to  the  international  notification  system  as  explained  in  measure 
“Improve the exchange of information between national registration authorities 
including obligation for MS to provide reasons for de-registration.” (page 165) 

Reasoning: this is a specification of WFD Article 8a(1) point (a) and (c). 

2.4  Producers  responsible  to  provide  rules,  software,  and  plausibility  checks  for  the 
monitoring  of  material  flows,  with  the  aim  to  demonstrate  compliance  with  RRR 
targets. The interfaces for the ATFS and shredders shall be a single contact point / 
interface (not a different system for all brands) making it most comfortable to the ATFs 
and shredders to apply the system (and demonstrate compliance). 

Reasoning: this is a specification of WFD Article 8a(1) point (a) and (c). 

2.5  Producers responsible to support monitoring and reporting on illegal activities in the 

sector to responsible authorities (police and environmental inspectorates) 

Reasoning: As reported at a meeting of the German Ministry of the Environment, the 
illegal  operators  are  well  known  to  the  legal  operators,  but  the  legal  operators  are 
reluctant to take legal action for two reasons: They are afraid of the time involved in 
such proceedings, and they are afraid of being personally attacked. 

2.6  Producers  responsible  to  cover  costs  linked  to  the  training  of  staff  from 
dismantling/recycling  sector  (for  example  to  acquire  the  necessary  skills  to  remove 
batteries from electric ELVs), as well as the reporting, via digital means, by this sector 
on the attainment of the recycling/reuse targets set out in EU legislation. 

167 As included in the French Climate and resilience bill (2021): Article 32, 
https://www.legifrance.gouv.fr/jorf/id/JORFTEX00043956924 

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2.7  Producers  responsible  to  provide  easier  access  to  harmonised  information 

(advanced IDIS) as addressed in Measures 

• 

• 

• 

 “2.1.f)  Obligatory  reporting  requirements  on  the  use  of  materials  that  affect 
dismantling  and  recyclability  to  facilitate  identification  of  incompatible  practices” 
(page 116) 

 2.1.i)  Set  out  an  obligation  for  OEMS  to  provide  additional  information  on 
composition of cars” (page 120) 

“Improved  communication  on  hazardous  substances  in  the  automotive  value 
chain” (page 123) 

2.8  Fee modulation for collective EPR schemes:   

Producers shall provide the national competent authority (clearing house) with data 
relevant  for  the  fee  modulation.  The  national  competent  authority  (clearing  house) 
shall  propose/  publish  criteria  for  the  fee  modulation  in  close  and  transparent 
cooperation with the producers and the stakeholders of the dismantling and recycling 
sector.  The  producers  shall  provide  this  information  together  with  the  information 
document they provide on reusability and recyclability in the context of the European 
Union  vehicle  RRR  type  approval.  For  vehicles  with  type  approval  before  these 
provisions entered into force, the producers shall provide these data for all types the 
latest 2 years after this obligation entered into force. Small series and end-of series 
limits as defined in Annex V of the Regulation (EU) 2018/858 168 are exempted. 

The modulation of total EPR fees can be based on criteria such as:  

•  Weight of a vehicle (the production of a heavier vehicle requires the use of more 

primary resources than the production of a lighter one) 

•  Type of vehicles (combustion engine vehicles, BEV, HEV, PHEV, FCEV, others) 

•  how much the lifetime / the use phase of components can be expanded by repair, 

re-use and remanufacturing at reasonable costs,  

•  The  expected  level  of  recyclability/  re-usability  of  materials  and  components, 

based on the 3R type approval declarations 

•  dismantling time of parts which need to be removed prior to shredding under the 

new legislation to allow for re-use, remanufacturing or recycling 

• 

• 

the share of materials disturbing recycling / polluting recyclable materials during 
the recycling process, 

the share of components difficult to repair, reuse, remanufacture or recycle, 

168 Regulation (EU) 2018/858 of the European Parliament and of the Council of 30 May 2018 on the approval and market 
surveillance of motor vehicles and their trailers, and of systems, components and separate technical units intended for such 
vehicles, amending Regulations (EC) No 715/2007 and (EC) No 595/2009 and repealing Directive 2007/46/EC 

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• 

the level of recycled content (metal, plastics, other), 

•  The presence and location of hazardous substances 

The fee modulations for the national EPR schemes shall be effective at the latest by 
four  years  after  the  regulation  entered  into  force  and  EPRs  shall  prove  that  the 
modulation effectively contributes to CE and is not marginal to the producers.  

If  necessary,  a  detailed  methodology/guidance  would  be  established  to  render  the 
above-mentioned criteria more operational.  

> EC entitled to develop guidelines / implementing acts <  

Reasoning:  this  is  a  specification  of  WFD  Art8a(4)b:  The  fee  modulation  shall  create 
economic  incentives for those OEMs  that  advanced  compared to  the  standard  in  terms  of 
reusability, remanufacturing, and recycling of the product.  

2.9 Compliance Cost offsetting 

The Producers shall offset compliance cost if these costs are not recovered by the 
result of the distinct operation. The decision on the required level of the offset shall 
be discussed in close cooperation with the stakeholders under. The national 
competent authority / clearing house shall establish procedures for the cooperation, 
moderate this cooperation and take and publish regular decisions on the level of the 
offset for different compliance operations. 

> EC entitled to develop guidelines/implementing acts < 

2.9a Establishment of an obligation for producers to cover costs of the dismantling sector, 
linked to mandatory dismantling of parts and components prior to shredding, as laid 
down in the future legislation (i.e. the fees paid by producers should amount to the 
difference between revenues generated by the sale of these parts/components and 
the costs linked to their dismantling) 

Examples 

•  The  effort  of  ATFs  for  the  (destructive)  dismantling  of  catalytic  converters  (and 
storage  and  transport  to  recyclers)  is  compensated  by  the  revenues  for  the 
separated catalytic converters. Offsetting of the compliance cost is not required.  

•  The effort of ATFs for the (destructive) dismantling of glass, electric and electronic 
components  and  large  plastic  components  (and  storage  and  transport  to 
recyclers)  is  not  compensated  by  the  revenues  for  the  separated  material. 
Offsetting of the compliance cost is required.  

•  The effort for the dismantling of a traction battery from an electric ELV, the storage 
and  the  transport  to  a  recycling  facility  is  often  not  compensated  by  revenues 

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received for selling the battery169. This is in particular the case if the traction battery 
is from an ELV after (technical total loss) accident. Offsetting of the compliance 
cost is required. 

Reasoning:  specification  of  Art  8a  (4a)  WFD.  As  demonstrated  in  section  2.3.2.3 
“Economic  situation  of  the  sector”  on  page  184,  the  illegal  sector  has  in  different 
scenarios  higher  benefits  compared  to  ATFs  of  about  250 €  to  300 €  per  ELV.  In 
consequence, ELVs are directed in high numbers to the illegal sector. The difference of 
the benefit between legal and illegal will increase if ATFs shall carry out additional non-
profitable  obligations  in  the  future  to  address  the  Circular  Economy  aim  of  the  EU.  In 
consequence,  more  vehicles  would  be  directed  to  the  illegal  sector  if  compliance  cost 
were not compensated. 

2.9b Establishment of an obligation for producers to cover costs of the recycling sector, 
linked to requirements for higher amount and/or quality of recycling (costs linked to 
the difference between revenues generated by the sale of these materials and costs 
linked to their recycling, as well as costs linked to training of staff for these dismantling 
operations and possible investments, for ex. new recycling technologies). 

Reasoning: specification of Art 8a (4a) WFD. 

2.3.5.3  Advanced European EPR  

3.1  EPR Schemes for intra EU Trade (delegated / implementing act) 

In  case  of  EPR  schemes  or  DRF  schemes  apparently  unfair  allocation  of  funds  between 
Member  States  might  be  caused.  To  overcome  such  adverse  effects,  a  transfer  of  funds 
together with the export of the used vehicle might be an option. 

For  this  purpose,  the  EC  shall  be  invited  to  develop  criteria  to  ensure  cross-border 
cooperation concerning extended producer responsibility schemes for ELVs (see Article 8(5) 
of the  WFD,  where this was  already  foreseen  for municipal  waste,  but  has  not  been  done 
yet). This is important to ensure that EPR schemes properly cover the costs of vehicles which 
are treated at the end of their life in a Member State which is different from the MS where 
these vehicles were put on the market. 

Reasoning: Used vehicles are traded within the EU in high numbers. For instance, Germany 
reports  statistically  documented  exports  of  used  vehicles  to  EU  countries  in  2018  of  1.95 
million plus 0.15 million vehicles of statistically unaccounted exports to EU countries170. If a 
fee is collected for these vehicles when placed on the market this fee is not available to the 
dismantlers/ shredders where the vehicles was exported to.  

169 This is currently and for the next year expected as the number of such batteries is very small but preparedness for the 
management is cost expensive as employees need specific education/training and storage needs specific heat controlled and 
fire-proof containers. Transport is expensive too, as for the next year only limited amounts are shipped, and specific permits 
are required for the shipment.  

170 German Environment Agency & Federal Ministry for the Environment, Nature Conservation and Nuclear Safety (6 July 
2020): Jahresbericht über die Altfahrzeug-Verwertungsquoten in Deutschland im Jahr 2018 

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3.2  European EPR for the European market (feasibility study) 

To  assess  the  opportunity  of  a  harmonised  European  wide  EPR  system  instead  of  many 
national EPR systems, the EC will initiate a working group with Member States and relevant 
stakeholders to discuss possible options and their advantages and challenges. The EC shall 
prepare a feasibility report on the results of this working group two years after the Regulation 
entered into force.  

Reasoning: The introduction of an EPR system at EU level rather than at Member State level 
could be interesting, as the type-approval of vehicles is harmonized for all vehicles placed on 
the European market (a type-approval in one Member State is recognized in all other Member 
States).  Information  requirements  are  for  many  aspects  the  same  and  procedures  and 
software  might  be  harmonised.  Such  system  would  also  enable  to  regulate  the  transfer  of 
collected EPR fees from the exporting country to the importing country.  

It is assumed that such an approach would be appreciated by producers, however the concept 
is premature and needs more preparation time and cooperation with stakeholders on details.  

2.3.5.4  Advanced economic incentives 

4.1 Deposit Refund (DRF) Schemes managed by OEMs.  

DRF schemes are described in detail in section 2.2.5.2.3. In principle such DRF 
schemes can be managed by public authorities / public fund management as it is 
done for the two existing systems in Denmark and Norway. Despite this existing 
experience it is possible that such DRF schemes are managed under EPR 
obligations as it is the case for some DRF schemes under the Packaging and 
Packaging Waste Directive. 

As the measure under section 2.2.5.2.3 is developed as voluntary measure, the MS are free 
to opt whether DRF schemes shall be managed by public authorities or by producers. 

4.2 Green Public Procurement (GPP) 

The EU GPP criteria are developed to facilitate the inclusion of green requirements in public 
tender documents. While the adopted EU GPP criteria aim to reach a good balance between 
environmental performance, cost considerations, market availability and ease of verification, 
procuring authorities may choose, according to their needs and ambition level, to include all 
or only certain requirements in their tender documents.171  

The currently valid document on GPP criteria for road transport addresses for purchase, lease 
or  rental  of  cars,  light  commercial  vehicles  (LCVs)  and  L-category  vehicles  with  low 
aspects172:  
the 
environmental 

following 

impact 

•  TS1.  Type-approval CO2 value  

171 https://ec.europa.eu/environment/gpp/eu_gpp_criteria_en.htm (accessed: 10 June 2022) 

172 COMMISSION STAFF WORKING DOCUMENT: EU green public procurement criteria for road transport; SWD (2021) 296 
final; Brussels, 18.10.2021 

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•  TS2.   Air pollutant emissions  

•  TS3.   Energy consumption display  

•  TS4.   Traffic information and route optimisation  

•  TS5   Minimum warranty  

•  AC1.  Lower CO2 emissions  

•  AC2   Energy efficiency 

•  AC3.  Improved air pollutant emissions performance  

•  AC4.  Zero tailpipe emission capability  

•  AC5.  Speed limiter  

•  AC6   Extended warranty  

The Commission's Joint Research Centre's Institute for Prospective Technological Studies 
(JRC-IPTS) in Seville/Spain is leading the GPP criteria development process on the basis of 
an annual GPP work plan which is coordinated with the EU Ecolabel workplan. This work plan 
is adopted in consultation with the informal GPP Advisory Group (GPP AG). 

The aspects of repairability, remanufacturing, reusability and recyclability are not considered 
so far in the last version of the GPP criteria for road transport. 

Information  with  this  regard  can  be  derived  from  the  revised  RRR  type  approval  and  the 
information provided by the OEMs for the modulation of EPR fees. Today this information is 
not available yet.  

The EU Directive on Energy Efficiency (EED) is currently under review173, inter alia with the 
aim to strengthen the obligatory application of the procurement criteria for a broader scope of 
contracting authorities (see Article 7 in the draft revision). 

The measure would be to include an Article in the revised ELV Regulation similar to Article 
70 of the draft Batteries Regulation174. The Article shall introduce additional criteria for GPP: 
aspects of repairability, manufacturability, reusability, and recyclability. Two years after entry 
into force of the Regulation the EC shall provide detailed specification of the criteria and the 
relation to Directive 2014/24/EU by a delegated act. 

173 Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on energy efficiency (recast); 
Dossier interinstitutionnel:2021/0203(COD), Bruxelles, le 20 juin 2022 

174 EU Commission (COM(2020) 798 final; 2020/0353: Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT 
AND OF THE COUNCIL concerning batteries and waste batteries, repealing Directive 2006/66/EC and amending Regulation 
(EU) No 2019/1020 

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2.4  Extension  of  the  vehicle  categories  in  scope  of  the  ELV 

Directive 

2.4.1  Introduction 

In an impact assessment, when analysing the burden and benefits of amending a legislative 
text, the question of the appropriateness of the scope of the legislation is one that is often 
asked.  In  the  case  of  the  ELVD,  the  question  of  an  extension  of  the  vehicle  categories  in 
scope was raised in earlier studies, e.g., in the Evaluation of the ELV Directive (Williams et. 
al 2020) as well as in the Scoping Study to assess the feasibility of further EU measures on 
waste prevention (European Commission 2022c). The possibility of extending the scope to 
additional  vehicle  categories  is  sought  to  analyse  the  possibility  of  incentivising  a  circular 
approach in the production and end-of-life treatment of vehicles currently outside the scope 
of the ELV Directive. 

The  current  scope  of  the  Directive  (according  to  ELVD  Art.  2.1)  includes  cars  and  vans 
classified as M1175, light-commercial vehicles classified as N1176 (< 3,5 tons), and three-wheel 
motor vehicles as defined in Directive 92/61/EEC 1992177 but excludes motor tricycles (which 
are of type L5e as defined in Regulation 168/2013 2013178). The study focusses on assessing 
the need and feasibility of expanding the scope of the ELV legislation to the following type-
approved road vehicles: 

•  L  vehicles  (powered  two-  and  three-wheel  vehicles,  mopeds,  motorcycles  (incl. 
motorcycles with side-car) and quadricycles), type approved through REGULATION (EU) 
No 168/2013, referred to as powered two- and three wheelers (PTW) in the following; 
•  M vehicles (used for the carriage of passengers, e.g. cars and buses), N vehicles (used 
for the carriage of goods, e.g. lorries), and O vehicles (trailers including semitrailers), type 
approved  through  REGULATION  (EU)  No  2018/858  with  the  exemption  of  vehicle 
category T (agricultural tractors). 

Expanding the scope of ELVD to non-type approved e-bikes, ships, planes, trains, agricultural 
and non-road mobile machinery (NRMM, T-approved), and military purposes & space is not 
part of the assessment. These vehicles have a common the characteristic that they are non-
road vehicles, with the exemption of non-type approved (electric) bicycles. Main reasons for 
not  considering  the  inclusion  of  non-road  vehicles  under  the  scope  of  ELVD  are  that  they 
have own regulations, e.g., for e-bikes or ships, or series in which they are produced are very 
small, e.g., trains or NRMM. Also, their type-approval is separate to that of road vehicles and 
in particular does not address objectives of the 3R Type approval. Details can be found in 
section 6.1.1.  

175 Category M1: Motor vehicles designed and constructed primarily for the carriage of persons and their luggage and 
comprising not more than eight seating positions in addition to the driver’s seating position. Vehicles belonging to category M 
1 shall have no space for standing passengers. The number of seating positions may be restricted to one (i.e. the driver’s 
seating position). See Regulation (EU) 2018/858. 

176 Category N1: Motor vehicles designed and constructed primarily for the carriage of goods and having a maximum mass not 
exceeding 3,5 tonnes. See Regulation (EU) 2018/858. 

177 Council Directive 92/61/EEC of 30 June 1992 relating to the type-approval of two or three-wheel motor vehicles (repealed 
by Regulation (EU) No 168/2013 of the European Parliament and of the Council of 15 January 2013 on the approval and 
market surveillance of two- or three-wheel vehicles and quadricycles) 

178 Regulation (EU) No 168/2013 of the European Parliament and of the Council of 15 January 2013 on the approval and 
market surveillance of two- or three-wheel vehicles and quadricycles Text with EEA relevance 

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As  on  section  7.4.2  discussed,  the  question  also  arises  as  to  whether  this  results  in 
consequences for the scope of Directive 2005/64/EC 2005179 on the type-approval of motor 
vehicles  with  regard  to  their  reusability,  recyclability  and  recoverability  (3R  Directive),  and 
what might be the effects / impacts thereof. Closely connected with ELVD, the 3R Directive 
ensures that ELVD design requirements are fulfilled. The link between the two Directives is 
further discussed in Annex II of this report, where sections 7.2.2.2 and 7.4.2 (both in Annex 
II) specifically focus on the scope of the 3R Directive and its comparison with the scope of 
ELVD. As the process according to 3R Directive (section 7.2.3, Annex II) is part of the general 
process  of  type  approval  and  in  particular  Regulation  of  EU  2018/858180,  its  functioning  is 
independent of the ELVD. Nonetheless, it is important to consider how the two Directives are 
kept aligned and how this is to be monitored in the future. Because this study is intended to 
support the IA of the ELVD, the before-mentioned question only plays a role in a few places. 

2.4.2  Current Situation  

In  the  EU,  322  million  vehicles  were  registered  in  2020.  Currently,  by  unit,  ~83 %  of  all 
vehicles are within the scope of ELVD (~74 % Passenger cars (M1 type) and ~9 % lorries 
(N1 type)) resulting in 17% of vehicles (by unit) that are not covered (line 2 in Table 2-13 plus 
1,2% from special purpose vehicles). In terms of mass, about 33 % (~159 million tons of the 
stock; lines 4 & 5 in Table 2-13 plus 2% from special purpose vehicles) are not covered by 
the Directive181. See the full data and calculation in the Annex I (Table 6-2).  

Table 2-13 Overview of units and weights of PTW, buses, lorries and semi-trailers in 
2020 

PTWs (L)* 

Buses (M2, M3) 

Lorries 
N3) 

(N2, 

(Semi-)Trailer 
(O) 

Stock in 2019/20 

22.296.012 

703.368 

6.218.833 

18.250.515 

by 

6,9% 

0,2% 

1,9% 

5,7% 

Percentage 
number  

(See Table 6-2) 

weight 
Average 
payload) 
(without 
per vehicle (range) 

84  kg  –  282  kg 
and 
(ADEME 
SURPLUS MOTOS 
2022) 

t  –  13,5 

8 
(EC 2015) 

t 

t  –  14,5 

2 
(EC 2015) 

t 

2.64  –  7,84  t  (see 
Annex,  Table  6-8)  

Total  weight 
stock in 2019/20 

of 

4.080.170 t 

7.561.206 t 

51.305.372 t 

95.815.204 t 

179 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 and amending Council Directive 70/156/EEC 

180 Regulation (EU) 2018/858 of the European Parliament and of the Council of 30 May 2018 on the approval and market 
surveillance of motor vehicles and their trailers, and of systems, components and separate technical units intended for such 
vehicles, amending Regulations (EC) No 715/2007 and (EC) No 595/2009 and repealing Directive 2007/46/EC 

181 A recent publication (2022c) reported that a share of 19% by weight (94 million tonnes) was not covered by the ELVD. 
However, this study did not include the trailers and semi-trailers. According to the data in Table 6-2, trailers represent ~5,7% 
of all vehicles by number and ~18,1% by weight.  

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(See Table 6-2) 

0,8 % 

by 

Percentage 
weight  

(See Table 6-2) 

1,4 % 

9,7 % 

18,1 % 

Source: Eurostat 2021 for stock of PTW and (semi-)trailers in 2019; PRIMES (European Commission 2022b) for stock of 
buses and lorries in 2020. A full overview of data is provided in Table 6-2 (Annex I). 
Notes: (*) The Eurostat dataset is not consistent with the L-type-approval categories of (EU) 168/2013. It is assumed that in 
addition to the indicated number of motorcycles, 10-15% of additional L-type approved vehicles might be on the market. 

Information  that  provides  an  overview  of  the  current  situation  of  end-of-life  treatment  and 
circularity of vehicles not in scope of ELVD is rare. Therefore, the stakeholders’ descriptions 
represent an important reference for describing the status-quo.  

Looking at powered two-wheelers (PTW), only a very small number is returned to 
recyclers,  i.e.,  to  authorized  treatment  facilities  (ATFs)  as  parts  are  supposedly 
removed  by  the  owners and  specialized  operators  beforehand.  Figures  as  to the 
numbers of PTW treated in ATFs cannot be provided due to the lack of data. As far as it is 
known, there are no specific PTW recyclers (‘never seen one’, says the European Association 
of  Motorcycle  Manufacturers  ACEM).  Compared  to  other  types  of  vehicles,  such  as  cars, 
PTW  have  no  ‘chassis’.  Thus,  a  component  which  represents  a  considerable  amount  of 
vehicle’s  material  is  not  available.  This  means  that  the  material  from  PTWs  that  could 
potentially  be  sent  to  shredder  after  removal  of  components  is  very  little.  In  general,  ‘car 
dismantlers say that they would gladly take the PTWs [if they would get them]. Standard tools 
can  be  used,  dismantling  is  easy,  no  investments  nor  additional  training  of  recyclers  is 
needed. Car recyclers receive accidental PTW but not the end-of-life PTW.’ (ACEM 2021)  

In general, stakeholders reported that the practice of reuse is more established for PTW as 
well  as  for  trucks  and  buses  than  for  passenger  cars  (ACEM  2021;  ACEA/Volvo  2021; 
ANERVI/AETRAC  2021).  This  is  supported  through  reuse  statistics  for  PTW  in  Finland 
(SMOTO 2021) and best-practice examples for heavy duty vehicles from literature (Saidani 
et al. 2018). The reuse rate of the parts for PTW at Finish operators specialized in the handling 
of motorized two-wheeled vehicles was found between 60 and 70%. At around 95%, the reuse 
rate  is  even  higher  for  practitioners  at  motorcycle  clubs  (hobbyists).  On  the  other  side,  at 
operators specialized in car handling, the reuse of parts from PTW is only around 10% (see 
Annex, Figure 6-3).  

In 2019, the EU motorcycle sector had 389 000 jobs and contributed around 21.4 billion euros 
to the gross domestic product across Europe. In terms of tax revenue, 16.6 billion euros can 
be attributed to the motorcycle industry, which is particularly important in the large markets 
such  as  Germany,  France,  Italy,  the  UK  and  Spain.  Export  of  European  and  UK-based 
companies  in  the  motorcycle  sector  to  non-European  customers  worth  around  2.1  billion 
euros each year. The most important export markets include the USA, Switzerland, Australia 
and Japan. (Dervisevic 2021) With regards to masses or weights motorcycles are significantly 
lighter than  cars: motorcycles  on  average  weigh less  than  10% to  15%  of  a  car.  Also,  the 
number of parts is smaller than that of cars. This in consequence will lead to lower recycling 
masses and less parts available for reuse. (ACEM 2021) 

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While PTWs can be treated at car recyclers, buses and lorries182 require 
treatment  at  specialized  dismantling  and  recycling  facilities.  Lorry  and 
bus  dismantlers  and  recyclers  require  larger  spaces  due  to  the  larger 
size of the vehicles, e.g., larger space for storing ELVs, and they require different equipment 
for the depollution or to work with specific components, e.g., steel parts are thicker in lorries. 
At present, national ELV and general waste legislations oblige dismantlers and recyclers to 
pre-treat,  i.e.,  de-pollute,  end-of-life  lorries.  (ACEA/Volvo  2021;  ANERVI/AETRAC  2021) 
Lorry recycling infrastructure is different in different EU MS: In Spain, 25-30 ATFs exist that 
treat  ELV  lorries.  ‘Heavy  duty  vehicles  that  have  been  received  by  ATFs  in  Spain  in  2021 
were  around  7.000  units,’  says  a  representative  of  SIGRAUTO  (Workshop  2022). 
Additionally,  according  to  ANERVI/AETRAC,  Lithuania,  Estonia  and  Latvia  have  a  strong 
business in lorry treatment. In many countries, e.g., France, the number of end-of-life lorries 
is expected to be too small for specialised ATFs to be economically viable. According to a 
representative of ADEME, ‘today, there are only nearly 20 specialised companies in France’ 
(Workshop  2022). Generally,  lorry  recycling  is  considered  a  profitable  business  due  to  the 
high number of metals (EGARA 2021). Thereby, means costs can be topped by the revenues 
from recycling  and  spare  part sales.  ‘Buses  are  a  bit  different  – the  engines  are  similar  to 
trucks. The parts of the steering can be used, and they are probably also exported. There is 
more waste on a bus, because it has a lot of glass and sometimes the coach has (laminated) 
aluminium or other funny materials’, EGARA (2021) says. 

Stakeholders reported that the practice of reuse is more established for trucks and buses (as 
for  PTWs)  than  for  passenger  cars  (ACEM  2021;  ACEA/Volvo  2021;  ANERVI/AETRAC 
2021).  Looking  at  lorries,  according  to  ANERVI/AETRAC  (2021),  ‘there  is  a  specialised 
market for parts from lorries across Europe. There is a high demand for and well established 
communication on the availability of spare parts A flourishing market for spare parts suggests 
that repair and reuse play an important role in the end-of-life treatment of lorries. ACEA/Volvo 
(2021)  comments  that  ‘reuse  […]  is  already  strongly  driven  by  the  market’  and  adds  that 
‘certain  components  that  are  very  expensive  can  also  be  refurbished  and  reused  –  like 
engines,  turbo  chargers,  catalysts,  starter  engines.  So,  everything  is  already  designed  to 
allow  the  easy  replacement  during  the  lifetime  of  a  lorries.  We  already  design  for  reuse. 
Customers  demand  delivery  over  20-30  years  for  spare  parts.  It  is  driven  by  supply  and 
demand.’ Another business model is the leasing of vehicles, e.g., SCANIA (2022) considers 
‘a shift towards servicisation’, thus, ‘transport as a service, mobility as a service, vehicles as 
a service, shared services, operational lease, rental’. 

A study by Saidani et al. (2018) supports these statement (details are described in Annex I, 
section 6.1). Information on or any estimation of a reuse rate for parts from lorries is lacking. 
For  buses  and  trailers,  information  on  the  extent  of  reuse  of  parts  is  not  available  from 
stakeholder interviews. 

Main materials of trailers are steel, plastics, light metals, e.g., aluminium, textiles 
(for  curtains),  and  wood.  ANERVI/AETRAC  says  that  ‘an  ATF  that  can  manage 
trucks, can also manage the trailers. Sometimes they do specialised dismantling 
campaigns for a certain type of trailer’, e.g. temperature controlled boxes that need 

additional treatment steps due to the removal of coolants.   

182 Eurostat differentiates between road tractors and lorries, however, whenever this report refers to ‘lorries’ vehicles for 
transportation of good >3,5 tons are referred to including road tractors. 

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2.4.3  What is the problem and why is it a problem?  

2.4.3.1  Description of the problem 

The Evaluation (Williams et. al 2020) has identified that, though the majority of vehicles is 
covered by the ELVD, ‘gaps remain’ with regards to vehicles other than M1 and N1. Against 
the background of numbers presented above in terms of what is not covered by the Directive 
by  weight  these  gaps  are  considered  significant.  The  following  subsections  present  and 
describe six problems associated with the vehicles not covered under the ELVD (no ranking):  

1)  The potential to contribute to the CE of a large share of vehicles is not exploited yet 

2)  Missing traceability for vehicles not in scope of ELVD 

3)  For vehicles not in scope of ELVD, there is no legal incentive to design for circularity 

4)  For vehicles not in scope of ELVD, the current legal setup is insufficiently harmonized 

across the EU 

5)  Inconsistency between scopes of ELVD and 3R Directive 

6)  Increase of the total amount of vehicles 

The potential to contribute to the CE of a large share of vehicles is not exploited yet 

The overall problem is that the potential to contribute to the circular economy of a large share 
(17% by unit, ~ 47 million, or 33% by mass, 159 million tons; Table 2-13) of vehicles in the 
EU  market  (but  outside  the  scope  of  the  ELV  Directive)  is  not  exploited  yet:  Table  2-14 
displays the dimensions of material streams to be expected from ELVs not in scope of ELVD: 
Based on the expected number of ELVs, the average sum of materials from powered two- 
and three wheelers (PTW), buses and lorries that became waste in 2020 amounted to 
more than 7,54 million tons. It is expected that this is an underestimation due to missing 
data on other types of L-type-approved vehicle categories of (EU) 168/2013. The average 
sum of material from PTW, buses and lorries that are expected to become waste in the 
year 2030 increase to more than 10,14 million tons, which is an underestimation just like 
above.  

Table 2-14 Dimensions of material streams from ELV not in scope of ELVD 

PTWs (L)* 

Buses (M2, M3) 

Lorries (N2, N3) 

(Semi-)Trailer 
(O)*** 

Nr. of ELV expected 
in 2020 

1 336 572 

28 061 

212 025 

1 007 722 

0,11  –  0,38  million 
tons 

0,22  –  0,38  Mio 
tons 

0,42  –  3,00  million 
tons 

2,66  –  7,90  million 
tons 

sum 

Total 
of 
material  from  ELV 
to 
expected 
in 
became  waste 
2020** 

Sum in 2020 

ø 7,54 million tons (range: 3,42 – 11,66 million tons) 

Nr. of ELV expected 
in 2030  

1 557 104 

31 359 

263 158 

1 402 422 

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PTWs (L)* 

Buses (M2, M3) 

Lorries (N2, N3) 

(Semi-)Trailer 
(O)*** 

0,13  –  0,44  million 
tons 

0,25  –  0,42  million 
tons 

0,53  –  3,82  million 
tons 

3,70 – 10,99 million 
tons 

sum 

Total 
of 
material  from  ELV 
to 
expected 
become  waste 
in 
2030**  

Sum in 2030 

ø 10,14 million tons (range: 4,61 – 15,67million tons) 

Source: ELVs: Oeko model based on stock in Table 6-2; sum of material: range; calculated based on data in Annex I chapter 
6.1.3. 
Notes: (*) underestimate, an additional amount of plus 10-15% of L-type approved vehicles can be expected.  
(**) The numbers are given per year, i.e., 2020 and 2030. It is not a sum of material expected to become waste until 2030. 
(***) (Semi-)Tailers have a high variety in total weight and material composition. It was not possible to obtain generalized data 
or to assume their material composition due to the high variability in the vehicles. See examples for the weight of trailers in the 
Annex (6.1.1). 

The  material  composition  of  selected  lorries,  buses  and 
PTWs shows that steel, aluminium, iron, copper, glass, plastics 
and rubber are the main materials with regards to their weight 
in  the  vehicles  (Figure  2-29).  Absolute  numbers  of  the  total  weight  and  of  the  individual 
material  fractions  are  provided  in  the  Annex  (chapter  6.1.3).  A  differentiated  material 
composition per vehicle with different drivetrain (other than M1 and N1) is lacking.  

Figure 2-29  Material composition of examples of lorries, buses and PTWs compared 
to cars 

100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%

Other

Rubber

Plastics

Glass

Copper

Iron

Aluminium

Steel

Note: It is assumed that Plastics represents thermoplastics. Foams and elastomers were included in “others” where primary 
data indicated these materials specifically. 
Abbreviation: GVW=gross vehicle weight. 
Source: (Wolff et al. 2020; Ricardo-AEA 2015; ADEME and SURPLUS MOTOS 2022; Bouter et al. 2020) See absolute values 
and attribution of sources per vehicle in the Annex (Table 6-11). 

In almost all examples, except for the midibus, the steel fraction has the highest shares with 
42% (L5e) up to over 60% (rigid truck 1 and curtainsider). Aluminium plays an important role 
in buses and PTWs, however, from the available data, wrought and cast aluminium fractions 
cannot  be  distinguished.  Iron  can  be  found  in  lorries  and  buses,  but  not  in  PTWs.  In 

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percentages, copper fractions are highest in PTWs. As expected, glass fractions are highest 
in  buses.  There  is  no  vehicle  type  that  leads  the  comparison  in  terms  of  percentages  for 
plastic.  

It should be noted that sources of information are different for different vehicles. It is possible 
that authors of different studies attributed different individual materials to the group of plastics. 
If primary data was regrouped for the purpose of this study, data on elastomers and foams, 
specifically,  was  included  under  ‘others’.  It  is  assumed  that  ‘plastics’  represent  recyclable 
thermoplastic fractions. Depending on the source of information, the group of other materials 
contains elastomers, foams, textiles, leather, lead, glass-fibre reinforced materials (in trucks), 
paint, zinc or magnesium. Knowing that this is a high variety to be grouped under ‘others’ but 
considering the less significance of the weight of the group of other materials, the variety is 
considered acceptable. In the example of the rigid truck 2, glass-fibre reinforced material has 
an individual share of 16% of the total vehicle.  

Based  on  the  weight,  material  composition  and  fleet  data,  it  is  possible  to  outline  the 
dimension of materials from end-of-life vehicles that are currently not in scope of the ELVD. 
This would imply that these materials may not enter recycling streams, their environmentally 
sound treatment is not ensured and the possibility to steer the sector outside the scope of 
ELVD towards circularity is not given. The data presented in Table 2-14 and Figure 2-29 is 
used  in  the  quantitative impact  assessment  to  further  characterize material  streams  which 
are used as a basis for the assessment. 

Missing traceability for vehicles not in scope of ELVD 

An additional factor leading to losses of materials for the EU, is the missing traceability: Export 
of vehicles and illegal waste operations are a problem for all vehicles, including M1, N1, and 
lorries, buses, PTWs etc. because it is leading to material losses. Member States are obliged 
to  collect  statistical  data  on  the  ELVs  in  scope  (Commission  Decision  2005/293/EC183). 
However,  statistics  on  ELVs  other  than  M1  and  N1  vehicles  does  not  exist.  There  is  no 
specific waste code for PTW, lorries or buses to separate them from waste cars. Thus, the 
overall dimensions of yearly numbers of ELVs others than passenger cars (M1) and light duty 
vehicles (N1) are unclear.  

However, there is statistical data on the export of used vehicles (EU trade statistics database, 
European  Commission  2022a).  According  to  answers  to  Slido  questions  during  the 
stakeholder  meeting  (Workshop  2022),  the  export  to  non-EU-countries  (as  second  hand 
vehicles)  is  the  typical  EoL  scenario  for  the  majority  (>  50%weight)  of  buses,  lorries  and 
trailers. For PTW, the most common EoL scenario is dismantling for reuse. Motor vehicles, 
trailers  and  semi-trailers  are  highly  traded  goods,  e.g.,  according  to  the  German  Federal 
Statistical Office these vehicles ‘continued to be Germany's most important export goods in 
2019.’ (Destatis 9 Mar 2020) And the fact that African countries adopted polies and import 
restrictions for used vehicles including lorries184, shows that the export of used lorries is part 
of that viable business.  

183 For Eurostat (yearly reporting), MS they are asked to name the "total number of vehicles of ELV" and number of CoD 
issued. Ideally the CoD issued by ATF should be shared with the national authority and the number of CoD should reflect the 
real number of ELVs arising in the country. COMMISSION DECISION 2005/293/EC of 1 April 2005 laying down detailed 
rules on the monitoring of the reuse/recovery and reuse/recycling targets set out in Directive 2000/53/EC of the European 
Parliament and of the Council on end-of-life vehicles. 

184 ‘Egypt and South Africa, for example, have banned the import of used vehicles. Morocco has an age restriction for imported 
Light-Duty Vehicles (LDVs) and Heavy- Duty Vehicles (HDVs) of five years and requires vehicles to be at least Euro 4.8 
Libya has set an age restriction of ten years for Light-Duty Vehicles and Heavy-Duty Vehicles in 2019.’ (2020). 

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The export data for the period of 2010-2020/21 was analysed for used lorries (vehicles used 
for transport and road trucks), buses for >10 per. and (semi-)trailers within the context of this 
study in order to understand the aspect of export of 2nd-hand (“used”) vehicles as part of the 
problem of vehicles of unknown whereabouts. Extra EU Export data is considered robust as 
customs collect this data for trade purposes185. The data is available in the Annex (chapter 
6.1.5).  

Figure 2-30  Extra EU Export of used vehicles for 2010-2021 in numbers.  

225000

200000

175000

150000

125000

100000

75000

50000

25000

0

25000

0

0 0 0 0 0 0 0 0 0 0 0 0

Used vehicles for transport and road tractors

Used busses for > 10 per.

#BEZUG!

Source: EU trade statistics, European Commission (2022a), , Product Codes: 87012090 (used road tractor); 87021019, 
87021099, 87029019, 87029039 (used buses); 87042299, 87042399, 87043299 (used lorries); 87163980 (used trailers). Data 
in Annex I, Table 6-9. 

When  comparing  the  numbers  for  four  types  of  vehicles,  namely  road  tractors186,  lorries, 
trailers and semitrailers and buses, Figure 2-30 (and data in Table 6-9, Annex I) shows that  

•  On  average,  80 120  used  road  tractors  and  76 839  used  vehicles  for  transport  were 
exported per year. Both vehicle groups together relate to ~74% of expected waste lorries 
(Stock  in  2020  (PRIMES):  6 218 833,  Nr.  of  ELV  expected  in  2020  (Oeko  model): 
212 025).  

185 This is different for intra EU trade data which is less robust, however, for the purpose of this analysis, only extra EU trade 
data has been assessed. 

186 Eurostat and trade statistics differentiate between lorries and road tractors. For the reason of simplifying most of the 
analysis does not differentiate between these two vehicle categories but when speaking about lorries, road tractors shall be 
understood to be included. For the model of ELVs, lorries  

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•  On  average,  75 074  used  (semi-)trailers  were  exported  per  year  relating  to  ~8%  of 
expected  waste  lorries187  (Stock  in  2019  (Eurostat  2021):  18 250 515,  Nr.  of  ELV 
expected in 2019 (Oeko model): 976 946).  

•  On average, 9 327 used buses are exported per year, this relates to ~34% of the expected 
ELVs  (Stock  in  2020  (PRIMES):  703 368;  Nr.  of  ELV  expected  in  2020  (Oeko  model): 
27 658). 

Generally,  the  number  of  exports  decreased,  at  least  for  road  tractors,  buses  and  trailers; 
even  if  excluding  the  year  2010  which  seem  to  show  exemptional  high  export  numbers. 
Authors  of  a  Dutch  study  (Netherlands  Ministry  of  Infrastructure  and  Water  Management, 
Human Environment and Transport Inspectorate 2020) provide an argument for the general 
trend: West-African countries ‘have decided that as of January 1, 2021, they will only import 
used vehicles with a minimum Euro 4/IV emission standard. Considering this, it is noteworthy 
in our findings that the vast majority of the used vehicles (more than 80%) currently exported 
to these countries will not meet their future import criteria. They are too old and below Euro 
4/IV  emission  standard.  Moreover,  several  emission  control  systems  are  not  present, 
functioning,  or  removed’.  Renault  Trucks  considers  that  the  increasingly  complexity  of  the 
exhaust emission control system and the hybridization of truck engines will make exporting 
trucks  to  non-EU  countries  more  difficult.  Therefore,  one  solution  has  been  to  develop  a 
network of specialised companies for treating trucks that links the dismantling network with 
repair networks to allow a high level of referencing for parts. (contribution from France, MS 
meeting 2022).  

For PTWs, there are no codes for the trade in used products. Thus, the aspect of 
export of 2nd-hand (“used”) vehicles as part of the problem of vehicles of unknown 
whereabouts cannot be studied for this vehicle category. 

The ~157,000 used lorries (vehicles for transport + road tractors) leaving the stock 
per year potentially represent 1.1 million tonnes of waste. Based on the average 
material composition of lorries (according to Table 6-7), this represents a material 
flow of about 670 000 tons of steel, 106 000 tons of iron, 34 000 tons of aluminium, 10 000 
tons each of copper and glass, 80 000 tons of plastics and 61 000 tons of rubber (see Annex 
Table 6-11). Used lorries are exported to Jordan (TOP 1), Ukraine, Afghanistan, Serbia and 
Saudi Arabia (in the row of accumulated exports from 2010-2020).  

In  addition to  statistical numbers,  an  exemplary study  is  presented  showing  that  problems 
associated with export of used vehicles are real: Export of lorries (the report refers to ‘heavy 
duty vehicles’) to African countries was studied in the Netherlands as part of a broader study 
on exported vehicles to Africa. ‘We have inspected a group of thirty-eight diesel vehicles. […] 
Eighteen vehicles are lorries for the carriage of goods, like trucks. […] Diesel lorries are from 
sixteen different brands. The five most prominent brands are Mercedes, Volkswagen, Man, 
Iveco, and Hyundai. […] Our desk study indicates that a significant part of the used vehicles 
exported  to  Africa  is  often  very  old  and  very  similar  to  end-of-life  vehicles  recycled  in  the 
Netherlands. The “leakage flow” to Africa involving uncontrolled treatment of vehicles causes 
environmental  harm  if  hazardous  liquids  or  other  hazardous  substances  leak  into  the 
environment and causes related injuries to the health of the people handling such materials 
inadequately. There is also a risk of losing secondary raw materials.’ (Netherlands Ministry of 
Infrastructure  and  Water  Management,  Human  Environment  and  Transport  Inspectorate 
2020) 

187 As the Nr. of ELV expected was modelled based on Eurostat, this data is less profound compared to the other vehicles in 
this chapter modelled in accordance with EU reference scenario 2020 or PRIMES data. 

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The photographs of buses and lorries in Figure 2-31 have been taken 
in  Nigeria  and  Greece.  They  support  the  findings  of  the  export  data 
analysis in their conclusion that the problem of traceability and unknown 
whereabouts exists in practice, also for lorries and buses. One of the pictures suggest that 
vehicles  might  be  parted  out  substantially,  another  that  vehicles  are  “disposed  of”  in  the 
natural  environment.  Several  pictures  taken  in  Nigeria  are  showing  vehicles  with  German 
writing (advertisement). 

Figure 2-31  Buses and lorries of unknown whereabouts.  

Note: Pictures in middle and downer row have German writing though photos were taken in Lagos, Nigeria. 
Source: left upper corner by G. Mehlhart (2018, Kreta, Greece), others by A. Manhart, Oeko-Institut (2009, Lagos, Nigeria). 

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For vehicles not in scope of ELVD, there is no legal incentive to design for circularity 

One  important  aspect  to  support  circularity  is  the  design.  So  far,  there  is  little  incentive  to 
design and produce vehicles in a way which limits the use of primary materials and increase 
the  use  of  secondary  materials:  For  vehicles  not  in  scope  of  ELVD,  the  waste  framework 
directive (+ MS specific regulations, if exists) applies. However, EU regulation on the design 
for circularity (e.g., 3R Type approval, hazardous substance requirements) of such vehicles 
does  not  exist.  Also,  the  waste  framework  directive  does  not  include  design  aspects 
specifically.  Some  stakeholders  admit  that  the  current  contribution  of  the  sub-sector  of 
vehicles  not  in  scope  of ELVD  is  limited:  For  instance,  according to the Spanish  industrial 
vehicle recycler’s association “at the moment, lorry producers are not aligned with the vision 
for End-of-life of the vehicles. This means, that they currently do not have any objectives to 
optimize dismantlability etc.” (ANERVI/AETRAC 2021) 

A  trend  for  reducing  the  weight  of  vehicles  is  expected  as  in  the  case  of  cars 
(chapter 2.1.2.1). In one example presented in Figure 2-29 (‘rigid truck 2’), glass-
fibre reinforced material has an individual share of 16% of the total vehicle. It is not 
possible to say, how many of such vehicles there are in the total EU lorry fleet. Depending on 
the  materials  used  for  weight  reduction,  this  could  have  a  negative  effect  on  increased 
emissions in the production phase, e.g., if aluminium is used to replace steel, or could have 
an effect on the recyclability of such vehicles, in cases where non-recyclable, e.g., carbon-
fibre based materials are replacing recyclables. In the best case, ‘lorries are highly recyclable: 
85% of their weight consists of iron, steel and aluminum. One third of a Volvo Group’s lorry 
is  produced  from  recycled  materials.  The  high  degree  of  commonality  of  Volvo  Group’s 
products  facilitates  the  remanufacturing  and  reuse  of  spare  parts’  (Saidani  et  al.  2018). 
However, lorries ‘concentrates less on recycling technologies and more on materials that are 
more ambitious for environmental impact reduction (e.g., lighter materials = positive impact 
on  use  phase  |  lighter  vehicles  mean  less  energy  needed  to  use  the  vehicle  [comment  of 
author: or higher payload]). In design considerations a larger importance in given to the use 
phase of vehicles, especially to weight (to save on energy consumption [comment of author: 
or increased payload]); if the energy mix becomes ‘greener’, it might be that impacts in other 
life-cycle phases will gain in importance. Load carrying capacity reduces the number of lorries 
on the road – as you can transport more goods.’ (ACEA/Volvo 2021) Besides environmental 
benefits,  as  load  carrying  capacity  are  of  the  priority  product  priorities  for  lorries  (SCANIA 
2022), there is a direct economic incentive to reduce weight in the case of lorries as it directly 
adds to load carrying capacity.  

Typical  materials  in  lorries  can  be  replaced  by  lightweight  materials,  entailing  a  weight 
reduction  potential  each.  The  higher  the  weight  reduction  potential,  be  better  the  energy 
efficiency, or the higher the payload, in the use phase of the vehicle, see Table 2-15. High 
weight reduction potential is attributed to various composite materials. 

Table 2-15 Lorries: Strategies for weight reduction focus on composites 

Lightweight material that can be used as a 
substitute for typical materials in lorries 

Material replaced 

Weight 
potential 
through substitution 

reduction 
archivable 

Carbon Fibre Composites 

Steel 

50-70% 

Magnesium 

Steel, Cast Iron 

30-70% 

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Aluminium 

Steel, Cast Iron 

30-60% 

Glass Fibre Composites 

Steel 

Advanced  materials*, 
composites 

includes  metal  matrix 

Steel 

25-35% 

10-30% 

Advanced high strength steels 

Mild Steel, Carbon Steel 

10-30% 

Steel and cast iron (propulsion) 

Mild Steel 

0-15% 

Source: (U.S. Department of Energy 2013) 
(*) Note: Encompasses titanium, nickel alloys, metal matrix composites 

Inconsistency between scopes of ELVD and 3R Directive 

The 3R Directive is an aspect closely related to the problem mentioned before. In relation to 
the  design  requirements  set  out  in  the  ELVD,  the  3R  Directive  plays  an  important  role  in 
ensuring  that  vehicles  placed  on  the  market  comply  with  ELVD  design  requirements.  The 
report attached to this study in Annex II has the aim to provide a targeted review of the 3R 
Directive with a focus on the interlinkages between ELVD and 3R Directive. It was identified, 
that currently, the scopes of ELVD and 3R Directive are similar but not identical. Exemptions 
from the Directive vary among the two legislations. Both include passenger cars classified as 
M1 and light-commercial vehicles classified as N1 (< 3,5 tons) in the scope. In terms of the 
exemptions,  small  series  and  multi-stage  built  vehicles  are  generally  exempt  from  3R 
Directive but not mentioned in ELVD. Special purpose vehicles are generally exempt from the 
3R Directive too, however, they are in scope of ELVD188 but exempt from Art. 7 provisions of 
ELVD. A tabular overview covering the mentioned and additional differences in the scopes is 
provided in Table 7-6 (Annex II).  

Major discrepancies exist in relation to vehicles produced in small series and for multi-stage-
built vehicles. The fact that the multi-stage built vehicles and 
small  series  are  not  specifically  mentioned  under  ELVD 
effectively  means  that  the  ELVD  requirements,  including  the 
Art. 7 (3R targets), apply for multi-stage built vehicles and vehicles produced in small series, 
if M1 and N1 type approved. See examples for such vehicles in section 7.4.2 (Annex II). On 
the one hand side, these vehicles might be produced in small series, but in that case, there 
is no exemptions for them in the ELVD, thus, they need to comply with ELVD. On the other 
hand, these vehicles might comply with the criteria for special-purpose vehicles specified in 
the general type-approval (Regulation 2018/858, Annex I, Part A). If so, they are exempted 
from Article 7 provisions of ELVD (but not generally). To conclude, if multi-stage built M1 or 
N1 vehicles (whether produced in a small series or not) do not fulfil the criteria for special 
purpose vehicles– which is considered only in a few cases - it is assumed that the compliance 
with the 3R targets, hazardous substance provisions etc. is not ensured. There is no statistical 
evaluation possible on EU level on the extent of the problem, nor it is on MS level as the data 
is most likely not collected. It is understood from ACEA/Volvo (2021) that nearly all N2, N3, 
and possibly M2, M3 and O vehicles are multi-stage build vehicles. When assessing the need 
and  feasibility  of  expanding  the  scope  of  the  ELV  legislation  to  N2,  N3,  M2,  M3  and  O 
vehicles, aiming to use the 3R Directive to ensure design for circularity for vehicles placed on 

  188 In its frequently asked questions chapter, the ELV Guidance Document (EU, 2005) clarifies that motor caravans are in 
scope. This is explained based on Directive 70/156/EEC, which defines motor caravans as a special purpose M category 
vehicle. 

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the  market,  the  discrepancies  of  ELVD  and  3R  Directive  in  relation  to  multi-stage  build 
vehicles need to be overcome. The process of multi-stage type approval is explained in the 
Annex (chapter 6.1.6). 

For vehicles not in scope of ELVD, the current legal setup is insufficiently harmonized 
across the EU 

It can be understood that the waste management of motorcycles, trucks and buses is currently 
not  subject  to  regulation  at  EU  level.  However,  some  MS  require  that  the  treatment  of 
motorcycles and trucks is ensured and/or environmental permits for facilities are requested 
through vehicle-specific or general waste legislation. This is the situation at least in Spain, 
France, Flanders/Belgium, Lithuania, Italy, Hungary, Netherlands, and Germany. There is no 
regulation  on  end-of-life  of  vehicles  not  in  scope  of  ELVD  in  Greece  and  Finland.  For  the 
majority of MS, requirement for treatment in ATFs exists and subsequently the deregistration 
based on Certificates of Destruction (CoDs). (EU MS ELV IA Survey 2022; EGARA 2022b; 
ACEM 2021)189 

Examples of the design of the regulation are 

•  Spain: Differentiated waste codes. While 160104* is the EU waste code for ELVs190, in 
Spain, there are 160104*-10 (cars, vans) and 160104*-20 (other vehicles) Real Decreto 
265/2021, Anexo VIII Codification Ler-Veh191. The coming into force was on 15.04.2021. 
•  The Netherlands: A voluntary EPR for scooters for mopeds and mopeds up to 50 cubic 
centimetres, the Scooter Recycling Nederland (SRN), was founded by importers, dealers 
and garages in 2011 (Auto Recycling World 2021). ‘The network exists of 180 delivery 
points  and  65  scooter  dismantlers  (mostly  cars  dismantlers  that  do  scooters  as  a  side 
job). Aim is collection without costs for the last owner and sustainable recycling.’ (EGARA 
2022b) The system is voluntary at present. According to the SRN webpage (BOVAG; RAI 
2022),  25  000  scooters  were  scrapped  at  drop-off  points  of  1.2  million  scooters  in  the 
Netherlands.  
Italy: Vehicles other than M1 and N1 are governed by the waste framework legislation in 
part IV of the Legislative Decree n. 152 of 3 April 2006 and subsequent amendments, in 
particular  by  article  231,  and  subsequent  amendments,  which  transposes  Directive 
2000/53/EC.  The  legislative  decree  D.Lgs  152/06,  Article  231  ‘End-of-life  vehicles  not 
covered  by  D.Lgs  209/03’192  details  how  motorcycles  must  be  managed.  e.g.,  the 
technical  requirements  of  the  ATF  motorcycles  and  for  the  dismantling  phases 
(depollution and demolition) are the same.  

• 

•  The French anti waste bill’s193 scope, the EPR scheme especially, was expanded to 2,3-
wheel vehicles and quadricycles, thus, the EPR scheme shall apply for these vehicles as 
well (ADEME 2020). The rules come in force as of 01.01.2022. It includes the obligation 
to  hand  over  ELVs  to  ATFs,  the  obligation  to  take  back  all  ELVs  incl.  abandoned  and 
impounded, together with the issuing of CoDs.  

189 Both lists of MS that have or do not have regulations for other vehicles than M1 and N2 are not exhaustive. For the MS 
which are not named, the situation is unclear. 

190 COMMISSION DECISION of 18 December 2014 amending Decision 2000/532/EC on the list of waste pursuant to Directive 
2008/98/EC of the European Parliament and of the Council 

191 https://www.boe.es/eli/es/rd/2021/04/13/265/con 

192 https://www.normattiva.it/atto/caricaDettaglioAtto?atto.dataPubblicazioneGazzetta=2003-08-
07&atto.codiceRedazionale=003G0227&atto.articolo.numero=0&atto.articolo.sottoArticolo=1&atto.articolo.sottoArticolo1=10&
qId=&tabID=0.59010272527045&title=lbl.dettaglioAtto&generaTabId=true   

193 https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000041553759 

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• 

In  the  Czech  Republic,  all  end-of-life  vehicles  are  dealt  with  in  the  “Act  on  End-of-Life 
Products” (542/2020 Coll. 2020). With regards to vehicles, only vehicles of armed forces 
and non-road mobile machinery are excluded. Vehicle-specific rules are laid down in Part 
III (Section 103-112). Additional rules are set in the ‘Decree on details of the management 
of  end-of-life  vehicles’  (345/2021  Coll.  2021),  among  others  provisions  include  various 
measures on reuse194. This decree came into force on 1 October 2021. 

From Italian legislation, no evaluation is yet available due to the short time that the legislation 
is in place (Ministerio para la Transición Ecológica y el Reto Demográfico, Italy 2022). Also, 
the laws in Spain, France and the Czech Republic have been in force for one or less than a 
year, it has not been confirmed by representatives, but it can be assumed that there are no 
evaluations  of  their  impact  or  effectiveness  available  at  this  point  of  time.  Also  in  Italy, 
according to information from ISPRA (2022) to date, no specific studies have yet been carried 
out for waste streams from PTW and/or lorries due to the fact that the calculation of reuse, 
recovery and recycling targets is not required for these vehicles. Also in Lithuania, which had 
indicated  in  the MS  survey  that there  are  specific  laws  for  PTW  and/or  lorries,  there  is  no 
study on the waste management of these vehicles (Ministry of Environment of the Republic 
of Lithuania 2022). 

The MS-specific regulation of the treatment of ELVs other than cars and vans does not (yet) 
ensure that problems similar to those identified in the Evaluation of the ELVD (section 1.1) 
does  not  exist  for  other  vehicle  types.  Contributions  by  EGARA  (2022b)  describe  the 
problems in some MS:  

• 

• 

• 

‘Regardless  of the regulations  in  Poland,  about 65%  of  vehicles  are  dismantled  in the 
grey zone’;  
In  Spain,  ‘there  are  owners  who  sell  them [mopeds  and  motorcycles]  without  knowing 
their  final  whereabouts,  or  who  buy  them  assuming  the  road  tax  [has  been  paid]  and 
disassemble them to sell their parts, without having the authorization of an ATF.’;  
In the Netherlands, ‘sometimes export is used to end registration so the owner can do 
with the bike or remains whatever he feels like. For us is this another reason to plea for 
compatible national registration systems (or an EU system)’; and ‘problems that we have 
are sometimes owners that are reluctant to hand over the remains or the papers, or the 
storage  address  already  took  some  parts,  sometimes  even  destroyed  parts  to  use  in 
insurance fraud. These broken parts will be put on other accident motorcycles in order to 
increase the claim.’; 

•  ARN (2021) comments on the experiences with the Dutch scooter recycling network that 
‘OEMs or producers [are] willing to do something coming together and set up a system, 
but you have to cope with free-riders if there is no legislative enforcement to support the 
willing  group.  […]  it  was  quite  hard  as  it  is  not  the  same  product,  not  the  same 
infrastructure, not the same players on the market […] So it’s hard to […] copy it for other 
vehicles. To give examples of difficulties of the system: Due to less strict other rules on 
deregistration for mopeds as for cars it is difficult to ensure that all mopeds arrive at ATFs, 
[or] if an ATF is licensed to treat ELVs it was not automatically permitted to treat mopeds, 
so additional permits were needed.’ 

•  For  Greece,  where  no  ELV  regulation  exist  for  vehicles  other  than  M1  and  N1,  the 
contribution from EGARA explains that ‘without a legal framework, without government 

194 The decree regulates […] ‘h) the extent and manner of keeping records of materials and parts for reuse by the processor of 
end-of-life vehicles; i) the method for calculating the level of reuse and recycling or other recovery of selected end-of-life 
vehicles and their parts; j) the conditions of preparation for the re-use of reusable parts and their storage; k) the extent of the 
data kept in the End-of-Life Vehicle Information System; l) the particulars of the proof of the repairability of the vehicle and of 
the functionality of the vehicle part.’ (345/2021 Coll. 2021). 

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• 

• 

inspections and without controls on registration status of vehicles 90% of motorcycles and 
trucks are illegally dismantled.’ 
In France, ‘the presence of parallel markets is even greater in motorcycles than in cars 
(up  to  10  times  higher).  Many  parts  are  resold  online:  they  are  untraceable  and 
unchecked.’ 
‘In practise, the systems [in Finland] allow dismantlers to [issue] CoDs [for motorcycles]. 
And some do so. Heavy vehicles, tractors etc. don’t require [a] CoD neither, but especially 
for trucks, CoDs are often [issued].’ 

Increase of the total amount of vehicles 

Materials from vehicles not in scope may nowadays be recycled and components from these 
vehicles  will  be  reused  if  economically  viable.  However,  there  is  no  obligation  to  achieve 
minimum targets nor EU wide mechanisms for reporting on the achieved rates. It is expected 
that  the  number  of  vehicles  further  increases  and  consequently  the  loss  of  materials  too 
(Figure 2-32; a plus of more than 2,2 million lorries, i.e., plus ~40% compared to 2010, and 
165 000 buses, i.e., plus ~25% compared to 2010): In 2030, potential losses of materials from 
ELVs not in scope of ELD could amount to 10,14 million tons (range: 4,61 – 15,67 million 
tons; see Table 2-14).  

Figure 2-32  Growth in the numbers of vehicles 

9.000.000

8.000.000

7.000.000

6.000.000

5.000.000

4.000.000

3.000.000

2.000.000

1.000.000

0

900.000

800.000

700.000

600.000

500.000

400.000

300.000

200.000

100.000

0

2010

2015

2020

2025

2030

2035

2040

2045

2050

heavy duty

buses

Source: Fleets based on PRIMES-TREMOVE (European Commission 2022b). 

Relations to other problems 

From above, it becomes clear that the problems relate to other problems of the ELV Impact 
Assessment Study displayed in the intervention logic (section 1.1.1), i.e.: 

•  problem 2 ‘design, production and EOL are not sufficiently circular’,  
•  problem  3  ‘large  number  of  ‘unknown  whereabouts’:  Not  all  vehicles  are collected  and 

recycled’, and  

•  problem 4 ‘lack of economic incentives’ applies to vehicles not in scope of ELVD.  

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2.4.3.2  Description of the problem drivers 

The  following  is  a  list  of  general  problem  drivers  in  relation  to  all  vehicles  not  in  scope  of 
ELVD. Further below, in section 2.4.3.4 ‘why the EU should act’, for each of the four vehicle 
categories  under  consideration  (PTW,  lorries,  buses,  trailers)  the  most  important  problem, 
problem drivers and reason why the EU should act are named.  

Problem drivers in relation to the market 

It is expected that reuse and repair play an important role in prolonging the lifetime of PTW, 
lorries  and  potentially  buses,  based  on  the  limited  information,  e.g.,  on  reuse  for  PTW  in 
Finland (SMOTO 2021), it can be concluded that a) individuals and small garages play an 
important role in the repair and (EoL) treatment market, and b) that reuse is less in case of 
car ATFs handling PTW, if not specialized in treating PTW. As a result, in the case of a), the 
more  different  operators  exist, the  more  difficult it  is  to control  ATF requirements,  licenses 
etc.  For  b),  it  is  clear  that  imperfect  information  for  (car)  ATFs  hinders  even  higher  reuse 
quota, at least for PTW where not such system as IDIS exists (there is an IDIS for lorries). 

In relation to circular design, from the available information, e.g., the high reuse rates and 
viable repair businesses across, it is concluded that the market for vehicle categories other 
than  cars  and  vans  is  working  so  that  these  vehicles  are  designed  circular  in  respect  of 
longevity and repairability. However, this cannot be substantiated, as exact numbers are not 
available.  For  design  aspects  considered  under  the  ELVD  today,  namely,  hazardous 
substances,  plastic  coding  and  recyclability  (3R  targets),  the  market  situation  is  unclear. 
Though, the ELV substance prohibitions do not apply, it is probable that at least for similar 
components, hazardous substances have been substituted as the suppliers are shared with 
vehicle suppliers and will not necessarily continue manufacture for vehicles of a small market. 
Nonetheless,  the  composition  of  PTW,  lorries  and  buses  is  different  from  passenger  cars, 
with motorcycles having more plastic parts and lorries and buses applying additional materials 
in the stages built on the base vehicle. In that sense the prohibited substances may be applied 
in other applications or also in cases where more extreme use conditions (e.g., heavy duty of 
trucks) place higher demands on the material reliability. 

Design for recycling, more specifically the 3R targets, are expected to be a greater challenge. 
It is unclear whether the market will be addressing design-for-recycling in a sufficient manner. 
In case of a regulatory intervention, stakeholders emphasize that there is no data basis to 
conclude on realistic ambition levels for 3R targets. In relation to the increase of lightweight 
materials for lorries, the associated trade-off in relation to CO2 emission reduction during use 
phase compared to recyclability should be analysed well to set political priorities and avoid 
misaligned incentives in one or the other direction.  

It is not unusual that from an economical point of view revenues generated from exporting a 
used vehicle, though close to its end-of-life, can be higher than revenues generated from the 
treatment of the vehicle, at the end of life (see the problem described in chapter 2.2.3). An 
export  of  a  used  vehicle  close  to  its  end-of-life  could  mean  that  they may  be  subjected to 
unsound treatment with lacking minimum depollution and dismantling requirements. This may 
especially be the case in countries where there is no (general waste) legislation in place that 
covers vehicles. In the EU, examples are Greece or Finland, but this relates also to non-EU 
countries to which end-of-life vehicles are exported to. Also, when end-of-life vehicles are left 
standing around in nature without any waste treatment, there is a risk of uncontrolled leakage 
of polluting liquids. In that case, one can speak of a market failure in relation to externalities. 
However, this is not only a market but as well a regulatory, i.e., enforcement, failure which is 
also addressed below. 

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There are small signs that the export of used vehicles might decrease in the future. Arguments 
presented above are a more selective approach in which vehicles shall be on the roads in 
import  countries  in  Africa,  Renault  referred  to  the  increasing  complexity  of  lorries,  also 
hybridization and electrification that could decrease export volumes. As a consequence, the 
markets for used vehicles might diminish. 

Problem drivers in relation to the existing regulation 

In light of the developments of high-level policy goals, namely the Green Deal and the Circular 
Economy Action Plan, since the time when ELVD came into force, the aspect of circularity 
has won in importance. The finding that the potential to contribute to the CE of a large share 
of  vehicles  is  not  exploited  yet,  suggests focusing  the regulatory  intervention  to  encounter 
problems associated with a lack of circularity for all vehicles, i.e., not just cars and vans. Tools 
and incentives are missing to motivate circular design in general and for addressing the trade-
off  between  strategies  for  greenhouse  gas  emission  reduction  (from  the  use  phase  of 
vehicles)  and  recyclability  explicitly.  The  existing  “mechanism”  to  control  the  design  of 
vehicles  placed  on  the  market,  the  3R  Directive,  has  shown  some  shortcomings  when 
comparing the scope of ELVD and 3R Directive, see Annex II, chapter 7.2. 

Vehicles not in scope of ELVD are in scope of MS-specific regulation. Many MS require that 
the  sound  treatment  of  PTWs  and/or  trucks  is  ensured  and/or  environmental  permits  for 
facilities  are  requested  through  vehicle-specific  or  general  waste  legislation.  This  is  the 
situation at least in Spain, France, Flanders/Belgium, Lithuania, Italy, Hungary, Netherlands 
and Germany. There is no regulation on end-of-life of vehicles not in scope of ELVD at least 
in Greece and Finland (EU MS ELV IA Survey 2022; EGARA 2022b; ACEM 2021)195. In the 
case of a single market, as in the EU, and against the background that extra EU export is 
expected  high  in  numbers  and  associated  with  environmental  problems  in  the  importing 
countries, different treatment rules in different EU countries should be avoided. Thus, as far 
as there is no EU-wide common legislation, there is a risk that non-uniform rules will create 
loopholes.  So  far,  regulators  have  no  tool  available  and  there  are  no  enforcement 
mechanisms  nor  incentives  to  tackle  the  problem  of  loss  of  material  through  missing 
traceability and exports for vehicles other than cars and vans. 

In  general,  limited  information  on  the  numbers of  ELVs  other than  cars  and  vans,  missing 
export  statistics  for  PTW  and  a  lack  of  information  on  the  material  streams  of  waste  from 
these vehicles make it difficult to describe the problem to the full extent. In relation to end-of-
life PTW, lorries, buses and trailers, there is no adequate scientific evidence to show that the 
market is fully intact, e.g., in relation to reuse, that harm to the environment can be excluded. 
Or, to give another example, there is also no adequate scientific evidence that information for 
ATFs and recyclers is sufficient to recycle the materials from waste cars at the highest quality 
possible.  

Generally, with an increase of the total amount of vehicles of all categories, it is expected that 
the total amounts of waste from ELVs increases in the future which is expected to add to the 
described problem driver, or in relation to trailers to the size of the unknown problem. 

2.4.3.3  Key players and affected population 

195 Both lists of MS that have or do not have regulations for other vehicles than M1 and N2 are not exhaustive. For the MS 
which are not named, the situation is unclear. 

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The most relevant players and stakeholder affected by the problem…  

1)  …  of  the  CE  potential  not  being  exploited  are  authorities  for  whom  the  lack  of  the 
availability of data affects fact-based decision making in relation to measures to take 
in  line  with  political  priorities,  such  as  the  CEAP.  Indirectly,  this  effects the  general 
society  which  has  an  interest  in  achieving  progress  and  political  priorities  being 
followed.  

Other players affected in relation to the problem that the potential to contribute to the 
CE of a large share of vehicles is not exploited yet: 

o 

o 

In encountering the trade-off between non-recyclable light weight material for 
emission reduction during use phase and recyclability, manufacturers play a 
key role for decision making in relation to material choices 
Information to recyclers may be lacking, e.g., in the case of PTW for which no 
IDIS-equivalent system is set up so far 

o  That  there  is  no  incentive  to  design  for  recycling  may  affect  the  quality  of 
recyclates that can be obtained from shredders, meaning a potential loss of 
materials  or  material  quality  as  well  as  possibly  affecting  the  revenues  of 
shredders. 

o  The  (non-)availability  of  or  investment  in  installation  of  larger  facilities  (to 
“accept” trucks and buses), of PTW-dedicated ATFs nearby or missing tools 
(to allow dismantling from different types of vehicles) is the limiting factor to 
the capacity of EoL treatment  

o  The presence of hazardous substances as impurities or at higher levels in ELV 
recyclates  may  result  in  downcycling,  indirectly  meaning  that  more  primary 
materials will need to be extracted for use in new vehicles, which is associated 
with energy costs and environmental impacts. 

2)  … of missing traceability for vehicles not in scope of ELVD are ATFs and legal 

shredders, as well as societies in non-EU countries or/and where ELVs are disposed 
of illegally in the nature. Arguments are the following: 

o  ATFs  compete  with  illegal  garages  and  illegal  exporters  –  which  may  be 
capable to pay higher prices as they do not comply with all legal requirements. 
For  vehicles  not  in  scope  of  ELVD,  there  is  no  legal  incentive  to  design  for 
circularity 

o 

o  Due to illegal export and treatment by illegal and legal garages not being ATFs 
the ATFs have less turnover than expected and ATFs business might be less 
profitable / not profitable. 
Illegal export limits the turnover of shredders and the generation of recyclable 
fractions. 
Illegal treatment facilities, or facilities where no law exists, may not comply with 
the environmental standards for ATFs leading to environmental pollution. 
Other players affected by missing traceability for vehicles not in scope of ELVD:  

o 

o  Companies shipping used vehicles legally to another EU Member State or to 
third countries, which sometimes derive important revenues from this activity, 
but face competition of illegal SS. 

o  MS authorities & National vehicle registration authorities shall control ATFs 

and type approval registrations 

o  Citizens, not taking due care what is happening to their vehicle might receive 

higher prices for their ELV when it is sold to non-ATFs.  

o  Citizens  are  affected,  based  on  their  obligations  as  owners,  for  example 
related to the registration and de-registration of vehicles, e.g., temporary (de-
) registration of vehicles, or for buying reused parts. 

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3)  … that EU-wide harmonisation in EoL rules is not ensured, are end-of-life operators 
encounter different legal setups in different EU MS creating an uneven-playing field  

2.4.3.4  Why should the EU act? 

Problems of the ELVD have been identified in the Evaluation (Williams et. al 2020) and have 
been described above. For vehicle types other than M1 and N1, it was found that they have 
in common with M1 and N1 vehicles the problems of design, production and EOL not being 
sufficiently circular and a ‘large number of ‘unknown whereabouts’, i.e., not all vehicles are 
collected and recycled’. With the decision to amend the ELV legislation, EU regulators have 
found that ELV legislation has an added value to address – after amending and improving – 
the identified problems in relation to the various vehicle categories. Acting on EU level means 
to  close  regulatory  loopholes  that  exist  between  EU  MS,  avoid  potential  ‘loss’  of  material 
resources  and  to  avoid  leakage  of  pollutants  where  no  or  unsound  treatment  is  applied, 
thereby contributing to a level playing field. 

This  revision  of  ELVD  represents  a  possibility  to  introduce  legal  clarity  for  the  group  of 
vehicles  that  are  multi-stage  and/or  produced  in  small  series  but  are  not  special  purpose 
vehicles in relation to Art. 7 of ELVD. It should be noted that amendments to the scope of 
ELVD without parallel amendments in the scope of the 3R Directive and/or different means 
to create legal clarity for vehicles in scope of ELVD but not in scope of 3R Directive, create 
regulatory inefficiencies. It is in the hand of EU legislators, to acknowledge and potentially 
draw  conclusions  in  relation to  the  identified  discrepancies  in the scopes of  ELVD  and  3R 
Directive. 

ELVD Recitals display the initial intention of ELVD. Though, differently important for different 
vehicle  types,  arguments  presented  there  are  still  valid  to  justify  EU  action  based  on  the 
problem described above, e.g.,  

• 
• 
• 

• 
• 

• 

‘to minimise the impact of end-of life vehicles on the environment’;  
‘to ensure coherence between national approaches’;  
‘to ensure correct waste management, where waste [components and materials] should 
be reused and recovered, and  
that preference be given to reuse and recycling’;  
‘that economic operators set up systems for the collection, treatment and recovery of 
end-of life vehicles’; and  
‘that last holder and/or owner can deliver the end-of life vehicle to an authorised 
treatment facility’. (Directive 2000/53/EC 2000) 

2.4.3.5  Summary of problem, problem drivers and reason for EU 

action per vehicle category 

PTW: In the EoL and repair business, there are many individual operators, i.e., little 
control  for  regulators,  thus,  a  high  potential  for  illegal  operations.  Presumably, 
treatment information for waste management operators is limited, but a complete 
overview  of  material  streams  and  the  sector  in  general  (and  in  relation  to  potential  illegal 
operations,  though  it  was  reported  for  France  by  EGARA  (2020))  is  lacking,  among  other 
things because the different vehicles in the group of PTW are very diverse and each MS deals 
with PTW in a different regulatory way. Whether insufficient design-for-recycling or export of 
used vehicles plays a role is unclear due to the lack of data. Presumably, multi-stage type 

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approval, i.e., the problem of the discrepancy between the scopes of ELVD and 3R Directive, 
does not play a role for PTW. The general material composition of PTW, e.g., more plastic, 
and application of materials outdoor poses different requirements to the materials selected. 
In that sense the substances prohibited for N1 and M1 vehicles or other substances may be 
applied. 

Lorries:  The  lack  of  control  on  extra-EU  export  (~74%  of  expected  ELVs)  and 
transboundary  shipment  of  ELVs  within  the  EU  is  probably  the  biggest  problem 
driver in relation to trucks, mainly because EVLs do not have to be reported by the 
MS. Illegal treatment facilities, or facilities where no treatment law exists, may not comply with 
the  environmental  standards  for  ATFs  leading  to  environmental  pollution.  In  the  area  of 
circularity, the  use  of  lightweight,  non-recyclable  materials  is  probably relevant.  As  well  as 
substances, that might be hazardous could be applied in component parts for lorries in cases 
where more extreme use conditions (e.g., heavy duty of trucks) place higher demands on the 
material reliability. The relevance of the discrepancy between the scopes of ELVD and 3R 
Directive for lorries, mainly in relation to multi-stage build vehicles, and the lack of knowledge 
about EoL material flows is identified.  

Buses: Compared with trailers and lorries, there are far fewer buses in the stock, 
i.e., fewer that reach the end of their lives per year. Compared to lorries, the relative 
share  of  used  buses  exported  is  also  lower  (~34%  in  the  cases  of  buses). 
Nevertheless, the lack of export control is probably a considerable problem, see photos. In 
terms of material composition, buses are special: Glass (from the windows) and textiles (from 
the  seats)  are  probably  more  common  than  in  any  other  vehicle  category.  Steel  and 
aluminium are also important materials. The weight is similar to that of lorries, probably weight 
reduction  plays  a  role,  but  details  are  not  known.  It  can  be  assumed  that  the  circularity 
potential is not exploited. 

(Semi-)Trailers:  In terms  of  the  entire  fleet,  trailers  account for  less than  6%  by 
unit,  but  ~18%  by  weight.  The  variability  of  these  vehicles  is  high,  the  material 
composition also varies greatly depending on the trailer type. Little is known about 
the  end  of  life  of  trailers.  Export  trade  statistics  show  that  ~  75  000  trailers  are 
exported per year (~8% of expected ELVs). This is little compared to other vehicles discussed 
above. Therefore, it is concluded that there is a large mass of materials from trailers for which 
there  is  currently  no  information  available  on  their  end-of-life  (and  for  their  design).  It  is 
therefore unclear whether the CE potential is exploited, where the levers for the CE lie, or 
whether there are problems with inadequate treatment. For (semi-)trailers, the problem and 
its  drivers  can  only  be  inadequately  described  greatly  affecting  authorities  in  fact-based 
decision making in relation to measures to take in line with political priorities. 

2.4.4  Which objective should be achieved? 

The EU industry as a whole is identified to be ‘too linear, and dependent on a throughput of 
new materials extracted, traded and processed into goods, and finally disposed of as waste 
or emissions.’ (EU Green Deal, EC (2019)) This relates to all players engaged in economic 
activity around vehicles including the non-M1- and non-N1 vehicles. The general objective of 
the  intervention  should  aim  at  obtaining  contributions  from  the  whole  vehicle  sector  to  the 
targets set out in the EU Green Deal (European Commission 2019) and the Circular Economy 
Action Plan (European Commission 2020a), namely to increase the circularity of respective 
vehicles. Therefore, the objective is to ensure a comprehensive coverage of the sustainable 

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production and waste management at EoL (dismantling, sorting, reuse, recycling, recovery, 
disposal) of all relevant vehicles by the ELV Directive.  

This should apply to all materials and components 
of the vehicle, including vehicles currently outside 
of  the  Directive,  promoting  a  circular  approach  in 
the scope 
the production and end-of-life treatment of vehicles. Also, this objective includes the option to 
react  to  the  identified  ‘large  number  of  ‘unknown  whereabouts’,  i.e.,  that  all  vehicles  are 
collected and recycled. In the attempt to achieve this objective, first, the extension of scope 
of the ELV legislation, and second, the harmonisation of EU wide of ELVs other than M1 and 
N1 will build the basis.  

Obtaining information is an important objective for all four vehicle categories: Most important 
in  the  short  term  is  the  introduction  of  a  reporting  of  ELVs  as  laid  down  in  EC  Decision 
2005/293/EC  for  M1  and  N1  as  they  lay  the  foundation  for  measures  for  increasing  the 
collection of vehicles. For PTW, buses and trailers, it is also about (one-off) information to 
characterise the EU-wide EoL market, i.e., number, location and type of operators, throughput 
of their facilities, recycling efficiencies, etc. Data for the EoL of lorries is already available for 
individual MS, e.g., Spain (ANERVI/AETRAC 2021), but the overall EU overview is missing 
for all categories of vehicles. In relation to PTW, data on exports of used vehicles is lacking 
as well as information for waste management operators. While export data for used buses 
and trailers is available, it is unclear whether recyclers are lacking information needed for the 
recycling of buses and trailers. 

Though data is limited, there is a certain amount of expected ELVs that has to be dismantled 
and  recycled  in  the  EU  (after  subtracting  a  certain  percentage  for  export  and  additional 
vehicles  that  are  not  recycled  but  just  stand  around).  And  though  it  is  expected  that 
dismantling and reuse/sale of used parts is established for the four groups of vehicles, it can 
be  expected  that  certain  fractions  enter  the  recycling.  In  the  short  term,  it  should  be  the 
objective to be able to quantify these material streams (per vehicle category), so that in the 
long term identify assess and identify the need for measures that ensure design for recycling, 
high  quality  of  recyclates  and  the  highest  quantities  of  recyclates  possible;  and  with  that, 
measures  to  ensure  that  vehicles  placed  on  the  market  comply  with  the  design  rules.  A 
detailed  assessment  of  the  scope  extension  with  currently  available  data  can  be  found  in 
Annex I, section 6.10.  

In order to avoid leakage of pollutants from unsound treatment in illegal operations, another 
objective should be the formalisation of the EoL sector, where not formalised already today. 
Authorized, that means formalised, treatment facilities are the stakeholders to report to MS 
authorities,  based  on  CoDs,  the  number  of  ELVs  treated.  In  this  respect,  formalisation 
supports the reporting of ELVs, thus, the robustness of the numbers.  

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2.4.5  What are the measures to achieve the objective? 

2.4.5.1  Measures 

to  achieve  objective  1:  Ensure  a 
comprehensive  coverage  of  the  sustainable  production 
and  dismantling  of  all  relevant  vehicles  by  the  ELV 
Directive 

The  pre-condition  to  ensure  the  achievement  of  the  above-mentioned  objective  is  the 
extension of the scope of ELVD and 3R Directive to L vehicles196 referred to as powered two- 
and three wheelers (PTW) in the following as well as   M  vehicles  (used for  the  carriage  of 
passengers, e.g. cars and buses), N vehicles (used for the carriage of goods, e.g. lorries), 
and O vehicles (trailers including semi–trailers)197 with the exemption of vehicle category T 
(agricultural  tractors).  To  be  precise,  special  purpose  vehicles198  and  multi-stage  build 199 
vehicles of category M2,3, N2,3, and O (considered not relevant for L-type-approved vehicles) 
or such  vehicles  built  in small  series200  are covered  by  the measures. Only  when  vehicles 
currently outside of the scope of the ELVD enter the scope of the two Directives, the existing 
tools of the Directives and measures under consideration in relation to the other objectives of 
this study can be applied.  

Measures to achieve objective consist of the following.  

• 
Information to waste management operators 
•  MS reporting (via Eurostat) on ELVs by number 
•  OEM and ATF reporting to EC: One-off reporting obligation on characteristics of the end-

of-life market 

•  Hazardous substances restrictions 
•  ATF treatment 
•  Full 3R Type Approval 
•  Design for circularity 
•  Reuse & Recycling 
•  CoD (traceability) 
•  Advanced traceability 
•  Export restrictions 
•  EPR for all vehicle types 

196  Powered two- and three-wheel vehicles, mopeds, motorcycles (incl. motorcycles with side-car) and quadricycles, type 
approved through REGULATION (EU) No 168/2013. 

197 Type approved through REGULATION (EU) No 2018/858. 

198 According to Regulation 2018/858/EU: ‘special purpose vehicle’ means a vehicle of category M, N or O having specific 
technical features that enable it to perform a function that requires special arrangements or equipment, and characterised 
through Regulation 2018/585/ EU, Annex 1, Part A, point 5. 

199 as referred to in Regulation 2018/858/EU. The multi-stage procedure (described in article 22(1) of the mentioned 
Regulation) is a procedure where “one or more approval authorities certify that […] an incomplete or completed type of 
vehicle satisfies the relevant administrative provisions and technical requirements” (Regulation 2018/858/EU, article 3(8)). 

200 In the Regulation 2018/858, the general type-approval regulation in force today, the annual limits per Member State are 500 
units for O1, O2, and 250 for M1, M2, M3, N1, N2, N3, O3, O4. The EU-wide annual limits are 1 500 for M1, N1, N2, N3, and 
0 for other categories.  

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The description of the measures differs in detail. A short description is provided below, while 
detailed descriptions can be found in other parts of the report (references can be found below 
each measure). Generally, it should be noted that some of the measures to achieve objective 
1 shall only apply to vehicles that are not yet in scope, some measures apply to M1 and N1 
already in the current version of ELVD, and a third set of measures are being considered as 
new  provisions  for  M1  and  N1  as  well  as  for  those  not  yet  in  scope  of  ELVD,  i.e.,  such 
measures might apply to all vehicles covered under the new legislation.  

2.4.5.1.1  Information to waste operators 

Generally,  in  order  to  dismantle  parts  for  reuse  or  separate  recycling  in  a  safe  and 
environmental  manner,  ATFs  need  information,  e.g.,  as  to  location  and  method  for 
dismantling  components  that  need  to  be  depolluted  or  recycled  separately  or  that  can  be 
reused.  Currently,  though  not  considered  ideal,  at  least  for  lorries,  such  information  is 
provided through IDIS. A PTW-specific IDIS does not exist. Still, dismantling for reuse is said 
to be common for PTW. 

Future legislation shall foresee a provision that ensures that operators of waste vehicles other 
than M1 and N1 have access to the required information. In relation to M1 and N1, ELVD 
already obliges OEMs to provide certain types of data to ATFs and additional requirements 
are under consideration for M1 and N1 vehicles, possibly added as an obligation for provision 
of data as part of the 3R Type approval process. At least the same information as for M1 and 
N1  vehicles  shall  be  provided  to  non-M1-N1  vehicle  dismantlers,  if  relevant  to  these 
dismantlers.  The  list  of  information  requirements  for  waste  operators  should  be  double 
checked with ATFs of PTW, lorries, buses or trailers to see if they see the need for information 
for  supporting  circularity  in  addition to  the  information required  for  M1  and  N1  vehicles (or 
information that is not needed for vehicles of other categories).  

Vehicle specifics: The majority of the items for which information is required is considered 
vehicle-unspecific, though, the information as such will differ from passenger cars. A list of 
additionally  required  vehicle-specific  information  will  be  different  for  the  different  vehicle 
categories, but such lists are not yet available. 

Expected Outcome: Same access to information is considered one factor to create a level 
playing field for dismantlers. If in the future implemented together with the ATF requirement 
(as explained below), a dismantler might deal one vehicle category today but could expand 
their business to other vehicle categories in the future. Thus, especially waste operators not 
(yet)  specialised  in  the  treatment  of  certain  vehicles,  e.g.,  PTW  may  benefit  from  the 
information provided to reduce dismantling times or get an idea of component parts that are 
beneficial for removal, e.g., due to the material composition. 

Affected Stakeholders: Vehicle manufacturers and their suppliers 

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2.4.5.1.2  MS Reporting on ELVs by number 

Today, through the ELVD, Member States are obliged to collect statistical data on the number 
of  ELVs  in  scope  of  ELVD  (Commission  Decision  2005/293/EC)  which  was  introduced  to 
monitor the reuse/recycling and reuse/recovery targets set out in the ELVD. Under specific 
through  measure  2.4.F)  REVISION  OF  COMMISSION  DECISION 
objective  2.4, 
2005/293/EC ON THE CIRCULARITY ASPECTS (see section 0), it is foreseen to revise the 
reporting for M1 and N1 vehicles.  

Statistics  on  ELVs  other  than  M1  and  N1  vehicles  do  not  exist.  Under  this  measure,  the 
reporting on the vehicle fleet shall be established for new vehicles. As for M1 and N1 vehicles 
today, for Eurostat (yearly reporting), MS shall be asked to name the "total number of vehicles 
of ELV"201. Dependent on whether the measure 2.3 F is amongst the preferred measures to 
address the problems associated with the objective 2, it shall be reflected whether a revised 
Commission  Decision  2005/293/EC  (measure  2.3  F)  shall  fully  apply  to  new  vehicles,  or 
whether the reporting on the vehicle fleet shall apply for non-M1-N1 vehicles, but not other 
parts of the revised Commission Decision 2005/293/EC.  

Vehicle  specifics:  Changes  are  expected to  be  different  in  different MS  and  different  per 
vehicle category as reporting on ELVs already exist in some MS for some vehicle categories, 
e.g., Spain for lorries. The highest effort is expected for PTW for which the possibility to obtain 
temporary  deregistration  is  important.  It  shall  be  ensured  that  a  seasonal,  i.e.,  half-year, 
deregistration of motorbikes is possible at minimum additional administrative burden to the 
owner. 

Expected Outcome: The reporting on the end-of-life vehicles, e.g., through registration and 
de-registration, where applicable, facilitates Member States to identify the extent of problems 
associated  with  missing  vehicles.  It  is  considered  a  contribution  to  closing  the  lack  of 
knowledge hindering authorities in fact-based decision making. 

Affected Stakeholders: MS authorities, ATFs/dismantlers 

2.4.5.1.3  One-off  reporting  on  EoL  (OEMs  and  ATFs  to 

report to MS which report to the EC) 

The aim of the measure is to provide a comprehensive description of the way under which 
vehicles  outside  the  scope  of  ELVD  are  currently  treated  at  end-of-life  and  how  the 
design/production of such vehicles takes circularity aspects into account.  

The measure requires 

(i) economic operators (OEMs and ATFs) either involved in production or EoL treatment of 
motorbikes, trucks, trailers and buses to provide information on the design, production and 
EoL treatment of their vehicles within one year of entry into force of the new rules, and  

201 If implemented together with the measures on ATF requirements and that CoDs shall be issued for vehicles other than 
passenger cars, the real number of ELVs arising in the country could be collected based on the CoD issued by ATF. 

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(ii) the Commission to investigate the waste management of other vehicles not yet in scope 
of ELVD and produce a report within two years of entry into force of the rules.  

The  report  shall  include  an  assessment  of  the  potential  gains  (or  losses)  for  the  circular 
economy (i.e. amounts and types of parts and materials that can be reused or recycled) that 
could be leveraged if such vehicles are included in the scope of the ELV legislative framework. 
The report should also assess which rules and provisions that were agreed on for M1 and N1 
in the new ELV legislation should apply to vehicles other than M1 and N1 in the future. 

In principle, Member States shall report to the European Commission. For this purpose, the 
Commission shall adopt a delegated act/implementing rule or provide a template/guideline 
laying down the format for data to be reported. Information to be reported shall depend on the 
provisions to apply to new vehicles in scope from entry into force of legislation but also on 
provisions that will be decided at a later point of time. This may include new provisions to be 
added to the ELVD for passenger vehicles (i.e., if recycled content targets are added, data 
will need to be reported to allow estimating what target rate would be relevant for new vehicle 
types in scope). It is thus expected that the reporting format will be established shortly after 
the legislation comes into force (within one year), with the MS expected to submit the report 
one  year  later.  The  format  for  reporting  on  end-of-life  treatment  of  vehicles  new  in  scope 
should include a list of information requirements on:  

• 
• 

the treatment capacities of end-of-life trucks, buses and motorcycles,  
the estimated amounts of reuse parts and of recycled materials (including breakdown into 
material composition),  

•  description  of  typical  treatment  routes  of  an  ELV  of  these  types,  e.g.  dismantling, 

recycling, shredding, PST, etc.  
•  Potentially: recycled content, … 

This measure is closely linked to the ‘circularity strategy’ under consideration for M1 and N1 
vehicles under specific objective 2.1. It is also a different type of design of the measure ‘design 
for circularity’ (chapter 2.4.5.1.8). It differs in the actor obliged to report, in the frequency of 
reporting, and this measure may allow a focus on new vehicles in scope whereas the measure 
‘design for circularity’ (chapter 2.4.5.1.8) points to all vehicles in the future scope of ELVD 
specifically. 

Vehicle specifics: MS specific; highest effort expected for PTW 

Expected Outcome: The reporting on the end-of-life of vehicles facilitates Member States 
as  well  as  the  European  Commission  to  identify  the  extent  of  problems  associated  with 
missing  circularity  of  vehicles  that  are  not  in  scope  of  ELVD  today.  It  is  considered  a 
contribution  to  closing  the  lack  of  knowledge  hindering  authorities  in  fact-based  decision 
making. 

Affected Stakeholders: MS authorities, manufactures and their suppliers, EoL stakeholders 

2.4.5.1.4  Hazardous substance Restrictions (based on Art. 4 

ELVD).  

Under  this  measure,  it  is  foreseen  to  restrict  the  four  heavy  metals  mentioned  in  Art.  4  of 
ELVD  for  new vehicles entering  the  scope  of  ELV  legislation.  Experiences from  the  RoHS 
Regulation (Directive 2011/65/EU 2011) suggests that a minimum period of 2 years is needed 
to allow OEMs to collect information from the supply chain through a survey to get an overview 
of where hazardous substances are used and where exemptions may be needed to allow a 
longer transition or to develop substitutes. After it is clear where exemptions may be needed, 
another  1,5  to  2  years  would  be  needed  to  allow  submission  of  applications  for  these 

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exemptions,  for  their  assessment  and  where  justified,  for  amendment  of  the  list  of 
exemptions.  Legally,  existing  exemptions  could  apply  to  new  vehicles  in  scope  from  the 
moment the legislation entries into force, allowing OEMs to put non-compliant vehicles on the 
market  for  a  transition  period  of  four  years  to  allow  for  the  processing  of  justified  new 
exemptions. Alternatively, the substance prohibitions could apply after a four-year transition 
period, throughout which new vehicle OEMs would need to apply for all exemptions relevant 
– those already listed as well as necessary new ones.  

Vehicle  specifics:  This  measure  shall  be  applicable  to  all  vehicle  categories.  Though, 
different exemptions from the restrictions will be needed for the different vehicles, as shown 
through various stakeholder contributions. Independent of the preferred option for the specific 
objective 2.4 ‘ensure elimination of hazardous substances in vehicles’ in relation to the future 
legislation  to  deal  with  additional  hazardous  substances  in  vehicles,  differentiation  for  the 
different vehicle categories will be required. 

Expected Outcome: Already today, REACH is of relevance for hazardous substances in the 
vehicles  whether  in  scope  of  ELVD  or  not,  e.g.,  model-based  information  on  SVHC  to  be 
provided to customers on demand (Art. 33 of REACH) and parts related information can be 
found  in  SCIP  database.  The  avoidance  of  the  heavy  metals  in  waste  from  vehicles  is 
expected  to  provide  environmental  and  health  benefits  from formalized treatment  and  less 
environmental burden from vehicles dropped in nature.  

Affected Stakeholders: Manufacturers and their suppliers, EoL stakeholders 

2.4.5.1.5  Obligation that vehicles are dismantled in ATFs  

M1 and N1 vehicles shall be brought to authorized treatment facilities (ATFs) according to 
Art. 5 & 6 of ELVD. It is the aim of this measure to apply the existing rules for ATF treatment 
to  vehicles  other  than  passenger  cars.  Under  objective  3,  the  ATF-provision  might  be 
strengthened with additional enforcement, e.g., minimum requirements for sector inspections 
and  penalties  for  illegal  operators.  Dependent  on  the  preferred  option  in  relation  to  these 
measures  addressing  the  problems  in  relation  to  missing  vehicles,  it  is  still  to  be  decided 
whether the potentially stricter enforcement rules shall apply to the waste operators dealing 
with  new  vehicles.  Given  that  car  ATFs  might  deal  with  PTW,  and  that  lorry  ATFs  can 
dismantle  trailers  etc.  it  might  be  considered  that  the  same  rules  apply  to  all  ATFs 
independent  of  the  vehicle  category  they  are  specialised  on,  but  this  cannot  be  further 
developed at this stage.  

For  new  vehicles,  stakeholders  stated  that  heavy  duty  vehicles  are  already  dismantled  in 
ATFs  (at  least  in  some  MS),  but  that  there  are  no  motorbike-specific  ATFs  (ACEM  2021; 
ANERVI/AETRAC 2021). Nonetheless, the dismantling of motorbikes can also be performed 
by passenger car ATFs (ACEM 2021). It is thus assumed that only a short transition period 
would be needed to apply the obligation of treatment of new vehicles in scope in ATFs, e.g. 
one year. 

Vehicle specifics: Though the ATFs may differ, e.g., need larger spaces and other tools, the 
measure as such is not vehicle specific. 

Expected  Outcome:  On  the  sides  of  benefits,  environmental  benefits  are  expected  from 
formalised treatment and externalised costs will be internalized (distribution effect, economic). 
For some countries, one expected outcome is that informal jobs will be formalized. For this 
measure the burden can be attributed to administrative costs.  

Affected Stakeholders: Vehicle owners, ATFs/dismantlers, MS authorities 

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2.4.5.1.6  Obligation to  give a  CoD  to  the  last owner  of  the 

vehicle 

In  combination  with  the  obligation  to  treat  vehicles  in  ATFs,  this  measure  shall  ask  that  a 
certificate of destruction (CoD) is given to the last owner of the vehicle (by the ATF), which 
would  be  necessary  for  deregistration.  At  a  minimum,  through  this  measure  the  same 
provisions  shall  be  established  for  vehicles  not  yet  in  scope  of  ELVD  as  for  M1  and  N1 
vehicles today.  

Among the measures to address the problem of missing vehicles (in relation to objective 3.1) 
the  OBLIGATIONS  FOR  DISMANTLERS  /RECYCLERS  TO  CHECK  AND  REPORT  ON 
ELVS/CODS is under consideration(see details under section 2.2.5.1.5). Dependent on the 
preferred option in relation to this measure (amongst others) it is still to be decided whether 
the new obligation to check and report ELVs on the number of CoDs shall apply to the waste 
operators dealing with new vehicles. 

The provision shall be formulated so as not to create obstacles for the reuse market.  

Vehicle specifics: not vehicle specific. 

Expected  Outcome:  This  measure  facilitates  Member  States  to  identify  the  extent  of 
problems associated with missing vehicles. It is considered a contribution to closing the lack 
of knowledge hindering authorities in fact-based decision making. 

Affected Stakeholders: Vehicle owners, ATFs/dismantlers 

2.4.5.1.7  3R TA provisions 

Currently, the 3R Directive provides a mechanism for ensuring that M1 and N1 vehicles that 
are placed on the market comply with certain requirements, including the ELV heavy metal 
restrictions  and  the  targets  specified  under  ELV  for  reuse,  recycling,  and  recovery.  It  is 
currently being considered to change the 3R Directive, e.g., so that the calculation applied to 
establish whether vehicles comply with the reuse, recycling, and recovery targets reflects the 
actual targets achieved at end of life more precisely. OEMs may also be required to provide 
evidence  on  the  benefits  in  the  use  phase  that  are  achieved  when  significant  amounts  of 
materials that are not recyclable at the time POM prohibit fulfilment of the targets. 

Through this measure, the scope of the 3R Directive shall be aligned with the potential future 
scope of the ELVD, thus, extended in the same way than the scope of the ELVD. Provisions 
of 3R Directive shall apply without exemptions and including the above-mentioned considered 
measures for the 3R type-approval of M1 and N1 vehicles. 

Please  note  that  the  measure  to  include  multi-stage  build  M1  and  N1  vehicles  in  the  3R 
Directive is discussed elsewhere in this report (add reference) together with other measures 
to amend 3R Directive for M1 and N1 vehicles. 

Vehicle specifics: In relation to the mechanism of the 3R Directive, to ensure that vehicles 
brought to the market comply with certain requirements, this measure is not vehicle specific. 
Even the methodology for calculation of the recyclability rate, ISO 22628:2002(E), is per its 
title intended for ‘road-vehicles’ referring to ISO 1176 ‘road vehicles – masses – vocabulary 
and code’ (ISO 1176:1990) but not M1 and N1-specific. However, the ambition level of the 
3R targets is vehicles specific, but not covered by this measure (however, covered by another 
measure). This is because it is a ELVD requirement directly taken over to the 3R Directive. 
Still, in some placed vehicle-specific differentiation is needed. Among, others, this measure 

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requires a vehicle-specific Annex V of 3R type approval directive (referred to in Art. 7 of the 
same Directive) which refers to component parts which shall be deemed to be non-reusable 
for  the  purpose  of  calculating  the  3R  rate  and  that  may  not  be  reused  according  to  the 
specifications of new vehicles in scope.  

Expected  Outcome:  For  vehicles  other  than  passenger  cars,  some  the  general 
process/methodology of the 3R type-approval is expected implementable, as already today, 
these vehicles are being generally type approved. Also, it is expected that vehicle types that 
will  be  new  in  scope  of  the  ELV  framework  and/or  3R  Directive  could  use  the  same 
methodology for calculating the recyclability and recoverability. The potential benefits of the 
measure  are  difficult  to  imagine  without  a  link  to  ELVD  requirements  such  as  hazardous 
substance restrictions or 3R targets which are discussed as separate measures.  

Affected Stakeholders: Authorities, manufacturers 

2.4.5.1.8  Design for circularity 

Though the ELVD refers to the need to promote more circular design of vehicles (design that 
facilitates waste management at EoL), it does not set any specific measures as to how this is 
to be achieved. It is thus currently being considered whether to require OEMs to develop and 
submit a “circularity strategy” that will need to fulfil minimum information requirements. At the 
first stage the strategy would report on the current status quo (how much recycled content is 
used, what methods are applied to facilitate easier dismantling, etc.). An updated report would 
need  to  be  submitted  every  5  years.  Allowing  the  ambition  of  minimum  information 
requirements to increase, meaning that this measure starts as a soft one but could become 
more  stringent  if  needed. In  addition,  implementing  a recycled  content target  or  plastics  is 
being considered and could be considered in the future for additional materials (e.g., REE or 
magnets,  glass  and  rubber).  See  the  detailed  description  above  (for  detail  see  section 
2.1.5.1.3). 

Under this measure, the preferred measure for design-for-circularity measure for M1 and N1 
vehicles shall be considered for categories L, M2,3, N2,3, and O in identical manner (among 
the  measures  2.1.a  to  2.1.c,  excluding  3R  type-approval-related  measures  (excluding 
measures 2.1.d to 2.1.i) which, for non-passenger cars, are covered by another measure.  

Vehicle specifics: not vehicle category specific. 

Expected Outcome: It is assumed that this measure could lead to benefits over time, though 
this depends to a large degree on what is the preferred option for M1 and N1 vehicles, e.g., 
whether  there  are  minimum  information  requirements  and  how  they  will  develop  from  one 
reporting period to another. 

Affected Stakeholders: Authorities, manufacturers and their suppliers 

2.4.5.1.9  Reuse & Recycling 

The  ELVD  requires  M1  and  N1  vehicles  to  fulfil  a  reuse+recovery  and  recycling+recovery 
target (thereafter referred to as 3R targets). However, it is considered that there is potential 
to increase the reuse of components. To this end, a few measures are being considered for 
implementation to promote reuse and remanufacturing. Definitions for these terms are to be 
included  in  the  legislation.  The  level  of  reuse  is  to  be  monitored  by  introducing  reporting 
requirements that will refer to a monitoring target. Measured that are to promote the demand 
for reused and remanufactured components could be implemented and though not targeting 
reuse, measure developed to increase and improve recycling may also have a positive effect 
on reuse. On recycling, aside from the reuse, recycling and recovery targets that need to be 

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achieved, the Directive also makes certain provisions as to parts that are to be depolluted or 
removed form vehicles and treated in a certain way. Here too, additional measures are under 
consideration: to expand the list of components that must be removed from the vehicle prior 
to shredding (e.g., glass, EEC, etc.), to establish material specific targets in some cases (e.g., 
plastic)  or  to  require  the  application  of  certain  shredding  and  post  shredding  processes 
through  compliance  with  EoL  standards.  The  existing  targets  are  also  being  looked  at  to 
consider if their level of ambition is to be changed, also in the case that a calculation point is 
implemented in the reporting requirements for vehicles. See the detailed description above 
(see measures described under section 2.1.5.3 and section 2.1.5.4). 

Under this measure, the preferred measure for design-for-circularity measure for M1 and N1 
vehicles shall be considered for categories L, M2,3, N2,3, and O in identical manner, though 
with vehicle specifications where needed as detailed below. 

Vehicle specifics: individual per vehicle category 

Expected Outcome: The measure contributes to a larger amount of material being reused, 
larger amount of material to be recycled and of higher quality of recycled material. Among 
others, reduced CO2 emission and other environmental impacts from new material extractions 
are the environmental benefits thereof. On the economic side, revenues from spare parts and 
recycling are expected to rise for recyclers and dismantlers.  

Affected Stakeholders: Authorities, manufacturers, EoL stakeholders 

2.4.5.1.10  Advanced traceability 

Here,  advanced  traceability  is  referred  to  in  contrast  to  the  measures  that  were  earlier 
presented on MS reporting on ELVs by number and obligation to give a CoD to the last owner 
of vehicles. These two measures are designed to at least establish rules comparable to the 
existing  rules  for  M1  and  N1.  However,  it  has  been  shown  that  the  existing  rules  are  not 
sufficient to address the problem. Thus, under objective 3, measures are considered for M1 
and  N1  vehicles  to  improve.  Amongst  the  preferred  measures  in  relation  to  advanced 
traceability are those grouped in policy option 3A mainly targeting enhanced reporting and 
enforcement, e.g., ATFs to improve reporting on CoDs. See the detailed description above 
(see details on measures under section 2.2.5.1). 

Under  this  measure,  the  preferred  measures  under  specific  objective  3.1  (Ensure  that  all 
ELVs are treated in accordance with the requirements of the ELV Directive) for M1 and N1 
vehicles shall be considered for categories L, M2,3, N2,3, and O in identical manner. 

Vehicle specifics: not vehicle specific 

Expected Outcome: Based on advanced traceability, it shall be possible to assess whether 
all ELVs are directed to authorised treatment facilities (ATFs) or not. The existing concerns 
about environmental impacts, losses of potential recyclables if not directed to legal treatment 
facilities, economic losses for the formal sector, and social impacts for informal sector workers 
shall be overcome.  

Affected Stakeholders: Authorities, vehicle owners, illegal second-hand operators 

2.4.5.1.11  Export restrictions 

The intention to regulate the exports of vehicles is building on the problems associated with 
missing traceability and intra-EU trade on the one hand side, and on problems associated 
with  extra-EU  export,  e.g.,  environmental,  health  and  social  risks  for  the  countries  of 
destination caused by (old) used vehicles imported. Thus, under objective 3, measures are 

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considered for M1 and N1 vehicles to improve, e.g., an improved definition of what is an ELV 
and  coupling  export  with  a  road  worthiness  certificate.  Under  this  measure,  the  preferred 
measures under specific objective 3.2 (Reduce levels of illegal dismantling and illegal export 
of ELVs) and 3.3 (Establish enforceable criteria to avoid the export of (used) cars which do 
not meet roadworthiness or minimal environmental standards) for M1 and N1 vehicles shall 
be considered for categories L, M2,3, N2,3, and O in identical manner. 

See the detailed description for above measures under section 2.2.5.2). 

Vehicle  specifics:  Not  vehicle  specific.  However,  considered  highly  relevant  for  lorries, 
buses and trailers, but the current situation and relevance is unknown for PTW. 

Expected Outcome: From implementation of measures to restrict the export, it is expected 
that no (non-depolluted) ELVs is exported to non-OECD countries, that the rules of the Basle 
Convention and Waste Shipment Regulation are applied, and that no used vehicles exported 
which would generate environmental adverse impacts the receiving countries. 

Affected Stakeholders: Authorities, illegal second-hand operators 

2.4.5.1.12  EPR for all vehicle categories 

More  challenging  regulations  in  the  context  of  the  Circular  Economy,  aiming  for  a  higher 
quality  recycling,  might  require  more  effort  at  ATFs.  Such  effort  might  be  as  such  not 
economically viable and cannot be covered by revenues or would reduce the profits of the 
ATFs (which would reduce the competitiveness of ATFs with the illegal sector). The relevance 
of compliance cost offsetting for ATFs will depend on the various measures listed above. As 
for the M1 and N1 vehicles, the establishing of an EPR is considered an individual measure. 
Thus, under this measure, an EPR shall be established for the vehicle categories L, M2,3, 
N2,3, and O in identical manner to the EPR rules that shall be established for M1 and N1 
vehicles See the detailed description above (section2.4.5).  

Details  of  such  measure  highly  depend  on  the  decisions  in  other  places  and  cannot  be 
provided at this stage. 

Vehicle specifics: The mechanism of EPR is not vehicle specific. But, in the transposition, 
vehicle-specific fees etc. may be required.  

Expected  Outcome:  If  relevant,  the  main  outcome  of  establishing  an  EPR  would  be  the 
compliance cost offsetting for ATFs. As for M1 and N1 vehicles, it is expected that an EPR 
ensures transparency and a fair distribution of costs linked to the treatment of ELV, in line 
with  the  polluter-pays  principles.  The  EPR  Scheme for  ELVs  shall  enable  consideration  of 
Circular Economy beyond the simple economic viability considering the efficiency of the EPR 
requirements regards environmental impacts, cost and social impacts. 

Affected Stakeholders: manufacturers, EoL stakeholders 

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3.  Impact assessment 

3.1  Circularity  

3.1.1  Baseline  

The baseline reflects what would happen under a “non-policy-change” scenario without new 
policy intervention, and assuming realistic implementation of existing legislation.  

Though the design of vehicles is mentioned in the current ELVD, aside from the prohibition 
of hazardous substances, there are no clear requirements on the design of vehicles. As is 
currently the case, any actions at this stage taken by manufacturers to increase the circularity 
of vehicles are voluntary. Such actions are expected to continue and to increase in magnitude, 
however at a slow pace: 

• 

IDIS will continue to be applied by manufacturers to provide information to ATFs on the 
depollution  and  dismantling  of  vehicles  and  it  can  be  expected  that  its  level  of 
harmonisation will increase, however a significant number of ATFs do not use IDIS and 
without specific action to change this situation, this is not expected to change. Data that 
is not included in IDIS (e.g., on dismantling of parts not addressed under Annex I.3-4 of 
ELVD and on digitally “locked” parts) will probably continue to be available only on other 
platforms  at  a  cost.  It  can  be  expected  to  be  used  mainly  by  larger  ATFs  and  those 
servicing only vehicles of a small number of OEMs. 

•  Though some manufacturers are active in developing the design of their vehicles to allow 
easy  dismantling  of  certain  components  (e.g.,  windows,  wire  harness,  etc.),  the 
information does not always reach all ATFs, reducing the number of benefits that such 
actions can achieve. This is expected to persist, 

•  Manufacturers that already target the increased inclusion of recycled content in the design 
of their vehicles will continue, but such efforts are still not implemented in the majority of 
vehicles at significant amounts, and this will probably not change significantly, 

•  The phase-out of the ELVD prohibited mercury, cadmium and hexavalent chromium has 
been achieved, but some uses of lead can be expected to prevail in the coming years. 
Additional  substances  are  regulated  through  other  legislation  (e.g.,  POPs  and  REACH 
Regulations). This situation of multiple legislation may not have a negative effect on the 
phase-out of hazardous substances but results in a higher administrative burden for the 
vehicle production sector. It would not be expected to change in the baseline. 

The  ELVD  requires  that  minimum  targets  of  reuse,  recycling  and  recovery  be  achieved  at 
EoL, and OEMs are required to demonstrate how they achieve these targets through the 3R 
Type  Approval  process.  However,  it  will  remain  questionable  whether  this  demonstration 
reflects the situation at EoL, seeing as e.g., material losses are disregarded, the calculation 
method  only  refuses  market  entry  of  vehicles  with  substantial  amounts  of  non-recyclable 
materials and reuse is not addressed through this demonstration. Reaching these targets was 
possible in most MS in the past but is becoming increasingly difficult. The expected changes 
in  the  design  of  vehicles,  increasing  the  amounts  of  plastics  and  materials  with  unclear 
recyclability with a view of reducing weight can be expected to change the balance between 
the share that is reused and recycled and that recovered or even worse landfilled. Achieving 
the reuse and recycling target of 85% is expected to become harder in the following years. 
Some MS can be expected to introduce individual regulation to ensure higher levels of reuse 
and recycling (e.g., France), but it is expected that others will have an increasingly harder 
time complying with the current targets. 

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3.1.2  Policy Options 

3.1.2.1  Identification of discarded measures 

With the aim to have a shortlist of measures for further assessment, all measures have been 
checked for viability. This step is not to be confused with the impact assessment itself and 
therefore  does  not  include  all  categories  of  impact  assessment  (economic,  social  and 
environmental) nor does it look into the detailed effects regards proportionality or impacts for 
the different stakeholder groups (like e.g., consumers and SME). 

The  details  of  this  viability  check  are  displayed  in  Annex  VI,  section  6.4.1.  In  result  the 
following measures are discarded and not shortlisted for the detailed assessment:  

•  2.1.a) OEM voluntary pledges campaign to increase circularity (2.1.5.1.2) 
•  2.1.b) EC non-binding guidelines on how to improve circularity in vehicles (2.1.5.1.3) 
•  2.1.g) Establishment of mandatory recycled content targets for materials used in cars – 

currently discarded for glass and rubber (2.1.5.1.8) 

•  2.1.h) Obligatory due diligence for materials used in vehicles (2.1.5.1.9) 
•  2.3.c) Voluntary activities of OEMs and their suppliers to promote the application of reused 

and remanufactured components (2.1.5.3.3) 

•  2.3.d) Voluntary activities of Member States to promote circularity (2.1.5.3.4) 

The remaining measures are shortlisted and are grouped for policy options in the following 
sections.  

3.1.2.2  Policy option overview 

The  various  measures  were  considered  in  the  development  of  three  general  options  for 
review. See Figure 3-1 below.  

Figure 3-1  Overview of policy options for circularity objectives 2.1-2.4 

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These options are based on a top-down approach, meaning that the analysis of the policy 
options would look at the vehicle as a whole, through general assumptions as to how design 
and  end-of-life  requirements  affect  the  treatment  of  vehicles  and  the  resulting  amounts  of 
material that can be reused, recycled or recovered from them. An assessment in this fashion 
would either remain quite vague, for example as to how specific materials are affected, or 
would be quite complex to carry out in a way that allows an understanding of the materials to 
be  reused,  recycled  or  recovered  and  how  these  are  affected  by  various  measures.  This 
approach creates the impression that a measure can either be applied, affecting all relevant 
components and materials in the vehicle or it cannot be applied, however the reality is that 
some  measures  may  be  more  suitable  for  addressing  certain  materials  while  for  other 
materials  a  different  approach  would  be  preferable  (i.e.,  a  different  measure  or  sub-set  of 
measures). It also has very little flexibility to accommodate changes at later stages, i.e., in the 
combination of measures considered under a specific option, as assessments would be taken 
at vehicle level and not at the level of single components and/or materials.  

However, against the background information provided in the current situation sections, it is 
already clear that a further specification of the measures, detailing to which materials and/or 
components  they  apply,  and  to  which  not,  would  allow  making  the  measures  more  fit  for 
purpose. Variations in the scope of applicability could also be applied to differentiate between 
the policy options but their specification requires a separate bottom-up analysis, looking at 
different  materials  or  components  separately,  to  allow  a  better  understanding  of  the 
applicability of each measure. 

Thus, a bottom-up approach was developed and is documented in the next section to allow 
an analysis at the material level for most measures and in some cases also at the vehicle 
level. Methodologically, an initial assessment was run to understand the various affects and 
the  ranges  of  impacts  where  these  could  be  quantified.  In  some  cases,  measures  were 
analysed as a sub-set of measures at vehicle level (for example for design measures) and in 
others  a  more  detailed  approach  was  taken,  looking  at  the  measures  of  relevance  for  a 
specific material and performing the analysis for the material in relation to the measures that 
appeared to have the highest potential for (positive) impacts. Assessed impacts were then 
considered  in  the  re-specification  of  policy  options  (see  sections  3.1.2.2.1  through  section 
3.1.2.2.3 below) that addressed three levels – design improvements affecting the circularity 
of  materials;  design  improvements  affecting  the  reuse  and  recycling  at  EoL;  and  waste 
management  improvements  affecting  the  treatment  stage  directly.  These  were  considered 
again in a revision of the analysis at material and vehicle level which is documented below. 
Presenting the results at this level leaves more flexibility to consider different combinations of 
measures should this be relevant.  

Finally, after a re-specification of the single measures was possible (where relevant), results 
of  this  analysis  were  combined  to  understand  the  impacts  of  specific  policy  options  that 
address all levels and that are presented together with the results of their analysis in section 
3.1.12 at the end of this chapter. 

The following options are thus considered as a starting point and were subjected to further 
refining at a later stage, after the specification of sets of measures for analysis at the material 
and vehicle level and following the analysis at this level. The resulting policy measures and 
their analysis are detailed later on in section 3.1.12. 

It  is  noted  that  there  is  a  gap  in  the  implementation  of  measures  referred  to  in  the  policy 
options developed for the design stage and measures that have been developed directly for 
the waste management. Due to the long lifetime of vehicles, it is expected that impacts of 
measures  affecting  design  will  only  be  visible  in  ELVs  arriving  at  EoL  after  this  so-called 
lifetime gap, i.e. after 15 years or so. 

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3.1.2.2.1  Policy Options 2.1: Design improvements to increase the 

circularity of materials.  

Focus: materials  

Objective: increasing the circularity of materials 

On  the  one  side  this  is  done  through  creating  a  demand  for  recycled  content  in  the 
manufacture of vehicles and on the other by considering substances that should be prohibited 
in the manufacture of vehicles so as not to create obstacles for the use of secondary materials 
recovered from them in the future.   

The measures included under this option aim to change the design of vehicles with a view to 
reducing the use of primary raw materials in the production of new vehicles, through a higher 
uptake of recyclable materials. It therefore aims at addressing the environmental footprint of 
the  automotive  sector,  linked  to  the  production  phase  of  new  vehicles  and  renders  this 
production phase more circular. The measure focuses on the materials for which recycling 
rates and use of recycled materials are currently very low (plastics, magnets containing rare 
earth  elements,  other  CRMs).  According  to  Maury  et  al.  (2022)  in  the  baseline  only  2% 
recycled content of plastics is assumed. These low levels indicate that, if left to market forces 
alone,  the  automotive  industry  will  continue  to  be  dependent  on  the  use  of  primary  raw 
materials and the environmental footprint linked to the production phase of new vehicles will 
continue  to  grow.  To  address  this  situation,  regulatory  intervention  is  needed,  through  the 
setting of mandatory targets for the use of recycled content for plastics, REEs contained in 
magnets  and  possibly  additional  CRMs  used  in  EVs.  The  measures  proposed  under  this 
option have a high level of prescriptiveness, requiring OEMs to apply changes to their design 
and production that may be implemented via changes in the 3R.  

At the final stage of treatment, the presence of certain substances (hazardous but in some 
cases a substance can be disruptive to recycling even without having hazardous properties), 
can hinder the usability of materials recycled from the vehicle, in some cases also hindering 
their  recycling  altogether.  To  limit  such  impacts,  the  ELVD  already  prohibits  that  vehicles 
contain  4  heavy  metals,  with  a  number  of  exemptions  still  allowing  use  in  specific  cases. 
Measures  have  been  developed  to  enhance  these  prohibitions,  also  through  the 
consideration of the legal framework chosen for the regulation of substances in vehicles. Such 
measures affect the vehicle and more specifically its materials at the design stage, with the 
goal of contributing to the general circularity of the vehicle.  

Policy option 2.1 includes the following measures: 

Title of measure 

Chapter 

Effective by 

Implemented via: 

2.2.a): Restriction of substances in vehicles 

(2.1.5.2) 

2025 

(and  ELV  or 

3R 
REACH/ROHS)  

2.1.g) Establishment of mandatory recycled 
content targets for materials used in cars 

(2.1.5.1.8) 

Various dates 
depending on the 
material and target 

3R 

Measures  addressing  the  elimination  of  hazardous  substances  (specific  objective  2.4)  are 
assessed  separately.  Measure  2.1.g  on  a  recycled  content  targets  is  considered  a  design 
requirement and is thus clustered under this policy option. However it is tightly connected to 
the measures addressed under specific objective 2.4 (increasing recycling rates of…). As this 
measure  is material  related  it  will  be  considered  as  an  alternative  (or  in combination)  with 
other measures that address reuse and/or recycling of the material that is to be affected (e.g., 
plastic).  

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3.1.2.2.2  Policy  Options  2.2:  Design  improvements  to  increase 

recyclability and reusability 

Life-cycle stage: design (prevention) 

Focus: vehicle  

Objective: Improved recyclability and reusability 

Under this option, to allow a large flexibility in how the objectives are achieved, the measures 
address information or reporting requirements that would require OEMs to make changes in 
design to comply, however without prescribing how the design of vehicles is to be changed.  

Policy option alternatives to be investigated under 2.2 include the following measures:  

No  

Title of the measure 

Chapter 

Effective by 

Implemented 
via: 
3R 

2025 

2.2A: Better 
compliance 

Adaptation of the 3R Directive to the new 
Type approval Framework Regulation (see 
details below) + proper definition of types 
of vehicles (see detail below) + 2.1.d) 
Provisions for improving the relation 
between the 3R Type approval process 
and ELV waste management performance. 
+ 2.1.e) Option for OEMs to submit life 
cycle data as part of the 3R type approval 
process to justify the use of materials 
where recycling is not yet established + 
2.1.i) Set out an obligation for OEMS to 
provide additional information on 
composition of cars + 2.2.b: Improved 
communication on hazardous substances 
in the automotive value chain 

2.2B: Better 
Compliance + 
Circularity 
strategy 

2.2C: Better 
Compliance + 
Circularity 
strategy+ 
minimum 
levels of 
recycled 
content 

In addition to the measures included under 
2.2.a, the following measure also included: 
2.1.c) Obligation for OEMs to develop and 
implement a circularity strategy for 
increasing the circularity of vehicles 
In addition to the measures included under 
2.2.a, an information obligation would also 
be introduced in the form of an obligation 
to declare the level of recycled content 
applied for materials for which a recycled 
content is specified under ELV 

(2.1.5.1.4 in 
combination 
with 2.1.5.1.5) 

(2.1.5.1.10 in 
combination 
with 2.1.5.2.2) 

(2.1.5.1.3) 

2027 

3R 

2025 (existing 
platforms) or 
2027 (type 
approval 
submissions 
and/or DPP) 
2025 

ELV + 3R 

ELV+3R 

(ELV+) 3R 

(2.1.5.1.8) 

2030/2035 

Additional  details  are  given  for  the  three  policy  option  alternatives  specified  above  in  the 
following: 

•  Policy Option 2.2A: Better Compliance Option: This option includes adaptation of the 3R 
Directive  to  the  new  Type  Approval  Framework  Regulation.  This  would  include  the 
possibility to perform Conformity of Production and Market Surveillance tests for vehicles 
that have already been type approved ad put on the market. Should such tests result in a 
vehicle  being  identified  as  non-compliant,  it  would  be  possible  to require  a  recall  of  all 
vehicles of the same model put on the market for repair of for being taken out of the market 
and to sanction manufacturers up to 30,000 Euro for each non-compliant vehicle put on 
the market. In this option, the definition of types of vehicles would also be revised in order 
to  facilitate  application  of  the  requirements  and  a  declaration  of  the  manufacturer  that 
none of the hazardous materials regulated (under ELV and/or REACH) are present in the 

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vehicle.  In  relation  to  the  obligations  for  OEMS  to  provide  information  on  the  vehicle 
composition and on methods and times of dismantling, this could be performed through 
existing  platforms  like  IDIS  or  RMI  or  through  the  development  of  a  digital  product 
passport  and  shall  be  discussed  in  more  detail  in  the  impact  assessment  of  these 
measures.  

•  Policy Option 2.2B: Better Compliance + Circularity strategy: Aside from the measures 
included under Policy option 2.2.A, this alternative also includes a measure for OEMS to 
submit a circularity strategy and revise it on a bi-annual basis.  

•  Policy Option 2.2.C: Better Compliance + Circularity strategy+ minimum levels of recycled 
content:  Aside  from  the  measures  included  under  Policy  option  2.2.A  ad  2.2.B,  this 
alternative  also  includes  a  declaration  obligation  on  the  content  of  recycled  content,  in 
particular in alignment with ELV measures specifying a minimum recycled content target 
for  specific  materials  (e.g.  plastics).  The  information  of  the  percentages  of  recycled 
materials  achieved  in  line  with  obligatory  targets,  would  also  be  included  in  the 
Environmental Vehicle Passport, already foreseen in the Euro 7 Regulation proposal as 
a measure to inform consumers of the circularity of vehicles. It includes a declaration of 
the manufacturer  of  all the  percentages  of recycled  materials  present  in a  new vehicle 
type. 

These  measures  will  be  assessed  separately  at  vehicle  level  and  are  only  considered 
supporting measures, facilitating the implementation and compliance with other measures but 
not having a significant impact when implemented independently.  

Measure 2.1.e (section 2.1.5.1.5) has a direct relation on the use of non-recyclable materials 
in  vehicles  and  will  be  assessed  at  material  level  in  this  respect  in  relation  to  “non-
recyclables”. 

3.1.2.2.3  Policy  Options 

2.3:  Waste  management 

improvements to increase recycling and reuse: 

Life-cycle stage: EOL (end-of-pipe) 

Focus: vehicle, parts, materials  

Objective: improve reuse and recycling of the vehicle, it’s components and materials. 

End-of-life  oriented  sub-options  aim  at  improving  the  quantities  and  qualities  of  reuse  and 
recycling through requiring waste management operators to comply with certain practices, to 
achieve  certain  targets  and  in  some  cases  to  align  technologies  with  minimum  standards. 
These can have a direct effect on the practice of waste management, sometimes being very 
rigid and sometimes leaving more flexibility as to how an objective is to be achieved. 

Policy option 2.3 includes the following measures:  

Title 

2.4.a) Align definition of ‘recycling’ with the WFD 
2.4.f) Revision of Commission Decision 
2005/293/EC on the circularity aspects 

2.1.c) Obligation for OEMs to develop and 
implement a circularity strategy for increasing the 
circularity of vehicles 
2.4.b) Making it mandatory to remove certain 
parts/components before shredding to encourage 
their Reuse and recycling 
2.4.c) Set material-specific recycling targets for a 
selection of materials  
in combination with 

Implemented via: 

ELV 

ELV 

ELV 

Chapter 

2.1.5.4.1 
2.1.5.3.6 

(2.1.5.1.3 
2.1.5.4.2) 

Effective 
by 
2025 

variable 
2025 

2.1.5.4.3 in 
combination with 
2.1.5.4.5 

2030 
(monitoring 
point by 2027) 

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Title 

2.4.e) Increase (?) current re-use and recycling 
targets and/or ban disposal or landfilling of waste 
from ELVs  
2.3.f) Set up a separate (monitoring) target for re-
use/preparing for re-use/remanufacturing  
in combination with 
2.3.e) Establish provisions to support the market 
of used spare parts 
2.4.d) Regulate shredder/post shredder facilities to  
2.3.a) Clarify definition of re-use in the ELV 
Directive vs re-use and preparing for re-use in the 
Waste Framework Directive  
in combination with  
2.3.b) Introduce a definition of remanufacturing 
and specific provisions to support 
remanufacturing 

Chapter 

Effective 
by 
2030 

Implemented via: 

2.1.5.3.6 in 
combination with 
2.1.5.3.5 

2.1.5.4.4 
2.1.5.3.1 in 
combination with 
2.1.5.3.2 

2027 

ELV 

2027 
Variable 
2025 

ELV 
ELV 

The effectiveness of most measures is often dependent on the specific material or component 
in focus and its current status of reuse and recycling. For each material, the combination of 
measures that will be the most effective in improving reuse and/or recycling will differ based 
on the specificities of that material. In this sense, the compilation of measures analysed for 
each material/component group is specified in the next section. 

3.1.2.3  Specification of the options at material and vehicle level 

The options described above remain at the general level, prescribing which measures are to 
be applied under which option, but without clarifying how this would apply to specific materials 
or  to  the  vehicle  as  a  whole.  However,  for  some  materials,  some  measures  will  be  more 
effective than others whereas some measures may have a low viability. For this purpose, a 
second stage is applied to specify a set of viable measures for each material, which will be 
the focus of the assessment of impacts that follows. This stage also clarifies which measures 
shall be analysed at the material level, whereas the general analysis will then be based on a 
compilation of the material specific costs and benefits, and which measures shall be analysed 
at  the  vehicle  level.  Thus,  the  following  table  specifies  the  measures  to  be  considered  for 
each material as well as the set of measures to be assessed only at vehicle level. It is also 
specified how other areas will be linked into the assessment. The table uses a colour code to 
clarify (for each material and at vehicle level): which measures will be reviewed in detail as 
they are considered viable and are expected to result in significant benefits and which are 
discarded at this stage for various reasons (detailed). 

Steel 

Aluminium 

Copper 

Plastic 

Glass 

2.1.c: 
strategy  

Circularity 

2.1.f:  Incompatibility 
reporting 

Recycled 

2.1.g: 
content target 
2.2.e: Promote reuse 
market  

Reuse 
2.2.f: 
monitoring 
(& 
component  specific 
targets) 
2.3.a:  Exclusion  of 
backfilling 

x 

x 

x 

x 

x  
(e.g., engines) 

x** 

239 

x 

x 

x  
premature 

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Mandatory 

Material 
recycling 
(calculation 

2.3.b: 
dismantling 
2.3.c: 
specific 
target 
point) 
2.3.d: 
shredder/post 
shredder 
2.3.e:  Ban  disposal 
of waste  

Regulate 

2.1.c: 
strategy 

Circularity 

2.1.f: Incompatibility 
reporting 

2.1.g: 
content target 
2.2.e: 
reuse market 

Recycled 

Promote 

Mandatory 

Reuse 
2.2.f: 
monitoring 
(& 
component  specific 
targets) 
2.3.a:  Exclusion  of 
backfilling 
2.3.b: 
dismantling 
2.3.c: 
specific 
target 
point) 
2.3.d: 
shredder/post 
shredder 

Material 
recycling 
(calculation 

Regulate 

x 

x 

x (to increase 
separation of 
non-
recyclables) 

2.3.e:  Ban  disposal 
of waste 

x 

Steel 

Aluminium 

Copper 

Plastic 

Glass 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x (to reduce 
copper content) 

x (to allow alloy 
separation and 
reduce losses) 

x (to reduce 
copper losses) 

(to 

x 
increase 
of 
separation 
individual  polymers 
and reduce losses) 

Non-
(established) 
recyclables 

Rubber - 
Premature 

Textiles - 
Premature 

CRMs 
(including 
NdFeB 
magnets)* 

EEC 

Vehicle 
level 

x 

x 

x 

x 

x 

x 

x 

x 

(x) 

x 

x 

x 

x 

x 

(x) 

(x) 

x 

x (to 
increase 
separation 
of rubber 
and reduce 
losses) 
x 

x (to increase 
separation of 
textile and 
reduce losses) 

x 

x 

x 

x 

x 

x (and 
increase 
(?) of 
targets) 

Originally, it was considered to set material specific targets for textiles and rubber. After in-
depth  analysis  of  the  current  situation  2.1.2.5,  it  is  recommended  not  to  include  these 
materials at present. It is expected that the alignment of the recycling definition of the ELVD 
with the WFD together with the harmonisation of reporting (e.g., not allowing materials used 
for  road  surfacing  in  landfills  or  for  filling  underground  mines  to  be  accounted  for  in  the 
reporting as recycling) and the ban of disposal or landfilling (measure described under section 

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2.1.5.4.5)  will  require  the  development  of  recycling  technologies  for  these  materials  (e.g., 
chemical  recycling)  to  ensure  an  alternative  manner  for  their  recycling.  It  cannot  yet  be 
estimated how such developments will change the recyclability of these materials over time 
and what measures could be suitable to improve the level of recycling.  

The feasibility of setting up targets for REE and CRM materials is unclear at this stage. For 
PGM, particularly those included in the catalytic converter, collection and recycling is already 
very high. For REE, though a few recycling technologies exist, capacities are not available in 
the  EU.  It  is  also  not  clear  when  the  amount  of  relevant  collected  fractions  (e.g.,  NdFeB 
magnets) from ELVs would justify the realisation of such capacities. The feasibility of such 
target(s)  will  be  analysed  by  JRC  in  the  coming  months,  therefore  in  this  study  the 
consideration of a target for, i.e., neodymium magnets will not be assessed in detail.  

The assessment of a recycled content target for plastic has been performed by the JRC and 
is documented in a separate report. The current assessment will summarise relevant results 
to ensure a comparison to the other measures to be assessed can be established but will not 
revise the assessment nor reproduce it in its entirety.  

Measures  relating  to  definitions  and  reporting  are  for  the  most  part  considered  to  be 
supportive in nature to the implementation of the other measures. They will be assessed for 
the most part on a qualitative basis but will only be discussed in detail where their individual 
application could result in an improvement of the level of recycling of a certain material (i.e., 
glass and alignment to the WFD recycling definition). 

Looking at the various measures in the impact assessment in a communal way would require 
either  a  simplification  of  impacts  (risking  high  uncertainties)  or  developing  a  very  complex 
modelling system to allow consideration of impacts on different materials in parallel. This is 
related  to  different  materials  having  different  problems  in  the  current  situation  and  thus 
needing to be considered differently for each measure. To first allow addressing the current 
situation  of  each  material  differently  (and  in  one  case  a  component  group),  the  various 
measures are analysed at material level to allow concluding in each case which measures 
are more appropriate in the context of the specific material at hand. After an initial analysis, 
scenarios  are  drawn  at  material  level,  allowing  an  understanding  of  how  the  relevant 
scenarios affect each material. This allows making assumptions as to the amount of material 
in specific components or in the vehicle in general as to what treatment routes will apply under 
each scenario for the material stream. Subsequently this later allows compiling the analysis 
at vehicle level to understand how materials are differently affected when measures for reuse 
and recycling measure are applied to the vehicle as a whole. 

Thus,  in  the  next  sections,  the  analysis  of  different  measures  is  applied  in  some  cases  at 
vehicle level and in others at the material level. The first section looks at the general design 
measures at vehicle level. Still related to design, in the next sections the impacts of different 
measure are analysed for non-recyclable materials, making a link in the scenarios between 
design  and  waste  management  to  show  how  the  type  approval  of  vehicles  can  affect  the 
number of non-recyclables that later need to be dealt with at EoL through other measures. 
As the last section on design, the analysis of measures on hazardous substances in vehicles 
follows,  which  are  looked  at  more  broadly  due  to  the  nature  of  the  measures  at  hand.  To 
understand the measures developed for reuse and recycling, but also for recycled content, 
the next sections analyse measures from the material perspective for: steel and copper, which 
have some interrelations, aluminium, glass and plastic and finally EEC on the basis of their 
contents of precious and critical materials. The material level analysis allows the specification 
of each measure for the different materials (i.e., which component is it relevant to dismantle 
to address specific materials) but also in what cases materials can be excluded from a certain 
measure (e.g., for which materials should recycling targets be considered and at what level 
in  each  case.  This  data  is  then  gathered  in  the  following  analysis  at  the  vehicle  level  that 

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allows  integrating  the  specifications  and  concluding  how  different  measures  will  allow 
achieving different levels of reuse and recycling in the various scenarios and what this means 
for recovery and for process inefficiencies.  

How the EPR measures (see section 2.3.5) shall link to the measures addressed in this part 
will  be  assessed  as  necessary  at the  material  level  (e.g.,  materials  the treatment  of  which 
could require compensations) and/or vehicle level (e.g., training of ATFs) at the end of the 
specific section. 

Finally, a compilation will be provided for policy options constructed at vehicle level to allow 
compiling  the  various  impacts  and  to  compare  this  with  measures  developed  under  other 
chapters. 

3.1.3  Method of analysis applied 

In the following sections, as explained above, separate analysis’ are presented. A first section 
refers  to  analysis  of  measures  in  design.  Most  measures  are  analysed  at  vehicle  level, 
including  in  the  policy  option  on  hazardous  substances  and  this  is  complemented  with  a 
material  level  analysis  for  non-recyclables.  The  second  section  focuses  on  the  end-of-life 
stage and begins with separate analysis of specific measures at material level. This includes 
separate  sections  for  steel,  copper,  aluminium,  glass,  plastic  and  EEC  which  is  actually  a 
component  level  analysis,  however  related  to  these  components  being  rich  in  various 
precious and critical metals. The material analysis often looks at an example component at 
least in part in order to allow better quantification of costs. Thus, the material/component level 
sections are followed by a last analysis at vehicle level or the reuse and recycling measures 
that sheds light on impacts at this level. 

The  sections  are  structured  as  follows.  They  begin  with  a  listing  of  measures  identified  in 
section 3.1.2.3 as relevant for analysis at material and/or vehicle level. In an initial analysis it 
is  explained  why  the  analysis  focuses  on  the  assessment  of  some  of  the  measures  and 
discards  other.  This  is  followed  by  a  section  in  which  the  baseline  for  comparison  is 
characterised as well as the scenarios for assessment. These often refer to a single measure, 
however  in  a  few  cases  combinations  are  also  propose,  explaining  the  grounds  for  such 
grouping. A qualitative analysis is specified to already pint to the main impacts and expected 
results.  A  quantitative  analysis  then  follows,  which  begins  with  a  presentation  of  initial 
assumptions  for  the  assessment. In  this section,  it  is  often  specified for the  component  or 
material  flow  under  investigation,  which  shares  have  been  assumed  in  the  analysis  to 
calculate material flows. Then impacts are presented for the environment, economic impacts 
and social impacts. The section concludes with a comparison of the various costs and benefits 
and some initial conclusions. Where relevant EPR considerations are discussed, followed by 
a proposal of the scenarios to be included for the final analysis of the preferred option. 

The analysis is based on data collected from various sources. To calculate impacts in most 
cases the model described in annex I 6.9 is applied. Data on the composition of a specific 
components  or  a  material  in  the  vehicle  is  used  as  a  basis  to  calculate  material  flows  at 
component  or  vehicle  level.  On  this  basis  and  with  the  use  of  LCA  data,  environmental 
impacts are calculated for global warming potential. Furthermore, where data is available, the 
material  flows  are  applied  to  calculate  cost  related  to  revenues  from  sales  of  secondary 
materials  and  related  dismantling  costs  which  also  allow  some  assumptions  as  to  social 
impacts  (impacts  on  employment).  Other  impacts  are  presented  based  on  date  from  the 
literature or stakeholder statements with a view to quantification of impacts where possible. 

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3.1.4  Analysis  of  measures  on 

the  design  of  vehicles  and 

preparation for their being put on the market (vehicle level) 

Three alternative options were shortlisted for improving the design of vehicle with a view to 
increase recyclability and reusability, including the following measures: 

Chapter 

(2.1.5.1.4 in 
combination with 
2.1.5.1.5) 

Title 

Adaptation of the 3R Directive to the new Type approval Framework Regulation +  
Proper definition of types of vehicles +  
2.1.d) Provisions for improving the relation between the 3R Type approval process and 
ELV waste management performance. + 2.1.e) Option for OEMs to submit life cycle data 
as part of the 3R type approval process to justify the use of materials where recycling is 
not yet established+ 

The manufacture of vehicles and vehicle components makes use of numerous materials of 
both primary and secondary nature. Some of these are sourced from countries (outside the 
EU) where the local governing conditions and/or the level of performance of mining and 
processing facilities may not ensure the provision of human rights, the health of workers 
and/or  of  nearby  residents,  or  the  prevention  of  adverse  impacts  on  the  environment. 
Where the manufacture of vehicles has a high dependency on material sourcing from such 
countries, this can contribute to adverse impacts on society and on human health and the 
environmental.  To  prevent  such  impacts,  vehicle  manufacturers  could  be  required  to 
perform due diligence when sourcing materials to produce vehicles and their components 
from high- risk countries. This can be related either to primary materials that are sourced 
from conflict-affected or high-risk areas or to secondary materials sourced from countries 
that do not ensure a minimum level of environmental performance and/or of minimum social 
working conditions.  

At horizontal level, in relation to the sourcing of minerals from conflict-affected or high-risk 
areas, Regulation 2017/821/EU lays down supply chain due diligence obligations for Union 
importers of tin, tantalum and tungsten, their ores, and gold originating from such areas. 
The  sourcing  of  e.g.,  tin,  tungsten,  tantalum,  niobium  and  gold  minerals  and  metals  for 
vehicle  manufacture  would  be  addressed  through  this  Regulation,  making  an  ELV 
obligation redundant. 

In some cases, there may be other materials used in vehicles sourced from countries that 
do not ensure that the sourcing and processing of such materials is environmentally and 
socially sound. For such cases, due diligence obligations could be included in the Directive, 
similar  to  those  currently  proposed  for  the  new  regulatory  framework  for  batteries.  This 
would include a provision, laying down obligations for OEMs to perform due diligence on 
the  supply  of  certain  materials  (primary  and  secondary),  and  to  declare  on  the  risk  of 
occurrence of adverse impacts and on strategies for their mitigation. Declarations on such 
actions, including third party verification would need to be made available to authorities as 
part of the type-approval process and for MS inspections. A list of materials (e.g., REE) for 
which this is to be obligatory would be included in the future legislation for vehicles, also 
specifying thresholds for each material as to the amount of use contained in a vehicle above 
which the obligation would comply. The annex would be updated continuously, in relation 
to the thresholds and if necessary, also as to the materials specified therein.  

There is also a need to consider the requirements set out in the Corporate Sustainability 
Due Diligence Directive. The CSDD is a horizontal legislation that focusses more 
generally on the behaviour of companies and addresses the entire value chain for all 
goods and services. It will implement the due diligence requirements of the proposed 
Batteries regulation by introducing a value chain due diligence related to raw materials 
(and goods and services) that are not covered in the Batteries Regulation. Both build on 
the OECD due diligence guidance, making implementation coherent.  
Expected outcome: It is currently not clear which materials could be addressed through a 
due diligence obligation to be included in the future ELV legislation. Materials addressed 
under other legislation (or in focus of future sectoral legislation such as the Batteries 
Regulation) are not used in large amounts in vehicles.  
In parallel, the European Commission has published a tender to review the functioning of 
Regulation 2017/821/EU, which towards 2026 could both lead to adaptations in future 
due diligence requirements as well as in the materials for which such requirements are 
necessary.  

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Title 

2.1.i) Set out an obligation for OEMS to provide additional information on composition of 
cars+ 2.2.b: Improved communication on hazardous substances in the automotive value 
chain 

In addition to the measures included under 2.2.a, the following measure is also included: 
2.1.c) Obligation for OEMs to develop and implement a circularity strategy for increasing 
the circularity of vehicles 

In addition to the measures included under 2.2.a, an information obligation would also be 
introduced in the form of an obligation to declare the level of recycled content applied for 
materials for which a recycled content is specified under ELV 

Chapter 

(2.1.5.1.10 in 
combination with 
2.1.5.2.2) 

(2.1.5.1.3) 

(2.1.5.1.8) 

Colour code: Red – discarded, Yellow – premature, Grey – supporting measure 

All  of the  proposed  measures  are  considered  to be  feasible  (aside from  inclusion  of multi-
stage vehicles under type approval already discarded above for passenger cars and thus not 
discussed here again). In this sense, all measures are to be assessed in the sections that 
follow and detail is here is provided on the main objectives to be achieved and on how the 
assessment is structured. 

•  Revisions  to  be  performed  to  the  3R  Type-approval  (2.1.d)  in  combination  with  the 
obligation in some cases to submit life cycle data (measure 2.1.e) are expected to assist 
type approval authorities in distinguishing between vehicles that can be type approved 
and those that should not. This has to do with the way that the type approval process, and 
in particular the calculation of the 3Rs reflects the actual ability of achieving the targets at 
EoL. Though it is not considered that the new calculation method shall allow to forecast 
the future, however materials with low recyclability or with a low recycling efficiency will 
be better reflected in the calculation. Where this will then show that the targets cannot be 
met,  this  will  lead  to  type  approval  rejections  in  the  short  term  and  to  vehicles  being 
designed in a more circular way in the mid-to long term. In relation to materials considered 
to be non-recyclable at the time of the type approval, measure 2.1.e shall only allow use 
of  such  materials  in  large  volumes  when  it  is  proven  that  this  reduces  the  total 
environmental impacts of a vehicle. Where this is not the case, the use of such materials 
shall be limited, thus also increasing the circularity of the vehicle fleet over time. This latter 
measure is investigated separately at material level under section 3.1.4.7.1. 

•  Measure relating to the provision of information build on existing provisions in the ELVD 
(2.1.2.5.10 in combination with 2.1.5.2.2). Though OEMs are already obliged to provide 
data  to  ATFs  to  facilitate  waste  management,  it  is  observed  that  data  is  not  always 
sufficiently available. The measures proposed thus aim at improving harmonisation and 
accessibility to data that would support the dismantling of components and materials and 
a more circular waste management.  

•  The measure for developing a circularity strategy (2.1.c) is not expected to directly affect 
the type approval of individual vehicle types. It rather only serves the purpose of ensuring 
that the OEM has a strategy in place to improve circularity over time. Though information 
is to be specified in some cases also at vehicle level, it would not necessarily affect actual 
type approvals which shall be decided on case by case in light of the compliance of the 
OEM with the obligations specified for the design of the vehicle in the 3R legislation and/or 
in  the  ELV  legislation.  Nonetheless,  it  will  allow  the  authorities  to  observe  progress  of 
OEMs  in  increasing  the  circularity  of  vehicles  and  could  lead  in  the  long  term  to 
introduction  of  additional  provisions  where  efforts  are  not  observed  to  be  far  reaching 
enough. 

•  Measures requiring a declaration on the level of recycled content in specific vehicles are 
only relevant in cases that including a minimum rate of recycled content (i.e. achieving a 
target) is obligatory, though where a target is under consideration or to come into force in 

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the future, it could also be useful to observe the development of the sector in this area. 
Though  the  declaration  could  trigger  some  additional  use  of  recycled  content,  this  is 
considered marginal if a mandatory target has not been set. The differing impact in this 
case can be seen in the material level assessment for plastics, where recycled content 
level  obligations  are  under consideration (see  section  3.1.9.1).  In this  section,  only  the 
costs related to providing such declarations are taken into consideration.  

3.1.4.1  Scenarios for quantitative analysis  

At  present  the  type-approval  does  not  facilitate  the  provision  of  information  on  the  vehicle 
composition to ATFs. Though in theory, the 3R Directive requires OEMs to submit a strategy 
“to ensure dismantling, reuse of component parts, recycling and recovery of materials”, such 
strategies are quite general in nature and data on dismantling is provided to ATFs through 
IDIS, though not addressing all components and materials for which such data would support 
circularity. 

More  importantly,  though,  the  3R  type  approval requires OEMS to  show  how  they  comply 
with the 3Rs, the calculation for showing this and information provided during the practical 
application of the 3R process of type-approval does not reflect whether parts can be reused 
nor  how this  affects the achievability  of  the  targets.  As there  was  no monitoring  of  the  3R 
Type-approval process and results in relation to the actual fulfilment of targets at EoL in the 
past,  it  cannot  be  said  to  what  degree  granted  3R  type-approvals  reflect  the  actual 
achievement of the 3Rs at EoL, however the fact that recyclable materials are accounted for 
as 100% recycling, ignoring any material losses, suggests that the format and process are 
not fit for purpose, particularly with the expected development towards vehicle light-weighting 
which shall increase the use of materials with no or less established recycling. Similarly, the 
fact that a material with a TRL above 4 is currently considered as 100% recycled at EoL, but 
does not necessarily reach this level at EoL, suggests that the calculation is not sufficiently 
reflective of EoL. 

3.1.4.1.1  Baseline 

The 3R Type-approval Directive and process remain the same, with the result that over time 
more vehicles are placed on the market that cannot fulfil the 3R targets at EoL: 

• 

• 

In  some  cases,  this  is  related  to  the  use  of  non-recyclable  materials  that  will  not  be 
recyclable at EoL and could affect the general fulfilment of the targets at MS level. This is 
for  example  currently  the  case  with  vehicles  that  use  large  amounts  of  carbon  fibre 
reinforced plastics, which is looked into separately under section 3.1.9.1. 
In other cases, this is a result of certain materials being considered as 100% recyclable 
but being downcycled (e.g., glass) or used in large amounts for recovery (e.g., rubbers, 
plastics). With the increased use of plastics expected for light-weighting, this could lead 
to the  current  level  of  85% recycling  not  being achieved  over  time.  In  particular,  in the 
short term, with the expected increase in electric vehicles in the vehicle fleet, the fact that 
Li-Ion batteries, accounting for a significant weight of the vehicle, and still far from being 
100% recycled, will make achieving the targets increasingly more difficult.  

It is assumed that this is already the case today for a small number of vehicles, however, that 
in the older fleet vehicles using e.g., non-recyclables, large quantities of plastics and Li-Ion 
traction batteries are still rare. This means that vehicles fulfilling and going beyond the targets 
dominate the vehicles arriving at EoL and can still compensate for those that do not. By 2035, 
more vehicles with e.g., high volumes of non-recyclable materials, large amounts of plastics 
and  Li-Ion  traction  batteries  shall  reach  EoL  and  for  the  comparison  with  other  scenarios, 
these are assumed to result in only 70% reuse and recycling being achieved at vehicle level 

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(based on new calculation point concept). To substantiate this, Figure 3-22 shows an analysis 
of  the  amounts  assumed  to  be  recycled,  reused,  recovered  and  “lost  due  to  process 
inefficiencies” in 2035 of all collected ELVs in the baseline, suggesting that around 18% of all 
materials in the fleet would be “lost” and 9% recovered.  

The new type-approval Regulation (EU) 2018/858 which applies since 1 September 2020 and 
introduces  the  specific  rules  on  market  surveillance  activities  applicable  to  automotive 
products.  Article  8  of  Regulation  (EU)  2018/858  sets  out  the  obligations  for  market 
surveillance  authorities.  It  includes  a  minimum  requirement  for  the  number  of  tests  to  be 
carried out by market surveillance authorities in each Member State, requiring one test for 
every 40,000 motor vehicles registered in the MS during the previous year and no less than 
5  tests  per  MS.  20%  of  the  tests  carried  out  are  required  to  be  emissions  tests.  The 
Commission  also  now  has  the  capacity  of  carrying  out  test  and  inspections  to  verify  the 
compliance of vehicles, systems, components and separate technical units.202 

However, there is no specification as to the focus of market surveillance tests other than those 
carried out regarding emissions and thus, it is unclear how many activities will be focused on 
the 3R Type approval and its correlation with actual fulfilment of the 3R targets at EoL without 
this being specified as a necessity, e.g., in the 3R Directive. The same is true regarding the 
EC’s  capacity  to  carry  out  inspections  of  vehicles,  though  here  with  the  increased 
understanding that the 3R Directive may not be sufficiently effective, some inspections could 
be expected. However, without a change of legal obligations, it is not clear how these could 
contribute to improving the situation in the baseline.  

As there are no provisions in the Directive requiring manufacturers to take action to increase 
circularity, such activities will continue to take place at small scale on a voluntary basis but 
will not result in significant benefits in vehicles put on the market until 2035. 

As  for  provision  of  information,  OEMs  will  continue  to  use  IDIS  to  provide  ATFs  with 
information on the localisation and methods for dismantling components with depollution or 
dismantling  obligations  specified  under  Annex  I  of  the  directive.  However,  obligations  only 
refer to a small number of components and are in some cases vague (e.g., plastic treatment, 
weight  of  Al  or  plastic  parts  that  need  to  be  dismantled).  Information  on  dismantling  of 
components  for  the  purpose  of  reuse  and  digital  keys  for  enabling  dismantling  and  re-
installation  of  locked  components,  shall  only  be  provided  through  RMI  data,  with  only  few 
ATFs making use of such data due to the low level of harmonisation and the cost of data. In 
result, the level of reuse shall remain low (assumed 8% in 2035, see Figure 3-22) and the 
quality of recycling may also not reach its full potential for some materials. Information on the 
use of hazardous substances in different components is provided to the SCIP data base in a 
format considered to be impractical for the use of waste management operators. Though data 
on the use of hazardous substances and CRMs in supplier components is understood to be 
available to OEMs in the IMDS system, it is not available to waste management operators, 
and this would not be expected to change in the baseline.  

3.1.4.1.2  Scenario Design 1: Better compliance option 

The 3R Type-approval directive is to be aligned with the type-approval framework Regulation 
(EU) 2018/858. This will lead to general coherence but will also allow ensuring that a minimum 
of  market  surveillance  tests  performed  will  be  focused  on  3R  Type  approval  aspects.  It  is 
assumed that this would concern at least 1 test per MS per year.  

202 Personal communication with DG GROW from 19.08.2022. 

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In addition, the Commission will use its capabilities to perform dismantling tests of 5 newly 
approved vehicle types put on the market in each year, with the objective of checking to what 
degree they can be dismantled in reasonable time in a way that supports a higher reuse rate 
and  a  higher  level  of  high-quality  recycling.  Both  market  surveillance  activities  and  EC 
dismantling  and  shredding  tests,  will  contribute  to  a  better  understanding  of  vehicle 
composition that can achieve the 3R targets at EoL. In consequence, however, some vehicles 
may be identified that do not sufficiently comply with the 3R Directive and ELVD provisions 
and this may lead to a need to recall such vehicles, replacing them with complying ones, also 
sanctioning the respective OEM with up to 30,000 Euro for each non-compliant vehicle.  

The definition of “vehicle type” will be revised, ensuring that any provisions that affect vehicle 
design or communication on vehicle composition shall be implementable at the vehicle type 
level. This will ensure that e.g., information on components with a dismantling obligation or 
potential  and  on  components  containing  hazardous  substances  will  be  made  available  as 
required by the legislation at vehicle level. 

The 3R Type-approval procedure shall be changed to be more specific and better match with 
the reality of how materials in vehicles can be recycled, re-used or remanufactured. To show 
that a vehicle submitted for type approval can fulfil the 3R targets, OEMs will need to: 

•  change the design of vehicles to include at least 85% of materials with a TRL above 9, 

excluding losses related to tyres, and/or 

•  change vehicle design to ensure a higher dismantlability of components with dismantling 
obligations  or  a  high  potential  for  reuse  and  high-quality  recycling  when  recycled 
separately (without undergoing shredder operations), and/or 

•  ensure that materials used in volumes above 10 kg with a TRL of 8 and below contribute 

to the vehicle’s environmental performance  

In this sense, the recyclability and reusability of a vehicle can be expected to increase and 
ensure that the rates of reuse and recycling will increase in comparison to the baseline. For 
the purpose of comparison and based on the analysis of reuse and recycling measures at 
vehicle level, this is assumed to result in at least 74% reuse and recycling being achieved at 
vehicle  level  (based  on  the  new  calculation  point  concept).  This  level  is  assumed  in  the 
analysis at vehicle level in the case that all provisions are applied, however not taking into 
consideration  the  impact  of  a  revision  of  the  3R  Directive  and  better  access  to  data.  It  is 
possible that the measures included under the vehicle design scenarios would increase the 
reusability and recyclability of vehicles a bit further, though there is no data to allow this to be 
quantified.  

This scenario would also require manufacturers to provide more information on the vehicle 
composition, including data on the dismantlability of components with a potential for reuse 
and/or  recycling  (dismantling  method  and  time).  As  part  of  the  process,  OEMS  are  to  be 
required to provide: 

• 

the EPR scheme with data necessary for fee modulation (e.g., on components for which 
the preferable treatment route is slightly below economic feasibility),  

•  dismantlers with data on the dismantling of materials and components with a depollution 
obligation (annex I(3) of ELVD), with a dismantling obligation (annex I(4) of ELVD), or with 
a reporting obligation due to the potential for reuse (to be included as part of annex I or in 
a new annex) - free of cost and in a harmonised manner), 

•  dismantlers  with  data  to  unlock  and  enable  reuse  of  parts  with  a  digital–key  -  at  a 

reasonable cost and in a harmonised manner, 

•  dismantlers with data on component interchangeability between models and brands, to 
allow  maximising  reuse  of  components  -  at  a  reasonable  cost  and  in  a  harmonised 
manner, 

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•  dismantlers upon request with data on the location and content of hazardous substances 

in specific components of specific vehicle models. 

To  facilitate  the  provision  of  data,  OEMs  could  decide  to  use  existing  or  new  web-based 
platforms or to develop a digital product passport. If IDIS is used, it is assumed that it shall 
be  harmonised  further,  following  exchange  with  ATFs  to  ensure  that  it  shall  later  enjoy  a 
higher acceptability and usability (at least 10,000 of the 12,000 ATFs operating in the EU). In 
this  case,  IDIS  would  be  assumed  to  be  used  for  all  information  that  needs  to  be  made 
available without costs to ATFs. If the RMI platforms shall be used, this is assumed to only 
be  applied  for  information  that  can  be  provided  to  ATFs  at  a  “reasonable  cost  and  in  a 
harmonised  way”203.  The  vehicle  sector  is  currently  working  on  a  vehicle  digital  product 
passport204  and  could  decide  to  develop  it  further  to  also  cover  such  information  in  this 
initiative. For compliance, provision of data shall be considered fulfilled when access is given 
to the authority through the same method that it will be made available to dismantlers and the 
EPR: e.g., a web-platform (like IDIS) or a digital product passport so that the availability of 
the data, its accessibility to certain actors and its level of harmonisation can be ensured.  

In addition, OEMs will be required to perform a dismantling and shredding test on a vehicle 
(prototype) as part of the type approval process of each type. Documentation on the results 
of this test shall be submitted together with an application for type approval. It is assumed 
that only vehicles for which the test supports that waste management will allow achieving the 
target shall be submitted to type approval, however the available data will enable the EPR 
schemes to develop fee modulation if necessary for vehicles. In parallel, it can be assumed 
that particularly in the first years of implementation, that OEMs may in some cases have a 
dismantling  and  shredding  test  performed  on  a vehicle  (prototype),  with the result  that the 
vehicle designed is revised prior to 3R type approval. To consider such cases, it is assumed 
that in 2035 for every 4 vehicle’s types submitted to type approval, at least one will have had 
a dismantling and shredding test performed twice. 

3.1.4.1.3  Scenario Design 2: Better Compliance + Circularity 

strategy 

In  addition  to  the  measures  addressed  under  scenario  Design  1,  OEMs  will  be  obliged  to 
submit a circularity strategy every 5 years that refers to minimum reporting requirements set 
forth in an annex of the ELVD. This could require specification of the state of certain elements 
(e.g.,  use  of  recycled  content  –  see  detail  in  measure  description).  The  ambition  of  the 
minimum  information  requirements  could  change  with  time,  requiring  certain  targets  or 
actions to be fulfilled within a certain duration. 
In  principle, though the proposed  circularity  strategy  is  to replace  the  current  strategy that 
OEMS  must  submit  in  line  with  3R  Directive  Article  6(3),  the  requirements  will  be  more 
stringent  and  thus  it  is  anticipated  that  OEMS  will  need  to  review  their  existing  strategies 

203 From a personal communication with DG GROW from 19.8.2022, it is understood that in accordance with Article 63 of 
Regulation (EU) 2018/858, a manufacturer may charge reasonable and proportionate fees for access to vehicle repair and 
maintenance information which shall not discourage access to such information by failing to take into account the extent to 
which the independent operator uses it. Delegated Regulation (EU) 2021/1244 amends Annex X to Regulation (EU) 
2018/858 and introduces a reference to standard EN ISO 18541 ‘Road vehicles – Standardized access to automotive repair 
and maintenance information (RMI)’ with the aim of facilitating the exchange between manufacturers and independent 
operators of vehicle RMI by establishing the technical requirements and procedures for access to that information. Even 
though, that Regulation will only apply 30 July 2023, it is already an indication of the requirements that manufactures will 
need to follow by that date and lcarifies that despite efforts towards harmonisation, there will not be a single database but 
rather a standardised way that manufacturers need to comply with for their databases. 

204 See: https://catena-x.net/en/, last accessed 4.9.2022  

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significantly to ensure provision of required information at fleet and vehicle level. This will be 
more of an effort the first time the strategy is submitted but will also need to be updated bi-
annually, meaning an additional effort, where at present the strategies are understood not to 
be updated so often.  
In terms of the information that the strategy is to include, type approval authorities that shall 
review the strategies as part of the type approval process will obtain a better overview as to 
how vehicles are assembled to ensure dismantlability. This will feed into the review of type 
approval submissions in relation to data provided for components that are dismantled form 
the vehicle.  

3.1.4.1.4  Scenario Design 3: Better Compliance + Circularity 

strategy+ minimum levels of recycled content 

In  addition  to  the  measures  addressed  under  scenario  Design  2,  OEMs  will  be  obliged  to 
provide a declaration, i.e., report on the rate of use of recycled content from all content used 
of a specific material. Under the current assessment, this will require the declaration of the 
rate of recycled plastic from all plastic used in a vehicle submitted to type approval. Depending 
on  other  measures  to  be  implemented,  should  a  minimum  target  be  introduced  as  to  the 
minimum  recycled  content  rate,  the  declaration  would  also  be  considered  for  the  general 
compliance of the vehicle with design requirements and for its 3R type approval. 

3.1.4.2  Results of qualitative analysis  

Scenario Design 1 is aimed at increasing the effectiveness of the type-approval process in 
ensuring  that  the  3R  Targets  are  achievable  by  vehicles  placed  on  the  market  and  that 
sufficient  data  is  available  to  ATFs  to  allow  components  to  be  dismantled  that  have  been 
intended  for  such  operations  in  their  design.  Additionally,  the  measures  are  designed  to 
ensure that reuse is covered more adequately by the 3R Type-approval, removing obstacles 
to reuse for components.  

The  data  that  is  to  be  provided  by  OEMs  is  already  known  and  some  of  it  is  provided  to 
existing platforms like IDIS or RMI individual manufacture platforms. However, in the baseline: 

• 

• 

• 

• 

information made available on parts with depollution or dismantling obligations can still 
lack detail of importance for dismantling and is presented in a less harmonised way which 
discourages ATFs from using such data, 
information made available on parts with a reuse potential is provided in the RMI individual 
platforms  at  a  cost  that  decreases  per  use,  discouraging  ATFs  that  only  use  data 
occasionally, i.e., in particular smaller ATFs that treat vehicles of multiple brands, form 
using such data and thus also from dismantling components for reuse, 
information needed to ensure reuse of digitally locked components, is usually provided by 
OEMS on individual platforms at a cost that decreases per use, again meaning that ATFs 
that treat multiple brands will face high costs per use and in particular the smaller ones 
will be discouraged from dismantling components with digital locks and preparing them 
for reuse, 
information  on  the  interchangeability  of  components  between  models  and  brands  is 
understood  not  to  be  available  to  ATFs,  though  OEM  suppliers  will  have  data  on  the 
interchangeability of their supplied components.  

Under  all  design  scenarios  OEMs  would  be  required  to  provide  such  data  in  a  more 
harmonised  way,  either for free  (dismantling  data  for components  with  obligations)  or  at  a 
consistent  and  fair  price  (digital  keys,  interchangeability  data).  Though  it  would  be  most 

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efficient for all such data to be provided to ATFs on a single platform, it is not expected that 
the legislation would be prescriptive as to the type of platform, but rather only as to the level 
of  harmonisation  and  cost  categories  (no  cost  or  low  cost).  It  is  thus  expected  that OEMs 
would either continue to use IDIS and RMI for the data for which each platform is used today 
or would develop a digital product passport for vehicles (possibly adapting existing initiatives 
like Catena-x for this purpose).  

• 

• 

In  the  case  that  IDIS  will  continue  to  be  used  for  dismantling  data,  it  is  expected  that 
additional  harmonisation  will  be  needed,  resulting  in  an  administrative  burden. 
Nonetheless,  harmonisation  of  IDIS  data  is  understood  to  be  an  activity  in  which  the 
platform is constantly engaged and thus costs for such activities would be expected to be 
of an acceptable range. Using the platform for data on digital keys and interchangeable 
components would be convenient for ATFs, but would probably require developing new 
IT architecture, increasing the total burdens. 
In the case that RMI is used for some or all data, it would, probably be necessary to legally 
require the introduction of specific user costs for ATFs to ensure that the cost shall not 
discourage  access  to  such  information  as  required  by  Article  63  of  Regulation  (EU) 
2018/858)205. Though this may result in an administrative burden, it is not expected to be 
high as the IT architecture would probably remain similar, however OEMs may see some 
losses  in  terms  of  the  fees  that  they  currently  receive  form  ATFs  through  the  system 
(range  of  related  revenues  is  unknown).  As  RMI  data  shall  remain  available  on  OEM 
individual platforms, it is not clear if this would not on its own already discourage ATFs (in 
particular independent and smaller ones) from use of such data. 

•  Data on the interchangeability of components is understood currently not being available. 
Should OEMs be obliged to provide such data, it may be provided on either IDIS or RMI 
platforms  or  through  a  digital  product  passport.  In  any  case  provision  would  require 
developing related IT architecture, creating development costs, but would be expected to 
support more reuse of components with high interchangeability. 
Improving accessibility of data on content of hazardous substances could be addressed 
through adaptations to the SCIP or to GADSL and IMDS or through development of the 
DPP as currently contemplated under the ESPR. This is explained in more detail under 
Section 3.1.4.9 below. 

• 

•  Should a digital product passport be applied, this would be expected to have the highest 
costs, as the platform does not yet exist. Nonetheless, the fact that the automotive sector 
has already embarked on such initiatives suggests that a benefit of a mutual digital data 
base for the sector exists. Should such a system develop naturally, is assumed to indicate 
that the benefits are higher than the expected costs. Should the legislation require such 
a development, costs could be higher and would probably also be accelerated in time.  

In any case, under all design scenarios, the accessibility of data is expected to be higher than 
in the baseline and in so far to increase the rate of reuse in components where this is hindered 
at present due to lacking data on dismantling, on digital keys or on interchangeability. Data 
on  dismantling  could  also  have  a  positive  impact  on  the  rate  of  recycling,  where,  when 
performed prior to shredding operations, this results in higher quality or quantity of recycling. 

205 Currently Article 63(1) of Regulation (EU) 2018/858) allows the OEM to “charge reasonable and proportionate fees for 
access to vehicle repair and maintenance information […] Those fees shall not discourage access to such information by 
failing to take into account the extent to which the independent operator uses it”. However, paragraph 2 of the same article 
allows the OEM to “make available vehicle repair and maintenance information, including transactional services such as 
reprogramming or technical assistance, on an hourly, daily, monthly, and yearly basis, with fees for access to such 
information varying in accordance with the respective periods of time for which access is granted”. Thus the current cost 
scheme is not expected to change for ATFs without intervention and would be expected to continue to discourage use, in 
particular for small and independent ATFs. 

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This could be the case for components and materials for which dismantling obligations do not 
exist but also for components with a reuse potential, as some of those to be dismantled will 
be damaged during removal or will not be purchased for reuse and will, thus, subsequently 
be sent to separate recycling.  

Under the design scenarios it is further envisioned that MS and the EC shall perform market 
surveillance and vehicle dismantling tests. Though this comes with some administrative costs, 
it is expected to increase the knowledge of type approval authorities and of authorities as to 
the correlation of the 3R type approval calculation with the actual 3R targets achieved at EoL. 
This should over time lead to more vehicles which can fulfil the targets being placed on the 
market.  

It  is  also  envisioned  under  all  design  scenarios  that  OEMs  will  be  required  to  perform 
dismantling tests of prototype vehicles as part of the 3R type approval. This should lead also 
to  an  increase  in  the share  of  vehicles  placed  on  the  market  that  can  fulfil  the  targets  but 
would also allow fee modulation in cases of vehicle models where e.g., vehicle design does 
not sufficiently facilitate dismantling of components with obligations. Though in the first years 
this may be a burden to OEMs, it can also be expected to reduce the number of 3R directive 
market surveillance violations that would results in sectioning of OEMs. In other words, the 
benefits in the long run would probably justify the costs of implementation.  

Under  Scenario  Design  2,  OEMs  will  be  requiring  submitting  a  circularity  strategy  and  to 
update it on a bi-annual basis. The strategy will include data on the circularity performance of 
OEMS at vehicle fleet and at the level of some individual models. The data is not expected to 
change  the  compliance  of  OEMs  with  legal  requirements  but  could  lead  some  OEMs  to 
advance a little bit voluntarily. In so far, the strategies could help type approval authorities to 
better understand the efforts made by OEMS to increase circularity through design and what 
this  may  mean  for  the  type  approval  process.  OEMs  will  have  costs  for  developing  the 
strategies but also for their implementation in areas that go beyond the legal obligations. It is 
however not clear to what degree design changes would actually go beyond legal obligations 
in  a  way  that  differs  from  the  baseline  (i.e.,  frontrunners  would  be  expected  to  perform 
similarly).  

Scenario Design 3 is considered for the most part as a measure that ensures compliance in 
the case of a target for recycled content. Where the declaration is required by OEMs without 
a target, a small increase in the use of recycled content may be expected to allow “declaring 
on positive results”. However, this would most likely only be a small difference to the baseline 
and would probably rely more on recycling from other sectors than on recycling of materials 
from vehicles. Once the declaration is coupled with a target for recycled content (as proposed 
for e.g., plastic), the main benefit of this option is for compliance verification, whereas it is the 
measure introducing the targets which would be expected to generate the increase in the use 
of recycled content in general and more specifically from vehicle origin. 

3.1.4.2.1  Environmental impacts 

Under all design scenarios, the prescribed measures do not address environmental aspects 
directly, but rather how the 3R type approval process is carried out, how it is enforced in terms 
of market surveillance and what type of information needs to be provided by OEMs as part of 
the  process.  Nonetheless,  these  aspects  can  be  expected  to  affect  the  composition  of 
vehicles,  their  dismantling  and  thus  also  the  level  of  the  3Rs  at  EoL,  leading  indirectly  to 
environmental impacts: 

In  relation  to  the  general  reusability  and  recyclability  of  vehicles  placed  on  the  market 
following the 3R type approval, it is expected that under the design scenarios, the level of 
reuse and recycling will increase from around 70% to at least 74% (based on the monitoring 

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with the calculation point concept). This is not just related to the 3R revision but also to the 
application  of  additional measures,  however,  the  former may  increase  the  total  achievable 
rates  a  little  further,  as  market  entrance  of  vehicles  that  cannot  fulfil  targets  will  be  more 
limited.  

The reuse and recycling rates could increase further with time due to the dismantling tests 
that OEMs will need to perform and submit documentation for: this information will allow both 
OEMs  and  type  approval  authorities  to  develop  a  better  understanding  of  what  practices 
facilitate dismantling, reuse and recycling to a higher degree. This could be reflected both in 
OEMs  choice  of  practices  in  vehicle  types  submitted  for  approval  and  in  decisions  of 
authorities as to approval of vehicle types for market access. 

In addition, it is expected that the use of non-recyclables in large amounts in vehicles will be 
less  common  in  vehicles that  do  not  show  a  higher  environmental  performance  during the 
use  phase  that  sets-off  negative  impacts  on  recyclability.  Though  it  could  be  that  vehicles 
using non-recyclables will have a lower fulfilment of the 3R targets, this would be expected to 
be set-off through benefits to have incurred from the use of respective materials in the use 
phase, i.e., a net benefit in total.  

The  availability  of  information  on  dismantling  and  on  digital  keys  and  interchangeable 
components will likely increase the rate of components dismantled for reuse and/or recycling. 
This is expected to particularly be the case: 

•  For components for which OEMs have developed quick dismantling methods but where 
information  does  not  sufficiently  reach  ATFs  under  the  baseline.  EGARA  (2021)  for 
example reported on a vehicle model in which the OEM invested in a method for quick 
release of the copper wire harness, however as the information did not reach ATFs, the 
practice was abandoned instead of being applied by additional OEMs and increasing the 
complete dismantling of such components. Similar cases are expected to be relevant for 
other material components.  

•  For components where digital keys prohibit the reuse in vehicles, a more harmonised and 
less expensive accessibility is likely to increase the rate of dismantling and sales for reuse. 
As such components are EEC, this will have a positive effect on the reliance of the vehicle 
sector on primary precious metals and CRMs and will also have a positive effect on the 
level  of  copper  impurities  in  steel  scrap.  Similarly,  information  on  dismantling  of 
components with a potential for reuse can be expected to increase the dismantling and 
sales for reuse of other components, also affecting the reliance on resources needed to 
manufacture new components for replacement. 

Under  the  design  scenarios,  the  increase  in  the  rate  of  reuse  of  certain  components  will 
translate into a decrease in the amount of resources needed for manufacturing new ones.  
Under  the  design  scenarios,  MS  could  be  expected  to  perform  more  market  surveillance 
activities looking at the enforcement of the legislation. The same is true for the EC performing 
dismantling  tests.  Where  non-compliant  vehicles  are  to  be  identified,  this  could  result  in  a 
premature  recall  and  scrapping  of  such  vehicles,  meaning  that  the  resources  used  to 
manufacture such vehicles will have not reached the full potential of the vehicle service life. 
This impact will be less severe, as materials could be recycled, however the environmental 
burden of recycling scrapped vehicles into new materials cannot be ignored.  

Under scenario design 2, as manufacturers using large amounts of non-recyclables will be 
obligated to show how they will promote recycling of such materials within 7 years of the initial 
type  approval,  it  will  additionally  be  expected  that  the  recyclability  of  non-recyclables  is 
increasingly possible at EoL or that the OEM collects such materials to ensure their waste 
management independently.  

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Furthermore, under this scenario, the reporting on practices that support circularity to type 
approval authorities could increase the knowhow of staff over time, again resulting in vehicles 
that have a higher compliance with design requirements and with the 3R targets being placed 
on the market mor often.  

Under  Scenario  design  3,  the  declaration  obligation  may  have  some  benefit  in  terms  of 
increasing  the  level  of  recycled  content  marginally  (see  results  of  the  plastic  analysis  at 
material level under section 3.1.9 for more details) when no target exists. However, once a 
target  is  enforced  it  is  assumed  that  the  target  is  the  driving  force  behind  environmental 
benefits  and  not  the  declaration.  This  measure  is  thus  mainly  considered  a  supporting 
measure to allow ensuring compliance with future recycling content targets, having a benefit 
in terms of ensuring enforcement. 

3.1.4.2.2  Economic impacts 

For all design scenarios, economic impacts can be expected for OEMs, 3R Type approval 
authorities and for ATFs.  

The  revisions  to  the  type  approval  calculation  under  the  design  scenarios,  could  be 
considered to make the process somewhat more complex for OEMs and for 3R type approval 
authorities, however the calculation generally follows the existing one, with the main burden 
being  expected  to  result  in  a  one-time  transitional  costs  for  adjusting  the  software  so  that 
when a material is given with a TRL lower than 9 or in the case of materials with low recycling 
efficiency (rubber), that such materials are accounted for only partially (or not at all) in the 
calculation  of  the  3Rs.  Though  this  will  have  an  impact,  it  is  assumed  to  be  negligible  in 
relation to other costs, in particular as the automotive already has a document specifying the 
recyclability level of different material typed which is updated from time to time and is used 
by the various OEMs.  

Under  the  design  scenarios,  the  increase  in  the  rate  of  reuse  of  certain  components  will 
mean  that  suppliers  of  replacement  components  see  a  loss  of  business,  while  ATFs  and 
remanufacturers  will  see  an  increase  in  business.  This  is  considered  to  be  more  of  a 
distributional  impact.  In  parallel,  vehicle  owners  shall  profit  from  the  increased  supply  of 
reused parts (assuming that demand will increase), as these are less costly, meaning that 
repairs will be less expensive.  
Market  surveillance  authorities  performing  activities  in  relation  to  type  approvals  or  EC 
dismantling  activities  would  have  a  burden  in  terms  of  the  time  needed  for  surveillance 
activities and the costs that e.g., surveillance of a single vehicle would incur. For example, if 
the authority would need to pay for the vehicle to be surveyed this could easily translate to a 
few  tens  of  thousands  of  €  per  year  for  authorities  dismantling  whole  vehicles  (assumed 
30,000  €  on  average)  or  a fraction thereof (assumed  1,000  €  per  average  component) for 
authorities dismantling specific components. Assuming that each MS performs at least one 
activity  related  to  3R  type  approval  annually,  and  assuming  that  20%  of  activities  are  at 
vehicle level would mean that annually close to 185 thousand € would be spent only on the 
vehicles or components to be surveyed. Additional costs may incur for equipment used for 
surveillance as well as for the time that employees will spend on such activities (see below 
under administrative burden).  
Vehicle recalls resulting from market surveillance or EC dismantling tests are also expected 
to have a significant economic cost for OEMs. Market surveillance sanctions could lead to 
fines of up to 30,000 € per vehicle. If to assume that a vehicle has been placed on the market 
in the EU at a volume of 10,000 vehicles in the year following its type approval, at the end of 
which a non-compliance is revealed, this could lead to sanctions at a value of 300 million € 
just for the one case. This is furthermore considered an underestimation, as additional costs 
would incur due to vehicle owners needing to be compensated for their damages and due to 

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the  “losses”  related  to  the  upscaling  of  production  of  a  vehicle  type  that  will  no  longer  be 
manufactured. 

Regarding provision of data, it is difficult to assess what costs this will result in for OEMS. 
Whether (sometimes existing) platforms are used, or a digital product passport (DPP) could 
affect the costs for OEMS: a DPP would need to be developed as an IT solution and can be 
considered to be more complex and costly in its entirety than a web-platform, particularly as 
some  of  these  are  already  established  (IDIS;  RMIS,  GADSL  And  IMDS)  and  could  be 
improved instead of developed anew. Nonetheless, it is also observed that the vehicle sector 
is already considering the development of a digital product passport for vehicles, meaning 
that this is also assumed to have certain benefits. Whether this would also be the case for 
provision of data to ATFs through a DPP is not clear. If the decision between the options is 
left open to OEMs, impacts can be considered to be acceptable even if different in range. 
Where the regulator decides to require a certain solution over alternatives, in particular a DPP 
solution,  it  should  be  kept  in  mind  that  this  shall  probably  increase  economic  impacts  on 
OEMs.  

As for the impact of different methods of provision of data on ATFS, here, there is also a lack 
of quantified data as to the actual benefits. Data proposed to be made available (in general 
or in a more harmonised way) is data for which stakeholders have explained that there is a 
lack in data  (EGARA 2021; EuRIC 2021) or that use of data results in costs for ATFs that 
discourage ATFs from reuse of respective components. Generally, it can be understood that 
for ATFs it would be an advantage to have all data in one place as, it is explained to be a 
burden if an ATF needs to open multiple PDFs to reach data of interest. INDRA (2021) explain 
that IDIS is too general, “you know the information only per model but the model can have 
different  options  which  are  not  detailed”  and  recommend  the  use  of  a  RFID,  QR  code  for 
access  to  data.  “Dismantlers  should  not  be  asked  to  search  in  a  database  for  20  min  on 
different websites but can scan the code of the car / component that he has in front of him in 
the dismantling line”.  

It  is  thus  also  assumed  that  needing  to  install  multiple  platforms  of  individual  ATFs  will 
discourage ATFs from use of such data, as it requires not just installation but familiarity with 
the structure of multiple sites that are not used often enough for this to develop. If all data is 
located  under  one  platform  and  harmonised,  this  could  be  assumed  to  have  a  benefit  for 
ATFs, however they should be included in the process of development of the IT architecture 
of  such  platforms  to  increase  their  efficient  use.  A  digital  product  passport  may  have  an 
advantage, as it would be assumed to work with a QR code or RFID, allowing the use by the 
operator “at the vehicle”, however such systems are yet to be developed to clarify their actual 
efficiency of use. ATFs, who over time should have an increased availability of data would be 
expected to see an increase in activity for parts that could be reused or recycled separately 
due to the newly available data. Though this may increase costs of dismantling it would also 
be expected to increase revenues where the data is applied. 

Administrative costs for 3R Type approval authorities shall need to assume the additional 
task of ensuring that required information has been submitted (or linked) with the 3R Type-
approval  application.  This  will  increase  the  costs  of  the  process  but  is  likely  to  only  affect 
some  authorities  as  not  all  MS  perform  3R  Type  Approvals.  One  Type  approval  authority 
estimated that it needs less than < 0.25 years full time job equivalents (FTE) per each 3R 
type approval performed, however it is not clear if the days needed are closer to 3 months 
work  or to  a  few  days. A  type  approval  service provider  that  supports  another  authority  in 
checking submissions of 2 OEMs estimated 10 days of work per annum, without specifying 
the number of approvals that this covers. Assuming 10 working days for a single type approval 
thus seems to be an over estimation. If the need to check the provision of data would increase 
this by 50%, this would still only be 5 additional day per annum. It is understood that only a 
handful of MS perform 3R type approvals, but even if half would be involved in such tasks, 

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this would still only result in less than 70 working days in the EU in terms of the administrative 
cost, amounting to less than 15,000 € per annum. 

As  data  is  lacking  to  allow  a  more  accurate  quantification,  it  has  been  assumed  that  the 
administrative costs for MS performing market surveillance activities will require 3 days for 
testing a vehicle and 1 day for testing an average component. Again assuming one activity 
per MS and, 20% of which are at vehicle level, would amount in less than 40 days of work in 
the  EU  in  terms  of  administrative  costs.  Cost  for  vehicles/components  have  also  been 
included in the sum. This amounts to ca. 190 thousand € per annum across the EU. 

In addition, the Commission will be tasked with performing and reviewing dismantling tests, 
creating  costs  for  the  purchase  of  vehicles  for  dismantling  as  well  as  costs  for  the  actual 
dismantling  exercise,  the  review  of  its  results  and  communication  to  3R  Type  approval 
authorities. Cost for 5 vehicles have also been included in the sum. This amounts to ca. 160 
thousand € per annum. 

OEMs are also expected to have additional costs for dismantling tests of (prototype) vehicles 
prior to submission of type approvals. Assuming that the OEM would need to cover expenses 
of 5 days for a shredder activities and 10 days for type approval service provider activities for 
each vehicle tested, assuming 5 vehicles tested per year per OEM (at a cost of 30,000 € for 
the vehicle itself) and assuming 10 OEMs, this would amount to around half a million € per 
annum. 

In total, this amounts to around 820 thousand €per annum for thus scenario. 

Scenario Design 2 

Under  scenario  design  2,  manufacturers  using  large  amounts  of  non-recyclables  will  be 
obligated to show how they will promote recycling of such materials within 7 years of the initial 
type  approval.  Though  it  is  not  sure  that  this  method  of  treatment  would  be  more 
environmental  than  the  method  applied  by  ATFs,  however  the  burden  for  ATFs  would  be 
significantly smaller, leaving more of a financial margin to treat other materials at a higher 
level.  For  OEMs  this  may  mean  higher  costs  for  treatment  of  such  materials,  however  as 
OEMs are expected to have benefits from the use of such materials, such costs would be 
expected to either be acceptable or to create a disincentive from using such materials where 
recyclability cannot be ensured over time.  

Costs are expected mainly for OEMs, who need to prepare and submit the strategy and to 
update  it  on  a  bi-annual  basis.  Though  OEMs  already  have  an  obligation  to  prepare  and 
submit a strategy, this is understood to be more general and is not updated very often. The 
new obligation would require preparing a more detailed strategy and also clarifying at vehicle 
level  to  some  degree  how  it  is  implemented  over  time.  This  is  assumed  to  be  a  more 
significant  effort,  however  there  is  no  data  as  to  how  much  time  OEMs  would  spend  on 
developing the strategy and how much would be spent in its implementation. Though the cost 
could  be  expected  to  be  significant,  it  is  considered  to  support  design  improvements  that 
would make vehicles more circular.  

Even though type approval authorities would need to review such strategies, they are already 
expected to do so in relation to the strategy that OEMs are expected to submit, and costs 
would not be expected to differ significantly. 

Scenario Design 3 

Costs are mainly expected for OEMs and shall depend on the effort of certifying the amount 
of  recycled  content  used  per  vehicle.  JRC  has  made  estimations  of  providing  such 
declarations and explained that these are negligible in comparison to the effort of increasing 
the  amount  of  recycled  content  actually  applied.  This  is  explained  to  some  degree  in  the 
section assessing impact for plastics and in the JRC report (see (Maury et al. 2022)). 

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3.1.4.2.3  Social impacts 

Where there shall be more work, an increase in employment could be expected, however the 
range of additional jobs is difficult for quantification. 

For  measures  addressed  under  Scenario  Design  1  and  relevant  for  all  scenarios 
increases  in  jobs  can  be  estimated  in  relation  to  the  expected  administrative  burden.  This 
amounts to around 900 working days per annum in total and makes up for around 4.5 jobs 
with less than 1 job being associated with authority activities.  

In addition, new employment can be expected to develop at OEMs in relation to actual design 
changes to be initiated to ensure compliance of vehicles to be type approved. As the range 
of design changes could vary between vehicles it is not possible to estimate the range of this 
impact. 

In  addition,  additional  jobs  would  also  be  assumed  to  be  created  at  ATFs  where,  more 
components could be dismantled and sold for reuse due to the additional availability of data. 
However here too, there is no data to allow a quantification, also as this would depend on the 
quality of data made available and on the platform chosen. 

In Scenario Design 2, OEMs can be expected to have costs for preparing their strategies 
but also for their implementation, thus driving a small increase in employment. Though type 
approval authorities will experience some additional work for the review of strategies this is 
expected to be covered by existing employees. 

In Scenario Design 3, OEMs can be expected to have costs for performing dismantling tests. 
These  would  be  performed  by  type  approval  authorities  and  by  shredders,  making  up  for 
almost 4 jobs annually as explained above. 

3.1.4.3  Results of quantitative analysis  

Data is not available to allow a quantitative analysis of most aspects. 

3.1.4.4  Comparison of scenarios  

Impacts 

Scenario design 1 

Type approval 

Additional impacts 
under Scenario 
design 2 circularity 
strategy  

Additional impacts 
under Scenario 
design 3 

Declaration on 
recycled content  

c
i
m
o
n
o
c
E

on ATFs 

on Shredders  

costs 

Some 
for 
additional  dismantling 
but assumed to be set-
off by benefits for selling 
components  for  reuse 
and scrap for recycling 

Between + and ++ 

Possible  decrease 
in 
shredder  inputs  where 
more  dismantling  takes 
place 

- 

256 

Indirect  benefits 
from 
OEMs  strategies  in  the 
long  term,  as  vehicles 
become more circular 

related 
in 

Benefits 
increase 
content  but  not 
declaration 

to 
recycled 
to 

+  

n.a 

impact, 
Unclear 
depending 
how 
vehicles  become  more 
circular 

on 

related 
in 

Benefits 
increase 
content  but  not 
declaration 

to 
recycled 
to 

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Impacts 

Scenario design 1 

Type approval 

Additional impacts 
under Scenario 
design 2 circularity 
strategy  

Additional impacts 
under Scenario 
design 3 

Declaration on 
recycled content  

On recyclers 

increase 

in 
Possible 
revenues 
where 
dismantling for separate 
recycling increases  

Between 0 to + 

impact, 
Unclear 
depending 
how 
vehicles  become  more 
circular 

on 

related 
in 

Benefits 
increase 
content  but  not 
declaration 

to 
recycled 
to 

n.a 

on SME  

Inefficient provision of information assumed to have a larger impact on small 
and independent ATFs who would be discouraged from using data. 

OEMs 

Circularity 

Environmental 

Social  

Employment 

Costs 
for  calculation 
revision assumed to be 
mainly 
low 
transitional 

and 

Between 0 and - 

Admin  costs  of  about 
for 
half  a  million  € 
implementing 
dismantling tests  

Costs  from  provision  of 
data unknown, possibly 
higher if DPP is required 

Between - and --- 

Small  increase  in  the 
share  of  vehicle  that 
comply  with 
the  3R, 
raising  the  reuse  and 
recycling 
by 
around 4%  

level 

Between + and ++ 

Decrease  in  the  use  of 
resources 
for 
manufacture  of  new 
parts  due  to  increased 
reuse 

Between + and ++ 

in 

type 
service 
and 

Increase 
approval 
provider 
ATF/shredder 
employment  of  around 
4  jobs  for  dismantling 
tests 

+ 

in 

Increase 
Type 
approval  authority  and 
employment, 
EC 

257 

Administrative  costs  for 
developing and revising 
strategy 
for 
implementation  in  the 
mid-long term 

and 

Between - and -- 

Administrative  costs  for 
declaring 
of 
content, 
recycled 
possibly negligible: 

rate 

Between 0 and - 

in 
Small 
circularity in the long run 

increase 

Between 0 and + 

Declaration 
expected 
significant impact 

not 
to  have  a 

Increase in employment 
at OEMs for developing 
and 
implementing 
circularity strategy 

Between + and ++ 

Existing  type  approval 
authorities  assumed  to 
cover 
to 
able 
be 
additional work 

n.a 

Increase in employment 
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Impacts 

Scenario design 1 

Type approval 

Additional impacts 
under Scenario 
design 2 circularity 
strategy  

Additional impacts 
under Scenario 
design 3 

Declaration on 
recycled content  

estimated  at  less  than 
one job 

Between 0 and + 

in 

Increase 
ATF 
to 
employment  due 
additional dismantling – 
level unknown 

Between + and ++ 

Proportional  to  ensure 
that  vehicles  placed  on 
the  market  achieve  3R 
targets and that data is 
sufficiently  available  to 
ATFs 

++ 

Proportionality  

Proportional to increase 
circularity in the long run 

+ 

Unclear  if  proportional, 
but 
considered 
supporting measure 

Between – and +,  

Cost effectiveness  

Low  costs  but 
benefits 

low 

increase 
Costs  will 
proportionally 
to 
benefits (probably low) 

Negligible  costs  and 
benefits  but  considered 
supporting measure 

Coherence 

Possibly  not  coherent 
with  Regulation  UN 
ECE  133,  could  affect 
movements  of  vehicles 
between  EU  and  non- 
EU countries 

General coherence with 
the  CEAP,  promoting 
waste  treatment  of  a 
higher  hierarchy  and 
circularity)  

-  

+ 

n.a 
– 
measure 

supporting 

EPR considerations: 

As information on the dismantling time of various components will be submitted together with 
the 3R Type-approval application (or linked thereto), it shall be able to feed into the EPR and 
any necessity to develop fee modulations. Such data will be more accurate if OEMs required 
to perform dismantling tests, data of which is also to feed into fee modulation.  

3.1.4.5  Preferred Scenarios for inclusion in final policy options 

It is proposed to look consider the measures addressed under scenario design 1 and 2 in 
combination and to further combine scenario 3 in all policy options in which recycled content 
targets are envisioned.  

•  3R  Type-approval  information  requirements  and  dismantling  tests  +  OEM  obligation  to 

submit and implement circularity strategy. 

•  3R  Type-approval  information  requirements  and  dismantling  tests  +  OEM  obligation  to 

submit and implement circularity strategy + recycled content declaration. 

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3.1.4.6  Reporting and monitoring requirements 

All of the measures addressed in this section have a reporting element by requiring OEMs to 
report  on  certain  aspects  (scenario  design  2  and  3)  or  through  the  dismantling  tests  of 
vehicles that is considered to enable monitoring of the 3R Type-Approval. 

3.1.4.7  Analysis for non-recyclables 

Six measures were shortlisted for non-recyclable materials or those with not yet established 
recycling capacities in the EU, including the following measures: 

Title 

2.1.d: Provisions for improving the relation between the 3R Type- approval process and ELV waste 
management performance with a view to having non-recyclables better reflected in the type-
approval calculation 
2.1.e: Option for OEMs to submit life cycle analysis data as part of the 3R Type-approval process to 
justify the use of non-recyclables 
2.3.a: Align definition of ‘recycling’ with the WFD to prohibit backfilling of non-recyclables 
2.3b: Making it mandatory to remove parts made of non-recyclables before shredding to encourage 
their recycling or to prevent contamination of other fractions 
2.3.d: Regulate shredder/post shredder facilities to ensure higher quality of recycling 
2.3.e: Ban disposal or landfilling of waste from ELVs 

Chapter 
2.1.5.1.4 

2.1.5.1.5 

2.1.5.3.1 
2.1.5.3.2 

2.1.5.3.4 
2.1.5.3.5 

Colour code: Red – discarded, Yellow – premature, Grey – supporting measure 

•  The first two measures (2.1d) will be considered jointly. In the first measure, one of the 
main  changes  proposed  for  the  calculation  method  applied  in  the  3R  Type-approval 
process  relates  to  the  technology  readiness  level  (TRL)  of  the  recycling  of  a  specific 
material. This is mainly targeted at reflecting non-recyclable materials more precisely in 
the calculation. When such materials are used in large volumes, this aims at considering 
whether it is reasonable to assume that the 3R Targets will be complied with or, if this is 
not the case, considering the rejection of the request. The second measure (2.1.e) adds-
on to this approach, allowing OEMs the option of justifying lacking compliance when the 
use  of  such  materials  leads  to  a  significant  benefit  in  the  use  phase  (e.g.,  emission 
reduction). This measure is meaningless when not implemented together with the type-
approval calculation changes. An additional strength of this measure is that it ensures that 
the non-recyclable material will be identified as such in the type approval process and in 
related  information  for  dismantlers that  is  to  be made  available  as  part of the process. 
OEMs would also be required to recommend how to treat the material at EoL should the 
recycling still not be established. 

•  Measure 2.3.b prescribes an obligation to dismantle non-recyclables from the vehicle prior 
to shredding. This is expected to either push the market to find solutions for the recycling 
of such materials or to at least allow obliging OEMS that make use of such materials to 
take  responsibility  for  its  treatment  in  line  with  the  EPR  principles.  As  a  minimum 
obligatory  dismantling  would  ensure  that  contamination  of  other fractions  is  prevented, 
i.e., when non-recyclables are sent to the shredder and following treatment together with 
other materials. 

Measures 2.3.a and 2.3.e, could both affect the recycling of non-recyclables insofar that they 
create limitations for material fractions that cannot be treated without downcycling or without 
disposal. Which of these measures is more suitable to address non-recyclables, depends on 
the material at hand: 

•  Measure 2.3.a refers to an alignment of the definition of recycling with the WFD, in practice 
prohibiting that backfilling is counted towards the recycling target. At present, backfilling 
is practiced with the mineral fraction that is generated by shredders. Measure 2.3.a is thus 

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only considered suitable for materials that land in the mineral fraction after treatment of 
the SHF.  

•  Measure 2.3.e proposes among others a ban on disposal for shredder-light fraction that 
is  not  sent for  PST  and for  PST  output fractions  with  a  specific  weight  of  >  1.3  g/cm3. 
Banning the disposal of SLF and sending it to PST to allow removing the fraction with a 
specific  weight  of  >  1.3  g/cm3  is  targeted  at  removing  the  fraction  contaminated  with 
decaBDE and substances that increase the specific density of plastic materials. As the 
analysis  looks  at  Carbon  Fibre  Reinforced  Plastics  (CFRP)  to  demonstrate  possible 
impacts of measures, it cannot be excluded that decaBDE or similar substances were not 
used  CFRP  components  in  vehicles  put  on  the  market  prior  to  the  ban  in  2018.  This 
measure is thus considered to be more suitable in this case and will be analysed, whereas 
measure 2.3.a will be discarded. 

•  Measure 2.3.d is aimed at limiting the quantity of recyclables (mainly metals) in shredder 
residues. As the non-recyclables identified under Section 2.1.2.5.10 are not of metallic 
nature and as metals used in high volumes are generally recyclable, this measure is not 
expected to have an effect on the content of non-recyclables. It is thus discarded.  

For the sake of simplicity, the following sections refer to the example of CFRP to demonstrate 
the  costs  and  benefits  of  the  various  scenarios. For  this  reason,  CFRP  is  referred  to  as  a 
material and in the names of the scenarios and not under the term “non-recyclables”. 

3.1.4.7.1  Scenarios for quantitative analysis  

3.1.4.7.1.1  Baseline 

As described by Marklines (2015), an increasing number of European automakers has added 
CFRP to some vehicle models in an effort to reduce weight and thus also emissions during 
use. BMW has used CFRP for the body of some of its vehicles like the i3 and the i8, and other 
manufacturers like Mercedes-Benz and Audi were also reported to be considering the use of 
such materials. EGARA (2021) mentions additional non-recyclable materials like composite 
plastics, and reinforced plastics, and explained that that these are currently neither used in 
many vehicles nor in large amounts, but that an increase in use is expected.  

According  to  (DexCraft  2015),  a  carbon  fibre  supplier,  as  a  material,  carbon  fibre  offers 
stiffness and strength at low density, which is lighter than aluminium and steel, and provides 
many  practical  benefits. Assuming the  same  weight,  carbon  fibre  offers 2  to  5 times  more 
rigidity (depending on the fibre used) than aluminium and steel, and even higher values when 
the component in question will only be stressed along one plane (i.e., one-direction carbon 
fibre). If a component has a weight limit in design, and is thus limited to a thickness of 1.5 mm 
when using steel or 4 mm when using aluminium, the use of carbon fibre will allow increasing 
the thickness to up to 7 mm. The additional thickness however then also translates into higher 
stiffness, as where the thickness increases x 2 it provides an increased rigidity of 23. 

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Table 3-1  Analysis of aluminium, steel and two-direction carbon fibre regarding 
stiffness against weight and strength against weight  

Aluminium  Steel 

Two-direction 
carbon  fibre  – 
common 
modulus 

Two-direction 
carbon  fibre  – 
improved 
modulus 

Two-direction 
carbon  fibre  – 
highest 
modulus 

Stiffness against weight 
(Specific Modulus) 
Unit: 10 6 m2s-2  

Resistance to damage 
(Specific Strength) 
Unit kN·m/kg 

26 

25 

56 

83 

214 

254 

392 

211 

120 

126 

Source: (DexCraft 2015) 

Since we can assume that reducing vehicle weight will play a larger role in the future, the use 
of non-recyclables will probably continue to increase, whether through use of CFRP or new 
materials  to  be  developed  for  this  purpose.  Where  the  volumes  of  use  will  increase 
significantly, recycling could develop, but where it does not, this shall affect the ability of such 
vehicles  to  achieve  the  3R  Targets  and  shall  reduce  the  general  circularity  of  vehicles,  in 
particular when such materials replace larger amounts of conventional ones like steel. 

3.1.4.7.1.2  Scenario CFRP 1: Type-approval revisions  

The 3R Type-approval process will be changed. Aside from excluding materials with a TRL 
of 4 from the accounting of the recyclability rate, those with non-established recycling will be 
penalised in the calculation as they will not be accounted for to 100 % (see details in measure 
description,  Section  2.1.5.1.4).  To  allow  exclusions  for  vehicles  where  the  use  of  non-
recyclable material (TRL of 4 and below) results in an environmental benefit during the use 
phase, the manufacturer will have the option of submitting life cycle analysis data to show 
that the use of the material in question provides benefits during the use phase that set off the 
negative impacts of not recycling at EoL. 

3.1.4.7.1.3  Scenario CFRP 2: Obligatory dismantling of non-recyclables  

The removal of non-recyclable materials used in a vehicle shall be made obligatory. Relevant 
material parts and components with a total weight above 5 kg shall need to be removed and 
recycled  separately.  This  weight  threshold  is  suggested  to  ensure  removal  of  all  larger 
components,  but  with  an  understanding  that  removal  of  smaller  ones  could  be  very  time 
consuming, affecting the economic feasibility of this practice. 

3.1.4.7.1.4  Scenario CFRP 3: Ban on disposal  

A ban will be introduced on the disposal of the shredder-light fraction that is not sent to PST 
and PST output fractions with a specific weight of > 1.3 g/cm3.  

3.1.4.7.2  Results of qualitative analysis  

With  regard  to  vehicles  that  use  large  amounts  of  non-recyclables,  Scenario  CFRP  1  will 
allow  to  make  a  distinction  between  cases  where  this  does  not  lead  to  a  significant 
environmental contribution to the use phase and cases in which this occurs. Evidence used 
for  justification  is  to  be  provided  in  reference  to  the  single  vehicle,  i.e.  comparing  data  on 
emissions and environmental performance at the level of the single vehicle. Comparisons at 

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fleet level could be submitted to further support the request, however as future PoM levels 
are not always known during the initial type approval of a vehicle, the single vehicle level is 
proposed to ensure that in all type approvals, the data is reviewed in a comparable fashion. 

• 

• 

In the former case, such vehicles would be denied market access if they cannot show that 
the  targets  are  met.  This  is  expected  to  push  manufacturers  towards  using  less  non-
recyclables,  to  ensure  that  the  targets  are  met.  Alternatively,  it  could  also  lead  to 
investments  of  manufacturers  in the  establishment  of recycling capacities  for  materials 
that are expected to have a higher potential for benefits during the use phase. 
In the latter case, the 3R Type approval could be granted as the environmental benefits 
during use set off the costs during EoL of the volume that cannot be recycled. This said, 
it is possible that in some cases OEMs may decide not to submit LCA data if the additional 
administrative  effort  is  perceived  as  too  burdensome  or  if  there  is  uncertainty  as  to 
whether the case would be considered justified.  

It is considered that this scenario will lead to an increase in administrative costs for OEMs, as 
they will need to provide more data to the 3R Type-approval submission. The range of costs 
would depend on whether LCA data is provided or only the additional data compiled for the 
non-recyclable material. Theoretically, the scenario could also lead to revenue losses, where 
the  3R  Type  approval  of  a  vehicle  is  denied,  requiring  the  model  design  to  be  revised  or 
resulting  in  the  design  being  abandoned  (loss  of  the  investment  costs  of  developing  the 
model). However it is expected that OEMs would ensure that their designed vehicles level of 
use of non-recyclables is too low to hinder achieving the 3R targets, or that they would ensure 
that  when  large  volumes  are  applied,  that this  has  justification that can be  shown  through 
evidence. There is a risk that the measures would affect innovation, though this could develop 
in  two  directions.  In  some  cases,  OEMs  would  avoid  development  of  new  materials, 
anticipating that this could jeopardise type-approvals and subsequently their product portfolio. 
In others this could push more OEMs to using the same innovative materials and cooperating 
with waste operators to ensure the timely development of recycling capacities. It is generally 
considered that OEMs will learn to work with the system, so that after a certain period from 
implementation there will be more certainty on which cases can be type-approved and which 
cannot. Thus, in the mid- to long-term, the scenario would be expected to contribute to more 
circularity when new materials are introduced into the design of vehicles.  

Scenario  CFRP  2  leaves  all  options  open  as  to  the  use  of  non-recyclables,  however,  it 
requires their  removal  and  separate recycling  at  EoL.  For some  materials,  it  could  be  that 
recycling will have developed at this stage and for some possibly not. In the latter case, waste 
management operators could be faced with large storage costs of materials for which there 
is  no  recycling,  or  with  high  investment  costs  of  developing  new  recycling  techniques  and 
capacities. In some cases, such collected fractions may end up being shredded after all. A 
few past examples show that this can have different consequences. 

EGARA (2021) give an example of a bearings manufacturer that used vehicle hulks after the 
dismantling stage to produce bearings. “Normally it’s impossible to make cars again out of 
car scrap because of contamination with copper”. However, after removal of the copper, the 
manufacturer managed to produce steel bearings, despite the upholstery (including plastics) 
being left in the hulk and the result was just as good. They could use the recycled steel for 
bearings production, but less carbon in the melting and forging process needed to be added”. 
In such cases, a high-quality recycling of the non-recyclables is not pursued, but at least non-
recyclables of plastic or hydrocarbon composition could be used, e.g., in steel manufacturing 
instead of adding carbon to the process. A second example refers to the vehicle dashboard 
due  to  its  electronic  components  rather  than  to  a  non-recyclable  material.  “There  was  the 
case that it was obligatory in Denmark to take the dashboards out of the vehicle (instrument 
panels), so they were removed and piled up, but there was no specific recycling for it at the 
time – in the end it went to the shredder”. On the instrument panels “10 years ago it was too 

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hard  to  recycle.  Now  Stena  (Swedish  recycling  company)  recycles  it,  so  maybe  it  has 
changed”.  To  summarise  this  scenario  could  promote  the  development  of  some  recycling 
techniques, thus increasing circularity, but where this does not happen (or in cases where it 
takes too long), obligatory dismantling could have a high financial toll for ATFs, not always 
ensuring that the targeted material is indeed recycled. 

The  effectivity  of  Scenario  CFRP  3  depends  on  the  density  and  weight  of  the  material  in 
question. Carbon fibre composites have a density of 1.55 g/cm3 (epoxy resin 30 %, carbon 
fibre 70 %)206 which would mean that they would be affected by the ban in this case. CFRP 
would need to be removed from the SLF, ensuring that it is not landfilled, however, this does 
not ensure that it will be recycled at high quality. It could be that such materials are used for 
backfilling or as construction filling materials or as explained above, in some cases they could 
be fed to smelting processes to replace the addition of carbon-based fuels. As the material 
will  have  been  shredded  and  possibly  also  grinded,  high-quality  recycling  could  also  be 
hindered in some cases due to contamination with other materials. 

3.1.4.7.3  Results of quantitative analysis  

The BMW i3 is taken as an example to demonstrate some of the impacts at vehicle level. The 
total weight of the BMW i3 is 1345 kg when unladen207. According to by Marklines (2015), 
68.5 kg (5 % of total weight) of the body weight is composed of CFRP, comparing this with 
the weight of the body if it had to be composed of steel and concluding that the CFRP and 
other light-weight materials used in the body could be reduced by 90 kg of this component 
and the total vehicle weight.  

According to Dupont208, reducing an automobile’s weight by a mere 50 kg (110 lbs) reduces 
up to 5CO2of CO2/km and increases fuel economy by up to 2 %. This translates into a 90 kg 
CO2  eq.  per  year  or  900  kg  CO2  eq.  for  a  lifetime  of  10  years  (both  considered  to  be 
conservative assumptions).  

IDIS dismantling data209 which is provided by the OEM specifies 152 kg (11 % of total weight) 
of CFRP for the body. Taking into consideration that the 3R Targets allow 10 % of material to 
be recovered and leaving 5 % to be disposed, means that this material does not leave much 
room for other materials that are not considered to be recycled, particularly not if the content 
is  indeed  above  10 %.  This  vehicle  contains  a  Li-Ion  traction  battery  (235  kg  according  to 
IDIS). Based on the material recovery targets being considered for such batteries under the 
new Batteries Regulation (65 % for 2025 and 70 % by 2030), this would also leave between 
5-6% of non-recycled material that needs to fit under the targets. Under the current Batteries 
Directive  (2006/66/EC),  the  Li-Ion  battery  only  needs  to  be  recycled  to  50 %,  resulting  in 
almost  9 %  of  non-recycled  material.  Based  on  the  IDIS  data,  by  2030,  if  the  recycling  of 
CFRP does not change, all other materials in the vehicle would need to be recycled to achieve 
the targets, though it is expected that not all materials in the vehicle are currently recycled 
(e.g., not all plastics are recycled). First models of the BMW i3 were placed on the market in 
2013  and  BMW  announced  that  it  would  be  discontinued  in  2022210,  meaning  that  some 
vehicles are already reaching end of life now and that in 2035 ELVs would still be expected 
at ATFs. Based on the above data, it is concluded that in the baseline, it is not clear how the 

206 http://www.dexcraft.com/articles/carbon-fiber-composites/aluminium-vs-carbon-fiber-comparison-of-materials/, last viewed 
24.6.2022 

207 Data for BMW i3 120 Ah: https://ev-database.org/car/1145/BMW-i3-120-Ah, last viewed 24.6.2022  

208 Dupont website on “Light-weighting” https://www.dupont.de/knowledge/lightweighting.html, last viewed 24.6.2022 

209 IDIS data for BMW i3: https://data.idis2.com/IDIS_data/faces/contents/vehicle/vehicleMain.xhtml, last viewed 24.6.2022   

210 See: https://www.bmwblog.com/2022/01/28/bmw-explains-why-i3-discontinued/, last viewed 20.8.2022  

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vehicle would comply with the RRR targets, and it is probable that it will still have difficulties 
reaching  the  targets  in  2030.  And  yet  the  BMWi3  was  type-approved,  so  that  it  can  be 
assumed that under the baseline, the TRL level considered for CFRP (and possibly also for 
other materials) was 4 or above, as otherwise the vehicle type-approval should not have been 
approved.  

Under Scenario CFRP 1, the vehicle could have only been type-approved if submitted LCA 
data  would  show  that  the  CFRP  resulted  in  fuel  benefits.  Looking  at  the  above  data,  this 
translates to a use related reduction of 900 kg CO2 eq. emissions setting off the related “cost” 
of not recycling the CFRP. If the CFRP is not recycled into a material with equivalent use, the 
environmental  cost  can  be  compared  with  that  of  manufacturing  new  CFRP.  The  carbon 
footprint of manufacturing wing rib made of CFRP thermoset by the technique of in-autoclave 
single-line-injection (SLI) is around 109 kg CO2 equivalent for each kg of CFRP (Al-Lami et 
al. 2018). It is not clear whether this result can be applied to the case of CFRP in the vehicle, 
however, assuming this value would mean that the 68.5 kg of CFRP needed for use in a new 
vehicle as there is no recycling result in over 61 thoCO2nd CO2 eq. Assuming that at least 
some  of  the  amount  could  be  sent  to  recovery  would  result  in  a  lower  amount,  however 
whether such data would support the type approval of the vehicle can be questioned. 

Whereas  the  assumption  in  the  baseline  is  that  the  vehicle  is  placed  on  the  market,  (also 
assumed for Scenario CFRP 2 and 3 which only apply requirements on the treatment of the 
CFRP) it is not clear whether this would be the case under Scenario CFRP 1. Here, two cases 
can be distinguished:   

•  Case A: Vehicle placed on the market, no special treatment requirements (i.e., evidence 

supports type approval), or 

•  Case  B:  Vehicle  placed  on  the  market  following  design  revision  and  change  to  other 

materials. 

3.1.4.7.3.1  Environmental impacts 

Under scenario CFRP 1B, it can be assumed that design revisions would result in the use of 
heavier materials like steel (for structural reasons) or aluminium (if it can provide the structural 
requirements).  Looking  at  the  Marklines  (2015)  data-based  estimation,  this  could  increase 
the vehicle emissions by up to 900 kg CO2 eq. over the lifetime of the vehicle. In parallel, the 
shift  to  materials  which  are  recyclable  would  be  expected  to  offset  this  impact,  at  least 
partially, through recycling credits obtained from the recovery of metals. 

Under all other scenarios, the vehicle is not changed, but the scenarios may affect how the 
material is treated at EoL.  

Under  scenario  CFRP  1A,  there  are  no  requirements  for  the  CFRP  treatment,  and  it  is 
assumed to be the same as in the baseline (see below).  

In  scenario  CFRP  2,  the  CFRP  must  be  removed.  Where  the  CFRP  will  be  collected 
separately, it could be that it is sent for use in energy recovery or that it is grinded with other 
fractions and used as a filling material (construction, back-filling). This option may have the 
fate of scenario CFRP 1A and the baseline (see below). A further option is that the CFRP 
will be sent to recycling211. This would also be the case where the OEM is required to take 
care of the material treatment. One obstacle for this up till now has been that recycling is only 
economically  feasible  when  large  amounts  are  collected  and  separated  for  recycling. 

211 According to Sukanto el al. (2020), recycling of CFRP is currently limited as capacities are very small in relation to the 
amounts manufactured. In addition, CFRP cannot be recycled at present back to the same quality, however it has been 
shown that it can be used in the form of short fibres in composite materials under medium and low loads.  

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Scenario CFRP 2 will not necessarily solve this in the short term, as first vehicles using CFRP 
only came on the market about 10 years ago, and the economies of scale may still not be 
sufficient to ensure that separate collection and recycling will become economically viable in 
the  next  few  years.  However,  the  use  of  CFRP  could  increase,  in  which  case  collected 
amounts  may  be  sufficient  to  establish  its  recycling  further.  Already  in  2014,  there  were 
prospects for reclaiming CFRP from end-of-life sources (aircraft and, eventually, ELVs) and 
repurposing it for use in automotive composite applications used in the interior (Gardiner G. 
2014) so that the recycling limitation is not necessarily a technical one.  

In all these cases (aside from CFRP 1B), as long as 95 % of the vehicle is recovered (as a 
material or energy), at least some of the CFRP could still be landfilled. Whether this will create 
pressure to recycle CFRP or rather to recycle other fractions (other plastics or glass) is not 
clear. 

Under  scenario  CFRP  3,  landfilling  is  excluded  and  a  treatment at  a  higher  hierarchy  will 
need to be applied. Here too, energy recovery or use as a filling material could still be applied 
as long as the targets are fulfilled. For the baseline and scenarios CFRP 1A, CFRP 2 and 
CFRP 3, it is assumed that at least in the short term, i.e., as long as CFRP capacities are not 
more established throughout the EU, there will be little changes in comparison to the current 
situation. 

3.1.4.7.3.2  Economic impacts 

From  an  economic  perspective,  scenarios  in  which  CFRP  will  be  collected  and  sent  to 
recycling can be assumed to result in higher treatment costs that will affect ATFs (dismantling 
and  transport  costs), shredders  or  PST  operators  (separation  and  transport  costs).  This  is 
probably the case for scenario CFRP 2 (in the moderate to long term). Though there could 
be recycling of this type under the baseline, scenario CFRP 1A and scenario CFRP 3 if 
there is a risk of not meeting the 3R targets, it would probably only be applied in facilities that 
treat larger volumes of CFRP- containing vehicles and that are located relatively near to a 
CFRP reprocessing facility. It is not clear how common such facilities are at present and thus 
a change in this direction would mainly be expected in the long term if at all. 

Under scenario CFRP 1A, OEMs would submit LCA data to justify the use of CFRP. These 
could be prepared inhouse or contracted to LCA practitioners. The cost per vehicle model is 
be assumed to be in the order –f 50 - 100 thousand Euro and is also assumed to cover the 
effort for preparing the data for submission to the type approval process. 

Scenario CFRP 1B is expected to have an impact on consumers that would purchase the 
same  vehicle  despite  the  change  in  the  vehicle  weight.  Such  consumers  would  incur 
additional  costs  for  fuel  consumption  throughout  the  vehicle  life  (2 %  more  according  to 
Dupont212). The change in the design of the vehicle will result in some costs for redesign for 
OEMs and can also be expected to result in slight benefits for waste operators resulting from 
an  increased  use  in  recyclable  material.  The  actor  depends  on  the  type  of  operator  that 
removes  the  additional  metal  and  sells  it  to  recyclers,  collecting  related  revenue.  The 
additional dismantling or removal costs are assumed to be negligible as various metals are 
already  removed  through  the  ELV  treatment  and  sent  to  separate  recycling  (for  the  ATF 
depending on profitability). 

212 See footnote 208. 

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3.1.4.7.3.3  Social impacts 

Scenario  CFRP  2  could  promote  the  development  of  recycling  capacities,  at  least  for 
materials that are more commonly used. This would lead to an increase in employment. 

Under scenario CFRP 1A, a low increase in employment can also be related to the need to 
perform  LCA  analysis  studies  as  part  of  the  3R  Type  approval  for  vehicles  with  non-
recyclables. 

Scenario CFRP 1B may also result in an increase in employment related to the necessity to 
redesign vehicles, however, this would only affect some models and would probably decrease 
as OEMs get used to the new 3R Type-approval requirements.  

3.1.4.7.4  Comparison  of  scenarios 

for  CFRP 

/non-

recyclables 

The differences in impacts of the scenarios as compared to the baseline are compiled in Table 
3-2 below to allow an easier comparison. All impacts are considered to be low, as CFRP is 
not used in most vehicles at present and, even with an increase, it is not the only option for 
light-weighting (e.g., aluminium is lightweight and recyclable). Nonetheless, the idea behind 
the measures is to address high volume use of non-recyclable materials in a way that shall 
ensure the conditions under which such materials can be used or, alternatively how they are 
to be treated at EoL and who is to carry the burden in such cases. 

Table 3-2  Summarising table for the comparison of the non-recyclables’ scenarios 

Impacts 

Scenario CFRP 1 

Scenario CFRP 2 

Scenario CFRP 3 

Type approval 

Increase 

CFRP1B: 
in 
revenues  from  sales  of 
recyclables. 

on ATFs 

+  

i

c
m
o
n
o
c
E

on Shredders  

On recyclers 

CFRP1A: -/- 

Shredders/PST 
operators  may  need  to 
develop  some  form  of 
treatment 
to  ensure 
targets  are  complied 
with,  expected  in  the 
long term if at all 

Between 0 to + 

Possible investments in 
recycling 
CFRP 
capacities 
time 
investment) expected in 
the long term. However, 
then set off by revenues 

(one 

between 0 and + 

266 

Increase  in  costs  for 
dismantling and storage 
of CFRP 

- 

-/-  

Possible 
set-off 
when/where  CFRP  can 
be  recycled,  moderate- 
to long-term 

Between 0 to + 

-/- 

-/- 

-/- 

Possible investments in 
recycling 
CFRP 
capacities 
time 
investment) expected in 
the long term. However, 
then set off by revenues 

(one 

Between 0 and + 

 
 
 
 
 
 
 
 
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Impacts 

Scenario CFRP 1 

Scenario CFRP 2 

Type approval 

Scenario CFRP 3 

on SME  

OEMs 

Consumers 

Administrative  costs 
Burden 

For ATF SME, the dismantling obligation (scenario CFRP 2) will likely result in 
higher costs. SMEs are understood to be common among waste operators, 
so any costs for these (ATF, shredder, PST, recycler) could have a heavier 
burden for SMEs. 

for 

Costs 
ensuring 
treatment / take-back of 
if 
non-recyclables 
required  by  EPR  (see 
below)  

for 

Costs 
ensuring 
treatment / take-back of 
if 
non-recyclables 
required  by  EPR  (see 
below) 

-/- 

-/- 

-/- 

-/- 

Design  costs  where 
vehicle  does  not  pass 
type approval  

CFRP1B:  2 %  increase 
in  fuel  costs  of  some 
vehicles. 

- 

costs 

Increased 
for 
OEMs  where  LCA  data 
submitted 
type-
approval  process  and 
for 
for 
authorities 
reviewing such data 

to 

2ndary resources  

Increase in SRM where 
non-recyclable replaced 
by recyclables  

in  SRM 

Increase 
in 
moderate-  to  long  term 
where 
recycling 
technologies develop 

Changes 
negligible 

considered 

Environmental  

+ 

CFRP1B: Increase over 
vehicle lifetime (~900 kg 
CO2 eq./vehicle)  

CO2 eq. emissions  

-  

+ 

-/- 

-/- 

CFRP1A:  no  change 
expected  but  benefit  of 
non-recyclable 
in  use 
phase ensured 

Increase 

CFRP1B: 
in 
credits  due  to  shift  to 
recyclables. 

+  

CFRP1A: 
baseline 

Negligible 

similar 

to 

Recycling credits 

In the mid- to long-term, 
recycling  will 
lead  to 
increase  in  credits  and 
circularity  

+ 

Similar to baseline 

Negligible 

Social  

Employment 

CFRP  1A  Increase  in 
employment 
for 
performing LCA 

Increase in employment 
for dismantling and new 
recycling capacities  

267 

Possible 
employment 

increase 

in 
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Impacts 

Scenario CFRP 1 

Scenario CFRP 2 

Type approval 

+ 

+ 

CFRP  1B  Increase  in 
employment 
for 
redesign 

+ 

Scenario CFRP 3 

PST 
capacities 
(expected in long term) 

Between 0 and + 

Proportionality  

Proportional  to  ensure 
that  vehicles  placed  on 
the  market  achieve  3R 
Targets 

Proportional  as  highest 
potential  to  encourage 
of 
recycling 
non-
recyclables 
/  use  of 
recyclables 

+ 

++ 

Assumed  proportional 
to  avoid  disposal  of 
non-recyclables 

+ 

Cost effectiveness  

Low  costs  but 
benefits 

low 

+ 

Higher effectiveness - 

High  costs  but  higher 
benefits 

++ 

Low  costs  but 
benefits 

low 

+ 

Coherence 

Stakeholder 
acceptance 

Not 
coherent  with 
Regulation  UN  ECE 
133, 
affect 
could 
movements  of  vehicles 
between  EU  and  non- 
EU countries 

-  

General coherence with 
waste 
legislation  and 
the  CEAP,  promoting 
waste  treatment  of  a 
higher  hierarchy  and 
circularity) + 

General coherence with 
waste 
legislation  and 
the  CEAP,  promoting 
waste  treatment  of  a 
higher  hierarchy  and 
avoiding disposal) + 

Various stakeholders have raised the problems related to the use of non-
recyclable materials and how this could affect the ability to achieve targets. 
Nonetheless, when asked if such materials should be prohibited, 
stakeholders state that this would have a negative impact on innovation. 
Waste operators generally have low acceptance to any change in the waste 
management as they fear it will increase their costs. 

Lower  acceptance  due 
to  costs  of  dismantling 
unclear 
with 
compensations 
and 
unclear  availability  of 
material outlets  

Lower  acceptance  due 
to  costs  of  PST  with 
unclear  availability  of 
material outlets 

Notes: 

-/-: no impact 

Costs or burdens: between 1 and 3 minus signs (-; --; or ---), indicating low (1 minus sign) and high (3 minus signs) costs or 
burdens 

Benefits or savings: between 1 and 3 plus signs (+; ++; or +++), indicating low to high savings 

(): brackets around symbols if costs, benefits etc. are only potentials or are uncertain. If the costs, benefits etc. are rather 
uncertain, a broader range is indicated: e.g. ++ to +++ or – to + 

n.a.: not applicable 

Looking  at  the  different  scenarios  and  the  impacts  detailed  in  the  earlier  sections,  a  few 
conclusions can be made: 

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•  Scenario CFRP 1 is considered to have a high relevance for ensuring that vehicles 

placed on the market comply with the 3R Targets and respectively that the 3R Directive 
is effective in this regard. It could affect the choice of materials for vehicles, however, at 
least promoting more use of the same materials in the long term, which in turn will 
promote recyclability. The cost of justifying a non-recyclable is low in relation to the 
removal of obstacles to market entry (though at present it is not clear whether type 
approval authorities actually deny market entry in such cases). The 3R Calculation itself 
will require some additional detail for non-recyclables, but the format for the calculation 
will remain the same, and the data is assumed to be available to OEMs and thus only 
slightly increases administrative burden of the process. The need to justify the use of 
non-recyclables based on environmental performance is expected to provide Type 
approval authorities a clear, black and white method for deciding on the granting of type 
approval in respective cases and to ensure the effectiveness of the 3R Directive in such 
cases. Though this scenario is not coherent with the international Regulation UN ECE 
133, the EC or MS could initiate an update of the Regulation or could decide to withdraw 
for this international regulation. It is not clear how this would affect the movement of 
vehicles from outside the EU inside (i.e., nor how often such vehicles are imported). 
Regarding exports, it is understood that the proposed changes would still fulfil the 
requirements of the UN ECE 133, but also fulfil requirements with higher ambition. Thus, 
it would be assumed that exports would not necessarily be impacted. This scenario has 
a positive effect also on measures that promote the recycling of metals in cases where 
non-recyclables will be substituted by those in redesign (e.g., steel, aluminium, etc.). 

•  Scenario CFRP 2 is the only one that is expected to potentially increase the 

recyclability of (some) non-recyclables, however, the costs for ATFs could be substantial 
(at least at the single vehicle level), particularly as long as recycling for such materials is 
not established. It is recommended to ensure that this scenario is also addressed under 
the future EPR, to ensure that ATFs are not the only ones to carry the costs related to 
non-recyclables. Currently, the use of large amounts of non-recyclables is still limited in 
the vehicle fleet, however, should this change without changes in the recyclability of 
such materials, the affect in terms of costs on ATFs will increase, possibly hitting the 
small facilities harder than the larger ones. 

•  Though scenario CFRP 3 will prevent disposal of non-recyclables, its potential for 

benefit is only set in the long term and does not necessarily guarantee a higher quality 
of treatment for non-recyclables. 

•  A combination of scenarios can be expected to have a higher positive impact on the use 
of non-recyclables in vehicles. In particular, the combination of scenario CFRP 1 and 2 
would also allow requiring the provision of data for non-recyclables to support 
dismantling, while also increasing the awareness to the size of the non-recyclable 
problem. For this latter aspect, it is noted that the requirement to provide separate data 
on recyclability/recoverability in the 3R type-approval calculation and to provide data on 
dismantlability should be linked to a threshold level of the total weight of non-recyclables 
(e.g., 10 kg). If the threshold is too low, the administrative burden will increase due to 
the need to report on each element (for example for use of e.g., sealing materials and 
glues which are used in very small quantities. Reference to a component threshold 
could result in manufacture of smaller components to circumvent the limitations for non-
recyclables. In addition, a weight threshold could be considered for components for 
which separate data is to be provided (e.g., 1 kg) otherwise sufficing to e.g., specify the 
total weight of CFRP components. This would also keep the administrative burden low. 

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EPR considerations: 

The dismantling of CFRP and other non-recyclables will increase costs for ATFs, at least as 
long as the recycling is not established. This is not just related to the dismantling itself but 
also to storage and, where/when capacities are available, to transport. It is to be seen whether 
the recycling is economically feasible. If not, compensation could be needed, with the related 
value  needing  to  be  investigated  in  the  future.  Possibly  of  more  importance  to  the 
development of vehicle EPR is the case of materials that cannot be recycled at the time of 
dismantling. Here it could be considered to compensate e.g., ATFs for storage costs, or to 
allow ATFs (or shredder/PST operators) that separate the non-recyclable fraction to require 
the OEM to collect and treat the material independently and at no cost to the ATF. 

3.1.4.7.5  Preferred  Scenarios  for  inclusion  in  final  policy 

options 

It is proposed to look at the three following measures for comparison under the various policy 
options: 

•  Revision of the 3R Type-approval rules regarding the calculation method for showing 

that the 3R Targets are complied with (including provision of data on dismantling of non-
recyclables above a minimum total weight),  

•  Revision of the 3R Type approval rules (including provision of data on dismantling of 
non-recyclables above a minimum total weight) in combination with an obligatory 
dismantling of non-recyclables and requirements for separate treatment. 

3.1.4.7.6  Reporting and monitoring requirements 

There is currently no monitoring of the 3R Type approval process. Instead of monitoring, this 
study considers introducing annual dismantling and shredder tests of 5 single (newly Type-
approved) vehicles with the aim of monitoring the “distance” between the calculations of the 
3R in type-approval applications and between the actual rate of reuse, recycling and recovery 
at  EoL.  Revision  of  the  3R-Type  approval  rules  addressed  under  the  analysis  for  non-
recyclables would not need further individual monitoring on an annual basis (also seeing as 
not all MS are active in checking 3R Type-approval submissions). However, periodic reporting 
(e.g.,  every  5  years)  from  MS  that  perform  3R  Type-approvals  may  help  in  understanding 
what type of non-recyclables are used in large volumes and could hinder compliance with the 
3R Targets.  

Reporting on the other measures investigated here should take place as part of the general 
reporting  on  materials  that  are  dismantled  and  sent  to  separate  recycling  (by  ATFs).  The 
effectivity  of  a  disposal  ban  could  be  measured  in  relation  to  the  general  reporting  on 
compliance  with  the  3R  Targets  as  well  as  reporting  that  is  under  consideration  for  PST 
facilities to better understand the available capacities in the EU.  

3.1.4.8  Analysis hazardous substances: measure 2.2a 

3.1.4.8.1  Baseline 

The baseline for comparison is the current split of prohibitions between ELV, restricting the 
use  of  four  heavy  metals,  and  the  REACH  Regulation,  where  other  restriction  applies  to 
specific products or applications. More specifically:  

•  ELVD:  

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o  Article  4  on  Prevention  of  the  ELVD  specifies  that  materials  and  components  of 
vehicles do not contain lead, mercury, cadmium or hexavalent chromium other than 
in  cases  listed  in  Annex  II  under  the  conditions,  e.g.,  on  maximum  concentration 
values  specified  therein.  It  further  specifies that the  Commission  shall  on  a  regular 
basis, according to technical and scientific progress, amend Annex II.  

o  As for further substance restrictions, it can be assumed from Recital 11213 and Article 
4(1)(a)214 that additional prohibitions could be justified in cases where a decrease or 
the  elimination  of  substances  in  ELVs  would  prevent  their  release  into  the 
environment, facilitate recycling and avoid the disposal of hazardous waste. However, 
further criteria or guidance on the process for listing are not specified. Therefore, the 
addition of new substance restrictions under the current ELVD is not anticipated.  
o  Exemptions for the  four heavy metals  are  listed  in  Annex II.  The  exemptions  cover 
certain materials and components of vehicles if the use of these restricted substances 
is unavoidable. Those materials and components of vehicles should be designated as 
such so that they can be stripped before further treatment; they shall be labelled or 
made identifiable by other appropriate means.  

o  The exemption mechanism under ELV is under the scrutiny of the EU COM that shall 
on a regular basis amend Annex II according to technical and scientific progress.  

•  Under REACH:  

o  Restrictions  adopted  under  REACH  envisage  the  amendment  of  Annex  XVII  of 
REACH  when  there  is  an  unacceptable  risk  to  human  health  or  the  environment, 
arising  from  the  manufacture,  use  or  placing  on  the  market  of  a  substance,  which 
needs to be addressed on a Union-wide basis as specified in Article 68(1) of REACH. 
Articles 69 – 73 of REACH define a procedure according to which – starting from a 
restriction  dossier  prepared  by  the  European  Chemicals  Agency  (ECHA)  at  the 
request of the Commission, or by a Member State – the Agency assesses and issues 
an opinion on the content and merits of the restriction proposed. If the requirements 
for  a  restriction  are  fulfilled,  Article  73  requires  the  Commission  to  prepare  an 
amendment of Annex XVII, which is decided upon via the regulatory procedure with 
scrutiny (comitology). Restrictions are listed in Annex XVII to the Regulation, which 
lists  specific  substances  or  groups  of  substances  and  where the text  of each  entry 
defines the specific scope of the restriction. 

o  Substances  of  very  high  concern  (SVHCs)  included  in  the  Authorisation  cannot  be 
placed on the market or used unless the use(s) of that substance on its own or in a 
mixture has been authorised.  

As  part  of  the  baseline,  it  is  acknowledged  that  REACH  is  under  review,  however,  it  is 
assumed that the revised chemical legislation following REACH when coming into force has 
mechanisms  compared  to  the  current  legislation  to  restrict  the  application  of  certain 
hazardous substances in various products/articles.  

213 (11) It is important that preventive measures are applied from the conception phase of the vehicle onwards and take the 
form, in particular, of reduction and control of hazardous substances in vehicles, in order to prevent their release into the 
environment, to facilitate recycling and to avoid the disposal of hazardous waste. In particular, the use of lead, mercury, 
cadmium and hexavalent chromium should be prohibited. These heavy metals should only be used in certain applications 
according to a list which will be regularly reviewed. This will help to ensure that certain materials and components do not 
become shredder residues, and are not incinerated or disposed of in landfills. 

214 Article 4 Prevention:  

1. In order to promote the prevention of waste, Member States shall encourage, in particular: 

(a) vehicle manufacturers, in liaison with material and equipment manufacturers, to limit the use of hazardous substances in 

vehicles and to reduce them as far as possible from the conception of the vehicle onwards, so as in particular to prevent their 
release into the environment, make recycling easier, and avoid the need to dispose of hazardous waste; … 

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3.1.4.8.2  Policy Options 

As mentioned above, the three alternative policy options are:  

•  POLICY OPTION 1A – RESTRICTIONS AND EXEMPTIONS UNDER REACH 
•  POLICY OPTION 1B – RESTRICTIONS AND EXEMPTIONS UNDER REVIEWED ELVD 
•  POLICY OPTION 1C – HYBRID APPROACH 

Policy Option 1a – Restrictions and exemptions under REACH 

The currently most comparable system with ELVD substance prohibitions for heavy metals is 
the REACH restriction mechanism where the use or presence of the restricted substance in 
specific applications is specified.  

Under this policy option:  

•  The  existing  restrictions  of  the  four  heavy  metals  as  well  their  exemptions  are  to  be 
transferred to Annex XVII of REACH during the legislative process. The exemptions are 
taken up as derogations for the new entries of the four heavy metals in Annex XVII. A 
regular review of the derogations is so far not foreseen under REACH but could result 
from the ongoing REACH revision.  

•  Further  restrictions  are  managed  exclusively  under  REACH  and  by  ECHA  under  the 

restriction procedure managed by ECHA.215  

•  There  are  limitations  in  the  current  REACH  restriction  procedure  with  regards  to 

application for and regular review of derogations.  
o  Application for derogation: During the 6 months “call for evidence”, concerned parties 
provide  information  that  affects  the  scope  of  the  restriction,  e.g.,  on  the  need  for 
derogations.  This  information  is  reviewed  during  the  opinion  making  by  RAC  and 
SEAC.  This  process  must  be  made  explicit  and  transparent  as  process  for  an 
exemption application.  

o  Regular review of derogations: At the moment, there is no automatic mechanism to 

review derogations (a change in a restriction entry requires a new restriction). 

In restrictions, spare parts should be addressed when relevant, as the restriction report 
addresses articles that were placed on the market before entry into force and spare parts 
produced after that. For both, derogations can be considered. 

• 

•  Changes have to be made in the ELVD to provide coherence with REACH:  

o  Article 4(2) of the ELVD needs to be adapted specifying the coverage of the substance 

restrictions by REACH.  

o  The  protection  of  human  health  should  be  added  in  Article  1  and  Article  4;  the 
protection of human health and the environment from the risks that can be posed by 
chemicals is the objective of REACH.  

•  Restrictions  under  REACH  are  currently  not  possible  solely  on  the  grounds  that  the 
substance negatively affects the re-use and recycling of materials in the product in which 
it is present.216  

215 See explanation under the Baseline; besides, the restriction procedure is specified here: 
https://echa.europa.eu/regulations/reach/restrictions/restriction-procedure  

216 The recent Proposal for a Regulation establishing a framework for setting ecodesign requirements for sustainable products 
(COM(2022) 142 final) introduces as additional criterion for substances of concern, if a substance “negatively affects the re-
use and recycling of materials in the product in which it is present.”  

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Policy Option 1b – Restrictions and exemptions under reviewed ELV Directive 

A revised ELVD where restriction and exemption mechanism would remain in the piece of 
legislation has to cover the following points:  

•  Changes have to be made in the ELVD to provide coherence with REACH: The protection 
of human health should be added in Article 1 and Article 4 (and in the relevant recitals) 
(“….the protection of human health and the environment from the risks that can be posed 
by chemical” (REACH wording) or “The use of hazardous substances in [vehicles] should 
be  restricted  in  order  to  protect  human  health  and  the  environment  and  to  reduce  the 
presence of such substances in waste” (wording in the new Battery Proposal a Battery 
Regulation).  

•  The procedure to restrict new substances for vehicles are defined comparable to the new 
Proposal for a Battery Regulation.217 Recital (17) of the Proposal explains the procedure 
follows:  
as 
“The  procedure  for  adopting  new  and  amending  current  restrictions  on  hazardous 
substances in batteries should be fully streamlined with Regulation (EC) No 1907/2006. 
To  ensure  effective  decision-making,  coordination  and  management  of  the  related 
technical,  scientific  and  administrative  aspects  of  this  Regulation,  the  European 
Chemicals  Agency  set  up  under  Regulation  (EC)  No  1907/2006  (‘the  Agency’)  should 
carry  out  specified  tasks  with  regard  to  the  evaluation  of  risks  from  substances  in  the 
manufacture and use of batteries, as well as those that may occur after their end-of-life 
as well as the evaluation of the socio-economic elements and the analysis of alternatives, 
in accordance with relevant guidance by the Agency. Consequently, the Committees for 
Risk Assessment and Socio-economic Analysis of the Agency should facilitate the carry-
ing  out  of  certain  tasks  conferred  on  the  Agency  by  this  Regulation”  (see  detailed 
requirement in the text box below).  

•  Comparably, this means that the assessment of the restriction dossier is carried out by 
ECHA, which would submit an opinion to DG ENV. Subsequent decision-making would 
be carried out by the Commission in consultation with a specific expert group under the 
waste legislation. The Commission would then adopt delegated acts: The restrictions are 
listed in Annex II of the reviewed ELVD via delegated acts. 

•  As the regular review of the Annex is foreseen under ELVD, a methodology needs to be 
defined. It seems consistent that the review is managed by ECHA based on the REACH 
restriction procedure. Another possibility for the review of derogations could imply that a 
simplified procedure could be envisaged (e.g., opinion prepared by ECHA experts without 
the  involvement  of  the  committees  instead  of  a  full  restriction  procedure  involving  the 
committees RAC and SEAC).  

Policy Option 1c – Hybrid approach 

The following option describes a hybrid approach where the substance restriction process is 
addressed  under  REACH  but  the  exemption  mechanism,  as  currently  not  comparably 
covered by REACH in term of regular amendments, remains under the ELVD. 

Elements in this policy option are:  

•  The restrictions of new substances in vehicles are managed under REACH and are listed 

in Annex XVII of REACH.  

217 COM(2020) 798 final 

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•  Existing restrictions of the four heavy metals and their exemptions remain in ELV. Their 
review and maintenance would still be done via delegated acts under the ELVD, with a 
view to their progressive elimination. 

•  The review of these exemptions would be supported by ECHA, inspired by the REACH 
restriction  assessment  process,  where  an  opinion  would  be  delivered  by  ECHA  to  DG 
ENV B3 for then amending annex II via delegated acts.  

•  The particularly important derogation on lead in lead-acid starter batteries to be addressed 

by the Batteries Regulation.  

•  Changes have to be made in the ELVD to provide coherence with REACH:  

o  Article 4(2) of the ELVD needs to be adapted specifying the coverage of the substance 

restriction by REACH.  

o  The  protection  of  human  health  should  be  added  in  Article  1  and  Article  4;  the 
protection of human health and the environment from the risks that can be posed by 
chemicals is the objective of REACH.  

To summarize, under the hybrid approach, besides the provisions regarding the four heavy 
metals policy option, 1a applies.  

3.1.4.8.3  Analysis 

Economic impacts 

Policy Option 1a – Restrictions and exemptions under REACH 

As  most  stakeholders  in  the  automotive  value  chain  have  to  follow  the  REACH  regulation 
anyway, a benefit in terms of less administrative burden is expected from needing to follow 
one legislation instead of two. However, the extent of this benefit cannot be determined. 

Generally, authorities are expected to save costs as there would not be the need to ensure 
coherence of REACH and ELV. It also applies to EU authorities, e.g., Commission and ECHA, 
that administrative costs incurred from running one system as compared to two are expected 
to be lower. Furthermore, as REACH is a regulation, the administrative burden for Member 
States can be expected to be lower because there is no need for a transposition to national 
law of changes regarding the exemptions from the prohibitions.  

Transition  costs  to  REACH  as  a  new  format  and  to  ECHA  as  executing  agency  are  not 
expected, as it would build on the preparation and running of restriction proposals that are 
already performed under REACH.  

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Policy Option 1b - Restrictions and exemptions under reviewed ELV Directive 

•  Transition costs to REACH as a new format and ECHA as executing agency are expected. 
The  Proposal  for  a  Regulation  concerning  batteries  and  waste  batteries  mentions  that 
“the ECHA will also support the Commission in managing battery substances and their 
regulatory restriction as part of the existing REACH activities. This requires a total of two, 
new full-time-equivalent (FTE) temporary-agent staff (AD 5-7) at the ECHA (average cost 
EUR 144 000/year over 7 years and beyond). In addition, one FTE contract agent (CA 
FG  III,  average  cost  EUR  69  000/year  over  3  years)  will  be  necessary to  increase the 
knowledge base, and to facilitate an informed priority setting and work plan. This work 
plan  should  be  based  on  a  study  to  build  the  ECHA’s  current  knowledge  on  how  the 
battery  industry  manages  its  hazardous  chemicals  to  identify  relevant  substances  for 
regulatory risk management in the future.” 218 

•  As for MS, the impact assessment for the Proposal for a Regulation concerning batteries 
and waste batteries219 concluded that “Member States will have greater clarity and lower 
administrative burden by dealing with the technical and socio-economic assessment of 
the proposals for restrictions under one single common assessment framework, provided 
by ECHA according to the methodologies developed for chemical risk management under 
REACH. This is very much in line with the “one-substance, one assessment” approach 
put forward in the upcoming Chemical Strategy for Sustainability. 
Industry will benefit from the high standards and procedural guarantees in carrying-out 
chemical  risk  assessments  given  by  the  REACH  restriction  processed  managed  by 
ECHA.” 

Policy Option 1c – Hybrid Approach 

Stakeholders would have to follow two legislations, however, as the known restrictions and 
exemptions are kept without any changes under ELVD, no increase of administrative burden 
is expected.  

As for future substance restrictions, the considerations of policy option 1 a applies.  

Social impacts  

Policy Option 1a – – Restrictions and exemptions under REACH 

There is an expected social benefit because reference to human health protection is added 
to  the  ELVD  and  will  be  considered  for  future  restriction  of  substances  in  vehicles.  A 
quantitative assessment of the possible reduction in the use of substances in vehicles due to 
human health concerns is not possible.  

Policy Option 1b - Restrictions and exemptions under reviewed ELV Directive 

Same considerations as for policy option 1a.  

Policy Option 1c – Hybrid Approach 

The same considerations as for policy option 1a applies.  

218 COM(2020) 798 final  

219 SWD(2020) 335 final PART 3/3  

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Environmental impacts  

Policy Option 1a – Restrictions and exemptions under REACH 

Equally, benefits for environmental health are expected if the future restriction of substances 
in  vehicles  is  clearly  located to  REACH  and  the  restriction  procedure  ensuring  that  further 
restrictions  are  set  up.  Such  restrictions  could  then  be  translated  in  reduced  emissions  of 
hazardous  substances  during  service  life  and  subsequently  in  waste  management.  The 
environmental  benefits  of  future  restriction  of  substances  in  vehicles  will  be  case  and 
substance specific.  

Policy Option 1b - Restrictions and exemptions under reviewed ELV Directive 

Same considerations as for policy option 1a.  

Policy Option 1c – Hybrid Approach 

For the provisions on the four heavy metals, it can be concluded the environmental benefits 
have  been  achieved:  An  ex-post  analysis  on  the  four  heavy  metals  shows  environmental 
benefits of past restrictions: lifecycle emission reductions between 2000 – 2005 for Pb were 
estimated at 99,6%, for Cd at 96% and for CrVI at 99,99%.220  

The applications of heavy metals for which exemptions are in place, these can be considered 
as being already narrowed down and provided with an expiry date. Remaining exemptions 
without  an  expiry  date  are  the  alloy  exemptions  1(a),  2(c)(i),  2(c)(ii)  and  3  and  special 
exemptions for lead in solders such as 8e and lead in glass or ceramic materials (exemption 
10(a) and 10(b)).  

For future substance restrictions under REACH, the environmental impacts depend on the 
(range of) applications in which substances to be restricted in the future are applied, as well 
as on the difficulty or ease of their substitution.  

Effectiveness, efficiency and coherence 

Policy Option 1a – Restrictions and exemptions under REACH 

A transfer of substance restriction under REACH would make use of the comprehensive and 
robust restriction procedure, which relies on the expertise of ECHA, according to a defined 
structure. Stakeholder participation via consultation is built into the process and managed by 
the Agency.  

in  place  under  REACH:  An  explicit  and 

With regards to efficiency, the exemption mechanisms must be raised as a point that is so far 
not 
for 
derogations/exemptions  for  a  specific  use  of  a  restricted  substances  as  well  as  the 
mechanism for a regular review of these derogations/exemptions is so far not in place under 
the REACH restriction procedure. As this is understood to have a focus in the REACH revision 
and the restriction procedure might be merged with the authorisation procedure, an explicit 
and  transparent  derogation/exemption  mechanism  with  regular  review  and  following  clear 
criteria might be installed. However, at this point this cannot be concluded with certainty.  

transparent  process 

to  apply 

Coherence  is  understood  to  be  established  as  all  provisions  regarding  substances  are 
covered by the REACH regulation.  

220 Oeko-Institut 2010 on behalf of ACEA 

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Policy Option 1b - Restrictions and exemptions under reviewed ELV Directive 

The new Proposal for a Battery Regulation221 is still under negotiation. It is understood that 
there are concerns that the proposal duplicates REACH provisions instead of simply referring 
to them. Against the background of the REACH revision, the provisions on the proposal might 
be  outdated  before  they  are  approved  in  case  that  the  REACH  restriction  procedure  is 
changed. This affects the option in terms of effectiveness and coherence.  

The  impact  assessment  for  the  Proposal  for  a  Regulation  concerning  batteries  and  waste 
batteries222 describes an increased efficiency because  

•  a restriction proposal can also be initiated by Member States,  
• 

it takes advantage of the expertise of ECHA and of its established Scientific Committee 
and public consultation procedures, to deal with the assessment of the risks and socio-
economic impacts of potential restrictions of substances, as this seems the most efficient 
approach currently available, also providing a unity of action with REACH as regards the 
methodologies and bodies entrusted with these tasks,  

•  a  specific  focus  of  policy  analysis  envisaged  in  decision-making  under  the  Batteries 
Regulation  is  possible,  not  further  saturating  the  subsequent  decision-making  process 
under REACH.  

It is important to note that battery-related derogations/exemptions from the restriction of sub-
stances  did  not  need  many  reviews  or  changes  over  time.  In  contrast,  vehicles  are  more 
complex  in  design,  the  development  of  the  ELVD  annex  for  exemptions  suggests  that 
changes will be needed more often to ensure adaption to scientific and technical progress 
and to ensure a gradual elimination of restricted substances. It has to be made clear in the 
revised  ELVD  if,  for  example,  Member  States  are  also  allowed  to  initiate  the  review  of  a 
restriction proposal or if a methodology for a regular review is to be introduced. However, it is 
not yet possible to fully assess the legal feasibility of both options and to determine to which 
preference shall be given.  

Policy Option 1c – Hybrid Approach 

In  the  interviews  conducted  in  the  course  of  this  impact  assessment,  stakeholders  often 
mentioned  the  option that the  current restrictions  of the  four heavy  metals  as  well  as their 
exemptions can remain under ELVD, as this could be seen as a discontinued model with only 
a few remaining exemptions.  

As the future and additional substance restrictions would be work described in policy option 
1b, the considerations on effectiveness and efficiency also apply here.  

3.1.4.8.4  Summary and conclusion 

Under all policy options, the restriction procedure under REACH is the assessment procedure 
to  which  reference  shall  be  made.  Therefore,  the  policy  options  are  largely  equivalent. 
However, the possibility under policy option 1b and 1c is to preserve the specificity and policy 
focus  that  results  from  keeping  decision-making  under  a  separate  instrument  (the  ELVD). 
This advantage was a rationale for the new Proposal for the Battery Regulation to introduce 
this  system.  However,  it  should  be  noted  that  this  proposal  is  still  negotiated,  so  that  this 
system serving as a template is so far not finally approved.  

221 COM(2020) 798 final 

222 SWD(2020) 335 final PART 3/3  

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Besides, under these policy options, the concern of a duplication of REACH provisions that 
might  be  revised  should  be  avoided.  Otherwise,  this  policy  options  bear  the  risk  of  being 
incoherent.  

A  crucial  point  to  decide  in  favour  of  one  of  the  policy  options  concerns  the  exemption 
mechanism and the regular review derogations/exemptions for a specific use of the restricted 
substances.  However,  under  all  three  policy  options,  uncertainty  remains  if  such  a  regular 
review of the derogations/exemptions can be installed as a formalized and explicit process. 

If the REACH revision results in an amendment of the restriction procedure that foresees the 
review of derogations of restrictions after a default period, or a period individually determined 
for the derogation, this would support the choice of policy option 1a.  

3.1.4.9  Analysis hazardous substances: measure 2.2.b 

3.1.4.9.1  Baseline 

The following points describe the current baseline:  

•  The SCIP database is in place and manufacturers submit data; so far, recyclers practically 
cannot  use  the  information.  However,  there  is  an  impact  assessment  for  the  WFD 
currently ongoing and the outcome in relation to SCIP is pending.  

•  No major changes are expected as to how manufactures submit data to GADSL/IMDS.  
•  REACH will be revised, but the information requirements on SVHC in products/articles 

are not expected to change.  

•  The  ESPR  is  still  under  negotiation  with  unpredictable  outcome  regarding  the  final 
provisions  on  reporting  on  substances  of  concern  in  products  when  ESPR  enters  into 
force.  

3.1.4.9.2  Policy Options 

For  this  measure,  no  policy  options  are  considered.  The  measure  can  be  implemented  in 
different  schemes,  the  schemes  of  SCIP  and  Product  Passport  being  subject  to  different 
legislations.  While  the  schemes  are  described  and  compared  with  each  other,  much 
uncertainty  is  expected  as  the  related  legislations  are  under  discussion  for  revision  and 
amendments (REACH) and further development (ESPR).  

3.1.4.9.3  Analysis 

The  following  analysis  describes  the  potential  impacts  of  the  measure  2  “improved 
communication on hazardous substances” for the three information schemes:  

•  Via  the  SCIP  database as  a  centralised  European  Database  which  would  need further 
development and adaptations in order to provide relevant dismantling information to the 
waste treatment facility.  

•  Via  an  industry-driven  system  based  on  GADSL/IMDS,  for  example,  which  would  also 
need adaptations to provide the relevant dismantling information to the waste treatment 
facility.  

•  Via  a  Digital  Product  Passport  (DPP)  which  is most  likely  based  on  a  decentralised IT 
architecture,  as  defined  in  the  Proposal  for  a  Regulation  establishing  a  framework  for 
setting Ecodesign requirements for Sustainable Products (ESPR).  

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Economic impacts 

The measure would impose additional administrative burden on industry due to the increased 
information  to  be  reported,  compared  to  the  current  baseline,  and  defined  by  the  SVHC 
reporting obligations to the SCIP database. For an improved communication proposed in this 
measure, the SCIP database would need further development of the database. This would 
impose burdens for public administrations, particularly the European Commission and ECHA 
in terms of IT development and infrastructure as well as management and maintenance.  

Experience in the setting of the SCIP database223 indicates potential one-off adaptation costs 
running into the several million Euros over several years, and a permanent increase in the 
fixed maintenance and the operational costs of the database. 

The  stakeholder  feedback  indicates  that  the  GADSL/IMDS  data  format  would  need 
adaptations  that  result  in  administrative  and  economic  burden  for  industry  with  regard  to 
enabling  treatment  facilities  to  use  the  relevant  information.  It  is  expected  that  this  would 
require significant investment for adapting IT systems etc. Stakeholders from industry roughly 
estimated  that,  since  the  establishment  of  GADSL/IMDS  25  years  ago,  an  investment  of 
“dozens  of  millions  of  €”  has  been  made,224  which,  however,  served  to  meeting  the 
requirements  of  various  legislations  and  contributed  to  maintenance  which  is  a  common 
industry activity on which a magnitude of time and costs are spent. 

Stakeholders have expressed views on the SCIP as well as on an extension of the GADSL 
and IMDS:  

•  For  the  SCIP  database,  individual  stakeholders  noted  in  the  interviews  that  the 
notifications in SCIP are not scrutinized and thus questioned the reliability of the entries.225 
Besides,  the  SCIP  platform  for  hazardous  substances  currently  does  not  serve  waste 
management  purposes  because  it  does  not  match  with  the  needs  of  the  recycling 
industry.226 

•  Half of the answers of stakeholders to interactive questions asked during the stakeholder 
meeting  indicated  that  OEMs  document  data  on  the  content  of  GADSL  substances  in 
vehicles and components through the parts list of the vehicle (i.e., linked to the VIN).227 
The BMW Group explains that the “information on the content of GADSL substances in 
vehicles and components is linked to part numbers, not to vehicles; a linkage to the VIN 
number is seen as an unreasonable effort, due to millions of potential variations (and due 
to the  fact, the  vehicle  owner may  have  changed  parts,  which  cannot  be  considered)”. 
The Renault Group also explains that “it is possible to extract indirectly a maximizing list 
of GADSL substances for a given vehicle i.e., a list of substances, corresponding to an 
"envelope vehicle" that would contain the parts of all possible versions of a model (i.e., 
not  the  exact  list  of  substances  actually  contained  in  a  given  vehicle/VIN).”  Thus, 
according  to  the  stakeholders,  the  current  form  of  the  GADSL/IMDS  would  need 
adaptation to meet the requirements of the proposed measure.  

223 Citation from John Garcia in impact assessment of the PPWD.  

224 Interview Stellantis/Opel  

225 EUROMETEAUX interview 

226 ACEA interview.  

227 On the Slido question “Is it correct to assume that OEMs document data on the content of GADSL substances in 
vehicles and components through the parts list of the vehicle (i.e., linked to the VIN)?”: 13 individuals answered this 
question. Only a single answer was possible. Almost half of the participants think the assumption is correct. The rest did not 
have an opinion (I don’t know”).  

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Although an estimation on the DPP as further information scheme cannot be made, the impact 
assessment of the ESPR stated that substantial efforts and investment are also needed to 
put such a system in place. 

Social impacts  

No specific social impacts are expected to be linked to this measure, apart from the fact that 
stakeholders will have to dedicate additional resources to the notification.  

If  the  objective  of  the  measure  was  reached,  additional  jobs  in  the  recycling  sector  could 
potentially be assumed. Additionally, the provision of data on legacy substances – which is 
deemed to be possible – would in some cases make it easier to remove these substances 
from the material cycle, leading among others to health benefits. 

Environmental impacts  

According  to  stakeholders,  SCIP  in  its  current  form  is  not  expected  to  contribute  to  the 
environmental  benefits,  as  it  is  not  practical  for  waste  management  operators  to  retrieve 
information  on  the  localisation  of  hazardous  substances.  A  potential  improvement  in 
environmental  performance  of  waste  management  facilities  is  one  aim  of  the  measure  to 
achieve better sorting and lower losses of material quantity or material quality. In cases where 
depollution is possible, impacts could be quantified in tonnes of avoided emissions.  

Effectiveness, efficiency and coherence 

The effectiveness of this measure would also depend on the extent of hazardous substances 
that is covered by the database. As e.g., the existing SCIP database only covers substances 
of  very  high  concern  identified  under  REACH,  whereas  GADSL  and  IMDS  cover  more 
substance groups and individual substances, the latter should be considered more effective. 
The ESPR defines substances of concern in a way that also allows restricting a substance 
when it “negatively affects the re-use and recycling of materials in the product in which it is 
present”.  Although  this  is  not  further  specified,  it  can  be  assumed  that  a  wider  extent  of 
substances might be addressed under ESPR as compared to GADSL/IMDS. Thus, regarding 
coherence,  the  three  information  schemes  refer  to  different  policy  requirements;  whereas 
SCIP is based on the notification requirement of REACH Article 33, GADSL/IMDIS includes 
this, and further voluntary reporting and the DPP rely on Ecodesign.  

The  efficiency  of  the  information  schemes  cannot  be  compared  here,  as  the  ESPR  and 
especially the DPP has not been developed yet: Article 10 of the Commission’s proposal for 
a  regulation  on  eco-design  for  sustainable  products  envisages  the  adoption  of  an 
implementing act establishing the detailed technical rules for the design and operation of the 
product  passport.  The  impact  assessment  of  the  ESPR  states  on  the  DPP:  “Given  the 
developments pending in this area, it is not possible, and premature, to assess the impacts 
that relying on such a system could have.”  

3.1.4.9.4  Summary and conclusion 

Under  all  options  for  practical  implementation  and  against  the  background  of  the  dynamic 
around the ESPR and DPP, we consider this measure as being premature at this point of 
time. Instead, it should be re-examined at a later stage in the context of a vehicle product 
passport, where the objective of e.g., a full material and component declaration is addressed 
in  a  broader  context  of  data  flow  and  data  access.  Thus,  making  a  statement  about  the 
potential administrative burden or environmental savings as a result of this measure would 
be highly speculative at this point of time. 

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3.1.5  Analysis for steel 

3.1.5.1  Qualitative analysis for steel 

Six measures were shortlisted for steel including the following measures: 

No JH 

Title 

2.1B 

2.1B 

2.3A1 

2.3C 
Possible 
alternative 

2.3.e) Establish provisions to support the market of used spare parts 
composed of steel 
2.3.f) Set up a separate (monitoring) target for re-use/preparing for re-
use/remanufacturing of steel components 
2.4.b) Making it mandatory to remove certain copper parts before 
shredding to encourage high quality steel/aluminium and high quantity 
copper recycling  
2.4.c) Set material-specific recycling targets for steel 
2.4.d) Regulate shredder/post shredder facilities to ensure high 
quality/quantity of materials obtained for recycling and to improve final 
treatment process 

Chapter 
2.1.5.3.5 

2.1.5.3.6 

2.1.5.4.2 

2.1.5.4.3 
2.1.5.4.4 

Colour code: Red – discarded, Yellow – premature, Grey – supporting measure 

•  Measure  (2.2.f)  about  the  monitoring  of  components  for  reuse/remanufacturing  would 
require provisions aimed to increase the demand of such components containing steel 
(e.g., bumpers, and fenders).  

•  The removal from the vehicles of components with a high content of steel and sending 
them to separate recycling would limit the ‘poor quality’ of obtained recycled steel, i.e., 
where the removed components is composed of a steel alloy with low levels of impurities. 
However, (FEAD 2022) expects that separate recycling of steel parts (prior to shredder) 
would have a small impact on the quality of secondary steel. Hence, mandatory removal 
of steel parts is thus discarded at this stage but could be reconsidered in the future if the 
implementation of other measures does not lead to a sufficient improvement in circularity.  
•  A  number  of  studies  show  copper  contamination  in  end-of-life  scrap  posing  a  future 
metallurgical problem in the global steel recycling (more details in section 2.1.2.5.1). Also, 
EUROFER  refers  to  copper  as  an  impurity  in  steel  which  can  affect  the  portfolio  of 
applications  in  which  secondary  steel  can  be  applied.  The  removal  of  electronic 
components and cables (wire harness) prior to shredding is raised as one option to limit 
such  impurities.  Thus,  mandatory  removal  of  certain  copper  parts  before  shredding  to 
encourage high-quality steel recycling is considered. This measure is linked to analysis 
of copper (section 3.1.6). This measure shall encourage high-quality steel recycling as 
well as higher copper recycling. However, mandatory removal of parts can promote reuse 
as well when removed part will not be recycled but instead reused. 

•  Regulation  of  shredder/post-shredder  facilities  and  especially  the  standardisation  of 
deliverables from these facilities could lead to the improvement of existing technologies 
or  the  promotion  of  the  dismantling  of  reusable  components  prior  to  shredding. 
Additionally, setting standards on the Cu-concentration in steel scrap would support high-
quality steel recycling. Thus, this measure is considered in further analysis.  

•  A separate recycling target for steel, since the recycling rate of this material is currently 
rather high, up to 90 % is discarded from further analysis. Also, according to (EUROFER 
2021a), “the only compulsory target shall always refer to the weight of the entire vehicle. 
The information about the recycling of specific fractions or materials recovered from ELVs 
shall  be  complementary  information  to  better  check  the  legislation's  functioning  and 
support the automotive industry in improving the design of their vehicles.” 

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3.1.5.2  Scenarios for quantitative analysis  

3.1.5.2.1  Baseline Steel 

Throughout the  EU,  the commonly  applied  methods to  treat steel  from  ELVs  are  shredder 
operations,  usually  combined  with  some type  of  post-shredder treatment  operations.  Steel 
scrap  obtained  from  shredder/PST  facilities  is  generally  used  by  steelmakers  to  make 
construction products, such as reinforcing bars, which do not require high-quality steel (e.g., 
purity). Only a limited part of steel originating from ELVs can be recovered in the production 
of new vehicles. 
According to the various stakeholders, the recycling rate of steel from the ELVs is rather high, 
90 %.  
On this basis, it is assumed that under the baseline, steel shall continue to be treated mainly 
in shredder/PST facilities, achieving a similar level of recycling.  

3.1.5.2.2  Scenario  Steel  1:  Monitoring  of  components 

composed of steel for reuse/remanufacturing 

this  scenario 

the  monitoring  of  components  composed  of  steel 

Under 
for 
reuse/remanufacturing  shall  be  introduced.  For  this  purpose,  a  list  of  components 
recommended for reuse/remanufacturing (Annex to ELVD) would be defined. The preliminary 
list prepared in this report contains also elements made of steel, e.g., engines, bumpers. This 
list should be revised from time to time to consider the current market situation of components 
for reuse and remanufacturing.  
The  list’s  review  should  also  consider  the  new  technological  solutions  that  promote 
remanufacturing  as  a  way  of  processing  components  from  ELVs.  An  example  is  the 
remanufacturing  process  that  converts  waste  sheet  steel  (WSS)  from  the  exterior 
components of ELVs into value-added mesh steel sheet (MSS) as a sustainable end-of-life 
strategy as an alternative to recycling the recovered steel by smelting (Abdullah 2021).  

This scenario also considers implementation of harmonised monitoring of components that 
have been removed for reuse/remanufacturing to understand the actual volume of reuse in 
different MS and will enable the comparability of monitoring data. Obtained information will 
allow a better understanding of the potential for reuse and how it is influenced by measures 
that affect market demand. It will also help in the future in the revision of the list of removed 
spare  parts  as  well  as  to  potentially  set  out the targets.  The  reporting  obligation  would  be 
limited to the components listed in the Annex to ELVD (“list of components recommended for 
reuse/remanufacturing”).  However,  separate 
for 
reuse/remanufacturing  could  also  be required though  it may  create  a  burden for  ATFs  if  it 
cannot be linked to an existing list of sales. 

reporting  on  components  sold 

3.1.5.2.3  Scenario  Steel  2:  Market  support  of  used  spare 

parts composed of steel 

Under this scenario the market demand for spare parts should be regulated by requiring car 
repair shops to provide customers with an offer to repair a vehicle with used/remanufactured 
components alongside offers for repair with new components. Insurance companies will also 
be obliged to offer car owners discounted policies if they agree that repairs are performed 
with reused/remanufactured parts when these are available. Furthermore, a ban on the online 
sales of illegally operating facilities would be introduced.  

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Use  of  spare  parts  is  market  driven,  and  increasing  demand  is  assumed  to  provide  more 
flexibility  to  ATFs  to  decide  on  components  to  be  dismantled  as  opposed  to measures  for 
increasing supply which could result in a high burden for storage without significant impact 
on  the  actual  reuse/remanufacturing  of  components.  Obligations  for  insurance  companies 
may only be implementable through national legislation. Strengthening the market demand 
for  reused  components  will  increase  the  profitability  of  dismantling  relevant  components. 
Provisions  on  online  sales  will  reduce  sales  of  used  components  from  illegally  operating 
facilities, increasing profitability of legally operating ones. Again, these provisions may only 
be implementable through national legislation.  

3.1.5.2.4  Scenario  Steel  3:  Mandatory  removal  of  certain  copper  parts  before 
shredding to encourage high quality steel/aluminium recycling and high 
quantity copper recycling 

A dismantling obligation for copper-bearing components is already provided by the ELVD, but 
only if the copper is not segregated in the shredding process.  

The  copper  contained  in  vehicles  is  about  60%  in  the  cable  harness  and  in  engines,  e.g., 
ventilation  and  heating  (Argonne  2021).  While  a  separation  of  the  large  electric  motors  is 
effectively  possible  after  shredding,  the  separation  of  increasingly  fine  and  more  widely 
distributed cable strands can only be realised with considerable effort.  

For instance, the Japanese ELV system contains provisions that dismantlers when they want 
to send ELV directly to the electric furnaces without shredding process, are allowed to do it, 
under the condition that copper contents are reduced to max 0.3%. In consequence they have 
to  remove  the  wire  harness  from  ELVs.  Like  this,  Japanese  dismantlers  remove  them  by 
operating heavy machinery.228  

(Russo  et  al.  2002)  carried  out  several  trials  to  analyse  the  influence  of  the  dismantling 
parameter on scrap quality, with special focus on tramp elements, like copper. The results 
show that removal of the engine has a direct effect of removing 62 % of the copper present 
in  the  car,  thus  the  total  copper  removal  from  car  to  shredder  scrap  is  thus  90 %,  to  be 
compared  to  only  71.5 %  without  prior  dismantling.  The  study  proved  that  engine  removal 
leads  to  the  possibility  of  producing  shredded  scrap  with  a  copper  level  of  around  0.1 % 
(without dismantling of the engine it would be on the level of 0.28 %).  

Copper content in steel scrap destined for recycling is considered an impurity of steel and 
may affect the portfolio of applications in which secondary steel can be applied (EUROFER 
27.10.21).  

Thus, removal of electronic components and cables (wire harness) prior to shredding is an 
option to limit such impurities and is a part of this scenario.  

3.1.5.2.5  Scenario Steel 4: Regulate shredder/post-shredder facilities to ensure 
high quality/quantity of materials obtained for recycling and to improve 
final treatment process 

The  intention  of  this  scenario  is  to  ensure  high  recovery  of  metals  from  the  shredder/PST 
residues. It aims also to obtain high-quality recycling output from these treatment plants. To 

228 https://www.gov.scot/binaries/content/documents/govscot/publications/progress-report/2013/12/remanufacture-
refurbishment-reuse-recycling-vehicles-trends-opportunities/documents/00440543-pdf/00440543-
pdf/govscot%3Adocument/00440543.pdf 

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obtain the goal, a legally binding maximum metal content for shredder residues229 should be 
set up at an ambitious level in order to recover as many metals as possible as secondary raw 
materials  and  it  should  be  oriented  towards  the  best  available  technical  practices.  The 
removal of metal from the shredder light fraction at least to below 1 % metal content by means 
of post-shredder separation (Tabel et al. 2011) is considered to be feasible for this purpose. 

On  the  other  side  copper  content  in  steel  scrap  destined  for  recycling  is  considered  an 
impurity of steel and may affect the portfolio of applications in which secondary steel can be 
applied (EUROFER 27.10.21).  

The full implementation of this scenario would require setting up a maximum copper content 
in  steel  scrap230  (output  from  shredders/PST)  that  is  sourced  from  recycling,  possibly  by 
means  of  a  European  standard,  e.g.,  currently  under  development 
is  “European 
standardisation  deliverables  on  Road  vehicles  –  Post-shredding  recycling  –  design-for-
recycling guidelines for plastic products”231. 

For more information, please refer to the information on copper in the current situation chapter 
and measure description (2.1.2.5.2 and 2.1.5.4.2). 

3.1.5.3  Results of qualitative analysis  

Scenario  Steel  1  and  Steel  2  are  intended  to  increase  the  reuse/remanufacturing  level  of 
components in ELVs incl. those containing steel. Scenario Steel 1 in a way intends to increase 
the  attention  of  ATF  to  component  reusability  as  well  as  supporting  the  policy  maker  in 
understanding the situation of the market of components, potentially dismantled and reused. 
On the other hand, scenario Steel 2, includes legally binding obligations for both ATFs and 
insurance companies, and it is expected that level of dismantling will increase more under 
scenario Steel 2 than under Steel 1 due to the expected increase in demand for reused parts.  

However, implementation of the scenario Steel 2 requires legal adjustments mainly at national 
level,  which  may  affect  its  implementability  by  all  Member  States.  Both  scenarios  would 
require  development  of  administrative  support  in  terms  of  i.e.,  monitoring/reporting.  For 
dismantled (relatively) pure steel sheets (with no copper contamination), both scenarios are 
expected to potentially increase the level of high-quality recycling. Where it is not possible to 
reuse/remanufacture  components  that  have  already  been  dismantled,  they  can  be  sent  to 
separate recycling, avoiding shredder process.  

Scenario Steel 3 refers to dismantle copper-bearing components prior shredding. This would 
require  additional  steps  before  shredding  and  will  lead  to  additional  costs  for  ATFs. 
Dismantling could be done manually or automatically, for parts that are easily accessible. The 
copper  contained  in  vehicles  is  about  60%  in  the  cable  harness  and  in  engines,  e.g., 
ventilation and heating. As already highlighted before, Cu-contamination in steel scrap limits 
the applicability of this scrap.  

In  addition  to  increased  steel  scrap  quality,  dismantled  components  might  be  shifted  for 
reuse/remanufacturing, as  well  as  more  copper (or  other  materials)  would  be  available  for 
(high-quality) recycling. Scenario Steel 4 aims to obtain: 1) a higher quantity of metals (ferrous 
and non-ferrous) for recycling, 2) a high-quality steel scrap for recycling.  

229 destined for backfilling/ landfill construction, energy recovery/ incineration or final disposal/landfill sites 

230 More on possible max value under description of measure. 

231 
file:///C:/Users/I65A1~1.KOS/AppData/Local/Temp/Draft%20standardisation%20request%20as%20regards%20medical%20d
evices%20and%20in%20vitro%20diagnostic%20medical%20devices.pdf  

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introduction  of 

this  provision  would  require  regular  checks  of 

The 
the  obtained 
outcomes/residues  from  shredder.  The  monitoring  under  this  scenario  would  require 
development of a harmonised testing approach. This can be done twofold: either by shredder 
or by recycler. The testing of the steel scrap samples is less precise as chemical analysis of 
smelted input material to EAF. However, material put into EAF normally comes from different 
sources, what might challenge to assess the composition of each input material separately 
(this issue requires further investigation).  

Reporting on the steel scrap quality would also involve development of a reporting scheme 
that to submit by facilities (shredders/recycler) the monitoring results to the authority to be 
responsible for controlling.  

There are two possible actions once the results of monitoring are not satisfactory: 

1) the authorities could develop local/regional/national strategies to improve the situation, by, 
e.g., introduction of mandatory dismantling of parts that contain copper before shredding (if 
not implemented yet).  

2) modulation on price for steel scrap for recycling.  

3.1.5.4  Results of quantitative analysis  

The calculation of potential environmental impact is based on the model (described in detail 
in Annex I 6.9). The following tables show assumed treatment routes for the steel fraction that 
would potentially be available in the collected ELVs in 2035. For instance, a different share is 
assumed  to  be  dismantled  in  each  scenario.  In  scenario  Steel  3  and  4  the  share  of 
components  for  reuse/remanufacturing  is  the  same,  however  in  scenario  3  and  4  less  of 
dismantled steel is sent to shredder and thereafter to the recycler (it is assumed that provision 
on  mandatory  removal  and  PST/shredder  regulation  will  support  separate  recycling). 
Additionally,  in  scenario  Steel 3  and  4,  a  higher  share  of  dismantled  steel  is  sent  to  the 
recycler  directly  (skipping  the  shredding  process)  in  contrary  to  other  scenarios.  High 
dismantling is assumed in order to see how the environmental benefits could change when it 
is required to dismantle more components prior shredding or when Cu-content threshold is 
put  on  steel  scrap  in  order  to  obtain  the  outputs  from  shredder/PST  facilities  in  sufficient 
quality. 

The  following  table  specifies  the  rates  that  have  been  assumed  for  each  scenario  as 
dismantled,  reused,  recycled  pre-  or  post-shredder,  recovered,  or  lost;  and  with  which 
quantitative impacts have been calculated.  

Table 3-3  Routes of treatment for steel under the various scenarios  

Baseline  Scenario 1 

Dismantled -> 
reused/remanufactured 
Dismantled -> recycled (no 
shredding) 
Dismantled -> shredded -> 
recycled 
Shredded -> recycled 

Losses/process 
inefficiencies 

10% 

2% 

2% 

75% 

12% 

15% 

4% 

4% 

65% 

11% 

Scenario 2  Scenario 3  Scenario 4 
18% 

18% 

18% 

7% 

7% 

57% 

10% 

13% 

4% 

54% 

10% 

18% 

4% 

50% 

10% 

Based on this description and the shares specified in Table 3-3, in the baseline and in each 
scenario,  the  amounts  that  would  be  reused/remanufactured  as  well  as  recycled  pre-  and 

Source: Oeko-Institut: own assumptions 

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post-shredder  were  calculated  (Figure  3-2).  The  total  mass  of  steel  in  EoL  vehicles  is 
assumed to be about 6 130 Mt in 2035. 

Table 3-4  Tonnes of steel from collected ELVs assumed to be either reused or 
recycled and losses of the material in the treatment process (in 2035) 

Total of the material in EoL vehicles (without 
battery) [tonnes] 
Total of the material in EoL vehicles (without 
battery) 
In components for reuse/remanufacturing 

Recycled material of potentially higher quality 
(Directly recycled, no shredding) 
Recycled material after shredding (incl. Steel 
in tyres) 
Losses/process inefficiencies (Direct 
recycling) 
Losses/process inefficiencies (Shredder; incl. 
Steel in tyres) 
Losses/process inefficiencies (Recycling; incl. 
Steel in tyres) 

Baseline 

Scenario 1  Scenario 2  Scenario 3  Scenario 4 

6,113,500 

6,113,500 

6,113,500 

6,113,500 

6,113,500 

611,300 

917,000 

1,100,400 

1,100,400 

1,100,400 

107,600 

269,000 

430,400 

807,000 

1,076,000 

4,686,900 

4,260,800 

3,941,300 

3,568,500 

3,302,100 

14,700 

36,700 

58,700 

110,000 

146,700 

53,800 

48,900 

45,200 

41,000 

37,900 

639,100 

581,000 

537,400 

486,600 

450,300 

Table 3-5  Change in tonnes of materials for recycling comparing to the baseline ["-" 
decrease, "+" increase] (in 2035) 

Change in tonnes of materials for recycling 
comparing to the baseline  
["-" decrease, "+" increase]  
Recycled material of potentially higher quality 
(Directly recycled, no shredding) 
Recycled material after shredding (incl. Steel 
in tyres) 

TOTAL 

Baseline 

Scenario 1  Scenario 2  Scenario 3  Scenario 4 

161,400 

322,800 

699,400 

968,400 

-426,100 

-745,600 

-1,118,400 

-1,384,800 

-264,700 

-422,800 

-419,000 

-416,400 

Figure 3-2  Tonnes of steel from collected ELVs assumed to be either reused or 
recycled and losses of the material in the treatment process (in 2035)  

Source: Own illustration  

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3.1.5.4.1  Environmental impacts 

To calculate potential environmental impact for each scenario, the masses of steel (Figure 
3-2)  were  multiplied  by  the  respective  environmental  impacts  in  terms  of  global  warming 
potential  (GWP).  For  recycled  steel  a  corresponding  credit  is  given,  for  the  losses  an 
environmental  burden  is  calculated  which  results  from  the  disposal  of  these  losses.  The 
results are shown below for all steel from ELVs collected in the year 2035 (Figure 3-3).  

Table 3-6  Credits for Global warming potential (GWP) for each scenario for steel in 
collected ELVs in 2035 to primary production (Mt CO2eq) 

Environmental impact in GWP [Mt CO2-eq.] ["-" environmental 
credits,  
"+" environmental burdens] 
In components for reuse/remanufacturing 

Recycled material of potentially higher quality (Directly recycled, 
no shredding) 

Recycled material after shredding (incl. Steel in tyres) 

Losses/process inefficiencies (Direct recycling) 

Losses/process inefficiencies (Shredder; incl. Steel in tyres) 

Losses/process inefficiencies (Recycling; incl. Steel in tyres) 

TOTAL 

Baselin
e 

Scenari
o 1 

Scenari
o 2 

Scenari
o 3 

Scenari
o 4 

-
1,295,30
0 

-
1,943,00
0 

-
2,331,60
0 

-
2,331,60
0 

-
131,700 
-
5,677,70
0 

-
329,100 
-
5,161,60
0 

-
526,600 
-
4,774,50
0 

-
987,400 
-
4,322,80
0 

-
2,331,60
0 
-
1,316,60
0 
-
4,000,20
0 

33,800 

30,700 

28,400 

25,700 

23,800 

7,600 

7,600 

7,600 

7,600 

7,600 

410,700  388,000  374,500  374,800  375,000 
-
7,242,00
0 

-
7,222,00
0 

-
7,007,00
0 

-
7,234,00
0 

-
6,653,00
0 

Table 3-7  Change in tonnes of materials for recycling comparing to the baseline ["-" 
decrease, "+" increase] (in 2035) 

Change in Mt CO2-eq. comparing to the baseline  
["-" decrease, "+" increase] 

Recycled material of potentially higher quality 
(Directly recycled, no shredding) 
Recycled material after shredding (incl. Steel in 
tyres) 
TOTAL for recycling (excl. reuse and burdens due 
to losses/process inefficiencies) 
TOTAL of the whole process steps (e.g. reuse, 
recycling, etc.) 

Baseline 

Scenario 1  Scenario 2  Scenario 3  Scenario 4 

-197,400 

-394,900 

-855,700 

-1,184,900 

516,100 

903,200 

1,354,900 

1,677,500 

318,700 

508,300 

499,200 

492,600 

-354,000 

-569,000 

-581,000 

-589,000 

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Figure 3-3  Credits for Global warming potential (GWP) for each scenario for steel in 
collected ELVs in 2035 to primary production (Mt CO2eq) 

Source: Own illustration  

The figure above shows an LCA comparison of the dismantling and recycling route with the 
shredder route showing that the shredder has major environmental impacts, while dismantling 
has  a  minor  environmental  benefit.  Additionally,  there  is  only  a  slight  environmental  profit 
when the parts are sent directly to recycler after dismantling (avoiding shredding process). 
However, scenario 4 assumes regulation on the shredder/PST, thus in this scenario the whole 
treated steel for recycling is of high-quality. This scenario assumes removal of copper from 
the steel scrap in the shredder facilities. Additionally, the threshold on max Cu-content in the 
steel scrap for recycling might be obtain also by dismantling, thus the removal of ELVs parts 
containing copper is higher than in scenario 3 (Table 3-3). The amount of removed copper is 
illustrated in the scenario Copper 4 for copper in the following chapter. In the calculations it 
was assumed that original Cu-content in the steel scrap is 0.4 % which is then reduced to 
0.1 %232.  For  the  removal an  additional  energy  demand  of  50 kWh  electricity  per ton  steel 
scrap is used (Daehn 2019). 

Steel  scrap  under  scenario  4  is  assumed  to  be  of  high-quality.  This  would  mean  that 
potentially, mining and processing of primary iron ore could be avoided, i.e., through avoided 
production of high-quality primary steel or when needed for dilution of steel scrap to obtain 
the required quality of the relevant steel alloy. However, this potential is not expected to occur 
as long as there is not a surplus of steel scrap (there is not demand on cast steel that exists 
in  the  stock).  Currently,  it  is  not  the  case,  thus  in  the  global  scale  (2.1.2.5.1)  there  is  still 
demand for cast steel from ELVs for instance in the construction field.  

232 Calculation was done based on available data, however original Cu-content in steel scrap is in the range of 0.2 to 0.7 %.  

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3.1.5.4.2  Economic impacts 

Investment costs 

Investment  costs  are  considered  to  arise  in  each  scenario  as  well  as  in  the  baseline.  In 
Scenario  Steel  1  and  Steel  2  are  expected  to  occur  bit  higher  costs  than  in  baseline. 
Implementation  of  Scenario  Steel  3  would  potentially  require  investment  in  dismantling 
machines and tools by ATFs for removal of mandatory parts. These costs would in similar 
hight  also  appear  in  Scenario  Steel  4  together  with  additional  costs  for  shredder/PST  to 
improve their efficiency in removing copper from steel scrap and metals in the residues from 
PST.  Assuming  transition  time  in  introduction  of  the  provision  on  the  quality  of 
outcomes/residues from shredders/PSTs the investments costs would be shifted in time. This 
additional time would be required for further development of methods for removal of copper, 
which are in practice under certain conditions and could be expanded or need to be scale-up 
since are proven only at laboratory scale (please refer to 2.1.2.5.1, 2.1.2.5.2, and 2.1.5.4.4). 
The  share  on  the  investment  costs  either  for  increased  dismantling  or  higher  develop 
shredder technologies, might differ among MS, since the provision introduced together with 
Scenario  Steel  4  would  not  prescribe  how  defined  thresholds  need  to  be  achieved.  Some 
countries  might  develop  strategy  to  dismantle  more  parts  that  contain  copper  before 
shredding  and  improve  hand  picking  after  shredding  instead  of  investing  in  e.g.,  sorting 
machines.  This  approach  might  increase  labour  costs.  (Daehn  et  al.  2017a)  illustrates 
effectiveness  (copper  concentration  achievable)  to  qualitative  energy/cost  for  various 
technologies to separate copper (Figure 2-24). 

The  main  stakeholder  of  EoL  automotive  sector  are  ATFs,  shredder  and  PST  facilities, 
recyclers, and garages (repair shops that have no official approval to dismantle ELVs). As it 
is  introduced  in  several  parts  of  this  report  (e.g.  2.3.2.3  and  3.2.5),  more  challenging 
regulations in the context of the Circular Economy, aiming for a higher quality recycling, in the 
end  might  require  more  effort  at  ATFs.  Shredder  and  PST  facilities  in  practice  are  always 
profitable that in case of high investments costs or low revenues for sold outcomes of their 
treatment process, would compensate their costs by decreasing price for input material. In 
that case, economical effort is put on ATFs, which might not be covered by revenues, and 
would  cause  decrease  of  their  profits.  This  in  consequence  might  lead  reduction  of  the 
competitiveness of ATFs with the illegal sector.  

The  operation  costs  for  shredding/PST  are  not  accessible  und  unclear  and,  according  to 
(EGARA 2022a), “financial results are… not detailed enough”, and it is not sufficiently clear 
that PST will actually reach a sufficient quality at lower cost than dismantling. Nevertheless, 
based  on  the  input  from  stakeholders  during  the  workshop  in  March  2022,  the  facilities 
operators compensate their costs through the prices they charge from their customers. When 
steel  scrap  prices  decline,  the  price  that  ATFs  receive  from  shredders/recyclers  for  input 
material  for  downstream  processes,  declines  as  well.  Insofar  it  might  be  concluded  those 
shredders  (in  general)  are  profitable,  since,  in  the  event  of  their  operation  cost  being 
comparatively high due to lower revenues, they forward the excess costs up the value chain 
in the form of lower compensation for the ATFs delivering the ELVs. The figure below (Figure 
3-4)  illustrates  the  development  of  the  prices  for  steel  shredder  scrap  (E40)  over  the  past 
years. 

Dismantling costs depend on several aspects, e.g., access complexity to the component for 
removal,  required  additional  machines,  tools  to  remove  it.  For  example,  the  removal  of 

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bumpers with a metal bar used to attach a bumper to a car, can costs between 1,400 to 2,300 
Euros per tonne233 (IRT M2P 2021). 

Figure 3-4  Min / max prices for shredder steel, free factory (Germany) 

n
o
t

r
e
p
o
r
u
E

600

500

400

300

200

100

0

min,  free factory

max,  free factory

average for the entire period,  free factory

Source: www.euwid-recycling.com  

Further costs and revenues 

Aside from the difference in costs of steel processing from ELVs, a further economic aspect 
is related to the expected administrative cost of reporting. Under the baseline, Commission 
Decision  2005/293/EC,  which  specifies  the  current  reporting  rules,  already  requires  MS  to 
report  on  the  “metal  components”  arising  from  depollution  and  dismantling  in  Table  1. 
However, this data is voluntary and mandator is only a sum of all depolluted and dismantled 
materials,  incl.  “metal  components”.  Introduction  of  scenario  Steel  1  (and  especially  the 
monitoring  aspect)  will  require  adjustment  of  the  reporting  format  as  well  as  changing  the 
reporting  from  voluntary  to  mandatory.  This  adjustment  is  assumed  to  result  in  additional 
economical  costs  for  public  administration  as  well  as  for  ATF  that  report  on  removed 
parts/components (please refer to Table 3-2 on economic impacts of measures addressing 
the treatment of vehicles at EoL).  

These additional costs will be related to the additional time for collecting all data for ATFs 
thus more cells to fill in, as precise reporting of the total weight of reused parts/components 
is  to  be  required  for  each  component  in  the  reporting  table.  Optimally,  if  ATFs  would  also 
report on the material composition of the dismantled parts/components, but this would require 
more thorough information for the producers, e.g., in IDIS. More time will also be needed for 
the institution that collects, summarises, and validates data before its official publication. It is 
to  assume  that  the  expected  additional  administrative  cost  of  reporting  would  be  similar 
significantly higher for scenario Steel 2 in comparison to Steel 1. Some cases repair shops 

233 This includes the following costs: collection and transport, depollution, specific investments, labor costs for dismantling, 
carcass depreciation, transportation to the recycler. 

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(including ATFs) already apply reused parts, anyway the obligation under Steel 2 would lead 
to  an  increase  in  such  activities.  Further  costs  under  this  scenario  are  related  to 
implementation of enforcement against illegal sales of reused components, thus MS would 
need to inspect online sale platforms to ensure no illegal activities.  

Steel 3 considers mandatory dismantling, what can affect investment costs (introduced above 
under investment costs) but also labour costs. The average costs of labour work as well as 
the  number  of  dismantled  parts/components  ahead  shredding  differ  among  MS,  thus  the 
possible  increase  of  additional  costs  for  MS  might  differ,  while  introducing  mandatory 
dismantling. Administrative costs for reporting on dismantled parts are assumed to be higher 
than in Scenario Steel 1 despite already existing scheme on reporting. It is assumed that for 
ATFs it would be an additional effort due to higher number of dismantled parts/components 
as  well  as  due  to  need  to  provide  more  data  on  weight  and  kind  of  dismantled 
parts/components.  In  case  when  Scenario  Steel  1  and  Steel  3  would  be  implemented 
together, the administrative costs for reporting would not sum up234, because while reporting 
on  dismantled  part/components,  ATFs  would  highlight  for  which  purpose  it  is  dismantled 
(reuse/remanufacturing,  recycling).  However,  the  level  of  detail  of  reporting  on  dismantled 
parts would increase.  

Additional  costs  will  also  exist  due  to  requirement  on  reporting  on  the  quality  of 
shredders/PSTs  deliverables  (scenario  Steel  4).  These  costs  will  appear  for  facilities’ 
operators (shredder or/and recycler depending on the agreed measurement point) as well as 
for public authorities, however it is expected that these costs will be higher for facilities. As 
described above, public offices will need to collect data, validate it, and assess the situation 
(locally, regionally, or nationally) and to eventually establish an improvement strategy when 
it is necessary.  

The  administrative  costs  for  each  steel  scenario  are  highlighted  in  section  3.1.11  on  the 
analysis of measures addressing the treatment of vehicles at EoL.  

Figure below shows possible high of revenues for steel scrap for analysed scenarios (2035) 
and status-quo (2020). These values do not consider revenues for dismantled components 
for reuse/remanufacturing as well as costs for this process.  

Table 3-8  Revenues for steel scrap of potentially higher quality and obtained after 
shredding in mln Euro. Below also a change in mln Euro of these revenues 
comparing to the baseline. 

Total of the revenues for recycled material [mln Euro] 

Baseli
ne 

Scenari
o 1 

Scenari
o 2 

Scenari
o 3 

Scenari
o 4 

Recycled material of potentially higher quality (Directly recycled, no 
shredding) 

Recycled material after shredding (incl. Steel in tyres) 

TOTAL 

20 

877 

897 

50 

797 

847 

81 

737 

818 

151 

668 

819 

201 

618 

819 

Table 3-9  Change in mio Euro of these revenues comparing to the baseline ["-" 
decrease, "+" increase] 

Change in mio Euro of revenues comparing to the baseline  
["-" decrease, "+" increase] 

Baseli
ne 

Scenari
o 1 

Scenari
o 2 

Scenari
o 3 

Scenari
o 4 

Recycled material of potentially higher quality (Directly recycled, no 
shredding) 

Recycled material after shredding (incl. Steel in tyres) 

TOTAL 

30 

-80 

-50 

61 

-140 

-79 

131 

-209 

-78 

181 

-259 

-78 

234 Relevant for components for reuse/remanufacturing arise on the list for monitoring.  

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Source: own calculations, the price does not consider the steel scrap quality, which might be 
higher due to dismantling of some parts and sending them directly to recycler (no shredding). 
For  the  price  current  prices  were  taken.  Lowest  raw  represents  a  total  and  percentage  of 
revenue’s decrease/increase in each scenario 1 to 4 in comparison to baseline (decrease in 
revenue  is  due  to,  e.g.,  higher  reuse/remanufacturing  or  direct  recycling  of  components 
dismantled by ATFs). 

The calculation of ATFs dismantling costs in steel scenario is based on the time required to 
remove an engine. When we refer to dismantling of an engine, it means that the engine is 
removed in its entirety and is either reused or shredded and in some cases sent directly to 
the steel smelter. When we refer to deep dismantling, it means that the engine is removed 
and then dismantled into separate material parts – this of course needs more time.  

In  the  calculations  dismantling  time  of  engine  to  the  steel  and  aluminium  scenarios  are 
allocated 50:50 and time for deep dismantling of engines is allocated 33:33:33 to Fe:Cu:Al 
scenarios. Additionally, the percentage of dismantled and deep-dismantled engines variate 
among  scenarios  and  depends  also  on  the  vehicle’s  type.  Allocation  ()  of  calculated 
dismantling time to three materials allows avoiding double counting. Also, dismantling times 
vary for components removed for reuse (20 min) and for recycling (10 min). 

Table 3-10 Allocation of calculated dismantling time to three materials (steel, copper, 
and aluminium) to avoid double counting. 

Scenario 
Steel 
Copper 
Aluminium 

Dismantling (removal) 

Deep-Dismantling 

ICE and Hybrid 
50% 
0% 
50% 

EV and Plug-in 
50% 
0% 
50% 

ICE and Hybrid 
33% 
33% 
33% 

EV and Plug-in 
33% 
33% 
33% 

Following  table  summarises  assumptions  to  calculate  dismantling  time  for  engines  for  all 
scenarios. These assumptions are valid for all three materials.  

Table 3-11 Assumptions to calculate dismantling time for engines for all scenarios of 
steel, copper, and aluminium 

Status-quo  
Baseline 
Scenario 1  
Scenario 2 
Scenario 3  mandatory removal for recycling 

reuse 
reuse 

mandatory removal for reuse 

Scenario 4  PST output quality, for recycling 

PST output quality, for reuse 

Dismantling (removal) 

Deep-Dismantling 

Time 
(min) 
20 
20 
20 
20 
10 
20 
10 
20 

ICE and 
Hybrid 

EV and 
Plug-in 

Time 
(min) 

ICE and 
Hybrid 

EV and 
Plug-in 

30% 
32% 
33% 
42% 
70% 
30% 
40% 
30% 

5% 
5% 
6% 
7% 
95% 
5% 
95% 
5% 

0 
0 
0 
0 
10 
0 
10 
0 

0 
0 
0 
0 
70% 
0 
40% 
0 

0 
0 
0 
0 
95% 
0 
95% 
0 

As  example,  Scenario  3  sets  an  obligation  to  remove  engines,  thus  it  is  assumed  that  all 
engines are dismantled (among them 30% for reuse and 70% for recycling). In Scenario 4, 
less engines from ICE and hybrid will be removed (in total 70%), however for EV and plug-in 
the percentage remains the same as in Scenario 3, due to higher content of copper in the 
engines from these types of vehicles.  

The average cost per hour is 51 Euros (base on the information from EGARA). 

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Following table show the total costs in million Euro for baseline and additional dismantling 
costs (as compared to the baseline, also in mln Euro) 

Table 3-12 Total costs for baseline and additional dismantling costs (as compared to 
the baseline) in mln Euro 

Total costs, in 
million Euro 
Baseline 

Material 
Steel  

Additional dismantling costs (as compared to the baseline, in million Euro) 

Scenario 1  

Scenario 2  

Scenario 3  

Scenario 4  

21 

1 

7 

48 

31 

3.1.5.4.3  Social impacts 

Figure 3-2 illustrates shift (from baseline to Scenario Steel 4) into higher amount of steel in 
reuse/remanufactured  components  containing  steel  and  steel  from  dismantled  parts  send 
directly  to  recycler.  Increase  in  reuse/remanufacturing  and  dismantling  would  potentially 
increase  the  dismantling  cost,  incl.  need  for  more  employee  to  remove235  more 
parts/components from the ELVs. 

Based on one example the possible social impact is calculated. Calculations are based on 
the assumptions applied to estimate economical costs for ATFs (previous sub-chapter). The 
following tables shows the number of additional job positions in the ATFs as compared to the 
baseline.  

Table 3-13 Number of additional job positions in the ATFs as compared to the baseline 

Material 
Steel  

Scenario 1  

Scenario 2  

Scenario 3 

Scenario 4 

Additional positions (number) as compared to the baseline 

12 

86 

582 

383 

Additionally,  employee will  be  needed  for the  operation  of  new machines  in  shredder/PST 
and  additional  employees  for  hand  picking/sorting  in  shredder  facility.  In  Europe  there  are 
about 300 shredders/PST. It is expected that relevant investments would do done by facilities 
from  middle  up  to  big  size,  thus  not  in  all  existing  facilities.  There  is  not  precise  data  on 
shredder/PST  and  also  on  the  fact  if  shredder  have  a  PST  in  house,  therefore  rough 
assumptions  are  done:  60%  of  existing  plants  are  middle  or  bigger  size,  for  the  new 
technological solutions there will be need for 2 employees that could operate new machines. 
It would mean that for Scenario Steel 4 (for which bigger investments are planned) would be 
required to hire additional 360 employees. 

3.1.5.5  Comparison of scenarios for steel 

The differences in impacts of the scenarios as compared to the baseline are compiled in Table 
3-14  below  to  allow  an easier  comparison.  The scope  of  the  analysis  is EoL  of  steel  from 
collected  ELVs,  however  some  of  the  outcomes  either  overlap  with  the  outcomes  of  the 
analysis of other materials or are representative for other material(s) as well. Thus, the finding 
listed below should not be sum up with other summarising tables for the separately analysed 
materials.  The  overall  analysis  on  the  collected  ELV  level  is  performed  in  section  3.1.11 
below. 

235 Especially for these parts/components, which cannot be removed by machines and in MS where labour costs are still not so 
high.  

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Table 3-14 Summarising table for the comparison of the steel scenarios (the 
assessed impacts are based on the total of ELVs collected in 2035)  

Impacts 

Scenario  
Steel 1 

Scenario  
Steel 2 

on ATFs 

1 mln € costs 
due to 
additional 
dismantling236 
(comparing to 
the baseline) 
Additional 
revenues for 
dismantled 
parts/comp. for 
separate 
recycling 
(+30 mln €) 
- 

6 mln € costs 
due to 
additional 
dismantling 236 
comparing to 
the baseline) 
Additional 
revenues for 
dismantled 
parts/comp. for 
separate 
recycling 
(+61 mln €) 
-- 

Scenario  
Steel 3 
43 mln € costs 
due to 
additional 
dismantling 
(comparing to 
the baseline) 
Additional 
investment cost 
in dismantling 
technologies  
Additional 
revenues for 
dismantled 
parts/comp. for 
separate 
recycling 
(+131 mln €) 
--- / + 

c
i
m
o
n
o
c
E

on shredders  

Loss of 
shredding 
material (loss 
of revenue) 
Decrease in 
revenues for 
steel scrap 
(-80 mln €) 
- 

Loss of 
shredding 
material (loss 
of revenue) 
Decrease in 
revenues for 
steel scrap 
(-140 mln €) 
- 

Loss of 
shredding 
material (loss of 
revenue)  
Decrease in 
revenues for 
steel scrap 
(-209 mln €) 
-- 

on recyclers 

Small decrease 
in business, 
due to loss of 
steel scrap 
(-50 mln €) 
However, 
increase in 
higher quality 
material 
(dismantled 
prior shredding) 
0 

Small decrease 
in business, 
due to loss of 
steel scrap 
(-79 mln €) 
However, 
increase in 
higher quality 
material 
(dismantled 
prior 
shredding) 
+ 

Small decrease 
in business, 
due to loss of 
steel scrap 
(-78 mln €) 
However, 
increase in 
higher quality 
material 
(dismantled 
prior shredding) 
+ 

Scenario  
Steel 4 
28 mln € costs 
due to 
additional 
dismantling 
(comparing to 
the baseline) 
Additional 
investment cost 
in dismantling 
technologies  
Additional 
revenues for 
dismantled 
parts/comp. for 
separate 
recycling 
(+181 mln €) 
--- / + 
Loss of 
shredding 
material (loss of 
revenue) 
Additional 
investment 
costs in 
separation 
technologies 
and hand 
picking 
However, the 
secondary steel 
is of high-quality 
and potentially 
of higher price 
(higher 
revenues)237 
--- / +++ 
Small decrease 
in business, due 
to loss of steel 
scrap 
(-78 mln €) 
However, huge 
increase in 
higher quality 
material 
(dismantled 
prior 
shredding), thus 
potentially lower 
processing 
costs to obtain 

236 Value represents the additional costs for manual dismantling (labour costs), there might occur also additional investment 
costs in the machines for automatic dismantling (especially relevant for scenario Steel 3 and 4). 

237 Assuming the price for high-quality secondary steel the same as for the cast steel, there will occur decrease in revenues for 
steel scrap (-227 mln Euro) 

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Impacts 

Scenario  
Steel 1 

Scenario  
Steel 2 

Scenario  
Steel 3 

Scenario  
Steel 4 
steel of high 
quality 
++ 

on SME  

Other  

Small ATFs would probably have higher costs than larger ones. With 
higher dismantling costs the profitability of the business for the ATFs 
might be questionable and possibly the activities of these facilities might 
shift to illegal activities.  
Economic impacts on other stakeholders can be compared to the total 
cost of vehicles and are considered as marginal 

Administrative 
costs burden 

2ndary 
resources  

Moderate 
increase in 
administrative 
burden for 
reporting for 
regulators and 
waste 
management 
-- 

Moderate 
increase in 
administrative 
burden for 
reporting for 
regulators and 
waste 
management 
-- 

Decrease in 
availability of 
secondary steel 
(-50 mln €) due 
to increase in 
reuse 
- 

Decrease in 
availability of 
secondary 
steel 
(-79 mln €) due 
to increase in 
reuse 
- 

High increase 
in 
administrative 
burden for 
reporting for 
regulators and 
waste 
management 
and developing 
of improvement 
strategies 
--- 

Decrease in 
availability of 
secondary steel 
(-78 mln €) due 
to increase in 
reuse 
- 

Environmental 

Environmental 
impacts: LCA 
credits from 
reuse/rem. and 
recycling238 

Increase in 
credits: ~354 
Mt CO2-eq. 
+ 

Increase in 
credits: ~569 
Mt CO2-eq. 
++ 

Increase in 
credits: ~581 
Mt CO2-eq. 
++ 

Social  

Employment239 

Increase in jobs 
in ATF (~12) 
+ 

Increase in 
jobs in ATF 
(~86) 
++ 

Increase in jobs 
in ATF (~582) 
++ 

High increase in 
administrative 
burden for 
reporting for 
regulators and 
waste 
management 
and developing 
of improvement 
strategies 
--- 

Decrease in 
availability of 
secondary steel 
(-78 mln €) due 
to increase in 
reuse 
However, the 
secondary steel 
is of high-quality 
++ 

Increase in 
credits: ~589 Mt 
CO2-eq. 
++ 

Increase in jobs 
in ATF (~383) 
Increase in jobs 
in shredder 
facilities (~360) 
+++ 

Proportionality  

All scenarios are considered proportional for achieving the objectives 
that the EU Treaties intends to implement 

Cost 
effectiveness  

Low costs but 
low benefits 
+ 

Similar 
effectiveness to 
scenario 3 and 
4 in GWP and 
amount of 
recycled steel, 
while lower 
costs.  
However, the 
quality of 
recycled 

Higher costs 
than scenario 
Steel 2 to result 
in the similar 
amount of 
secondary steel 
as scenario 
Steel 2.  
However, the 
quality of 
recycled steel is 
higher. 

Very high costs 
in comparison 
to scenario 
Steel 2 and 3. 
Highest 
revenues for 
ATFs for sold 
recyclable 
material. 
However, the 
obtained 
secondary steel 

238 As a difference to baseline scenario 

239 Increase in comparison to baseline scenario. The calculations done based on dismantling time of engine/gearbox, so the 
values presented here in reality might be even higher while considering more parts/components for dismantling.  

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Scenario  
Steel 1 

Coherence with 
waste 
legislation and 
the CEAP, 
promoting 
waste 
treatment of a 
higher 
hierarchy and 
circularity. 
++ 

Scenario  
Steel 2 

material is 
lower.  
++ 
Coherence with 
waste 
legislation and 
the CEAP, 
promoting 
waste 
treatment of a 
higher 
hierarchy and 
circularity. 
++ 

Scenario  
Steel 3 

Scenario  
Steel 4 

++ 

Coherence with 
waste 
legislation and 
the CEAP, 
promoting 
maximal 
recycling.  
++ 

is of high 
quality. 
++ 

Coherence with 
waste 
legislation and 
the CEAP, 
promoting 
maximal high-
quality 
recycling.  
+++ 

Coherence 

Impacts 

Notes: 

-/-: no impact 

Costs or burdens: between 1 and 3 minus signs (-; --; or ---), indicating low (1 minus sign) and high (3 minus signs) costs or 
burdens 

Benefits or savings: between 1 and 3 plus signs (+; ++; or +++), indicating low to high savings 

(): brackets around symbols if costs, benefits etc. are only potentials or are uncertain. If the costs, benefits etc. is rather 
uncertain, a broader range is indicated: e.g. ++ to +++ or – to + 

n.a.: not applicable 

Please see EPR section in analysis at EEC level in section 3.1.10.1.4 for possible costs of 
dismantling EEC containing copper and in section 3.1.12 on possible costs of PST at vehicle 
level. 

3.1.6  Analysis for copper 

3.1.6.1  Qualitative analysis for copper 

Measures were shortlisted for copper including the following measures: 

Title 

2.3.e) Establish provisions to support the market of used spare parts composed of copper 
2.3.f) Set up a separate (monitoring) target for re-use/preparing for re-use/remanufacturing of 
copper components 
2.4.b) Making it mandatory to remove certain copper parts before shredding to encourage high 
quality steel/aluminium and high quantity copper recycling 
2.4.c) Set material-specific recycling targets for copper 
2.4.d) Regulate shredder/post shredder facilities to ensure high quality/quantity of materials 
obtained for recycling and to improve final treatment process 

Chapter 
2.1.5.3.5 
2.1.5.3.6 

2.1.5.4.2 

2.1.5.4.3 
2.1.5.4.4 

Colour code: Red – discarded, Yellow – premature, Grey – supporting measure 

•  Monitoring of components for reuse/remanufacturing is a supporting measure (2.2.f) that 
will need to accompany provisions designed to increase the demand of components for 
reuse/remanufacturing (2.2.e) that contain copper, e.g., EV motor. EV motors contain also 
high shares of aluminium and, since the reuse/remanufacturing of aluminium components 
is analysed under the next section, these two measures will be discarded from the further 
analysis here.  

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•  Regulation  of  shredder/post-shredder  facilities  and  especially  the  standardisation  of 
deliverables from these facilities could lead to the improvement of existing technologies 
or the promotion of the dismantling of reusable copper (containing) components240 prior 
to shredding.  

•  A mandatory removal of certain components aims to limit ‘poor-quality’ material recovery 
operations through removing from vehicles components with a high content of copper and 
sending  them  to  separate  recycling.  Dismantling  of  parts  composed  of  copper  and 
sending them to recycling is a pre-condition for the recycling of higher amounts of copper 
as well as obtaining the ELV steel scrap of lower Cu-contamination. Treatment of copper 
components together with the rest of the hulk in the shredder limits the number of coppers 
recycled but also limits the applicability of recycled steel (for more details please refer to 
the chapter 2.1.2.5.1).  

•  Setting  a  separate  reuse  and  recycling  target  for  copper  would  also  aim  at  increasing 
reuse/remanufacturing, also contributing to increasing the quantity of copper for recycling. 
However, reporting on this target would create significant administrative burden. The most 
challenging would be obtaining the weight of the specific material in the components for 
reuse/remanufacturing. Additionally, tracking of materials from the ELVs in the shredder 
process is hampered since ELVs that are processed in these facilities are often mixed 
with  other  items.  Setting  only  the  material-specific  recycling  target  (excluding  the 
components for reuse/remanufacturing from it) would act contra-productive for promoting 
reuse/remanufacturing.  Also  identifying  a  meaningful  level  of  these  targets  would  be 
extremely challenging. Hence, a separate target for copper is discarded at this stage but 
could be reconsidered in the future if the implementation of other measures does not lead 
to a sufficient improvement in circularity. 

3.1.6.2  Scenarios for quantitative analysis  

3.1.6.2.1  Baseline Copper 

EU  wide  the  commonly  applied  methods  to  treat  copper  from  ELVs,  similarly  to  steel,  are 
shredder operations, usually combined with some type of post-shredder treatment operations. 
After the scrap is shredded into first-size pieces, it is separated by a magnet into a ferrous 
and a non-ferrous stream. The efficiency of this process might be limited, since some ferrous 
pieces are still connected to non-ferrous pieces, causing a certain degree of impurity in each 
stream. One example are copper wires from electric motors that remain attached to ferrous 
components in their stream. Partly the remaining wires might be removed manually. The rest 
remains in the ferrous scrap and causes its impurity. Shredding companies are aware of their 
customers’  requirements  and  can  adjust  their  processes  accordingly.  Nevertheless,  in  the 
heavies’ fraction of non-ferrous stream, which accounts for 20-25 % of the non-ferrous output, 
contains about 1-15 % copper.241  

On this basis, it is assumed that under the baseline, copper shall continue to be treated mainly 
in  shredder/PST,  with  the  chance  that  the  quality  of  obtained  deliverables  will  improve 
together  with  development  of  new  technologies.  Dismantling  of  specific  components  for 
recycling  may  potentially  increase,  however,  similarly  to  treatment  in  shredder/PST,  the 
economic viability is questionable. As said above, its profitability might depend on additional 
fundings.  

240 Wheels, transmissions, and engines (EV, ICEV).  

241 https://www.cargroup.org/wp-content/uploads/2017/02/Copper-in-End_of_Life-Vehicle-Recycling.pdf 

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3.1.6.2.2  Scenario  Copper  1:  Monitoring  of  components 

composed of copper for reuse/remanufacturing 

Under  this  scenario  the  monitoring  of  components  for  reuse/remanufacturing  shall  be 
introduced. For this purpose, a list of components recommended for reuse/remanufacturing 
(Annex to ELVD) would be defined. The preliminary list prepared in this report contains also 
elements  made  of  copper,  e.g.,  engines.  This  list  should  be  revised  from  time  to  time  to 
consider the current market situation of components for reuse and for remanufacturing.  

This scenario also considers implementation of harmonised monitoring of components that 
have been removed for reuse/remanufacturing to understand the actual volume of reuse in 
different MS and will enable the comparability of monitoring data. Obtained information will 
allow a better understanding of the potential for reuse and how it is influenced by measures 
that affect market demand. It will also help in the future in the revision of the list of removed 
spare  parts  as  well  as  to  potentially  set  out the targets.  The  reporting  obligation  would  be 
limited to the components listed in the Annex to ELVD (“list of components recommended for 
reuse/remanufacturing”).  However,  separate 
for 
reuse/remanufacturing  could  also  be required though  it may  create  a  burden for  ATFs  if  it 
cannot be linked to an existing list of sales. 

reporting  on  components  sold 

3.1.6.2.3  Scenario Copper 2: Market support of used spare 

parts composed of Copper 

Under this scenario the market demand for spare parts should be regulated by requiring car 
repair shops to provide customers with an offer to repair a vehicle with used/remanufactured 
components alongside offers for repair with new components. Insurance companies will also 
be obliged to offer car owners discounted policies if they agree that repairs are performed 
with reused/remanufactured parts when these are available. Furthermore, a ban of the online 
sales of illegally operating facilities could be introduced.  

Use  of  spare  parts  is  market  driven,  and  increasing  demand  is  assumed  to  provide  more 
flexibility  to  ATFs  to  decide  on  components  to  be  dismantled  as  opposed  to measures  for 
increasing supply which could result in a high burden for storage without significant impact 
on  the  actual  reuse/remanufacturing  of  components.  Obligations  for  insurance  companies 
may only be implementable through national legislation. Strengthening the market demand 
for  reused  components  will  increase  the  profitability  of  dismantling  relevant  components. 
Provisions  on  online  sales  will  reduce  sales  of  used  components  from  illegally  operating 
facilities, increasing profitability of legally operating ones. Again, these provisions may only 
be implementable through national legislation.  

3.1.6.2.4  Scenario Copper 3: Mandatory removal of certain 
copper  parts  before  shredding  to  encourage  high 
quality steel/aluminium recycling and high quantity 
copper recycling 

A dismantling obligation for copper-bearing components is already provided by the ELVD, but 
only if the copper is not segregated in the shredding process.  

The copper contained in vehicles is about 60 % in the cable harness and in engines, e.g., 
ventilation  and  heating  (Argonne  2021).  While  a  separation  of  the  large  electric  motors  is 
effectively  possible  after  shredding,  the  separation  of  increasingly  fine  and  more  widely 
distributed cable strands can only be realised with considerable effort. 

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For instance, the Japanese ELV system contains provisions that dismantlers when they want 
to send and ELV directly to the electric furnaces without shredding process, are allowed to 
do it, under the condition that copper contents are reduced into max 0.3%. In consequence 
they have to remove the wire harness from ELVs. Like this Japanese dismantler remove them 
by operation heavy machinery.242  

(Russo et al. 2002) curried out several trials to analyse influence of the dismantling parameter 
on  scrap  quality,  with  special  focus  on tramp  elements,  like  copper.  The results  show  that 
removal of the engine has direct effect of removing 62 % of the copper present in the car, 
thus the total copper removal from car to shredder scrap is thus 90 %, to be compared to only 
71.5 %  without  prior  dismantling.  The  study  proved,  that  engine  removal  leads  to  the 
possibility  of  producing  shredded  scrap  with  a  copper  level  of  around  0.1 %  (without 
dismantling of the engine it would be on the level of 0.28 %).  

Copper content in steel scrap destined for recycling, is considered an impurity of steel and 
may affect the portfolio of applications in which secondary steel can be applied (EUROFER 
27.10.21).  

Thus, removal of electronic components and cables (wire harness) prior to shredding is an 
option to limit such impurities and is a part of this scenario.  

3.1.6.2.5  Scenario  Copper  4:  Regulate  shredder/post-
shredder facilities to ensure high quality/quantity of 
materials  obtained  for  recycling  and  to  improve 
final treatment process 

The  intention  of  this  scenario  is  to  ensure  high  recovery  of  metals  from  the  shredder/PST 
residues. It aims also to obtain high-quality recycling output from these treatment plants. To 
obtain the goal, a legally binding maximum metal content for shredder residues243 should be 
set up at ambitious level in order to recover as many metals as possible as secondary raw 
materials  and  should  be  oriented  at the  best  available  technical  practices.  The removal  of 
metal from the shredder light fraction at least to below 1 % metal content by means of post-
shredder separation (Tabel et al. 2011) is considered to be feasible for this purpose. 

On  the  other  side  copper  content  in  steel  scrap  destined  for  recycling,  is  considered  an 
impurity of steel and may affect the portfolio of applications in which secondary steel can be 
applied (EUROFER 27.10.21).  

The full implementation of this scenario would require setting up a maximum copper content 
in  steel  scrap244  (output  from  shredders/PST)  that  is  sourced  from  recycling,  possibly  by 
means  of  a  European  standard,  e.g.,  currently  under  development 
is  “European 
standardisation  deliverables  on  Road  vehicles  –  Post-shredding  recycling  –  design-for-
recycling guidelines for plastic products” . 

For more information, please refer to the information on copper in the current situation chapter 
and measure description (2.1.2.5.2 and 2.1.5.4.2). 

242 https://www.gov.scot/binaries/content/documents/govscot/publications/progress-report/2013/12/remanufacture-
refurbishment-reuse-recycling-vehicles-trends-opportunities/documents/00440543-pdf/00440543-
pdf/govscot%3Adocument/00440543.pdf 

243 destined for backfilling/ landfill construction, energy recovery/ incineration or final disposal/landfill sites 

244 More on possible max value under description of measure. 

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3.1.6.3  Results of qualitative analysis  

Scenario Copper 1 and Copper 2 are intended to increase the reuse/remanufacturing level 
of components in ELVs incl. those containing copper. Scenario Copper 1 in a way intends to 
increase the attention of ATF to component reusability as well as supporting the policy maker 
in  understanding  the  situation  of  the  market  of  components,  potentially  dismantled  and 
reused. On the other hand, scenario Copper 2, includes legally binding obligations for both 
ATFs and insurance companies, and it is expected that level of dismantling will increase more 
under scenario Copper 2 than under Copper 1 due to the expected increase in demand for 
reused parts.  

However,  implementation  of  the  scenario  Copper  2  requires  legal  adjustments  mainly  at 
national  level,  which  may  affect  its  implementability  by  all  Member  States.  Both  scenarios 
would require development of administrative support in terms of i.e., monitoring/reporting. For 
dismantled (relatively) pure steel sheets (with no copper contamination), both scenarios are 
expected to potentially increase the level of high-quality recycling. Where it is not possible to 
reuse/remanufacture  components  that  have  already  been  dismantled,  they  can  be  sent  to 
separate recycling, avoiding shredder process.  

Scenario  Copper  3  aims  to  dismantle  copper-bearing  components  prior  shredding.  This 
would  require  additional  step  before  shredding  and  will  lead  to  additional  costs  for  ATFs. 
Dismantling could be done manually or automatically, for parts that are easily accessible. The 
copper  contained  in  vehicles  is  about  60%  in  the  cable  harness  and  in  engines,  e.g., 
ventilation and heating. As already highlighted before, Cu-contamination in steel scrap, limits 
the applicability of this scrap.  

In  addition  to  increased  steel  scrap  quality,  dismantled  components  might  be  shifted  for 
reuse/remanufacturing, as  well  as  more  copper (or  other  materials)  would  be  available  for 
(high-quality) recycling. 

Scenario Copper 4 aims to obtain: 1) a higher quantity of metals (ferrous and non-ferrous) 
for recycling, 2) a high-quality steel scrap for recycling.  

Introduction of this provision would require regular checks of the obtained outcomes/residues 
from  shredder.  The  monitoring  under  this  scenario  would  require  development  of  a 
harmonised testing approach. This can be done twofold: either by shredder or by recycler. 
The testing of the steel scrap samples is less precise as chemical analysis of smelted input 
material to EAF. However, material put into EAF normally is coming from different sources, 
what  might  of  challenge  to  assess  the  composition  of  each  input  material  separately  (this 
issue require further investigation).  

Reporting on the steel scrap quality would also involve development of a reporting scheme 
that to submit by facilities (shredders/recycler) the monitoring results to the authority to be 
responsible for controlling.  

There are two possible actions once the results of monitoring are not satisfactory: 

1) the authorities could develop local/regional/national strategies to improve the situation, by, 
e.g., introduction of mandatory disposal of parts that contain copper before shredding (if not 
implemented yet).  
2) modulation on price for steel scrap for recycling.  

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3.1.6.4  Results of quantitative analysis  

The wire harness is one of the larger components with a large share of copper in the vehicle. 
Engines, which contain copper and in EV its use in it is even double so high as in ICEV, are 
understood to commonly be removed for reuse, though this also depends on the model. The 
reuse potential for EV engines may currently be similar to that of combustion engines but is 
expected to increase as it is often said that service life of an EV engine is significantly longer 
than that of the vehicle. In future such components could be reused in new vehicles (assumed 
to be relevant already in 2035 due to expected increase of EV sales). 

For  the  purpose  of  the  impact  analysis,  the  total  amount  of  copper  in  collected  ELVs  is 
considered, however some calculations are done for the wire harness and engines due to 
high copper content. The scope of the analysis is to consider in the copper analysis also the 
amount of copper that can be gain thanks to its reduction in steel fraction245 (Scenario Copper 
4). Based on ADEME data from 2017, the average weight of wire harness is 10 kg, with 90% 
of  the  composition  being  copper  and  the  rest  plastic.  It  is  assumed  that  the  plastic  is  not 
recycled among others due to probably contents of flame retardants.  

The  following  table  specifies  the  rates  that  have  been  assumed  for  each  scenario  as 
dismantled,  reused,  recycled  pre-  or  post-shredder,  recovered,  or  lost;  and  with  which 
quantitative impacts have been calculated. For instance, a different share is assumed to be 
dismantled  in  each  scenario.  In  scenario  Copper  3  and  4  the  share  of  components  for 
reuse/remanufacturing is the same, however in scenario Copper 3 and 4 a higher share of 
dismantled steel is sent to the recycler directly (skipping the shredding process) in contrary 
to other scenarios. However, higher share is assumed in Scenario Copper 3, thus mandatory 
removal. It is also assumed that no dismantled parts that contain copper would be send to 
the shredder. High dismantling is assumed in order to see how the environmental benefits 
could change when it is required to dismantle more components prior shredding or when Cu-
content  threshold  is  put  on  steel  scrap  in  order  to  obtain  the  outputs  from  shredder/PST 
facilities in sufficient quality. 

Scenario  Copper  4  introduces  threshold  on  Cu-content  in  steel  scrap  (outcome  from 
shredding), thus additional copper removed from this fraction was calculated. It was assumed 
that  original  Cu-content  is  0.4 %,  which  is  reduced  to  0.1 %.  The  obtained  copper  can  be 
recycled, thus its recycled values is calculated and included to the following table and two 
figures (kg and GWP). The amount of steel scrap is assumed to be the same as in Scenario 
Steel 4.  

Table 3-15 Routes of treatment for copper under the various scenarios  

Baseline  Scenario 1  Scenario 2  Scenario 3  Scenario 4 

Dismantled -> 
reused/remanufactured 
Dismantled -> recycled (no 
shredding) 
Dismantled -> shredded -> 
recycled 
Shredded -> recycled 

Losses/process 
inefficiencies 
Recycled removed copper 
from steel scrap 

1% 

5% 

0% 

60% 

34% 

0% 

5% 

15% 

0% 

49% 

31% 

0% 

7% 

15% 

0% 

47% 

30% 

0% 

8% 

46% 

0% 

21% 

25% 

0% 

Source: Oeko-Institut: own assumptions 

8% 

31% 

0% 

30% 

26% 

5% 

245 Increased amount of copper recycled intend to improve quality of steel scrap and thus its applicability 

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Based on this description and the shares specified Table 3-15 in the baseline and in each 
scenario,  the  amounts  that  would  be  reused/remanufactured  as  well  as  recycled  pre-  and 
post-shredder  were  calculated  (Table  3-16).  The  total  mass  of  copper  in  EoL  vehicles  is 
assumed to be about 1 66 Mt in 2035.  

Table 3-16 Tonnes of copper from collected ELVs assumed to be either reused or 
recycled and losses of the material in the treatment process (in 2035) 

Total of the material in EoL vehicles 
(without battery) [tonnes] 

Baseline 

Scenari
o 1 

Scenari
o 2 

Scenari
o 3 

Scenari
o 4 

Total of the material in EoL vehicles (without 
battery) 
In components for reuse/remanufacturing 

Recycled material of potentially higher quality 
(Directly recycled, no shredding) 
Recycled material after shredding  

Recycled removed copper from steel scrap 

Losses/process inefficiencies (Direct recycling) 

Losses/process inefficiencies (Shredder) 

Losses/process inefficiencies (Recycling) 

166,700 

166,700 

166,700 

166,700 

166,700 

1,700 

8,300 

11,700 

13,300 

13,300 

8,900 

99,400 

0 

2,800 

23,000 

30,900 

25,400 

81,100 

0 

7,900 

18,700 

25,200 

25,400 

78,900 

0 

7,900 

18,200 

24,500 

76,300 

34,600 

0 

23,700 

8,000 

10,700 

50,900 

50,800 

8,500 

15,800 

11,700 

15,800 

Table 3-17 Change in tonnes of materials for recycling comparing to the baseline ["-" 
decrease, "+" increase] (in 2035) 

Change in tonnes of materials for 
recycling comparing to the baseline  
["-" decrease, "+" increase]  

Recycled material of potentially higher quality 
(Directly recycled, no shredding) 
Recycled material after shredding  

TOTAL 

Baseline 

Scenari
o 1 

Scenari
o 2 

Scenari
o 3 

Scenari
o 4 

16,500 

16,500 

67,400 

42,000 

-18,300 

-20,500 

-64,800 

-40,100 

-2,000 

-4,000 

3,000 

2,000 

Figure 3-5  Tonnes of copper from collected ELVs assumed to be either reused or 
recycled and losses of the material in the treatment process (in 2035) (kg) 

Source: Own illustration  

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3.1.6.4.1  Environmental impacts 

Based on this description and the shares specified in Table 3-15, in the baseline and in each 
scenario,  the  amounts  that  would  be  recycled  pre-  and  post-shredder  are  calculated.  The 
obtained results are masses of copper multiplied by the respective environmental impacts in 
terms of Global warming potential (GWP). This is shown below for all copper from collected 
ELVs in the year 2035 (Table 3-18). 

Table 3-18 Credits for Global warming potential (GWP) for each scenario for copper in 
collected ELVs in 2035 to primary production (Mt CO2eq) 

Environmental impact in GWP (without 
battery) [Mt CO2-eq.]  
["-" environmental credits, "+" 
environmental burdens] 

In components for reuse/remanufacturing 

Recycled material of potentially higher quality 
(Directly recycled, no shredding) 
Recycled material after shredding  

Recycled removed copper from steel scrap 

Losses/process inefficiencies (Direct recycling) 

Baseline 

Scenario 
1 

Scenario 
2 

Scenario 
3 

Scenario 
4 

-10,800 

-54,200 

-75,900 

-86,700 

-86,700 

-32,500 

-92,800 

-92,800 

-278,400 

-185,600 

-308,400 

-251,500 

-244,700 

-107,300 

-157,600 

0 

0 

0 

0 

19,100 

Losses/process inefficiencies (Shredder) 

Losses/process inefficiencies (Recycling) 

1,700 

14,400 

5,000 

5,000 

11,800 

11,500 

14,900 

5,000 

9,900 

7,400 

TOTAL 

19,400 
-316,000 

15,800 
-366,000 

15,400 
-382,000 

6,700 
-446,000 

9,900 
-384,000 

Table 3-19 Change in tonnes of materials for recycling comparing to the baseline ["-" 
decrease, "+" increase] (in 2035) 

Change in Mt CO2-eq. comparing to the 
baseline  
["-" decrease, "+" increase] 

Recycled material of potentially higher quality 
(Directly recycled, no shredding) 
Recycled material after shredding (incl. Steel in 
tyres) 
TOTAL for recycling (excl. reuse and burdens due 
to losses/process inefficiencies) 
TOTAL of the whole process steps (e.g. reuse, 
recycling, etc.) 

Baseline 

Scenario 
1 

Scenario 
2 

Scenario 
3 

Scenario 
4 

-60,300 

-60,300 

-245,900 

-153,100 

56,900 

63,700 

201,100 

150,800 

-3,400 

3,400 

-44,800 

-2,300 

-50,000 

-66,000 

-130,000 

-68,000 

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Figure 3-6  Credits for Global warming potential (GWP) for scenarios for copper in 
collected ELVs in 2035 to primary production (kg CO2eq) 

Source: Own illustration 

The figure above shows an LCA comparison of the recycling route with the shredder route, 
where  it  is  concluded  that  the  environmental  benefits  are  higher  thanks  to  recycling  route 
avoiding shredder. Less environmental benefits can be gain when the copper is sent to the 
shredder  and  recycled  afterwards.  It  is  due  to  the  high  losses  of  copper  in  the  shredder 
process. In the calculations of copper removed from the steel scrap (Scenario Copper 4), it 
was assumed that original Cu-content in the steel scrap is 0.4 % which is then reduced to 
0.1 %246.  For  the  removal an  additional  energy  demand  of  50 kWh  electricity  per ton  steel 
scrap is used (Daehn 2019). The energy input requested for sorting is environmental burden, 
which is higher than credits from removed from steel scrap copper, thus the additional effort 
is illustrated as environmental burden.  

3.1.6.4.2  Economic impacts 

Investment costs 

Investment  costs  are  considered  to  arise  in  each  scenario  as  well  as  in  the  baseline.  In 
Scenario Copper 1 and Copper 2 are expected to occur bit higher costs than in baseline. 
Implementation  of  Scenario  Copper  3  would  potentially  require  investment  in  dismantling 
machines and tools by ATFs for removal of mandatory parts. These costs would in similar 
high  also  appear  in  Scenario  Copper  4 together  with  additional costs for  shredder/PST  to 
improve their efficiency in removing copper from steel scrap and metals in the residues from 
PST.  Assuming  transition  time  in  introduction  of  the  provision  on  the  quality  of 
outcomes/residues from shredders/PSTs the investments costs would be shifted in time. This 
additional time would be required for further development of methods for removal of copper, 
which  are  in  practice  under  certain  conditions  and  could  be  expanded  or  may  need  to  be 
scaled-up  where  proven  only  at  laboratory  scale  (please  refer  to  2.1.2.5.1,  2.1.2.5.2,  and 
2.1.5.4.4).  The  share  on  the  investment  costs  either  for  increased  dismantling  or  higher 

246 Calculation was done based on available data, however in Cu-content in steel scrap is in range of 0.2 to 0.7 %.  

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develop  shredder  technologies,  might  differ  among  MS,  since  the  provision  introduced 
together  with  Scenario  Copper  4  would  not  prescribe  how  defined  thresholds  need  to  be 
achieved. Some countries might develop strategy to dismantle more parts that contain copper 
before shredding and improve hand picking after shredding instead of investing in e.g., sorting 
machines.  This  approach  might  increase  labour  costs.  (Daehn  et  al.  2017a)  illustrates 
effectiveness  (copper  concentration  achievable)  to  qualitative  energy/cost  for  various 
technologies to separate copper (Figure 2-24). 

The  main  stakeholders  for  EoL  automotive  sector  are  ATFs,  shredder  and  PST  facilities, 
recyclers, and garage (repair shops that have no official approval to dismantle ELVs). As it is 
introduced in several parts of this report (e.g. 2.3.2.3 and 3.2.5), more challenging regulations 
in the context of the Circular Economy, aiming for a higher quality recycling, might require at 
the end more effort at ATFs. Shredder and PST facilities in practice are always profitable. In 
the  case,  of  high  investments  costs  or  low  revenues  for  sold  outcomes  of  their  treatment 
process, would compensate their costs by decreasing price for input material. In that case, 
economical effort is put on ATFs, which might not be covered by revenues, and would cause 
decrease of their profits. This in consequence might lead reduction of the competitiveness of 
ATFs with the illegal sector.  

The  operation  costs  for  shredding/PST  are  not  accessible  und  unclear  and,  according  to 
(EGARA 2022a), “financial results are… not detailed enough”, and it is not sufficiently clear 
that PST will actually reach a sufficient quality at lower cost than dismantling. Nevertheless, 
based  on  the  input  from  stakeholders  during  the  workshop  in  March  2022,  the  facilities 
operators compensate their costs through the prices they charge from their customers. When 
steel  scrap  prices  decline,  the  price  that  ATFs  receive  from  shredders/recyclers  for  input 
material  for  downstream  processes,  declines  as  well.  Insofar  it  might  be  concluded  those 
shredders  (in  general)  are  profitable,  since,  in  the  event  of  their  operation  cost  being 
comparatively high due to lower revenues, they forward the excess costs up the value chain 
in the form of lower compensation for the ATFs delivering the ELVs.  

Further costs and revenues 

Aside from the difference in costs of copper processing from ELVs, a further economic aspect 
is related to the expected administrative cost of reporting. Under the baseline, Commission 
Decision  2005/293/EC,  which  specifies  the  current  reporting  rules,  already  requires  MS  to 
report  on  the  “metal  components”  arising  from  depollution  and  dismantling  in  Table  1. 
However, this data is voluntary, and mandatory is only a sum of all depolluted and dismantled 
materials,  incl. “metal components”. Introduction of scenario  Copper  1  (and  especially the 
monitoring  aspect)  will  require  adjustment  of  the  reporting  format  as  well  as  changing  the 
reporting  from  voluntary  to  mandatory.  This  adjustment  is  assumed  to  result  in  additional 
economical  costs  for  public  administration  as  well  as  for  ATF  that  report  on  removed 
parts/components  (see  Table  3-61  on  economic  impacts  of  measures  addressing  the 
treatment of vehicles at EoL).  

These additional costs will be related to the additional time for collecting all data for ATFs 
thus more cells to fill in, as precise reporting of the total weight of reused parts/components 
is  to  be  required  for  each  component  in  the  reporting  table.  Optimally,  if  ATFs  would  also 
report on the material composition of the dismantled parts/components, but this would require 
more thorough information for the producers, e.g., in IDIS. More time will also be needed for 
the institution that collects, summarises, and validates data before its official publication. It is 
assumed  that  the  expected  additional  administrative  cost  of  reporting  would  be  similar 
significantly higher for scenario Copper 2 in comparison to Copper 1. In some cases repair 
shops (including ATFs) already apply reused parts, anyway the obligation under Copper 2 
would lead to an increase in such activities. Further costs under this scenario are related to 

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implementation of enforcement against illegal sales of reused components, thus MS would 
need to inspect online sale platforms to ensure no illegal activities.  

Copper  3  considers  mandatory  dismantling,  what  can  affect  investment  costs  (introduced 
above under investment costs) but also labour costs. The average costs of labour work as 
well as the number of dismantled parts/components ahead shredding differ among MS, thus 
the  possible  increase  of  additional  costs  for  MS  might  differ,  while  introducing  mandatory 
dismantling. Administrative costs for reporting on dismantled parts are assumed to be higher 
than in Scenario Copper 1 despite already existing scheme on reporting. It is assumed that 
for ATFs it would be an additional effort due to higher number of dismantled parts/components 
as  well  as  due  to  need  to  provide  more  data  on  weight  and  kind  of  dismantled 
parts/components. In case when Scenario Copper 1 and Copper 3 would be implemented 
together, the administrative costs for reporting would not sum up247, because while reporting 
on  dismantled  part/components,  ATFs  would  highlight  for  which  purpose  it  is  dismantled 
(reuse/remanufacturing, recycling). However, the level on detail on reporting on dismantled 
parts would increase.  

Additional  costs  will  also  exist  due  to  requirement  on  reporting  on  the  quality  of 
shredders/PSTs  deliverables  (scenario  Copper  4).  These  costs  will  appear  for  facilities’ 
operators (shredder or/and recycler depending on the agreed measurement point) as well as 
for public authorities, however it is expected that these costs will be higher for facilities. As 
described above, public offices will need to collect data, validate it, and assess the situation 
(locally, regionally, or nationally) and to eventually establish an improvement strategy when 
it is necessary. The administrative costs related to the copper scenarios are highlighted in the 
Table 3-61 presenting the analysis of measures addressing the treatment of vehicles on EoL.  

Figure below shows possible high of revenues for copper scrap for analysed scenarios (2035) 
and status-quo (2020). These values do not consider revenues for dismantled components 
for reuse/remanufacturing as well as costs for this process.  

Table 3-20 Revenues for copper scrap of potentially higher quality and obtained after 
shredding in mln Euro. Below also a change in mln Euro of these revenues 
comparing to the baseline. 

Total of the revenues for recycled material [mln 
Euro] 

Baseline 

Scenario 
1 

Scenario 
2 

Scenario 
3 

Scenario 
4 

Recycled material of potentially higher quality 
(Directly recycled, no shredding) 

Recycled material after shredding (incl. Steel in tyres) 
TOTAL 

56 

625 

681 

160 

510 

670 

160 

496 

656 

480 

217 

697 

320 

373 

693 

Table 3-21 Change in mln Euro of these revenues comparing to the baseline ["-" 
decrease, "+" increase] 

Change in mln Euro of revenues comparing to 
the baseline  
["-" decrease, "+" increase] 

Recycled material of potentially higher quality 
(Directly recycled, no shredding) 

Recycled material after shredding (incl. Steel in tyres) 
TOTAL 

Baseline 

Scenario 
1 

Scenario 
2 

Scenario 
3 

Scenario 
4 

104 

-115 

-11 

104 

-129 

-25 

424 

-408 

16 

264 

-252 

12 

Source: own calculations  

247 Relevant for components for reuse/remanufacturing arise on the list for monitoring.  

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The  price  does  not  consider  the  copper  scrap  quality,  which  might  be  higher  due  to 
dismantling of some parts and sending them directly to recycler (no shredding). For the price 
current  prices  were  taken.  Lowest  raw  represents  a  total  and  percentage  of  revenue’s 
decrease/increase in each scenario 1 to 4 in comparison to baseline (decrease in revenue is 
due to, e.g., higher reuse/remanufacturing or direct recycling of components dismantled by 
ATFs). 

Detail  assumptions  for  the  ATF  costs  are  introduced  in  chapter  for  steel.  They  based  on 
removal of engines including dismantling and deep dismantling. In copper scenario only deep-
dismantling of removed engines are assumed. In order to avoid double counting, the 33 % of 
time  (and  costs)  of  this  process  is  allocated  to  copper  scenario.  In  addition,  for  copper 
scenario,  time  required  for  dismantling  of  cables  is  also  considered.  The  percentage  of 
removed cables remain the same for baseline and scenarios 1 and 2 (10 %). It increases to 
100 % in Scenarios 3 and 4. The average cost per hour is 51 Euros (base on the information 
from EGARA). 

Following table show the total costs in million Euro for baseline and additional dismantling 
costs (as compared to the baseline, also in million Euro) 

Table 3-22 Total costs for baseline and additional dismantling costs (as compared to 
the baseline) in million Euro 

Total costs, in 
million Euro 
Baseline 

Material 
Copper  

Additional dismantling costs (as compared to the baseline, in million Euro) 

Scenario 1  

Scenario 2  

Scenario 3  

Scenario 4  

9 

0 

0 

104 

98 

3.1.6.4.3  Social impacts 

Figure 2-14 illustrates amounts of copper send directly to recycling and amount of copper in 
reused/remanufactured components and their increases in scenario 1 to 4 in comparison to 
the baseline scenario. Increase in reuse/remanufacturing and dismantling would potentially 
increase  the  dismantling  cost,  incl.  need  for  more  employee  to  remove248  more 
parts/components from the ELVs.  

Based on one example the possible social impact is calculated. Calculations are based to the 
assumptions  done  to  assume  economical  costs  for  ATFs  (previous  sub-chapter).  The 
following tables shows the number of additional job positions in the ATFs as compared to the 
baseline.  

Table 3-23 Number of additional job positions in the ATFs as compared to the 
baseline 

Material 
Steel  

Scenario 1  

Scenario 2  

Scenario 3 

Scenario 4 

Additional positions (number) as compared to the baseline 

0 

0 

1,196 

1,196 

However, it is needed to mention that this analysis does not consider the development of new 
technologies or a wider application of existing automatic technics to dismantling wires, which 
on one hand would increase the investment costs but on the other decrease the dismantling 
time and potentially decrease the number of employees required for dismantling of wires so 
in  consequence  decrease  the  level  of  salaries.  As  soon  as  it  will  be  possible  to  dismantle 
components by machine, it is to expect that number of employees will reduce.  

248 Especially for these parts/components, which cannot be removed by machines and in MS where labour costs are still not so 
high.  

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Additionally,  more  employees  will  be  needed  for  the  operation  of  new  machines  in 
shredder/PST  and  additional  employees  for  hand  picking/sorting  in  shredder  facility.  In 
Europe there are about 300 shredders/PST. It is expected that relevant investments would 
do done by facilities from middle up to big size, thus not in all existing facilities. There is no 
precise data on shredder/PST and also on the fact if shredder have a PST in house, therefore 
rough assumptions are done: 60% of existing plants are middle or bigger size, for the new 
technological solutions there will be need for 2 employees that could operate new machines. 
It would mean that for Scenario Copper 4 (for which bigger investments are planned) would 
be required to hire additional 360 employees. 

3.1.6.5  Comparison of scenarios for copper 

The differences in impacts of the scenarios as compared to the baseline are compiled in Table 
3-24 below to allow an easier comparison. The scope of the analysis is EoL of copper from 
collected  ELVs,  however  some  of  the  outcomes  either  overlap  with  the  outcomes  of  the 
analysis of other materials or are representative for other material(s) as well. Thus, the finding 
listed below should not be sum up with other summarising tables for the separately analysed 
materials. The overall analysis on the collected ELV level is performed in section 3.1.11.  

Table 3-24 Summarising table for the comparison of the copper scenarios (the 
assessed impacts are based on the total of ELVs collected in 2035) 

Impacts 

Scenario  
Copper 1 

Scenario  
Copper 2 

on ATFs 

c
i
m
o
n
o
c
E

on shredders  

0 € costs due to 
additional 
dismantling249 
(comparing to 
the baseline) 
Additional 
revenues for 
dismantled 
parts/comp. for 
reuse/rem. and 
separate 
recycling 
(+104 mln €) 
- / + 

0 € costs due to 
additional 
dismantling249 
(comparing to 
the baseline) 
Additional 
revenues for 
dismantled 
parts/comp. for 
reuse/rem. and 
separate 
recycling 
(+104 mln €) 
-- / + 

Loss of 
shredding 
material (loss of 
revenue)  
Decrease in 
revenues for 
copper scrap 
(-115 mln €) 
- 

Loss of 
shredding 
material (loss of 
revenue) 
Decrease in 
revenues for 
copper scrap 
(-129 mln €) 
- 

Scenario  
Copper 3 
104 mln € costs 
due to additional 
dismantling 
(comparing to 
the baseline) 
Additional 
investment cost 
in dismantling 
technologies 
Additional 
revenues for 
dismantled 
parts/comp. for 
reuse/rem. and 
separate 
recycling 
(+424 mln €) 
--- / +++ 

Loss of 
shredding 
material (loss of 
revenue)  
Significant 
decrease in 
revenues for 
copper scrap 
(-408 mln €) 
-- 

Scenario  
Copper 4 
98 mln € costs 
due to additional 
dismantling 
(comparing to 
the baseline) 
Additional 
investment cost 
in dismantling 
technologies 
Additional 
revenues for 
dismantled 
parts/comp. for 
reuse/rem. and 
separate 
recycling 
(+264 mln €) 
-- / ++ 
Loss of 
shredding 
material (loss of 
revenue) 
Additional 
investment costs 
in separation 
technologies 
and hand 
picking 
Increase of 
secondary 
copper  

249 Value represents the additional costs for manual dismantling (labour costs), there might occur also additional investment 
costs in the machines for automatic dismantling (especially relevant for scenario Steel 3 and 4). 

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Impacts 

Scenario  
Copper 1 

Scenario  
Copper 2 

Scenario  
Copper 3 

on recyclers 

Small decrease 
in business, due 
to loss of copper 
scrap 
(-11 mln €) 
However, 
increase in 
higher quality 
material 
(dismantled prior 
shredding) 
+ 

Small decrease 
in business, due 
to loss of copper 
scrap 
(-25 mln €) 
However, 
increase in 
higher quality 
material 
(dismantled prior 
shredding) 
+ 

Slightly increase 
in business, due 
to increase of 
copper scrap 
(+16 mln €) 
However, 
increase in 
higher quality 
material 
(dismantled prior 
shredding) 
+ 

Scenario  
Copper 4 
However, still 
decrease in 
revenues for 
copper scrap 
(-252 mln €) 
--- 
Slightly increase 
in business, due 
to increase of 
copper scrap 
(+12 mln €) 
However, huge 
increase in 
higher quality 
material 
(dismantled prior 
shredding), thus 
potentially lower 
processing costs 
to obtain steel of 
high quality 
++ 

on SME  

Other  

Small ATFs would probably have higher costs than larger ones. With higher 
dismantling costs the profitability of the business for the ATFs might be 
questionable and possibly the activities of these facilities might shift to 
illegal activities.  
Economic impacts on other stakeholders can be compared to the total cost 
of vehicles and are considered as marginal 

Administrative 
costs burden 

2ndary resources  

Moderate 
increase in 
administrative 
burden for 
reporting for 
regulators and 
waste 
management 
-- 

Slightly 
decrease in 
availability of 
secondary 
copper 
(-11 mln €) due 
to increase in 
reuse  
- 

Moderate 
increase in 
administrative 
burden for 
reporting for 
regulators and 
waste 
management 
-- 

Decrease in 
availability of 
secondary 
copper 
(-25 mln €) due 
to increase in 
reuse 
- 

High increase in 
administrative 
burden for 
reporting for 
regulators and 
waste 
management 
and developing 
of improvement 
strategies 
--- 

Increase in 
availability of 
secondary 
copper 
(+16 mln €) 
thanks to higher 
dismantling 
+ 

High increase in 
administrative 
burden for 
reporting for 
regulators and 
waste 
management 
and developing 
of improvement 
strategies 
--- 

Increase in 
availability of 
secondary 
copper 
(+12 mln €) 
thanks to better 
sorting  
++ 

Environ
mental 

Environmental 
impacts: LCA 
credits for 
reuse/rem. and 
recycling250 

Social  

Employment251 

Increase in 
credits: 
~50 Mt CO2-eq. 
+ 

Increase in 
credits: 
~66 Mt CO2-eq. 
++ 

Increase in 
credits: ~130 Mt 
CO2-eq. 
++ 

Increase in 
credits: 
~68 Mt CO2-eq. 
++ 

Increase in jobs 
in ATF (0) 
+ 

Increase in jobs 
in ATF (0) 
++ 

Increase in jobs 
in ATF (~1,196) 
+++ 

Increase in jobs 
in ATF (~1,196) 

250 As a difference to the baseline scenario 

251 Increase in comparison to baseline scenario. The calculations done based on dismantling time of engine/gearbox, so the 
values presented here in reality might be even higher while considering more parts/components for dismantling.  

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Impacts 

Scenario  
Copper 1 

Scenario  
Copper 2 

Scenario  
Copper 3 

Scenario  
Copper 4 
Increase in jobs 
in shredder 
facilities (~360) 
++ 

Proportionality  

All scenarios are considered proportional for achieving the objectives that 
the EU Treaties intends to implement 

Cost effectiveness  

Low costs but 
low benefits 
+ 

Similar 
effectiveness to 
scenario 1 in 
GWP and 
amount of 
recycled copper, 
while lower 
costs.  
However, the 
quality of 
recycled 
material is 
lower.  
++ 

Coherence with 
waste legislation 
and the CEAP, 
promoting waste 
treatment of a 
higher hierarchy 
and circularity. 
++ 

Coherence with 
waste legislation 
and the CEAP, 
promoting waste 
treatment of a 
higher hierarchy 
and circularity. 
++ 

Coherence 

Notes: 

-/-: no impact 

Higher costs 
than scenario 2 
thus higher 
amount of 
secondary 
copper as 
scenario 2.  
However, the 
quantity of high-
quality recycled 
copper is the 
highest among 
all scenarios. 
Highest 
effectiveness in 
GWP. 
Highest revenue 
for ATFs. 
+++ 

Coherence with 
waste legislation 
and the CEAP, 
promoting 
maximal 
recycling.  
++ 

Very high costs 
in comparison to 
scenario 2 and 
3. 
However, the 
quality of 
recycled copper 
is higher. 
More secondary 
copper in 
comparison to 
other scenarios. 
Highest revenue 
for shredders.  
+++ 

Coherence with 
waste legislation 
and the CEAP, 
promoting 
maximal high-
quality recycling.  
+++ 

Costs or burdens: between 1 and 3 minus signs (-; --; or ---), indicating low (1 minus sign) and high (3 minus signs) costs or 
burdens 

Benefits or savings: between 1 and 3 plus signs (+; ++; or +++), indicating low to high savings 

(): brackets around symbols if costs, benefits etc. are only potentials or are uncertain. If the costs, benefits etc. is rather 
uncertain, a broader range is indicated: e.g., ++ to +++ or – to + 

n.a.: not applicable 

Please see EPR section in analysis at EEC level in section 3.1.10.1.4 for possible costs of 
dismantling EEC containing copper and in section 3.1.12 on possible costs of PST at vehicle 
level. 

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3.1.7  Analysis for aluminium 

3.1.7.1  Qualitative analysis for aluminium 

Measures were shortlisted for aluminium including the following measures: 

Title 

2.3.e) Establish provisions to support the market of used spare parts composed of aluminium 
2.3.f) Set up a separate (monitoring) target for re-use/preparing for re-use/remanufacturing of 
aluminium components 
2.4.b) Making it mandatory to remove certain copper parts before shredding to encourage 
high quality steel/aluminium and high quantity copper recycling as well as mandatory removal 
of selected parts/components that contain aluminium 
2.4.c) Set material-specific recycling targets for aluminium 
2.4.d) Regulate shredder/post shredder facilities to ensure high quality/quantity of materials 
obtained for recycling and to improve final treatment process 

Chapter 
2.1.5.3.5 
2.1.5.3.6 

2.1.5.4.2 

2.1.5.4.3 
2.1.5.4.4 

Colour code: Red – discarded, Yellow – premature, Grey – supporting measure 

Monitoring of components for reuse/remanufacturing is a supporting measure (2.3.f) that will 
need  to  accompany  provisions  designed  to  increase  the  demand  of  components  for 
reuse/remanufacturing (2.3.e) that contain aluminium, e.g., bumper carrier frames, engines.  

A mandatory removal of certain aluminium components aims to limit ‘poor quality’ material 
recovery  operations  through  removing  components  with  high  contents  of  aluminium  from 
vehicles and sending them to separate recycling. The aluminium fraction dismantled prior to 
shredding  is  a  pre-condition  to  recycling  of  wrought  aluminium  separately  from  cast 
aluminium.  Treatment  of  aluminium  components  together  with  the  rest  of  the  hulk  in  the 
shredder  limits  their  recycling  into  cast  aluminium  only  (European  Aluminium  2022).  In 
addition, the value of secondary aluminium is linked to the prices for primary aluminium and 
depends on its quality and can go as high as the value of primary aluminium itself.  

Regulation of shredder/post-shredder facilities and especially the standardisation of outputs 
from these facilities, could lead to the improvement of existing technologies or promote the 
dismantling of relevant aluminium components prior to shredding.  

Setting a separate recycling target for (wrought and cast) aluminium would also aim at gaining 
high  quality  aluminium.  However,  reporting  on  reuse  and  recycling/recovery  targets  would 
create significant administrative burden. The most challenging would be obtaining the weight 
of  the  specific  materials  (in  this  case  wrought  and  cast  aluminium)  in  the  components  for 
reuse/remanufacturing.  Additionally,  tracking  of  materials  from  the  ELVs  in  the  shredder 
process is hampered since ELVs that are processed in these facilities often are mixed with 
other items. Setting only the material-specific recycling target (excluding the components for 
reuse/remanufacturing 
promoting 
reuse/remanufacturing.  Also  identifying  a  meaningful  level  of  these  targets  would  be 
extremely challenging. Hence, a separate target for copper is discarded at this stage but could 
be  reconsidered  in  the  future  if  the  implementation  of  other  measures  does  not  lead  to  a 
sufficient improvement in circularity. 

contra-productive 

it)  would 

from 

act 

for 

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3.1.7.2  Scenarios for quantitative analysis  

3.1.7.2.1  Baseline Aluminium 

EU wide the commonly applied methods to treat aluminium from ELVs, similarly to steel, are 
shredder operations, usually combined with some type of post-shredder treatment operations. 
Recycling results in a fraction (termed zorba), which has a high Al content but is also rich in 
impurities as it is a mix of different alloys. It can be applied in higher amounts in alloys which 
are more susceptible to impurities (e.g., casting alloys) but not in alloys where a high purity is 
required (e.g., wrought alloys). However, for some car parts the recycling practice might differ. 
According to (European Aluminium 2022) currently ICE engines are often dismantled before 
the shredding process and are directly sold either for reuse or to aluminium recyclers without 
further pre-treatment. Aluminium engines are thus often not shredded. The same happens to 
wheels that are dismantled together with tyres before shredding. The aluminium wheels are 
directly  sold  to  aluminium  recyclers  without  further  pre-treatment.  Thus,  aluminium  wheels 
are  not  shredded.  The  findings  of  (IRT  M2P  2021)  show  that  dismantling  of  aluminium 
components  from  ELVs  is  profitable  only  for  heavy  components  (more  than  10  kg)  and 
performed  within  only  a  few  minutes  of  dismantling.  Otherwise,  the  labour  and  specific 
investment costs will exceed the possible revenue from selling of removed components. 

Technologies to separate aluminium from other fractions are commonly applied to treat post-
consumer  scrap.  However,  technologies  to  separate  different  aluminium  alloys  from  each 
other  in  post-consumer  scrap  are  not  applied  at  the  moment.  According  to  (European 
Aluminium  2022)  a  lot  of  research  and  testing  is  ongoing  to  improve  the  speed  of  such 
technologies and the reliability. These types of technologies however are very expensive for 
now, thus funding is a key point to have more widespread use of post-shredding technologies 
and  quality  control  instruments  that  will  contribute  to  improve  the  quality  of  the  aluminium 
fraction.  

On this basis, it is assumed that under the baseline, aluminium shall continue to be treated 
mainly in shredder/PST, with the chance that the quality of obtained deliverables will improve 
together  with  development  of  new  technologies.  Dismantling  of  specific  components  for 
recycling  potentially  might  increase,  however,  similarly  to  treatment  in  shredder/PST,  the 
economic  viability  may  be  questionable.  As  said  above,  its  profitability  may  depend  on 
additional financing.  

3.1.7.2.2  Scenario Aluminium 1: Monitoring of components 
composed of aluminium for reuse/remanufacturing 

this  scenario 

the  monitoring  of  components  composed  of  steel 

Under 
for 
reuse/remanufacturing  shall  be  introduced.  For  this  purpose,  a  list  of  components 
recommended for reuse/remanufacturing (Annex to ELVD) would be defined. A preliminary 
list prepared in this report contains also elements made of aluminium, e.g., engines, bumpers 
carrier  frames.  This  list  should  be  revised  from  time  to  time  to  consider  current  market 
situation of components for reuse and for remanufacturing.  

This  scenario  also  considers  implementation  of  harmonised  monitoring  of  components 
removed for reuse/remanufacturing to understand the actual volume of them in different MS 
and will enable the comparability of monitoring data. Obtained information will allow a better 
understanding  of  the  potential  for  reuse  and  how  it  is  influenced  by  measures  that  affect 
market demand. It will also help in the future in the revision of the list of removed spare parts 
as well as to potentially set out the targets. The reporting obligation would be limited to the 
components  listed  in  the  Annex  to  ELVD  (“list  of  components  recommended  for 

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reuse/remanufacturing”).  However,  separate  reporting  on  other  components  sold  for 
reuse/remanufacturing is proposed to be voluntary at this stage as it could create a burden 
for ATFs if it cannot be linked to an existing list of sales. 

3.1.7.2.3  Scenario  Aluminium  2:  Market  support  of  used 

spare parts composed of aluminium 

Under this scenario the market demand for spare parts should be regulated by requiring car 
repair shops to provide customers with an offer to repair a vehicle with used/remanufactured 
components alongside offers for repair with new components. Insurance companies will also 
be obliged to offer car owners discounted policies if they agree that repairs are performed 
with reused/remanufactured parts when these are available. Furthermore, a ban of the online 
sales of illegally operating facilities would be introduced.  

Use  of  spare  parts  is  market  driven,  thus  increasing  demand  is  assumed  to  provide  more 
flexibility  to  ATFs  to  decide  on  components  to  be  dismantled  as  opposed  to measures  for 
increasing supply which could result in a high burden for storage without significant impact 
on  the  actual  reuse/remanufacturing  of  components.  Obligations  for  insurance  companies 
may only be implementable through national legislation. Strengthening the market demand 
for  reused  components  will  increase  the  profitability  of  dismantling  relevant  components. 
Provisions  on  online  sales  will  reduce  sales  of  used  components  from  illegally  operating 
facilities, increasing profitability of legally operating ones. Again, these provisions may only 
be implementable through national legislation. 

  Scenario Aluminium 3: Mandatory removal of certain copper parts before 
shredding to encourage high quality steel/aluminium recycling and high 
quantity  copper  recycling  as  well  as  mandatory  removal  of  selected 
parts/components that contain aluminium 

A dismantling obligation for aluminium-bearing components is already provided by the ELVD, 
but only if the copper is not segregated in the shredding process.  

For aluminium it can be understood that recycling results in a fraction (termed zorba) which 
has a high Al content but is also rich in impurities as it is a mix of different alloys. It can be 
applied in higher amounts in alloys which are more susceptible to impurities (e.g., used for 
casting). However, to enable use in alloys with higher quality specifications, dismantling would 
need to be improved: aluminium parts would need to be sorted prior to shredding for example 
into  cast  alloy  parts  and  wrought  alloy  parts.  Eurometaux  (Eurometaux  21  Feb  2021) 
mentions  bumpers,  doors,  the  engine  block  as  parts  of  relevance  for  removal  prior  to 
shredding. This statement is in line with the Circular Aluminium Action Plan252.  

More about legitimacy of aluminium dismantling is detailed in section 2.1.2.5.3 on “Current 
situation: aluminium”.  

Copper content in shredder/PST deliverables is considered an impurity also for fractions rich 
in  aluminium.  Similar  to  steel,  Eurometaux  state  that  the  dismantling  of  components  with 
copper  prior  to  shredding  would  allow  secondary  aluminium  of  higher  purity.  Benefits  of 
copper removal related to EEC from the aluminium/steel fraction are mentioned shortly under 
the EEC chapter (see section 3.1.10).  

252 engines, heat exchangers, doors, bonnets, fenders, bumpers and gearboxes 

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3.1.7.2.4  Scenario  Aluminium  4:  Regulate  shredder/post-
shredder facilities to ensure high quality/quantity of 
materials  obtained  for  recycling  and  to  improve 
final treatment process 

The  intention  of  this  scenario  is  to  ensure  high  recovery  of  metals  from  the  shredder/PST 
residues. It aims also to obtain high-quality recycling output from these treatment plants. To 
obtain the goal, a legally binding maximum metal content for shredder residues253 should be 
set up at ambitious level in order to recover as many metals as possible as secondary raw 
materials  and  should  be  oriented  at the  best  available  technical  practices.  The removal  of 
metal from the shredder light fraction at least to below 1 % metal content by means of post-
shredder separation (Tabel et al. 2011) is considered to be feasible for this purpose. 

On the other side copper content in shredder/PST deliverables is considered an impurity also 
for  fraction  rich  in  aluminium.  Similar  to  steel,  Eurometaux  state  that  the  dismantling  of 
components with copper prior to shredding would allow secondary aluminium of higher purity. 
Benefits of copper removal related to EEC from the aluminium/steel fraction are mentioned 
shortly under the EEC chapter (see section 3.1.10). 

The full implementation of this scenario would require setting up a maximum copper content 
in  steel  scrap254  (output  from  shredders/PST)  that  is  sourced  from  recycling,  possibly  by 
means  of  a  European  standard,  e.g.,  currently  under  development 
is  “European 
standardisation  deliverables  on  Road  vehicles  –  Post-shredding  recycling  –  design-for-
recycling guidelines for plastic products”255. 

For more information, please refer to the information on copper in the current situation chapter 
and measure description (2.1.2.5.2 and 2.1.5.4.2). 

3.1.7.3  Results of quantitative analysis  

Through  scenario  Aluminium  1  and  Aluminium  2  it  is  intended  to  increase  the 
reuse/remanufacturing  level  of  components  in  ELVs  incl.  those  containing  aluminium. 
Aluminium 1 in a way intends to increase the attention of ATF to components reusability as 
well as support the policy makers in understanding the market situation of components with 
a potential for reuse, their dismantling and reusability. On the other hand, scenario Aluminium 
2, includes legally binding obligations for ATFs and insurance companies, thus, it is expected 
that the level of dismantling would be higher in scenario Aluminium 2 than in Aluminium 1.  

However, implementation of the scenario Aluminium 2 requires legal adjustments mainly at 
the  national  level,  which  may  affect  their  implementability  by  all  Member  States.  Both 
scenarios  would  require  development  of  administrative  support 
i.e., 
monitoring/reporting.  Where  it  is  not  possible  to  reuse/remanufacture  components  already 
dismantled, they can be sent to separate recycling avoiding shredder process.  

terms  of 

in 

Scenario Aluminium 3 aims to dismantle copper- and aluminium-bearing components prior 
shredding.  This  would  require  additional  step  before  shredding  and  will  lead  to  additional 

253 destined for backfilling/ landfill construction, energy recovery/ incineration or final disposal/landfill sites 

254 More on possible max value under description of measure. 

255 
file:///C:/Users/I65A1~1.KOS/AppData/Local/Temp/Draft%20standardisation%20request%20as%20regards%20medical%20d
evices%20and%20in%20vitro%20diagnostic%20medical%20devices.pdf  

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costs for ATFs. Dismantling could be done manually or automatically, for parts that are easily 
accessible.  

Aluminium parts would need to be sorted prior to shredding for example into cast alloy parts 
and wrought alloy parts. Due to mandatory dismantle of parts containing copper, aluminium 
scrap  should  be  of  higher  purity  additionally.  Dismantled  components  might  be  shifted  for 
reuse/remanufacturing,  as  well  as  more  secondary  material  would  be  available  for  (high-
quality) recycling. 

Scenario Aluminium 4 aims to obtain: 1) a higher quantity of metals (ferrous and non-ferrous) 
for recycling, 2) a high-quality steel and aluminium scrap for recycling.  

Introduction of this provision would require regular checks of the obtained outcomes/residues 
from  shredder.  The  monitoring  under  this  scenario  would  require  development  of  a 
harmonised testing approach. This can be done twofold: either by shredder or by recycler. 
The testing of the steel scrap samples is less precise as chemical analysis of smelted input 
material to EAF. However, material put into EAF normally is coming from different sources, 
what  might  of  challenge  to  assess  the  composition  of  each  input  material  separately  (this 
issue require further investigation).  

Reporting  on  the  aluminium  scrap  quality  would  also  involve  development  of  a  reporting 
scheme that to submit by facilities (shredders/recycler) the monitoring results to the authority 
to be responsible for controlling.  

There are two possible actions once the results of monitoring are not satisfactory: 

1) the authorities could develop local/regional/national strategies to improve the situation, by, 
e.g., introduction of mandatory disposal of parts that contain copper before shredding (if not 
implemented yet).  

2) modulation on price for steel scrap for recycling. 

3.1.7.4  Results of quantitative analysis  

For the purpose of analysis, the total aluminium from collected ELVs in 2035 was considered. 
In all scenarios, it is assumed that some part256 of aluminium treated in the shredder remains 
in the257 steel fraction.  

A different share is assumed to be dismantled in each scenario. In Scenario Aluminium 1 and 
2 the share for reuse/remanufacturing is lower in comparison to Scenario Aluminium 3 and 4. 
In the Scenario Aluminium 3 high shares of dismantled aluminium components are sent to 
the recycler directly (skipping shredding process).  

The  following  table  specifies  the  rates  that  have  been  assumed  for  each  scenario  as 
dismantled,  reused,  recycled  pre-  or  post-shredder,  recovered,  or  lost;  and  with  which 
quantitative impacts have been calculated. 

256 In the model it is assumed that 50% of calculated material losses in EoL remains in the steel scrap. The other 50% is 
disposed. More detail about model in Annex I.  

257 This aluminium in the steel fraction has a value since it can act as a reducing agent in steel recycling. Aluminium is then 
used to produce alloys of iron. For aluminium that ends up in the steel recycling, a corresponding credit for saved coke is 
applied in the model. 

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Table 3-25 Routes of treatment for aluminium under the various scenarios  

Dismantled -> 
reused/remanufactured 
Dismantled -> recycled (no 
shredding) 
Dismantled -> shredded -> 
recycled 
Shredded -> recycled 

Part diverted to steel scrap 
(energy recovery) 
Losses/process inefficiencies 

Baseline 

Scenario 1  Scenario 

Scenario 3  Scenario 

2 

4 

10% 

14% 

15% 

1% 

2% 

69% 

9% 

9% 

3% 

4% 

61% 

8% 

8% 

4% 

4% 

60% 

8% 

8% 

18% 

22% 

8% 

33% 

6% 

6% 

18% 

9% 

10% 

45% 

7% 

7% 

Source: Oeko-Institut: own assumptions 

Based on this description and the shares specified in Table 3-26, in the baseline and in each 
scenario,  the  amounts  that  would  be  reused/remanufactured  as  well  as  recycled  pre-  and 
post-shredder were calculated (Figure 3-7). The total mass of aluminium in EoL vehicles is 
assumed to be about 1,240 Mt in 2035.  

Table 3-26 Tonnes of aluminium from collected ELVs assumed to be either reused or 
recycled and losses of the material in the treatment process (in 2035) 

Total of the material in EoL vehicles (without 
battery) [tonnes] 

Total of the material in EoL vehicles (without 
battery) 
In components for reuse/remanufacturing 

Recycled material of potentially higher quality 
(Directly recycled, no shredding) 
Recycled material after shredding  

Baseline 

1,240,100 

Scenario 
1 
1,240,100 

Scenario 
2 
1,240,100 

Scenario 
3 
1,240,100 

Scenario 
4 
1,240,100 

124,000 

173,600 

186,000 

223,200 

223,200 

9,200 

41,300 

45,800 

275,100 

114,600 

888,700 

821,600 

807,700 

583,000 

719,400 

Part diverted to steel scrap (energy recovery) 

109,100 

101,800 

100,300 

Losses/process inefficiencies (Direct recycling) 

Losses/process inefficiencies (Shredder) 

Losses/process inefficiencies (Recycling) 

300 

83,000 

25,900 

1,200 

76,700 

23,900 

1,300 

75,400 

23,500 

79,400 

8,000 

54,400 

17,000 

91,400 

3,300 

67,200 

20,900 

Table 3-27 Change in tonnes of materials for recycling comparing to the baseline ["-" 
decrease, "+" increase] (in 2035) 

Change in tonnes of materials for recycling 
comparing to the baseline  
["-" decrease, "+" increase]  

Recycled material of potentially higher quality 
(Directly recycled, no shredding) 
Recycled material after shredding  

Baseline 

Scenario 
1 

Scenario 
2 

Scenario 
3 

Scenario 
4 

32,100 

36,600 

265,900 

105,400 

-67,100 

-81,000 

-305,700 

-169,300 

TOTAL 

-35,000 

-44,400 

-39,800 

-63,900 

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Figure 3-7  Tonnes of aluminium from collected ELVs assumed to be either reused or 
recycled and losses of the material in the treatment process (in 2035) (kg) 

Source: Own illustration  

3.1.7.4.1  Environmental impacts 

Based on this description and the shares specified in Table 3-26, in the baseline and in each 
scenario,  the  amounts  that  would  be  reused/remanufactured  as  well  as  recycled  pre-  and 
post-shredder are calculated. The obtained results are masses of aluminium multiplied by the 
respective environmental impacts in terms of global warming potential. This is shown below 
for all bumper carrier frames made of aluminium from ELVs collected in the year 2035 (Figure 
3-8). 

Table 3-28 Credits for Global warming potential (GWP) for each scenario for 
aluminium in collected ELVs in 2035 to primary production (Mt CO2eq) 

Environmental impact in GWP 
(without battery) [Mt CO2-eq.]  
["-" environmental credits, "+" 
environmental burdens] 

In components for 
reuse/remanufacturing 
Recycled material of potentially 
higher quality (Directly recycled, no 
shredding) 
Recycled material after shredding  

Part diverted to steel scrap (energy 
recovery) 
Losses/process inefficiencies (Direct 
recycling) 

Losses/process inefficiencies 
(Shredder) 
Losses/process inefficiencies 
(Recycling) 

Baseline 

Scenario 1  Scenario 2  Scenario 3  Scenario 4 

-2,389,200 

-3,344,800 

-3,583,700 

-4,300,500 

-4,300,500 

-138,600 

-623,500 

-692,800 

-4,156,700 

-1,732,000 

-10,435,700 

-9,647,500 

-9,484,800 

-6,845,900 

-8,447,500 

-1,375,200 

-1,284,100 

-1,264,500 

-1,006,500 

-1,154,800 

200 

800 

800 

5,000 

2,100 

52,100 

48,200 

47,400 

34,200 

42,200 

16,200 

15,000 

14,800 

10,700 

13,100 

TOTAL 

-14,270,000 

-14,836,000 

-14,963,000 

-16,260,000 

-15,577,000 

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Table 3-29 Change in tonnes of materials for recycling comparing to the baseline ["-" 
decrease, "+" increase] (in 2035) 

Change in Mt CO2-eq. 
comparing to the baseline  
["-" decrease, "+" increase] 

Recycled material of potentially 
higher quality (Directly recycled, no 
shredding) 
Recycled material after shredding 
(incl. Steel in tyres) 
TOTAL for recycling (excl. reuse and 
burdens due to losses/process 
inefficiencies) 
TOTAL of the whole process steps 
(e.g. reuse, recycling, etc.) 

Baseline 

Scenario 1  Scenario 2  Scenario 3  Scenario 4 

-484,900 

-554,200 

-4,018,100 

-1,593,400 

788,200 

950,900 

3,589,800 

1,988,200 

303,300 

396,700 

-428,300 

394,800 

-566,000 

-693,000 

-1,990,000 

-1,307,000 

Figure 3-8  Credits for Global warming potential (GWP) for scenarios for aluminium in 
collected ELVs in 2035 compared to primary production (kg CO2eq) 

Source: Own illustration  

The figure above shows an LCA comparison of the dismantling and recycling route with the 
shredder  route  where  it  is  concluded  that  the  shredder  and  recycling  route  have  major 
environmental impacts, while dismantling has a minor environmental impact. Although, larger 
environmental benefits can be seen for dismantled aluminium parts sent to recycling avoiding 
the shredding process (Scenario Aluminium 3 that assume mandatory dismantling).  

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The following figures illustrate GWP for wrought aluminium and cast aluminium separately. 
For the  calculation  the  separate  route  of  treatment for  each  aluminium  type  was  assumed 
(Table  3-36  and  Table  3-37)258.  GWP  for  Scenario  Wrought  Aluminium  3  (Figure  3-9) 
visualises rank of dismantling of wrought aluminium and its recycling prior shredding.  

Figure 3-9  Credits for Global warming potential (GWP) for scenarios for wrought 
aluminium in collected ELVs in 2035 compared to primary production (kg CO2eq) 

Source: Own illustration  

258 Based on this estimation the route of treatment of overall aluminium was calculated. 

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Figure 3-10  Credits for Global warming potential (GWP) for scenarios for cast 
aluminium in collected ELVs in 2035 compared to primary production (kg CO2eq) 

Source: Own illustration  

Table 3-30 Routes of treatment for wrought aluminium under the various scenarios  

Dismantled -> 
reused/remanufactured 
Dismantled -> recycled (no 
shredding) 
Dismantled -> shredded -> 
recycled 
Shredded -> recycled 

Part diverted to steel scrap 
(energy recovery) 
Losses/process inefficiencies 

Baseline 

Scenario 1  Scenario 

Scenario 3  Scenario 

2 

4 

10% 

14% 

15% 

2% 

1% 

70% 

9% 

9% 

9% 

1% 

61% 

8% 

8% 

9% 

1% 

59% 

8% 

8% 

18% 

57% 

1% 

17% 

4% 

4% 

18% 

24% 

1% 

45% 

6% 

6% 

Source: Oeko-Institut: own assumptions 

Table 3-31 Routes of treatment for cast aluminium under the various scenarios  

Dismantled -> 
reused/remanufactured 
Dismantled -> recycled (no 
shredding) 
Dismantled -> shredded -> 
recycled 
Shredded -> recycled 

Part diverted to steel scrap 
(energy recovery) 
Losses/process inefficiencies 

Baseline 

Scenario 1  Scenario 

Scenario 3  Scenario 

2 

4 

10% 

14% 

15% 

0% 

3% 

69% 

9% 

9% 

0% 

7% 

62% 

8% 

8% 

0% 

8% 

60% 

8% 

8% 

18% 

0% 

16% 

50% 

8% 

8% 

18% 

0% 

20% 

46% 

8% 

8% 

Source: Oeko-Institut: own assumptions 

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3.1.7.4.2  Economic impacts 

Investment costs 

Investment  costs  are  considered  to  arise  in  each  scenario  as  well  as  in  the  baseline.  In 
Scenario  Aluminium  1  and  Aluminium  2  are  expected  to  occur  bit  higher  costs  than  in 
baseline. Implementation of Scenario Aluminium 3 would potentially require investment in 
dismantling machines and tools by ATFs for removal of mandatory parts. These costs would 
in  similar  high  also  appear  in  Scenario  Aluminium  4  together  with  additional  costs  for 
shredder/PST to improve their efficiency in removing copper from steel/aluminium scrap and 
metals in the residues from PST. Assuming transition time in introduction of the provision on 
the quality of outcomes/residues from shredders/PSTs the investments costs would be shifted 
in time. This additional time would be required for further development of methods for removal 
of copper, which are in practice under certain conditions and could be expanded or need to 
be scale-up since are proven only at laboratory scale (please refer to 2.1.2.5.1, 2.1.2.5.2, and 
2.1.5.4.4).  The  share  on  the  investment  costs  either  for  increased  dismantling  or  higher 
develop  shredder  technologies,  might  differ  among  MS,  since  the  provision  introduced 
together with Scenario Aluminium 4 would not prescribe how defined thresholds need to be 
achieved. Some countries might develop strategy to dismantle more parts that contain copper 
before shredding and improve hand picking after shredding instead of investing in e.g., sorting 
machines.  This  approach  might  increase  labour  costs.  (Daehn  et  al.  2017a)  illustrates 
effectiveness  (copper  concentration  achievable)  to  qualitative  energy/cost  for  various 
technologies to separate copper (Figure 2-24). 

The  main  stakeholder  of  EoL  automotive  sector  are  ATFs,  shredder  and  PST  facilities, 
recyclers, and garage (repair shops that have no official approval to dismantle ELVs). As it is 
introduced in several parts of this report (e.g. 2.3.2.3 and 3.2.5), more challenging regulations 
in the context of the Circular Economy, aiming for a higher quality recycling, might require at 
the end more effort at ATFs. Shredder and PST facilities in practice are always profitable that 
in  case  of  high  investments  costs  or  low  revenues  for  sold  outcomes  of  their  treatment 
process, would compensate their costs by decreasing price for input material. In that case, 
economical effort is put on ATFs, which might not be covered by revenues, and would cause 
decrease of their profits. This in consequence might lead to a reduction of the competitiveness 
of ATFs with the illegal sector.  

The  operation  costs  for  shredding/PST  are  not  accessible  und  unclear  and,  according  to 
(EGARA 2022a), “financial results are… not detailed enough”, and it is not sufficiently clear 
that PST will actually reach a sufficient quality at lower cost than dismantling.  

Further costs and revenues 

Aside from the difference in costs of aluminium processing from ELVs, a further economic 
aspect  is  related  to  the  expected  administrative  cost  of  reporting.  Under  the  baseline, 
Commission  Decision  2005/293/EC,  which  specifies  the  current  reporting  rules,  already 
requires MS to report on the “metal components” arising from depollution and dismantling in 
Table 1. However, this data is voluntary and mandator is only a sum of all depolluted and 
dismantled materials, incl. “metal components”. Introduction of scenario Aluminium 1 (and 
especially the monitoring aspect) will require adjustment of the reporting format as well as 
changing the reporting from voluntary to mandatory. This adjustment is assumed to result in 
additional  economical  costs  for  public  administration  as  well  as  for  ATF  that  report  on 
removed  parts/components  (please  refer  to  the  Table  3-61,  presenting  these  costs  under 
economic impacts of measures addressing the treatment of vehicles at EoL).  

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These additional costs will be related to the additional time for collecting all data for ATFs 
thus more cells to fill in, as precise reporting of the total weight of reused parts/components 
is  to  be  required  for  each  component  in  the  reporting  table.  Optimally,  if  ATFs  would  also 
report on the material composition of the dismantled parts/components, but this would require 
more thorough information for the producers, e.g., in IDIS. More time will also be needed for 
the institution that collects, summarises, and validates data before its official publication. It is 
to  assume  that  the  expected  additional  administrative  cost  of  reporting  would  be  similar 
significantly  higher  for  scenario  Aluminium  2  in  comparison  to  Aluminium  1.  Some  cases 
repair  shops  (including  ATFs)  already  apply  reused  parts,  anyway  the  obligation  under 
Aluminium 2 would lead to an increase in such activities. Further costs under this scenario 
are related to implementation of enforcement against illegal sales of reused components, thus 
MS would need to inspect online sale platforms to ensure no illegal activities.  

Aluminium 3 considers mandatory dismantling, what can affect investment costs (introduced 
above under investment costs) but also labour costs. The average costs of labour work as 
well as the number of dismantled parts/components ahead shredding differ among MS, thus 
the  possible  increase  of  additional  costs  for  MS  might  differ,  while  introducing  mandatory 
dismantling. Administrative costs for reporting on dismantled parts are assumed to be higher 
than in Scenario Aluminium 1 despite already existing scheme on reporting. It is assumed 
that  for  ATFs  it  would  be  an  additional  effort  due  to  higher  number  of  dismantled 
parts/components  as  well  as  due  to  need  to  provide  more  data  on  weight  and  kind  of 
dismantled parts/components. In case when Scenario Aluminium 1 and Aluminium 3 would 
be implemented together, the administrative costs for reporting would not sum up259, because 
while reporting on dismantled part/components, ATFs would highlight for which purpose it is 
dismantled (reuse/remanufacturing, recycling). However, the level on detail on reporting on 
dismantled parts would increase.  

Additional  costs  will  also  exist  due  to  requirement  on  reporting  on  the  quality  of 
shredders/PSTs deliverables (scenario Aluminium 4). These costs will appear for facilities’ 
operators (shredder or/and recycler depending on the agreed measurement point) as well as 
for public authorities, however it is expected that these costs will be higher for facilities. As 
described above, public offices will need to collect data, validate it, and assess the situation 
(locally, regionally, or nationally) and to eventually establish an improvement strategy when 
it is necessary.  

The  administrative  costs  for  each  aluminium  scenario  are  highlighted  in  the  Table  3-61 
presenting the analysis of measures addressing the treatment of vehicles on EoL.  

Table and Figure below highlight possible high of revenues for aluminium scrap for analysed 
scenarios  (2035).  These  values  do  not  consider  revenues  for  dismantled  components  for 
reuse/remanufacturing as well as costs for this process.  

Table 3-32 Revenues for aluminium scrap of potentially higher quality and obtained 
after shredding in million Euro. Below also a change in million Euro of these 
revenues comparing to the baseline. 

Total of the revenues for recycled material [mln 
Euro] 

Baseline 

Scenario 
1 

Scenario 
2 

Scenario 
3 

Scenario 
4 

Recycled material of potentially higher quality 
(Directly recycled, no shredding) 

Recycled material after shredding (incl. Steel in tyres) 
TOTAL 

11 

860 

871 

48 

795 

843 

53 

781 

834 

319 

564 

883 

133 

696 

829 

259 Relevant for components for reuse/remanufacturing arise on the list for monitoring.  

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Table 3-33 Change in million Euro of these revenues comparing to the baseline ["-" 
decrease, "+" increase] 

Change in mln Euro of revenues comparing to 
the baseline  
["-" decrease, "+" increase] 

Recycled material of potentially higher quality 
(Directly recycled, no shredding) 

Recycled material after shredding (incl. Steel in tyres) 
TOTAL 

Baseline 

Scenario 
1 

Scenario 
2 

Scenario 
3 

Scenario 
4 

37 

-65 

-28 

42 

-79 

-37 

308 

-296 

12 

122 

-164 

-42 

Source: own calculations, the prices assumed for the calculations distinguish the aluminium 
scrap  quality,  thus  amounts  of  aluminium  send  directly  to  recycler  after  dismantling  (no 
shredding) are categorised as secondary wrought aluminium and are higher than the prices 
for  aluminium  shredded  (categorised  as  secondary  cast  aluminium).  Current  prices  were 
taken  for  the  calculations.  Lowest  raw  represents  a  total  and  percentage  of  revenue’s 
decrease/increase in each scenario 1 to 4 in comparison to baseline (decrease in revenue is 
due to, e.g., higher reuse/remanufacturing or direct recycling of components dismantled by 
ATFs). Similarly as for steel scenario, the calculation of economic costs for ATF based on the 
dismantling and deep dismantling of engines. To avoid double counting, the ATFs costs of 
dismantling  of  50 %  engines  as  well  as  33 %  of deep-dismantled  engines  are  allocated to 
aluminium scenario. For more details, please refer to chapter on Economic impacts in steel 
scenario.  

The average cost per hour is 51 Euros (base on the information from EGARA). 

Following table show the total costs in million Euro for baseline and additional dismantling 
costs (as compared to the baseline, also in mln Euro) 

Table 3-34 Total costs for baseline and additional dismantling costs (as compared to 
the baseline) in million Euro 

Total costs, in 
million Euro 
Baseline 

Material 
Copper  

Additional dismantling costs (as compared to the baseline, in million Euro) 

Scenario 1  

Scenario 2  

Scenario 3  

Scenario 4  

21 

1 

7 

48 

31 

3.1.7.4.3  Social impacts 

Based on one example the possible social impact is calculated. Calculations are based to the 
assumptions  done  to  assume  economical  costs  for  ATFs  (previous  sub-chapter).  The 
following tables shows the number of additional job positions in the ATFs as compared to the 
baseline.  

Table 3-35 Number of additional job positions in the ATFs as compared to the baseline 

Material 
Steel  

Scenario 1  

Scenario 2  

Scenario 3 

Scenario 4 

Additional positions (number) as compared to the baseline 

12 

86 

582 

383 

Additionally, employees will be needed for the operation of new machines in shredder/PST 
and  additional  employees  for  hand  picking/sorting  in  shredder  facility.  In  Europe  there  are 
about 300 shredders/PST. It is expected that relevant investments would do done by facilities 
from  middle  up  to  big  size,  thus  not  in  all  existing  facilities.  There  is  not  precise  data  on 
shredder/PST  and  also  on  the  fact  if  shredder  have  a  PST  in  house,  therefore  rough 
assumptions  are  done:  60%  of  existing  plants  are  middle  or  bigger  size,  for  the  new 
technological solutions there will be need for 2 employees that could operate new machines. 

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It would mean that for Scenario Steel 4 (for which bigger investments are planned) would be 
required to hire additional 360 employees. 

3.1.7.5  Comparison of scenarios for aluminium 

The differences in impacts of the scenarios as compared to the baseline are compiled in Table 
3-36 below  to  allow  an  easier  comparison.  The  scope  of  the  analysis  is  EoL  of  steel  from 
collected  ELVs,  however  some  of  the  outcomes  either  overlap  with  the  outcomes  of  the 
analysis of other materials or are representative for other material(s) as well. Thus, the finding 
listed below should not be sum up with other summarising tables for the separately analysed 
materials. The overall analysis on the collected ELV level is performed in section Table 3-36.  

Table 3-36 Summarising table for the comparison of the steel scenarios (the 
assessed impacts are based on the total of ELVs collected in 2035)  

Impacts 

Scenario  
Aluminium 1 

Scenario  
Aluminium 2 

Scenario  
Aluminium 3 

Scenario  
Aluminium 4 

1 mln € costs due 
to additional 
dismantling260 
(comparing to the 
baseline) 

Additional 
revenues for 
dismantled 
parts/comp. for 
reuse/rem. and 
separate recycling 
(+37 mln €) 

- 

 7 mln € costs 
due to additional 
dismantling260 
(comparing to 
the baseline) 

Additional 
revenues for 
dismantled 
parts/comp. for 
reuse/rem. and 
separate 
recycling 
(+428 mln €) 

-- 

48 mln € costs 
due to additional 
dismantling 
(comparing to 
the baseline) 

Additional 
investment cost 
in dismantling 
technologies  

Additional 
revenues for 
dismantled 
parts/comp. for 
reuse/rem. and 
separate 
recycling 
(+309 mln €) 

--- / + 

on ATFs 

c
i
m
o
n
o
c
E

on shredders  

Loss of shredding 
material (loss of 
revenue) 

Loss of 
shredding 
material (loss of 
revenue) 

Loss of 
shredding 
material (loss of 
revenue)  

Decrease in 
revenues for 
material scrap 
(-65 mln €) 

- 

Decrease in 
revenues for 
material scrap 
(-79 mln €) 

Decrease in 
revenues for 
material scrap 
(-296 mln €) 

- 

-- 

31 mln € costs 
due to additional 
dismantling 
(comparing to the 
baseline) 

Additional 
investment cost in 
dismantling 
technologies  

Additional 
revenues for 
dismantled 
parts/comp. for 
reuse/rem. and 
separate recycling 
(+122 mln €) 

--- / + 

Loss of shredding 
material (loss of 
revenue) 

Additional 
investment costs 
in separation 
technologies and 
hand picking 

Decrease in 
revenues for 
material scrap 
(-164 mln €) 

--- / +++ 

260 Value represents the additional costs for manual dismantling (labour costs), there might occur also additional investment 
costs in the machines for automatic dismantling (especially relevant for scenario 3 and 4). 

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Impacts 

Scenario  
Aluminium 1 

Scenario  
Aluminium 2 

Scenario  
Aluminium 3 

Scenario  
Aluminium 4 

on recyclers 

Small decrease in 
business, due to 
loss of material 
scrap (-28 mln €) 
However, 
increase in higher 
quality material 
(dismantled prior 
shredding) 

0 

Small decrease 
in business, due 
to loss of 
material scrap 
(-37 mln €) 

Small decrease 
in business, due 
to loss of 
material scrap 
(+12 mln €) 

However, 
increase in 
higher quality 
material 
(dismantled prior 
shredding) 

However, 
increase in 
higher quality 
material 
(dismantled prior 
shredding) 

+ 

+ 

Small decrease in 
business, due to 
loss of material 
scrap (-42 mln €) 

However, increase 
in higher quality 
material 
(dismantled prior 
shredding) 

++ 

on SME  

Small ATFs would probably have higher costs than larger ones. With higher 
dismantling costs the profitability of the business for the ATFs might be 
questionable and possibly the activities of these facilities might shift to illegal 
activities.  

Other  

Economic impacts on other stakeholders can be compared to the total cost of 
vehicles and are considered as marginal 

Administrativ
e 
costs 
burden 

Moderate 
increase in 
administrative 
burden for 
reporting for 
regulators and 
waste 
management 
-- 

Moderate 
increase in 
administrative 
burden for 
reporting for 
regulators and 
waste 
management 

-- 

High increase in 
administrative 
burden for 
reporting for 
regulators and 
waste 
management 
and developing 
of improvement 
strategies 

High increase in 
administrative 
burden for 
reporting for 
regulators and 
waste 
management and 
developing of 
improvement 
strategies 

--- 

--- 

Decrease in 
availability of 
secondary steel 
(-28 mln €) due to 
increase in reuse 

- 

Decrease in 
availability of 
secondary steel 
(-37 mln €) due 
to increase in 
reuse 

Decrease in 
availability of 
secondary steel 
(+12 mln €) due 
to increase in 
reuse 

- 

- 

Decrease in 
availability of 
secondary steel 
(-42 mln €) due to 
increase in reuse 

++ 

Increase in 
credits: ~566 Mt 
CO2-eq. 

Increase in 
credits : ~ Mt 
CO2-eq. 

Increase in 
credits: ~2,095 
Mt CO2-eq. 

Increase in credits 
: ~1,358 Mt CO2-
eq. 

+ 

++ 

++ 

++ 

2ndary 
resources  

Environment
al impacts: 
LCA credits 
from 
reuse/rem. 
and 
recycling261 

Environm
ental 

261 As a difference to the baseline scenario 

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Impacts 

Scenario  
Aluminium 1 

Scenario  
Aluminium 2 

Scenario  
Aluminium 3 

Scenario  
Aluminium 4 

Social  

Employment
262 

Increase in jobs in 
ATF (~12) 

Increase in jobs 
in ATF (~86) 

Increase in jobs 
in ATF (~582) 

+ 

++ 

++ 

Increase in jobs in 
ATF (~383) 

Increase in jobs in 
shredder facilities 
(~360) 

+++ 

Proportionali
ty  

All scenarios are considered proportional for achieving the objectives that the 
EU Treaties intends to implement 

Cost 
effectiveness  

Low costs but low 
benefits 

+ 

Similar 
effectiveness to 
scenario 1 in 
GWP and 
amount of 
recycled steel, 
while lower 
costs.  

However, the 
quality of 
recycled 
material is 
lower.  

++ 

High costs 
however at the 
same time very 
high revenue for 
the secondary 
wrought 
aluminium. 

Highest 
revenues for 
ATFs for sold 
recyclable 
material. 

Highest 
environmental 
credits due to 
recyclability of 
secondary 
wrought 
aluminium.  

+++ 

Very high costs in 
comparison to 
scenario Steel 2 
and 3. 

High 
environmental 
credits due to 
recyclability of 
secondary 
wrought 
aluminium.  

++ 

Coherence 

Coherence with 
waste legislation 
and the CEAP, 
promoting waste 
treatment of a 
higher hierarchy 
and circularity. 

Coherence with 
waste legislation 
and the CEAP, 
promoting waste 
treatment of a 
higher hierarchy 
and circularity. 

++ 

++ 

Coherence with 
waste legislation 
and the CEAP, 
promoting 
maximal 
recycling.  

Coherence with 
waste legislation 
and the CEAP, 
promoting 
maximal high-
quality recycling.  

++ 

+++ 

Notes: 

-/-: no impact 

Costs or burdens: between 1 and 3 minus signs (-; --; or ---), indicating low (1 minus sign) and high (3 minus signs) costs or 
burdens 

Benefits or savings: between 1 and 3 plus signs (+; ++; or +++), indicating low to high savings 

(): brackets around symbols if costs, benefits etc. are only potentials or are uncertain. If the costs, benefits etc. is rather uncertain, 
a broader range is indicated: e.g. ++ to +++ or – to + 

n.a.: not applicable 

262 Increase in comparison to baseline scenario. The calculations done based on dismantling time of engine/gearbox, so the 
values presented here in reality might be even higher while considering more parts/components for dismantling.  

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3.1.8  Analysis for glass  

3.1.8.1  Qualitative analysis for glass 

3.1.8.1.1  Qualitative analysis for glass 

Four measures were shortlisted for glass including the following measures: 

Title 

2.1.g) Establishment of mandatory recycled content targets for glass used in cars 
2.4.a) Align definition of ‘recycling’ with the WFD to prohibit the backfilling of glass 
2.4.b) Making it mandatory to remove glass windows before shredding to encourage their 
recycling 
2.4.c) Set a material-specific recycling target for glass 

Chapter 
2.1.5.1.8 
2.1.5.4.1 
2.1.5.4.2 

2.1.5.4.3 

Colour code: Red – discarded, Yellow – premature, Grey – supporting measure 

The feasibility of the proposed measures is assessed as follows:  

•  Measure 2.1.g: A recycled content target might affect the quality of recycling but would 
probably require more data to conclude on technical feasibility than is currently available. 
Current  data  suggests  that  technically  glass  from  vehicles  can  easily  be  recycled  into 
container  glass  or  insulation  materials  but  is  mainly  limited  due  to  a  lack  in  ELV  cullet 
supply (i.e., uncommon dismantling). Recycling back into vehicle applications (windows) 
may  be  technically  possible  and  is  mentioned  by  some  facilities  (see  data  on  Maltha 
Glasrecycling  under (ARN  2022a)),  however other sources  clarify  that  it is  not (widely) 
practiced. Given that only little glass is dismantled from ELV at present, it is however not 
surprising  that  there  is  little  data  as  to  such  recycling.  In  this  sense,  it  could  be  that  a 
target would not be difficult to fulfil if use of secondary materials sourced from vehicles is 
not required and would then not necessarily affect the waste management of vehicles. As 
for  the  opposite  case,  the  benefit  of  a  closed  loop  recycling  is  questionable.  Glass  for 
Europe (2022) explains in this respect that though closed-loop recycling from flat glass 
into  flat  glass  is  desirable,  it  is  most  difficult  to  attain  due  to  the  required  quality 
requirements  of  vehicle  glass.  They  furthermore  consider  that  this  measure  would  not 
support  effective  dismantling  and  sorting  of  automotive  glazing  but  only  exacerbate 
competition  between  glass  manufacturers  to  source  an  already  scarce  resource.  This 
measure  is  thus  discarded  at  this  stage  but  could  be  reconsidered  in  the  future  if  the 
implementation of other measures does not lead to a sufficient improvement in circularity. 
•  Measure  2.4.a:  Alignment  of  the  definition  of  recycling  with  the  WFD  will  exclude 
backfilling as a viable treatment for fulfilling the recycling target. As coherence with the 
WFD and with other waste legislation is understood to be of importance, this measure is 
assumed to be an essential supportive measure to be considered in all scenarios. 

•  Measure 2.4.b: For glass, the data (see section 2.1.2.5.4) suggests that dismantling and 
separate recycling could lead to a large benefit in terms of circularity, quality of recycled 
material and respective environmental impacts. This is particularly the case as at least at 
present, when glass is shredded, it is diverted to the mineral fraction that can be used as 
a  filling  material  (downcycling)  but  that  currently  does  not  allow  high  quality  recycling. 
Though  PST  could  develop  in  the  future  to  remedy  this  situation,  there  is  no  data  to 
suggest that such treatments exist or are in final development stages. Dismantling and 
separate recycling, however, are not considered to be economically viable, mainly due to 
the transport costs and are not commonly practiced. However, there are countries that 
remove  glass  (in  some,  it  is  required  by  law,  in  others,  supported  through  financial 
compensations, etc.) and thus it is assumed that such MS assume that the environmental 
benefits set off the economic costs and that the practice is not far from economic viability.  

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•  Measure 2.4.c: A recycling target is also an option to increase the high-quality recycling 
of  glass.  Its  advantage  is  that  it  leaves  more  flexibility  as  to  how  the  target  is  to  be 
achieved, but it would also require ensuring that certain recycling practices (use as filling 
materials) are not counted towards fulfilment of the target. The level of recycling could be 
associated  to  the  volume  of  the  glass  stream  expected  to  result  from  destructive 
dismantling of glass, seeing as shredding and PST currently do not deliver products that 
can be considered to reflect high quality recycling.  

3.1.8.1.2  Scenarios for quantitative analysis  

Between  2012-2013  a  few  studies  were  performed  for  Flanders  (OVAM  2022)  about 
technical,  economic  and  environmental  aspects  of  the  dismantling  and  recycling  of 
automotive glass (Intertek RDC & OVAM 2013?; VITO & OVAM 2013?; OVAM 2012?). These 
studies are the most comprehensive source on the waste management of vehicle glass at 
end-of-life, and as such comprise a source that has been taken into consideration for many 
of  the  assumptions  made  in  the  following  analysis.  More  recent  sources  usually  did  not 
include quantifiable data, though supporting for the most part aspects raised in the OVAM 
studies.  

3.1.8.1.2.1  Baseline 

Though  the  ELVD  specifies  that  glass  should  be  removed  under  Annex  I(4),  “Treatment 
operation[s] in order to promote recycling”, it does not specify whether this needs to be done 
prior  to  shredding  operations  or  not.  In  so  far  it  is  left  open  to  MS  how  to  deal  with  this 
requirement. According to OVAM (2012?), in 2012, selective glass removal was not widely 
applied  in  the  EU  27:  at  this  time,  glass  removal  took  place  in  six  member  states:  the 
Netherlands, Austria, Poland, Portugal and, to some extent, Spain and Sweden. In France 
and  Hungary,  the  legal  obligation  to  remove  glass  had  recently  been  approved  and 
implementation  was  expected  in  the  short  term.  In  two  out  of  six  countries  where  glass 
removal was said to already occur – the Netherlands and Poland – OVAM (2012?), explains 
that dismantlers receive an allowance for glass removal alone, or for the complete depollution 
process and dismantling of the ELV, which compensates for the costs of glass dismantling 
and logistics. Though a full survey of the practices of glass removal in the EU 27 was not 
performed in recent years, data on a few MS presented in section 2.1.2.5.4 suggests that at 
present  the  situation  is  similar,  with  glass  mainly  being  removed  when  reuse  is  targeted, 
resulting in the production of only small amounts of cullet and subsequently only little high 
quality recycling. On this basis, the consultants assume that under the baseline, glass shall 
continue  to  be  removed  in  a  few  Member  States,  but  post-shredder  technologies  shall  be 
widely applied, resulting in glass being diverted to the mineral fraction and sent to use as a 
filling material, which is considered as downcycling.  

3.1.8.1.2.2  Scenario Glass 1: alignment of ‘recycling’ definition with WFD  

Under this scenario, it is assumed that the use of post-shredder mineral fractions containing 
glass for backfilling operations will no longer count as a recycling operation, effective by 2025. 
Subsequently, it is assumed that countries that have accounted such operations as recycling 
until  now,  will  either  use  mineral  post-shredder  fractions  as  a  construction  filling  material 
(majority)  or  start  dismantling  and  recycling  glass  (minority)  from  2025  and  on  to  enable 
compliance with the current RRR targets. 

3.1.8.1.2.3  Scenario Glass 2: mandatory removal of glass and separate recycling 

Under this scenario it shall become mandatory to remove window glass from vehicles and 
send  it  separately  from  other  waste  to  recycling  facilities.  For  this  purpose,  destructive 

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removal (the window is broken with various tools and the pieces are collected and sent to 
separate recycling) is assumed to comply with the requirement, meaning that around 30% of 
the glass is lost in the process263. Stakeholders (e.g., FEAD (2022) but also 6 stakeholders 
who  responded  to  interactive  questions  at  the  workshop)  have  confirmed  that  destructive 
removal techniques retrieve around 80 % of the glass in an ELV at the time it is treated at the 
ATF.  Together  with  other  losses,  it  is  assumed  that  70 %  of  the  glass  in  vehicles  can  be 
removed  from  ELVs  and  recycled  at  high  quality.  To  ensure  that  a  minimum  amount  is 
removed and sent to recycling, the measure could include a requirement that at least 20 kg 
is to be removed per vehicle (average value) and transferred to a recycler as glass cullet to 
comply  with  the  provision.  A  minimum  amount  of  glass  is  suggested  to  facilitate  a 
straightforward reporting that is not overly burdensome in terms of administrative costs. The 
reference to cullet is made to ensure that the output of ATFs is the secondary material sought 
by glass manufacturers to reduce their dependability on primary material, and subsequently 
the footprint of manufacturing new glass.  

3.1.8.1.2.4  Scenario Glass 3: alignment of ‘recycling’ definition with WFD + material specific recycling target for 

glass 

Under this scenario, a recycling target would be specified in the future legislation of ELVs, 
requiring  a  minimum  share  of  glass  in  vehicles  to  be  recycled  at  high  quality,  i.e.,  without 
downcycling. In the case of glass, high quality is interpreted to mean that the cullet can be 
used for production of container glass, insulation materials, flat glass and other equivalent 
uses in terms of quality. Vehicle glass use in windows would also be considered a high-quality 
use, as the glass is retained in the material cycle and can be recycled again, contributing to 
circularity. However, the feasibility is not clear from available data. Based on Intertek RDC & 
OVAM (2013), it is assumed that at present, an average of 20.8 kg could be recovered per 
vehicle, amounting to around 70% recycling that could be achieved. 60% and 80% recycling 
will also be looked at quantitatively. This measure leaves open whether the glass is removed 
and treated separately or recovered from the shredder through application of PST. Available 
data  suggests  that  current  PST  technologies  would  not  result  in  a  glass  fraction  that  is  of 
sufficient quality264, however, such technologies could still be developed and applied in the 
future if minimum quality requirements are to be achieved. Monitoring and enforcement would 
require ATFs to provide evidence of the number of vehicles treated and the amount of glass 
dismantled  from  all  vehicles  and  sent  to  recyclers.  Shredders  and  PST  operators  would 
probably also be required to report on vehicle inputs and recycled material outputs (glass sent 
to  recyclers  and  glass  containing  mineral  fractions  that  can  be  used  in  construction  or  in 

263 According to Intertek RDC & OVAM (2013?), aside from the glass that is lost in the logistics of transporting a car to an ATF 
and also to depollution and dismantling processing at the ATFs premises, when glass is dismantled “destructively”, a 
container or tray will be used to collect glass that is broken out of the vehicle window frames. Glass that lands outside the 
container or tray, will be swept from the floor of the dismantling space, however as it usually contains dust and other 
impurities, it will not be collected with the glass sent to recycling to avoid contamination. The study estimates that 20.8 kg is 
recovered per ELV when destructive dismantling is applied. Assuming an average weight of 30 kg of glass per vehicle means 
that this reflects around 70% of the glass in a vehicle. 

264 Intertek RDC & OVAM (2013?) explain that automotive glass separated after shredding and PST is not accepted (in 2012) 
by the glass recyclers. This is due to it still containing many impurities (plastics, metals, stones), as it is a mix of glass of 
different sources (i.e., heterogenous – sourced form ELVs but also from e.g., washing machines, car lamps) and as it is 
provided in very small pieces (< 8 mm) which with the current technologies applied hinders the separation at the glass 
recycling plant into glass of different types (composition). The mineral fraction containing automotive glass is either recycled 
as building material (Examples: road basement and landfill covering), to replace other mineral materials (sand, rocks…) if the 
quality is sufficient, or is landfilled. 

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backfilling operations (limited amounts may be “recovered”)). Finally, recyclers will also need 
to report as to their vehicle inputs and about the amount recycled at high quality.  

3.1.8.1.3  Results of qualitative analysis  

Though  scenario  Glass  1  shall  prohibit  the  use  of  post  shredder  mineral  fraction  for 
backfilling, it will still allow its use for construction purposes. Compared to the baseline, though 
some MS may shift to glass dismantling and separate recycling, this scenario is not expected 
to increase the level of high-quality recycling substantially. In contrast, both in scenario Glass 
2 and Glass 3, the level of dismantling is expected to increase.  

Scenario Glass 2 requires ATFs to show that at least 20 kg of dismantled glass cullet is sent 
to (and accepted by) glass recyclers. This level is based on the average amounts of glass 
reported  by  Intertek  RDC  &  OVAM  (2013?)  as  feasible  by  application  of  destructive 
dismantling and thus also considered to require an acceptable increase in dismantling time 
and costs. 

In Scenario Glass 3, the achieved level depends on the target to be set. A target of 70% of 
the  glass  in  a  vehicle  is  also  based  on  the  application  of  destructive  dismantling  and  an 
average use of 30 kg of glass per vehicle and thus assumed to achieve a similar level of glass 
recycling.  A  lower  target,  e.g.,  60%  would  not  apply  the  full  potential  of  destructive 
dismantling: The data on dismantling methods presented by Intertek RDC & OVAM (2013?) 
shows  that  there  are multiple  methods  achieving  a  removal  rate  of  85% and  above  of the 
glass in the vehicle at the time of dismantling (glass losses occur also prior to dismantling). It 
is  thus  assumed  that  60%  would  not  be  ambitious  in  relation  to  what  is  possible  through 
technologies already available a decade ago. Similarly, based on the Intertek RDC & OVAM 
(2013?)  data,  a  higher  target,  e.g.,  80%  would  be  over  reaching  in  relation  to  destructive 
dismantling. This would result in ATFs needing to apply techniques that are more intensive in 
labour and/or more costly in terms of equipment, affecting the costs of the process for ATFs. 
As removal is currently not practiced due to a low economic feasibility, it is assumed that is 
assumed that the costs in this case would not be proportional to benefits should such a target 
be applied at present. In parallel, a higher target could be considered for the future with the 
understanding that it could lead to better design of vehicle windows for removal. As the vehicle 
lifetime is relatively long, it would take time until such changes facilitate higher removal levels 
and would thus only be expected to allow compliance in the long-term, if at all.  

From an environmental perspective, in both Scenario Glass 2 and 3, the level of high-quality 
recycling  is  expected  to  increase  significantly  and  to  be  similar.  High  quality  recycling  is 
expected to have environmental benefits as opposed to downcycling (to be analysed in the 
next  section).  However,  these  scenarios  are  expected  to  differ  in  terms  of  administrative 
burden, as monitoring would be more complicated in a case where it is left open for operators 
to decide how to achieve the target. 

3.1.8.1.4  Results of quantitative analysis  

From the available data it can be understood that various shares of glass are not directed to 
recycling  due  to  breakage  at  various  process  stages,  being  sent  to  reuse  or  losses  and 
process inefficiencies. Thus, to specify the amounts of glass going into each fraction, it is first 
necessary to make some assumptions as to the volume of breakage, reuse and inefficiencies.  

Intertek RDC & OVAM (2013?) estimates that that 5-10 % of glass does not reach ATFs due 
to  breakage  in  accidents  or  during  transport  to  ATFs  and  that  another  5-10 %  of  glass 
windows are dismantled (usually with doors) and reused.  

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Thus, under all scenarios, it is assumed that 10 % of vehicle window glass from vehicles that 
arrive at an ATF is missing due to accidents or breakage during the transport to the operator. 
This 10% is part of the total losses considered. Furthermore, a different share is assumed to 
be dismantled in each scenario. In all cases, this dismantled share is assumed to include:  

•  5 % of glass that is removed for reuse (usually with the door), 
•  The European average of glass sent to separate recycling (in the baseline, 5% represents 
the MS that already require removal of glass or provide compensations that facilitate the 
practice),  

•  A further 5 % “breakage” is collected at the ATF premises and sent to the shredder. This 
is  either  glass  broken  during  transport  processes  or  during  dismantling  when  glass  is 
shattered but does not land in trays or curtains used to collect it for separate recycling.  

•  Losses of 3% for process inefficiencies. 

As for glass that is not recycled at high quality, it is either recycled after shredder operations 
(mineral  fraction  used  for  construction)  or  considered  to  be  recovered  through  backfilling. 
Though in the baseline, backfilling also counts towards recycling, this is not allowed in other 
scenarios and thus assumed to decrease to zero. 

Both in scenario glass 2 and 3 a high level of glass that is dismantled and then sent to a 
recycler (without shredding) is assumed. This is based on the available data for efficiencies 
of destructive dismantling and on the amount of glass that can be recovered per vehicle.  

• 

Intertek RDC & OVAM (2013?) detail various dismantling techniques, most of which allow 
the removal of 75-95265% of the glass. The rest is explained to remain in part in the vehicle 
and to be sent to shredder or is collected from the facility premises and sent to shredder 
due to contamination with dust etc.  

•  The Intertek RDC & OVAM study estimates that 20.8 kg per vehicle can be recovered 
through destructive dismantling and separate recycling. The shares specified here thus 
assume that around 70 % can be recovered as a secondary material when dismantled 
and sent to pre-shredder recycling.  

As for consideration of changes in the use of glass in the future, according to stakeholders 
(Intertek RDC & OVAM 2013), the function of glass windows (particularly of the wind-screen) 
has evolved over the last two decades and is expected to evolve further. Glass windows may 
be  designed  to  accommodate  additional  functions  e.g.,  sun-protection,  antenna,  head-up 
display, solar-cell, heating and sensor. Such components are similar in terms of composition 
to those already applied in the windscreen and the rear window and said not to hinder the 
recycling of glass and it is anticipated that this will not change. Intertek RDC & OVAM (2013?) 
further  expect  an  increase  in  the  use  of  sun-roofs  in  vehicles,  which  are  mainly  made  of 
laminated glass. However here to, it is not expected that this shall affect recyclability. In any 
case Intertek RDC & OVAM (2013?) expect sunroofs to be present in ELV only in (very) small 
amounts  in  the  coming  decade(s)  as  they  have  a  relatively  low  market  share  (mainly  the 
luxurious  cars).  In  conclusion,  neither  of  these  evolutions  are  reflected  in  the  following 
analysis, however they would also not be expected to change the nature of results. 

The  following  table  specifies  the  rates  that  have  been  assumed  for  each  scenario  as 
dismantled,  reused,  recycled  pre-  or  post-shredder,  recovered,  or  lost;  and  with  which 
quantitative  impacts  have  been  calculated.  This  is  followed  by  a  description  of  expected 

265 This is generally based on the data on the share of glass sent to recyclers specified under Table 2(Summary dismantling 
technique) of the report but also on data for some methods where RDC performed field observations as to the amounts 
removed and sent for recycling, This number only reflects the share of glass removed form the vehicle in the dismantling 
stage. Some losses may occur prior to this stage, i.e., it is not to be concluded that 0.75-95% recycling is viable through 
destructive dismantling. 

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impacts  in  each  scenario  after  which  impacts  are  presented  for  the  impact  categories 
environmental, economic, and social. 

Table 3-37   Routes of treatment for glass from ELVs in 2035 under the various 
scenarios in shares (%) of total material stream  

Vehicle glass 
In components for 
reuse/remanufacturing 
Recycled material of 
potentially higher quality 
(directly recycled, no 
shredding) 
Dismantled --> shredded --> 
recycled 
Shredded --> recycled (no 
dismantling) 
Recovery: backfilling 

Losses 

Baseline 

Scenario 1  Scenario 2  Scenario 3 

5%* 

5% 

5% 

5% 

10% 

12% 

70%** 

70%** 

5% 

50% 

17% 

13%* 

5% 

65% 

0% 

13%* 

12% 

0% 

0% 

13%* 

12% 

0% 

0% 

13%* 

Source: Oeko-Institut: own assumptions based on available data. 

*Based on *Intertek RDC & OVAM (2013?) estimates 5-10 % of glass windows are dismantled (usually with doors) and reused 
and that 5-10 % of glass does not reach ATFs due to breakage in accidents or during transport to ATFs. For reuse of glass, 
5 % has been assumed and for losses prior to ATFs 10 % has been assumed – both reflecting a conservative assumption. 

**Based on Intertek RDC & OVAM (2013?) See explanations above.  

Under  scenario  Glass  1,  post-shredder  mineral  fractions  containing  glass  for  backfilling 
operations  will  no  longer  count  as  a  recycling  operation.  In  some  countries  where  such 
treatment is counted towards reaching the reuse and recycling target, this would make it more 
difficult to achieve the target, as glass constitutes around 3 % of the vehicle weight. However, 
the prohibition of accounting backfilling as recycling would still allow counting post-shredder 
mineral fractions used for construction purposes as recycled. Based on OVAM (2012?), in 
the past, at least 6 MS removed glass although this was not a requirement. For the remaining 
21 MS, it can be assumed that all of them shred glass with the vehicle in most cases, reporting 
it as recycled. Under this scenario, those that applied the backfilling route could either require 
removal of glass prior to shredding or send post-shredder mineral fraction for use as filling 
material in construction works. It is assumed that most of the 21 MS would choose the latter 
route, as glass removal would increase the costs of ELV waste management. Intertek RDC 
& OVAM (2013?) explains that automotive glass separated after shredding and PST is not 
accepted  (in  2012)  by  glass  recyclers.  This  is  due  to  the  fact  that  it  still  contains  many 
impurities  (plastics,  metals,  stones),  as  it  is  a  mix  of  glass  of  different  sources  (i.e., 
heterogenous – sourced from ELVs but also from other waste e.g., washing machines, car 
lamps),  and  that  it  is  generated  in  very  small  pieces  (< 8 mm)  which,  with  the  current 
technologies applied, hinders the separation at the glass recycling plant into glass of different 
types (composition). FERVER and Denuo (2022) also refer to the impurities after shredder 
as  an  obstacle  for  recycling.  The  mineral  fraction  containing  automotive  glass  is  either 
recycled  as  building  material  (examples:  road  basement  and  landfill  covering),  to  replace 
other  mineral  materials  (e.g.,  sand,  rocks)  if  the  quality  is  sufficient,  or  is  landfilled.  It  is 
assumed that both in the baseline scenario and in scenario Glass 1 most MS will continue 
to  treat  glass  in  the  shredder,  resulting  in  its  application  as  a  construction  filling  material 
(baseline and scenario Glass 1) or backfilling (baseline only) material. Only a small share of 
MS will continue (baseline) or shift (scenario Glass 1) to glass removal and recycling.  

Under  scenario  Glass  2,  all  glass  will  need  to  be  removed  prior  to  shredding.  In  a  study 
prepared by Intertek RDC & OVAM (2013?), various dismantling methods were presented, 
looking  at  their  different  characteristics.  Multiple  methods  were  presented  that  require  an 

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average of 6-10 minutes for removal of all glass windows (windscreen, side windows and rear 
window).  Depending  on  the  type  of  window  removed,  the  various  methods  achieved  a 
removal  rate  between  75-95 %  of  the  glass  applied  in  windows.  It  is,  however,  noted  that 
some of the glass may be missing by the time the ELVs arrives at the dismantling station. 
Considering all losses, the study assumed that the removal of glass would result in a recovery 
of 20.8 kg of glass on average from each vehicle, corresponding to almost 70 % of the glass 
used in vehicles266. The study confirms that such glass will be collected separately and then 
shipped  to  a  recycler.  Concerns  were  raised that  the  use  of  foils  and  electric  components 
(e.g.  heating  elements)  in  some  windows  can  hinder  the  recycling  quality  of  the  glass 
(FERVER and Denuo 2022). However, Intertek RDC & OVAM (2013?) confirmed with various 
operators and recyclers that separated glass is crushed and sorted to remove metal, foil and 
other materials upon arrival. The non-glass components of automotive glass (PVB, heating 
wires) do not hinder glass recycling, and glass from all types of windows (windscreen, side, 
rear)  is  accepted  even when  mixed.  Recycling of  cullet  sourced from  vehicles  has  a  good 
market in the production of container glass and insulation material production (flat glass is a 
potential market but technically more complicated). This view is also supported by FERVER 
and  Denuo  (2022),  who  explain  that  the  global  demand  of  the  glass  industry  for  used/ 
recyclable automotive glass is rather high since it is a rather pure waste stream (assuming 
the glass is separated pre-shredder). 

Under scenario Glass 3, it is up to operators how to achieve the target, however, as currently 
only destructive dismantling of glass would cater for the quality of recycling addressed by the 
target, it is assumed that at least in the short term, the level of dismantling would be similar 
to that applied in scenario Glass 2. This could change in the future, should PST technologies 
be developed to achieve higher quality separation of glass from shredder fractions. But as 
there is currently no data that supports such developments, they are assumed not to develop 
in the short term. 

3.1.8.1.4.1  Environmental impacts 

For the analysis at hand, the model developed for this study specifies that the around 220 
thousand tonnes of glass will be contained in ELVs to be collected in 2035, when all measures 
could be expected to be fully implemented. This assumes a weight of vehicle glass of between 
21 and 26 kg per vehicle depending on the vehicle type  267. Based on above assumptions 
and the shares specified in Table 3-37, the tonnage of vehicle glass treated in different routes 
was calculated and is presented in Figure 3-11 below. 

266 Intertek RDC & OVAM (2013?) refers to individual weights in a range of 10-20 kg for windscreens, 2-5 kg for each side 
window and 3-10 kg for rear windows, globally 20-40 kg altogether. 30 kg glass per vehicle has been assumed for 
convenience. 

267 Weights used in the model depend on vehicle type and were 24 kg for ICE, 21 kg for HEV, 22 kg for PHEV and 26 kg for 
BEV. Data suggest that vehicle glass will averagely weigh 30 kg per vehicle. 

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Figure 3-11  Tonnage of glass treated in the different routes under each scenario, in 
kg  

Source: Own illustration  

The higher rates of dismantling of vehicle glass that can be recycled at high quality in Scenario 
Glass 2 and 3 result in around 131 thousand tonnes of vehicle glass being recycled in 2035, 
which is 6 times higher than the baseline and almost 5 times higher than Scenario Glass 1 in 
that year. 

Based on the above tonnage calculated for the baseline and for each scenario, the respective 
environmental impacts in terms of global warming potential were quantified for each scenario. 
This is shown below for all vehicles to be collected as ELVs in the year 2035 (Figure 3-12). 
Specific data can also be seen in annex 6.4.2.1, representing impacts based on the functional 
unit (all window glass of a typical vehicle) to show impacts in terms of global warming potential 
when the glass is directed to different treatment routes. 

Figure 3-12  Credits for Global warming potential (GWP) of the treatment options for 
all vehicle glass compared to primary production, calculated for all vehicles collected 
as ELVs in 2035 (kgCO2eq) 

Though Figure 3-12 refers to additional routes besides reuse and pre-shredder recycling, the 
figure specifies these as zero. Though glass sent to the shredder and then backfilled (or used 
for filling in construction) will have a certain environmental benefit (e.g., GWP credits) over 

Source: Own illustration  

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glass  losses,  the  value  of  these  is  negligible  in  comparison  to  the  credits  achieved  from 
recycling at high quality. For simplicity it is shown as zero here. 

Based  on  this  analysis,  though  the  credits  for  reuse  are  the  same  in  all  scenarios  (not 
expected to be affected by the measures under consideration), credits for dismantling and 
then recycling increase the total credits of Scenario Glass 2 and 3 significantly to around 139 
thousand tonnes of CO2 equivalents, as compared to the more modest credits in the baseline 
and  Scenario  Glass  1  that  amount  to  around  12.8  and  16.8  thousand  tonnes  CO2eq 
respectively.  As  explained,  the  contribution  of  vehicle  glass  sent  to  shredding  and  thus 
considered downcycled is negligible, reflecting the fact that this material leaves the material 
cycle.  

This is further supported by an LCA comparison of the dismantling and recycling route with 
the  shredder  route  (use  of  mineral  fraction  for  construction)  performed  by  VITO  &  OVAM 
(2013?)  that  concluded  that  the  shredding  route  has  minor  environmental  impacts  and 
benefits depending on the impact category, while dismantling in all categories has a much 
larger environmental benefit. The differences estimated in this comparison refer to additional 
impact categories as can be seen in the figure below. Whereas 100% represents the impact 
under each category for dismantling, the related impact for the shredder route (referred to as 
shredding and PST) is shown in comparison to this level. In this respect, a negative value is 
understood to mean that there is a contribution to reducing impacts, whereas a positive value 
reflects a negative impact related to the indicator in question. 

Figure 3-13  Comparison of the environmental impacts of dismantling (and 
recycling) versus post shredder recycling (backfilling or construction uses) in % 

Source: VITO & OVAM (2013?) 

VITO & OVAM (2013?) explains that by using cullet in glass production, primary materials 
(silica  sand,  soda,  limestone,  dolomite)  and  energy  are  saved,  which  yields  higher 
environmental benefits than avoiding the use of building sand by replacement with the post-
shredder mineral fraction. The study also explains that, despite the fact that dismantling of 

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glass  generates  a  net  environmental  benefit,  even  in  the  best-case  scenario,  the 
environmental  benefits  that  can  be  expected  from  glass  dismantling  and  recycling  are 
relatively small. This treatment of automotive glass yields the same average CO2 reduction 
per  ELV  (6.4 kg)  as  a  reduction  in  personal  car  use  of  27 km.  For  comparison  in  the 
estimations  made  with  the  environmental  impacts  model  of  this  study,  the  average  CO2 
reduction per ELV was calculated to be slightly higher (around 11 kg per ELV), which has a 
similar order of magnitude. 

Furthermore, according to VITO & OVAM (2013?), the total glass flow generated annually by 
ELVs  is  estimated  to  be  about  5,000 tonnes  (in  Belgium),  which  is  also  a  limited  quantity. 
Assuming, an average car drives about 15,600 km per year, the CO2 reduction potential of 
dismantling and recycling glass from 170,000 ELVs annually (in Belgium) equals the yearly 
CO2 emissions of roughly 300 average personal cars (1100 tonnes CO2). 

Although it may sound as if the benefit from glass removal is small when looking at the vehicle 
level, it needs to be kept in mind that currently the use phase of a vehicle is assumed to have 
the largest contribution to its total global warming potential. In other words, it is not a surprise 
that contributions related to a specific material are more modest.  

To  give  additional  context  to  the  impact  of  generating  more  glass  cullet  for  recycling,  it  is 
worth  considering  the  CO2  savings  that  this  generates  for  glass  recyclers.  In  this  respect, 
Glass for Europe (2022) estimated that replacing 1.2 t of raw materials by 1 t cullet saves 310 
kg CO2 at the manufacturing site (process emissions) and 315 kg CO2 related to the non-
production of primary raw materials. Thus assuming 625 kg CO2 savings for each tonne of 
cullet that can be generated in Scenario Glass 2 and 3, would mean that in total 95 thousand 
tonnes of CO2 savings would be generated form the increase in available cullet, in comparison 
to only 13.7 thousand tonnes of CO2 savings in the baseline and 16.4 thousand tonnes of 
CO2 savings in Scenario Glass 1. These impacts are already reflected in the calculated impact 
presented in Figure 3-12 and are only mentioned to clarify that the range of impact may differ 
but remains in the same order of magnitude.  

3.1.8.1.4.2  Economic impacts 

From an economic perspective, glass dismantled and recycled separately results in higher 
costs for operators than when it is left in the vehicle and sent to shredding. Intertek RDC & 
OVAM (2013) estimated the total costs when glass is shredded and used for backfilling or 
construction  at  49 €  per  tonne  of  glass  as  compared  to  213 €  per  tonne  when  glass  is 
dismantled and recycled separately. Costs differ depending on the size of the facility (in terms 
of  ELVs  treated)  and  economies  of  scale  which  affect  both  the  cost  of  dismantling  and  of 
transport and logistics of separated glass.  

Looking  at  the  differences  in  costs  of  the  various  scenarios  to  the  baseline  based  on  the 
Intertek RDC & OVAM (2013?) data, scenario Glass 1 (prohibition of backfilling) would result 
in an increase in costs of around 0.75 million €. An increase in costs of around 22.8 million € 
is estimated for both scenario Glass 2 and 3, which result in the same amounts of glass being 
recycled pre-shredder as well as post-shredder. This calculation is understood to take into 
consideration the additional costs of equipment needed for glass dismantling (investments 
and maintenance) as well as any revenues related to the sales of recycled glass or mineral 
fraction (benefits). 

It  is  noted  that  the Intertek  RDC  & OVAM  (2013?)  quantification  is  based  on  a calculation 
representative for an average facility in Belgium. Costs can vary depending on the size of the 
ATF. Larger ATFs may be expected to have higher costs for logistics (storage of glass), but 
probably also lower costs for dismantling and transport in light of economies of scale.  

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A further study (ADEME, France 2015) that looked at the costs for recycling vehicle glass in 
France  states  that  the  total  costs  associated  with  glass  dismantling  (sometimes  including 
revenues from the sale of glass to recyclers) specified in various sources, ranges from € 3 to 
€ 15/ELV,  with  the  majority  of  estimates  from  various  sources  ranging  between  € 4  and 
€ 8/ELV. As part of the study, an ATF survey was performed, where ELV centres surveyed 
reported average dismantling times of 30 minutes (10 minutes on average for the windscreen, 
9.5 minutes for the side windows, 12 minutes for the rear window). Assuming a labour cost 
of 40 €/hour, a total labour cost of 21 €/ELV was estimated. The ELV centres also reported 
collection  and  processing  costs  of  64 €/t  on  average,  which  corresponds  to  1.4 €/ELV 
considering  22 kg  of  dismantlable  glass.  The  study  refers  to  the  Netherlands,  where  ARN 
financed the dismantling of glass by ELV centres until 2011 at a cost of 19 €/ELV, based on 
a  dismantling  time  of  18  minutes  -  these  estimates  are  said  to  be  particularly  high.  The 
estimated cost of dismantling from the ADEME survey questionnaires is therefore 22.4 €/ELV, 
which  is  assumed  to  be  relatively  high  compared  to  other  available  data.  Post  shredder 
treatment costs for glass are also mentioned, however, explaining that much less information 
is available. The OVAM studies are referred (treatment costs of 1.02 €/ELV as well as a much 
higher value estimated in Germany to be between 2.80 € and 4.20 €/ELV. The ADEME costs 
are compiled in the table below. 

Table 3-38 Cost differences between glass processing by dismantling and post-
shredding sorting identified in the studies 

Source 

Cost of dismantling 

Cost 
shredder treatment 

of 

post 

Differences 

Estimations OVAM 

Between 4.3 and 5 €/ELV 
(4.4 €/ELV on average) 

1.02 €/ELV 

3.4 €/ELV 

German estimations 

Between 4.6 and 8 €/ELV 

Between 
4.20 €/ELV 

2.80 

and 

Between 
3.8 €/ELV 

1.8 

and 

Other 
interviews 

studies 

and 

Between 3 and 15 €/ELV 
(mostly  between  4  and 
8 €/ELV) 

Source: translated and reproduced from table 3 in ADEME, France (2015) 

In some countries, the distance between an ATF and a glass recycler may also affect the cost 
of transport and result in a further increase (or decrease) of costs. For PST the Intertek RDC 
& OVAM (2013?) study assumed that 56 % of shredders have PST operations at the same 
site and would have no additional transport costs. 44 % of shredders would need to transport 
the heavy fraction to a PST with costs varying “between 3 and 10 €/tonne, as it is a transport 
of  a  heavy  fraction  (high  density)  and  as  the  distances  are  relatively  short  (maximum 
150 km)”.  

For the transport of glass from a dismantler to a recycler, 45 €/tonne were assumed for both 
storage  and  transport.  The  transport  cost  alone  was  estimated  to  range  between  10  and 
30 €/tonne, as low volume facilities will transport a smaller container than large volume ones, 
resulting in a higher costs per tonne. Additionally, the difference is also related to the lower 
density of broken glass that results in larger volumes for transport. Detail was not given as to 
the distance between ATFs and recyclers, but this is assumed to be similar to the average 
distance of shredders to PST facilities, i.e., relatively low distances.  

What  is  not  accounted  for  in  the  costs  of  glass  dismantling  and  glass  shredding  +  PST 
presented  above  are  possible  benefits  for  shredders.  Glass  entering  the  shredders  is 

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understood  to  cause  abrasion  of  the  shredder  surfaces  and  to  increase  the  frequency  of 
maintenance works and related costs. In that sense, though Scenario Glass 1 is very close 
to the baseline in this respect, under Scenarios 2 and 3 a decrease in such costs is expected 
that  would  be  beneficial.  Though  this  benefit  cannot  be  estimated,  shredder  statements 
support this notion in terms of having a preference to accept vehicle hulks after the removal 
of glass (ARN 2022b).  

ARN were contacted and asked about a pilot (the glass indicator) they had run to support that 
ATFs removing glass prior to shredding are compensated. In a personal communication, ARN 
stated that “4 car dismantling companies (ATF’s) joined the glass indicator pilot project (from 
the  213  affiliated  car  dismantling  companies).  The  pilot  has  been  run  with  one  shredder 
location”.  In  2021  the  pilot  resulted  in  117  tons  of  dismantled  glass  being  transported  to 
recyclers, on average 16-17 kg dismantled glass per ELV (of on average it was said that an 
ELV contained >25 kg of glass). Data on the benefits for shredders was not made available 
and it was explained that the pilot was stopped for various reasons. It was also said that the 
“past  has  shown  that  payment  for  manual  glass  dismantling  has  led  to  substantial  fraud“. 
Asked to explain this, ARN stated that ”If ATFs get paid for taking out and handing in glass, 
an  intensive  monitoring  system  should  be  set  up.  It  turned  out  to  be  very  simple  and 
commercially interesting to put other glass in a container (such as glass from car glass repair 
and replacement shops) and in the meanwhile not dismantle the glass from EOL vehicles. 
Glass from still driving vehicles is difficult to distinguish from glass coming from EOL vehicles. 
From a mass balance perspective, it can reflect a perfect situation, but in reality, an incentive 
is given to 1. Not do the work and 2. Create a paid gateway for waste streams form other 
market players. (This is not a hypothetical situation but was the case with a number of ATFs 
when ARN still reimbursed ATFs for glass dismantling.)268 

As for the cost to recycle the PST fraction, Intertek RDC & OVAM refer to between 0-3 €/tonne 
and  to  between  0-20  €/tonne  for  the  cost  to  recycle  the  dismantled  fraction.  The  cost  is 
understood to reflect the quality of the glass delivered to a recycler. In particular, the lower 
part  of  the  range  given  for  dismantled  glass  is  assumed  to  reflect  cases  where  despite 
dismantling the glass is highly contaminated. In this sense, in terms of economic benefits, the 
consultants  assume  around  1.5  €  revenue  per  tonne  when  shredded  glass  is  sent  to 
backfilling (only relevant in the baseline), 10 € per tonne when shredded and used as a filling 
material  and  18  €/tonne  when  dismantled  and  sent  as  cullet  for  recycling.  Looking  at  the 
differences in the tonnes recycled pre-shredder and post shredder under each scenario, an 
additional  benefit  of  0.36  million  €  is  generated  from  sales  of  fractions  to  recyclers  under 
scenario Glass 1 as compared to the baseline. For Scenario Glass 2 and 3 the difference 
amounts to 1.37 million €. In all scenarios the difference in range depends on the quality of 
the glass delivered. 

Though glass recycling is relevant from a circularity perspective and considered critical by 
FERVER and Denuo (2022) to improve the recycling of this fraction, they also mention that 
the resulting reduction  in  the  amounts  of  materials  that  could  be  used  for  backfilling  could 
have  economic  implications:  “Glass  in  landfill  material  is  frequently  used  to  ensure  landfill 
stability  and  is  therefore  a  useful  material  in  the  landfill  mixture;  glass  in  landfill  is  not  a 
problem, but its absence could be. Consequently, the glass fraction in landfill is sometimes 
exempt  from  landfill  taxes.  It  must  therefore  be  considered  how  landfill  costs  would  be 
impacted  if  a  larger  proportion  of  glass  were  removed  from  the  landfill  material.  But  the 
general trend is to reduce the landfilling of waste, especially with high organic contents as it 
is  the  case  for  post-shredder  waste,  promoting  recycling,  material  recovery  and  waste-to 
energy recovery”. Data is not available to allow quantification. 

268 Personal communication per emails between Janet Kes and Yifaat Baron on 27.9.2022 and 29.9.2022. 

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Administrative costs 

Aside from the difference in costs of glass processing from ELVs, a further economic aspect 
is related to the expected administrative cost of reporting. Under the baseline, Commission 
Decision  2005/293/EC,  which  specifies  the  current  reporting  rules,  already  requires  MS  to 
report on the total weight of dismantled glass reused (A1) and recycled (B1) in their country, 
however this reporting is on a voluntary basis. Glass recycled from the post-shredder heavy 
fraction as mineral fraction can be reported under “other” as recycled fraction (B2), currently 
covering  the  use  of  this  fraction  for  both  backfilling  and  construction.  These  rules  could 
partially  be  applied  under  Scenario  Glass  1,  however,  any  backfilled  fractions  could  no 
longer be reported as recycled (B2) and would probably require the rules to be adjusted so 
that  they  could  be  reported  under  recovery  (C2  currently  refers  only  to  energy  recovery). 
When landfilled in both cases, the heavy fraction or any materials recovered from it (mineral 
fraction) are to be reported as disposal (E2). Though this would require a small revision of the 
rules, it would seem that for MS that use the post-shredder mineral fraction for construction 
(at present or in the future for scenario Glass 1) nothing would change. For those reporting 
on backfilling as recycling, if the use changes to construction, the effort of reporting would 
also  remain  unchanged.  Increases  in  dismantled  and  recycled  glass  would  need  to  be 
reported in differently from today, also requiring the MS to collect documentation from waste 
operators:  “declarations  from  the  receiving  recycling/recovery  or  collection  company, 
weighing  notes,  other  forms  of  bookkeeping  or  disposal  notes”.  Any  mineral  fraction  still 
backfilled would require a change in the mode of reporting (recovery or backfilled instead of 
recycling), but not in the documentation to be provided by waste facilities. Though this is a 
higher effort as compared to the baseline, it is assumed to result in a negligible increase in 
comparison with the other scenarios. See quantification in vehicle level analysis (excluded 
here to avoid double counting). 

Under Scenario Glass 2, the existing rules could also be applied if MS are obliged to report 
on the weight of dismantled recycled glass separately, as they are also required to report on 
the  number  and  weight  of  ELVs  treated  in  their  country.  This  provision  of  data  enables  a 
relatively  simple  check  of  compliance.  However,  it  is  expected  that  more  documentation 
would need to be collected and checked for the increased amount of dismantled and recycled 
glass, increasing the effort somewhat for regulators and operators in countries that currently 
do  not  remove  and  recycle  glass  separately.  In  this  sense,  the  administrative  burden  is 
expected to  be  somewhat  higher  under  this scenario  –  i.e.,  a  low to moderate  increase  in 
administrative burden, due to the fact that currently, reporting on glass is voluntary, so the 
reporting scheme on this material in some MS might not be developed yet. See quantification 
in vehicle level analysis (excluded here to avoid double counting). 

In contrast, under Scenario Glass 3, the reporting will become more complex. Though the 
aspects reported on for Scenario Glass 2 would still be relevant, under Scenario Glass 3 it 
will also be necessary to report data by the recyclers, optimally obtained at the calculation 
point  or  alternatively  measurement  point,  to  ensure  that  the  total  amount  received  and 
processed complies with the target of 70 % recycled glass. For most recyclers, this could be 
more than a standard reporting of inputs and outputs, as in the recycling process, glass will 
be mixed with other fraction, requiring an effort in allocation. Though the exact effort cannot 
be quantified, it is assumed that the reporting under this scenario would require a larger effort 
both  in  the  development  of  the  future  reporting  rules  and  in  their  implementation  by  both 
regulators and waste facilities. The administrative burden is expected to the highest under 
this scenario – i.e., a moderate – high increase in administrative burden. See quantification 
in vehicle level analysis (excluded here to avoid double counting). 

Under both Scenarios Glass 2 and 3, any mineral fraction used for construction or backfilled 
could  be  reported  as  described  under  Scenario  1,  but  only  small  amounts  would  still  be 

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possible due to the obligatory dismantling and recycling, with the separately recycled fraction 
having the main influence on the range of total costs. 

3.1.8.1.4.3  Social impacts 

As  scenario  2  and  3  will  result  in  significantly  more  glass  windows  being  dismantled,  an 
increase  in  the  time  needed  for  dismantling  is  expected.  Intertek  RDC  &  OVAM  (2013?) 
assumed that 6 - 10 minutes are needed for the dismantling of all vehicle windows. Assuming 
10 minutes per vehicle as a conservative assumption and based on a workload of 200 days 
per  employee,  this  would  translate  to  19  additional  jobs  in  scenario  Glass  1  and  to  644 
additional jobs in scenario Glass 2 and 3 in the dismantling sector alone. 

3.1.8.1.5  Comparison of scenarios for glass 

The differences in impacts of the scenarios as compared to the baseline are compiled in Table 
3-39 below to allow an easier comparison. 

Table 3-39 Summarising table for the comparison of the glass scenarios  

Impacts 

Scenario Glass 1  Scenario Glass 2 

Scenario Glass 3 

c
i
m
o
n
o
c
E

on ATFs 

on Shredders  

On recyclers 

on SME  

Other  

Administrative 
costs burden 

of 

of 

of 

Loss 
shredding 
material  set-off  by  lower 
maintenance costs 
+ 

23 million € costs due to 
dismantling 
additional 
and  separate  recycling 
- - - 

23  million  € 
costs  due 
to 
additional 
dismantling  and 
separate 
recycling 
- - - 
Loss 
shredding 
material  set-off 
by 
lower 
maintenance 
costs 
to 
Estimated 
result 
a 
in 
decrease  of  1.3 
mil. € 
+ 

0.76  million  € 
due 
to 
additional 
dismantling and 
separate 
recycling 
- 
Loss 
shredding 
material  set-off 
by 
lower 
maintenance 
costs 
to 
Estimated 
result 
in  an 
addition  of  0.3 
mil. € 
Negligible 
Small  increase 
business, 
in 
due 
to  glass 
fraction 
available 
high-quality 
recycling 
Additional 
revenue of 0.08 
mil. € 
+ 
Small ATFs would probably have higher costs than larger ones 
Economic impacts on other stakeholders can be compared to the total 
cost of vehicles and are considered as marginal 
Costs for dismantling and separate recycling may be higher where the 
distance to recycling facilities is significantly >150 km 

Large 
in 
business,  due  to  glass 
for 
fraction  available 
high-quality recycling 
Additional revenue of 2.4 
mil. € 
+++ 

Large 
increase 
in business, due 
to  glass  fraction 
available 
for 
high-quality 
recycling 
Additional 
revenue  of  2.4 
mil. € 
+++ 

increase 

for 

Additional 
reporting  costs: 
123 
– 
ATF 
thousand € 
MS: 0 € 

Additional 
reporting  costs: 
988 
– 
ATF 
thousand € 
MS: 1000 € 

Additional 
reporting 
costs:  ATF  –  1,235 
thousand € 
Shredders/recyclers:206 
thousand €  
MS: 2000 € 

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Impacts 

Scenario Glass 1  Scenario Glass 2 

Scenario Glass 3 

Environment
al 

Social  

2ndary 
resources  

Environmental 
impacts:  LCA 
for 
credits 
recycling 

Employment 

Proportionality  

increase 

increase 
Large 
in  availability  of 
secondary glass 
for  high-quality 
applications 
131,000 tonnes 

Large 
in 
availability  of  secondary 
glass 
for  high-quality 
applications 
131,000 tonnes 

Small  increase 
in  availability  of 
secondary 
glass  for  high-
quality 
applications 
4,000 tonnes 
Increase 
credits 
recycling: 
~4,000  t  CO2-
eq. 
(negligible) 
Increase in jobs 
(ca. 20) 
All  scenarios  are  considered  proportional  for  achieving  the  objectives 
that the EU the Treaties intends to implement 

Increase 
credits 
recycling: 
~126,000 
CO2-eq. 
++ 
Increase  in  jobs 
(ca. 645) 

Increase  in  credits  from 
recycling:  ~126,000 
t 
CO2-eq. 
++ 

Increase in jobs (ca. 645) 

in 
from 

in 
from 

t 

Cost 
effectiveness  

Low  costs  but 
low benefits 
+ 

scenario 

Higher 
effectiveness 
than 
Glass 3 
High  costs  but 
higher benefits 
++ 
General 
coherence  with 
waste 
legislation  and 
the 
CEAP, 
promoting 
waste treatment 
higher 
of 
hierarchy 
and 
circularity) ++ 

a 

Highest costs to result in 
the  same 
benefits  of 
range as scenario Glass 
3 
+ 

General  coherence  with 
waste legislation and the 
CEAP,  promoting  waste 
treatment  of  a  higher 
hierarchy and circularity) 
++ 

high  coherence 
in 
with  WFD 
relation 
to 
recycling 
definition 
limited 
contribution 
circularity 
+ 

but 

to 

the 
of 

Stakeholders of 
all 
categories 
generally 
support 
exclusion 
backfilling, 
that 
explaining 
it 
is  not  a 
problem  for  the 
recycling 
industry 
but 
may  require  a 
revision  of  the 
targets  (EuRIC 
2021). 

Though  stakeholders  expressed  concern  at  the 
workshop (particularly ATFs) as to any obligatory 
requirements  as  to  how  certain  fractions  are 
treated,  for  glass  there  is  support  that  high-
quality  recycling  would  be  feasible  possibly 
requiring  EPR  compensations  for  ensuring  the 
economic 
(EuRIC  2021;  EGARA 
2021).  Glass  manufacturers  highly  support 
measures  that  would  increase  availability  of 
cullet  for  recycling  (Glass  for  Europe  2022; 
FERVER  and  Denuo  2022).  Though  one  car 
manufacturer did not object to a target for glass, 
ACEA  (2021a)  generally  does  not  support 
material specific targets. 

feasibility 

Coherence 

Stakeholder 
acceptance 

Notes: 

-/-: no impact 

Costs or burdens: between 1 and 3 minus signs (-; --; or ---), indicating low (1 minus sign) and high (3 minus signs) costs or 
burdens 

Benefits or savings: between 1 and 3 plus signs (+; ++; or +++), indicating low to high savings 

(): brackets around symbols if costs, benefits etc. are only potentials or are uncertain. If the costs, benefits etc. is rather 
uncertain, a broader range is indicated: e.g. ++ to +++ or – to + 

n.a.: not applicable 

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Regarding the effectiveness of the scenarios, each of them allows increasing the amounts 
of  high-quality  recycled  glass  through  provision  of  ELV  glass  cullet  to  the  market.  Under 
Scenario Glass 1 however only a slight increase of glass is expected to be recycled prior to 
dismantling and thus this scenario is expected to have the lowest effectiveness. Scenarios 
Glass 2 and 3 are expected to result in much higher amounts of ELV glass cullet becoming 
available to the market and are thus considered to be much more effective. In the short to 
mid-term these scenarios could be expected to have a very similar effectiveness, however 
Scenario Glass 3 has a higher flexibility as to how this objective is achieved and could thus 
promote more creativity in the further future in the development of technologies that would 
simplify glass removal. This cannot be excluded for Scenario Glass 2 but is considered to 
be less probable. 

Efficiency  describes  the  cost-benefit-ratio.  Though  the  costs  for  implementing  Scenario 
Glass 1 are expected to be low for the different actors, this scenario also does not result in 
significant  impacts.  It  could  be  considered  efficient  in  terms  of  the  cost-benefit  ratio  but 
remains  does  not  affectively  achieve  the  objective.  Both  Scenario  Glass  2  and  3  are 
expected to increase ATF costs for dismantling, though these could be supported by an EPR, 
in which case they would shift to OEMs. Considering the costs of a new vehicle, the additional 
dismantling costs are not considered to be so high and in contrast to the first scenario they 
achieve much higher benefits. For these actors the two more progressive scenarios could be 
considered to be more effective, however Scenario Glass 3 is expected to result in a higher 
administrative burden for, in particular for ATFs. This scenario is thus considered to have a 
somewhat lower efficiency as compared to Scenario Glass 2.  

In terms of the coherence of the options with the overarching objectives of EU policies, all of 
the  three  options  contribute  to  the  goals  set  out  in  the  Circular  Economy  Action  Plan 
(European  Commission  2020a).  This  is  related  to  backfilling  activities  (downcycling)  being 
avoided in line with the WFD and also to increases in the availability of ELV glass cullet that 
will decrease the reliance on primary materials. Nonetheless, only Scenario Glass 2 and 3 
are expected to generate high amounts of ELV glass cullet, suggesting a lower coherency of 
Scenario Glass 1. The situation of proportionality is similar. As they support circularity to a 
much higher degree in terms of decreasing the dependency on primary materials, Scenario 
Glass 2 and 3 may have higher costs than Scenario Glass 1, but these are still considered 
proportionate in terms of achieving their objective. 

Looking  at  the  different  scenarios  and  the  impacts  detailed  in  the  earlier  sections,  a  few 
conclusions can be made: 

•  Though of relevance for ensuring coherence with the WFD, Scenario Glass 1 shall be 
very limited in promoting circularity. Despite the fact that it would significantly limit the 
practice of backfilling with mineral fractions derived from SHF, it still allows using this 
fraction as a filling material in construction: a practice that results in the downcycling of 
glass and in (permanent) removal of the related glass from the material cycle. Revising 
the definition, so that all practices that would be considered as downcycling (and that 
remove glass from the material cycle) cannot be counted as recycling would have an 
improved affect insofar that such practices could no longer be considered when 
accounting for compliance with the reuse & recycling target. This would push the waste 
sector towards high-quality recycling, however, without prescribing methods or minimum 
amounts. In this respect, instead of excluding backfilling, (Glass for Europe 2022) 
propose an alignment of the ‘recycling’ definition with the WFD, where a requirement for 
the quality of recycling is included, “adding the criterion of preservation or recovery of 
the distinct characteristics of the material with the view of maximising their potential to 
be re-used”. The amount of high-quality recycled glass that this flexibility would result in 
will then mainly depend on how much of other materials of the car composition can be 
reused or recycled and if the ATF can still reach the reuse and recycling target without 

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glass dismantling and recycling (or with lower amounts). Assuming that other materials 
are addressed with more rigid provisions, this sub-scenario could prove to be a good 
compromise between environmental benefits and economic costs, as it has a high 
flexibility and only requires small revisions of the reporting, making reporting on glass 
recycling obligatory to allow monitoring. 

•  Scenarios Glass 2 and 3 are very similar in their expected environmental impact, which 
achieves a significant improvement in terms of the circularity of glass. As a high quality 
of glass treatment is required for a minimum amount by the provisions in each of the 
scenarios, it appears that this result would be achieved regardless of whether the 
recycling definition is aligned with the WFD to exclude backfilling or not. Nonetheless, if 
backfilling and other forms of downcycling are not excluded form Scenario Glass 3 as 
currently suggested, achieving the target would be possible without increasing the 
quality of recycling, subsequently meaning that the environmental benefits would 
probably be lower, making this scenario less attractive. For Scenario Glass 2 the 
exclusion of backfilling was not suggested and as the scenario requires reporting on the 
amount of glass cullet sent from ATFs to recyclers it is not considered that such an 
exclusion would have an impact on the environmental impacts in either direction. That 
said, to ensure alignment with the WFD, it would be preferable to exclude backfilling 
under this scenario as well. As the obligatory dismantling of this scenario will already 
generate a shift away from backfilling and will affect the reporting, this change would not 
be considered to result in additional costs. Both Scenarios Glass 2 and 3 are expected 
to result in significantly higher costs for dismantlers in terms of operations. Though the 
difference in the administrative costs give a preference for scenario Glass 2, it is more 
prescriptive, leaving little room for PST to develop towards high-quality glass removal. 
For the latter reasons, it is not proposed to discard either of the two scenarios. 

EPR considerations: 

•  The additional costs related to dismantling and separate glass recycling could have a 
significant effect on the profitability of vehicle dismantling. Per vehicle, the costs that 
Intertek RDC & OVAM (2013?) specify for pre-and post-shredder recycling show a 
difference of over 150 €/tonne. This value seems high as it refers to the cost per tonne 
of glass, however, a vehicle typically contains around 30 kg of glass, meaning that the 
cost per vehicle is significantly lower.  

A later study (ADEME, France 2015) specifies various sources regarding glass dismantling 
ranging  between  2  €  -  15  €  per  vehicle,  with  the  majority  of  sources  referring  to  values 
between  4  €  -  8  €  per  vehicle.  Following  a  comparison  of  these  costs  with  post  shredder 
recycling  costs,  ADEME  specified  the  differences  to  range  between  1.8  and  3.8 €/ELV 
depending on the study cited. ADEME also surveyed the dismantling times for windows at 
dismantling facilities specifying an average dismantling times of 30 minutes (10 minutes on 
average  for  the  windscreen,  9.5  minutes  for  the  side  windows,  12  minutes  for  the  rear 
window). 

•  There is also some data from MS that require the removal of glass (or have required it in 

the past) such as in cases in which ATFs are compensated for glass removal. For 
example, according to EGARA (2021), in the past, ARN (the Dutch EPR) rewarded 
dismantlers for material separation, resulting in mono streams of plastics, glass, rubber 
and fibre from seatbelts. For this removal, the first car owner was charged a sum of 
45 €/vehicle and annum to cover depollution, unprofitable collection / transport and 
recycling (EGARA 2021). This fee covered other materials and not just glass and has 
since decreased to 25 €/vehicle and annum. EuRIC (2021) explains in this respect that 
recycling (in the WFD sense, excluding backfilling) is technically feasible, referring to 
studies carried out in France and Belgium, showing that it is not an economic practice. 
However, EuRIC state that with an EPR such recycling could be achieved.  

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3.1.8.1.6  Preferred  Scenarios  for  inclusion  in  final  policy 

options 

It is proposed to look at the three following measures for comparison under the various policy 
options: 

•  Revision of the definition of recycling to exclude all practices that remove glass from the 
material cycle and are considered to be a recycling of low quality (down cycling) --> high 
flexibility, low economic costs, low to moderate environmental benefits, 

•  Obligatory removal and separate recycling of a minimum of 20 kg glass per ELV (average) 

--> low flexibility, high economic costs, high environmental benefits, 

•  Recycling target of 70 % glass recycling --> moderate flexibility, high economic costs, high 

environmental benefits. 

3.1.8.1.7  Reporting and monitoring requirements 

Reporting requirements are detailed in earlier sections of the analysis. As recommended by 
ARN,  should  dismantling  be  implemented  in  an  obligatory  basis,  it  may  make  sense  to 
develop  a  monitoring  system  for  ATFs  to  see  that  glass  is  removed  form  ELVs  and  not 
replaced  or  supplemented  with  glass  from  new  vehicles.  This  would  probably  require 
additional  market  surveillance  efforts  in  the  MS.  That  said,  if  this  would  lead  to  a  general 
increase in cullet sent to recycling, this would also be beneficial, whereas monitoring should 
ensure that only glass dismantled form ELVs is accountable should compensations be made 
to ATFs through the EPR schemes. 

3.1.9  Analysis for plastic 

3.1.9.1  Analysis for plastic 

A  variety  of  plastic  polymers  and  elastomers  are  used  in  vehicles  in  many  different 
components.  The  following  tables,  reproduced  from  (Maury  et  al.  2022)  provide  a  good 
overview of the composition of components and their weights.  

Table 3-40 Main polymer types per application in all types of vehicles: Components 
understood to be larger in volume (and heavier in weight) are specified in bold 

Polymer type 
POLYPROPYLENE (PP) 

POLYETHYLENE HIGH 
DENSITY (PEHD) 
POLYURETHANE (PUR) 

ACRYLONITRILE 
BUTADIENE STYRENE 
(ABS) 
POLYAMIDE (PA, NYLON 
6/6, NYLON 6) 
POLYVINYL CHLORIDE 
(PVC) 
POLYSTYRENE (PS) 

Front/rear bumpers, interior panels, dashboard, cable insulation  

Applications 

Fuel tank 

Flexible  foam  seating,  foam  insulation  panels,  elastomeric  wheels 
and  tires,  automotive  suspension  bushings,  cushions,  electrical 
potting compounds, hard plastic parts 
Body parts, dashboards, wheel covers 

Gears, bushes, cams, bearings, weatherproof coatings, carpet fibres 

Instruments panels, electrical cables, pipes, doors 

Equipment housings, buttons, fittings. 

POLYETHYLENE (PE) 

Car bodies (glass reinforced), electrical insulation. 

POLYOXYMETHYLENE 
(POM) 

Interior and exterior trims, fuel systems, small gears 

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POLYCARBONATE (PC) 

Bumpers, headlamp lenses 

ACRYLIC (PMMA) 

Windows, displays, screens 

POLYBUTYLENE 
TEREPHTHALATE (PBT) 
POLYETHYLENE 
TERAPHTHALATE (PET) 
ACRYLONITRILE STYRENE 
ACRYLATE (ASA) 

Door handles, bumpers, carburettor components 

Wiper  arm  and  gear  housings,  headlamp  retainer,  engine  cover, 
connector housings. 
Housings, profiles, interior parts 

Source: Specified by (Maury et al. 2022) as adapted from the Plastics Industry Trade Association (2016) 

Table 3-41 Example of mass distribution intervals of recycled plastic materials per 
application types for a passenger car representing a potential ‘front-runner case’. 
Percentage of recycled content is averaged based on the estimated masses of both 
pre-CR and post-CR 

Plastics materials application 

tot. mass (kg) 

tot. recycled (kg) 

% rec. content 

External accessories - Bumpers 

Removable parts – Labels 

Interior trim 

Heating, Air conditioning 

Engine cooling system 

Electrotechnical 

Pedal unit, break, tools 

Power distribution systems(*) 

Safety systems(*) 

Dashboard 

Fuel tank (*) 

Seats(**) 

Lighting – indicators  

Sealing, windows, mirrors 

Upper engine 

18-20 

6-8 

35-40 

6-8 

6-8 

2-5 

2-5 

6-8 

2-3 

15-20 

8-10 

15-20 

6-8 

10-15 

3-5 

10-11 

4-6 

2-4 

2-4 

1-3 

0-2 

0-2 

0 

0 

0 

0 

0 

0 

0 

0 

60% 

80% 

9% 

46% 

30% 

45% 

45% 

0 

0 

0 

0 

0 

0 

0 

0 

Total 

150-170 

25-32 

15-18% 

(*) Technical or safety parts for which recycled plastics materials is excluded. Chemical recycling might be an option in 
the coming decade 
(**) At the moment, PUR is downgraded during recycling and is not eligible for the same applications (seat foams). 

Sources: Specified by (Maury et al. 2022) as (Gallone and Zeni-Guido, 2019), personal communication with relevant 
stakeholders 

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Five measures were shortlisted for plastics, including the following measures: 

Title 

2.1.g: Establishment of mandatory recycled content targets for plastics used in cars 
2.4.a: Align definition of ‘recycling’ with the WFD to prohibit backfilling of plastic residues 
2.4.b: Making it mandatory to remove certain plastic parts before shredding to encourage their 
recycling 
2.4.c: Set material-specific recycling target for plastic 
2.4.e: Ban disposal or landfilling of waste from ELVs --> requiring PST targeted at plastics 

Chapter 
2.1.5.1.8 
2.1.5.4.1 
2.1.5.4.2 

2.1.5.4.3 
2.1.5.4.5 

Colour code: Red – discarded, Yellow – premature, Grey – supporting measure 

•  Measure  2.4.b  making  the  dismantling  of  plastic  parts  obligatory  is  considered  to  be 
redundant and thus discarded: The ELVD already refers to large plastic components in 
Annex I(4) referring to bumpers, the dashboard, fluid containers, etc., as components that 
should  be  removed  “if  these  materials  are  not  segregated  in  the  shredding  process  in 
such a way that they can be effectively recycled as materials”. Though a threshold could 
be considered on the weight of components to be removed and additional components 
could be added to the list, the measure is considered to already exist and would only need 
to  be  updated  as  relevant.  Looking  however  at the  data  specified  for  plastic  in  section 
2.1.2.5.8, it  seems  that  there  are  not  many  mono-plastic  components  in  a  vehicle  that 
would justify setting such a threshold: aside from bumpers, the above tables clarify the 
larger weights for dashboards, fuel tanks, interior trims and seats. However, most of these 
cannot be recycled (PU foam in seats, dashboard need to be disassembled and this is 
usually not performed269, mono material fuel tanks understood to not be recycled at high 
quality). Adding a threshold for polymers with known recycling capabilities could ensure 
recycling for the case of bumpers, but it is not clear if it would make a difference for other 
components, whereas for bumpers it would suffice to adapt the annex so that bumpers 
need to be removed in any case. This measure is thus discarded. 

•  Measure  2.4.a,  which  would  exclude  backfilling  is  also  discarded. It  is  understood that 
plastics that are included in the shredder fraction would be removed in the various sorting 
processes and do not remain in large amounts in the (sorted) mineral fraction that is sent 
to backfilling. This measure would thus not be considered to be effective in this case and 
is discarded.  

•  Measure 2.1.g, considering a recycled content target for plastics has been investigated 
by the Joint Research Centre (Maury et al. 2022). Results of the analysis are reported in 
the context of this analysis, however, without revising the analysis itself. This measure 
will be looked at initially  as an alternative to the other measures investigated so that a 
distinction can be made on the contributions of each measure, however it is likely that it 
would later be combined with either one or both of the other measures considered.  
•  Measure 2.4.c, A recycling target is also an option to increase the high-quality recycling 
of  plastic.  High  quality  recycling  would  be  a  pre-condition  for  introducing  a  recycled 
content target but could also be considered as a single measure.  

•  Measure 2.4.e, ban disposal or landfilling of waste from ELVs is explained to be achieved 
through requirements of PST targeting the removal of PVC and POPs from SLF, either 
directly or after it has been subject to PST treatments (granulates). Through a prohibition 
on disposal of PST to landfills and a ban on material recycling of these fractions when 
SLF is treated with PST or when fraction resulting from PST have a specific weight above 

269 This was specified by EGARA (2021) who also explained that it was obligatory in the past in Denmark to dismantle the 
dashboard, however there was no specific recycling at the time and was stored and later sent to shredder. The obligation is 
understood to have been removed. The instruments panel of the dashboard is now recycled by STENA, but this is 
understood to focus more on the recycling of the EEC, i.e., the dismantling is not performed to obtain the plastic. 

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1.3 g/cm3. Though this measure is expected to reduce amounts of SLF to be disposed in 
landfill,  it  is  also  expected  to  promote  PST  that  targets  fractions  that  can  be  sent  to 
material recycling. In so far it would also be expected to increase the recycling of vehicle 
plastics. 

3.1.9.1.1  Scenarios for quantitative analysis  

3.1.9.1.1.1  Baseline 

Plastic is used in increasing amounts in vehicles. At EoL some of the plastic components are 
dismantled and sent to separate recycling (after sorting into different polymers, e.g., PP, ABS) 
and some remain in the vehicle and go through shredding and PST operations. According to 
Maury et al. (2022), at present, Polypropylene (PP), Polyurethane (PUR) and Polyamide (PA) 
are  the  3  main  polymers  used  in  the  overall  plastic  composition  of  the  EU  ICE  equivalent 
vehicles’  plastic  components.  The  share  of  PVC  in  vehicles  is  significantly  decreasing  in 
Europe  according  to  recyclers  feedbacks,  being  around  3%.  However,  the  polymers 
composition  is  expected  to  change  in  the  future,  mainly  due  to  the  wide  uptake  of  battery 
electric  vehicles  (BEV).  According  to  some  stakeholders,  a  simplification  in  the  number  of 
polymer types and grades, i.e., less diversity on the plastic types and grades may occur (e.g. 
more PP and PET and less PA in the future).  

•  PP will remain the most used polymers in cars with a probable future growth due to the 
crucial need of lightweight for BEV as well as new “under the hood” applications such as 
casing for batteries.  

•  PA substitution by PP and PE might stem from the lower thermal constraints of BEVs as 

compared to internal combustion engine vehicles.  

•  Potential new “under the hood” applications for PE should compensate, at least partly, 

the loss of fuel tank made with HDPE (i.e., with the shift from ICEs to BEVs). 

•  Several experts forecast that PVC applications will continue to decrease, already used to 
a lower extent than in the past in vehicles. This is explained to partly be due the complexity 
of  the  PVC  recycling  operations.  The  ABS  consumption  is  expected  to  decline  as 
polystyrene  and  PP  composites  with  improved  properties  continue  to  replace  ABS  in 
decorative parts in the interior, except perhaps for the highest premium / executive car.  
•  Finally,  a  higher  PC  consumption  is  expected  (around  2%  today)  due  to  wider 
development  of  glazing  applications  in  automotive.  PC  could  substitute  heavier  glass 
material in the next decades. The higher level of connectivity for future cars should also 
generate more demand for PC entering in the composition of sensors and optical devices 

Maury  et  al.  (2022)  explains  that  integration  of  recycled  plastics  in  vehicles  today  is  often 
considered  as  less  straightforward  by  the  automotive  stakeholders  due  to  the  potential 
difference in mechanical or aesthetics properties and substances composition between virgin 
and  recycled  materials.  However,  for  most  of  the  automotive  manufacturers  (OEMs),  JRC 
understands  from  ACEA  and  CLEPA,  that  integration  of  recycled  plastics  is  already  a 
common  practice.  First,  automotive  companies  reuse  their  own  plastic  production  scraps, 
defective  parts  and  other  materials  in  a  closed  loop  process  to  minimise  potential  waste 
streams. Going further, many manufacturers already integrate in their vehicles pre- and post-
consumer  recycled  materials  coming  from  both  closed-loop,  i.e.  materials  coming  from 
automotive industry, and open loop, i.e. materials from other sectors. For instance, PET from 
packaging waste and PA from carpet textiles find application in vehicle textile interiors. To a 
lesser extent, they also use recyclates sourced from ELV plastics. Interviews of stakeholders 
show that the main recycled polymers that are used are PP, followed by PET and to a lesser 
extent PA. Data also suggests that nowadays, up to 90% of the recyclates used in the vehicles 
come from pre-consumer sources rather than post-consumer. This is expected to change in 
the future as the supply of pre-consumer sources is limited. Where pre-consumer recyclates 

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have  known  and  stable  composition  that  may  be  suitable  for  interiors,  aesthetics,  or  even 
safety  plastics  parts,  for  post-consumer  recyclates  there  are  uncertainties  on  composition, 
and  these  are  thus  usually  used  for  non-aesthetics  and  non-safety  parts.  Technical 
applications may be more limited than when using pre consumer materials. JRC assumes 
that 8% is the current average of recycled content in vehicles, with 18% assumed for the more 
advanced OEMs. 6% of pre-consumer recyclates are assumed for both ICE and BEV vehicles 
for the baseline, differentiating between the various polymer types.  

Considering  the  composition  of  current  vehicles  reaching  end-of-life  the  following  values 
seem relevant: PP (37%); PUR (15%); PA (12%); ABS (7%); PE (8%); PET (5%) others (incl. 
PC, PMMA, PBT, POM…) (16%). (Maury et al. 2022) 

On  average,  of  the  plastic  included  in  ELVs,  19 %  is  diverted  to  recycling,  41%  to  energy 
recovery  and  40%  to  disposal  (mainly  landfill),  though  there  are  deviations  between  the 
various MS. Only a few countries in the EEA achieve levels above 35 % of plastic recycling 
including Norway, Sweden and Switzerland with most EU countries achieving less than 25% 
recycling (Maury et al. 2022). This is among others a result of the fact that metal recycling is 
more economical than plastic recycling, while also contributing more to achieving the targets 
which are weight based.  

End-of-life vehicles (ELVs) are considered as a substantial high-value waste stream, in which 
mixed plastics waste is estimated to account for around 1.5 Mt annually of which more than 
1  Mt  is  collected  at  ATFs.  This  latter  amount  refers  to  around  6  million  of  ELVs  annually 
treated  in  EU-27  in  compliance  with  the  ELVD.  The  current  stream  of  plastic  waste  from 
automotive  sector  sent for  recycling  is  estimated  in  350  kt/a,  and the remaining  fraction  is 
sent either to energy recovery or to landfill. PP from bumpers and PE from fuel tanks are the 
most  recycled  plastics  removed  by  dismantlers  and  bumpers  can  be  recycled  back  into 
bumpers though not common as it is cheaper to send the bumper with the hulk to shredding. 
Plastic from dismantled fuel tanks is usually sent to recycling in drainage tubing or for heat 
valorisation in cement kilns. In total it is assumed that an average of 1% of the total plastic in 
ELVs can be estimated to be dismantled at ATF and sent to recycling without shredding, while 
other dismantled parts for reuse are estimated to represent up to 18.5% of the vehicle plastic. 
(Maury et al. 2022) 

1.05  Mt  of  mixed  plastics  fractions  is  typically  generated  in  the  EU  27  in  the  automotive 
shredder residues (ASR) fraction. Plastics in ASR usually vary from 20 to 40%wt and PUR 
foam from 4 to 15%wt. Sorting fractions out of the ASR is challenging, among others due to 
the ASR being a mix of ELV and waste of other sectors (e.g., WEEE) and due to the presence 
of various hazardous substances. Standard PST, sorts ASF into sub-fractions and is mainly 
aimed  at  sorting  ferrous  metal  from  non-ferrous  metal  fractions.  Advanced  PST  aims  to 
separate  plastic  fractions  (in  shredder  light  and shredder  heavy  fractions  or  SLF  and  SHF 
fractions)  in  addition  to  metal  fractions  from  the  output,  by  using  e.g.,  density  and  gravity 
separation  processes  which  allow  the  recovery  of  polyolefins  or  styrenics  compounds. 
Advanced  PST  is  in  place  in  Germany,  France,  Belgium  and  the  Netherlands,  and  their 
importance for environmentally suitable waste treatment has been recognized (achieving a 
recycling rate of 56% for some plastics such as PP/PE. The SLF is composed of plastics, 
PUR  foam, textiles  and rubber, metal  &  wire,  and  others (such  as  wood,  paper,  soil/sand, 
glass),  produced  when  the  non-ferrous  fraction  is  separated  into  metal  and  non-metallic 
streams. In SLF the share of plastics usually varies from 9 to 37%wt and of PUR foam from 
5 to 29%wt. The SHF is the remaining fraction and mainly composed of heavy materials, such 
as metal  fines,  rubber,  glass,  or  soil/sand  fraction,  however  it  can  also  contain  plastic  and 
textiles. In the SHF the share of plastic varies the from 12 to 31%wt and PUR foam from 2 to 
3%wt. (Maury et al. 2022) 

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In PST and later in advanced PST, a plastic rich stream is separated from other fractions and 
then sorted into separate polymers based on different densities, electrostatic charging and 
separation, and surface properties of the streams within the ASR. According to stakeholders 
the  number  of  facilities  across  Europe  is  rather  limited,  with  around  20-25  facilities  with 
advanced  PST  mainly  in  France,  Belgium,  the  Netherlands  and  Germany.  Advanced  PST 
sorts plastic polymers by applying different steps of float/sink separation aimed at separating 
mixed plastics and grading them by means of density differences. Density-based separators 
include, among other, settling tanks, hydrocyclones and jigs. Other techniques, such as froth 
flotation or laser and infra-red systems have been developed to separate plastics by colour 
and polymers type, as well as eliminate impurities such as wood fragments. Other separation 
sensor technologies are based on optical or atomic differences and chemical analysis. A few 
further technologies have been suggested and could develop in the future to allow elimination 
of impurities (such as styrenic polymers, foams and films) by means of airflow technologies, 
such  as  zigzag  separators  or  densiometric  tables,  or  to  over-separate  the  flow  products 
through use of electrostatic separation. As for long-term developments related to advanced 
PST  that  can  be  understood  to  require  changes  in  design  relates  to  certain  limitations  in 
optical  sorting  of  ASR  plastics  by  near  infrared,  due  to  presence  of  humidity,  oil  residue, 
coatings and plastic colouring with carbon black. To promote optical sorting, R&D focus on 
adding chemical compounds (e.g., phosphor markers) to components as a fingerprint easily 
identified by sensors. (Maury et al. 2022) 

For 2019, the CPA (2021) estimated that from 1.5 million tonnes of plastics collected from 
ELVs, only 350 thousand tonnes were sorted for recycling, resulting in a total of 150 thousand 
tonnes recycled (~10 %). According to the CPA (2021) the separation of different plastics has 
made significant progress in recent years and several thousand tonnes (approx. 0.35 Mt) of 
different polymers (e.g., PP, PE, ABS, PVC...) can be obtained from ASR through advanced 
PST to generate higher-quality recycled plastics (appr. 0.15 Mt) able to meet the requirements 
(e.g.,  legal,  technical,  and  quality)  for  the  automotive  market  or  other  sectors  (e.g., 
construction). 

The following table provides details on the outputs of plastics to reuse, recycling, recovery 
and disposal during the treatment cycle of ELVs in a few countries and is a compilation of 
results of a study performed by (Ramboll 2020). The data demonstrates that recycling can be 
a  result  of  dismantling  or  of  shredding  (with  or  without  PST),  with  the  quality  of recyclates 
depending on the specific country and the waste management facilities that treat ELVs in the 
various stages.  

Table 3-42 Outputs of plastic in tonnes to the 3Rs along the treatment cycle of ELVs 
(data representing 2014) 

Germany 

Total 
plastic 
73,839 

Netherlands 

28,858 

Dismantled 

Shredded  

1,410 
Recycling: 1,274 
Reuse: 108 
Disposal: 28 
No data 

69,337 

No data 

France 

125,092 

14,400 
Recycling: 5,019 
Reuse: 9,363 
Disposal: 18 

98,062 
SLF Recycling: 13,102 
SLF Recovery: 21,813 
SLF Disposal: 38,824 
Heavy residues & fines: 
SLF Recycling: 11,842 
SLF Recovery: 6,338 
SLF Disposal: 11,665 

349 

PST 

n.a. 

19,712 (68%) 
Landfilling: 169 
Recovery:15,598 
Mechanical recycling: 3,945* 
90,901** 
Disposal: 25,377 
Recovery:17,415 
Mechanical  recycling:  48,110 
(recycled  PP  and  PE  are  sent 
to automotive industry, PS and 
ABS sent to other recipient 

 
 
 
 
 
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Notes: *Used for manufacturing road signs and waterfront facing sheets 

Plastic entering PST in France assumed to partly already be accounted for in the shredder fraction 

Compiled from data in (Ramboll 2020), PST shares are calculated based on the data included in the report. 

JRC estimates that an average of 1% of the total plastic contained in a vehicle (on average 
132 kg/ELV) is currently dismantled and recycled separately. After the shredder operations, 
various  sources  indicate  that  the  plastic  content  usually  varies  from  9  to  37%wt  and  PUR 
foam from 5 to 29%wt in the shredder light fraction, and from 12 to 31%wt and PUR foam 
from 2 to 3%wt in the shredder heavy fraction (Maury et al. 2022). 

According to the JRC assumptions (Maury et al. 2022) and based on a vehicle of 1,000,kg, 
the following shares (and amounts) are assumed to be treated through the various routes in 
the baseline:  

•  An ELV contains 12% or 132 kg of plastics.  
•  At the ATF (depollution and) dismantling result in stream of 11 kg of plastics per vehicle, 
with  9.7  kg  (8.3%  of  the  total  plastic  stream)  diverted  to  reuse  and  1.3  kg  (or  1%)  to 
recycling (no shredder).  

•  121 kg (91.6 %) of plastics is sent to the shredder. 
•  After all processing stages, the EU standard level of operation results in 21 kg (16%) of 
recycled  plastics  and  where  advanced  PST  is  applied  this  is  said  to  result  in  31  kg 
(23.5%). 

The  JRC  data  does  not  allow  specifying  how  much  of  the  shredded  fraction  is  diverted  to 
energy recovery and how much is “lost” due to process inefficiency of the sorting and PST as 
well as of polymer compounding. For convenience it has been assumed that the remaining 
plastic is split half-half between these two streams, i.e., in the standard level, 50 kg (38%) is 
sent to energy recovery (possibly also a little bit of backfilling due to plastic residues in the 
heavy  fraction)  and  50  kg  (38%)  is  disposed  of  or  landfilled.  Where  the  current  state  of 
advanced PST is applied, this stream is reduced to 45 kg (34%) sent to energy recovery and 
the same amount sent to disposal.  

3.1.9.1.1.2  Scenario Plastic 1: Establishing a recycled content target for plastic 

The recycled content targets measure for plastics was developed by JRC and details of the 
analysis  and  further  options  can  be  viewed  in  their  final  report.  (Maury  et  al.  2022).  This 
scenario is thus presented in lesser detail, as compared to the other sub-scenarios presented 
here. 

The share of recycled content from all plastics used in vehicles remains relatively modest and 
is  mainly  comprised  of  pre-consumer  recyclates.  The  latter  is  due  to  uncertainties  in  the 
quality  and  consistent  supply  of  post-consumer  plastics.  Though  the  costs  of  secondary 
plastics by now are usually below those of virgin material, there are price fluctuations that can 
be  a  disadvantage,  for  recyclates  in  terms  of  increasing  the  recycled  content  share.  An 
increase in uptake of recycled content could also drive an increase in the costs of secondary 
plastics, creating competition between OEMs on supply. (Maury et al. 2022) 

A few alternatives could be considered under this scenario.  

•  Scenario plastic 1.0: To allow quick deployment and to collect information form OEMs on 
the status of recycled content in their vehicles, an obligatory declaration of plastic recycled 
content  in  new  vehicles  placed  on  the  market  (with  no  minimal  threshold)  could  be 
introduced,  entering  into  force  2  years  after  the  adoption  of  the  legislative  instrument 
(2025).  This  alternative  can  be  seen  as  a  supporting  measure,  allowing  a  better 
understanding of the actual situation. It could be applied on its own or coupled at a later 

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stage  with  one  of  the  target  alternatives  presented  below.  This  alternative  reflects 
scenario 2a of the JRC report. 

Other alternative prescribes setting a recycled content target for vehicles to be put on the EU 
market as to the minimum amount of plastic recycled content that they are to contain. Two 
options have been shortlisted after consultation with the Commission for the current analysis, 
considered to be most relevant in terms of the ratios of environmental benefits and economic 
costs: 

•  Scenario plastic 1.a: very ambitious mandatory targets for 25% in 2030 and 30% in 2035., 
This alternative reflects scenario 3c of the JRC report. It is based on proposals of EuRIC 
with the difference that it does not differentiate between plastic types and incorporates 
PUR foams. 

•  Scenario  plastic  1.b:  highest  ambition  mandatory  targets  for  30%  in  2030  and  35%  in 
2035. This alternative reflects scenario 3d of the JRC report. It expects large availability 
of  recyclate  materials  within  the  automotive  sector  and  from  other  sectors  and  is  thus 
proposed to be combined with scenario plastic 2 (see below). It also considers the future 
availability of new recycled grades that are not available today in the market (e.g. rPUR 
or rPC) but could be produced thanks to innovative recycling processes. 

For these last two alternatives, it is furthermore envisioned to require OEMs to provide the 
declaration referred to under Scenario plastic 1.0, on the content of recycled plastics in the 
specific model, presumably through the 3R Type-approval.  

3.1.9.1.1.3  Scenario Plastic 2: Establishing a material specific recycling target for plastic 

As opposed to other measures, a material specific target for plastic has an advantage insofar 
as it leaves flexible for waste operators to decide what processing stages to apply to ensure 
it is complied with. In this sense, operators could consider whether to increase dismantling 
and separate recycling or to adopt advanced PST and promote the development of further 
PST  technologies,  to  improve  their  outputs  but  also  to  allow  the  sporting  and  recycling  of 
additional  plastic  types  (such  as  PU  foams  mentioned  above  under  scenario  plastic  1b). 
Development of additional technologies would also not be excluded as explained below. 

The CPA (2021) mentions that separate waste collection is correlated with higher recycling 
rates (one of the important conclusions from a Plastics Europe report performed in 2019)270. 
In  parallel,  it  also  explains  that  for  polyolefins  and  other  polymers  (e.g.,  ABS)  mechanical 
recycling  is  good.  However,  to  increase  plastic  circularity,  chemical  recycling  (CR)  should 
focus on the recycling of those polymers (40-50 % of those present in a car) with a very low 
or nonmaterial recovery rate (e.g., PU, PCS, ETP …). In other words, an important question 
behind  the  setting  of  a  target  for  plastic  is  whether  chemical  recycling  would  be  counted 
towards recycling or not (currently unknown and may also vary between CR technologies).  

This  study  uses  the  JRC  simplification  to  include  all  types  of  physical  recycling  such  as 
solvent-based methods or series of purification steps that may allow converting polymers into 
chemicals,  and  processes  such  as  selective  dissolution,  pyrolysis,  gasification  and  both 
chemical  and  thermal  depolymerisation  (but  excluding  energy  recovery)  under  the  term 
chemical recycling. According to Maury et al. (2022), not all CR processes can treat mixed 
plastic waste, only cracking (pyrolysis or gasification) may be able to perform such feat. CR 
is  also  explained  to  not  yet  be  mature  and  cost  effective  when  compared  to  mechanical 
recycling  and  the  environmental  competitiveness  of  different  technologies  is  sometimes 
questioned. It is not yet clear how CR technologies will develop in the future and also whether 
they would be accredited at the same level as mechanical recycling (and accountable towards 

270 Referenced in (CPA 2021) as PlasticsEurope “The Circular Economy for plastics – A European overview” 

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reaching recycling targets). At this stage it can thus not be considered whether to include or 
exclude them from this measure, and the decision is thus left open. 

Stakeholders  were  asked  during  interviews  to  comment  on  some  proposed  levels  and 
following  their  responses  ((EuRIC  (2021);  a  plastics  recyclers  association  (2021))  it  is 
considered  that  30%  recycling  is  ambitious  but  could  be  achieved,  whereas  40%  was 
considered to be too high by the plastic recycling association. 

Stakeholders  also  specify  that  some  polymers  are  more  relevant  than  others  in  terms  of 
secondary  plastics  to  be  used  in  vehicles  but  advise  a  mutual  target  for  all  polymers  (as 
opposed to e.g., limitation to thermoplastics), to avoid that OEMs shift from one polymer to 
another to allow achieving a polymer specific recycling target.  

Against the various uncertainties, a target could be considered to require that 30-40 % of all 
plastics in the vehicle are to be recycled by 2030. This would allow operators to decide how 
to combine dismantling and existing and new PST technologies to achieve the minimum level. 
Depending  on  how  it  would  develop  and  whether  it  will  be  seen  as  an  alternative  to 
mechanical  recycling,  CR  technologies  could  also  be  considered,  in  particular  where  this 
could  allow  removal  of  hazardous  substances.  As  with  other  materials,  the  actual  level  of 
recycling  is  to  depend  on  where  recycled  plastics  need  to  be  measured  for  monitoring. 
Reporting similar to the current one will result in higher rates being reported as the basis is 
how much material can be sold to various plastic recyclers (high quality recycling but also 
downcycling). Monitoring of the plastic containing fraction when entering a treatment facility 
and the corresponding actual recycling efficiency will lower the targets that can be achieved 
but will be more effective in ensuring a higher quality. In the latter case the target should be 
set at 30 % by 2030 and in the former one at 40 %.  

A  plastic  recycling  target  could  be  applied  on  its  own  or  together  with  a  recycled  content 
target. The following analysis considers this option together with a recycled content target of 
the highest ambition (sub-scenario plastics 1c) mandatory targets of 30% in 2030 and 35% 
in  2035,  as  it  is  assumed  to  achieve  the  highest  amounts  of  recycling  and  is  assumed  to 
ensure a more stable supply of recyclates as compared to the following scenario where the 
actual level achieved could differ from time to time. 

3.1.9.1.1.4  Scenario Plastic 3: Banning the landfilling of fractions with a high content of plastics 

Most plastic is understood to be sent with the vehicle hulk to shredder operations and to later 
require a series of treatment processes to allow recovering the plastic fractions and sending 
them to recycling (high quality but also downcycling). It is considered by some stakeholders 
that the application of various PST technologies (current ones but also future developments) 
is the best option for material recovery of plastic, as once the capacities have been installed 
the operating costs are said to be lower than dismantling costs.  

In the Dutch PST facility in Tiel, raw materials contained in the shredder waste undergo a 
process that includes around 180 machines. This results in four different fractions, roughly 
classified as: metals, plastics, fibres and minerals. To separate plastics a pre-separator step 
is used to remove aluminium, iron and copper form the fraction. A magnet, an Eddy Current 
and a special sieve are used to remove iron, aluminium and copper. Crushed plastic goes 
into a zinc float separator and the plastics are separated in two baths on the basis of specific 
weight.  This  results  in  three  plastic  streams:  PP  &  PE,  blast  furnace  fraction  and  a  heavy 
fraction containing a lot of copper. The heavy plastic fraction and additional copper wires from 

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the fibre fraction are treated to extract copper and aluminium, contributing to the recovery of 
the plastic in this fraction.271 

the  Netherlands,  possibly  also  Denmark),  and 

As mentioned above, advanced PST is in place in in only few countries (Germany, France, 
Belgium  and 
for 
environmentally suitable waste treatment has been recognized (achieving a recycling rate of 
56 % for some plastics such as PP/PE” (Maury et al. 2022). As advanced PST is still not very 
common in the EU, it is assumed that increasing its application could raise plastic recycling 
in the short term, whereas in the longer term it is assumed that more advanced technologies 
would develop to improve the sorting of fractions and possibly also to recycle additional plastic 
types. 

importance 

their 

A ban will be introduced on the disposal of shredder light fraction that is not sent to PST and 
PST output fractions with a specific weight of > 1.3 g/cm3. Additionally, minimum performance 
requirements could be set for PST treatment of fractions containing plastics. The available 
data on post shredder technologies that could assist in the recovery of plastics is sparse and 
to a large degree also outdated. Further specification would require an in-depth investigation 
and possibly also development of a standard on such technologies. 

3.1.9.1.2  Results of qualitative analysis  

Under  scenario  plastic  1  the  sub-scenarios  differ  in  terms  of  the  targeted  uptake  of 
recyclates in the automotive sector. This will affect both the benefits expected from each sub-
scenario  but  also  results  in  differences  regarding  the  costs  that  achieving  the  targets  is 
expected to result in. A mandatory declaration by OEMs (scenario plastic 1.0) will prepare the 
ground for audit and traceability schemes, letting time to adapt to a most ambitious regulatory 
measure,  should  one  be  considered  in  the  future.  Very  ambitious  level  targets  (scenario 
plastic 1.a) would represent important efforts for OEMs as well as for recyclers to supply the 
increased  demand.  Highest  level targets  (scenario  plastic  1.b)  would  represent  substantial 
efforts  for  OEMs  as  well  as  for  recyclers  to  supply  the  increased  demand.  An  increase  of 
availability  of  recyclates  from  all  sectors  is  to  be  expected  in  this  case,  meaning  that  the 
amount of secondary material derived from ELVs would need to increase. Where mandatory 
targets of recycled plastic content are included, this is expected to increase the circularity of 
vehicles, expected to be marginal under scenario 1.0, low under scenario 1.a and moderate 
under scenario 1.b. The level of ambition will determine to what degree and will also affect 
costs. Though a more ambitious target results in high investment costs in the beginning, it 
also secures the future demand for recycled plastics, which is of particular importance when 
targets also require a certain level of closed loop recycling, as this will ensure that investments 
are also returned to a higher degree over time. This is also expected to help in potential job 
creation. 

One  of  the  advantages  of  scenario  plastic  2  is  that  it  leaves  open  how  to  achieve  the 
recycling  targets,  as  opposed  to  obligatory  dismantling  or  requirements  for  PST.  Though 
some stakeholders support PST as being a less expensive option for increasing recycling, in 
EGARAs  (2022a)  opinion,  the  costs  of  PST  are  the  same  as  separation  at  the  source 
(dismantling)  due  to  many  unprofitable  materials.  What  is  more  expensive  can  differ  from 
country to country. Some will prefer to invest in dismantling as the cost of labour is not so 
high, whereas others will prefer a one-time investment in PST that then reduces the annul 
operational cost. Other factors may also affect such choices such as the distance between 
ATFs to further treatment and recycling facilities. The recycling target ensures that over time 
a  minimal  level  of  recycling  would  be  achieved  (assuming  set  realistically)  but  gives  more 

271 Summary from https://adoc.pub/dossier-pst-fabriek-de-onmisbare-schakel-dossier-grondstoffe.html, last viewed 25.6.2022  

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flexibility for operators to consider what the most economically efficient way is of achieving 
the  target.  Introducing  a  target  is  expected  to  increase  the  amounts  of  plastic  material 
recycled from vehicles, which will lead to an increase in costs for the processing of plastics 
by  operators.  For  some this  will  mean  more  dismantling  and  separation  of  certain  plastics 
(e.g., PP, ABS) and for others an investment in PST capacities that enable separation of the 
plastic fraction into separate polymers that can be recycled. Various actors (EGARA 2021; 
CPA 2021) refer to dismantling of plastic components as having a positive effect on the use 
of recycled content as it will result in better quality of shredded plastic fractions and foams 
and a higher quantity of recovered plastics fractions (thanks to easier sorting) as well as PUR, 
however little evidence has been provided by stakeholders to clarify plastic components, the 
dismantling of which would lead to higher quality recycling. In parallel, from the data compiled 
by (Maury et al. 2022) it is understood that application of advanced PST technologies by more 
MS  is  expected  to  allow  a  shift  from  the  standard  16%  recycling  to  the  frontrunner  24%. 
Chemical  recycling  may  also  play  a  role  in  achieving  a  target,  depending  on  how  it  is  to 
develop and whether it will count as recycling. In short, this measure is assumed to promote 
a  more  heterogenous  application  of  methods  to  achieve  the  target,  giving  operators  more 
flexibility. The latter will lead operators in different MS to promote the alternative considered 
most economically feasible in their area. . 

As for scenario plastic 3, the CPA (2021) explains that “the recycling sector still favours PST 
over  dismantling  based  on  the  experience  with  the  cost/benefit  of  both  approaches. 
Investment in PST makes more economic sense in terms of improving plastic recovery from 
the  ASR  and  recycling  through  advanced  PST.  ASR  represents  approx.  90 %  of  plastics 
present in a car and shows the opportunity to increase the recovery of plastic material from 
this  ASR”.  Advanced  PST  also  has  the  benefit  that  it  will  allow  better  sorting  of  plastic 
contaminated  with  hazardous  substances  from  the  plastic  stream,  i.e.,  reducing  losses  of 
material  currently  disposed  of  due  to  such  contaminants.  JRC  estimate  that  a  ban  on  the 
disposal or landfilling of waste from ELVs shall lead to a higher quantity of plastic from ELV 
entering the recycling route (Maury et al. 2022). It is however not clear how this would affect 
the total quantity of recyclates and more importantly could also result in an increase in low 
quality  recycling  or  energy  recovery.  In  terms  of  costs,  at  present  the  capacities  of  PST 
facilities in the EU are rather limited and only available in some countries (4-5 MS), so that it 
can be expected that this scenario may result in high costs a least for some MS. Nonetheless, 
the current experience with advanced PST shows that it can increase the share of recycled 
plastics significantly already with existing technologies (16% --> 24 %) and it is probably that 
additional  innovations  will  be  developed,  considering  the  already  existing  research  in  this 
direction. 

3.1.9.1.3  Results of quantitative analysis  

In the baseline, it is assumed that 5% of plastics are diverted to reuse in various components. 
The  actual  amount  of  material  recovered  (recyclates)  amounts  to  17 %  of  the  plastics  in 
vehicles. Of this 1 % is recycled as a result of dismantling and sorting into separate streams. 
The  rest  of  the  amount  is  split  half-half  between  energy  recovery  (39%)  and  losses  (39% 
assumed to be disposed of). 

Under scenario plastic 1, obligatory declaration on use of recycled content and/or a recycled 
content target shall be introduced, its impacts on the vehicle waste management will depend 
on the nature of the requirement.  

Sub-scenario plastic 1.0 looks at the sole results of an obligatory declaration. It assumes only 
a marginal increase in reuse (6%) and in recycling after dismantling (2%), meaning that 18% 
of plastics are recycled. 

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Sub-scenario  plastic  1.a  assumes  that  a  target  for  recycled  plastic  content  is  introduced, 
requiring 25% of min rec. content in 20230 and then 30% in 2035. This is understood to be 
ambitious and is assumed to drive more significant improvements under the baseline, namely 
the implementation of advanced PST across the EU at its current level. This will lead to an 
increase of reuse to 10% and of recycling after dismantling to 4%. Post shredder recycling 
would be assumed to increase to 20%, making for a total of 24% of recycled plastics from 
vehicles.  

Sub-scenario  plastic  1.b  is  understood  to  require  a  higher  increase  in  recycling  of  plastics 
from  vehicles  and  is  thus  coupled  with  a  material  recycling  target  for  plastics,  i.e.,  it  is 
combined into scenario plastic 2 (see there for details).  

Under  scenario  plastic 2,  a 40 % target  is to  be  introduced,  under the  assumption  that  it 
addresses  the  quantities  sent  to  recycling  (e.g.,  includes  losses,  but  monitoring  is  less 
burdensome). The sector will develop more separation at the source (dismantling) as well as 
improving both shredding and post-shredder techniques. Reuse is expected to remain stable 
(10%) but recycling after dismantling will increase to 6% and post shredder recycling to 24%, 
making for a total plastic recycling (actual recyclates) of 30%. This scenario is coupled with a 
recycled  content  target  of  30%  in  2030  and  35%  in  2035  and  the  recycled  amounts  are 
assumed to support this target with higher contributions from the vehicle sector. 

Under scenario plastic 3, operators are required to introduce PST requirements and it can 
be expected that this would need to be supported with the development of a PST standard to 
clarify the minimum level of performance. Advanced PST would be adopted across the EU. 
For some operators this would mean the current level of recycling of 24% could be reached, 
but it is also assumed that technologies would continue to develop and that some operators 
would  achieve  higher  levels.  Here  reuse  is  assumed  to  remain  10%,  recycling  after 
dismantling will amount to 5% and post shredder recycling will achieve an additional 24%, 
making for a total plastic recycling (actual recyclates) of 29%. As disposal is only allowed after 
PST and only for fractions with a specific weight of < 1.3 g/cm3 it is assumed that removal of 
hazardous substances shall achieve a higher level, thus decreasing amounts sent to recovery 
and inefficiencies (disposal) as cleaner fraction support more recycling.  

The following table specifies the routes of treatment assumed under each option. 

Table 3-43 Routes of treatment for plastics from ELVs under the various scenarios  

Plastics 

Dismantled -> 
reused/remanufactured 
Dismantled -> recycled (no 
shredding) 
Dismantled -> shredded -
>recycled 
Shredded -> recycled 

Recovered: (energy recovery or 
backfilling)  
Losses/process inefficiencies 

Baseline 

Scenario 
1 

Scenario 
2 

Scenario 
3 

Scenario 
4 

5% 

1% 

0% 

6% 

2% 

0% 

43.5% 

50.5% 

41.5% 

50.5% 

10% 

10% 

10% 

4% 

0% 

42.0% 

44.0% 

6% 

0% 

49.0% 

35.0% 

5% 

0% 

45.0% 

40.0% 

5% 

6% 

10% 

10% 

10% 

Source: Oeko-Institut: own assumptions based on available data. 

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3.1.9.1.3.1  Environmental impacts 

For  scenario  plastic  1,  JRC  presents  detailed  results  in  their  report,  whereas  here  only 
estimations for: Climate Change (in kg CO2 eq.), are reproduced. Figure 3-14 compares the 
potential impacts of some of the assessed policy scenarios with those of the corresponding 
Business  as  Usual  (BaU)  scenario,  focusing  on  the  Climate  change  category.  The  overall 
climate  change  impact  of  plastic  materials  used  in  one  average  vehicle  at  a  given  year  is 
progressively reduced when more recycled plastic is incorporated in the vehicle compared to 
the  relevant  BaU  scenario.  In  other  words,  an  impact  reduction  occurs  with  the 
implementation of the proposed policy options, and this reduction increases with the level of 
ambition  of  the  option  itself,  and  hence  with  the  uptake  of  recyclates  in  new  vehicles. 
(summarised from Maury et al. (2022)) 

Figure 3-14  Potential impact on Climate Change of plastic granulates from different 
feedstock sources, as calculated for the purpose of the JRC analysis. (kg CO2 eq. per 
kg of plastic granulates) 

Source: JRC report, figure 22 (Maury et al. 2022) 

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The JRC report explains that the impact on climate change is reduced by at least 50 % when 
comparing post-consumer recycled plastics from open-loop or closed-loop recycling with their 
virgin counterpart, and this for all the polymer types. The increased use of recycled plastic in 
scenario plastic 1-1 and 1-2 is thus expected to reduce the consumption of virgin plastics, 
consequently  improving  the  environmental  performances  related  to  GHG  emissions  from 
plastic material use in vehicles or elsewhere. (summarised from Maury et al. (2022))  

Relating to the scenarios proposed in this study that includes a recycled content element, it 
is assumed that in Scenario plastic 1-0, though there shall be a small increase in the level of 
recycling, however this shall not necessarily feed into the use of recycled content in vehicle 
production, given that there is no target, and even of the declaration shall motivate OEMS to 
apply my recycled content, this would not rely on the recycling from the sector. 

For  Scenario  plastic  1-2,  a  high target  is  adopted,  according to  which vehicles  reach  30% 
recycled content by 2035. This results in a reduction of ca. 75 kg CO2 eq. per vehicle. A tenth 
of this is reduction is understood to be achieved through post-consumer closed loop plastics, 
meaning that the ELV recycling contributes around 7.5 kg CO2 eq to the process. This share 
is subtracted to avoid double counting when combining the EoL material flows, resulting in 
67.5 kgCO2eq per vehicle. 

For Scenario plastic 1-2, the target is 5% higher. Assuming a linear increase kg CO2 eq would 
mean that per each vehicle ca. 71 kgCO2eq are saved.  

To summarise: 

  Scenario plastic 1-0: it is assumed that even if recycled content shall increase, it shall 

be marginal and shall not be sourced from vehicles. 

  Scenario  plastic  1-1:  An  increase  of  67.5  kgCO2eq  per  vehicle  is  assumed  to  be 

sourced from other sectors. 

  Scenario  plastic  1-2:  An  increase  of  ca  71  kgCO2eq  per  vehicle  is  assumed  to  be 

sourced from other sectors. 

These amounts have been used to calculate the additional contribution of each scenario to 
climate change reduction.  

Based on the shares of plastic to undergo various treatments at EoL, presented in Table 3-43, 
the material flows in the waste management sector were calculated. And are presented in 
Figure 3-15. 

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Figure 3-15  Average plastics from collected ELVs assumed to be either reused or 
recycled and losses of the material in the treatment process (in 2035), in kg 

Source: Own illustration 

The total increase in recycled plastics in comparison to the baseline under each scenario is 
specified in Table 3-44, which also specifies the increase of recycled plastics that originate 
form dismantled components and thus is potentially of higher quality.  

Table 3-44 Recycled plastics volume generated as compared to the baseline under 
the various scenarios in tonnes 

Delta recycled plastics as compared to baseline 

Delta recycled plastics from dismantling with 
potentially higher quality 

Scenario 
1-0 

Scenario 
1-1 

Scenario 
3 

Scena
rio 2 + 
1-2 
279,00

127,600  

191,200  

0  

249,400  

 13,500  

 40,450  

 67,400  

 53,900  

Source: Oeko-Institut: own assumptions based on available data. 

Though the total amount of recycled plastics is similar between scenario 2+1-2 and scenario 
3, the former is assumed to initiate a little bit more dismantling to ensure that the targets are 
reached – both the material specific recycling target and the recycled content one. 

It is furthermore assumed that, when recycling after dismantling, the plastic does not undergo 
the various shredding and sorting processes, so the benefit in terms of kg recyclate would be 
expected to be higher, i.e. as inefficiency losses to the shredder and PST are spared.  

Based on the material flows presented in Table 3-43, and on the estimations on the additional 
contributions of recycled content scenario to climate changes, the total GWP reductions were 
calculated for the various scenarios and are presented below. 

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Figure 3-16  Credits for Global warming potential (GWP) for each scenario for 
average plastic from collected ELVs to primary production (in 2035) in kgCO2 eq. 

Source: Oeko-Institut: own assumptions based on available data. 

Despite  the  lower  recycling  rates  in  scenario  1-1,  the  contribution  of  the  recycled  content 
target to the general status of recycling has a large contribution to the total benefit in terms of 
GWP.  Generally,  the  two  scenarios  where  recycled  content  targets  are  included  show 
significantly  higher  benefits.  Whereas  scenario  1-0  shows  an  additional  benefit  of  67 
thousand  tonne  CO2  eq,  (or  7%),  in  scenario  1-1  and  2  +  1-2  the  benefits  amount  to  an 
additional 766 and 660 thousand tonnes CO2eq (or 89 % and 81 %) respectively. Scenario 
3 still has benefits that are significant in relation to the baseline, of 119 CO2eq or (or 13%) 
less emissions, however this is significantly lower than the two other scenarios. 

3.1.9.1.3.2  Economic impacts 

JRC  estimates  (Maury  et  al.  2022)  the  average  recycling  costs  of  plastic  from  ELVs 
(dismantling, shredding and post shredding phase) would range from 80 to 110 €/tonne. While 
the compounding costs are approximately 300 €/t of processed material. The costs for new 
investments in the sector are assumed to be 1,000 €/t of processed materials, according to 
targeted stakeholder consultation, and refer to the construction of new recycling facilities (i.e., 
new  capacities).  It  is  not  completely  clear  if  the  latter  is  a  one-time  cost,  or  an  annual 
investment overtime due to financing. Assuming the latter, would mean that a total of 1380-
1410 € per tonne of material recycled. 

These  costs  will  be  applied  to  calculate  the  total  costs  of  the  scenario  for  the  ELV  sector, 
based  on the  amount  of  recyclates.  80  €  is  applied  for  recycling from  dismantled  fractions 
(given that there are assumed to be less losses and that this fraction is assumed to potentially 
result in higher quality recyclate, i.e., to take into considerations that the ATF may receive a 
higher  price  per  kg  than  operators  of  PST.  This  is  an  assumption  and  has  uncertainties, 
however  due  to  the  low  differences  in  plastics  recycled  after  dismantling  between  the 
scenarios of higher performance, the rate of error is not expected to have a significant impact. 
For the waste management actors, the costs of:  

  scenario 1-0 are ca. 11.75 million € higher than the baseline or 1.28 € per vehicle. 

  scenario 1-1 are ca. 100.5 million € higher than the baseline or 10.9 € per vehicle 

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  scenario 2 + 1-2 are ca. 223.5 million € higher than the baseline or 24.25 € per vehicle 

  scenario 3 are ca. 182.2 million € higher than the baseline or 19.76 € per vehicle 

Assuming  400  €  revenues  for  each  kg  of  plastic  sold  to  the  recyclers  and  the  expected 
tonnage of recycled plastics, the following revenues incur for the waste management sector 
from plastic recycling: 

  scenario 1-0 are ca. 3.5 million € higher than the baseline or 0.37 € per vehicle. 

  scenario 1-1 are ca. 28.8 million € higher than the baseline or 3.13 € per vehicle 

  scenario 2 + 1-2 are ca. 64 million € higher than the baseline or 6.94 € per vehicle 

  scenario 3 are ca. 52.1 million € higher than the baseline or 5.65 € per vehicle 

When combined with the costs, the NET benefits or losses accrue to: 

  scenario 1-0 are ca. 8.3 million € higher than the baseline or 1.10 € per vehicle. 

  scenario 1-1 are ca. 71.6 million € higher than the baseline or 9.49 € per vehicle 

  scenario 2 + 1-2 are ca. 159.5 million € higher than the baseline or 21.13 € per vehicle 

  scenario 3 are ca. 130 million € higher than the baseline or 17.22 € per vehicle 

The costs increase from scenario to scenario (and decrease slightly in scenario 3) as in each 
case more investments are needed to finance the production of recycled plastics. 

To put this cost into perspective, in a survey conducted in this study, Member States were 
asked  whether  landfilling  (e.g.,  of  shredder/PST  residues)  is  allowed  in  their  countries. 
Though only about half the MS responded, it was clarified that in half of the responding MS 
landfilling is prohibited. At EU level, according to CEWEP272, slightly less than half (11) MS 
have not adopted any restrictions. Though only 4 MS were stated not to have a landfill tax, in 
those that do tax landfilling Tax rates vary from 5 €/t (LT) to more than 100 €/t (BE). Assuming 
a case in which no plastic is recycled would result in a landfilling cost of between 0.66-13.2 € 
in  countries  applying  a  tax.  Assuming  that  a  higher  tax  will  drive  countries  to  apply  more 
advanced PST (as in the case of Belgium) could explain in part why some countries have 
invested in advanced PST whereas most have not. This would speak in favour of scenario 3 
as a means to promote advanced PST throughout the EU, in particular if a higher level of 
recyclates can be ensured in such cases.  

According to JRC, as a consequence of introducing higher targets for recycled plastics, the 
vehicle manufacturing lines will have to most likely be adapted, in order to comply with the 
safety  standards  of  the  vehicles.  Introducing  new  policy  options  would  lead  to  a  potential 
variation  in  the  production  costs  of  new  cars.  For  ICEs  an  increase  of  around  12  to  38 
€/vehicle is expected for policy options 3.a, 3.b and 3.c in 2030, while in 2035 the additional 
costs range approximately from 15 to 64 €/vehicle (see Figure 25 in JRC report). Similar costs 
are expected for BEVs as well (see Figure 26 in JRC report). (Maury et al. 2022) 

From  the  above  costs,  the  higher  range  of  costs  is  assumed  to  be  relevant  per  vehicle  in 
scenario 1-1, i.e., 64 € for ICEs and BEVs. In scenario 2 + 1-2, the costs would be expected 
to  be  somewhat  higher  as  manufacturers  must  reach  a  5%  higher  target.  In  the  other 
scenarios, where a recycling content target is not assumed such costs are not considered for 
manufacturers,  however  it  is  possible  that  OEMs  would  need  to  compensate  the  waste 
management costs if the additional costs are not covered by other activities. 

272 See: https://www.cewep.eu/landfill-taxes-and-restrictions/, last viewed 24.8.2022 

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In addition, JRC estimated the Δ€ (benefit) / per tonne for recyclers, of additionally produced 
recyclates  being  integrated  in  a  vehicle.  These  are  reproduced  in  the  following  figure, 
considering  the  ambition  of  the  target  for  each  policy  option  in  2030  and  2035  and  also 
considering reaching demand with 25 % closed loop. Maury et al. 2022) 

Table 3-45 Δ € (benefit) / per tonne of recyclates additionally produced compared to 
the baseline and being then integrated in a vehicle 

Source: JRC report, table 21 (Maury et al. 2022) 

The NET benefit from recycling plastic of 386 € per tonne is representative for scenario 1-1 
(or around 3.5 million €), whereas as here too, the cost for scenario 2+1-2 would be expected 
to be somewhat higher. 

As for audit, certification and verification schemes of the recycling content, the corresponding 
costs would need to be distributed across the value chain. The costs estimated by JRC were 
explained to be very low per vehicle and are not reproduced here. These costs are assumed 
to be relevant for scenario 1-0 and could be considered as well for scenarios with a recycling 
target, in terms of manufacturers administrative burden, however as they are very low, they 
are disregarded. 

To summarise, the costs and benefits are compiled into the table below. 

Table 3-46 Costs and benefits of the scenarios in terms of the difference to the 
baseline, in total (and in €/vehicle) unless otherwise stated 

Costs for waste management actors 

Revenues for recyclers from plastic 
sales 

Net benefit for recyclers per tonne 

Cost for manufacturing (OEMS) 

Cost of landfilling were plastics not 
recycled at all, nor recovered 

11.75 million € 
(1.28) 

Scenario 1-0  Scena
rio 1-1 
100.5 
million 
€ 
(10.90 
€) 
28.8 
million 
€ 
(3.13 €) 
386 € / 
tonne 
64€/ 
vehicle 

No recycled 
content target 

3.5 million € 
(0.37 €) 

Scenario 2 + 1-2 

Scenario 3 

223.5 million € 
(24.25 €) 

182.2 million € 
(19.76 €) 

64 million € 
(6.94 €) 

52.1 million € 
(5.65 €) 

Somewhat higher 
than 386 € / tonne 
Somewhat higher 
than 64 €/vehicle 

No recycled 
content target 
Hypothetical cost as perspective for the costs of recycling: 
0.66-13.2 €/vehicle 

Source: Oeko-Institut: own assumptions based on available data. 

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3.1.9.1.3.3  Social impacts 

Under  scenario  plastic  1,  JRC  estimates  that  jobs  will  increase  under  each  of  the  sub-
scenarios by 2035 as follows: 

Table 3-47 Summary of employment impacts under scenario 1 

Scenario 

Scenario plastic 1.a 

Scenario plastic 1.b 

Scenario plastic 1.c 

Number  of 
manufacturing sector 

jobs 

in 

Number  of 
waste 
sector 

in 
jobs 
management 

~1630 

~600 

~3265 

~1195 

 ~6530 

~1795 

Employment in the JRC scenario 1c represents additional employment in scenario 1-1, with 
6530 jobs assumed for the manufacturing sector and 1795 for the waste management sector. 

For scenario 2+1-2, the jobs for the manufacturing sector could be expected to be higher. 
Judging  by  the  amounts  of  recycled  plastics  produced,  the  number  of  jobs  for  the  waste 
management sector would be higher, with scenario 3 having a level in between the two.  

It is assumed that scenarios 1-1, 2 + 1-2 and 3 will all result in an increase in the level of PST 
facilities. This is assumed as today only 4-5 MS are understood to have advanced facilities. 
It is not clear how many employees would be needed for new facilities. In some cases, it is 
expected  that  the  new  facilities  would  be  independent  (i.e.,  single  installation  run  by  an 
operator),  and  in  others,  existing  operators  could  be  expected  to  invest  in  new  facilities. 
Assuming that installations are relatively automated and thus, that the latter would not require 
a  large  number  of  additional  employees,  5  employees  are  assumed  for  an  “independent” 
operator and 2 for an existing one. With 22 MS assumed not to have advanced facilities, this 
would make up for between 44 and 110 new jobs if only one installation is erected per MS. 
Additional employment would be generated for dismantlers, however there is lacking data to 
consider which components would be dismantled and what the dismantling times would be.  

These numbers would be relevant for all three scenarios where PST is expected to develop, 
with  scenario  2  +  2-1  expected  to  have  the  highest  costs  and  scenario  3  somewhere  in 
between. 

Though  in  scenario  1-0 costs  incur  for the  preparation  of  the  declarations  (manufacturers) 
these are understood to be very low and would be assumed to be covered by the existing 
level of employment.  

In  addition,  where  PST  shall  be  developed,  it  can  be  assumed  that  less  materials  will  be 
disposed  of  and  that  fractions  contaminated  with  hazardous  substances  will  be  better 
controlled. Lacking data would not allow to estimate the level of benefit, but it is assumed to 
be proportional to the amount of PST recyclates. 

.  

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3.1.9.1.4  Comparison of scenarios for plastic 

Table 3-48 Summarising table for the comparison of the plastic scenarios  

Impacts 

c
i
m
o
n
o
c
E

Scenario 
plastic 1-0 
recycled 
content 
declaration 

Scenario 
plastic 1-1 
(3c) - 
recycling 
content 
target 30% 

Scenario 
plastic 2 + 1-2 
(3d) -recycling 
target 30% + 
recycling 
content target 
35% 

Scenario 
plastic 3 – 
PST + 
disposal ban 

on ATFs 

 1 million €  

 3.2 million €   

 5.4 million € 

 4.3 million €   

on 
PST/Shredders  

On  recyclers  - 
revenues 

Recycler 
compounding 
costs 

Investments  in 
waste 
management 

Vehicle 
manufacturers 
– 
production 
costs 

 -0.5 million €  

3.5 million €  

 10.2 million €  

 8.4 million €  

 3.5 million €  

 28.8 million €  

 64 million €  

 52.1 million €  

 2.6 €  

 21.6 €  

 48 €  

 39.1 million €  

8.6 million € 

72 million € 

160 million € 

130 million €  

n.a 

64 €/vehicle 

  64 

n.a 

€/vehicle  

on SME  

Small operators may have higher logistics costs assuming they have less 
storage space, need to send plastic scrap batches more often and thus 
also in smaller batches 

Administrative 
costs Burden 

2ndary 
resources: 

 total recyclate 

Recyclate from 
dismantling 

Costs covered under vehicle level analysis 

OEM  may  have  costs  for  declarations/certification;  however  these  are 
understood to be very small  

127.6 thousand 
tonnes 

191.2 thousand 
tonnes 

279 
tonnes 

thousand 

249.3 thousand 
tonnes  

thousand 

13.5 
tonnes 

thousand 

40.4 
tonnes 

67.4 
tonnes  

thousand 

thousand 

53.9 
tonnes 

Environmental  Environmental 
impacts:  LCA 
for 
credits 
recycling 
in 
CO2eq 

thousand 

67 
tonne  

766 
tonne 

thousand 

660 
tonne 

thousand 

thousand 

758 
tonne 

Social  

Employment 

low  

6530 
(OEMS) 

jobs 

Higher  number of 
jobs for OEMS 

Higher 
waste sector  

for 

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Impacts 

Stakeholder 
acceptance 

in 

Decrease 
hazardous 
substance 
emissions 

Proportionality  

Cost 
effectiveness  

Coherence 

Scenario 
plastic 1-0 
recycled 
content 
declaration 

Scenario 
plastic 1-1 
(3c) - 
recycling 
content 
target 30% 

Scenario 
plastic 2 + 1-2 
(3d) -recycling 
target 30% + 
recycling 
content target 
35% 

1795 
sector) 

(waste 

Highest  for  waste 
sector 

Scenario 
plastic 3 – 
PST + 
disposal ban 

n.a 

Low 

moderate 

High 

not 

Does 
contribute 
much 
to 
objectives  but 
considered 
necessary 
in 
the  case  of  a 
recycled 
content target 

Not  effective  in 
achieving 
circularity  but 
considered 
supporting 
measure 
monitor 
recycled 
content targets 

to 

All  scenarios  contribute  to  objectives  that  the  EU 
Treaties  intend  to  implement  through  increase  in 
circularity.  Emission  reduction  contribution  are  more 
modest, in particular when considering the high cost per 
vehicle  that  this  generates  in  the  more  ambitious 
scenarios 

Possibly  most 
effective 
as 
costs  are  more 
moderate  than 
scenario  2  + 
1.2 
and 
scenario  3,  but 
recycled 
content 
still 
higher 
contribution 
GWP 
scenario 3 

target 
a 

to 
than 

has 

Moderate 
effectiveness  as 
costs are high per 
vehicle, 
but 
benefits  are  the 
highest 

Low 
effectiveness  -
costs, 
Higher 
significant 
generation  of 
recyclables, 
however  with 
low contribution 
to emissions. 

+ 

All  scenarios  considered  coherent  as  they  lead  to  an 
increase in circularity (coherence with the CEAP) and 
towards  waste 
treatment  of  higher  hierarchy 
(coherence with the WFD) + with better control of POPs 
and other BFRs. 

Plastic was one of the materials for which stakeholders (particularly in the 
waste  management)  view  a  recycling  content  as  a  measure  to  give 
certainty  and  allow  investments  in  the  recycling  of  plastics  in  vehicles. 
Plastics Europe (2022) is understood to support the measure, stressing 
however  the  need  to  ensure  quality  of  vehicle  recyclates  to  support  its 
implementation. 

A few stakeholders stated that PST is more cost effective than dismantling 
(though there are also voices saying that the costs are similar). The main 
view expressed is that it is better to leave more flexibility as to how targets 
are achieved than to prescribe a certain technology. In this sense though 
the target may be high, the flexibility it provides is preferable to the PST 
development required under scenario 3. EuRIC stated that a 40 % target 
would  be  very  ambitious  but  is  considered  ok.  A  plastic  recyclers 
association agreed that 20 % by 2025 would be possible but referred to 

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Impacts 

Notes: 

-/-: no impact 

Scenario 
plastic 1-0 
recycled 
content 
declaration 

Scenario 
plastic 1-1 
(3c) - 
recycling 
content 
target 30% 

Scenario 
plastic 2 + 1-2 
(3d) -recycling 
target 30% + 
recycling 
content target 
35% 

Scenario 
plastic 3 – 
PST + 
disposal ban 

the 40 % target in 2035 as too ambitious. Generally, it is preferred not to 
have separate targets for specific polymers. 

Costs or burdens: between 1 and 3 minus signs (-; --; or ---), indicating low (1 minus sign) and high (3 minus signs) costs or 
burdens 

Benefits or savings: between 1 and 3 plus signs (+; ++; or +++), indicating low to high savings 

(): brackets around symbols if costs, benefits etc. are only potentials or are uncertain. If the costs, benefits etc. is rather 
uncertain, a broader range is indicated: e.g. ++ to +++ or – to + 

n.a.: not applicable 

Except for scenario 1-0, which in any case is considered a supporting scenario that will not 
affect circularity significantly on its own, all scenarios achieve nice levels of recyclates, though 
it is unclear to what degree this would also result in high quality plastic. Scenario 2+1-2 is 
expected  to  have  the  highest  benefit  to  both  circularity  (amounts  of  recyclates)  and  to 
emission  reductions,  however  the  latter  is  related  to  the  recycled  content  target  that  the 
proposed recycled target is combined with. In particular this is related to the contribution of 
other sectors to secondary materials which has nice savings in terms of avoiding manufacture 
of primary materials and results in the significant difference in GWP between Scenario 2+1-
2 and Scenario 1-1 as compared to Scenario 3. 

Nonetheless,  the  understanding  that  under  scenario  3  a  high  level  of  PST  would  be 
established throughout the EU is expected to eliminate landfilling significantly (only fractions 
with hazardous substances could be disposed of as hazardous waste).  

The assumptions assumed that Scenario 2 + 1-2 would have the highest dismantling of all 
scenarios and this is related to the flexibility that a target provides in terms of implementation, 
however in practice it is hard to say if this scenario would not be more similar to scenario 3 in 
terms of the capacities of PST to be developed. 

EPR considerations: 

JRC explain that modulated EPR fees related to the declared recycled content (as proposed 
in the JRC policy option 2, to be implemented in a relatively short term, e.g. 3 to 5 years after 
entry into force) is seen as a promising way to reward, via e.g. bonus or lowered fees, vehicles 
produced  by  frontrunners  who  can  prove  they  meet  given  contents  of  recycled  plastics. 
(Maury  et  al.  2022)  This  option  would  be  particularly  relevant  for  scenario  plastic  1-0  as  it 
would probably lead to higher circularity at least for some OEMs, 

For  scenario  plastic  1-1  2  +  1-2  and  3,  the  additional  costs  for  recycling  of  plastics  per 
vehicle have been estimated to range between 10.9 and 24.25 € per vehicle, with the higher 
costs  applying  to  alternatives  requiring  generating  larger  amounts  of  recyclates.  As  the 
production of recycled fractions is assumed to allow their sale, it could be expected that such 
sales  would  cover  at  least  part  of  the  costs  of  recycling,  though  this  can  also  fluctuate  in 
corelation to changes in the costs of primary plastics. Of interest is to observe the differences 

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between MS in terms of whether landfilling is still allowed and how this is reflected in taxes 
on waste. Corelation of the higher taxes with advanced PST is assumed to be explained to 
some degree by the expensive landfilling costs of such countries (BE and possibly also NL, 
FR, DE). This suggests that in such countries the additional costs are acceptable or financed 
by EPR in some cases. In particular at times of high competition of the prices of secondary 
plastics with those of primary plastics, it could be that some form of compensations will need 
to be provided by the EPR to ensure that operations remain profitable. 

3.1.9.1.5  Preferred  Scenarios  for  inclusion  in  final  policy 

options 

It is proposed to look at following measures for comparison under the various policy options: 

•  Combination of a recycled content declaration with PST (ban on disposal) 
•  Combination of a recycled content target with a recycling target (30%) in 2030, 
•  Combination  of  a  recycled  content  target  with  a  recycling  target  (40%)  in  2030  –  this 
scenario  could  be  investigated  but  is  considered  too  ambitious  at  this  time.  Perhaps  it 
would be more useful to specify a revise clause to allow an increase in the farer future. 

3.1.9.1.6  Reporting and monitoring requirements 

The  JRC  report  (Maury  et  al.  2022),  details  various  aspects  of  the  monitoring  required  to 
support recycled content targets. The need to develop a standardise calculation for recycling 
content targets and a format for declarations of vehicle manufacturers is elaborated there, 
also explaining what needs may arise for certification through this measure.  

The reporting on a recycling target could be simpler, as is the case today, specifying that all 
fractions sent to recycling must be reported on. This method of calculation does not account 
for material losses and would mean that a higher target is relevant to ensure that the actual 
recycling  achieves  a  minimum  level.  If  the  reporting  is  more  developed,  also  requiring 
reporting of input and output (vehicle sourced) fractions from recyclers, it will result in a higher 
administrative  burden  but  will  allow  specifying  the  target  in  relation  to  the  actual  amount 
recycled. Reporting on a ban of disposal and PST requirements could be done in the same 
way, however here, due to the lack on data on the status of PST among the various MS, it is 
also recommended to require a reporting from MS as to the PST capacities established in 
their  country  (type  of  treatment,  available  capacity  and  amounts  treated  per  annum.  This 
should allow establishing the status of PST and will also enable a more critical review of the 
reporting on vehicle waste treatment by the various MS. 

3.1.10  Analysis for electric and electronic components (EEC) 

Though EEC are a group of components rather than a material, as explained in section 0, 
they  are  quite  intensive  in  various  precious  and  critical  materials.  As  they  are  usually  not 
removed and recycled separately, most of these materials are not recovered in high qualities 
or  at  all,  as  the  sorting  operations  that  follow  the  shredding  of  ELVs  mainly  targets  the 
commodity metals (steel and aluminium and to a lesser degree copper). Thus, with a view of 
increasing the recovery of precious and critical metals, this section focuses on measures that 
could facilitate the reuse and recycling of materials contained in EEC.  

Three measures were shortlisted for electric and electronic components (EEC), including the 
following measures: 

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Title 

2.3.e) Establish provisions to support the market of used EEC 
2.3.f) Set up a separate (monitoring) target for re-use/preparing for re-use/remanufacturing of 
EEC 
2.4.b) Making it mandatory to remove certain EEC before shredding to encourage their recycling 
2.4.d) Regulate shredder/post shredder facilities to improve recovery of precious and critical 
metals contained in EEC  

Chapter 
2.1.5.3.5 
2.1.5.3.6 

2.1.5.4.2 
2.1.5.4.4 

Colour code: Red – discarded, Yellow – premature, Grey – supporting measure 

•  Monitoring of components for reuse/remanufacturing is considered a supporting measure 
(2.3.f)  that  will  need  to  accompany  provisions  designed  to  increase  the  demand  of 
components for reuse/remanufacturing (2.3.e) such as EEC.  

•  A mandatory removal of certain EEC or those above a certain size or weight is of interest 
as  separate  sorting  could  allow  recycling  that  is  more  targeted  towards  the  resources 
contained in such components.  

•  Under the current situation, most EEC is not removed from vehicles by ATFs and is thus 
sent with the hulk to the shredder. As explained in (Restrepo et al. 2017), this results in 
large shares of these elements ending up in the steel and aluminium scrap fraction, in 
shredder residues and in other fractions. The low concentration in such fractions would 
probably render recycling of these elements as non-feasible, i.e., without disrupting the 
recycling of other elements dominant in these fractions (see also (Andersson et al. 2019)). 
Restrepo et al. (2018) refers to scarce technology metals in this respect and explains that 
most are lost after the shredder, either remaining as tramp metals in industrial base metals 
(Fe, Cu and Al) or being directed to the shredder light fraction. In parallel in this study, 
requiring post shredder treatment to improve the recycling of copper is being investigated 
(see analysis under section 3.1.6). Possibly, elements that associate to the copper in the 
shredded  fractions  could  be  recovered  to  some  degree  through  this  measure. 
Nonetheless, it is understood that to further facilitate the removal of copper from steel, it 
will  likely  be  beneficial  to  dismantle  certain  copper  containing  electronic  components 
anyway.  With  the  understanding  that  EEC  dismantling  obligations  will  probably  not 
address  all  EEC  but  rather  a  sub-set, this measure for  copper may  be  useful  to target 
EEC that is shredded. It is however not analysed here again to avoid double counting with 
the  measure  being  investigated  in  the  copper  analysis.  A  measure  requiring  PST  and 
targeted only at specific precious and CRM is not considered to be feasible. 

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3.1.10.1.1  Scenarios for quantitative analysis  

Various resources are contained in EEC, including valuable metals like copper, gold, PGMs, 
(e.g., for conductivity), nickel and chromium (in coatings), aluminium for heat (dissipation), 
lead, silver, tin and other materials used in solders and electrical contacts. Other resources 
that  can  be  included  in  such  components  include  antimony,  bismuth,  cobalt,  fluorite, 
magnesium,  silicon  and  others.  Some  of these  are  included  in  the  2020 CRM  list, making 
them of interest for recycling. However, these valuable materials are strongly intertwined with 
other  vehicle  components.  After  shredding,  their  non-metallurgical  separation  from  other 
recyclables and from shredding residue is usually not economically viable, since the CRM are 
mixed with bulk material during shredding.  

3.1.10.1.1.1  Baseline 

Various  studies  name  a  large  variety  of  different  EEC  that  are  included  in  vehicles.  Main 
components include the following (additional detail can be found in annex 6.3.1.2): 

Restrepo et al. (2018) refers to: 

•  components  that  contain  REE  include:  ABS  Block,  alternator,  starter,  window  raising 
motor (front and rear), radiator fan motor, wind wiper motor (front and rear) (Restrepo et 
al. 2017) 

•  components  that  contain  other  CRM  include:  airbag  controller,  engine  controller, 
multifunctional display, navigation system GPS, radio CD, speedometer (Restrepo et al. 
2017) 

Groke  et  al.  (2017)  refers  to  the  following  (a  list  with  the  30  most  relevant  components  in 
terms of CRM content is reproduced in Annex 6.3.1.2): 

•  magnets as the most important applications for rare earth oxides, assuming 20 motors as 
the average number of electric motors in a vehicle and a total amount of neodymium of 
28-297  g:  electric  motor,  compressors  in  hybrid  vehicles,  circuits,  power  transference, 
braking, loudspeaker, theft protection, doors and control units. According to a JRC report 
from 2021, new investigations suggest that the content per vehicle is closer to the bottom 
range. According to the study: The Nd content, was estimated at 107 g per vehicle based 
on  a  2015  vehicle  in  the  PROSUM  project,  with  all  characteristics  unknown,  but  new 
investigations allowed the JRC to recently estimate 44 g (Løvik et al. 2021). 

•  printed wire boards are mentioned, referring to control devices which supervise the power 
transmission, braking, car body functions, air bag systems and other systems (between 
9-100 different components are mentioned by different sources) and to distributors. The 
highest  number  of  precious metals  are  said to  be found  within the  control  units  for  the 
engine  and  infotainment,  display  and  control  unit,  control  panel,  airbag  control  and 
auxiliary stop light. 

•  LCDs  and  LED  displays  are  said  to  contain  indium  tin  oxide,  yttrium,  europium, 
lanthanum, cerium, terbium and gadolinium with an amount of some milligram per cm2 
screen  surface,  for  example  in  the  navigation  system  in  the  central  console  and  in 
infotainment. 

•  Sensors  for  measuring  various  physical  states  are  also  reported,  referring  to  magnet 
sensors  (neodymium  or  ferrite),  oxygen  sensors  (platinum  or  palladium,  yttrium,  e.g., 
lambda  sensor),  radar  controls  (gallium  or  germanium)  and  temperature  sensors  (e.g. 
silver) as the most relevant sensor applications. 

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Arnold et al. (2021) conducted a study on the economic feasibility of manually dismantling 
electronic  components  from  end-of-life  vehicles  for  the  recycling  of  valuable  metals.  It  is 
explained that in countries with higher labour costs and at current raw material prices, only a 
few components, such as inverter for hybrid vehicles, oxygen sensor, side assistant sensor, 
distance and near distance sensors are beneficial to be manually removed from ELV. On this 
basis it is hard to say if these components will be dismantled or not as it can be understood 
from the literature that EEC is generally not dismantled with a view to recycle it separately 
from other vehicle parts.  

Rather in the baseline it is assumed that EEC are dismantled when reuse is relevant. Where 
the  component  is  finally  not  sold  for  reuse  or  where  it  is  damaged  during  dismantling, 
components  already  dismantled  would  be  assumed  to  be  sent  to  separate  recycling  (e.g., 
through copper smelters). Thus, in the baseline, most EEC is assumed to be directed to the 
shredder together with the hulk as explained under section 0. As EEC contain many valuable 
and critical metals, this results in the loss of most of these materials that end up in various 
fractions after the shredder and are usually not recovered thereafter. 

Restrepo  et  al.  (2017)  calculated  for  average  new  vehicles  (cohort  2014)  a  total  mass  of 
critical  metals  (originally  referred  to  as  CM  but  here  as  CRM)  in  EE  devices  per  average 
vehicle as follows: Ag: 1g, Au: 0,3g, Pd: 0,06, Ru: 0,001g, Dy: 5g, La: 40g, Nd: 40g, and Co: 
50g. Thereby, the precious metals are located in the PWB, while the rare earths and Co are 
contained in the actuators in form of permanent magnets. Actuators also contain steel and 
copper. Quantities vary depending on the size of the components. During the combined ELV 
dismantling,  depollution,  shredding  and  separation  processes,  these  critical  metals  are 
transferred to the output fractions in the following proportions compared to the extrapolated 
content in ELV (based on the Median measurements of 100 000 shredded ELV). Restrepo et 
al. (2017) notes for the data presented in the table that that the calculated transfer coefficients 
between the input flow of CRM into the ELV shredding and the extrapolated output flow as 
part of the different shredding fractions (Fe and Al scrap, shredder residues, other) do not 
match  for  almost  all  CRM  types  considered.  Restrepo  et  al  (2017)  assume  that  the  mass 
balance is influenced by CRM, contained in non-EEC in ELVEE components of ELV. In other 
words where for example for one of these fractions more than 100% is specified is understood 
to mean that there are other inputs to the total amount beyond the amount assumed to be in 
the investigated vehicle EEC.  

Table 3-49 Fate of critical metals during ELV waste management 

Element 
(100%) 

in  vehicle 

Share that ends up in 
Fe&Al scrap     

Share that ends up in 
shredder Residue 

Other 

Ag 
Au 
Pd 
Ru 
Dy 
La 
Nd 
Co 

40% 
1.9% 
0.7% 
>100% 
0% 
0.5% 
5% 
>100% 

>100% 
88% 
>100% 
>100% 
80% 
2.3% 
46% 
29% 

>100% 
25% 
>100% 
>100% 
10% 
0.3% 
3% 
4% 

Source: (Restrepo et al. 2017)  

From the above table it can be concluded that where EEC is not removed prior to shredding, 
that a large share of the above elements will land in steel scrap, aluminium scrap, shredder 
residues and other fractions where according to explanations (see 0 as well as (Andersson 
et al. 2019)) the amounts are too low to render separation and recycling economically and 
sometimes also technically feasible.  

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For  further  data  on  CRM  and  precious  metal  content  of  specific  components  see  annex 
6.3.1.2. 

3.1.10.1.1.2  Scenario EEC 1: Monitoring of EEC components for reuse/remanufacturing 

This scenario aims to support reuse/remanufacturing of used ELV components by introducing 
a list of components recommended for reuse/remanufacturing (Annex to ELVD). A preliminary 
list prepared in this report contains various components with a potential for reuse and it is 
considered whether to add EEC to this list.  

This  scenario  also  considers  implementation  of  harmonised  monitoring  of  EEC  that  have 
been removed for reuse/remanufacturing to understand the actual volume of reuse in different 
MS and to enable the comparability of monitoring data. Obtained information will allow a better 
understanding  of  the  potential  for  reuse  and  how  it  is  influenced  by  measures  that  affect 
market demand. It will also help in the future in the revision of the list of removed spare parts 
as well as to potentially set out the targets. The reporting obligation would be limited to the 
components  listed  in  the  Annex  to  ELVD  (“list  of  components  recommended  for 
reuse/remanufacturing”).  However,  separate 
for 
reuse/remanufacturing  could  also  be required though  it may  create  a  burden for  ATFs  if  it 
cannot be linked to an existing list of sales. 

reporting  on  components  sold 

3.1.10.1.1.3  Scenario EEC 2: market support of used EEC spare parts  

Under this scenario the market demand for spare parts, in this case EEC, should be regulated 
by  requiring  car  repair  shops  to  provide  customers  with  an  offer  to  repair  a  vehicle  with 
used/remanufactured  components  alongside  offers  for  repair  with  new  components. 
Insurance companies will also be obliged to offer car owners discounted policies if they agree 
that  repairs  are  performed  with  reused/remanufactured  parts  when  these  are  available. 
Furthermore, a ban of the online sales of illegally operating facilities would be introduced.  

Obligations for insurance companies may only be implementable through national legislation, 
possibly affecting their feasibility as a measure in future ELV legislation.  

3.1.10.1.1.4  Scenario EEC 3: Obligatory dismantling and separate recycling of EEC  

Under this scenario it shall be required to dismantle EEC for reuse or for separate recycling 
to avoid shredding operations that hinder recovery of contained resources. A threshold weight 
or size could be considered for this purpose. In particular it is recommended to align the ELV 
with the current WEEE Directive depollution requirements to dismantle and separately treat 
PWB  with  a  surface  area  greater  than  10  square  centimetres.  Regarding  the  possible 
dismantling of displays, considered to at least be relevant for dismantling when containing 
PWB  as  described  above,  other treatment  requirements for  e.g.,  WEEE displays  specified 
under CENELEC standard EN 50625-2-2s-Displays, are mainly focused on the depollution 
and  recovery  of  mercury  from  backlighting  discharge  lamps  of  flat  panel  displays  and  of 
fluorescent powders and lead oxide from cathode ray tube (CRT) displays. CRT displays are 
not expected to be of relevance for vehicles. As for mercury containing flat panel displays, 
such  displays  would  already  need  to  be  dismantled  to  remove  mercury  containing 
components as required in ELVD Annex II (3) and in any case are not expected to have high 
relevance  as  they  were  phased  out  in  vehicles  type  approved  from  July  2012  and  on273. 
Similarly, CENELEC standard EN-50625-2-4 which specifies how WEEE photovoltaic panels 
are  to  be  treated  at  EoL  could  be  considered  as  relevant  for  PV  contained  in  ELV.  Such 

273 According to remaining exemptions for mercury in vehicles, i.e., exemptions 15a and 15b of Annex II of the ELVD, which is 
by now only applicable to spare parts of older vehicles. 

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components  are  currently  not  expected  to  be  contained  in  ELV  (at  least  not  in  significant 
amounts)  but  could  become  more  relevant  in  the  future  should  they  be  included  in  new 
models. For WEEE, dismantling and sorting according to PV technology is required for PV 
that fall in the scope of the above standard, i.e., with a surface area of 0.2 square meters. 
Whether PV above this size threshold are to be integrated into vehicles in the future remains 
to be seen, however in such cases, this threshold could be applied, requiring dismantling and 
separate treatment according to WEEE requirements. Whether it is necessary to require the 
same  treatment  as  similar  components  removed  from WEEE  has  not  been  investigated  in 
detail, however it stands to reason that if there is a requirement to dismantle and treat these 
parts separately, that they would often be sent to treatment by the operators that treat similar 
WEEE components. 

Additionally, the following components are recommended for obligatory dismantling, based 
on studies already performed with a similar focus: 

The  UBA  ORKAM report  (Groke  et  al.  2017)  investigated the  profitability  of  dismantling  of 
certain electrical components due to their contents of valuable resources. the study refers to 
the  heating  fan  and  generator  (in  the  group  of  engine  components),  the  engine/gear 
control unit, inverter, drive control unit, start-stop-control unit (in the group of controller 
components), and the oxygen sensor (in the sensor component group) as components for 
which  dismantling  is  economically  profitable,  however  they  are  understood  to  not  be 
commonly removed prior to shredding operations. The alternator and transmission control 
unit are also mentioned. 

Arnold et al. (2021) concluded that even in countries with high labour costs it is economically 
feasible to dismantle the inverter for hybrid vehicles, oxygen sensor, side assistant sensor, 
distance  and  near  distance  sensors.  Dismantling  can  also  be  cost-effective  for  other 
components,  depending  on  the  vehicle  model,  labour  costs  and  current  material  prices, 
referring  to  the  heating  blower,  generator,  starter,  engine  and  transmission  control, 
start/stop motor, drive control, infotainment and chassis control. 

Restrepo et al. (2018) refer additionally to the following components and calculate that ca. 
190 minutes would be needed to dismantle these:  

•  ABS Block, alternator, starter, window raising motor (front and rear), radiator fan motor, 

wind wiper motor (front and rear) - REE relevant 

•  airbag controller, engine controller, multifunctional display, navigation system GPS, radio 

CD, speedometer – relevant for other CRM. 

Components for which dismantling is understood to be economically feasible appear in bold. 
Components for where feasibility is marginal (e.g., in countries with high labour costs) appear 
in bold and italics. 

The Swiss Institute EMPA, behind Restrepo et al. (2017) and Restrepo et al. (2018) is still 
researching options for obligatory dismantling for the Swiss Government. This is related to 
the  SWISS  VREG274  legislation  published  in  January  2022,  according  to  which  EEC 
permanently installed in vehicles are in the scope of the regulation if they can be dismantled 
and  if  their  treatment,  to  allow  material  recovery,  is  feasible  according  to  scientific  and 
technical progress (VREG Article 2(2)). The EMPA research is to contribute to decisions of 
the Swiss government as to which sub-set of EEC will be affected by obligatory dismantling 
and treatment requirements of the VREG. Publication of more recent results is still pending 
but anticipated for the beginning of 2023. Preliminary results were not available; however it 

274 Regulation on the collection and treatment of WEEE – Verordnung über die Rückgabe, die Rücknahme und die Entsorgung 
elektrischer und elektronischer Geräte, see https://www.fedlex.admin.ch/eli/cc/2021/633/de, last viewed 21.8.2022 

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is recommended to consider the final results and how Switzerland shall set the dismantling 
obligation as a source to align to regarding the final list of components to be in the scope of 
a dismantling obligation. 

To understand the economic feasibility of dismantling EEC components from vehicles for the 
purpose  of  reuse and  recycling,  Groke  et  al. (2017)  compared  costs  and  benefits  of three 
courses of action: Reprocessing of reusable parts, separate recycling of vehicle electronics 
and shredding of end-of-life vehicles. The reuse of ELV vehicle parts (with the exception of 
the  lambda  sensor)  shows  a  higher  revenue  than  recycling,  while  the  economic  benefit  of 
secondary materials recovered from separately recycled EEC still shows a positive balance. 
Shredding,  on  the  other  hand,  was  rated  as  the  least  economically  attractive.  Against  the 
background  of  the  results  of  the  economic  assessment,  Groke  et  al.  (2017)  recommend 
dismantling individual EE components from ELV. Separate dismantling is recommended for 
the following parts: Heating fan, alternator, inverter, engine control unit, transmission control 
unit,  drive  control  unit,  start/stop  engine  and  oxygen  sensor.  For  nine  other  components, 
separate recycling also appears to make sense, but a clear recommendation for or against 
dismantling cannot be given, as the economic viability of dismantling depends heavily on the 
boundary conditions. 

Opportunities to increase economic efficiency of separate recycling of embedded automotive 
electronics are mentioned as follows: 

•  Accelerate  dismantling  through  qualified  mechanics  that  are  provided  with  appropriate 

tools, 

•  Well organised procedures and in-house logistics, and  
•  Access  to  sufficient  sources  of  information  on  vehicle  electronics,  vehicle  design,  and 

markets to market the components (e.g., via product passport)  

Arnold et al. (2021) conducted a study on the economic feasibility of manually dismantling 
electronic  components  from  end-of-life  vehicles  for  the  recycling  of  valuable  metals.  They 
conclude that disassembly is economically viable only if disassembly can be accomplished in 
less than or equal to 2 minutes per part, since the revenue from the recovered material is 
small.  In  countries  with  higher  labour  costs  and  at  current  raw  material  prices,  only  a  few 
components,  such  as  inverter  for  hybrid  vehicles,  oxygen  sensor,  side  assistant  sensor, 
distance and near distance sensors are beneficial to be manually removed from ELV. Manual 
disassembly  can  also  be  cost-effective  for  other  components,  depending  on  the  vehicle 
model, labour costs and current material prices. These components include heating blower, 
generator,  starter,  engine  and  transmission  control,  start/stop  motor,  drive  control, 
infotainment  and  chassis  control.  For most  components  however, the  profit margin  is  very 
small. 

3.1.10.1.2  Results of qualitative analysis  

Though scenario EEC 1 shall help get a better understanding of the type of EEC that have 
potential for reuse, it is not expected to increase the rate of reuse significantly as it is mainly 
proposed as a monitoring measure.  

Scenario  EEC  2  would  be  expected  to  have  a  higher  contribution  to  the  reuse  of  such 
components,  possibly  increasing  recycling,  though  it  is  unclear  if  ATFs  would  send  such 
components  to  separate  recycling  as  their  removal  is  understood  not  to  be  common  and 
shipping  for  recycling  would  require  a  sufficient  amount  of  removed  components  to  justify 
transport costs. 

Scenario  EEC  3  is  expected  to  have  the  highest  contribution  to  both  reuse  and  separate 
recycling as it shall increase the amounts of EEC dismantled and subsequently accelerate 

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the  collection  of  sufficient  amounts  for  transport.  Separate  recycling  is  understood  to  be 
common  for  e.g.,  printed  circuit  boards  removed  from  electric  and  electronic  equipment275 
and  thus  it  is  assumed  that  at  least  part  of  this  fraction  would  have  a  recycling  outlet, 
increasing the probability of recycling precious metals from such components.  

For example, Umicore recycle printed circuit boards (also known as printed wiring boards) 
among others as a source of precious metals. Their plant is understood to also accept PCBs 
from automotive applications, though this is mainly relevant for dismantled separate fractions 
and not shredder non-ferrous fractions from PST due to their lower quality. Among others, 
the following materials can be recovered in this way: silver, gold, PGMs, but also other metals 
like lead, copper, nickel, antimony, tin, indium, bismuth, etc. It is further explained that the 
direct smelter routes (i.e., sending components directly to material recovery in smelters) have 
been  found  to  be  an  eco-efficient  solution  for  some  electronics  containing  PWBs  like  cell-
phones (Hagelüken 2006a). Hagelüken (2006b) explains this further: “In the case of circuit 
boards  or  small  devices  with  a  relatively  high  concentration  of  precious  metals,  further 
shredding and sorting out Fe, Al and plastics in many cases even can be counter-productive. 
In circuit boards most precious metals are strongly interlinked with plastics or non-ferrous-
metals, part of them easily go into dusts, others follow the iron-fraction and the aluminium. 
Especially  eddy  current separation  in  many cases  is  not  sharp  enough for these materials 
and significant portions of circuit board pieces can be contained in the “Al-fraction”. Optical 
sorting or other scavenging processes can be applied”. However, the direct treatment of (i.e., 
dismantled)  circuit  boards  in  an  efficient  metallurgical  process,  designed  to  maximise 
precious  metal-yields  and  to  “co-separate”  other  metals  by  metallurgical  means  is  more 
productive. This is explained for PWB of EEC origin but is also assumed to be the case for 
PWBs from vehicle origin, i.e., when these are dismantled and treated as a separate fraction. 

3.1.10.1.3  Results of quantitative analysis  

To  understand  the  potential  of  measures  for  EEC  it  is  first  important  to  understand  how 
common they are in vehicles. Some data on this is already presented above in section 0 and 
at the beginning of this chapter. For the most part this data clarifies that it is difficult to provide 
an exhaustive list of EEC contained in vehicles and to refer to their total weight in the vehicle 
and  relevance  in  terms of  contents  of  precious and  CRM.  Work  of  EMPA  (Restrepo  et  al. 
2018) is summarised below to provide partial quantification for a sub-set of components that 
were  investigated  by  EMPA  in  various  studies. In  addition,  the  example  of  an  inverter  has 
been  developed  on  the component  level  to  provide  some  insight  as  to relevant  impacts  of 
components  that  have  been  recommended  in  various  studies  for  dismantling  and  that  are 
also relevant for new types of vehicles. Initial data on the inverter is specified in this section 
and analysed impacts are presented in the following sections. 

Restrepo et al. (2018) looked at the number and type of embedded electronics in the Swiss 
vehicle fleet in 2014. They concluded at the time that on average, in 2014, ELVs contained 8 
EEC  components,  the  average  vehicle  in  the  stock  contained  20  components  and  newly 
imported vehicles contained 21 components. For the various components the distribution of 
critical  metal  mass  in  passenger  vehicles  was  also  investigated,  a  summary  of  which  is 
compiled in the following table. 

275 For example, Umicore accepts printed circuit boards from EEE in shipments above 10 tonnes. Shredded fractions with 

printed circuit boards are also accepted, but only from mechanical pre-processing of e-scrap and in quantities between 25-100 

tonnes. See: https://pmr.umicore.com/en/recyclables/e-scrap/, last viewed 27.6.2022 

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Table 3-50 Distribution of critical metal mass in passenger vehicles in the Swiss 
vehicle fleet in 2014 - Total mass per average vehicle in gram 

Elements 
in 
vehicles  

Average  content  of  a 
vehicle imported in 2014 

Average  content  of  a 
vehicle in the 2014 stock 
as 
- 
vehicle 
the 
representative  of 
average  

2010 

Average  content  of  a 
vehicle  that  becomes  an 
ELV in 2014, represented 
by  average  content  of  a 
vehicle form 2000     

Ag 
Au 
Pd 
Ru 
Dy 
La 
Nd 
CO 

1 
0.3 
0.06 
0.001 
5 
40 
40 
50 

1 
0.3 
0.06 
0.001 
2 
30 
20 
30 

1 
0.2 
0.03 
0.001 
0.1 
30 
3 
20 

Note: The large differences between amounts for new imports and for ELV can be accounted for to 50% due to the larger 
number of vehicles imported in 2014 as compared to ELVs in the fleet and to 50% due to the increase of the amounts of the 
various elements in a single vehicle, through a larger number of embedded electric components and larger amount of the 
elements contained therein.  

Source: (Restrepo et al. 2018) 

To  understand  the  current  rate  of  EEC  dismantled  from  vehicles,  Restrepo  et  al.  (2018) 
compiled data on dismantled components (it is not specifically mentioned but assumed that 
most EEC that are mentioned here and the relevant rates are dismantled for the purpose of 
reuse. In such cases it is further assumed that some components will end up being reused 
and some may be sent to separate recycling). The rate was calculated based on the relation 
between  the  number  of  dismantled  EEC  and  the  total  number  of  embedded  ones.  The 
researchers  noticed  that  EEC  were  more  often  dismantled  from  the  upper-class  vehicles 
(luxurious) than from standard ones. In other words, vehicle class was a better indicator for 
the dismantling probability than the dismantling time and costs. Additionally, EEC with electric 
motors have a higher dismantling rate than EEC with printed circuit boards (PWBs). Aside 
from four electric motors (sunroof motor, hydraulic power steering motor, air-conditioning fan 
motor,  and  alternator),  most  EEC  devices  had  a  disassembly  rate  below  50%.  Thus,  the 
potential for concentration of permanent magnets for later recovery of REE is smaller than 
that of PWBs for later recovery of precious metals. Reuse rates of different components are 
specified in the following figure: 

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Figure 3-17  dismantling rates for vehicle EEC 

Source: (Restrepo et al. 2018) 

On the basis of this data and additional research, a sub-set of components was selected for 
further  investigation  of  12  EEC.  The  choice  of  these  components  was  made  against  the 
understanding that 80% of the precious metals and REE mass in EEC of ELVs from the year 
2000 are found in the selected focus devices (6 ICT devices and 6 actuators). Results for 
these  12  components  (and  their  identification)  are  presented  in  the  following  chapters  to 
provide more insight as to the type of EEC for which dismantling is under consideration. 

The inverter has been selected for analysing the potential of the scenarios described above, 
as  it  contains  valuable  materials  in  its  housing and  components.  The  UBA  ORKAM  report 
(Groke  et  al.  2017)  gives  an  example  composition  from  a  4X4  hybrid  vehicle  in  which  the 
inverter has a total weight of 12 kg and contains the following materials. Such components 
are also understood to be used in BEV.  

Table 3-51 Materials contained in an inverter and they relative weight in kg/unit 

Total mass 
(g) 

13,550 

Printed 
circuit 
board (g)* 
364 

Fe (g) 

Al (g) 

Cu (g) 

Plastic (g)  Brass (g) 

2,107 

7,900 

1,077 

341 

84 

Source: compiled from: (Groke et al. 2017), *the PWB is specified to contain amounts of gold, palladium, silver, copper and tin  

The ORKAM study refers to a dismantling time of around 3 minutes for the inverter, however 
this  was  derived  together  with  dismantling  of  additional  components  and  may  be  an 
underestimation when not all other components are removed. A dismantling cost of approx. 
2.20 €/unit was estimated for the ATF, as well as a revenue from sales of the component of 
approx. 12.20 €/unit or of material sales of approx. 10.35 €/unit (Groke et al. 2017). 

The following shares of dismantling (reuse, pre- and post-shredder recycling), post shredder 
recycling, recovery and losses were assumed for calculating the impacts of the inverter. For 
the Restrepo et al. (2018) sub-set of EEC, impacts are mainly based on those presented in 
the source, however in some cases the following shares were also used to calculate additional 
impacts for this case (e.g., dismantling costs and related social impacts). 

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To consider the initial dismantling rate for the shares, the dismantling rates displayed under 
Figure  3-17  have  been  considered.  The  calculated  average  of  the  rates  displayed  for  30 
components returned 25.7 % dismantling, however it can also be understood that this list only 
reflects a sub-set and some components listed may be found in a vehicle more than once 
(e.g.,  exterior  lighting,  power  mirrors).  Furthermore,  it  is  explained  that  higher  dismantling 
rates were apparent for EEC sourced from vehicles in the upper-class range. Such vehicles 
are expected to be more common in Switzerland than in various EU countries, and as such, 
this  average  is  assumed  to  be  too  high  for  the  EU.  With  no  other  data  to  suggest  an 
appropriate level, an initial rate of 15% dismantling has been assumed for the baseline as a 
conservative assumption. The final rate of reuse assumed to be achieved under scenario 2 
is also considered to be conservative, due to the expectancy of an older fleet on average in 
EU countries. The allocation of all parts dismantled from the vehicle between the reuse and 
the recycling routes has been assumed according to a 2:1 relation, as in the baseline and the 
first two scenarios, dismantling is motivated by reuse. The increase of the total dismantling in 
scenario 3 is a result of the obligation to dismantle for the sake of recycling, thus here the 
share  of  components  dismantled for  separate recycling  is  significantly  higher.  The  level  of 
reuse is assumed not to be affected in this scenario as the potential for reuse is expected to 
be exhausted in the earlier scenarios, in particular scenario 2 which refers to measures to 
support the market for reused parts. In other words, the additional dismantling in this case is 
assumed to feed the separate recycling of EEC that has not undergone shredding operations. 
Under  this  scenario,  it  is  probable  that  some  EEC  affected  by  the  measure  would  be 
dismantled in a destructive way, i.e., vehicles for which demand for reused parts is negligible 
e.g., due to vehicle age. This could impact the costs for dismantling and will be reflected in 
the next sections where relevant. Recycling after shredder operations would in most cases 
mean that precious and CRM are lost to other fractions (e.g., impurities in steel and aluminium 
fractions or in ASR fractions. Thus, the assumptions for recovery and for losses are relatively 
low. Reduced losses are assumed for scenario 2, where dismantling results in recycling prior 
to shredder, where recovery of precious and CRM has a higher probability of being sought. 

Table 3-52 Routes of treatment for EEC from ELVs under the various scenarios  

EEC 

Baseline 

Scenario 
1 

Scenario 
2 

Scenario 3 

Dismantled -> 
reused/remanufactured 
Dismantled -> recycled (no 
shredding) 
Dismantled -> shredded -
>recycled 
Shredded -> recycled 

Recovered: (energy recovery or 
backfilling)  
Losses/process inefficiencies 

10% 

12% 

5% 

0% 

77% 

3% 

5% 

6% 

0% 

74% 

3% 

5% 

25% 

12% 

0% 

55% 

3% 

5% 

25% 

70% 

0% 

0% 

3% 

2% 

Source: Oeko-Institut: own assumptions based on available data. 

3.1.10.1.3.1  Environmental impacts 

To  estimate  the  effort  of  dismantling  certain  EEC  and  related  impacts,  in  Restrepo  et  al. 
(2018)  a  list  of  12  (or  14  when  front  and  rear  components  are  considered  as  separate 
components))  EEC  was  identified  and  subject  to  field  testing  to  determine  among  others 
average  dismantling  times  of  each  component  and  the  total  dismantling  time  for  this  EEC 
sub-set.  The  following  table  is  reproduced  from  the  report  and  presents  the  sub-set  of 
components, the dismantling times for each component and for the total. 188 minutes or 3.13 
hours were necessary in total, amounting to almost 3 hours. From a personal communication 
with members of the study team, this is representative for conservative dismantling that would 

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still  allow  reuse  of  parts  and  is  thus  assumed  to  be  more  time  intensive  than  destructive 
dismantling.  Results  also  take  into  consideration  the  situation  in  Switzerland  which  is  a 
relatively small country in terms of distances to relevant treatment facilities for EEC. In short, 
whether average costs would be higher or lower in the EU depends on the average distances 
between facilities as well as on how many of the EEC would be dismantled conservatively 
(related  to  age  and  class  of  average  vehicles)  and  how  much  would  be  dismantled 
destructively.  

Table 3-53 Average dismantling time of the EEC in minutes for the specified EEC  

Note 1: the tale refers to the average time and to the estimated average time. According to the source, where data was 
available, estimations were made as to the time needed for dismantling (estimated average time). However most of the results 
presented were determined in dismantling tests which usually showed that the actual dismantling time (here referred to as 
average time) is lower than the value assumed based on literature. 

Note 2: Translation of EEC, according to order: Devices containing REE: ABS Block, alternator, starter, window raising motor 
(front and rear), radiator fan motor, wind wiper motor (front and rear). Devices containing precious metals: airbag controller, 
engine controller, multifunctional display, navigation system GPS, radio CD, speedometer.  

Source: (Restrepo et al. 2018) 

The same sub-set of components was analysed by Restrepo et al. (2018) on the basis of LCA 
data  to  quantify  the  environmental  impacts  of  various  treatment  scenarios.  Aside  from  the 
baseline, advanced shredding was compared (resulting in smaller pieces being sorted and 
sent to further treatment) as well as two options for dismantling (combined with automated or 
manual sorting prior to recovery with EEE waste). It is noted that the data applied has various 
uncertainties  and  also  is  not  representative  of  EEC  relevant  for  EVs  as  at  the  time  of  the 
analysis such vehicles were very rare in the stock. Whereas the advanced shredding showed 
a reduction of 9% environmental impacts as compared to the baseline, dismantling scenarios 
showed a reduction of 49% and 120%276 respectively. See Figure below. This shows that the 
further improvements of PST (as is contemplated for the copper fraction) can be expected to 
lead  to marginal  improvements  in  terms  of  environmental  impacts,  whereas  dismantling  in 
both cases leads to significant reductions.  

276 The comparison is made between the Net benefit that reflects both negative and positive impacts. This comparison results 
in the last scenario reflecting an improvement of 120%.  

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Figure 3-18  Environmental impacts of the four scenarios, in thousands of UBP (eco-
points according to method of ecological scarcity, contribution per process 

Note: The scenarios investigated are Baseline (0), treatment of shredded fractions in advanced PST facility (1), Dismantling of 
EEC and separate mechanical treatment at a WEEE treatment facility (3) and dismantling of EEC and manual disassembly 
(e.g., of PWBs and permanent magnets) prior to separate treatment. 

Source: (Restrepo et al. 2018) 

Restrepo  et  al.  (2018)  does  not  specify  absolute  impacts  but  only  the  relation  between 
scenarios. In this sense, the impact is understood to refer to the impact for the same number 
of components dismantled as compared to not dismantled. This study however assumes a 
mix in most of the scenarios. Though the environmental impacts cannot be quantified based 
on  the  available  data,  however  the  consultants  assume  that  on  this  basis  the  reduction  in 
environmental impacts in a range of 49-120% is representative for the comparison between 
scenario 3 (where all components are dismantled) and the baseline of this study, depending 
on whether only dismantling would be required or also further manual sorting of disassembled 
parts. For other scenarios the environmental impact of dismantling is expected to be in the 
range between the baseline and scenario 3. 

Restrepo et al. (2018) explain that the maximum environmental savings are achieved through 
the dismantling and recycling of relatively heavy actuators such as generators, cooling fan 
motors and starters. Savings from the dismantling and recycling of ICT devices (Information 
Communication and Control devices) are lower than for actuators. This is mainly due to the 
lower mass of ICT devices - on average 1.2 kg compared to 3 kg for actuators. The greatest 
savings for the control units are achieved by dismantling and recycling relatively heavy control 
units such as the navigation system and ICE/EM controls. With increasing electrification and 
automation of the vehicle fleet, an increase in heavy power electronics is foreseeable and 
with it, possibly, also an increase of the Scarce Technology Metals (STM) mass. Interestingly, 
the  savings  in  environmental  impacts  from  STM  recovery  measures  are  mainly  due  to the 
recovery of the base metals, mainly copper, iron (i.e., steel) and aluminium. The recovery of 
precious metals, especially Au, contributes significantly to the environmental impact of ICT 
equipment. For example, a navigation system contains about 800 times more copper than 
gold, but the environmental impact from the primary production of 1 kg of gold is 1000 times 
higher  than  from  the  primary  production  of  1  kg  of  copper,  explaining  why  gold  makes  an 
important contribution to the overall savings from the recycling of navigation systems. The 

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recycling  of  REE  in  EEC  only  contributes  to  minor  reductions,  as  the  impacts  of  primary 
production of precious metals are low. For example, an alternator contains about 900 times 
more copper than neodymium, but both metals cause comparable environmental impacts in 
their primary production. Thus, the environmental savings from the recovery of neodymium 
are small compared to the recovery of copper (and other base metals). From these results it 
could be concluded that only actuators should be dismantled before shredding. However, this 
would lead to high losses of STMs from ICT devices, which usually end up in post shredder 
fractions  from  which  they  cannot  (be)  recovered.  However,  if  the  goal  is  to  maximize  the 
recovery of STMs (rather than the total environmental benefit), then the actual quantities of 
STMs recovered per device should also be considered in the prioritization process and not 
just the environmental impact savings. Though not mentioned by Restrepo et al. (2018), this 
could be the case for CRMs for which there is a supply risk that is mainly an economic risk. 
In such cases, the economic risk is to be considered to conclude whether the cost of recovery 
through dismantling is set-off by the respective decrease in the supply risk.  

To  summarise,  for  the  sub-set  of  components,  a  positive  environmental  impact  can  be 
concluded for all of the scenarios in relation to the baseline, due to higher dismantling and 
subsequently  higher  reuse  and  high-quality  recycling  rates.  However,  it  is  not  possible  to 
assume  what  amounts  of materials  would  be  recovered  in  each  case.  The  Restrepo  et  al. 
(2018)  data  suggest  that  in  terms  of  recovered  material,  this  would  mainly  be  reflected  in 
increased recovery of the base metals (steel, aluminium, copper) and of precious and CRM 
contained in PWBs that can be recovered in separate recycling – for example silver, gold, 
PGMs,  but  also  other  metals  like  lead,  copper,  nickel,  antimony,  tin,  indium,  bismuth  are 
mentioned  for  separate  recycling  of  PWBs  (Hagelüken  2006a).  REE  are  understood  to 
currently not be expected in terms of recovered elements. This is understood to be based on 
the  technologies  currently  applied.  The  consultants  are  aware  that  recycling  of  REE  from 
magnets is possible and practiced in Asia to some degree, however that capacities do not 
exist in the EU and that currently magnets are not dismantled for this purpose. As explained 
above, this  is  not  understood to  have  a  significant  environmental  impact,  however,  should 
there be economical reasons to collect and recycle magnets separately (to be investigated in 
a  follow  up  study),  this  could  be  addressed  through  a  requirement  to  disassemble  REE 
containing magnets from relevant components (e.g., permanent magnets, actuators) though 
only expected to impact environmental impacts marginally. 

For  the  inverter,  based  on  this  description  and  the  shares  specified  in  Table  3-52  in  the 
baseline and in each scenario, the number of inverters for each route of the different scenarios 
was calculated based on the number of EV vehicles to be collected as ELVs in 2035. This 
allowed calculating the mass flows diverted in each scenario to the various treatment routes 
based on the BEV ELVs collected in the year 2035 (Figure 3-19).  

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Figure 3-19  Mass flows for scenarios for inverters sent to different treatment routes 
(tonnes) 

Inverters from ELVs in the EU: Mass by recycling option

s
n
o
t

14000

12000

10000

8000

6000

4000

2000

0

Baseline

Scenario 1

Scenario 2

Scenario 3

Dismantled -> reused/remanufactured

Dismantled -> recycled (no shredding)

Shredded -> recycled

Recovered (energy recovery or backfilling)

Losses/process inefficiencies

Source: own illustration 

The inverter flows that are sent to reuse are considered to have the highest contribution in 
terms of circularity. For inverter sent to recycling, these are assumed to enable recycling of 
contained precious metals as well as having a contribution to copper recycling and related 
impacts  on  the  purity  of  the  Al  and  FE  scrap  fractions.  In  contrast,  for  inverters  sent  to 
shredder, though the base materials (Fe and Al and to a lesser degree also copper) could be 
recovered, it is assumed that precious metals would be lost as impurities in Fe and Al or in 
shredder residues. General flows can be observed in the table below: 

Table 3-54 Tonnes of inverters from collected ELVs assumed to be either reused or 
recycled or sent with hulks to the shredder (in 2035) 

Inverter 

Baseline 

Scenario 1 

Scenario 2 

Scenario 3 

Dismantled -> reused/remanufactured 

Dismantled -> recycled (no shredding) 

Shredded -> recycled 

1,470 

730 

11,290 

1,760 

880 

10,850 

3,670 

1,760 

8,070 

3,670 

10,270 

0 

The amounts of various base and precious metals that can potentially be recovered in larger 
amounts or at higher quality from inverters sent to dismantling are specified in the table below. 
These amounts have been quantified based on data regarding the contents of such materials 
in inverters and their PCBs. They represent the potential available for recycling but not the 
final quantity actually recycled. 

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Table 3-55 Tonnes of base and precious materials contained in inverters dismantled 
in each scenario that are thus potentially available for recycling (in 2035), values are 
in tonnes and are rounded 

Inverter 

Iron 

Aluminium 

Copper 

Brass 

Gold 

Palladium 

Silver 

Tin 

Baseline 

Scenario 1  Scenario 2 

Scenario 3 

100 

390 

58 

4.2 

0.005 

0.01 

4 

1.6 

20 

80 

11.5 

0.8 

0.001 

0.002 

0.8 

0.3 

140 

550 

81 

5.9 

0.006 

0.01 

5.6 

2.3 

1320 

5110 

749 

55 

0.06 

0.13 

52 

21 

Environmental impacts, represented in global warming potential were calculated for each of 
the scenarios. This is shown below for all inverters from BEV ELVs collected in the year 2035 
(Figure 3-20).  

Figure 3-20  Credits for Global warming potential (GWP) for scenarios for inverters 
compared to primary production – calculated for all inverters of ELVs collected (BEV) 
in 2035 (tCO2eq) 

Credits for Global warming potential (GWP) for recycling options for 
inverters compared to primary production

Baseline

Scenario 1

Scenario 2

Scenario 3

.

q
e
-
2
O
C
t

0

-20.000

-40.000

-60.000

-80.000

-100.000

-120.000

-140.000

-160.000

-180.000

-200.000

Dismantled -> reused/remanufactured

Dismantled -> recycled (no shredding)

Shredded -> recycled

Source: own illustration 

The values of the GWP contributions (total for the baseline and the difference thereto for the 
scenarios) is further presented in the table below. 

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Table 3-56 GWP contributions in the baseline and the difference thereto in the 
various scenarios for the specific treatment route (in 2035), values in CO2eq tonnes 
and are rounded 

Inverter 

Baseline - 
total 

Scenario 1 - 
difference 

Scenario 2 - 
difference 

Scenario 3 - 
difference 

Dismantled -> reused/remanufactured 

Dismantled -> recycled (no shredding) 

Shredded -> recycled 

-22,800 

-8,500 

-107,800 

4,600 

1,700 

-4,200 

34,200 

11,900 

34,200 

110,100 

-30,800 

-107,800 

The  figure  above  shows  an  LCA  comparison  of  the  different  scenarios  considering 
dismantling (incl. components for reuse/remanufacturing) and recycling route with and without 
the  shredder route.  The differences  between the  baseline  and  the  other scenarios  are  not 
huge, with scenario 1 having only 1% more credits (2 thousand tonnes CO2 eq.), scenario 2 
having 11% more credits (15 thousand tonnes CO2 eq.) and scenario 3 showing 26% more 
credits (36.5 thousand tonnes CO2 eq.) than the baseline. The differences are assumed to be 
relatively modest,  as the  base metals,  steel,  aluminium  and  copper that have  a significant 
share in the composition of the component will be recycled at a similar volume in all scenarios 
(though there would be some losses of copper and aluminium to the steel fraction in scenarios 
with more pre-shredder recycling, this is not reflected as much in the values, as some of the 
losses end up as impurities in other metals, affecting quality but not the total quantity). For 
the most part the differences are understood to reflect the small contents of other metals in 
the inverter that can be recovered to a higher degree when the inverter is dismantled prior to 
shredding (gold, palladium, silver and tin) and the PWB sent to separate recycling. Looking 
at the general amounts of credits related to the EEC scenarios, it is also relevant to note that 
this component is calculated for this scenario only for BEV which are expected un 2035 as 
ELV. However, in 2035 this reflects only 11.5% of the collected ELVs. In the long terms the 
absolute benefit would be expected to be more significant.  

3.1.10.1.3.2  Economic impacts 

For the sub-set of components, as already explained above, Restrepo et al. (2018) conclude 
that  a  total  of  188  minutes  or  3.13  hours  would  be  necessary  to  dismantle  all  of  the  12 
components form a vehicle. This is assumed to reflect the time needed by ATFs to dismantle 
a component so that it is fit for reuse and can thus be used as a basis to calculate at least the 
dismantling costs in each of the scenarios. Assuming costs of 51 € per hour of labour, costs 
of ATFs were calculated for the various scenarios. In Scenario 1, additional costs of around 
5.2 million € are to incur, representing an increase of around 20% for dismantling. In scenario 
2, the additional costs amount to around 38 million €, representing an increase of 147 % in 
dismantling costs. In both cases, it has to be assumed that the increase in dismantling serves 
to  provide  a  larger  demand  for  reused  parts,  meaning  that  the  costs  of  the  additional 
dismantling  are  set  off  by  the  costs  of  sales  of  reused  components.  In  scenario  3,  the 
additional  dismantling  costs  amount  to  around  147  million  €  and  represent  an  increase  in 
costs of ca. 565%. However, the calculation is based on the costs of dismantling for the sake 
of reuse, whereas it is to be expected:  

•  a) that the costs for the dismantling of all components reused and 12% of the recycled 
components  is  also  set-off  by  sales  of  reused  components,  as  under  scenario  2.  This 
represents 26% of the costs for dismantling. 

•  b) that cost for the remainder of components to be dismantled could be lower, as they are 
not  intended  for  reuse  and  could  be  dismantled  destructively.  Whether  the  costs  are 
indeed lower, may also depend on how the components are treated after dismantling (i.e., 
automated sorting or manual sorting), though this is part of the costs for further treatment 

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and not for dismantling. In that sense, the dismantling costs would be assumed to be a 
worst-case scenario. 

In all scenarios where a higher share of components is sent to reuse in comparison with the 
baseline, costs would also be expected for sorting and recycling, but also revenues for the 
materials  to  be  recovered.  The  available  data  does  not  allow  quantifying  such  costs. 
Nonetheless, after comparing the data on the dismantling rates (Figure 3-17) with the data 
on dismantling times (Table 3-53) Restrepo et al. (2018) notes that EEC with electric motors 
(and potentially with REE based magnets) are often dismantled despite the higher dismantling 
times.  In  contrast,  despite  low  dismantling  times,  components  with  PWBs  have  lower 
dismantling rates. It is thus concluded that an obligation to dismantle such components would 
potentially increase the amount of precious metals that can be recovered from PWBs more 
significantly  than  it  would  increase  amounts  of  materials  recovered  from  EECs  containing 
motors.  This  is  particularly  true  for  the  engine  control,  power  window,  radio,  hydraulic 
modulator (ABS pump), dashboard, airbag controller and the navigation system, which have 
a dismantling rate around 20% and below and a dismantling time between 8-18 minutes. 

For the inverter, costs of ATFs were calculated for the various scenarios based on the data 
provided in Groke et al. (2017) for dismantling costs and revenues from sales of components 
of reuse and for recycling (pre-shredded). The comparison of costs of the various scenarios 
is shown in the figure below. 

Figure 3-21  ATF dismantling costs and revenues from EEC reuse and material sales 
(€) 

12.000.000 € 

10.000.000 € 

8.000.000 € 

6.000.000 € 

4.000.000 € 

2.000.000 € 

- € 

-2.000.000 € 

-4.000.000 € 

Baseline

Scenario 1

Scenario 2

Scenario 3

Dismantling costs

Revenues - reuse sales

Revenues materials

Source: Own illustration 

On the example of EEC, the additional costs for scenarios EEC 1 to EEC 3 were calculated 
on the basis of dismantling costs and the revenues. The difference between each scenario 
and the baseline is as follows:  

•  scenario EEC 1: 0.3 million € or 20% higher revenues than in the baseline, 
•  scenario EEC 2: 2.2 million € or 147% higher revenues than in the baseline, 
•  scenario EEC 3: almost 7.2 million € or 475% higher revenues than in the baseline. 

As for other stakeholders, here, data was not available to allow a quantification of impacts, 
however they can be specified quantitatively. Assuming that more EEC being dismantled in 
the various scenarios is expected to increase the rate of reuse of such components while also 
increasing  separate  recycling.  As  the  amount  of  dismantling  for  reuse  and  dismantling  for 
recycling increase from scenario to scenario, costs and benefits can be expected to increase 

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or  decrease  proportionally  to  the  reuse  and  recycling  shares  in  each  scenario  unless 
specifically mentioned: 

In the scenarios proposed, increases in the rate of reuse occur only on the basis of voluntary 
dismantling, i.e., increases are generally expected where there is also an increase in demand 
as there is no obligation to reuse components. This will mean that where more reused parts 
become available for reuse, this is accompanied by a higher demand for reuse by consumers 
(vehicle  owners).  The  option  to  repair  a  vehicle  with  a  reused  or  remanufactured  part 
generally means that the consumer has lower expenses to repair a vehicle, considered as a 
benefit.  

In  parallel,  repair  shops  that  apply reused  parts  would  not  be  expected  to  lose  too  much 
revenue as the price of the part is for the most part transferred to the customer. The effort to 
source spare parts could be somewhat higher than that of a new part as in some cases it may 
be necessary to consult multiple ATFs to find a part, however many ATFs have digitised their 
reuse  inventory  and  now  sale  parts  online,  making  the  process  easier.  Furthermore,  it  is 
understood that repair shops already sell reused EEC in some cases, so any burdens are 
assumed to be acceptable in range. 

For shredders, the understanding that less EEC will be sent to shredders will mean a loss of 
business. This is related in general to lower volumes of ELV scrap being sent to shredders 
but could also have a small impact on shredder revenues as EEC will contain some metals 
that  are  targeted  in  the  treatment  of  ELV-waste  after  shredding  operations.  In  parallel, 
depending on how much of the base metals no longer arrive at shredders, it could be that the 
reduction of copper in Fe and Al scrap would set-off losses on quantities due to reduction of 
scrap impurities. 

For recyclers of steel and aluminium, amounts of recovered materials would not be expected 
to change drastically, though under the various scenarios, amounts sold by shredders would 
reduce somewhat and amounts sold by recyclers of EEC would increase proportionally to the 
amount of EEC recycled after dismantling. Nonetheless, as more copper is expected to be 
recovered by EEC recyclers, the purity of ELV steel and aluminium scrap would be expected 
to  increase  to  some  degree.  For  recyclers  of  EEC  (in  some  cases  copper  smelters),  an 
increase of business is expected depending on the amounts of EEC sent directly to recycling 
and also on the type of EEC in question and its metal content.  

In total, it can be expected that recyclers will place more secondary copper and secondary 
precious  and  CRMs  on  the  market,  though  the  case  for  different  elements  may  differ 
depending on the availability of recycling capacities that target the specific material. For REE 
from  magnets,  it  is  possible  that  a  dismantling  obligation  alone  will  not  suffice  to  promote 
recycling and thus will not result in increased REE availability on the European market. If the 
REE cannot to be sorted and sufficiently recovered from fractions after dismantled parts are 
subjected to dedicated shredding of EEC (separate from other equipment) it could be relevant 
to perform deep dismantling of certain EEC to disassemble e.g., magnets prior to shredding 
operations.  For  steel  and  aluminium,  higher  purities  will  have  an  impact  in  terms  of  less 
dependency on primary materials. In general, the higher availability of recyclables on the EU 
market will lower the dependability of the EU on extra-EU sources (primary but also secondary 
in  some  cases).  With the  current  war  in  Ukraine  and  lacking  clarity  on  further  geo-political 
developments, this reduction in dependency is not only an advantage for the EU in general 
but  could  also  reduce  supply  risks  for  the  European  automotive  industry  (or  other 
manufacturers).  The  case  of  copper  for  example  is  a  good  demonstration  in  this  respect. 
Ukraine is an important supplier of copper, and the current geopolitical situation has created 
difficulties in the supply of copper. In particular, lack of supply of copper wire harnesses can 
affect the business drastically as this component is assembled in the vehicle at early stages 
and a lack of supply means that completion of assembly can have heavy delays. In parallel, 

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the vehicle manufacturing industry may also experience higher costs for material recovery, 
either directly through costs of recyclables, but possibly also through a necessity to support 
the dismantling of components for which dismantling and separate recycling is marginal (e.g., 
through  EPR).  A  further  economic  aspect  is  related  to  the  expected  administrative  cost  of 
reporting.  Under  the  baseline,  Commission  Decision  2005/293/EC,  which  specifies  the 
current reporting rules, already requires MS to report on the “metal components” arising from 
depollution and dismantling in the required format. However, it is required to report a sum of 
all  depolluted  and  dismantled  materials  and  reporting  on  separately  listed  materials  is 
voluntary. Introduction of scenario EEC 1 (and especially the monitoring aspect) will require 
adjustment  of  the  reporting  format  as  well  as  changing  the  reporting  from  voluntary  to 
mandatory.  This  adjustment  is  assumed  to  result  in  additional  economical  costs  for  public 
administration as well as for ATF that report on removed parts/components.  

These additional costs will be related to the additional time for collecting all data by ATFs, 
developing a precise reporting of the total weight of reused parts/components is to be required 
for each component in the reporting table. More time will also be needed for the institution 
that  collects,  summarises,  and  validates  data  before  its  official  publication. It  is to  assume 
that the expected additional administrative cost of reporting would be similar in the case of 
scenario EEC 1 and EEC 2, but not doubling when the two scenarios are implemented jointly. 
These  costs  are reflected  in the  analysis  at  vehicle  level  which  looks  among  others  at the 
administrative  burden  related  to  reporting  on  reuse  and  is  thus  not  included  here  to  avoid 
double counting. 

Additional costs will also exist for reporting on the dismantled inverters sent to recycling in 
particular in scenario EEC 3. These costs will incur for facilities’ operators as well as for public 
authorities, however it is expected that these costs will be higher for facilities. As described 
above,  public  offices  will  need  to  collect  data  and  validate  it.  Here  too,  costs  treated  to 
administrative burden are calculated in the analysis at vehicle level in relation to the measure 
on obligatory dismantling and are not included here to avoid double counting. 

3.1.10.1.3.3  Social impacts 

For the components sub-set, based on the dismantling time specified in Restrepo et al. (2018) 
and the total amount of time needed for the additional dismantling, in each scenario the time 
needed for dismantling was used as a basis for calculating the additional jobs to be created 
through this measure. 65 additional jobs are estimated to be created under scenario EEC 1, 
ca. 465 additional jobs under scenario EEC 2 and ca. 1800 additional jobs under scenario 
EEC 3. 

the  sector,  particularly 

For the inverter, additional dismantling could result in an increase in the number of employees 
in 
time  (possibly  an 
underestimation), additional jobs were calculated based on dismantling for each scenario and 
amounted to 1 in scenario EEC 1, 7 in scenario EEC 2 and 29 jobs in scenario EEC 3. 

for  ATF.  Based  on 

the  dismantling 

3.1.10.1.4  Comparison of scenarios for EEC 

The differences in impacts of the scenarios as compared to the baseline are compiled in Table 
3-57 below to allow an easier comparison.  

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Table 3-57 Summarising table for the comparison of the EEC scenarios on the basis 
of treatment of the inverter (the assessed impacts are based on the total of ELVs 
collected in 2035) 

Impacts 

Scenario EEC 1 

Scenario EEC 2 

Scenario EEC 3 

on ATFs 

due 

Inverter:  0.3  million  € 
benefits 
to 
additional  dismantling 
costs  off-set  by  high 
revenues  Component 
sub-set:  5.2  million  € 
additional 
costs, 
benefits  unclear  but 
expected  to  be  set-off 
by 
related 
revenues. 

reuse 

due 

Inverter:  2,2  million  € 
benefits 
to 
additional  dismantling 
costs  off-set  by  high 
revenues  

Component  sub-set:38 
million  €  additional 
costs,  benefits  unclear 
but  expected  to  be  set 
off  by  reuse  related 
revenues 

Between 0 and + 

Between 0 and + 

on shredders  

shredding 
of 
(loss 

of 

Loss 
material 
revenue) 

- 

of 

Loss 
material 
revenue) 

-- 

shredding 
of 
(loss 

c
i
m
o
n
o
c
E

on recyclers 

less 

decrease 

Small 
in 
business due to reuse -
secondary 
-> 
material for recycling – 
however impact is only 
delayed  

Higher  decrease 
in 
business  due  to  less 
less 
--> 
reuse 
secondary  material  for 
recycling  –  however 
impact is only delayed 

between 0 to - 

- 

due 

Inverter:  7.2  million  € 
benefits 
to 
additional  dismantling 
costs  off-set  by  high 
revenues 

sub-
Component 
€ 
set:147  million 
additional 
costs, 
benefits  unclear  but 
expected  to  set  off  at 
least  26  million  €  of 
costs 
to 
dismantling for reuse 

related 

Between – and + 

shredding 
of 
(loss 

of 

Loss 
material 
revenue) 

--- 

Benefits for recyclers of 
Fe  and  Al  as  copper 
will 
impurities 
decrease, 
increasing 
quality  of  secondary 
materials.  Benefits  for 
EEC recyclers in terms 
of  higher  amount  of 
secondary 
material 
(copper  and  precious 
metals).  In  both  cases 
higher 
revenues 
expected  

++ 

on SME  

Small ATFs would probably have higher costs than larger ones 

Other  

Economic impacts on other stakeholders can be compared to the total cost 
of vehicles and are considered as marginal 

Administrative 
costs burden 

Quantified 
under 
vehicle  level  analysis 
for 
reuse  monitoring 
measure 

Quantified 
under 
vehicle  level  analysis 
for 
for 
measure 
the  reuse 
supporting 
market  

Quantified 
under 
vehicle  level  analysis 
for 
for 
measure 
obligatory dismantling  

2ndary resources 

increase 

in 
Small 
of 
availability 
precious 
secondary 
metals for manufacture 
and in the availability of 
reused parts, benefiting 

Moderate  increase  in 
of 
availability 
precious 
secondary 
metals for manufacture 
and in the availability of 
reused parts, benefiting 

increase 

in 
Large 
of 
availability 
precious 
secondary 
metals for manufacture 
and in the availability of 
reused parts, benefiting 

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Impacts 

Scenario EEC 1 

Scenario EEC 2 

Scenario EEC 3 

ATFs  and 
repair 
consumers  

indirectly 
and 

shops 

ATFs  and 
repair 
consumers 

indirectly 
and 

shops 

ATFs  and 
repair 
consumers  

indirectly 
and 

shops 

l

a
t
n
e
m
n
o
r
i

v
n
E

Social  

Stakeholder 
support 

Environmental 
impacts: LCA 
credits for reuse/ 
remanufacturing 
and recycling277 

+ 

++ 

+++ 

Inverter: 
Small 
increase  of  1%  (2,000 
in 
tonnes  CO2  eq) 
comparison to baseline 
scenario 

Moderate 
Inverter: 
increase 
11% 
of 
(15,200 tonnes CO2 eq) 
in 
to 
comparison 
baseline scenario 

Sub-set 
components: 
in 
credits 
range 

of 
increase 
environmental 
unknown 
– 

Sub-set 
components: 
in 
credits 
range 

of 
increase 
environmental 
unknown 
– 

+ 

++ 

Inverter: 
Large 
increase  of  about  26% 
(36,500 tonnes CO2 eq) 
in 
to 
comparison 
baseline scenario 

of 
Sub-set 
increase 
components: 
in a rage of 49-120% in 
environmental credits 

+++ 

Employment 

Increase in jobs (~1) for 
the  inverter  and  in  65 
additional  jobs  for  the 
component sub-set. 

Increase in jobs (~7) for 
the inverter and in 465 
additional  jobs  for  the 
component sub-set. 

Increase  in  jobs  (~29) 
for  the  inverter  and  in 
1800 additional jobs for 
the component sub-set. 

+ 

++ 

+++ 

importance 

Stakeholders  from  all 
explained 
categories 
of 
the 
for 
measures 
supporting 
the  reuse 
market  as  a  means  to 
for 
demand 
boost 
few 
reused  parts.  A 
include: 
examples 
(EGARA 
2021; 
Eurometaux  21  Feb 
EUROFER 
2021; 
27.10.21) 

who 
Stakeholders 
to 
the 
answered 
interactive 
workshop 
questions 
(Slido) 
agreed  (12  from  15) 
that  separate  recycling 
improve 
would 
recycling  of  materials 
contained  in  EEC.  In 
the  OPC,  around  50% 
supported 
obligatory 
dismantling  for  PWB, 
magnets  and  other 
EEC. 

Proportionality  

All  scenarios  are  considered  proportional  for  achieving  the  objectives  that 
the EU Treaties intends to implement 

Cost effectiveness  

Low  costs  but 
benefits 

low 

Moderate  costs  and 
benefits  

Highest  costs  but  also 
highest benefits 

+ 

++ 

Between + and -++ 

Coherence 

Coherence  with  waste 
and 
legislation 
the 
promoting 
CEAP, 
waste  treatment  of  a 
higher  hierarchy  and 
circularity  and  also 
coherence  with 
raw 
material  policies  as  it 

Coherence  with  waste 
and 
legislation 
the 
promoting 
CEAP, 
waste  treatment  of  a 
higher  hierarchy  and 
circularity  and  also 
coherence  with 
raw 
material  policies  as  it 

Coherence  with  waste 
and 
legislation 
the 
promoting 
CEAP, 
waste  treatment  of  a 
higher  hierarchy  and 
circularity  and  also 
coherence  with 
raw 
material  policies  as  it 

277 As a difference to baseline scenario 

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Impacts 

Notes: 

-/-: no impact 

Scenario EEC 1 

Scenario EEC 2 

Scenario EEC 3 

(critical 

supports  the  recovery 
and) 
of 
precious 
metals 
(depending  on  EEC 
reused and recycled) 

(critical 

supports  the  recovery 
and) 
of 
precious 
metals 
(depending  on  EEC 
reused and recycled) 

(critical 

supports  the  recovery 
and) 
of 
precious 
metals 
(depending  on  EEC 
reused and recycled) 

+ 

++ 

+++ 

Costs or burdens: between 1 and 3 minus signs (-; --; or ---), indicating low (1 minus sign) and high (3 minus signs) costs or 
burdens 

Benefits or savings: between 1 and 3 plus signs (+; ++; or +++), indicating low to high savings 

(): brackets around symbols if costs, benefits etc. are only potentials or are uncertain. If the costs, benefits etc. is rather 
uncertain, a broader range is indicated: e.g., ++ to +++ or – to + 

n.a.: not applicable 

Though  the  data  availability  allows  only  a  partial  analysis,  the  analysis  suggests  that  all 
scenarios would be effective. Scenario EEC 1 is to result in relatively small benefits but is 
also expected to have much lower costs. Under scenario 2 costs may be more significant but 
are expected to be set-off by revenues as reuse will only take place where there is a market 
for using reused components. Scenario EEC will have the highest costs as all components 
must be dismantled and treated separately. The costs are not completely clear however per 
vehicle, dismantling costs would be expected to be lower than in other scenarios, as a larger 
share  of  EEC  that  falls  under  dismantling  obligations  can  probably  be  dismantled 
destructively.  

In all cases, a higher efficiency is expected in relation to increasing the recovery of copper 
(and thus indirectly reducing impurities in steel and aluminium fractions (quality improvement) 
and of certain precious metals (e.g., gold palladium, silver, tin). This is related to dismantling 
of components containing PWB in which precious metals can be targeted for example through 
copper  smelting.  However,  the  efficiency  for  dismantling  actuators  containing  REE  is  not 
clear. To begin with, such materials do not show a high environmental difference between the 
baseline and other scenarios as their primary production is similar in intensity to base metals 
(Fe,  Al,  Cu).  REE  are  an  important  material  for  magnets  used  in  various  types  of  vehicle 
motors and currently the EU relies heavily on other countries (e.g., China) for their supply. 
This means that the recovery of REE has a political relevance that is also affected by geo-
political  developments,  however  this  cannot  be  quantified  to  allow  understanding  how  this 
affects  the  comparison  of  the  scenarios.  In  addition,  REE  contained  in  magnets  in  such 
components  would  not  be  recovered  based  on  the  current  recycling  capacities  in  the  EU. 
Though recycling capacities could develop by 2035, it may be worth investigating whether 
obligations  to  dismantle REE  containing  magnets  would  help  advance the  development  of 
such capacities. Dismantled magnets would then either need to be stockpiled until recycling 
capacities in the EU are sufficiently developed, or alternatively could be exported for recycling 
in this transitional period. 

A  few  recommendations  made  by  Restrepo  et  al.  (2018)  can  be  reproduced  here.  After 
comparing  the  environmental  impacts  with  the  dismantling  rates  and  times  for  each 
component, Restrepo et al. (2018) make the following recommendations: 

•  The  example  of  an  alternator  is  representative  of  the  REE  rich  components,  where 
dismantling results in smaller reductions of the environmental impacts as compared to the 

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baseline.  However, the  results  depend  on  how  the  fractions  are  treated after the  initial 
shredding. When sorting is performed after the initial shredding, some of the copper sticks 
to  clumps  of  other  base  metals  (e.g.,  where  the  copper  is  “anchored”  to  such  metals), 
which are relatively large. More copper thus ends up as an impurity in recovered steel 
and aluminium as compared to cases where advanced shredding is applied (resulting in 
smaller  pieces  sent  to  sorting).  In  this  case,  if  advanced  shredding  is  not  applied,  it  is 
recommended  to  dismantle  such  components  even  just  to  increase  the  recovery  of 
copper,  which  also  has  benefits  to  the  purity  of  other  metals.  After  dismantling, 
components not sold for reuse (as well as the malfunctional ones being replaced) should 
be disassembled so that the copper anchoring is removed and sent to separate recycling. 
•  The example of the GPS navigation system (representative for the PWB containing EEC) 
shows a somewhat different picture: these EECs are hardly ever removed for reuse as 
spare  parts,  i.e.  they  are  all  shredded,  which  means  that  the  possible  environmental 
reduction is small. Only when Cu and other metal content (mostly precious metals) are 
also  recovered,  is  there  a  considerable  environmental  benefit.  Accordingly,  here  it  is 
recommended  to  dismantle  all  GPS  navigation  systems  and  in  a  second  step  to 
disassemble some of their sub-components (cables, plugs and printed circuit boards) and 
send them to Cu and precious metals treatment plants.  

As regards proportionality, here the situation may somewhat differ for the various scenarios. 
Though some benefits have been assumed for scenario EEC 1 on the basis that the need to 
monitor  reuse  may  push  ATFs  to  more  dismantling  for  reuse,  however  this  benefit  is 
considered  to  be  relatively  small.  In  parallel,  ATFs  will  be  required  to  provide  a  detailed 
reporting  of  the  number  and  type  of  EEC  dismantled  and  related  weights.  Though  it  is 
expected that many ATFs will have such information digitized (more and more ATFs conduct 
the  sale  of  reused  components  online),  it  is  not  completely  clear  what  the  costs  of  such 
dismantling  would  be  and  whether  they  would  be  proportional  to  expected  benefits. 
Nonetheless, as without a more detailed monitoring on reuse it is considered that the actual 
status of reuse will remain very vague, perhaps other benefits need to be considered in this 
case. For scenario 2, the assumption is that components will only be dismantled (and sold) 
where there is an expected demand for them on the market. Furthermore, ATFs would only 
be  expected  to  dismantle  components  when  the  costs  are  set-off  by  respective  benefits. 
Though  some  stakeholders  may  have  related  costs  (e.g.,  loss  of  business  for  producers 
related  to  manufacture  of  new  parts,  repair  shops  that  will  have  an  extra  effort  to  prepare 
proposals) these are expected to be set off by the environmental benefit of reuse which saves 
credits related to the manufacture of materials for new production. In so far it is assumed that 
here  the  costs  are  proportionate  to  expected  benefits.  For  scenario  EEC  3,  proportionality 
may depend on the specification of the obligation to dismantle. From the literature, it appears 
that for some EEC, dismantling of EEC is economically feasible not just for reuse but also for 
recycling, also providing an environmental benefit. However, this is not always the case and 
specifying a list of components for obligatory dismantling in lack of sufficient data could affect 
the proportionality of this measure. As explained earlier in this chapter, the EMPA continues 
to  research  this  subject  in  detail  in  relation  to  a  similar  obligation  being  considered  for 
Switzerland. Results of this study are due for publication at the beginning of 2023 and should 
be  consulted  again to  allow  consideration  of the  results  and  a  possible alignment  with  the 
Swiss obligation. 

EPR considerations: 

The  costs  for  dismantling  of  EEC  will  depend  on  the  components  for  which  this  will  be 
obligatory. Some of the specifications proposed in this regard are supported by practices in 
other sectors (PWBs for WEEE and possibly also PV in the future) and some based on the 
various studies that have been performed on this subject. However actual costs depend on 
labour costs of which differ between MS as also on the revenues that can be expected for 

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reuse as also for recycling. In this sense, it is not possible to provide an estimation of possible 
support that ATFs may need from EPRs to facilitate this practice at this time. That said, the 
Restrepo et al. (2018) work estimates the time needed for dismantling at 188 minutes for a 
sub-set  of  12  components  types  expected  to  contain  significant  amounts  of  precious  and 
CRMs.  The  actual  dismantling  time  may  be  lower  when  components  are  dismantled  for 
recycling in a destructive way (though affecting possible benefits). This provides a reference 
for the possible costs of dismantling per vehicle, though it can be expected that at least a 
share of such costs would be set-off by revenues from reused parts and from sales of the 
EEC fraction for recycling and subsequently, sales of revenues from secondary materials.  

3.1.10.1.5  Preferred  Scenarios  for  inclusion  in  final  policy 

options 

It  is  proposed  to  include  all  three  measures  in  the  various  policy  options,  these  could  be 
combined in different ways, however a combination of all three measures could prove to have 
the highest relevance as these measures will support both reuse and separate recycling that 
are both understood to be relevant for EEC. The monitoring measure for reuse is mainly seen 
as a supporting measure that is necessary in any case and should in any case be considered 
is the measure for increasing the demand of reused parts. In that sense, the monitoring of 
reuse  could  be  proposed  as  a  single  measure  to  facilitate  better  compliance  with  existing 
provisions.  A  more  relevant  combination  would  see  all  three  measures  applied  and  a 
possibility for further ambition would be to consider different options for the list of EEC to be 
dismantled. The combinations to be considered are thus formulated as follows: 

•  Monitoring of reuse 
•  Monitoring of reuse +Measures to promote the demand of reused and remanufactured 
parts + Obligatory dismantling of the following EEC: printed circuit boards with a surface 
area greater than 10 square centimetres, photovoltaic components with a surface area of 
0.2  square  meters,  inverter,  drive  control  unit,  start-stop-control  unit,  oxygen  sensor, 
transmission  control  unit,  side  assistant  sensor,  distance  and  near  distance  sensors, 
airbag controller, engine controller, multifunctional display, navigation system GPS, radio 
CD, speedometer 

•  Monitoring of reuse +Measures to promote the demand of reused and remanufactured 
parts  +  Obligatory  dismantling  of  the  EEC  listed  above  in  addition  to:  ABS  Block, 
alternator, starter, window raising motor (front and rear), radiator fan motor, wind wiper 
motor (front and rear) 

It should further be considered whether to extend the list after publication of the EMPA study 
and in consultation with the obligatory dismantling list for EEC in Switzerland. 

To summarise, the following table contains recommendations, in some cases referred in the 
various sources and in some cases a result of the analysis prepared in this study: 

Materials 
of 
relevance 

REE 

Components 

Actuators in ABS Block, 
alternator, starter, window 
raising motor (front and 
rear), radiator fan motor, 
wind wiper motor (front and 
rear) 

Related 
source 

Restrepo 
et al.  

Proposed approach - recommendation 
based on literature conclusions if not 
specified otherwise - see source in 
adjacent column 
Part of the Restrepo sub-set: If only copper is 
targeted: require dismantling in cases that 
advanced shredding and PST are not applied to 
enhance removal of copper (beneficial for purity of 
Fe and AL scrap as well as for copper recycling) 
If REE targeted, make dismantling obligatory and 
further investigate if magnets should be 
disassembled before dedicated shredding of EEC 
batches. 

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Materials 
of 
relevance 

Proposed approach - recommendation 
based on literature conclusions if not 
specified otherwise - see source in 
adjacent column 

Other CRMs  Part of the Restrepo sub-set: GPS (navigation 

systems) recommended for obligatory dismantling 

Related 
source 

Restrepo 
et al.  

Precious 
metals 

The consultant recommends adapting the WEEE 
approach of requiring dismantling of PWB with a 
surface area greater than 10 square centimetres 

Groke et 
al. 

Components 

airbag controller, engine 
controller, multifunctional 
display, navigation system 
GPS, radio CD, 
speedometer  
Printed wiring boards in 
control devices. Most 
relevant are: control units 
for the engine and 
infotainment, display and 
control unit, control panel, 
airbag control and auxiliary 
stop light 
Inverter, oxygen sensor, 
side assistant sensor, 
distance and near distance 
sensors  
Photovoltaic panels  

Engine components: heating fan and 
generator 
Controller components: engine/gear control 
unit, inverter, drive control unit, start-stop-
control unit 
Alternator 

Transmission control unit 

Heating fan, alternator, inverter, engine 
control unit, transmission control unit, drive 
control unit, start/stop engine and oxygen 
sensor 

Only components relevant for economically 
feasible dismantling in countries with high labour 
costs 

Arnold et 
al. (2021)  

The consultant recommends adapting the WEEE approach of 
requiring dismantling of PV with a surface area of 0.2 square 
meters 
Recommended for dismantling as considered to 
be economically feasible 
Recommended for dismantling as considered to 
be economically feasible 

Groke et 
al. 
Groke et 
al. 

Recommended for dismantling as considered to 
be economically feasible 
Recommended for dismantling as considered to 
be economically feasible 
Recommended for dismantling as considered to 
be economically feasible 

Groke et 
al. 
Groke et 
al. 
Groke et 
al. 

3.1.10.1.6  Reporting and monitoring requirements 

Reporting requirements are explained earlier in the section. For the monitoring of reuse, a 
new  methodology  will  be  developed,  requiring  a  more  detailed  reporting  of  the  type  of 
components  sold  for  reuse  and  their  respective  weights.  This  monitoring  is  to  replace  the 
currently voluntary reporting on reuse that is not sufficient to allow understanding the actual 
level  of  reuse  on  the  various  MS.  Thus,  such  monitoring  will  be  necessary  for  both  of  the 
reuse measures proposed here. 

To  monitor  the  compliance  with  the  dismantling  obligation,  possibly  the  easiest  method  of 
monitoring would be to require ATFs to report on amounts of EEC sold for further treatment. 
This  shall  also  increase  transparency  as  to  how  such  fractions  are  recycled  (what  type  of 
recyclers). Understanding expected amounts of EEC to be dismantled and sent to recycling 
will be difficult as the number of components can vary between vehicle models as can also 
the weight. However, the reuse monitoring could provide some insight to allow for a better 
understanding in the future.  

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3.1.11  Analysis of measures addressing the treatment of vehicles at 

EoL: vehicle level 

Five measures were shortlisted for at the vehicle level, including the following measures: 

Title 

2.3.e) Establish provisions to support the market of used spare parts composed of steel 
2.3.f) Set up a separate (monitoring) target for re-use/preparing for re-use/remanufacturing of 
steel components 
2.4.a) Align definition of ‘recycling’ with the WFD to prohibit the backfilling 
2.4.b) Making it mandatory to remove certain copper parts before shredding to encourage high 
quality steel/aluminium and high quantity copper recycling as well as mandatory removal of 
selected parts/components that contain aluminium 
2.4.c) Set material-specific recycling targets for a selection of materials 
2.4.d) Regulate shredder/post shredder facilities to ensure high quality/quantity of materials 
obtained for recycling and to improve final treatment process 
2.4.e) Increase (?) current re-use and recycling targets and/or ban disposal or landfilling of 
waste from ELVs 

Chapter 
2.1.5.3.5 
2.1.5.3.6 

2.1.5.4.1 
2.1.5.4.2 

2.1.5.4.3 
2.1.5.4.4 

2.1.5.4.5 

Colour code: Red – discarded, Yellow – premature, Grey – supporting measure 

The  measures  above  are  relevant  for  the  reuse/remanufacturing  and  recycling  addressing 
the  treatment  of  vehicles  at  end-of-life.  All  of  the  above-named  measures  were  already 
considered in the various material level analysis and their outcomes discussed in the previous 
sub-chapters. The aim of this analysis is to gain better understanding of impacts for various 
assumption on the vehicle level. Thus, a combination of selected scenarios for materials were 
combined to perform analysis on the vehicle level. The intention was to select scenarios so 
they will be as much as possible in the line with the analysed policy options. Below table with 
the selected material scenario allocated to new overall scenarios on vehicle level.  

Table 3-58 Routes of treatment for complete vehicle under the various scenarios 

Steel, Copper, 
Aluminium, 
Other materials 
Glass 

Baseline 
Overall ELV 
Baseline 

Baseline 

Plastic 

Baseline 

Scenario 1 
Overall ELV 
Scenario 1 
(monitoring 
reuse) 
Scenario 1 
(alignment 
WFD) 
Baseline 

Scenario 2 
Overall ELV 
Scenario 2 
(support reuse) 

Scenario 1 
(alignment 
WFD) 
Baseline 

Scenario 3 
Overall ELV 
Scenario 3 
(mandatory 
dismantling) 
Scenario 2 
(mandatory 
dismantling) 
Scenario 3 
(landfill ban) 

Scenario 4 
Overall ELV 
Scenario 4 
(regulate 
shredder/PST) 
Scenario 3 
(material-
specific target) 
Scenario 2 
(material-
specific target) 

Source: Oeko-Institut: own assumptions 

3.1.11.1  Results of qualitative analysis  

The  results  of  qualitative  analysis  of  all  scenarios  were  already  introduced  in  the  analysis 
performed for various materials, thus will not be duplicate here and instead please refer to 
relevant parts of the document:  

Implementation of reuse/recycling measures: please refer to e.g., 3.1.5.3. 
Implementation of “calculation point”: please refer to e.g., 3.1.8.1.4.2. 

• 
• 
•  Mandatory removal of certain parts: please refer to e.g., 3.1.8.1.3. 
•  Requirements on deliverable from shredder/PST together with landfill ban: please refer to 

e.g., 3.1.5.3. 

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3.1.11.2  Results of quantitative analysis  

The following table are calculated routes of treatment for all materials in collected ELVs in 
2035 based on the estimated routes of treatment for individual material. 

Table 3-59 Calculated routes of treatment for all materials in collected ELVs under the 
various scenarios  

Baseline 

Scenario 1  Scenario 

Scenario 3  Scenario 

Dismantled -> 
reused/remanufactured 
Dismantled -> recycled (no 
shredding) 
Dismantled -> shredded -> 
recycled 
Shredded -> recycled 

Recovered 

Losses/process inefficiencies 

8% 

3% 

2% 

58% 

9% 

18% 

2 

12% 

14% 

5% 

5% 

50% 

9% 

18% 

7% 

8% 

43% 

9% 

18% 

4 

15% 

14% 

8% 

39% 

8% 

16% 

15% 

16% 

8% 

36% 

8% 

16% 

Source: Oeko-Institut: own calculations 

Figure 3-22 introduces the calculated amounts of materials from collected ELVs in 2035 that 
could be reused/remanufactured as well as recycled pre- and post-shredder. The total mass 
of these materials in EoL vehicles is assumed to be about 10,655 Mt in 2035.  

Figure 3-22  Tonnes of materials from collected ELVs assumed to be either reused 
or recycled and losses of the material in the treatment process (in 2035) (kg) 

Source: Own illustration  

Together  with  the  introduction  of  new  measures  the  level  of  common  reuse  and  recycling 
target  will  change.  The  rather  significant  impact  on  this  level  will  be  the  introduction  of 
“calculations point” since from the reported data all the losses have to be discarded and the 
adjustment  of  the  recycling  definition  to  the  WFD  due  to  the  fact  that  backfilling  will  not 
account anymore towards recycling rate. In view of the considered measures under Scenario 
Overall,  certain  assumptions  have  been  made  in  the  calculations,  for  instance  the  high  of 
reuse/remanufacturing  is  up  to  20%  of  dismantled  materials  (steel,  wrought  and  cast 
aluminium,  copper,  glass,  plastic),  part  of  remaining  parts/components  are  treated  in 

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shredder/PST and other parts are after dismantling send directly to the recycling. All losses 
in both routes are excluded in the calculation as well as vehicle’s battery weight. Towards 
reuse and recycling, the weight of aluminium treated together with steel is also considered. 
In a result, the recovery and recycling rates achieved in the different scenarios range between 
80% and 83% and the reuse and recycling rates between 70% and 74% 

Table 3-60 Obtained rates for reuse and recycling and rates for recovery and 
recycling for complete vehicle under the various scenarios 

Baseline 
Overall ELV 
80.4% 

Scenario 1 
Overall ELV 
85.6% 

Scenario 2 
Overall ELV 
82% 

Scenario 3 
Overall ELV 
87.3% 

Scenario 4 
Overall ELV 
86.8% 

70.6% 

75.9% 

76.2% 

78.9% 

77.9% 

reuse and 
recovery rate 
reuse and 
recycling rate 

Source: Oeko-Institut: own calculations 

3.1.11.2.1  Environmental impacts 

The  following  figure  shows  credits  in  GWP  for  various  scenarios  based  on  the  shares 
specified in Table 3-59 for the whole fleet in 2035. The highest GWP credits per kg material 
has  recycling  of  materials  followed  by  credits  for  components  for  reuse/remanufacturing. 
Benefit of recycling route without shredder (direct recycling) are more visible in Scenario 3 
Overall,  where  for  majority  of  materials  scenario  with  mandatory  removal  was  analysed. 
Visible environmental credits are also visible for Scenario 4 Overall. Here significant rule plays 
also dismantling in order to reach thresholds on the Cu-content in steel scrap as well as on 
metal content in PST residues. 

Figure 3-23  Credits for Global warming potential (GWP) for scenarios for the whole 
fleet compared to primary production – calculated for all ELVs collected in 2035 
(tCO2eq) 

Source: Own illustration  

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3.1.11.2.2  Economic impacts 

Economic impact was also addressed in higher detail under each of sub-section on various 
materials thus will be not considered on the vehicle level. However, in general, it can be said 
that dismantling costs are not competitive towards other ways of treatment. Thus, for several 
materials,  it  is  recommended  to  consider  developing  of  EPR  scheme  that  could  cover 
potentially higher costs by this scheme. (e.g. also described in detail in other sub-chapter with 
analysis  for  various  materials).  Since  the  dismantle  time  (i.e.,  dismantle  costs)  varied  for 
different  components  the  calculation  of  dismantling  cost  was  not  performed,  however  it  is 
possible  to  refer  to  previous  sub-chapter  to  get  familiar  with  the  calculations  for  various 
materials.  The  following  figure  shows  summed  up  revenues  obtained  from  recycling  of 
considered  materials.  Caution,  this  calculation  does  not  include  the  revenues  from  sold 
components  for  reuse/remanufacturing,  since  they  vary  among  the  components  and  the 
introduced calculation based on the material and not components. The calculations base also 
on the current prices for materials for recycling and recovery, however the fleet is from 2035.  

Figure 3-24  Total revenue from materials for recycling or recovery in Euro – 
calculated for all ELVs collected in 2035 (1000 Euro) 

Source: Own illustration  

Here again the intensive dismantling and direct recycling promoted under Scenario Overall 3 
and  4  for  various  materials,  shows  impact  of  the  revenues  for  these  separately  recycled 
materials on the total revenue. Prices for some materials variate, depending on the quality of 
material for recycling, i.e., secondary wrought aluminium can have a price of primary wrought 
aluminium and this current price was considered in the calculations.  

Currently, under the reporting format, the steel scrap is to be reported for recycling, recovery, 
and disposal. These values are nowadays mainly provided by shredders/PSTs. Together with 
introduction  of  a  “calculation/measurement  point”  in  the  reporting,  recyclers  will  also  be 
involved  in  the  reporting  (more  about  it  in  another  chapter).  This  will  also  increase  the 
reporting costs also in regard to calculate/assume/obtain data for reporting on all losses (in 
shredder/PSTs and in recycling processes) in order to derive the actual amount of steel scrap 
ready for use.  

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An  implementation  of  the  broader  reporting  scheme,  which  will  embrace  also  reporting  by 
recyclers,  has farther  economic  impact,  which  has  been  assessed  with  the  use  of  existing 
model for assessment of administrative costs. The crucial finding that was calculated on the 
overall ELV level (due to similar approach for all materials) are introduced in Table 3-61. The 
reporting schemes varied among MS, since its structure is defined by each MS by itself, thus 
the estimations done for the calculation of administrative costs are rather rough.  

Table 3-61 Yearly Admin. Costs (AC) for the Waste management sector and MS 
related to reporting (~12 000 ATFs (Elliott et al. 2019), 500 shredders and recyclers278) 

Activity 

Type of obligation 

Days of work 

ATF Reporting to MS authority on 
dismantled parts/components for 
reuse/remanufacturing  
MS Reporting on treated ELVS to 
Eurostat 
Repair shops 

Submission of (recurring) 
reports  

Submission of (recurring) 
reports  
Types of obligation 

MS Reporting on treated ELVS to 
Eurostat 
ATF Reporting to MS authority on 
mandatory dismantled 
parts/components either for 
reuse/remanufacturing or for recycling 
MS Reporting on treated ELVs to 
Eurostat 
Reporting obligation on PST capacities  Submission of (recurring) 

Inspection on behalf of 
public authorities  
Submission of (recurring) 
reports  

Submission of (recurring) 
reports  

MS Reporting on treated ELVs to 
Eurostat 
Recycler reporting on quality of 
smelted steel batches 
MS Reporting quality of steel 
recyclates to MS 
Reporting obligation on the quality of 
residues (POP content) 
MS Reporting on treated ELVS to 
Eurostat 
Waste operators/EPR reporting on 
treated ELVs to MS authorities 
("calculation point") 
MS Reporting on treated ELVS to 
Eurostat ("calculation point") 

reports  
Submission of (recurring) 
reports  
Submission of (recurring) 
reports  
Submission of (recurring) 
reports  
Submission of (recurring) 
reports  
Submission of (recurring) 
reports  
Submission of (recurring) 
reports  

Submission of (recurring) 
reports  

Total AC 
(€) 
1.976.395 

2.223 

1* 

1* 

52** 

108.392.924 

3 

1* 

1* 

1 

1 

12 

1 

1 

1 

25.014 

1.482.296 

1.668 

57.645 

11.117 

123.525 

11.117 

57.645 

8.338 

1*** 

12.451.290 

1*** 

3.127 

Assumption: (*) reporting effort assumed similar to baseline, with increasing additional effort per scenario due to changes in 
format and need to review additional documentation of waste management operators. (**) additional effort for ATFs due to 
reporting. (***) increased reporting effort due to complexity of reporting on material specific target and related calculation point. 
Further assumptions in Annex. 
Source:  

Table 6-17 (Annex I). 

278 According to (Mc Kenna 2014) a total of 352 “automotive shredders” were operating in the EU-28 and Norway in 2014, 
however this includes 47 UK shredders. 300 automotive shredders were assumed to be active in the EU in 2035 and 200 
more recyclers relevant for this material. 

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3.1.11.2.3  Social impacts 

Together with higher dismantling costs it is to be assumed that there shall be an increase in 
the number of jobs needed to perform dismantling work. The potential additional jobs were 
introduced under the sections for the specific material analysis and are not reproduced here 
to avoid double counting.  

3.1.12  Comparison of the options 

Based on the results of the material/component specific analysis above, the policy options 
initially compiled under Section 3.1.2 were revised and specified so that in each policy option 
includes measures to address the various materials/components and the vehicle level. 

Three  revised  options  are  proposed  and  detailed  in  the  following  table  in  terms  of  the 
measures included and materials and components addressed: 

•  The better compliance PO, 
•  The increased harmonisation PO, and  
•  The advanced implementation PO. 

Table 3-62 Options for comparison of circularity objective 

PO 1 - Better compliance  PO 2 - Increased 

Production  Adaptation of 3R to the new 

Framework Regulation + 
definition of vehicle type 
2.1.d) Review of standard for 
calculation of 3R rates + 2.1.e) 
life cycle data 
2.1.i) OEM Provision of 
dismantling information to ATFs 
2.2.b) OEM Hazardous 
substance declaration   
2.1.c) OEM Circularity strategy  

Design 

2.2.a) Restrictions and 
exemptions remain under ELV 

Reuse 

2.3.a) Reuse definitions  
2.3.b) Remanufacturing 
definitions 
2.3.f).Reuse monitoring 

harmonisation (preferred) 

Adaptation of 3R to the new 
Framework Regulation + 
definition of vehicle type 
2.1.d) Review of standard for 
calculation of 3R rates + 2.1.e) 
life cycle data 
2.1.i) OEM Provision of 
dismantling information to ATFs 
2.2.b) OEM Hazardous 
substance declaration   
2.1.c) OEM Circularity strategy  
2.1.g) Recycled content 
declaration 
2.2.a) Hybrid: 4 Heavy metals + 
exemptions under ELV, further 
prohibitions under REACH  
2.1.g) High recycled content 
targets for plastics 
25% in 2030 and 30% in 2035, 
25% of which closed loop 
2.3.a) Reuse definitions  
2.3.b) Remanufacturing 
definitions 
2.3.e) Reuse support of market 
2.3.f).Reuse monitoring 

PO 3 - advanced 
implementation 

Adaptation of 3R to the new 
Framework Regulation + 
definition of vehicle type 
2.1.d) Review of standard for 
calculation of 3R rates +  
2.1.e) life cycle data 
2.1.i) DPP: OEM Provision of 
dismantling information to ATFs 
2.2.b) DPP: OEM Hazardous 
substance declaration   
2.1.c) OEM Circularity strategy  
2.1.g) Recycled content 
declaration 
2.2.a) Restrictions and 
exemptions moved to REACH 
2.1.g) High recycled content 
targets for plastics 
 30% in 2030 and 35% in 2035, 
25% of which closed loop 

2.3.a) Reuse definitions  
2.3.b) Remanufacturing 
definitions 
2.3.e) Reuse support of market 
2.3.f).Reuse monitoring 

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PO 1 - Better compliance  PO 2 - Increased 

harmonisation (preferred) 

PO 3 - advanced 
implementation 

Recycling  2.4.a WFD definition, excluding 

backfilling 
2.3.e) introduce calculation 
point 
2.3.f) Reporting requirements 

2.4.b) Obligatory dismantling: 
glass windows, wire harness, 
EEC (PWBs with a surface area 
> 10 cm2, PV panels with a 
surface area >0.2 m2, 
controllers), Mono-material 
aluminium components with a 
weight above 10 kg.  
2.3.e) Ban of disposal or 
landfilling (non-inert) 
2.3.e) Introduce calculation point 
2.3.f) Reporting requirements 

Assumed to contribute to a level 
of 0.2% copper impurities in steel 
scrap 

2.4.a WFD definition, excluding 
downcycling 
2.4.b) Obligatory dismantling: 
engines, wire harness and 
large mono material copper, 
EEC (PWBs with a surface area 
> 10 cm2, PV panels with a 
surface area > 0.2 m2, 
controllers, engine motors), 
Mono-material aluminium 
components with a weight 
above 5 kg, NdFeB magnets*, 
non-recyclables. 
2.4.c) Material specific targets: 
glass 70%, plastic 30% 
2.4.d) Shredder operation 
requirement + PST to reduce 
metallic content + deflagration 
requirements + PST reporting 
2.3.e) introduce calculation 
point 
2.3.f) Reporting requirements 

Assumed to contribute to a 
level of 0.1% copper impurities 
in steel scrap 

*Review of NdFeB not part of this study – impacts not assessed so far. 

The following table summarises the main costs and benefits of each of the three policy options 
on this basis. The period calculated for is 2035 and the calculation is based on the number of 
collected ELVs expected to derive in that year. In most cases such calculations are based on 
all ELVs, in specific cases (as explained in the sections above, the calculations may have 
considered only the share of EVs or may have made different assumptions for the different 
vehicle categories (ICE, EV, hybrids and plug-in hybrids). 

In  terms  of  environmental  impacts,  global  warming  potential  is  referred  to  in  terms  of 
environmental credits and burdens related to various scenarios and the baseline. The scope 
of this analysis considers the amounts of gained materials in reused spare parts, amounts of 
materials recycled and/or recovered for each scenario and for the baseline. These amounts 
are considered as environmental credits. As well, the obtained CO2-eq refer to environmental 
burdens from treatment processes, i.e. final treatment of recycling losses.  

Hazardous  substances  avoided  are  referred  to  in  relation  to  scenarios  in  which  the 
prohibitions of such substances are affected.  

Finally,  the  table  also  refers  to  impacts  in  terms  of  the  difference  in  tonnage  of  recycled 
materials obtained from various scenarios and the baseline. Though it can be argued that this 
reflects also GWP differences and may thus be a form of double counting, the intention is to 
allow  a  better  understanding  of  how  the  scenarios  contribute  (or  not)  to  the  objectives  of 
circular economy. Averting from primary materials to secondary ones can also be considered 
to  have  environmental  benefits  that  are  not  reflected  on  the  GWP  indicator:  Mining  and 
processing of new materials are often associated with changes of the natural environment 
and in some cases also with pollution of the environment, when substandard practices are 
applied. Mining activities can also have a social impact when performed in countries where 
e.g.,  children  labour  is  still  common.  Such  impacts  could  not  be  quantified  and  thus  the 
reference to increases in secondary materials provides an indication of their relevance, while 

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also showing the contribution of policy options to the objective of circularity. Furthermore, the 
different environmental impacts are not referred to additively as the units differ – thus avoiding 
the risk of double counting. 

Some  of  the  measures  target  an  improvement  in  the  quality  of  materials  recycled  from 
vehicles and not just an increase in quantity. Subsequently, under the different policy options, 
for some materials the table refers not just to the total quantity, but to the shares of material 
recovered  at  low,  moderate  and  high  quality.  This  method  of  notation  is  used  here  for 
simplicity  and  also  for  unification,  whereas  the  sections  dealing  with  the  analysis  at  the 
material specific level give an indication of what types of quality may result from the waste 
management under different scenarios. Generally, high quality represents vehicle grade and 
equivalent and refers to a level that can be used for manufacture in vehicles. Low quality is 
used when the material is downcycled significantly. The moderate level may be relevant only 
for some materials, where levels exist in between these two extremes (not always the case). 
For  example,  glass  recycled  after  the  shredder  can  currently  only  be  applied  for  uses 
considered as downcycling. This is referred to as low quality. When glass is dismantled it can 
be  separated  and  used  for  manufacture  of  container  glass.  This  is  considered  moderate 
quality  as  it  is  currently  not  feasible  to  recycle  such  glass  so  that  it  could  be  used  for 
manufacture of window glass in vehicles, considered as high quality. For steel in contrast only 
two levels are distinguished. 

The  different  recycling  qualities  have  a  financial  significance  which  is  captured  in  the 
calculation of revenues from recycled material. From an economic perspective, an increase 
in quality also has an importance for reducing the dependency of the EU on other countries 
for the production of resources, however at present it is not possible to quantify such impacts. 
This  difference  can  also  be  considered  to  have  an  environmental  significance,  as  where 
recycled  materials  cannot  be  used,  primary  ones  would  need  to  be  produced.  However, 
where there is not a surplus of low- or moderate-quality materials, primary materials would 
need to be used anyway (i.e., where their supply is matched with the demand). For example, 
in the case of moderate quality steel that can be used on construction as is but that would 
need to be diluted with primary steel for vehicle manufacture), as long as there is demand for 
moderate  quality  steel  in  construction,  primary  steel  will  need  to  be  produced  anyway  and 
could be used in the vehicle sector. Respectively there is limited LCA data that reflect the 
environmental  differences  between  different  qualities  of  material  (very  small  difference). 
Thus,  the  indication  of  quantities  is  used  to  also  indicate  related  impacts  that  cannot  be 
quantified,  i.e.,  in  terms  of  various  secondary  steel  qualities  with  higher  or  lower  carbon 
content.    

In the table below, when referring to monetary impacts, the minus symbol is used when a 
cost is referred to (a negative monetary impact) and a plus when a benefit is referred to (a 
positive monetary impact). In a few cases, certain values appear more than once in the table. 
For  example,  the  revenues  from  sales  of  recovered  material  are  considered  a  benefit  of 
recyclers,  but  also  appear  alongside  the  tonnage  values  that  are  referred  to  under  the 
category “envi. Secondary materials”, as they provide an indication for the level of benefit in 
monetary terms. In the latter case, the values thus appear in red. In other words, whenever 
values appear more than once, repetition will be in red. For the case that the values under 
each  scenario  are  to  be  aggregated,  red  values  should  be  disregarded  to  avoid  double 
counting. 

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Table 3-63 Compiled results of comparison of the options for comparison of circularity objective 

Impact 
category 

Envi: GWP and 
other 

Material/ 
Vehicle 

Non-recyclables 

Option 1 - Better compliance 

Option 2 - Increased harmonisation 
(preferred) 

Option 3 - advanced implementation 

CO2 eq. emissions: no change expected but 
benefit of non-recyclables in use phase ensured 
Recycling credits similar to baseline 
Negligible 

CO2 eq. emissions: -/- 
Recycling credits: Similar to baseline 
Negligible 

CO2 eq. emissions: -/- 
Recycling credits: In the mid- to long-term, recycling 
will lead to increase in credits and circularity  
+ 

Steel 

Copper 

Aluminium 

Glass 

Plastic 

EEC 

Hazardous 
substances 

Increase in credits from reuse/rem.: ~570 Mt 
CO2-eq. 
++ 
Increase in credits: ~65 Mt CO2-eq. 
++ 
Increase in credits from reuse/rem.: ~693 Mt 
CO2-eq. 
++ 

Increase in credits from reuse/rem.: ~581 Mt 
CO2-eq. 
++ 
Increase in credits: ~130 Mt CO2-eq. 
++ 
Increase in credits from reuse/rem.: ~1,990 Mt 
CO2-eq. 
++ 

Increase in credits from reuse/rem.: ~589 Mt CO2-eq. 
++ 

Increase in credits: ~67 Mt CO2-eq. 
++ 
Increase in credits from reuse/rem.: ~1,307 Mt CO2-
eq. 
++ 

Increase in credits from recycling: ~4,000 t CO2-
eq. 
(negligible) 

Increase in credits from recycling: ~126,000 t 
CO2-eq. 
++ 

Increase in credits from recycling: ~126,000 t CO2-
eq. 
++ 

Additional 758 thousand tonne in credits 
Moderate decrease in hazardous substance 
emissions related to plastics 

Additional 661 thousand tonnes in credits 
Moderate decrease in hazardous substance 
emissions related to plastics 

For inverter: Moderate increase in credits of 11% 
(15,000 tonnes CO2 eq) in comparison to 
baseline scenario 
For sub-set of components: increase in 
environmental credits – unknown range 
+ 

Benefits in a range between the other two 
scenarios 
++ 

For inverter: Larger increase in credits of 26% 
(36,000 tonnes CO2 eq) in comparison to baseline 
scenario 
For sub-set of components: increase in a rage of 49-
120% in environmental credits 
+++ 

Benefits for the substances already prohibited 
under ELV have already incurred for the most 
part. 
Benefits expected for future restrictions, 
depending in range on applications in which 
substances to be restricted in the future are 
applied, as well as on the difficulty or ease of their 
substitution. 

Benefits for the substances prohibited under ELV 
have already incurred for the most part. 
Benefits expected for future restrictions under 
REACH, depending in range on applications in 
which substances to be restricted in the future are 
applied, as well as on the difficulty or ease of their 
substitution. 

Benefits for environmental health are expected if the 
future regulation of substances in vehicles enables 
the prohibition of additional hazardous substances, 
depending in range on applications in which 
substances to be restricted in the future are applied, 
as well as on the difficulty or ease of their substitution  

Envi: secondary 
materials 

Vehicle level design  Small increase in the share of vehicle that comply 
with the 3R, raising the reuse and recycling level 

Small increase in the share of vehicle that comply 
with the 3R, raising the reuse and recycling level 

Small increase in the share of vehicle that comply 
with the 3R, raising the reuse and recycling level a bit 

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Impact 
category 

Material/ 
Vehicle 

Option 1 - Better compliance 

a bit above 4% in comparison to baseline 
Between + and ++ 
Decrease in the use of resources for manufacture 
of new parts due to increased reuse 
Between + and ++ 

Option 2 - Increased harmonisation 
(preferred) 
a bit above 4% in comparison to baseline 
Between + and ++ 
Decrease in the use of resources for manufacture 
of new parts due to increased reuse 
Between + and ++ 
Small increase in circularity in the long run 
Between 0 and + 

Changes considered negligible 

Non-recyclables 

Steel 

Copper 

Aluminium 

Glass 

Plastic 

EEC 

Copper impurities in scrap < 0.4% 
Decrease in availability of secondary steel (- 46 
thousand €) due to increase in reuse 
- 

Copper impurities in scrap ≤ 0.2% 
Decrease in availability of secondary steel (- 45 
thousand €) due to increase in reuse 
- 

Decrease in availability of secondary copper (-4 
thousand €) due to increase in reuse 
- 
Decrease in availability of secondary aluminium (-
44thousand €) due to increase in reuse 
- 
Small increase in availability of secondary glass 
for high-quality applications 
4.4 thousand tonnes 

Increase in availability of secondary copper (+3 
thousand €) thanks to higher dismantling 
+ 
Decrease in availability of secondary aluminium (-
40 thousand €) due to increase in reuse 
- 
Large increase in availability of secondary glass 
for high-quality applications 
131 thousand tonnes 

Moderate increase in availability of secondary 
precious metals for manufacture and in the 
availability of reused parts, benefiting ATFs and 
indirectly repair shops and consumers 
+ 

ATFs 

Vehicle level design  Some costs for additional dismantling but 

assumed to be set-off by benefits for selling 
components for reuse and scrap for recycling 
Between + and ++ 

Total additional SRM = 130 thousand tonnes 
SRM from dismantling (higher quality assumed) = 
54 thousand tonnes  
Benefits in a range between the other two 
scenarios 
++ 

Some costs for additional dismantling but 
assumed to be set-off by benefits for selling 
components for reuse and scrap for recycling 
Between + and ++ 
Indirect benefits from OEMs strategies in the long 
term, as vehicles become more circular 
+  

401 

Option 3 - advanced implementation 

above 4% in comparison to baseline 
Between + and ++ 
Decrease in the use of resources for manufacture of 
new parts due to increased reuse 
Between + and ++ 
Small increase in circularity in the long run 
Between 0 and + 
Benefit related to declaration not expected 
n.a 
Increase in SRM in moderate- to long term where 
recycling technologies develop 
+ 
Copper impurities in scrap ≤ 0.1% 
Decrease in availability of secondary steel (- 45 
thousand €) due to increase in reuse 
However, the secondary steel is of high-quality 
++ 
Increase in availability of secondary copper (+2 
thousand €) thanks to better sorting  
++ 
Decrease in availability of secondary aluminium (-64 
thousand €) due to increase in reuse 
++ 
Large increase in availability of secondary glass for 
high-quality applications 
131 thousand tonnes 

Total additional SRM = 160 thousand tonnes 
SRM from dismantling (higher quality assumed) = 67 
thousand tonnes  
Large increase in availability of secondary precious 
metals for manufacture and in the availability of 
reused parts, benefiting ATFs and indirectly repair 
shops and consumers  
+++ 

Some costs for additional dismantling but assumed to 
be set-off by benefits for selling components for reuse 
and scrap for recycling 
Between + and ++ 
Indirect benefits from OEMs strategies in the long 
term, as vehicles become more circular 
+  
Benefit related to declaration not expected 
n.a 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
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Impact 
category 

Material/ 
Vehicle 

Option 1 - Better compliance 

Option 2 - Increased harmonisation 
(preferred) 

Option 3 - advanced implementation 

Non-recyclables 

n.a - no dismantling assumed 

n.a - no dismantling assumed 

Steel 

Copper 

7 million € costs due to additional dismantling 
(comparing to the baseline) 
Additional revenues for dismantled parts/comp. 
for reuse/rem. and separate recycling (+60 mln €) 
-- 

zero costs due to additional dismantling 
(comparing to the baseline) 
Additional revenues for dismantled parts/comp. 
for reuse/rem. and separate recycling (+104 mln 
€) 
-- / + 

Aluminium 

7 million € costs due to additional dismantling 
Additional revenues for dismantled parts/comp. 
for reuse/rem. and separate recycling (+43 mln €) 
-- 

Glass 

Plastic 

EEC 

Additional dismantling costs of 0.76 million € due 
to additional dismantling  
Additional revenues for dismantled glass cullet for 
reuse recycling (+0.04 mln €) 
- 
n.a 

-38 million € additional dismantling costs, benefits 
from reuse related revenues unclear but expected 
to set off costs  
Between 0 and + 

Shredders/PST 

Vehicle level design  Possible decrease in shredder inputs where more 

dismantling takes place 
- 

402 

48 million € costs due to additional dismantling 
(comparing to the baseline) 
Additional investment cost in dismantling 
technologies  
Additional revenues for dismantled parts/comp. 
for reuse/rem. and separate recycling (+131 mln 
€) 
--- / + 
104 million € costs due to additional dismantling 
(comparing to the baseline) 
Additional investment cost in dismantling 
technologies 
Additional revenues for dismantled parts/comp. 
for reuse/rem. and separate recycling (+424 mln 
€) 
--- / +++ 
48 million € costs due to additional dismantling  
Additional investment cost in dismantling 
technologies  
Additional revenues for dismantled parts/comp. 
for reuse/rem. and separate recycling (+309 mln 
€) 
--- / + 
Additional dismantling costs of 23 million € due to 
additional dismantling  
Additional revenues for dismantled glass cullet for 
reuse recycling (+1.3 mln €) 
- - - 
Additional costs for dismantling ≥ -4.3 million € 
(depends if PST requirements suffice to support 
closed loop recycling)  
Dismantling costs and benefits form sales for 
reuse in a range between the other two scenarios 
(calculated average -93 million €) 

Possible decrease in shredder inputs where more 
dismantling takes place 
- 
Unclear impact of strategies, depending on how 

Increase in costs for dismantling of CFRP 
- 
Possible set-off when/where CFRP can be recycled, 
moderate- to long-term 
Between 0 to + 
31 million € costs due to additional dismantling 
(comparing to the baseline) 
Additional investment cost in dismantling technologies  
Additional revenues for dismantled parts/comp. for 
reuse/rem. and separate recycling (+181 mln €) 
--- / + 

98 million € costs due to additional dismantling 
(comparing to the baseline) 
Additional investment cost in dismantling technologies 
Additional revenues for dismantled parts/comp. for 
reuse/rem. and separate recycling (+264 mln €) 
-- / ++ 

31 million € costs due to additional dismantling   
Additional investment cost in dismantling technologies  
Additional revenues for dismantled parts/comp. for 
reuse/rem. and separate recycling (+122 mln €) 
--- / + 

Additional dismantling costs of 23 million € due to 
additional dismantling  
Additional revenues for dismantled glass cullet for 
reuse recycling (+1.3 mln €) 
- - - 
Additional costs for dismantling of -5.4 million € 

-147 million € additional dismantling costs, benefits 
(revenues for reuse) unclear but expected to set off at 
least 26 million € of dismantling costs  
Between - and + 
Possible decrease in shredder inputs where more 
dismantling takes place 
- 
Unclear impact of strategies, depending on how 
vehicles become more circular 

 
  
  
  
  
STUDY TO SUPPORT THE IMPACT ASSESSMENT  
FOR THE REVIEW OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

Impact 
category 

Material/ 
Vehicle 

Option 1 - Better compliance 

Non-recyclables 

Steel 

Shredders/PST operators may need to develop 
some form of treatment to ensure targets are 
complied with, expected in the long term if at all 
Between 0 to + 
Loss of shredding material (loss of revenue) 
Decrease in revenues for steel scrap (-140 mln €) 
- 

Option 2 - Increased harmonisation 
(preferred) 
vehicles become more circular 
-/- 

Non-recyclables assumed to be sent to recovery 
or backfilling with non-recoverable plastics - no 
special treatment, n.a 

Loss of shredding material (loss of revenue)  
Decrease in revenues for steel scrap (-209 mln €) 
-- 

Copper 

Loss of shredding material (loss of revenue) 
Decrease in revenues for copper scrap (-129 mln 
€) 
- 

Loss of shredding material (loss of revenue)  
Significant decrease in revenues for copper scrap 
(-408 mln €) 
-- 

Aluminium 

Decrease in revenues for material scrap (-78 mln 
€) 
- 

Decrease in revenues for material scrap (-296 
mln €) 
-- 

Glass 

Plastic 

EEC 

Loss of shredding material set-off by lower 
maintenance costs (0.3 million € additional 
revenues) 
negligible 

Loss of shredding material set-off by lower 
maintenance costs (loss of 1 million € revenues) 
between 0 and - 

Additional operation costs at least 8.4 million € 
(depends on PST requirements suffice to support 
closed loop recycling)  

Option 3 - advanced implementation 

-/- 
Benefit related to declaration not expected 
n.a 
Non-recyclables dismantled, n.a 

Loss of shredding material (loss of revenue) 
Additional investment costs in separation 
technologies and hand picking 
Assuming the price for high-quality secondary steel 
the same as for the cast steel, there will occur 
decrease in revenues for steel scrap (-259 mln Euro). 
However, the secondary steel is of high-quality and 
potentially of higher price (higher revenues)  
--- / +++ 
Loss of shredding material (loss of revenue) 
Additional investment costs in separation 
technologies and hand picking 
Increase of secondary copper  
However, still decrease in revenues for copper scrap 
(-252 mln €) 
--- 
Additional investment costs in separation 
technologies and hand picking 
Decrease in revenues for material scrap (-164 mln €) 
--- / +++ 
Loss of shredding material set-off by lower 
maintenance costs (loss of 1 million € revenues) 

between 0 and - 
 Additional operation costs of 10.2 million €, 

Loss of shredding material (loss of revenue) 
- 

Loss of shredding material (loss of revenue) 
in a range between the other two scenarios 

Loss of shredding material (loss of revenue) 
-- 

Recyclers 

Vehicle level design  Possible increase in revenues where dismantling 

for separate recycling increases  
Between 0 to + 

Possible increase in revenues where dismantling 
for separate recycling increases  
Between 0 to + 
Unclear impact of strategies, depending on how 
vehicles become more circular-/- 

Possible increase in revenues where dismantling for 
separate recycling increases  
Between 0 to + 
Unclear impact of strategies, depending on how 
vehicles become more circular 
-/- 

403 

 
  
  
  
 
  
 
  
  
  
  
  
STUDY TO SUPPORT THE IMPACT ASSESSMENT  
FOR THE REVIEW OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

Impact 
category 

Material/ 
Vehicle 

Option 1 - Better compliance 

Option 2 - Increased harmonisation 
(preferred) 

Option 3 - advanced implementation 

Non-recyclables 

Steel 

Copper 

Aluminium 

Glass 

Plastic 

EEC 

Plastic 

Possible investments in CFRP recycling 
capacities (one time investment) expected in the 
long term. However, then set off by revenues 
between 0 and + 
Copper impurities in scrap < 0.4% 
Small decrease in business, due to loss of steel 
scrap (-79 mln €) 
However, increase in higher quality material 
(dismantled prior shredding) 
+ 

Possible investments in CFRP recycling 
capacities (one time investment) expected in the 
long term. However, then set off by revenues 
Between 0 and + 
Copper impurities in scrap ≤ 0.2% 
Small decrease in business, due to loss of steel 
scrap (-78 mln €) 
However, increase in higher quality material 
(dismantled prior shredding) 
+ 

Small decrease in business, due to loss of copper 
scrap (-25 mln €) 
However, increase in higher quality material 
(dismantled prior shredding) 
+ 

Slightly increase in business, due to increase of 
copper scrap (+16 mln €) 
However, increase in higher quality material 
(dismantled prior shredding) 
+ 

Small decrease in business, due to loss of 
material scrap (-36 mln €) 
However, increase in higher quality material 
(dismantled prior shredding) 
+ 

Small decrease in business, due to loss of 
material scrap (+13 mln €) 
However, increase in higher quality material 
(dismantled prior shredding) 
+ 

Small increase in business (0.08 million €), due to 
glass fraction available for high-quality recycling 
+ 

Higher decrease in business due to less reuse --> 
less secondary material for recycling – however 
impact is only delayed 
- 

Small increase in business (2.4 million €), due to 
glass fraction available for high-quality recycling 
++ 
Additional compounding costs of at least -3.41 
million € and additional revenues of 52 million € 
(depends on PST requirements suffice to support 
closed loop recycling)  
Benefits for recyclers in a range between the 
other two scenarios 
+ 

One-time investments in waste management of 
151.5 million €  

Benefit related to declaration not expected 
n.a 
Non-recyclables dismantled, n.a 

Copper impurities in scrap ≤ 0.1% 
Small decrease in business, due to loss of steel scrap 
(-78 mln €) 
However, huge increase in higher quality material 
(dismantled prior shredding), thus potentially lower 
processing costs to obtain steel of high quality 
++ 
Slightly increase in business, due to increase of 
copper scrap (+12 mln €) 
However, huge increase in higher quality material 
(dismantled prior shredding), thus potentially lower 
processing costs to obtain steel of high quality 
++ 
Small decrease in business, due to loss of material 
scrap (-41 mln €) 
However, increase in higher quality material 
(dismantled prior shredding) 
++ 

Small increase in business (2.4 million €),, due to 
glass fraction available for high-quality recycling 
++ 
 Additional compounding costs of at least -12.3 € and 
additional revenues of 64 million €  

Benefits for recyclers of Fe and Al as copper 
impurities will decrease, increasing quality of 
secondary materials.  
Benefits for EEC recyclers in terms of higher amounts 
of secondary material (copper and precious metals). 
In both cases higher revenues expected  
++ 
One time investments in waste management of 159.9 
million € 

Vehicle level  design  Costs for calculation revision assumed to be low 

and mainly transitional 
Between 0 and - 

Costs for calculation revision assumed to be low 
and mainly transitional 
Between 0 and - 

Costs for calculation revision assumed to be low and 
mainly transitional 
Between 0 and - 

404 

Waste 
management 
investments  
OEMs 

 
  
  
  
  
  
  
STUDY TO SUPPORT THE IMPACT ASSESSMENT  
FOR THE REVIEW OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

Impact 
category 

Material/ 
Vehicle 

Option 1 - Better compliance 

Admin costs of about half a million € for 
implementing dismantling tests  
Costs from provision of data unknown 
Between - and --- 

Non-recyclables 

Costs for preparing and submitting life cycle data 
based evidence 
Negligible 

Plastic 

Vehicle owners 

Vehicle level EoL 

Jobs 

Vehicle level design 

As the market demand for reused/remanufactured 
parts is expected to increase, consumers will 
have reduced costs for repairs where they apply 
such parts. 
+++ 
Increase in type approval service provider and 
ATF/shredder employment of around 4 jobs for 
dismantling tests 
+ 
Increase in Type approval authority and EC 
employment, estimated at less than one job 
Between 0 and + 
Increase in ATF employment due to additional 
dismantling – level unknown 
Between + and ++ 

405 

Option 2 - Increased harmonisation 
(preferred) 
Admin costs of about half a million € for 
implementing dismantling tests  
Costs from provision of data unknown 
Between - and --- 
Administrative costs for developing and revising 
strategy and for implementation in the mid-long 
term 
Between - and -- 
Administrative costs for declaring rate of recycled 
content, possibly negligible: 
Between 0 and - 
Costs for ensuring treatment if required by EPR 
(see below): it could be considered to 
compensate e.g., to allow shredder/PST 
operators that separate the non-recyclable 
fraction to require the OEM to collect and treat the 
material independently and at no cost to the ATF  

Additional production costs for use of recycled 
content 64 €/vehicle  
OEMs may have costs for 
declarations/certification; however these are 
understood to be very small  

The obligatory dismantling of components could 
support more reuse where demand exists, 
consumers will have reduced costs for repairs 
where they apply such parts. 
+ 
Increase in type approval service provider and 
ATF/shredder employment of around 4 jobs for 
dismantling tests 
+ 
Increase in Type approval authority and EC 
employment, estimated at less than one job 
Between 0 and + 
Increase in ATF employment due to additional 
dismantling – level unknown 
Between + and ++ 
Increase in employment at OEMs for developing 
and implementing circularity strategy 
Between + and ++ 

Option 3 - advanced implementation 

Admin costs of about half a million € for implementing 
dismantling tests  
Costs from provision of data unknown, possibly 
higher if DPP is required 
Between - and --- 
Administrative costs for developing and revising 
strategy and for implementation in the mid-long term 
Between - and -- 
Administrative costs for declaring rate of recycled 
content, possibly negligible: 
Between 0 and - 
Costs for ensuring treatment / take-back of non-
recyclables if required by EPR: it could be considered 
to compensate e.g., ATFs for storage costs, or to 
allow ATFs (or shredder/PST operators) that separate 
the non-recyclable fraction to require the OEM to 
collect and treat the material independently and at no 
cost to the ATF 
Additional production costs for use of recycled 
content 64 €/vehicle  
OEMs may have costs for declarations/certification; 
however these are understood to be very small  

The obligatory dismantling of components could 
support more reuse where demand exists, consumers 
will have reduced costs for repairs where they apply 
such parts. 
+ 
Increase in type approval service provider and 
ATF/shredder employment of around 4 jobs for 
dismantling tests 
+ 
Increase in Type approval authority and EC 
employment, estimated at less than one job 
Between 0 and + 
Increase in ATF employment due to additional 
dismantling – level unknown 
Between + and ++ 
Increase in employment at OEMs for developing and 
implementing circularity strategy 
Between + and ++ 
Increase in employment due to declarations negligible 
-/- 

 
  
  
  
  
  
  
  
  
  
STUDY TO SUPPORT THE IMPACT ASSESSMENT  
FOR THE REVIEW OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

Impact 
category 

Material/ 
Vehicle 

Option 1 - Better compliance 

Non-recyclables 

Increase in employment for preparing life cycle 
data based evidence 

Steel 

Copper 

Increase in jobs in ATF (~86) 
++ 

Option 2 - Increased harmonisation 
(preferred) 

Possible increase in employment for new PST 
capacities (expected in long term) 
Between 0 and + 
Increase in jobs in ATF (~582) 
++ 

Increase in jobs in ATF (~1,195) 
+++ 

Aluminium 

Increase in jobs in ATF (~86) 
++ 

Increase in jobs in ATF (~582) 
++ 

Option 3 - advanced implementation 

Increase in employment for dismantling and new 
recycling capacities  
+ 
Increase in jobs in ATF (~383) 
Increase in jobs in shredder facilities (~360) 
+++ 
Increase in jobs in ATF (~1,195) 
Increase in jobs in shredder facilities (see steel) 
++ 
Increase in jobs in ATF (~383) 
Increase in jobs in shredder facilities (see steel) 
+++ 
Increase in jobs (ca. 645) 

Glass 
Plastic 

EEC 

Hazardous 
substances 

SMEs 

Vehicle level design 
Non-recyclables 

Steel 

Copper 

Aluminium 

Glass 

Plastic 

EEC 

Increase in jobs (ca. 20) 

Increase in jobs (ca. 645) 
Significantly more than 1795 jobs (waste sector)  More than 6,530 jobs (OEMS) and somewhat more 

than 1,795 jobs (waste sector) 
Increase in jobs (~29) for the inverter and in 1,801 
additional jobs for the component sub-set 
++ 

Increase in jobs in a range between the other two 
scenarios 
between + and ++ 

Increase in jobs (~7) for the inverter and in 466 
additional jobs for the component sub-set 
+ 
This requires a total of two, new full-time-
equivalent (FTE) temporary-agent staff (AD 5-7) 
at the ECHA (average cost EUR 144 000/year 
over 7 years and beyond). In addition, one FTE 
contract agent (CA FG III, average cost EUR 69 
000/year over 3 years) will be necessary to 
increase the knowledge base, and to facilitate an 
informed priority setting and work plan. 
Inefficient provision of information assumed to have a larger impact on small and independent ATFs who would be discouraged from using data. 
SMEs are understood to be common among 
waste operators, so any costs for these (ATF, 
shredder, PST, recycler) could have a heavier 
burden for SMEs 
Small ATFs would probably have higher costs than larger ones. With higher dismantling costs the profitability of the business for the ATFs might be 
questionable and possibly the activities of these facilities might shift to illegal activities.  
Small ATFs would probably have higher costs than larger ones. With higher dismantling costs the profitability of the business for the ATFs might be 
questionable and possibly the activities of these facilities might shift to illegal activities. This may depend on the type pf copper components that must be 
dismantled 
Small ATFs would probably have higher costs than larger ones. With higher dismantling costs the profitability of the business for the ATFs might be 
questionable and possibly the activities of these facilities might shift to illegal activities - this may depend on threshold level of Al components to be dismantled 
Small ATFs would probably have higher costs than larger ones 
Costs for dismantling and separate recycling may be higher where the distance to recycling facilities is significantly >150 km 

For ATF SME, the dismantling obligation (scenario CFRP 2) will likely result in higher costs. SMEs are 
understood to be common among waste operators, so any costs for these (ATF, shredder, PST, recycler) 
could have a heavier burden for SMEs 

Small operators may have higher logistics costs assuming they have less storage space, need to send 
plastic scrap batches more often and thus also in smaller batches 

Small ATFs will have higher costs than larger ones 

406 

 
 
  
  
  
  
  
  
  
  
  
  
STUDY TO SUPPORT THE IMPACT ASSESSMENT  
FOR THE REVIEW OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

Impact 
category 

Administrative 
burden 

Material/ 
Vehicle 

Non-recyclables 

Option 1 - Better compliance 

Option 2 - Increased harmonisation 
(preferred) 

Option 3 - advanced implementation 

Increased costs for OEMs where LCA data 
submitted to type-approval process and for 
authorities for reviewing such data 

n.a 

n.a 

Hazardous 
substances 

Vehicle level EoL 

Reduced admin costs for EC/ECHA as only one 
legislation needs to be maintained. 
Member States will have greater clarity and lower 
administrative burden by dealing with the 
technical and socio-economic assessment of the 
proposals for restrictions under one single 
common assessment framework 
Additional burden or ATFs in the order of (-1.97) 
mln € for reporting on components removed for 
reuse. 
Additional burden for repair shops for providing 
proposals referring to reused parts in the order of 
(-108) mln €. 
Additional burden for MS for reporting on reuse in 
the order of (-27,000) € 
Additional burden for reporting on targets by 
EPR/waste operators in the order of (-12.4) mln € 
Additional burden of reporting on targets for MS in 
the order of (-3,000) €  
High increase in administrative burden for 
reporting for regulators and waste management 
--- 

The hybrid is considered to be similar to the 
baseline and should not change the 
administrative burden. 

Most stakeholders involved in prohibition process 
follow REACH in any case. Elimination of ELV will 
reduce burden of legal compliance. 
Reduced admin costs for EC/ECHA as only one 
legislation needs to be maintained. 
No admin costs for MS related to transposition. 

Additional burden for ATFs in the order of (-1.48) 
mln € for reporting on dismantled components. 
Additional burden for MS for reporting on reuse in 
the order of (-1,700) € 
Additional burden for EPR/PST operators for 
reporting on the quality of residues (POP content 
in plastic) in the order of (-57,600) € 
Additional burden for MS for reporting on treated 
ELVS to Eurostat (disposal ban) in the order of (-
8,000) € 
Additional burden for reporting on targets by 
EPR/waste operators in the order of (-12.4 mln €) 
Additional burden of reporting on targets for MS in 
the order of (-3,000) € 
 Moderate increase in administrative burden for 
reporting for regulators and waste management 
and developing of improvement strategies 
-- 

Additional burden form reporting obligation on PST 
capacities for EPR/PST operators, in the order of (-
57,000) € 
MS Reporting obligation on treated ELVs to Eurostat 
in the order of (-11,000) € 
Additional burden for recyclers reporting on quality of 
smelted steel batches, in the order of (-123,000) € 
Additional burden for MS reporting on quality of steel 
recyclates to EUROSTAT in the order of (12,000) € 
Additional burden for reporting on targets by 
EPR/waste operators in the order of (-12.4) mln € 
Additional burden of reporting on targets for MS in the 
order of (-3,000) €  
Moderate increase in administrative burden for 
reporting for regulators and waste management and 
developing of improvement strategies 
-- 

Other 

Targets 

… 

Hazardous 
substances 

There is an expected social benefit because reference to human health protection is added to the ELVD and will be considered for future restriction of 
substances in vehicles.  

reuse and recovery 
rate 
reuse and recycling 
rate 

82% 

76.2% 

87.3% 

78.9% 

86.8% 

77.9% 

*For EEC, results are given for "sub-set" of components unless otherwise specified 

** For non-recyclables under scenario 1: Vehicle placed on the market, no special treatment requirements (i.e., life cycle evidence supports type approval) 

407 

 
  
  
  
  
 
 
 
STUDY TO SUPPORT THE IMPACT ASSESSMENT  
FOR THE REVIEW OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

Total materials reused/recycled/recovered: 

Steel - reused 

Steel – recycled pre-shredder 

Steel – recycled post-shredder 

Copper - reused 

Copper – recycled pre-shredder 

Copper – recycled post-shredder 

Aluminium – reused 

Aluminium – recycled pre-shredder 

Aluminium - recycled post-shredder  

Aluminium – recovered (>steel) 

Glass reuse 

Glass – recycled pre-shredder (high quality) 

Glass – recycled post-shredder (low quality) 

Plastic reuse 

Plastic recycled pre-shredder (high quality) 

Plastic – recycled post-shredder (low quality) 

Plastic - recovered  

EEC recycled separately 

489,000 

323,000 

-746,000 

10,000 

17,000 

-21,000 

62,000 

37,000 

-81,000 

-9,000 

0 

4,000 

-5,000 

0 

0 

0 

0 

 787  

489,000 

699,000 

-1,118,000 

12,000 

67,000 

-65,000 

99,000 

266,000 

-306,000 

-30,000 

0 

131,000 

-131,000 

71,000 

54,000 

76,000 

-149,000 

in between 

489,000 

968,000 

-1,385,000 

12,000 

42,000 

-40,000 

99,000 

105,000 

-169,000 

-18,000 

0 

131,000 

-131,000 

71,000 

67,000 

93,000 

-220,000 

 7,220  

408 

 
 
STUDY TO SUPPORT THE IMPACT ASSESSMENT  
FOR THE REVIEW OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

The  impacts  compiled  for  the  three  options  in  the  table  above  are  based  on  the  analysis 
performed in the sections above and the impacts specified therein.  

3.1.13  Conclusions and the preferable option 

In some cases, some overlaps or synergies may exist, for example, measure 2.3.e (Ban of 
disposal  or  landfilling  (non-inerts))  would  require  development  of  PST  facilities  in  the  EU 
where they are not available and in some cases their improvement or expansion. In this case, 
such facilities would have a focus on the recovery and recycling of plastic fractions, however 
the fact that PST technologies are developed and improved can also be assumed to have an 
effect  on  measure  2.4.d,  which  specifies  shredder  operation  requirements  with  an  aim  to 
reduce metallic content.  

The same is true for example for measures addressing the dismantling of EEC, which often 
contains  copper  but  also  other  base  metals  like  steel  and  aluminium.  Dismantling  and 
recycling of such components will also have an effect on the recovery of steel, copper and 
aluminium. In cases, where multiple measures would lead to the same treatment route (e.g., 
dismantling  of  copper-based  EEC  in  copper  measures  or  its  dismantling  under  EEC 
measures) an overlap is assumed, meaning that should the impacts be summed, they would 
be expected to represent a bit of an overestimation due to double counting. In other cases, 
like  in  the  first  case  of  the  different  measures  affecting  the  capacities  of  PST,  some  post 
shredder technologies could improve plastic sorting, some could improve metal sorting, and 
some  could  improve  both.  Thus,  here  in  some  cases  synergies  may  exist  but  also  some 
overlap.  For  this  reason,  an  attempt  to  sum  the  impacts  is  not  undertaken.  Instead,  the 
impacts  have  been  colour  coded  so  that  it  is  more  apparent  in  which  cases  the  costs  are 
highest (darker red) and in which case the benefits are the highest (darker green) and vice 
versa.  

The comparison shows that it is difficult to distinguish between PO 2 and PO 3, both showing 
higher benefits but often also higher costs and differing from each other for various materials 
or impact categories. Both of these policy options are considered to be effective in terms of 
achieving the objectives to a large degree. PO 1 is considered less effective, as though the 
costs are usually low, the benefits achieved are also quite under-reaching in comparison.  

Since  at  present  the  ELVD  sets  out  an  annual  common  (for  all  materials)  recycling  target 
based on the average weight of the vehicle, not all the materials used in vehicles are subject 
to the same high standard of recycling. While high-quality recycling can often be technically 
feasible  and  environmentally  beneficial  (e.g.,  of  glass,  selected  plastics,  electronic 
components), it is not performed in cases with low or lacking profitability.  

In general, the higher availability of recyclables on the EU market will lower the dependability 
of the EU on extra-EU sources (primary but also secondary in some cases). With the current 
war  in  Ukraine  and  lacking  clarity  on  further  geo-political  developments,  this  reduction  in 
dependency is not only an advantage for the EU in general but could also reduce supply risks 
for  the  European  automotive  industry  (or  other  manufacturers).  This  has  already  become 
clear at the beginning of the war in regard to the supply of copper from the Ukraine which 
delayed assembly where wire harnesses were not available. This is an important motive not 
just for  recycling  in  general  but  also for the  options  that  lead  to  increases  in the  quality  of 
recyclates.  

For example, looking at the analysis for steel and copper, whereas for many categories both 
PO 2 and 3 show a similar relation of costs and benefits, it seems that PO 2 leads to higher 
credits,  meaning  that  in  general  this  PO  is  more  effective  for  copper.  However,  looking  at 
steel, PO 3 is assumed to lead to higher benefits as the quality of steel scrap shall improve 
and increase the range of applications for which it can be used significantly. This may not be 

409 

 
STUDY TO SUPPORT THE IMPACT ASSESSMENT  
FOR THE REVIEW OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

as important at present, as steel scrap can be used where cast steel is needed, however in 
the future, a surplus of cast alloys is expected and this means that actual benefits will be more 
significant in the long run, even if on the surface the levels are similar. 

For aluminium, it is clear that measures are relevant. Despite the fact that one of the PO may 
show higher benefits than others, data is still missing to consider how such measures should 
be characterised in detail. 

For glass, though PO 2 and PO 3 deliver benefits in the same order, main differences are 
expected in favour of PO 2 due to the reduced complexity of monitoring.  

For plastics, GWP impacts are not so high, however the benefits in term of SRM would feed 
into  the  manufacture  of  vehicles  and  allow  reducing  the  dependency  on  primary  materials 
and thus solving the current market failure. Though POC 3 may suggest higher benefits, it 
will also have higher costs. Whether this is justified or not is hard to say, but it could also be 
considered to use the elements of PO 2 and PO 3 to develop an increasing ambition over 
time. 

For EEC, it is logical that the longer the list of components to be dismantled, thus also the 
higher  the  benefits  can  be  expected  to  be,  in  terms  of  GWP  but  more  importantly  in  the 
contribution to SRM of precious and critical materials. The main question here will be of the 
level  of  costs  that  is  to  be  considered  feasible  for  the  sector  to  support,  either  due  to  the 
expected returns form reuse or recycling or if needed, in relation to the level of compensations 
needed from EPR to ensure the economic feasibility of operations for ATFs. For REE from 
magnets, it is possible that a dismantling obligation alone will not suffice to promote recycling 
and  thus  will  not  result  in  increased  REE  availability  on  the  European  market.  If  the  REE 
cannot  to  be  sorted  and  sufficiently  recovered  from  fractions  after  dismantled  parts  are 
subjected to dedicated shredding of EEC (separate from other equipment) it could be relevant 
to perform deep dismantling of certain EEC to disassemble e.g., magnets prior to shredding 
operations.  

Decisions on which EEC components are to be dismantled depend on the objective. If the 
main  objective  is  to  improve  the  removal  of  copper  impurities  from  Fe  and  Al  scrap  (also 
increasing copper recycling amounts), the dismantling can be considered as an alternative 
for cases where advanced shredding and PST is not applied (giving the waste management 
more flexibility how to achieve related targets, e.g., choosing between technology or labour-
intensive approaches). When the objective is also to improve the recycling of precious and 
critical materials, the importance of dismantling of EEC prior to shredding increases and in 
some  cases  certain sub-components  (e.g., magnets)  should  also  be  considered  to  ensure 
their sufficient recovery. Though for some materials this has an environmental relevance, for 
others it may be more of a geopolitical decision related to the dependency of the EU for supply 
of certain materials 

A further economic aspect is related to the expected administrative cost of reporting. Under 
the baseline, Commission Decision 2005/293/EC, which specifies the current reporting rules, 
already  requires  MS  to  report  on  the  “metal  components”  arising  from  depollution  and 
dismantling in the required format. However, it is required to report a sum of all depolluted 
and dismantled materials and reporting on separately listed materials is voluntary. Some of 
the measures will require adjustment of the reporting format as well as changing the reporting 
from voluntary to mandatory. This adjustment is assumed to result in additional economical 
costs for public administration as well as for ATF that report on removed parts/components. 

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3.1.14  Reporting and monitoring requirements 

To be able to monitor the measures proposed in the chapter above, it will also be necessary 
to consider how the reporting requirements for MS are revised. For several aspects, Oeko-
Institut  developed  a  proposal  for  an  amendment  of  the  reporting  format  in  Commission 
Decision 2005/293/EC and this proposal was shared with the Member States for comments 
accordingly. The feedback of the Member States is available to the contractor and a report 
was  provided  to  the  EC  on  23  May  2019  accordingly279.  Many  of  the  Member  States 
appreciate most of the proposed amendments, but some also question if the mandate in the 
ELVD covers all proposed amendments.  

With regard to future reporting obligations, it should therefore be examined which mandate 
would have to be laid down in the ELVD in order to allow for the necessary amendments to 
Commission  Decision  2005/293/EC.  For  instance,  mentioning  /  defining  terms  like  ‘post 
shredder technology (PST), reporting on the number of (certified) ATFs, shredders and PST 
plants and their input/ output. First issues are mentioned in section 0.  

However, a broader and more detailed consolidation of the mandate for the reporting forms 
is depending on the new measures proposed for implementation. If for instance new (material 
specific) recycling targets shall be introduced, this should also be reflected in the reporting 
requirements. 

Some  of  the  areas  analysed  above  also  provide  insights  as  to  aspects  that  should  be 
addressed  in  the  revision  of  Commission  Decision  2005/293/EC  and  of  any  reporting 
obligations of the ELVS.  

The  issue  of  reporting  on  the  changes  in  the  vehicles  fleet  (PoM,  import/export  of  used 
vehicles,  import/export  of  ELVs,  final  cancellation  of  registrations,  CODs  issued  and 
temporary de-registrations) is addressed in section 2.2.5.1.9 at page 166. 

279 Mehlhart, G.; Hay, D. (2019): Assessment of the comments of the Member States in relation to the draft proposal for the 
amendment of Commission Decision 2005/293/EC Amendment to contract No 07.0201/2015/723374/ETU/ENV.A.2; 
Darmstadt, 23.05.2019 

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3.2  Missing vehicles 

3.2.1  Baseline  

The baseline reflects what would happen under a “non-policy-change” scenario without new 
policy intervention, and assuming realistic implementation of existing legislation. 

For the aspect of missing vehicles and illegal export the situation and problem were manyfold 
discussed with the Member States at different level for instance it was continuously a topic in 
the working group meetings, respectively the TAC meeting for the ELVD. Diverse topics were 
discussed with the Member States like inspection campaigns in UK and Denmark; different 
registration regimes like in Denmark, Norway and the Netherlands; examples how to make 
use of international data exchange on re-registration of vehicles; fraudulent use of registration 
documents for stolen vehicles and last but not least the relevant studies commissioned by the 
EC.  

A report was commissioned by the European Parliament to evaluate the effectiveness of the 
ELV Directive and it detected the issue of the missing vehicles too. (Schneider et al. 2010).A 
report was commissioned by the European Parliament to evaluate the effectiveness of the 
ELV Directive and it detected the issue of the missing vehicles too. (Schneider et al. 2010). 

Regarding the distinction between used vehicles and ELV the correspondents to the Waste 
Shipment regulation established the Correspondents' guidelines No 9, which applies from 1 
September 2011.  

Guidelines for the reporting were published by Eurostat for the first time in 2010, last updated 
in 2019280, also addressing the problem on missing vehicles and how to overcome it. This 
guidance also includes the identification of sources for a more detailed national assessment 
of the whereabout of national ELVs.  

The  EC  launched  an  analysis  in  2010  on  the  European  second-hand  car  market  analysis 
(Mehlhart et al. 2011) which tried to calculate the vehicle balance and the whereabouts of 
ELVs from different available sources – but this approach failed and demonstrated that under 
the given conditions it is by far not possible to demonstrate that all ELVs are treated according 
the requirements of the ELVD. 

The most recent study commissioned by the EC, focussed on the assessment on the end of 
life  vehicles  of  unknown  whereabouts  and  discussed  proposals  how  to  overcome  the 
identified shortcomings of the current legislation with the Member States and in an open public 
consultation  with  other  stakeholders  (Mehlhart  et  al.  2017).  This  study  identified  several 
measures which might be established at national level as well. 

However,  the  EC  tried  for  a  decade  to  reinforce  the  implementation  of  the  ELV  Directive 
without legislative changes. However, this approach is, as demonstrated, not successful. For 
the baseline scenario it is estimated that the situation of 30% to 40% missing vehicles (3 to 4 
million vehicles will persist, without any principal changes).  

As some Member States281 are aiming to implement national specific legislation, we consider 
that the Baseline (for the entire EU) will improve regards the missing vehicles marginally only. 

280 How to report on end-of-life vehicles according to Commission Decision 2005/293/EC, Revision by Eurostat: 17 December 
2019 

281 E.g. France announced to establish an EPR regime which includes the obligation to collected abandoned vehicles.  

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3.2.2  Policy Options 

3.2.2.1  Identification of discarded measures 

With the aim to have a shortlist of measures for further assessment, all measures are checked 
for  legal  or technical  feasibility  and  effectiveness.  This  step  is  not  to  be confused  with  the 
impact assessment itself and therefore does not include all categories of impact assessment 
(economic, social and environmental). 

The  details  of  this  check  for  feasibility  and  effectiveness  are  displayed  in  section  6.6.1  in 
Annex I. In result the following measures are discarded and not shortlisted for the detailed 
assessment:  

•  MS to demonstrate implementation of Incentives, Level B (2.2.5.1.1) 
•  Establish  a  collection  target  based  on  the  reporting  obligations  on  the  national  vehicle 

market (2.2.5.1.10) 

•  Exchange on MS best practice on national implementation and enforcement incl. sector 

inspection campaigns (2.2.5.2.1) 

•  Voluntary  campaigns  on  export  of  ELVs  with  a  focus  on  the  current  waste  shipment 
correspondents’ guidelines No9 on distinction between ELVs and second-hand vehicles 
(2.2.5.2.2) 

•  European-wide deposit refund scheme for vehicles supervised by a single European body 

(2.2.5.2.4) 

•  Promote  international  non-binding  actions  at  the  international  level  (through  UN 

Environmental and road safety programmes) to address the issue (2.2.5.3.1) 

•  Promote  enforcement  actions  by  MS through  EU  funding  and  EU  enforcement  actions 

against environmental crime (2.2.5.3.2) 

The remaining measures are shortlisted and grouped for policy options in following sections.  

3.2.2.2  Policy option 3A: Enhanced reporting & enforcement 

The  policy  option  3A  is  relying  on  enhanced  monitoring  and  reporting  requirements  to 
demonstrate the whereabout of used vehicles and ELVs. The primary responsibility on how 
to achieve that the whereabout of vehicles can be demonstrated remains with the MS, while 
the MS retain a large degree of flexibility on the types of measures to be taken to address the 
problem of missing vehicles. It is expected that this option would raise the least amount of 
concerns related to subsidiarity. Policy option 3A includes the following measures:  

No 

3A1 

3A1 

3A1 

3A2 

3A3 

3A4 

Title 

Reporting by Member States on the current vehicle market 
and the ELVs on their territory  

Reporting and exchange of best practice on incentives in 
force to strengthen the effectiveness of the CoD 
Requirements for Member States to report on penalties 

Obligations for dismantlers /recyclers to check and report on 
ELVs/ CoDs  
Definition of minimum requirements for sector inspections  

Action at international level to support that roadworthiness 
(and others) become criteria for export of used vehicles. 

Chapter 

Effective 
by 

(2.2.5.1.9) 

2025 

(2.2.5.1.1) 
Level A 
(2.2.5.2.7) 
Level A 

(2.2.5.1.5) 

(2.2.5.2.6) 

2025 

2025 

2025 

2025 

(2.2.5.3.1) 

ongoing 

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3.2.2.3  Policy  Option  3B:  Interoperable  national  registers  and 

harmonisation 

This option is aiming to improve collection by: 

•  setting a harmonised approach between the Member States for some aspects linked to 
the national registration of vehicles and the definition of binding criteria on the distinction 
between used vehicles and ELVs (building on existing non-binding guidelines), as well as  
requiring that the national registrations systems be made interoperable.  

• 

Compared  to  option  3A,  this  option  may  reduce  MS  flexibility  by  harmonising  national 
definitions  for  “temporary  deregistration”  and  terms  on  registration  documents,  as  well  as 
setting binding criteria to distinguish used cars and ELVs (for export and accident cars). 

Policy option 3B includes the following measures:  

Title 

Interoperability between national registration authorities including 
obligation for MS to provide reasons for de-registration.  

Alignment of the terms of the ELV Directive with the terms of 
Directive 1999/37/EC  

Introduction of new definition: “temporary de-registration”  

Requirements for Member States to establish penalties 

Binding criteria for a distinction of used vehicles / ELVs 

No 

3B1 

3B2 

3B2 

3B3 

3B4 

Chapter 

Effective 
by 

(2.2.5.1.6) 

2025 

(2.2.5.1.2) 

(2.2.5.1.3) 

(2.2.5.2.7) 
Level B 

(2.2.5.2.5) 

Upon entry 
into force of 
new 
legislation 
Upon entry 
into force of 
new 
legislation 

2025 

Upon entry 
into force of 
new 
legislation 
n.a. 

3B5 

Effective Deposit Refund Scheme (voluntary) 

(2.2.5.2.3) 

3.2.2.4  Policy Option 3C: EU wide vehicle registration and export 

controls: 

This  option  consists  in  fully  harmonising  the  elements  of  the  current  national  registrations 
systems  relevant  for  the  tracking  of  vehicles  by  transferring  them  into  an  EU  system.  In 
addition, this option includes the establishment of new criteria regulating the export of used 
vehicles (which are not ELVs), to ensure better traceability and sustainability of these exports. 
More strict (extra-EU) export criteria, including the mandatory use of the VIN number in export 
documents, based on combined roadworthiness, age, emission level criteria set at EU level.  

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No 

Title 

3C1 

3C2 

EU vehicle registration database-system 
EU wide harmonised registration procedures for vehicles: 

a) conclusive list of conditions for permanent cancellation 
of the registration 
b) regulations for how to apply “temporary de-registrations” 

restrictions 

(Extra-EU)  Export 
to 
roadworthiness,  and  taking  into  consideration  rules  on  age  and 
emission  level  of  vehicles  entitled  to  be  imported  in  certain 
countries 

for  used  cars 

linked 

Chapter 

(2.2.5.1.8) 
(2.2.5.1.4) 

(2.2.5.1.4) 

Effective 
by 
2027 
2027 

2027 

(2.2.5.1.4) 

2027 

2025/2030 

(2.2.5.3.3) 

3C3 

Include  Vehicle 
declaration/control system 

Identification  Number 

(VIN) 

in  customs 

(2.2.5.1.7) 

2027 

3.2.2.5  Overview Policy Options 

Table 3-64 Overview Policy Options and related measures sorted by Objectives 

The numbers refer to the chapter where the potential measures are described 

Red italic letters = discarded measure 

Green box = Policy Options 3A 

Yellow box = Policy Option 3B 

Amber box = Policy Option 3C 

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Objective 3.1:  
Ensure that all ELVs are 
treated in accordance with 
the requirements of the ELV 
Directive 

Objective 3.2:  
Reduce levels of illegal 
dismantling and illegal 
export of ELVs 

1.1a Reporting and exchange 
of best practice on Incentives 
(Level A) 

2.1 Exchange on MS best 

practice 

Objective 3.3: 
Enforceable criteria to avoid 
the export of (used) cars 
which do not meet 
roadworthiness or minimal 
environmental standards 

3.1 Action at international level 
to support that roadworthiness 
(and others) become criteria 
for export of used vehicles. 

1.1b MS to demonstrate 

implementation of Incentives 
(Level B) 

2.2 Voluntary campaigns on 

export  

3.2. EU funding for 
enforcement 

1.2 Alignment of terms  

2.3 Effective Deposit Refund 
Scheme (Voluntary for MS) 

3.3 Export restriction linked to 
roadworthiness; respect rules 
of receiving countries regards 
age and emission level 

1.3 Definition of temporary 

2.4 EU wide Deposit Refund 

deregistration  

scheme  

1.4 a Conclusive list of 

conditions for permanent 
cancellation of the 
registration 

2.5 Better definition of ELVs 

1.4 b Management of 

2.6 Minimum requirements for 

temporary deregistration 

sector inspections 

2.7a MS are encouraged to 

establish fines and penalties 
for illegal activities of owners 
and operators of treatment 
plants 

2.7b MS are required to 

establish fines and penalties 
for illegal activities of owners 
and operators of treatment 
plants 

1.5 ATFs and shredders to 

check and report on ELVs / 
CoDs  

1.6 interoperability of national 

registers 

1.7 VIN in customs declaration 

1.8 EU vehicle registration 

data base-system 

1.9 Reporting obligation on the 

current vehicle market  

1.10 Collection target 

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3.2.3  Methodology 

It is difficult to assess the impacts of measures and policy options addressing the aspect of 
missing vehicles as is has manyfold reasons and diverse stakeholders are affected. On top it 
is not known which of the main reasons, either unreported extra EU export or unreported / 
illegal  dismantling  within  the  EU  (regardless  of  whether  transferred  between  MS)  is 
dominating the current situation. 

However, it is important to derive quantitative assessment for a number of aspects. As far as 
the impacts are  not directly detectable / derivable,  we established a  model, describing the 
shifts between diverse categories of whereabout as outlined below  

3.2.3.1  Model for the shift of numbers of whereabouts 

The model considers the following categories of whereabouts:  

•  A) ELVs directed to ATFs and subsequently to shredders and reported by ATFs and MS 

(ATF, reported) 

•  B)  ELVs  directed  to  ATFs  and  subsequently  to  shredders  but  not  reported  (ATFs,  not 

reported) 

•  C) ELVs directed to non-ATFs and subsequently to shredders, not reported (non-ATF) 
•  D) Used Vehicles exported (extra EU) and reported accordingly (Export, reported) 
•  E) Used Vehicles exported (extra EU) but not reported (Export, not reported) 
•  F) ELVs exported (extra EU), not reported (ELVs export, not reported) 
•  Missing vehicles 

The  distinction  of  these  measures  is  relevant  as  a  shift  from  one  to  another  has  different 
impacts on different stakeholders. Some examples:  

A shift of F) and E) to D) has no effects on the environment nor the economy in the EU but 
improves the quality of reporting and possibly demonstrating the achievement of the collection 
target.  

While a shift of F) and E) to either A), B) or C) does have a physical effect on environment 
and economy but if directed to B) and C) not on the statistics.  

A shift from B) to A) has currently a statistical effect only, but in the future, in combination with 
more challenging settings regards circularity this might change. 

A shift of D), E), F) to A), B), C) has several effects: a) physically changes for the recycling 
industry  in  EU  (more  vehicles)  with  related  environmental  and  economic  impacts  and 
economic impacts on those stakeholders who are involved in the extra EU export which will 
lose parts of their business.  

The table below demonstrates how these shifts are introduced to the model. The yellow cell 
indicates for instance a shift of 0.25 percent points of the total Number of ELVs from category 
E  (Export,  not reported) to category  D (Export, reported),  the red  cell  displays  the reverse 
(redundant  information).  The  total  displays  the  change  in  percent  points  for  the  entire 
category. For instance, category D (Export, reported) receives in total 0.5 percent points more 
vehicles  in  the  given  year  compared  to  the  year  2019  where  (at  least  for  some  of  the 
categories) data is available.  

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Source: own calculations 

Regards the situation in 2019 (=starting point of the model) the data for A) and D) and G) are 
considered as explained in the section “current situation” of this report. However, the share 
of B), C), E) and F) cannot be derived in exact figures from existing data and literature. Instead 
Mehlhart  et.al.  (2017)  assumed  for  the  EU,  that  50%  of  the  missing  vehicles  are  illegally 
treated domestically in the EU and 40% are illegally exported. Miljøstyrelsen (2016)282 reports 
for Denmark the assumption that 50% are illegally treated domestically and 40% are illegally 
exported and 10% are left on public or private ground. Umweltbundesamt (2022)283 assumes 
for Germany that 80% are illegally treated domestically and 20% illegally exported. In fact, 
the details of the whereabout for the categories B), C), E) and F) are not known, in particular 
not at the national level. 

For the purpose of the model, we considered that the share between illegal/unreported dis-
mantling within the EU should be compared to the unreported extra-EU export is 50 % of the 
unknown  vehicles  each.  As  both  include  two  distinct  categories  B/C  and  E/F  we  further 
consider  an  equal  share  for  each  category.  Thus,  for  each  category  B/C/E/F  we  consider 
25 % of the missing vehicles in 2019 as a starting point for 2019.  

For the interpretation of effects, the following aspects needs to be considered:  

•  A  shift  from  B  or  C  (both  non reported treatment)  to  A  reduces the  number  of missing 

vehicles 

•  A  shift  from  E  or  F  (both  non-reported  export)  to  D  reduced  the  number  of  missing 

vehicles. 

•  A shift from A to D or vice versa does not change the number of missing vehicles, while 
such shift between A and D has effects on ELVs available for recycling as addressed later 
in the Impact assessment.  

282 Udredning af skrotningsgodtgørelsens incitamentsstruktur; Udgiver: Miljøstyrelsen; Redaktion: Deloitte Consulting; 
Udredning; September 2016 [Investigation of the incentive structure of the scrapping premium; Publisher: Danish 
Environmental Protection Agency; Editing: Deloitte Consulting; Study; September 2016 

283 Zimmermann, T.; Sander, K.; Memelink, R.; Knode, M.; Freier, M.; Porsch, L.; Schomerus, T.; Wilkes, S.; Flormann. P. 
(2022): Auswirkungen illegaler Altfahrzeugverwertung, Publisher: Umweltbundesamt, Dessau, Germany, Publication in 
preparation 

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3.2.3.2  Results from model calculations for the share of missing 

vehicles 

It  is  important  to  be  aware  that  the  assumptions  were  made  for  the  purpose  of 
estimating magnitudes and are far from being accurate "model" forecasts. The shifts 
considered  for  calculating  the  impacts  of  the  policy  options  are  more  of  an  expert 
estimate than a correct calculation. 

For the different policy options the detailed assumptions for the shift between the categories 
and the impacts on the share of missing vehicles is displayed section 6.6.2.2 in Annex I.  

Figure 3-25 displays as one result of the model calculations the changes in the number share 
of missing vehicles caused by the different policy options. 

Figure 3-25  Model calculations for the change in missing vehicles due to the effects 
of the different policy options 

share of missing vehicles

35.0%

30.0%

25.0%

20.0%

15.0%

10.0%

5.0%

0.0%

Baseline

3A

3B

3C

Pref. PO

+EPR

2019*

2025

2030

2035

2040

Source: own calculations 

Note: For the purpose of easier reading, the preferred Policy Option and the preferred Policy Option 
including the effects of the rules for EPR are displayed here and in the subsequent figures too. The 
description of this Option and the combined impacts with EPR rules will follow later in chapter 3.2.9. 

As  mentioned  above  we  expect  for  the  baseline  marginal  effects  only  as  we  have 
experienced in the past – with a lot of attention by the EC – effectively no general change on 
the number of missing vehicles at EU level. To be not too pessimistic we consider a limited 
shift from category B,C, E, F to category A and also a slight shift from E and F to D. In result 
the share of missing vehicles declines by 2.4 percent points from 32.4 % in 2019 to 30.1 % 
(2040).  

The  policy  option  3A  is  relying  on  enhanced  monitoring  and  reporting  requirements  to 
demonstrate the whereabout of used vehicles and ELVs. It includes inter alia obligation for 
reporting on the changes in the vehicle fleet with the aim that such reporting shall prove that 
all ELVs are directed to ATFs. The MS have full flexibility to choose the measures to achieve 

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this target either with an adjusted registration system or with penalties or with incentives or 
other means.  

The main shortcoming of this options is that a single Member State alone has not all means 
at hand to complete the reporting form and thus can argue that he is by external reasons not 
able to fulfil his obligations. And might even hide with this argument his non-action in fields 
where the Member State would have opportunities to act and improve.  

Main missing aspects with this regard is the alignment definition of terms (e.g. for temporary 
deregistration) and the obligatory exchange of information of vehicles dismantled in another 
Member State as it was last registered and last not least the missing introduction of a more 
detailed/applicable definition of the term ELV. 

We expect a few more Member States to take action regards their registration system and 
also regards incentives/penalties. This will cause step by step a shift to the categories A and 
D (both decreasing the number of missing vehicles) and also a small shift from category E to 
F.  

According to our assumptions the share of missing vehicles will continuously decline by 7.2 
percent  points  from  32.4%  in  2019  to  25.2%  (2040).  Due  to  the  shortcomings  mentioned 
above  it  is  very  likely  that  the  Policy  Option  3A  is  at  risk  to  fail  in  generating  substantial 
improvements regards the share / number of missing vehicles. 

The Policy Option 3B aims to improve collection by: 

requiring that the national registrations systems be made interoperable.  

• 
•  a harmonised approach between the MS regards national registration of vehicles 
• 
•  binding criteria on the distinction between used vehicles and ELVs 

requirements regard incentives and penalties 

Compared to option 3A, this option reduces the flexibility of MS. 

However, it does not include the reporting obligation on the changes in the vehicle fleet (as 
in Policy Option 3A) which is an important tool to prove that all ELVs are directed to ATFs.  

Policy Option 3B provides the tools for cooperation between the MS but a clear method for 
the calculation of the change in the vehicle fleet is missing. Therefore, the current problem 
that  a  comparable  performance  monitoring  by  country  regards  missing  vehicles  is  not 
possible will persist and cause limited incentive to improve the overall situation on missing 
vehicles. 

However,  as  by  the  interoperability  the  tools  are  available  for  complete  balance  of  the 
whereabout of vehicles we expect some frontrunners of the Member States to make use of it 
and  seek  to  improve  their  performance  regards  missing  vehicles.  Other  measures  regard 
permits and incentives will support this change.  

Overall, the effect of Policy Option 3B is considered as more effective than Policy Option 3A, 
while the missing national reporting on the performance regards missing vehicles is a major 
gap to generate full effectiveness of this policy option. 

Policy Option 3C consists in implementing interoperability of national registrations systems 
relevant for the tracking of vehicles and for getting relevant information on export restrictions 
like the status of the roadworthiness certificate. 

In addition, this option includes the establishment of new criteria regulating the export of used 
vehicles  (also  those  which  are  not  explicit  ELVs),  to  ensure  better  traceability  and 
sustainability of these exports. Criteria for extra Export, including the mandatory use of the 
VIN  number  in  export  documents,  requiring  demonstration  of  a  valid  roadworthiness 
certificate are included too. 

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The limitation of (extra-EU) export to vehicles with valid roadworthiness certificate will have 
massive effects on the extra EU export. The limitation of the export will have a sudden effect 
by the date of enforcement. Most likely exports of older vehicles (without valid certificate) to 
non-EU Member States will even increase (“last chance”) in the period before the restrictions 
enter into force. For the assumptions regards the shifts between the categories we take into 
consideration  that  the  enforcement  date  will  be  2027  and  the  adverse  effects  will  become 
effective in 2025 and the intended effects become visible in 2030. 

The adverse impacts in 2025 on the number of missing vehicles are caused by the shift from 
treatment in ATFs to the export (Cat. D, E, F) and as we considered the unreported export to 
increase too, the number of missing vehicles increased for the year 2025. 

3.2.4  Selection of potential impacts 

According  BRG  Tool  #18  the  impact  assessment  potential  impacts  “should  be  screened 
objectively  in  order  to  identify  all  potentially  important  impacts  –  considering  both 
positive/negative,  direct/indirect,  intended/unintended  as  well  as  short/long-term  effects. 
Some  of  the  categories  are  cross-cutting  and  can  be  analysed  from  different  angles  (for 
example employment, income distribution, impacts on consumers or environmental impacts). 
A (well-justified) choice should then be made on the most significant impacts to be retained 
for  a more thorough analysis.  The  full  list  of  key impacts to  screen  is  displayed  in  section 
6.6.2.5 in Annex I. In the next chapter the affected stakeholders are identified and secondly 
the most significant impacts are assessed considering the list mentioned in BRG Tool #18.  

3.2.5  Economic Impacts 

3.2.5.1  Identification of affected stakeholders  

The following list provides an overview of the affected stakeholders. 

•  Vehicle owners 
•  Garages 
•  ATFs 
•  Shredders 
•  Used car dealers 
• 
Insurances 
•  Customs Services 
•  National vehicle registers 
•  Producers 
• 

Industries involved in processing/recycling of waste arising from ELVs treated in the EU 

3.2.5.2  Vehicle owners / consumers 

Vehicle owners might receive less compensation for their ELV if all ELVs are directed to ATFs 
and less vehicles are exported as less stakeholders are involved in the business with ELVs 
(e.g. specific exporters are kicked out and illegal dismantlers are reduced). The level of the 

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compensation depends on the brand, age and condition of the ELV. The German study284 
considers an average pay out to the last owner of 80 Euro per ELV.  

Vehicle owners might be affected if they must follow more strict obligations to report on the 
status of the owned vehicles and possibly experience fines or continuing fees if they do not 
report the change in ownership or the scrapping of the vehicle or do not provide a CoD to the 
registration authority.  

Different  concepts  of  DRF  schemes  have  different  impacts  during  the  use  phase  of  the 
vehicle.  

A DRS can be established by two options:  

• 
• 

It is included in the first sale 
It is collected during the use phase of the vehicle  

A levy charged on the sale of new cars would increase the cost of new cars, as well as used 
cars,  because  the  prices  of  old  used  cars  would  also  include  the  premium  payment  as  a 
markup on the market price. Thus, no “losses” apply to the first owner when selling a vehicle.  

An annual levy will increase step by step the value of the used car. As the last owner will at 
least get the premium from the ATFs. However, it is not benefit to the last owner as has paid 
the mark up to the used vehicle and also added the levy during his use phase. 

If it is collected during the use phase and no import fee is charged, such a system has adverse 
effects  for  countries  importing  a  relevant  number  of  end-of-life  vehicles.  The  table  below 
demonstrate  the  effects  of  different  national  market  characteristics  when  the  premium 
payment for ELVs is levied during the lifetime of the vehicle and no levy applies for imports 
of used vehicles. 

Table 3-65 Effects of import / export of used vehicles on the level of a yearly DRS fee 

The import / export quote is the only variable 

Premium per ELV 
Average age of ELVs 

share of used cars imported 
(“-” indicates export) 

average age of imported 

Effect: Annual levy for the 
collection of the premium 

300 € 
18 

300 € 
18 

300 € 
18 

300 € 
18 

300 € 
18 

300 € 
18 

-50% 

-25% 

6 

6 

0 

0 

25% 

50% 

75% 

6 

6 

6 

12.50 € 

15.00 € 

16.67 € 

17.86 € 

18.75 € 

19.44 € 

Multiple variables apply, reflecting the typical situations in the MS  

Premium per ELV 

Average age of ELVs 
share of used cars imported  
(“-” indicates export) 

average age of imported  
Effect: Annual levy for the 
collection of the premium 

300 € 

18 

300 € 

18 

300 € 

18 

250 € 

22 

200 € 

24 

150 € 

28 

-50% 

-25% 

4 

6 

0 

0 

25% 

50% 

75% 

4 

6 

8 

13.64 € 

15.00 € 

16.67 € 

11.79 € 

9.09 € 

6.10 € 

Source: own calculations 

284 Zimmermann, T.; Sander, K.; Memelink, R.; Knode, M.; Freier, M.; Porsch, L.; Schomerus, T.; Wilkes, S.; Flormann. P. 
(2022): Auswirkungen illegaler Altfahrzeugverwertung, Publisher: Umweltbundesamt, Dessau, Germany; publication in 
preparation 

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For the prices of (very) old used cars the premium becomes relevant for the price of that car 
as a mark up to the current market price. 

3.2.5.2.1  Problematic  effects  of  import  and  Export  of  used 

vehicles on the EPR fees 

On the one hand, the total EPR costs of manufacturers are caused by the degree of EPR 
ambition and country-specific treatment costs, which are also influenced by wage rates. On 
the other hand, they correlate with the number of end-of-life vehicles produced on the territory 
of the country.  

EPR schemes in a county exporting more than halve of the vehicle fleet before it is becoming 
ELVs need to collect less than half of the compliance cost compensation (Country A below). 
EPR  schemes  in  a  county  importing more than  halve  of  the  vehicle  fleet as  used  vehicles 
need to collect more than double of the compliance cost compensation per new vehicle PoM 
(Country B). 

In consequence Country C might decide to collect a contribution to the EPR scheme when a 
used vehicle is imported respectively registered for the use on public roads in the country of 
destination. 

As the table below shows, a transfer of the EPR fee from exporting country A to importing 
countries would be fairer. In this case, country A would have to collect the full amount of €200 
million and transfer half of it to the destination countries, which would then not have to charge 
an  import  fee  for  used  vehicles.  Under  real  conditions,  it  becomes  more  complicated,  as 
compliance costs vary from country to country, e.g. due to different wage rates.  

A secondary effect might be relevant too: Often, the countries importing a relevant share of 
used  vehicles  have  lower  wages.  For  instance,  labour  cost  for  the  NACE  sector  E  (Water 
supply; sewerage, waste management and remediation activities) vary in 2020 between 5.2 
€ per hour in Bulgaria and 44.7 € per hour in Denmark. The average EU27(2020) is 23.0 € 
per hour285. Therefore, we added in  

Table 3-66 below a calculation in the last column where the compliance costs are only half of 
the compliance cost compared to the exporting country. 

Table 3-66 Exemplary effects of import and export of used vehicles on the EPR fees 
Organisations identified 

Country A 

Country B 

Country C 

New Vehicles PoM 

Export of used 
vehicles  
Import of used 
vehicles 

ELVs  

Unit  

1000 
vehicles 
1000 
vehicles 
1000 
vehicles 
1000 
vehicles 

Compliance cost 
offsetting per ELV 
Required budget  
Fee per new vehicle  

€ per ELV 

Million € 
€ per ELV 

285 Source: Eurostat (lc_lci_lev), extracted: 16.2.2022 

2 000 

1 000 

-/- 

1 000 

100 

100 
50 

423 

500 

-/- 

500 

500 

-/- 

500 

Country 
D 
500 

-/- 

500 

1 000 

1 000 

1 000 

100 

100 
200 

100 

100 
100 

50 

50 
50 

 
 
 
 
 
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Fee per imported 
used vehicle  

€ per ELV 

-/- 

-/- 

100 

50 

Source: own calculations 

3.2.5.3  Garages  

Garages might be affected if they cannot make use of spare parts of used vehicles / ELVs 
without being an ATF.  

In consequence they might opt  

• 

• 

to register as an ATF. As the number of ELV treated might remain small (e.g. 10  – 15 
ELVs per year, this might cause unproportional additional administrative burden to those 
with small numbers of ELVs treated.  
to continue with the dismantling of valuable spare parts (which would be illegal) and seek 
how to direct the partially dismantled vehicles to ATFs or shredders.  

To some extend it is expected that Garages might continue with their business to make use 
of  spare  parts  and  bypass  legislation  as  enforcement  in  detail  is  difficult.  Some  specific 
measures  (minimum  level  of  sector  inspections,  monitoring  /  reporting  on  illegal  activities) 
might reduce this bypassing.  

The level of the economic effects is unknown. 

3.2.5.4  ATFs 

ATFs will be affected under the different scenarios by more ELVs directed to ATFs and also 
by  new  restrictions  regards  the  export  of  (old)  used  vehicles.  ATFs  selling/  exporting such 
(old)  used  vehicles  would  incur  losses  in  turnover  and  profit  due  to  the restrictions.  At  the 
same time, it is expected that ATFs as a whole would benefit from more ELVs directed to 
ATFs. 

Beside  this  ATFs  might  be  affected  due  to  more  (or  less  if  online  procedures  apply) 
administrative burden by issuing a CoD and demonstrating the source of spare parts sold. 

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Additional profits due to increasing number of ELVs directed to ATFs 

Germany prepared a study on the „Illegal treatment of end-of-life vehicles – Assessment of 
the environmental, micro- and macro-economic effects”.286  

The  study  provides model  calculations  distinguishing  between  6  types  of  legal  dismantling 
concepts and 4 types of illegal dismantling. 

Legal dismantling types:  

•  Baseline:  ATF  with  a  throughput  of  500  ELVs  per  year,  ELVs  are  equipped  with 
combustion  engines,  treatment  is  in  accordance  with  the  minimum  legal  requirements: 
depollution, dismantling, logistics but without dismantling of plastics and glass  

•  Plastics:  Baseline  +  dismantling  of  large  plastics  components:  front  and  rear  bumper, 

wheel arch closures 

•  Glass: Baseline + dismantling of vehicle glass: Laminated safety glass: windscreen glass, 

door glass. Toughened safety glass: fixed side windows, rear screen glass 

•  Spare Parts + Metal: Baseline + dismantling of spare parts by ATF staff + dismantling of 
metal components: engine, starter motor, gear box, axles; alternator; copper components 
•  Electric  vehicles:  Baseline,  but  exclusively  electric  vehicles  instead  of  conventional 
ELVs: mainly: battery instead of fuel tank, no catalytic converter, no engine oil, less gear 
box oil 

•  Gas vehicles: Baseline, but exclusively CNG/LPG instead of conventional ELVs gas tank 

instead of fuel tank 

Illegal dismantling  

•  Type 1:   Private actors such as private person, hobbyists, collectors and DIY auto repair 

communities and similar clubs.  

•  Type 2:   Actors  with registered  businesses  and  good  equipment  such as  workshops/ 

garages which occasionally dismantle vehicles.  

•  Type 3:   Actors  with  registered  businesses  and  partly  under-equipped  such  as 

workshops/ garages with poorer standards, spare parts dealers etc.  

•  Type 4:   Actors with registered businesses and largely without suitable equipment and 

inadequate dismantling practice such as used car or tire dealers.  

The Figure 3-26 displays the costs and revenues for the different concepts of the legal sector. 
It displays that the baseline (the minimum effort for compliance) does not generate a profit 
but the scenario which includes the revenues from dismantling of spare parts and metals the 
profit is about 248 €/ELV. Th study displays an additional scenario (not displayed in the graph 
below) for the dismantling of spare parts but without dismantling of metals, which generates 
a  profit  of  222  €/ELV.  The  cost  for  the  treatment  of  EV  depend  much  on  the  turnover  in 
numbers of EV as much upfront investment in staff and equipment is needed. 

286 Zimmermann, T.; Sander, K.; Memelink, R.; Knode, M.; Freier, M.; Porsch, L.; Schomerus, T.; Wilkes, S.; Flormann. P. 
(2022): Auswirkungen illegaler Altfahrzeugverwertung, Publisher: Umweltbundesamt, Dessau, Germany; publication in 
preparation 

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Figure 3-26  Cost and revenue of ELV treatment in German ATFs  

Cost per ELV, throughput of 500 ELV/a, average prices 2019 / 2020 

Source: Zimmermann et.al (2022)  

The Figure 3-27 displays the results of the investigations in the sector costs and revenues for 
the illegal and the legal sector per vehicle compared to the treatment in an ATF (scenario 
Baseline  +  dismantling  of  spare  parts  and  metals).  The  delta,  the  difference  between  the 
(best)  legal  scenario  and  the  different  illegal  scenarios  is  between  252  €/ELV  and  305 
€/vehicle.   

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Figure 3-27  Cost and revenue situation of the illegal dismantling per ELV 

Source: Zimmermann et.al (2022)  

Using the figures in table 67 of the study, it is possible to calculate the total revenues for the 
legal and the illegal actors as displayed in Figure 3-28 below. The turnover of selling (very) 
old used vehicles to third countries is not included.  

Figure 3-28  Model calculations for the revenues from dismantling activities in 
Germany for ATFs and different illegal actors (in Million €) 

116   

58   

46   

10   

379   

ATFs

Type 1

Type 2

Type 3

Type 4

Source, own calculations based on data in Zimmermann et.al. (2022) 

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As  demonstrated  by  the  studies  published  by  ADEME  (2015)287  and  UBA  (2022)288,  the 
operation of ATFs focusing on revenues for recyclables is not profitable. 

Based on very detailed questionnaire, completed by 24 selected ATFs for the reference year 
2012, the ADEME (2015) report concludes that the business is not profitable (on a weighted 
average) even if the spare parts separation activities are included. The ADEME report shows 
a weighted economic loss of 23.9 €per /ELV as displayed in the figure below. The average 
weighted turnover according to the same figure is 265.2 €/ELV. 

Figure 3-29  Résultat d’exploitation par sous-activité  
(moyenne pondérée de l’échantillon 24 centres VHU) 

Source: ADEME (2015) 

It  is  important  to  note  that  the  results  for  the  24  ATFs  included  in  the  study  range  from  a 
negative result of -225.2 €/ELV to a maximum profit of 109.8 €/ELV. One of the main effects 
to  distinguish.  The  ADEME  report  examines  in detail  whether  patterns can  be  identified to 
distinguish  which  ATFs  generate  losses  and  which  generate  profits.  An  important  aspect 
seems to be whether the treatment of end-of-life vehicles is the main activity or whether the 
business is dominated by other activities such as car trade or repair shop: “We note that the 
result in €/ELV is positive for the ELV centres whose % ELV turnover is greater than 75% of 
total turnover. This probably reflects a concern to optimise costs and margins on the main 
activity. The average operating profit in € for all activities combined of ELV centres whose 
ELV turnover is less than 75% of total turnover is positive. The margin of these companies is 
therefore achieved from activities other than that of the approved ELV centre.”289 

287 ADEME (2015): TERRA SA – DELOITTE – BIOIS - EVALUATION ECONOMIQUE DE LA FILIERE DE TRAITEMENT DES 
VEHICULES HORS D’USAGE – 2015 – Synthèse. 40 p. 

288 Zimmermann, T.; Sander, K.; Memelink, R.; Knode, M.; Freier, M.; Porsch, L.; Schomerus, T.; Wilkes, S.; Flormann. P. 
(2022): Auswirkungen illegaler Altfahrzeugverwertung, Publisher: Umweltbundesamt, Dessau, Germany, Publication in 
preparation 

289 ADEME (2015), Volume 1, page 67 

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In  contrast  to  the  ADEME  (2015)  report  (referring  to  a  survey)  the  UBA  (2022)  report 
developed model calculations for different operations concepts as mentioned above. For the 
operation concept including the separation of spare parts UBA (2022) reports a positive result 
of 222 €/ELV290. For the operation concept including the separation of spare parts and the 
separation of metals UBA (2022) reports a profit of 248 € per ELV. The turnover reported in 
UBA (2022) for the same operation concepts are 656 €/ELV respectively 714 €/ELV (the last 
including separation of metals).  

The German average profit (revenue - cost, including the cost of purchasing ELVs) per ELV 
may not be representative for the EU as a whole, as the profit depends on the revenues of 
shredder steel  scrap,  catalytic  converter  scrap  and  aluminium  scrap  (all of  which  fluctuate 
over the time series, but do not differ that much within the EU) and depends also on transport 
distances, investment in equipment and wage levels, and last but not least on the demand 
for spare parts from the ELVs typically treated in the country. 

As long as no other economic information is available, we consider as a total profit from the 
treatment of ELV considering the concept to dismantle spare parts a profit of 200 €/ELV and 
a turnover of 600 €/ELV. 

Losses due to limitations in export of used vehicles (similar to ELVs) 

We consider that ATFs currently are involved in exporting old vehicles, considered in the EU 
as ELV but with a positive market value in 3rd countries. As it must be more attractive to export 
them (or sell them to exporters) we consider that the profit per exported vehicle is about 400 
€ per vehicle for the ATF. Further we assume that ATFs are involved in 25% of such exports. 
The different scenarios have different effect to what extend the export is limited and directed 
to (EU domestic) ELV treatment in ATFs instead. 

Figure 3-36 below displays the effects for the Policy Options and the preferred option for both: 
increased profits due to more ELVs treated in ATFs (displayed in the first 4 bars for the years 
2025 - 2040) and the lost profits due to the limitations of the export (second set of the bars 
for each policy option. The reduced number of treated ELV in ATFS in 2025 in Policy Option 
3C (and subsequently the preferred Policy Option(s) is a one-off effect caused in advance to 
the shortly coming (envisaged for 2027) limitations of exports. 

290 UBA (2022), English version, Table 11, page 54 

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Figure 3-30  Profits (revenues – costs) for ATFs in EU-27 for the Policy Options:  
a) profits from ELVs directed to ATFs;  
b) profits from export of (old) used vehicles 

 3 000

 2 500

 2 000

€
n
o
 1 500
m

i
l
i
i

 1 000

 500

 -

Baseline

3A

3B

2025

2030

3C
2035

Pref. PO

+EPR

2040

Source: own calculations 

Assumptions for the calculations:  

•  Dynamic development of ELVs according to the fleet model 
•  Shift to ATFs (Category A and B) as displayed in Table 6-30 in Annex I 
•  Profits: 200 € per ELV treated in ATFs 
•  Profits due to exports to non-EU Countries: 400 € per exported vehicle; assumption that 

ATFs are involved in 25% of the total export of used vehicles to non-EU-Countries 

In PO3C and the preferred Policy Option there might be an on-off effect shortly in 2025, before 
the limitations for the export enter into force. This is caused by the “alarmed” exporters having 
a last chance to export such old vehicles which would not get a roadworthiness certificate but 
meet a demand in the receiving countries. In result the profits from treatment drop and the 
profits from export increase.  

Figure 3-31 below displays the total effects on profits of the combination of a) ATFs treated 
in EU27 and b) ATFs exported. As a result, the on-off effect will not reduce ATF profits in 
2025, and after 2025, the preferred policy option will lead to an increase in profits. 

Finally, Table 3-67 displays the profits for the Policy options compared to the baseline. 

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Figure 3-31  Aggregated change in profits for ATFs in million € for the different 
Policy Options 

ATFs effect total

 3 000

 2 500

€
n
o

i
l
l
i

m

 2 000

 1 500

 1 000

 500

 -

Baseline

3A

3B

3C

Pref. PO

+EPR

2025

2030

2035

2040

Source: own calculations 

Table 3-67 Additional profits (revenues – costs) for ATFs in EU-27 for the Policy 
Options in million Euro compared to Baseline  

Source: own calculations  

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New administrative burdens to ATFs 

At the same time ATFs are exposed to additional administrative burdens caused by the policy 
options 3A measure 3 requiring dismantlers to check and report on ELVs.  

Regards  3A3  the  situation  does  not  change  much:  ATFs  should  according  to  the  current 
legislation anyhow issue CoDs on demand. As the measure includes the obligation that the 
Member States shall establish electronic transfer to authorities, this might cause some one-
off  effort  to  some  ATFs,  but  as  it  might  be  a  simple  registration  procedure  and  a  simple 
interface it might even reduce the administrative burden to ATFs. Such burdens might cause 
a light shift from (very) small business to medium size business simply due to economy of 
scale.  

More challenging is the aspect that shredders shall be enabled to check the VIN number and 
accompanying  CoDs  (as  it  is  the  case  in  the  Netherlands).  This  would  not  allow  ATFs  to 
compress the cars to the maximum or to separate components / metal with hydraulic shears. 
Both might cause increasing transport cost for ATFs to shredder / recycling facility. 

3.2.5.5  Shredders 

The  study  of  ADEME  (2015)  selected  7  shredders  representing  the  average  situation  of 
shredders in France and these shredders provided economic data for the reference year 2012 
(with  some  deviations  depending  on  the  fiscal  year).  According  to  the  results  of  ADEME 
(2015) French shredders work in average with a (marginal) profit of 0.8 €/t (depolluted and 
dismantled ELV, with a range of maximal losses 29.8 €/t and a maximal profit of 27.2 €/t.  

Figure 3-32  Résultat d’exploitation par sous-activité (Moyenne pondérée 
del’énchantillon 7 broyeurs VHU) 

Source: ADEME (2015) 

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Three of the seven shredders analysed showed a negative operating result for the activity of 
shredding ELV carcasses. The results of this study are a bit surprising as according to the 
same  study  the  shredders  pay  for  the  incoming  depolluted  and  dismantled  ELV  between 
150.5 and 210.4 €/t. So why should the shredders buy these ELVs if they generate losses?  

The  UBA  (2022)  study  investigated  in  the  economic  situation  of  shredders  too.  The 
assessment is based on 4 shredders in Germany as displayed in the figure below.  

Figure 3-33  Cost and revenues of shredding plants per cost type 

Source: UBA (2022) 

Shredders will have additional turnovers and profits if more ELVs are treated in Europe. For 
the calculation below we consider that today ELVs treated domestically in ATFs (cat A and B 
of Model, see section 3.2.3 on the Methodology) and also those domestically treated in illegal 
(non-ATFs, cat C) are delivered to shredders. Additional mass/profits are generated by the 
shift from extra EU export (cat D) E) F)) to EU domestic treatment only. 

Considering an average 700 kg per dismantled and depolluted ELV the additional feed for 
shredder will be in maximum 1.5 million tonnes per year which is according to statements of 
the recycling sector feasible to absorb.291 

For  the  calculation  of  the  additional  profits,  we  consider  a  specific  additional  profit  for 
shredders of 20 €/t dismantled and depolluted ELV. 

Figure 3-34 displays the total profits of shredders from the treatment of ELVs for the different 
policy  options  and  Table  3-68  displays  the  additional  profits  under  the  policy  options 
compared to the baseline.  

291 The total amount of steel scrap (all qualities) consumed for crude steel production in the EU-27 in 2021 is about 88 million 
tonnes (Source: Eurofer / BIR; Statista) 

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Figure 3-34  Profits for Shredders from ELVs in EU-27 for the different Policy 
Options 

€
n
o

i
l
l
i

m

 200

 180

 160

 140

 120

 100

 80

 60

 40

 20

 -

Baseline

3A

3B

3C

Pref. PO

+EPR

2025

2030

2035

2040

Source: own calculations  

Assumptions for the calculations:  

•  Shift from exports (cat D, E, F) to domestic (EU27) treatment (cat A, B, C) as displayed in 

Table 6-30 in Annex I 

•  Profit for shredders per dismantled and depolluted ELV: 20 €/t dismantled and depolluted 

ELV 

Table 3-68 Additional profits (revenues – costs) for shredders in EU-27 for the Policy 
Options in million Euro compared to Baseline 

Source: own calculations  

Sometime stakeholders are of the opinion that the profits of shredder are higher when the 
prices for the shredder steel (or aluminium) are high as in 2021 (see figure below with peak 
prices  in  April  2022).  However,  the  shredders  have  to  buy  the  steel  scrap  including  the 
depolluted and dismantled ELVs and the purchase prices for the input increase too. 

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Figure 3-35  Min / max prices for shredder steel, free factory (Germany) 

n
o
t

r
e
p
o
r
u
E

600

500

400

300

200

100

0

min,  free factory

max,  free factory

average for the entire period,  free factory

Source: data: www.euwid-recycling.com, own compilation.  

Shredders  might  be  affected  by  the  fact  that  they  must  check  if  the  ELVs  arriving  at  their 
facility were depolluted and dismantled by ATFs and carry the correct CoD. This will require 
a  compacting  of  the  carcass/depolluted/dismantle  ELV  for  transport  from  ATF  to  shredder 
which allows checking the VIN number. This approach is already applied in the Netherland 
for the ARN network.  

3.2.5.6  Industries  involved  in  processing/recycling  of  waste 

arising from ELVs treated in the EU 

As  outlined  in  the  section  on  environmental  impacts  (3.2.6)  more  feedstock  for  several 
secondary materials will become available for other stakeholders in the recycling industry too. 
As for almost all of the materials mentioned in this section the recycling is profitable, additional 
feedstock will increase the profits of the recycling industry accordingly. 

3.2.5.7  Used car dealers  

Dealers with used cars might experience more administrative burdens and also higher costs 
if continuing fees / insurance apply during a temporary de-registration.  

Used  car  dealers  often  apply  for  temporary  deregistration  for  the  period  during  which  the 
vehicle is for sale. If a fee of e.g. 5 € per month and vehicle is due during this period, this 
would amount to 3 000 € per year for a dealer with e.g. 50 used cars to sell. If the average 
sales period is about 2 months, the additional costs to be covered by the sales prices amount 
to about 10 € per vehicle. 

Dealer with used cars would be affected by new rules restricting the (Extra EU) export of used 
vehicles. 

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As outlined for the current situation (see Annex I) the total number of exported used vehicles 
from EU-27 to non-EU Countries peaked in the past decade in 2012 with 1.4 million, dropped 
to 680 000 in 2016 and increased to 971 000 in 2019. 

The total value of the exported used vehicles to non-EU Countries is € 6.14 billion in 2012 
and dropped to € 4.33 billion in 2019. These data refer to the data as provided by Eurostat 
which is based on statistics from the customs services. As explained earlier we assume an 
additional share of the “missing vehicles” being exported too, but not reported to the customs 
services. As outlined in the section methodology we consider for the assessment that 50% of 
the missing vehicles are treated (but not reported) within the EU and 50% are exported but 
not  declared  to  the  customs  services.  For  2019  (last  available  data  when  the  report  is 
prepared) this would represent around 1.7 million used vehicles (also including a share which 
would  be  declared  within  the  EU  as  ELVs).  The  total  export  is  the  sum  of  reported  and 
unreported 2.67 million used vehicles.  

As we have no further sources on the characteristics of the unreported exports, we assume 
them  to  have  the  same  characteristics  as  the  officially  exported  with  an  average  value  of 
around 4 400 €/vehicle. Thus, the total value of the unreported vehicles would be about 11.75 
billion Euro.  

The model calculation is similar to the calculation of the economic impacts on ATFs, involved 
in export of used vehicles too.  

Therefore, we consider the same profit of per exported vehicle of about 400 € per vehicle. 
Further we assume that non-ATF car dealers are involved in 75% of such exports.  

The lost profits for the used car dealers in the different scenarios are displayed in Figure 3-36 
below and Table 3-69 displays the (lost) profits compared to the baseline.  

The  calculation  is  a  kind  of  worst-case  scenario  for  the  sector  as  we  expect  a  shift  of  the 
export activities of car dealers to younger vehicles, which can get easier a roadworthiness 
certificate.  

Figure 3-36  Profits in EU-27 for car exporters of (old) used vehicles for the different 
Policy Options 

€
n
o

i
l
l
i

m

 1 600

 1 400

 1 200

 1 000

 800

 600

 400

 200

 -

Baseline

3A

3B

3C

Pref. PO

+EPR

2025

2030

2035

2040

Source: own calculations 

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Assumptions for the calculations:  

•  Shift from exports (cat D, E, F) to domestic treatment (cat A, B, C) as displayed in in Table 

6-30 in Annex I 

•  Profits:  400  €  per  exported  vehicle  (25%  manged  by  ATFs  and  75%  managed  by  car 

dealers) ELV treated in ATFs 

•  Not realised profits (negative values) due to limited exports to non-EU Countries: 400 € 
per not exported vehicle; assumption that ATFs are involved in 25 % of the total export of 
used vehicles to non-EU-Countries 

Table 3-69 Additional profits in EU-27 for car exporters for the Policy Options in 
million Euro compared to Baseline 

Source: own calculations  

3.2.5.8  Insurances 

Insurances  often  apply  procedures  for  economic  and  technical  total  loss  which  have  the 
potential to disregard that these vehicles might be waste and shipment regulations for intra 
EU  must  apply  and  export  to  non-OECD  countries  might  be  prohibited.  If  the  definition  of 
ELVs is connected to the definition of “total technical loss” or even “total economic loss”, the 
insurances might be exposed to higher cost, and this might cause higher cost to consumers 
too.  

For the  Netherlands  a  number  of  30 000  total  loss  vehicles  per  year  is mentioned292.  This 
would represent a share of 0.3% of the fleet (approximately 9 million passenger cars in use) 
respectively a share of 15% of the ELVs reportedly treated (approximately 200 000 per year). 
Of the 30 000 a share of 10 000 are dismantled and 20 000 repaired293.  

3.2.5.9  National Authorities 

•  might be affected by  
•  more inspection/enforcement campaigns  
•  prepare their registration systems to become interoperable with the systems of other MS 
•  more administrative efforts to manage extra EU exports. 
• 

 New  reporting  obligations  regards  the  change  in  national  fleet  with  the  aim  to 
demonstrate that all ELV are directed to ATFs and reported to the registers accordingly  

292 E-Mail: H. Nix (EGARA), 7 August 2022 

293 E-Mail: H. Nix (EGARA), 7 August 2022 

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With regard to this first measure (more inspection/enforcement campaigns): To check 10% 
of the sectors facilities per year a relevant effort is required. Taking into consideration 12 000 
ATFs294  and  2  times  more  other  facilities  (like  garages  or  private  places  where  ELVs  are 
suspected to  be  stored) relevant for  inspection  then  10%  would  account  for  around  3  000 
facilities.  Taking  into  account  3  full  days  effort  per  facility  in  average,  multiplies  with  the 
average EU labour cost of 29 € per hour295 this would account for 2.5 million € for the entire 
EU + plus reporting to the EU of possibly about 10 000€ per MS. In total an amount of 2.8 
million €.  

Considering the average of new registered passenger vehicles in the EU for the period 2019 
– 2021 of 10.9 million vehicles this represents around 25 cent per new vehicle registered. 

In total, including the other efforts we estimate not more than 1 € per new vehicle registered. 

With regard to the second measure (making MS registration systems interoperable with the 
systems of other MS), the impact would be assessed as part of the impact assessment for 
the “roadworthiness package” which is under preparation by the European Commission296, 
as one aim of this package is to move to a full digitalisation of the registration documents and 
improve  the  exchange  of  information  between Member  States on their registers.  As  a first 
indication the envisaged budget of EUCARIS297  298 for the year 2022 might serve as a first 
proxy  which  is  around  1.6  million  €  for  the  services  provided  to  its  members.  The  cost  is 
charged separately for different services to the members of EUCARIS. Additional cost applies 
to the members when making use of the platform. However, the overall cost shall not exceed 
1 € per registered vehicle too. 

With regard to the third measure (new requirements on export of used vehicles and better 
enforcement of rules on export ELVs), the impact for national administrations is linked to the 
need to ensure training of all relevant services on the new controls that need to be performed 
upon  export,  to  foster  cooperation  between  the  different  administrations  concerned 
(especially competent authorities in charge of the implementation of the ELV legislation and 
customs), as well as to set up or upgrade the necessary IT infrastructure allowing for efficient 
border automated checks (especially in the case where the Vehicle Identification Number of 
used  vehicles  need  to  be  included  in  the  customs  declaration).  In  addition,  costs  of  the 
inspections to be performed by the relevant authorities on export should also be factored in. 
These costs would remain marginal for Member States which are not exporting or exporting 
very low quantities of used vehicles or ELVs and would represent a higher amount for other 
Member States, especially those hosting large ports specialised in export of large volumes of 
used vehicles/ELVs. It is difficult to provide a quantitative assessment of these costs, but they 
should remain limited. The measures put in place through the new legislation should actually 
mitigate some of these costs as they would render the procedures more efficient and targeted, 
compared to the current situation.  

294 ARGUS (2016): Implementation of Directive 2000/53/EU on end-of-life vehicles (the ELV Directive) with emphasis on the 
end-of-life vehicles with unknown whereabouts: Summary report on the implementation of the ELV Directive for the periods 
2008-2011 and 2011-2014 (“Lot 2”): In this report for EU27 11089 ATFs are listed (while not all MS refer to the same time 
period, the range of time periods considered is between 2008 - 2015 

295 https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Hourly_labour_costs 

296 Vehicle safety – revising the EU’s roadworthiness package (europa.eu) 

297 EUCARIS (short for European Car and Driving License Information System) is an information exchange system that 
provides an infrastructure and software to countries to share, among others, their car- and driving licence-registration 
information, helping fight car theft and registration-fraud. EUCARIS is developed by and for governmental authorities and is 
able to support all kinds of transport related information exchange based on treaties, directives, bi- and multilateral 
agreements. 

298 EUCARISBUDGETPROPOSALFINAL2022VERSION 1.1  

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With regard to the 4th measure, it is important that the 2nd and 3rd measures are in place and 
thus the related costs for the implementation and operation of these measures apply for the 
4th  measure  as  well.  Once  the  3rd  and  4th  measures  are  implemented,  limited  additional 
burdens apply to collect the data from the different sources established. 

Again we come to the conclusion that the overall cost for all four mentioned aspects will not 
exceed the cost of 1 to 2 € per newly registered vehicle.  

3.2.5.10  Producers / OEMs 

Producers will not be affected by the measures in Options 3A, 3B, and 3C. 

3.2.5.11  Overview 

The  table  below  gives  an  overview  by  measure  /  policy  option  and  in  principle  expected 
economic impacts with the aim to identify relevant stakeholders and measures to be looked 
at detail and to crosscheck if the assessment above is complete.  

The details of the impacts are here consolidated according to the elaborations above the main 
affected stakeholders are: 

•  ATFs having relevant additional profits due to the handling of more ELVs, depending on 
the policy option by 3A to 3C from 91 to 344 million € per year in 2040. As ATFs might be 
involved in the extra-EU export of used vehicles including those vehicle which might not 
get a valid roadworthiness certificate ATFs might be experience that profits from these 
activities decrease by up to 142 million € for Policy Options 3C. According to the model 
calculations,  the  last  should  be  by  far  overcompensated  by  the  additional  profits 
mentioned before. 

•  Used  car  dealer  with  a  focus  on  extra  EU  export  (and  not  involved  in  the  ELV 
management) will experience losses of profits under the different policy Options 3A to 3C 
due to the limitations of the exports of used vehicles which are not accompanied with a 
valid roadworthiness certificate of 70 to 425 million Euro per year in 2040. However, it is 
likely  that  effect  might  be  overestimated  as  the  exporters  of  used  vehicles  to  non-EU 
countries will adjust their business to the new legal requirements and seek to export more 
(younger?) vehicles with a valid roadworthiness certificate.  
Secondly  all  used  car  dealers  will  experience  due  to continuing  fees  during  the  selling 
phase (where used vehicles are often “temporary de-registered”) additional cost of around 
10€ per sold used vehicle.  

•  Shredder  plants  and  recycling  industry  will  experience  an  increase  in  turnover, 
however as the profit per tonne depolluted and dismantled vehicle is limited we expect 
limited additional profits for shredders of about 3 to 20 million € for PO 3A to 3C. 

•  Vehicle  owners/consumer  will  be  not  affected  by  the  change  in  profits  for  ATFs  and 
used car dealers. However, additional system cost will remain with the consumer of about 
10 € for each used car due to increased cost for the dealers (continuing insurance) 
•  Public  authorities  might  be  affected  by  more  inspection/enforcement  campaigns, 
prepare their registration systems to become interoperable with the systems of other MS, 
more administrative efforts to manage extra EU exports and follow up registration. The 
total effort is estimated to be below 1 € per new registered vehicle.  

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Title 

Policy Option 3A 

Policy Option 3B 

Policy Option 3C 

Table 3-70 Overview economic impacts in 2040 

Vehicle 
owners 

Garages 

Exporters* 

Car 
dealers 

Insurances 

ATFs* 

Shredders* 

-70 M € 

-219 M € 

-425 M € 

Cost of -10 € 
per used car 
sold 

+ 91 M € 
-23 M € 
+ 234 M € 
-73 M € 

+ 344 M € 
-142 M € 

+ 3 M € 

+ 10 M € 

+ 20 M € 

10 € for car 
dealers add. 
effort 

Producers 

National 
authorities 
< 1 € per 
new car 
< 1 € per 
new car 

< 1 € per 
new car 

*Expressed in profits (not turnover) 

Title 

Policy Option 3A 
Reporting on vehicle market and ELVs  

Reporting on incentives and fines (Level A) 
Requirements for MS to establish penalties 

Dismantlers /recyclers to check and report on ELVs 
Minimum requirements for sector inspections  

Implementation and enforcement action regards WFD 
Art 8/8a 

EPR obligation: Collection of abandoned vehicles 
EPR obligation: collection of all vehicles 

3A2 

3A2 
3A2 

3A3 
3A4 

4A1 

4A2 

4A2 

4A3 

EPR obligation: Notification system for CoDs 

Vehicle 
owners 

Garages 

Car 
dealers 

Insurances  ATFs  Shredders 

National 
authorities 

Producers 

AB 

AB/W 
OP 

AB 
AB 
AB 

AB 

AB 

AB 

AB/W 
OP 

OP 

OP 
OP 

OP 

AB 

AB 
AB: 50 € 
per new 
vehicle 
AB 

AB 

AB 

AB 

AB 

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4A4 

3A1 

3B1 
3B2 

3B2 
3B3 

4A1 

3C1 

3C2 

3C3 

4A1 

4B1 
4B2 

4B3 

4B4 

Title 

EPR obligation: Monitor and report on illegal activities 
Policy Option 3Ax  
All measures und 3A plus:  
Establish collection target 
Policy Option 3B 
Interoperability between national registration authorities 
Alignment of terms with Directive 1999/37/EC  

New definition: “temporary de-registration”  
Binding criteria for a distinction of used vehicles / ELVs 

EPR obligation: Collection of abandoned vehicles 
Policy Option 3C 
EU vehicle registration database including harmonised 
procedures and definitions 

(Extra-EU) Export restrictions for used cars linked to 
roadworthiness, age and emission level) 
Include Vehicle Identification Number (VIN) in customs  

EPR obligation: Collection of abandoned vehicles 
Policy Option 4B 
EPR: Compliance cost off-setting 
National DPR schemes (EPR or Public) 

EPR schemes for intra-EU trade 

Link CoD to incentives and penalties 
(Level B: choose the options the MS will have to 
deliver) 

Vehicle 
owners 

Garages 

Car 
dealers 

Insurances  ATFs  Shredders 

OP 

OP 

OP 

W 

W 

W 

W 

W/OPT 

OP 

W 

W 

W 

W 

W 

OP 

W/OP 

W/OP 

OP 

OP 

OP 

National 
authorities 

Producers 

AB 

AB 

AB 

AB 
AB 

AB 

AB 

W 

AB 

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3.2.6  Environmental Impacts 

3.2.6.1  Identification of expected environmental impacts  

The shift of extra EU export of ELVs and (old) vehicles with similar characteristics to ELVs 
may cause the following environmental effects:  

•  Resources available for recycling if treated in the EU (resources not lost) 
• 

In the method of life cycle assessments (LCA) credits are granted for recycling. In this 
case  we  can  consider the  additional  recyclables  available  in  Europe  from  of  additional 
ELVs directed to treatment plants in Europe.  
•  Less (hz) waste in receiving (extra EU) countries 

The shift from illegal (or unreported) treatment within Europe to ATFs may cause the following 
environmental effect:  

• 

Illegal treatment might not treat all refrigerants from the air conditioning system and all 
waste  oil.  If  the  ELVs  are  shifted  to  ATFs  less  losses  of  refrigerants  from  the  air 
conditioning system can occur  

•  Today, standard dismantling and shredding is in most countries completely self-managed 
by the recycling sector, without contribution / funding of the EPR systems. It is expected 
that  the  illegal  ELV  treatment  is  sending  the  same  amounts  of  steel,  aluminium  and 
catalytic converter to recycling and applies the same effort for separation of spare parts. 
In  consequence  no  change  for  the  case  that  more  ELVs  are  shifted  from  illegal  (or 
unreported) treatment within Europe to ATFs. 

No other environmental impacts came to our attention or are did not  

3.2.6.2  Additional resources available for recycling in EU 

If  vehicles,  used  or  ELVs  with  characteristics  similar  to  that  of  ELVs,  are  not  directed  any 
more to extra EU exports, they will be directed to ATFs (or illegal dismantlers in the EU) and 
subsequently to shredders and the resources will then be available for recycling. The effects 
for the available resources are as displayed in Table 3-71 below. 

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Table 3-71 Additional Resources compared to baseline for intra EU recycling in 2040 
for the different Policy Options 

Steel 
Cast Iron 
Wrought 
Aluminium 
Cast Aluminium 
Copper/Brass 
Glass 
Average Plastic 
Platinum 

1000 t 
1000 t 

1000 t 

1000 t 
1000 t 
1000 t 
1000 t 
t 

Baseline 
2040 
6 626 
761 
585 

719 
196 
0 
287 
27 

3A 
2040 
150 
17 
13 

16 
4 
0 
7 
1 

3B 
2040 
468 
54 
41 

51 
14 
0 
20 
2 

3C 
2040 
910 
105 
80 

99 
27 
0 
39 
4 

Pref. PO 
2040 
1 264 
145 
112 

137 
37 
0 
55 
5 

+EPR 
2040 
1 485 
171 
131 

161 
44 
0 
64 
6 

The calculation is based on the following assumptions:  

Source: own calculations 

•  Annex I section 6.9 on Description of the model to calculate the impact assessment:  

o  dynamic generation of ELVs 
o  split in ICV, HEV, PHEV and BEV  
o  Steady state efficiency for the recycling rate respectively loss rate (RR for glass = 0) 

•  Shift of vehicles from export to intra EU treatment. 
•  Without consideration of effects of measures to support circularity. 

The complete table for all Policy options and the years 2025, 2030, 2035 and 2040 is attached 
in Annex I, section 6.6.2.5.  

3.2.6.3  LCA credits for recycling of additional ELVs  

The  environmental  credits  for  recycling  when  calculating  the  above-mentioned  resources 
available for recycling are displayed in Figure 3-37 below. The credits for the policy options 
compared to the baseline are displayed in  

The credits are calculated with the LCA method as explained in the section on circularity.  

The calculation is based on the following assumptions:  

•  Annex I section 6.9 on Description of the model to calculate the impact assessment:  

o  dynamic generation of ELVs 
o  split in ICV, HEV, PHEV and BEV  
o  Steady state efficiency for the recycling rate / respectively loss rate (RR for glass = 0) 
o  Credits for recycled material 

•  Shift of vehicles from export to intra EU treatment. 
•  Without consideration of effects of measures to support circularity. 

The complete set of figures for all Policy options and the years 2025, 2030, 2035 and 2040 
is attached in Annex I, section 6.6.2.5. 

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Figure 3-37  Credits in 2040 for recycling due to shift from export (used and ELVs) to 
EU domestic treatment; aggregate; LCA unit: GWP 100a [1000 t CO2 eq] 

baseline

3A

3B

3C

Pref. PO

+EPR

0

-5 000

-10 000

-15 000

-20 000

-25 000

-30 000

-35 000

-40 000

Cast Aluminum

Wrought Aluminum Steel

Cast Iron

Copper/Brass

Platinum

Average Plastic

Source: own calculations 

Table 3-72 Additional Credits compared to baseline for intra EU recycling in 2040 for 
the different Policy Options 

Steel 

Cast Iron 

Wrought 
Aluminium 

Cast Aluminium 

Copper/Brass 

Glass 

Average Plastic 

Platinum 

Total  

1000 t 
CO2 eq 
1000 t 
CO2 eq 
1000 t 
CO2 eq 
1000 t 
CO2 eq 
1000 t 
CO2 eq 
1000 t 
CO2 eq 
1000 t 
CO2 eq 
1000 t 
CO2 eq 
1000 t 
CO2 eq 

Baseline 
2040 

8 084 

860 

8 844 

9 936 

715 

0 

545 

1 388 

3A 
2040 

183 

19 

201 

225 

16 

0 

12 

31 

3B 
2040 

571 

61 

625 

702 

51 

0 

39 

98 

3C 
2040 

1 110 

Pref. PO 
2040 

1 542 

+EPR 
2040 

1 811 

118 

164 

193 

1 215 

1 687 

1 982 

1 365 

1 895 

2 226 

98 

0 

75 

191 

136 

0 

104 

265 

160 

0 

122 

311 

30 373 

689 

2 147 

4 172 

5 792 

6 805 

Source: own calculations 

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3.2.6.4  Losses of refrigerants from the air conditioning system 

According to the  EU  ELV  rules,  ELV  must  be  depolluted  and  inter  alia  the  coolants for  air 
conditioning  must  be  separated  to  avoid  that  the  coolant  is  discharged  to  the  air.  As  the 
coolants are very volatile, this requires special extraction systems. If only a limited number of 
vehicles is depolluted it is economically not viable to invest in such extraction systems. 

To calculate the impact of refrigerant losses, many variables need to be considered: 

•  The  proportion  of  ELVs  with  air  conditioners  treated  by  non-ATFs  and  the  amount  of 

refrigerant299 per air conditioner. 
•  The equipment of these non-ATFs. 
•  The year of manufacture of the ELV, as it determines the type of refrigerant. 

Considering these aspects, the German Umweltbundesamt commissioned a comprehensive 
study  to  estimate  inter  alia  the  impacts  losses  of  refrigerants  from  the  air  conditioning 
system.300: The study assessed the potential impact and concluded that the coolant R12 (with 
a  GWP100  of  10.890  CO2eq),  which  was  phased  out  the  latest  1995,  are  not  relevant 
anymore. However, the coolant R134a (phased out the latest in 2017) is relevant300. 

As R134a is replaced by R1234yf and R744 (CO2), the GWP from treatment of end-of-life 
vehicles in illegal dismantlers will decrease after 2032.  

The  problematic  production  of  trifluoroacetic  acid  (TFA)  from  R1234yf  will  remain 
(Zimmermann et.al. 2022).  

Table 3-73 Refrigerants in air conditioning of vehicles 

Refrigerants 

R12 

R134a  

R1234yf  

R744 (CO2) 

Refrigerants In 
use for new 
vehicles 

Global Warming 
potential  
(CO2 eq) 

< 1995 

1990 bis 2017 

2011 ongoing 

2016 ongoing 

10 890 

1 430 

4 

1 

Source: (Zimmermann et.al. 2022) 

For the year 2018 the study considered an average volume of 600 gram per air condition and 
a share of ELVs equipped with air condition of 75% in scenario A and 92.6% in scenario B. 
For the year 2018 the report refers to a share of 2 % R1234f from ELVs and 98% R134a. For 
the  impact  assessment  below,  we  consider  that  95 %  of  all  coolants  from  exported  used 
vehicles / ELVs and ELVs treated in non-ATFs in EU are released to air. 

299 According to source below: Assumption for the calculation below: 600 g per ELV with air conditioning; apparently this value 
is questioned as a relevant share of air conditioners might be broken and have lost their coolant anyhow, thus it cannot 
avoided / collected by better collection and depollution.  

300 Zimmermann, T.; Sander, K.; Memelink, R.; Knode, M.; Freier, M.; Porsch, L.; Schomerus, T.; Wilkes, S.; Flormann. P. 
(2022): Auswirkungen illegaler Altfahrzeugverwertung, Publisher: Umweltbundesamt, Dessau, Germany, Publication in 
preparation 

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To assess the environmental impacts of the released R1234f the following assumptions apply 

1) Vehicles placed on the market and share of new vehicles equipped with R134a.301 The 
time series ends in 2021 as the application of R134a is phased out. 

Table 3-74 Refrigerants in air conditioning of vehicles 

Source: own calculations from different sources 

301 Source: Zimmermann, T.; Sander, K.; Memelink, R.; Knode, M.; Freier, M.; Porsch, L.; Schomerus, T.; 
Wilkes, S.; Flormann. P. (2022): Auswirkungen illegaler Altfahrzeugverwertung, [Impacts of illegal treatment of 
ELVs]. Texte 129/2022; Publisher: Umweltbundesamt, Dessau, Germany, November 2022; ISSN 1862-4804;  

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2) To assess the lifetime of the vehicle the same Weibull function as for the fleet model is 
applied. The Weibull parameters for the lifetime of a vehicle are displayed in the figure below. 

Figure 3-38  Lifetime distribution of vehicles 

3) Loss rate for the different destinations of the vehicle  

As  addressed  in  other  sections  (on  “missing  vehicles”)  we  distinguish  different  locations 
where the vehicles become an end-of-life vehicle. We distinguish the following cases: 

With  

A) ELVs directed to ATFs and subsequently to shredders and reported by ATFs and MS  

B) ELVs directed to ATFs and subsequently to shredders but not reported  

C) ELVs directed to intra-EU non-ATFs and subsequently to shredders, not reported  

D) Used Vehicles exported (extra EU) and reported accordingly  

E) Used Vehicles exported (extra EU) but not reported 

F) ELVs exported (extra EU), not reported 

As outlined in the German report mentioned earlier300 it is expected that a certain proportion 
of the coolant from the air-conditioning system of ELVs is not extracted in accordance with 
the regulations but is released uncontrolled to the air.  

Transposing these assumptions to the 6 categories above, we consider for the calculation of 
the  impact  that  the  following  share  of  coolant  is  not  extracted  in  accordance  with  the 
regulations but is released uncontrolled to the air (=loss rate) 

Destination where vehicles become ELVs and their loss rate 

(A)  ELVs directed to ATFs: 10% 

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(B)  ELVs directed to ATFs but not reported: 70% 

(C)  ELVs directed to intra-EU non-ATFs  : 70% 

(D), (E) and (F): extra EU export: 100% 

4) The above-mentioned data / assumptions are finally combined with the total numbers of 
ELVs directed to the 6 different destinations as calculated for the different scenarios under 
“missing vehicles”.  

The results are displayed in the Figure 3-39 and Table 3-75. 

Figure 3-39  GHG Emissions from coolants for the Policy Options 

Diagrammtitel

)
q
e
2
O
C
s
n
o
t
n
o

i
l
l
i

m

(
P
W
G

5 000

4 500

4 000

3 500

3 000

2 500

2 000

1 500

1 000

500

0

2025

2030

2035

2040

Baseline

PO A

PO B

PO C

pref. PO

+ EPR

Source: own calculations 

Table 3-75 GHG Emissions from coolants in million tons CO2eq compared to baseline 

Source: own calculations 

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3.2.6.5  Less (hz) waste in receiving countries 

If a used car is imported with a similar age as an ELV, e.g. 15 - 20 years, only a reduced 
service life remains and more waste is generated per kilometre driven, since the old vehicle 
must be replaced after another 10 years at the latest, for example. Thus, it can only be used 
for  10  years  instead  of  30  before  it  becomes  an  ELV.  As  a  result,  the  number  of  ELVs 
generated for the same purpose is three times higher in the receiving country. If the import to 
that country is limited to 5 years old vehicles the vehicle can last longer and less waste is 
generated per km. 

3.2.7  Social Impacts 

3.2.7.1  Employment 

According to Zimmermann et.al (2022), a shift of 363 000 ELV from the illegal to the legal 
sector plus a shift of 72 600 ELVs from illegal export to national ATF will cause between 300 
to 1200 additional employment subject to social security contributions (Full Time Equivalents, 
FTE) so 1 to 3 FTEs per 1000 vehicles. For the calculation we consider 1.5 FTE per 1000 
vehicles directed to the legal ATFs (category A and B). Whether the on-off effects of increased 
exports  shortly  in  advance  to  the  implementation  (last  chance  to  export  old  used  vehicles 
without roadworthiness certificate) of the export limitation becomes effective is to be seen or 
if the employers bridge this period (as they are in parts involved in the export activities and 
can shift staff. 

Table 3-76 Additional employees at ATFs in EU-27 for the Policy Options in million 
Euro compared to Baseline 

Source: own calculations  

3.2.7.2  Less air pollutant in receiving countries 

In the study (UNEP 2020) is a comprehensive section on the aspect of road safety which is 
below cited in full text:   

“Vehicles are among the most rapidly growing sources of pollution and present a major public 
health  risk  particularly  in  regions  where  growing  motorization  is  not  coupled  with  effective 
vehicle emission regulations. Vehicles, both gasoline and diesel, emit significant quantities of 
nitrogen oxides, sulphur oxides, particles, carbon monoxide and hydrocarbon. This cocktail 
of  pollutants  and  particles  are  responsible  for  strokes,  chronic  respiratory  diseases,  lung 
cancer, ischemic heart disease, diabetes, and other non-communicable diseases (HEI,2018). 
In  2012,  the  World  Health  Organisation  International  Agency  for  Research  on  Cancer 
classified diesel exhaust Particulate Matter (PM) as a Group 1 carcinogen (= causing cancer).  

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Reducing pollutants emissions from vehicles requires the use of clean vehicles technologies, 
especially exhaust after treatment technology. Catalytic converters that filter exhaust gasses 
from petrol vehicles can reduce pollutants by 90 per cent or more. And diesel particulate filters 
can filter more than 99 per cent of small particulates emitted by diesel vehicles.  

Rising  levels  of carbon dioxide  (CO2)  in  the  atmosphere  are  causing  global  warming.  The 
global vehicle fleet CO2 emissions are increasing faster than any other sector. Today CO2 
emissions  from the  global  fleet  are responsible  for  about  one  quarter  of all  energy  related 
CO2 emissions. This is set to go to one-third by 2050. Governments are now introducing strict 
regulations for the CO2 emissions of vehicles. Further, black carbon (BC), which comprises 
a  substantial  portion  of  small  particulates  is  an  important  climate  forcer,  contributing 
significantly  to  short-term  global  warming.  To  control  and  reduce  emissions  from  vehicles, 
countries put in place vehicle emission standards which define the quality of the mixture of 
exhaust gases at the tailpipe of vehicles. Automobile manufacturers are obliged to adhere to 
these standards in the territories where they are enforced as it forms part of a vehicle type 
approval process. Vehicle emission standards have been implemented since the early 90s. 
Many countries use the EU model of vehicle emission standards called the EURO standards. 
However, other countries have developed equivalent standards with varying implementation 
dates  i.e.  the  US,  China,  Japan,  and  India  have  their  own  vehicles  emissions  standards 
comparable with the EURO standards. […] Each of the emission standard is matched by a 
specified  fuel  quality  that  progressively  improves  with  every  standard  for  both  diesel  and 
gasoline. The used vehicles imported in low- and middle-income countries often do not meet 
advanced vehicles emissions standards. This can be because countries import older vehicles 
that date back from before the introduction of vehicles emissions standards or only meet the 
earlier, older, standards such Euro 1 to 3. In addition, some used vehicles have damaged or 
failing emission-control systems. There is a market for old vehicles filters (to recycle precious 
metals  used  in  these  filters)  and  as  a  result  some  of  the  used  vehicles  have  their  filters 
removed, often illegally, before export. Repair or replacement of vehicle emissions filters can 
be costly and when these filters are found to be faulty exporters may opt to export the vehicles 
rather than to invest in fixing the filter. So, there is a share of used vehicles that do not have 
emissions controls technologies installed, in some cases these systems have failed, in others 
they have been illegally removed.” 

While  it  is  not  possible  to  calculate  the  impacts  of  the  policy  options  on  the  emission  and 
immission  and  early  deaths  due  to  strokes,  chronic  respiratory  diseases,  lung  cancer, 
ischemic heart disease, diabetes, and other non-communicable diseases, it is obvious that a 
regulation for the functioning of the emission standard and more general the roadworthiness 
of the vehicles from the EU is strongly required.  

The conclusion of Inger Andersen, the UNEP Executive Director is with this regard more than 
valid.  

“Over  the  years,  developed  countries  have  increasingly  exported  their  used  vehicles  to 
developing countries; because this largely happens unregulated, this has become the export 
of  polluting  vehicles.  …  Developed  countries  must  stop  exporting  vehicles  that  fail 
environment  and  safety inspections  and  are  no  longer  considered  roadworthy  in their  own 
countries, while importing countries should introduce stronger quality standards”302 

At the same time, it is obvious that receiving countries need to improve regulation and control 
of emission reduction and roadworthiness in their own territories as well. Only a joint effort of 
exporting  and  importing  countries  could  succeed  in  improving  the  current  unpleasant 
situation. 

302 https://news.un.org/en/story/2020/10/1076202 

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3.2.7.3  Better road safety equipment of vehicle fleet in receiving 

countries 

In the study (UNEP 2020) is a comprehensive section on the aspect of road safety which is 
below cited in full text:  

“Poor  quality  used  vehicles  do  not  only  impact  climate  change  and  air  quality  but  also 
compromise road safety, particularly in low- and middle-income countries which often have 
“weak” or “very weak” used vehicle regulatory rankings. Road crashes kill an estimated 1.25 
million people each year and injure between 20-50 million more. It is the leading cause of 
death  for  young  people  aged  15-29  and  the  eighth  leading  cause  of  death  globally 
(WHO,2018).  Ninety  per  cent  of  these  deaths  occur  in  low  and  middle-income  countries, 
despite  these  countries  having  just  54  per  cent  of  the  global  vehicle  fleet.  Africa  has  the 
highest road traffic fatality rates with 246,000 deaths occurring each year and this number is 
projected to increase by 112 per cent, to 514,000 in 2030 (WHO, 2015). This contrasts with 
the  projected reduction  in  fatalities  in  Asia-Pacific,  Europe,  and  Central Asia  (World  Bank, 
2014). 

Road crashes impose a huge economic toll worldwide, totalling a loss of up to three per cent 
of the global GDP and up to five per cent of GDP for low and middle-income countries (WHO, 
2015). Road traffic injuries are estimated to cost the global economy US$1.85 trillion each 
year (IRAP, 2015). Road injuries and losses in many countries are not mitigated by adequate 
insurance coverage or social safety nets, and families can be left with crippling health care 
costs  and  the  loss  of  primary  income  earners.  The  highest  burden  of  death  and  long-term 
disability is on adults in their prime working age. An estimated 12-70 million people are kept 
in poverty each year due to road traffic injuries and fatalities (iRAP, 2015).  

Used vehicles often have compromised roadworthiness and crashworthiness in direct relation 
to their age, degree of wear and tear and technical design (Cosciug, Ciobanu & Benedek, 
2017).  The  informal  character  of  the  used  vehicle  trade  further  perpetuates  the  import  of 
vehicles with mechanical and safety defects. Although there are several factors that influence 
road safety and reliable data on road traffic injuries is scarce, there is increasing evidence on 
the links between road safety and used vehicles (Alloweg, Hayshi and Hirokazu 2011).  

Studies have shown that passengers of older vehicles with greater wear (e.g. higher mileage, 
undisclosed  crash  damages)  have  an  increased  risk  of  injury  compared  to  passengers  of 
younger vehicles. A study by the Monash University Accident Research Centre based on data 
from  New  Zealand  found  that  there  was  an  overall  increase  in  vehicle  crash  risk  with 
increasing  vehicle  age.  The  increase  in  risk  with  each  added  year  of  vehicle  age  was 
estimated to be 7.8 per cent (Keall, et al., 2012). Many countries with “very weak” or “weak” 
used vehicle regulatory rankings such as Malawi, Nigeria, Zimbabwe, and Burundi also have 
a very high road traffic death rate. Liberia, which has the highest rate of road traffic deaths in 
the  world  (35.9/100  000),  imports  vehicles from  the  Monrovia  port that  are  up  to  10  years 
old.21 By contrast, Chad, which is one of the few African countries with a ‘good’ ranking has 
a 27.6/100 000 road traffic death rate and does not accept vehicles more than five years old.” 

While  it  is  not  possible  to  calculate  the  impacts  of  the  policy  options  on  the  annual  death 
occurring it is obvious that a regulation for the quality of the vehicles from the EU is strongly 
required. The conclusion of Inger Andersen, the UNEP Executive Director is with this regard 
more than valid.  

“Over  the  years,  developed  countries  have  increasingly  exported  their  used  vehicles  to 
developing countries; because this largely happens unregulated, this has become the export 
of  polluting  vehicles.  …  Developed  countries  must  stop  exporting  vehicles  that  fail 

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environment  and  safety inspections  and  are  no  longer  considered  roadworthy  in their  own 
countries, while importing countries should introduce stronger quality standards”303 

At the same time, it is obvious that receiving countries need to improve regulation and control 
of  roadworthiness  and  road  safety  in  their  own  territories  as  well.  Only  a  joint  effort  of 
exporting  and  importing  countries  could  succeed  in  improving  the  current  unpleasant 
situation. 

3.2.8  Comparison of the options 

According  to  BRG  Toolkit  #11,  “the  comparison  of  options  should  always  address  the 
effectiveness, efficiency, and coherence of the options in relation to the specific objectives 
defined. 

•  The comparison of options should highlight key economic, social and environmental 

impacts, including when these are not part of the objectives. 

•  Their costs and proportionality to the issue at hand. 
•  The benefit/cost ratio, cost-effectiveness or net present value, if available; 
•  Their coherence with other EU policy objectives, including the Charter for fundamental 
rights, and with other policy initiatives and instruments (coherence) including the SDGs; 

The comparison should clearly present trade-offs reflected in the choice of options and the 
likely uncertainty in the key findings and conclusions and how these might affect the choice 
of preferred option should be analysed. 

Table 3-77 Summarising table for the comparison of the options 

Impact on  

Option 3A 

Option 3B 

Option 3C 

ATFs 

Limited positive impacts 
on profits of ATFs (+ 93 
m€ in 2040); main 
reason: no target. 
-/- to + 

Shredders  

Limited positive effects 
on profit (4 m€ in 2040) 
close to marginal. -/- 

(used) car 
dealers 

No impact -/- 

The target causes 
higher positive 
impacts on profits of 
ATFs, mobilising 
addition profits of 
184 m€ in 2040 
compared to the 
baseline, however 
not the full potential 
is mobilised. + 

Limited positive 
effects on profit (9 
m€ in 2040) close to 
marginal -/- 

If fees might 
continue during a 
temporary 
deregistration this 
might cause 10€ per 
sold vehicle - 

Positive impacts to 
ATFs (230 m€ in 
2040), 
implementation and 
enforcement 
hampered by missing 
target nor strong 
incentives, the 
potential is not fully 
mobilised. + 

Limited positive 
effects on profit (16 
m€ in 2040) near to 
marginal -/- 

Caused by export 
limitations exporters 
might experience 
losses in profits of 
~350 m€ in 2040 - 

c
i
m
o
n
o
c
E

SME  

Currently ATFs are dominated by SMEs. The measures under 3A/B/C have 
no impacts on the size of the operators. -/- 
As in the context of stricter EPR rules more administrative structures are 
expected, we expect slide trend to larger operators but possibly not 
exceeding the definition of small size operators (<50 employees). -/- 

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Impact on  

Option 3A 

Option 3B 

Option 3C 

OEMs / 
Producers 

Under the Options 3A – 3C the OEMs are not involved -/- 
but if it comes to EPR (see below the combination with the preferred policy 
options cost occur for the OEMs / Producers 

Consumers / 
Other  

Economic impacts on other stakeholders can be compared to the total cost 
of vehicles and are considered as marginal -/- 

Costs / Burden 
for public 
administration 
in MS 

Effectively no additional 
burdens only a few more 
reporting. 
-/- 

One-off cost occurs 
for changes in 
registration 
procedures and 
monitoring and the 
like. However, 
compared to the 
current cost 
marginal. 
-/- 

One-off cost occurs 
in registration and 
customs services 
procedures. The 
admin workflow shall 
be fully based on 
advance IT tools (no 
case-by-case 
investigations). If so, 
the cost will remain 
marginal. 
-/- 

More 2ndary 
resources 
available in EU 

LCA credits for 
recycling in 
2040  

~0.19 million tons, 
compared to the 
baseline + 

~0.7 m tons CO2 eq 
compared to the 
baseline + 

~0.58 million tons, 
compared to the 
baseline + 

~1.1 million tons 
compared to the 
baseline + 

~2.1 m tons CO2 eq 
compared to the 
baseline + 

~4.2 m tons CO2 eq 
compared to the 
baseline + 

Losses of 
refrigerants  

Less (hz) 
waste in 
receiving 
countries of 
export 

Currently emissions of 3.5 to 4.5 million tons CO2 eq considered from export 
of used vehicles and in illegal depollution in EU. Each additional ELV 
directed to ATFs will improve the situation. + 
The exact level is difficult to calculate as in parallel new coolants were 
introduced in 2017 with much lower Global Warming Potential. 

This impact is difficult to calculate, however longer use phase in the 
receiving countries will obviously reduce the waste volume in these 
countries. The Option 3C + is with this regard more effective than 3a and 3B 
-/- 

Employment in 
2040 

+ ~550 FTE, close to 
marginal -/- 

+ ~1 250 FTE, close 
to marginal, -/- 

+ ~2 000 FTE, close 
to marginal, -/- 

Benefits for 
health and 
safety in 
receiving 
countries of 
export 

This impact is difficult to calculate. However, UNEP is asking developed 
countries to export roadworthy vehicles only.  

9% less used vehicles 
exported (of the current 
quality) + 

24% less used 
vehicles exported 
(of the current 
quality) + 

43% less used 
vehicles exported (of 
the current quality) 
++ 

Cost 
effectiveness  

Costs and burdens are for all options marginal while some economic 
potential and environmental improvement can be mobilised but not fully 
realised + 

Coherence 

the measures under the Policy Options are designed to be coherent + 

l
a
t
n
e
m
n
o
r
i
v
n
E

l
a
i
c
o
S

Notes: 

-/-: no impact 

Costs or burdens: between 1 and 3 minus signs (-; --; or ---), indicating low (1 minus sign) and high (3 minus signs) costs or 
burdens 

Benefits or savings: between 1 and 3 plus signs (+; ++; or +++), indicating low to high savings 

(): brackets around symbols if costs, benefits etc. are only potentials or are uncertain. If the costs, benefits etc. is rather 
uncertain, a broader range is indicated: e.g. ++ to +++ or – to + 

n.a.: not applicable 

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3.2.9  Preferred Policy Option 

As demonstrated in the Impact Assessment for the 3 Policy Option above, all three Policy 
Options  have  their  specific  shortcomings  and  as  already  mentioned  in  the  study  with 
emphasis on the end of life vehicles of unknown whereabouts with focus on missing vehicles 
(Mehlhart et al. 2017) and more recently in the context of the stakeholder involvement of this 
Impact  Assessment  in  2022,  a  combination  is  necessary  of  measures,  addressing  the 
different reasons for the missing vehicles as displayed below in Figure 3-40 under Number 1 
to 4.  

In consequence the measures as displayed in Table 3-78 are selected for the preferred policy 
option. Subsequently the impacts of the preferred Policy Option are assessed in detail.  

Figure 3-40  Combination of measures is required to reduce the number of missing 
vehicles, in brackets the reference to the number of the measure) 

1. Incentives and / or penalties to 
make use of CoDs (1.1b, 2.3)

5. EPR schemes to promote 
circular production and ELV 
collection and treatment 
and strengthen 
competitiveness of ATFs

4. Fight against illegal 
treatment and illegal export 
of ELVs and EHS problems in 
receiving countries 
(2.5, 2.6, 2.7b, 3.3)

2. Improvement 
of registration and de-
registration procedures
(1.2 - 1.7)

3. Better statistics on vehicle 
stock and import / export to 
demonstrate compliance at 
Member State level 
(1.9)

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Table 3-78 Summarising table for the comparison of the options 

The numbers refer to the chapter where the potential measures are described 

Red italic letters = discarded measure 

Grey box = not considered for the preferred Policy Option 

blue box = preferred Policy Option  

Objective 3.1: 
Ensure that all ELVs are treated in 
accordance with the requirements of 
the ELV Directive 

Objective 3.2: 
Reduce levels of illegal dismantling 
and illegal export of ELVs 

1.1a  Reporting  and  exchange  of  best 

practices on Incentives (Level A) 

2.1 Exchange on MS best practice 

Objective 3.3: 
Enforceable criteria to avoid the 
export of (used) cars which do not 
meet roadworthiness or minimal 
environmental standards 

3.1  Action  at  international  level  to 
support 
that  roadworthiness  (and 
others)  become  criteria  for  export  of 
used vehicles. 

1.1b MS to demonstrate implementation 

of Incentives (Level B) 

2.2 Voluntary campaigns on export  

3.2. EU funding for enforcement 

1.2 Alignment of terms  

2.3  Effective  Deposit  Refund  Scheme 

(voluntary for MS) 

1.3 Definition of temporary deregistration   2.4 EU wide Deposit Refund scheme  

restriction 

3.3  Export 
to 
rules  of 
roadworthiness; 
receiving  countries  regards  age  and 
emission level 

respect 

linked 

1.4  a  Conclusive  list  of  conditions  for 
the 

cancellation 

of 

permanent 
registration *1 

2.5 Better definition of ELVs 

1.4  b  Management  of 

temporary 

2.6  Minimum  requirements  for  sector 

deregistration*1 

inspections 

2.7a  MS  are  encouraged  to  establish 
illegal 
fines  and  penalties 
activities of owners and operators of 
treatment plants 

for 

2.7b MS are required to establish fines 
and  penalties  for  illegal  activities  of 
owners  and  operators  of  treatment 
plants 

1.5  ATFs  and  shredders  to  check  and 

report on ELVs / CoDs  

1.6 interoperability of national registers *1 

1.7 VIN in customs declaration 

1.8  EU  vehicle  registration  data  base-

system 

1.9  Reporting  obligation  on  the  current 

vehicle market  

1.10 collection target 

*1 might be in parts implemented by other EU Legislations under supervision of DG Move. 

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For the comfortable reading and less repetition, the detailed impacts for the preferred policy 
option  are  displayed  together  with  the  calculations  for  the  Policy  Options  3A/3B/3C.  The 
overview of the impacts is displayed more blow  

3.2.9.1  Interrelations with preferred option regards the EPR 

Several  of  the  measures  addressing  the  implementation  of  the  Extended  Producer 
Responsibility (EPR) also have effects on the missing vehicle and are added to Figure 3-40 
as Number 5.  

Table 3-80 displays the detailed obligations for MS and Producers under the EPR regime. 
Most of them have a positive impact and might contribute to reduce the number of missing 
vehicles.  

3.2.9.2  Overview of impacts of the preferred policy option and the 
interrelations  with  the  preferred  measures  regards  the 
regulation of the EPR 

Table 3-79 Overview of impacts of the preferred policy option and the interrelations 
with the preferred measures regards the regulation of the EPR 

Impact on  

Preferred Policy Option 
“Missing vehicles” 

Preferred Policy Option “Missing 
vehicles” + EPR 

ATFs 

ATFs (~500 m€ in 2040; the potential 
is almost fully mobilised. ++ 

ATFs (~500 m€ in 2040; the potential is 
almost not fully mobilised. +++ 

Shredders  

Positive effects on profit ((~22 m€ in 
2040) + 

Positive effects on profit ((~26 m€ in 2040) 
+ 

(used) 
dealers 

car 

c
i
m
o
n
o
c
E

SME  

If fees continue during a temporary deregistration this might cause (~10€ per sold 
(used) vehicle - 

Caused by export limitations 
exporters might experience losses in 
profits of ~470 m€ in 2040 -- 

Caused by export limitations exporters 
might experience losses in profits of ~550 
m€ in 2040 -- 

Currently ATFs are dominated by 
SMEs. The preferred policy option 
has no impacts on the size of the 
operators.  
-/- 

As in the context of stricter EPR rules more 
administrative structures are expected, we 
expect slide trend to larger operators but 
possibly not exceeding the definition of 
small size operators (<50 employees). -/- 

OEMs 
Producers 

Consumers 
Other  

/ 

/ 

OEMs are not involved in measures 
under the preferred policy option  
-/- 

When stricter rules for EPR are applied, 
including compliance cost offsetting, cost 
occur for the OEMs / Producers (see 
separate assessments) -- 

Economic impacts on other stakeholders can be compared to the total cost of 
vehicles and are considered as marginal -/- 

Costs  /  Burden 
public 
for 

One-off cost occurs in registration and customs services procedures. The admin 
workflow shall be fully based on advance IT tools (no case-by-case investigations of 

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Impact on  

administration in 
MS 

Preferred Policy Option 
“Missing vehicles” 

Preferred Policy Option “Missing 
vehicles” + EPR 

public staff). If so, the cost will remain marginal. 
-/- 

2ndary 

More 
resources 
available in EU 

~1.6 million tons, compared to the 
baseline  
++ 

~1.8 million tons, compared to the baseline  
+++ 

LCA  credits  for 
in 
recycling 
2040  

~5.8 million tons CO2 eq compared to 
the baseline 
 ++ 

~6.7 million tons CO2 eq compared to the 
baseline  
+++ 

Losses 
refrigerants  

of 

Less  (hz)  waste 
receiving 
in 
countries 
of 
export 

Employment 
2040 

in 

Currently emissions of 3.5 to 4.5 million tons CO2 eq considered from export of used 
vehicles and in illegal depollution in EU. Each additional ELV directed to ATFs will 
improve the situation. ++ 
The exact level is difficult to calculate as in parallel new coolants were introduced in 
2017 with much lower Global Warming Potential. 

This impact is difficult to calculate, however longer use phase in the receiving 
countries will obviously reduce the waste volume in these countries.  
++ 

+ ~3 300 FTE + 

+ ~3 800 FTE + 

l

a
t
n
e
m
n
o
r
i

v
n
E

Benefits 
health 
safety 
receiving 
countries 
export 

l
a
i
c
o
S

This impact is difficult to calculate. However, UNEP is asking developed countries to 
export roadworthy vehicles only.  

for 
and 
in 

of 

58%  less  used  vehicles  exported  (of 
the current quality) ++ 

68%  less  used  vehicles  exported  (of  the 
current quality) +++ 

Cost 
effectiveness  

Costs and burdens are for all options marginal while some economic potential and 
environmental improvement can be mobilised but not fully realised + 

Coherence 

the measures under the Policy Options are designed to be coherent + 

Notes: 

-/-: no impact 

Costs or burdens: between 1 and 3 minus signs (-; --; or ---), indicating low (1 minus sign) and high (3 minus signs) costs or 
burdens 

Benefits or savings: between 1 and 3 plus signs (+; ++; or +++), indicating low to high savings 

(): brackets around symbols if costs, benefits etc. are only potentials or are uncertain. If the costs, benefits etc. is rather 
uncertain, a broader range is indicated: e.g. ++ to +++ or – to + 

n.a.: not applicable 

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3.2.9.3  Interrelations with preferred option regards the circularity 

In  general,  the  interrelation  with  measures  selected  to  improve  design  for  circularity  and 
measures selected to improved reuse and recycling will have additional positive impacts on 
the number of missing vehicles.  

It is important to note that, if ATFs were subject to additional burdens related to circular 
economy  without  adequate  compensation,  this  would  clearly  challenge  the  legal 
sector, and the illegal sector (which avoids unprofitable circular economy obligations) 
would  be  expected  to  increase.  Such  a  combination  (higher  burden  on  ATFs  /  no 
compensation for compliance costs) would clearly jeopardize the goal of reducing the 
number of missing vehicles.  

3.2.10  Reporting and monitoring requirements 

This aspect is addressed in detail in the description of Measure 2.2.5.1.9 Improve reporting 
obligations  on  the  current  vehicle  market  and  the  ELVs  on  their  territory.  This  measure  is 
included in the preferred Policy Option.  

3.3  Extended Producer Responsibility (EPR) 

3.3.1  Identification of discarded measures 

With the aim to have a shortlist of measures for further assessment, all measures are checked 
for feasibility and effectiveness. This step is not to be confused with the impact assessment 
itself and therefore does not include all categories of impact assessment (economic, social, 
and environmental). 

The  details  of  this  check  for  feasibility  and  effectiveness  are  displayed  in  Section  6.8.1  in 
Annex I.  

In  result  the  following  of  the  mentioned  measures  above  are  discarded.  All  others  are 
shortlisted for the detailed assessment 

2.3b  Support / software interfaces to international notification system 

4.1   Deposit Refund Schemes (DRF) manged by EPR scheme 

The remaining measures are shortlisted 

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3.3.2  Overview of measures and relation to “missing vehicles” and 

“circularity” 

Table 3-80 Measures in the context of the EPR regime with impact on the aspect of 
missing vehicles 

Red italic letters = discarded measure 
Not considered for the preferred option, see below in section 3.3.4, Table 3-81 

1. Specification of general minimum requirements of Art 8/8a WFD: 
Obligations for the Member States 

By when 

Relevant for 

missing 
vehicles 

Circularity  

1.1 Obligation for all MS to establish national EPR schemes 

+2 ys 

1.2 MS to report on implementation and enforcement action regards Art 

8/8a WFD and the specifications of EPR in the ELV Regulation  

+ 3 ys, + 
6 ys 

1.3 MS to establish an independent competent authority (clearing house) 

for monitoring, supervision, moderation of the EPR schemes and 
publication of rules / specifications for the implementation of the 
national EPR scheme 

+2 ys 

2. Specification of general minimum requirements of Art 8/8a WFD: 
Obligations for Producers to cover cost for  

2.1 Collection of vehicles at holder’s premises and abandoned vehicles 

free of charge for the last holder. 
 specification of WFD Art 8a(3) point (b) 

2.2 Awareness raising of last holder to deliver ELVs to ATFs 

2.3a Notification/ software / application / system for ELV, CoD and final 
cancellation of the registration to the national authorities and PROs  

2.3b.Support / software interfaces to international notification system 

+2 ys 

+ 2ys 

X 

X 

X 

X 

X 

X 

2.4 Rules, software and plausibility checks for the monitoring of material 

flows, with the aim to demonstrate compliance with RRR targets. 

+ 2ys 

2.5 Monitoring and reporting on illegal activities in the sector to 

responsible authorities (police and environmental inspectorate)  

+ 2ys 

X 

2.6. Training of staff from dismantling/recycling sector regards necessary 
technical skills (e.g. for management of EV); training on how to use 
reporting tools 

+2ys 

2.7 Provision of easy access to harmonised information for new 

registered vehicles (and for vehicles registered before the ELV 
regulation entered into force) 

+2 ys (+4) 

2.8 Fee modulation based on circularity features  

2.9 Compliance cost offsetting  

3. Advanced European EPR  

3.1 EPR schemes for intra EU trade (delegated / implementing act) 

3.2 European EPR for the EU market (feasibility study) 

4. Advance economic incentives 

4.1 Deposit Refund Schemes (DRF) manged by EPR scheme 

+4 ys 

+4 ys 

+2 ys 

+2 ys 

X 

X 

X 

X 

X 

X 

Not yet 

Not yet 

Not yet 

Not yet 

4.2 Green Public Procurement 

+2 ys 

X 

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3.3.3  Methodology 

Extended Producer Responsibility Schemes are not an objective by itself compared to the 
reduction  of  “missing  vehicles”  or  the  more  advanced  “circularity”.  Instead,  the  EPR  is 
developed to ensure that producers become responsible for the end-of-life management of 
their products. The legal requirements, as elaborated in the chapter “circularity” and “missing 
vehicles”,  define  the  compliance  level  for  the  end-of-life  management  and  also  include 
measures which are addressing the design for circularity (with the aim to reduce the end-of-
pipe effort for the Producers). The definition of obligations for Member States and Producers 
are  therefore  inevitable  measures  (as  the  “compliance  cost  compensation”)  or  supportive 
ones  (as  training  or  reporting)  which  should  help  the  ATFs  and  shredder  to  operate  most 
efficient.  

Therefore, the economic, environmental and social impacts are not elaborated in the same 
methodology  as  for  the  other  sectors  as  these  impact  relay  more  on  the  defined  level  of 
compliance under “circularity” and “missing vehicles” and less on the structure of the EPR.  

Nevertheless, it is important to assess the direct (often administrative) effort connected to the 
obligations under the EPR for both Member States and Producers as done in this section.  

Regards ATFs it is worth to note that, if the (increasing) compliance cost for circularity will be 
not  compensated,  it  is  most  likely  that  more  vehicles  will  be  directed  to  illegal  treatment, 
disregarding the requirement for circularity. 

3.3.4  Administrative  effort  /  burden  of  measures  for  different 

stakeholders 

Table 3-81 Initial assessment of measures to identify discarded and short-listed 
measures 

Measure  

Effectiveness 

1 

Specification of general minimum requirements of Art 8/8a WFD: 
Obligations for the Member States 

1.1  Obligation  for  all  MS  to  establish 

national EPR schemes 

Administrative 
Producers:  
Purely administrative effort to demonstrate a “zero cost network” 
is about 1 to 3 € per new vehicle placed on the market (see section 
6.7.2 in Annex I)  

effort 

for 

1.2  MS  to  report  on  implementation  and 

enforcement regards EPR 

Two  reports  in  year  +  3  and  +5  required.  Limited  one-off  effort 
demonstrating  implementation.  No  explicit  data  collection  but 
focussing on legal implementation. 

1.3  MS 

to  establish  an 

independent 
competent authority (clearing house)  

Advanced MS and also smaller MS establish “cover authorities” 
for more than on EPR only. Under such roof the effort should be 
limited. However, when it comes to negotiation of compliance cost 
compensation or fee modulation it might easily need one FTE high 
experienced  staff  +  2  FTE  support  staff  (at  least  for  the  larger 
countries,  smaller  countries  might  refer  to  lessons  learned  in 
larger ones. 

2 

Specification of general minimum requirements of Art 8/8a WFD: 
Obligations for Producers to cover cost for 

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Measure  

Effectiveness 

2.1  Collection  of  vehicles  at  holder’s 
premises  and  abandoned  vehicles 
free  of  charge  for  the  last  holder. 
à specification of WFD Art 8a(3) point 
(b) 

2.2  Awareness  raising  of  last  holder  to 

deliver ELVs to ATFs 

2.3a Establishment of a notification system 

for ELV, CoD and final cancellation 

Free collection at last holders’ premise might cause average cost 
of  38  €  per  new  vehicle304,  free  collection  of  abandoned  ELVs 
might  cast  (because  of  the  limited  number)  1.4  €  per  new 
vehicle305.  

Such regulation might worsen the attitude of last holders to offer/ 
deliver the vehicles to collection points / ATFS and instead dump 
more ELVs illegally in the environment with the attitude that the 
costs are anyhow covered by the Producers. 

The  current  system  that  the  last  holder  delivers  the  ELV  to  the 
collection  point  or  ATF  is  considered  sufficient  (in  combination 
with other measures addressing “missing vehicles”. 

In consequence this measure is not considered for the preferred 
option. 

While the task is important the budget is considered as limited 
with 0.04 per inhabitant and year, respectively <1 € per new and 
used car first registered 306 

Based on indication from Belgium (febelauto), Netherlands (ARN) 
and  Ireland  (ELVES)  we conclude that  the  effort  for  this task  is 
less than 1 € per new and used car first registered 

2.3b.Support 

/  software 
international notification system 

interfaces 

to 

Discarded before (see section 6.8.1 in Annex I) 

2.4  Monitoring  of  material 

flows  and 

compliance with RRR targets 

Based on indication from Belgium (febelauto), Netherlands (ARN) 
and  Ireland  (ELVES)  we conclude that  the  effort  for  this task  is 
between less than 1 € and in maximum 5 €per new and used car 
first registered 

2.5  Monitoring  and  reporting  on  illegal 

activities in the sector 

As  the  PRO  /  producer  must  activate  a  kind  of  whistle-blower 
functionality,  forwarding  the  information  to  the  responsible 
this 
authorities  only 
functionality is marginal.  

to  establish  and  maintain 

the  effort 

2.6  Training 

for  staff  of  ATFs 

(and 

shredders)  

Training  for the  handling of  batteries  up  to  1  € per  new vehicle 
sold307. Other training (less costly) to add. 

304 The obligation to collect all ELVs on demand at the premise of the last holder can cause high costs to the Producers. E.g. 
the service of a towing service for a distance of 30 km easily cost 100 to 200 € per vehicle. In average (considering one might 
assume cost of 100 € per ELV. Considering further that 4 million holders per year make use of this opportunity it will sum up 
to 400 m€ per year, respectively (with 10.9 million new vehicles in average) around 38 € per new vehicle.  

305 Considering that few end-of-life vehicles are left in the environment (e.g. 1% of 10 million) and the average cost of €150 per 
collection, this would amount to €15 million per year for the EU as a whole. With an average number of 10.9 million newly 
registered passenger cars in the EU for the period 2019-2021, this corresponds to about €1.4 per newly registered vehicle. 

306 See e.g. Ireland where the PRO conducts comprehensive effort for awareness raising: ELVES (2022): Annual report 2021: 
total expenditures 1.9 m€; 11% on advertising, marketing and PR = 0.2 m€: about 4 cent per inhabitant and year, respectively 
(considering 250 000 new and used cars registered for the first time in Ireland) less than 1 € per new and used car first 
registered 

307   Considering that each of the 12 000 ATFs will sooner or later need training in handling EV and traction batteries (high-
voltage battery handling training), such training, including missed work time, easily costs ATFs more than €5,000, which 
would add up to € 60 million for the entire EU. Considering that such training needs to be completed in a period of 5 years 
and taking into account 63 million new passenger cars registered in the previous 5-year period (2017 – 2021)   this would 
account for around 1 € per each new vehicle in that period. Other trainings to be added. 

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Measure  

Effectiveness 

2.7  Provision 

of 

easy 

access 

to 

harmonised information 

2.8  Fee modulation  

2.9  Compliance cost offsetting  

3. Advanced European EPR 

The  current  cost  (e.g.  for  IDIS)  are  estimated  by  ACEA  at  3 
m€/a308. The effort to provide easier accessible information in a 
harmonised  manner  (e.g.  via  photo  of  VIN  number,  directly 
accessible  to  the  tablet)  and  more  information  (not  obligatory 
for  reuse, 
dismantling  only,  but  on  valuable  components 
remanufacturing, recycling as well)309 the effort might double but 
remain < 1 € per new vehicle registered. 

The fee modulation will not change the total fee. The effort for the 
stakeholders (producers, dismantlers, shredders) associated with 
the  fee  adjustment  is  the  negotiation  process  to  adjust  the 
modulation (including studies to prove one's own position) and the 
effort for the (public) clearinghouse to moderate this process.  

The cost for the producers to offset compliance costs depends on 
the level of compliance requirements (see measures addressing 
circularity)  and  the  revenues  which  can  be  achieved  for  the 
distinct compliance operation. More details giving an indication on 
the  level  of  required  cost  compensation  for  the  proposed 
measures  are  displayed  in  the  circularity  sections  in  which 
measures  are  analysed  at  the  material  level.  See  for  example 
section  3.1.8.1.5  on  “Comparison  of  scenarios  for  glass”  or 
section 3.1.9.1.4 on “Comparison of scenarios for plastic”. 

3.1  EPR  schemes  for  intra  EU  trade 
(delegated / implementing act) 

So far cost for EC occur for staff and study occur to prepare (if 
any) delegated / implementing act (~ € 350 000) in total.  

3.2  European  EPR  for  the  EU  market 

(feasibility study) 

So far cost for EC occur for staff and study occur to prepare the 
feasibility study (~ 250 000) in total. 

4. Advance economic incentives 

4.1  Deposit  Refund  Schemes 
manged by EPR scheme 

(DRF) 

Discarded before (see section 6.8.1 in Annex i) 

4.2 Green Public Procurement 

Cost to EC to develop the criteria (~ 250 000) in total 

Cost  for  the  Member  States  to  comply  with  the  advanced 
requirements:  unknown:  to  be  assessed  in  the  process  of  the 
definition of the criteria above.  

3.3.5  Conclusion 

The producers / OEMs will be exposed by the introduction EPR schemes and new obligations 
under the EPR to additional costs:  

•  The obligation to collect ELV at the premise of the last holder might cost up to 40 € per 
new  vehicle  and  might  cause  even  adverse  effects  (more  abandoned  vehicles  in  the 
environment). Therefore, this measure is not included in the preferred policy option.  

308 COMMISSION SWD(2021) 60 final: Evaluation of Directive (EC) 2000/53 of 18 September 2000 on end-of-life vehicles 
309 Like the advance software of k.p.u.t.t gmbH: https://kaputt-gmbh.de 

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•  The offsetting of compliance cost depends on the level of compliance requirements and 
the economic viability of these measures. The level is not discussed here but under the 
section “circularity” 

•  Other new obligation under EPR schemes might have marginal cost for each but might 

add up in total to 10- 20 € per new vehicle. 

3.4  Extension  of  the  vehicle  categories  in  scope  of  the  ELV 

Directive 

The  study  focusses  on  expanding  the  scope  of  the  ELV  legislation  to  the  following  type-
approved road vehicles310  

•  L vehicles, type approval regulation for the motor vehicles through REGULATION (EU) 

No 168/2013 

•  Type  approval  regulation  through  REGULATION  (EU)  No  2018/858  (M  vehicles,  N 

vehicles, and O vehicles.) 

See reasons for not considering the inclusion of non-road vehicles under the scope of ELVD 
in section 6.1.1.  

3.4.1  Baseline 

The baseline scenario is that no provisions on vehicles which are not yet in scope of ELVD 
are added to the Directive (or related Directives, i.e., type approval and 3R Directive). As a 
consequence, in the baseline, no new vehicles enter the scope of any regulation. The share 
of vehicles not covered under the ELVD relates to nearly 17% by unit, ~ 47 million, or 33% 
by mass, 159 million tons (see Table 6-2).  

Generally,  it  is  assumed  that  the  total  number  of  all  type-approved  vehicles  in  Europe 
increases  (fleet  stock  number,  see  Figure  2-32).  Another  general  trend  is  expected:  It  is 
assumed that material variety increases whereas recyclability with given recycling technology 
decreases within type-approved vehicles. As for the waste management, it is assumed that 
parts  from  ELVs  will  be  removed  and  sold  for  reuse  and  that  vehicles  will  be  recycled. 
However,  though  there  are  MS-specific  regulation  in  place  (see  section  2.4.3.1),  in  the 
baseline,  there  are  no  EU-wide  requirements  on  the  waste  management  of  such  vehicles 
(e.g.,  depollution)  nor  on  the  conditions  of  such  facilities  as  well  as  no  targets  such  as 
mandatory removal of components or recycling targets. As depollution requirements do not 
exist, respective wastes such as fluids and oils may not be removed, affecting the share of 
the vehicles that can be recycled and the quality of obtained secondary materials. From the 
stakeholder  interviews,  it  is  understood  that  the  reuse  rate  is  higher  for  lorries,  PTW  and 
buses,  however  this  may  be  performed  more  often  by  private  owners  (common  for 
motorcycles) or by non-authorized facilities. Overall, it is expected that the design of vehicles 
currently not in scope of ELVD would not change substantially, e.g., no recycled content and 
no effort to increase recyclability. As well, no major achievements are expected at the end-
of-life of these vehicles, e.g., higher reuse or recycling rates.  

One will not be able to monitor certain indicators, e.g., current recycling rates and potential 
upcoming  achievements  in  the  end-of-life  treatment  of  these  vehicles  due  to  missing 
monitoring scheme. This means, in the baseline, the particular contribution of vehicles which 

310 with the exemption of vehicle category T (agricultural tractors) 

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are not yet in scope of ELVD to the goals of set out the Circular Economy Action Plan and 
the European Green Deal cannot be identified. 

However,  as  consumers  are  requesting  more  and  more  sustainable  products,  it  can  be 
assumed that there is a natural shift to more sustainable manufacturing practices. However, 
the particular way and dimension of sustainable practice is not foreseeable. Given the fact 
that often, when it comes to vehicles, recyclability and a reduction of carbon emissions during 
use  phase  are  inevitable  trade-offs,  the  contribution  of  a  natural  shift  towards  sustainable 
manufacturing practices to overall environmental, economic and social goals is unclear.  

Material quantities from ELVs for baseline  

In 2020, material quantities from waste lorries, buses and PTW (these sums do not include 
material  from  trailers311)  added  up  to  822,0  -  3825,4  Mio  tons  in  total.  This  splits  into  the 
materials as indicated in the table below. 

Table 3-82 Material quantities from waste lorries, buses and PTW in 2020 

Range_min  Range_max 

%_lorry 

%_bus 

%_PTW 

Alu_2020 

136,3 

293,1 

Copper_2020 

7,0 

Glass_2020 

Iron_2020 

Other_2020 

Plastics_2020 

Rubber_2020 

13,5 

61,8 

87,9 

99,4 

29,8 

21,9 

17,7 

362,9 

369,1 

237,8 

213,3 

Steel_2020 

386,4 

2309,7 

33% 

68% 

39% 

89% 

83% 

67% 

80% 

83% 

36% 

5% 

60% 

11% 

14% 

20% 

7% 

9% 

32% 

27% 

1% 

0% 

3% 

13% 

13% 

9% 

Source: Calculation based on expected ELVs and material compositions per vehicles. 

311 (Semi-)Tailers have a high variety in total weight and material composition. It was not possible to obtain generalized data or 
to assume their material composition due to the high variability in the vehicles. See examples for the weight of trailers in the 
Annex (6.1.1). 

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Figure 3-41  Shares that vehicle categories have in the total sum of material 

quantities from waste lorries, buses and PTW 

27%

5%

68%

32%

36%

33%

1%

60%

39%

100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%

0%
11%

3%
14%

89%

83%

13%

20%

67%

13%
7%

9%
9%

80%

83%

alphabetic order! 

Lorry

Bus

PTW

Source: Data in Annex I, Table 6-13 

As can be seen from Figure 3-41, lorries have a share of ~80% in the total sum of steel, iron, 
rubber and other material from waste vehicles in 2020 with the rest split between buses and 
PTW, except for iron which cannot be found in PTW. At aluminium, copper, glass and plastics, 
one has to look individually. The share that lorries have in the total sum of aluminium and 
glass  is  below  40%  each  which  is  little  compared  to  the  other  materials.  In  both  of  these 
material  categories,  buses  have  a  high  contribution  to  the  total  sum.  For  aluminium  and 
copper, PTW have a higher share in the total sum compared to other materials.  

Specifically for the vehicle categories it is assumed that:  

In the case of PTW, in the baseline it is expected that repair and reuse will be high (reuse 
quota for motorcycle dismantlers and hobbyists found to be 60-95% and ~10% at 
car  dismantling  facilities  in  Finland,  SMOTO  2021),  though  a  lot  of  regionally 
scattered,  individual  and  small  operators  continue  to  exist  that  conduct  the 
dismantling and repair. It is unclear, to which extend this covers illegal operations. Another 
aspect is that PTW will continue to be subject to different waste management laws in different 
countries and one will not be able to follow the developments, as the statistical indicator of 
the number of ELVs is not readily available, nor any EoL market overview. 

In the baseline, recycling of PTW will continue to be low by amount of material (‘never seen 
one’,  ACEM),  and  if  PTW  are recycled,  it’s  that car  dismantlers  have  a PTW  in their  input 
stream. Costumers of PTW will expect to be able to repair their vehicles, this will drive the 
market to follow their high focus on reuse, reused parts and repair. It is expected that Design-
for-recycling in particular does not play an important role in material choices for PTW. In the 
baseline the number of exported (or imported) used vehicles is not known, nor the number of 
ELVs. However, the general number of PTW is expected to increase given that stock statistics 
show an increase of ~ 2.0 Mio motorcycles (Eurostat is not consistent with L-type approval 
nomenclature).  

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Lorries are an important means of transport goods and will continue to be in Europe 
and other parts of the world. Small signs indicate that the extra EU export market 
of  used  lorries  might  turn  around,  i.e.,  either  stagnating  or  declining  (Typically, 
between  ~157  000  used  lorries  were  exported  per  year,  this  relates  to  ~74%  of  expected 
ELVs). The top 5 importing countries of used lorries are Jordan, Ukraine, Afghanistan, Serbia 
and  Saudi  Arabia.  Export  of  new  lorries  is  a  viable  business  as  well.  Looking  at  the  list  of 
importing countries, low waste management infrastructure can be expected associated with 
negative environmental consequences, like the leakage of liquids or low-efficiency exhaust 
gas emissions in waste treatment plants.  

In the baseline, it is continuously in the interest of the business-to-business customers using 
lorries in the transport of goods and leasing companies, that the fleets consist of long-lasting, 
robust vehicles that are easy to repair. On the other hand, seeing the high awareness of the 
climate  impact  of  road  vehicles,  it  is  expected,  to  serve  the  demand  of  reduction  of  CO2 
emissions from road transport, that an increase of light-weight material can be seen. This will 
lower the CO2 emission associated with the transport of goods. It is expected that Design-for-
recycling in particular does not play an important role in material choices for lorries. One will 
not be able to follow the developments, as the statistical indicator of the number of ELVs is 
not available, nor any EoL market overview. 

The number of buses that reach their EoL per year is little, compared to the other 
vehicles that are looked at. The amount of material in one vehicle is high as well 
as the material composition which is special compared to the other vehicles. It is 
expected that in the baseline not much changes in these respects. However, one will not be 
able  to  follow  the  developments,  as  the  statistical  indicator  of  the  number  of  ELVs  is  not 
available, nor any EoL market overview. In relation to exports, numbers for buses do not show 
the  same  developments  as  other  export  figures,  it  is  expected  that  the  number  of  exports 
continue to be ~10.000 buses per year. Environmental problems associated with such exports 
cannot be quantified.  

For trailers, the information on the whereabout and treatment at EoL is currently 
relatively unknown, except for the fact that around 75,000 (semi-)trailers are extra-
EU-exported  per  year.  Also,  general  materials  used  in trailers  suggest that they 
are  highly  recyclable,  sometimes  being  made  from  steel  only.  In  the  baseline,  without 
intervention, there is no increase of knowledge expected. 

To sum up, it is expected that in relation to the problems identified,  

•  The contribution to CE of a large share of vehicles cannot be quantified, nor described 
properly hindering the evaluation of the actual contribution to circularity of those vehicles 
and the decision for the need for and feasibility of EU action. The situation of the market, 
e.g., numbers of operators and their in- and output, is not known. 

•  Export of lorries, buses and trailers into countries with poor waste infrastructure continues, 
for PTW the situation will be unknown. Also, no information will be available on intra-EU 
transboundary shipment of vehicles not in scope of ELVD. Potential measures taken to 
tackle the same problems for M1 and N1 vehicles cannot be applied to other vehicles. 
•  For vehicles not in scope of ELVD, there will continue to be no legal incentive available to 

design vehicles for circularity.  

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•  For vehicles not in scope of ELVD, there will be member states with individual regulations, 
e.g.,  (voluntary)  EPR  systems  for  PTW  in  France  or  the  Netherlands,  requirement  to 
dismantle in ATFs in countries like Italy and Czech Republic, or general waste provisions 
like in Germany. But there will be MS as well without having rules for waste vehicles other 
tan M1 and N1, like Greece and Ireland.  
Inefficiencies between scopes of ELVD and 3R Directive identified (Annex II) continue to 
exist, and  

• 

•  An increase of the total amount of vehicles is expected that adds to the above-mentioned 

problems. 

3.4.2  Policy Options 

3.4.2.1  Identification of discarded measures 

None of the measures was discarded. 

3.4.2.2  Policy Options Overview 

The  baseline  as  well  as  three  options  (A,  B,  C)  represent  the  scenarios  between  which 
impacts shall be compared in the detailed assessment. To start, under options A, B and C, 
additional vehicles would be phased-into the legislation on end-of-life vehicles (and related 
legislation such as 3R Directive) through an extension of the scope, namely type-approved 
vehicles of categories Le1-Le7 (motorcycles), M2 and M3 (buses), N2 and N3 (lorries) and 
O1-O4 (trailer and semi-trailer)). To be precise, special purpose vehicles312 and multi-stage 
build313 vehicles of category M2,3, N2,3, and O (considered not relevant for L-type-approved 
vehicles) or such vehicles built in small series314 are covered by the measures. 

Setting legal requirements to solve the problem for M1 and N1 (chapters 2.1 & 0) supports 
the  fact  that  the  intervention  should  be  through  legislation  and  that  ELV  legislation  is 
considered the right place, as problems for M1 and N1 apply to other types as well. Thus, 
except for the baseline, in all options the scope of the ELV legislation (and related legislation) 
shall be expanded. In the grouping of the measures to build the options proportionality was 
decided  as  the  most  important  factor.  In  that  respect,  Option  A  is  the  extension  of  scope, 
however, only reporting and information requirements shall apply to new vehicles in scope. 
Option B is the extension of scope plus an additional set of basic requirements chosen as 
they target specific problems, e.g., collection, or are expected to be implemented easier than 
others at least for some vehicle categories, e.g., within the context of hazardous substances 
the restriction of the four heavy metals.315 Finally, the scope extension with full applicability 
of all current and future ELVD is Option C to be able to reach maximum benefits but possibly 
leading to disproportionate effects. 

312   According to Regulation 2018/858/EU: ‘special purpose vehicle’ means a vehicle of category M, N or O having specific 
technical features that enable it to perform a function that requires special arrangements or equipment, and characterised 
through Regulation 2018/585/ EU, Annex 1, Part A, point 5. 

313   as referred to in Regulation 2018/858/EU. The multi-stage procedure (described in article 22(1) of the mentioned 
Regulation) is a procedure where “one or more approval authorities certify that […] an incomplete or completed type of 
vehicle satisfies the relevant administrative provisions and technical requirements” (Regulation 2018/858/EU, article 3(8)). 

314   In the Regulation 2018/858, the general type-approval regulation in force today, the annual limits per Member State are 
500 units for O1, O2, and 250 for M1, M2, M3, N1, N2, N3, O3, O4. The EU-wide annual limits are 1 500 for M1, N1, N2, N3, 
and 0 for other categories.  

315   With regards to hazardous substances, Article 4(2) of the ELVD stipulates the restriction of the four heavy metals lead, 
mercury, cadmium or hexavalent chromium and the exemption mechanism for specific cases. 

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Figure 3-42  Scenarios addressing objective 1 addition to the baseline 

Objective 1: Ensure a 
comprehensive coverage of the 
sustainable production and 
dismantling of all relevant 
vehicles by the ELV Directive

A. Scope Extension of ELV legislation and 3R Directive
with information requirements

B. Scope Extension of ELV legislation and 3R Directive
with basic requirements

C. Scope Extension under ELV legislation and 3R Directive
with full application of requirements

Figure 3-43  Overview of policy options 

A. Scope Extension of ELV legislation and 3R Directive to all type-approved L, M, N 
and O vehicles with information requirements 

The  intention  of  this  option  is  to  gather  more  comprehensive  information  on  the  waste 
management  of  vehicles  currently  not  in  scope  of  ELVD  before  taking  the  decision  on the 
ambition  level  and  intensity  of regulation. Most of  the requirements  shall  not  apply  to  new 
vehicles  in  scope  immediately  after their  inclusion  under the  ELV  future  legislation.  It  thus 
stands  to  reason  that  the  reporting  for  such  vehicles  would  differ  from  passenger  vehicle 
reporting for the transition period until potential additional end-of-life requirements, e.g., 3R 
type approval, may apply.  

The Option A consists of the following measures: 

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No. 

1A1 
1A2 

1A3 

Title 

Information to recyclers 
MS reporting (via Eurostat) on ELVs newly added to the scope by 
nr. 
OEM and ATF to EC: One-time reporting oblig. on EoL 

Chapter 

2.4.5.1.1 
2.4.5.1.2 

Effective 
by 
2025 
2025 

2.4.5.1.3 

2025 

Mainly,  measures  in  this  policy  option  contribute to  the  solution  of  the  problems  described 
above  by  generating  knowledge  for  building  the  basis  for  further  decisions  in  relation  the 
problems that cannot be solved by pure information requirements. Information to recyclers 
(A1) might be the first step in the direction of ATFs and recyclers being able to take decisions 
what to dismantle for reuse (in addition to what they dismantle for reuse already). 

The vehicle types in scope of the new ELV legislation shall be defined based on the vehicle 
categories set out in Regulation (EU) 2018/858 and Regulation (EU) 2013/168. It is expected 
that  differentiating  between  various  types  of  powered  two  or  three  wheeled  vehicles,  i.e., 
including Le3-Le7 but excluding Le1 (light two-wheel powered vehicle) and Le2 (three-wheel 
moped), or different rules for lorries or semi-trailer tractors (both category N) would increase 
the complexity for end-of-life treatment facilities, e.g., for sorting what is in scope and what is 
not as a basis for reporting.  

Based on a report from the European Commission, within four years of entry into force of the 
legislative  framework  for  ELVs  the  Commission  shall  make  a  proposal  on  which  and  how 
requirements of those politically agreed on for the ELV legislation shall be applied to vehicles 
new in the scope of ELV legislation and related legislation316.  

B. Scope Extension of ELV legislation and 3R Directive to all type-approved L, M, N 
and O vehicles with basic requirements 

To come to terms with the limited information on the end-of-life treatment of such vehicles at 
the  on-set  of  this  option,  only  selected  obligations  would  apply  to  new  vehicles  in  scope. 
However,  some  measures  seem  proportionate to  address the  above-mentioned  problems: 
Measures in this option have been in place for M1 and N1 type approved vehicles since ELVD 
came into force – though there might be fine tuning for one or the other, generally, all of the 
measures B1-B3 (below) can be attributed to the catalogue of measures under the objectives 
to improve collection/traceability and circularity. 

On top of the options in policy option A, the following provisions are added to all vehicles in 
scope  of  the  future  legislative  framework  of  end-of-life  vehicles,  however,  providing  new 
vehicles in scope a transition period until they must comply with the provisions:  

No. 

1B1 
1B2 
1B3 

Title 

Haz. Substances restrictions 
ATF treatment (circularity) 
CoD (traceability) 

Chapter 

2.4.5.1.4 
2.4.5.1.5 
2.4.5.1.6 

Effective 
by 
2025 
2025* 
2025** 

(*) based on the understanding that various MS have such requirements in place already. 
(**) based on the understanding that the concept of CoDs exists for M1 and N1 vehicles. 

316 Depending on the future legislative setup, i.e., the decision of merging ELVD and 3R Directive or not, the scope of the 3R 
Directive would need to be amended too, as well as the type-approval Regulations for M, N, O (2018/858) and L (168/2013), 
making/introducing the link to the 3R legislative act.   

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It  is  suggested  that  all  measures  in  policy  option  A  are  added  to  this  option  together  with 
measures B1-B3, as they are serving various purposes that B1-B3 cannot or can only partially 
cover. To start with A1, this is related to B1, i.e., recyclers will need information specifically 
on the location of component with contents of hazardous substances. Also, measure A2 is 
connected to B3. In this policy option, a combination of these measures might be envisaged. 
Then, A3 is independent of the measures B1-B3, but is serving to provide enough information 
to be able to conclude on additional measures under policy option C.  

In order for this measure to be effective and not contra-productive, the legal text must clearly 
differentiate  between  provisions  applying  to  vehicles  of  type M1  &  N1 (current  scope)  and 
new vehicles in scope. For example, this could be done similarly to Art. 3(5) of the current 
ELV legislation which is specifically referring to the articles which apply to three-wheel motor 
vehicles. Alternatively, if the Directive is turned into a Regulation, it could start with provisions 
that apply to all vehicles and then include separate chapters for each vehicle type. 

C. Scope Extension under ELVD and 3R Directive with full application of requirements 

This measure is similar to Option B in so far that it aims to realise the potentials for circularity 
related  L, M,  N and O  category  vehicles  by  including  new  types  of  vehicles  in  scope. It  is 
however more ambitious as through the early application of all provisions. It aims to generate 
a  positive  environmental  impact  which  was  acknowledged  to  be  the  overarching  aim  by 
stakeholders in the OPC.  

The Option C builds on option A+B317 and adds the following measures: 

No. 

1C1 

1C2 
1C3 
1C4 
1C5 

Title 

Extension of scope of the 3R Directive and 3R Type 
Approval  requirements  to  include  conformity  of 
production  and  market  surveillance  for  all  types  of 
vehicles 

Design for Circularity 
Reuse & Recycling 
Advanced traceability 
Export restrictions 

Chapter 

2.4.5.1.7 

Effective 
by 
2030 

2.4.5.1.8 
2.4.5.1.9 
2.4.5.1.10 
2.4.5.1.11 

2027 
2030 
2030 
2027 

The  policy  option  1C  is  supported  by  the  following  measure  addressed  in  the  context  of 
Extended Producer Responsibility (EPR) too. 

No. 

1C6 

Title 

EPR for all vehicles 

Chapter 

2.4.5.1.12 

Effective 
by 
2030 

As  can  be  seen  from  the  list,  measures  in  this  option  target  all  of  the  above-mentioned 
problems:  

•  As a whole, this intervention harmonizes the EoL rules for vehicles not in scope of ELVD. 
Once  in  place,  additional  vehicles  placed  on  the  market,  i.e.,  the  growing  trend  in  the 
number of vehicles in stock, does not pose a problem as such anymore.  

317 Though, A3 is only reasonable if C1 and C3 are implemented with an offset in time, and for B3, overlaps of C4 and C5 
might be checked 

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•  Measures  A1,  B1+B2,  and  C2+C3+C6  represent  the  bundle  of  measures  addressing 

circularity and EPR as being the supporting mechanism for circularity. 

•  Measures  A2,  B3,  and  C4+5  addressing  the  aspects  of  missing  traceability  and  high 

exports. 

•  Measures  C1  addresses  the  aspect  of  the  current  inconsistency between  3R  Directive 

and ELVD and provides a legal incentive for Design-related measures.  

In detail, this measure aims at the inclusion of the vehicles of types Le1-Le7 (motorcycles), 
M2 and M3 (buses), N2 and N3 (lorries) and O1-O4 (trailer and semi-trailer) with obligations 
which are as ambitious as those of light duty vehicles (passenger cars).  

It is suggested that A1 (Information to recyclers) and A2 (MS reporting (via Eurostat) on ELVs 
newly  added  to  the  scope  by  number)  as  well  as  B1  (Hazardous  substances),  B2  (ATF 
requirement) and B3 (introduction of CoD) are added to this option as they are serving various 
purposes  that  C1-C6  cannot  or  can  only  partially  cover.  The  reasoning  is  that  A1  and  B1 
which are related to each other and B2 are not addressed in C1-C6. Measure A2 is connected 
to B3 and together they might have overlaps with C4 and/or C5. For measure A3 (OEM and 
ATF to EC: One-time reporting oblig. on EoL), addition to this option only has an added value 
if the provision not coming into force at the same time – but earlier – than C1 and C3. 

3.4.3  Methodology & overview of assumptions  

Methodological approach for quantification of material streams 

In  addition  to  the  general  model  description  in  chapter  6.9,  the  following  figure  provides  a 
visualisation of calculation steps.  

Figure 3-44  Methodological approach for quantification of material streams 

  Step 1             2 

                 3 

  4       5         6 

Material 
compositi
on from
Life cycle
inventorie
s of
specific
models

Fleet 
model; 
Nr. of 
ELVs 
modelled 

Material 
quantities 
from 
waste 
vehicles 
in tonne 
per 
annum

Apply a 
general
reuse rate 
(differs
per 
option, 
see 
below)

For the
remaining
material 
quantities
: apply
material-
specific
recycling
rates*

For the
rest: 
differentia
te
between
energy
recovery
and losses

(*) recycling rates assumed relate to ‘recycling after shredding’. 

The main raw data can be found in the Annex I to this report (step 1: see tables in 6.1.3; step 
2:  see  ‘description  of  the  model’  see  section  6.9  and  assessment  of  robustness  and 
completeness  of  fleet  data  see  section  6.1.1;  step  3:  Table  3-83).  Steps  4  to  6  can  be 
summarised as follows: Assumed reuse, recycling and loss rates per Option are displayed in 
Table  3-84.  The  only  reference  to  reuse  rates  (explicit  numbers),  is  the  survey  of  Finish 
Motorcycle Association (SMOTO 2021) among Finish motorcycle stakeholders: Between 60 
and 70% at Finish operators specialized in the handling of PTW, 95% for ‘hobbyists’ and 10% 
at  operators  specialized  in  car  handling.  Though,  car  recyclers  play  a  minor  role  in  PTW 
dismantling and recycling according to ACEM (2021), the reported reuse rates differ greatly 
from each other. It is unclear to which extent the data is representative for reuse rates for 
PTW in the European Union as a whole. As mentioned earlier in this report, no figures are 
available as to the reuse rates for lorries, buses and trailers. Reuse rates were assumed to 
be 30% (Baseline, Option A & B) and two variants were considered in Option C: 40% and 

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70%. These reuse rates were put up for discussion at the ELV stakeholder workshop in March 
2022,  however,  stakeholders  neither  supported  nor  rejected  the  assumed  reuse  rates 
referring  to  the  fact  that  ‘such  data  is  not  available’  (preferred  answer  to  respective  Slido 
question in the ELV stakeholder workshop). 

Table 3-83 Option-related assumptions for the modelling 

Reference year 
Reuse rate318 
Recycling 
rates* 

Recovery rates* 
Loss rates 

Baseline 
2022 
30% 
Steel 
99% 
Aluminium  85% 
99% 
Iron 
85% 
Copper 
0% 
Glass 
30% 
Plastic 
0% 
Misc. 
0% 
rubber 
13-21% 
2-5% 

Option A 
2030 
30% 
99% 
85% 
99% 
85% 
0% 
30% 
0% 
0% 
13-21% 
2-5% 

Option B 
2030 
30% 
99% 
85% 
99% 
85% 
0% 
30% 
0% 
0% 
15-21% 
2-5% 

Option C 
2030 
40%/70% 
99% 
90% 
99% 
90% 
45% 
35% 
0% 
0% 
15-19 % 
0,5-2% 

(*) depend on the material, assumptions are the same as for circularity measures (see description of the model, Annex I 
chapter 6.9) 

Assessing  the  impacts  of  mandatory  provisions  for  different  types  of  vehicles,  even  if 
qualitatively, will have high uncertainties in cases where the details of the provisions for M1 
and  N1  vehicles  have  not  been  decided.  As  a  consequence  and  seeing  as  the  end-of-life 
treatment  of  new  vehicles  in  scope  is  not  as  well  understood  as  for  passenger  cars,  it  is 
suggested to grant a transition period of three to five years from entry into force onwards so 
that the market can transition smoothly towards the fulfilment of all provisions.  

Quantification of impacts (if not indicated in the respective section) 

•  Benefits from increase of circularity: see ‘description of the model’ in section 6.10. 
•  Administrative cost model according to European Commission (2015)  

It  is  important  to  be  aware  that  the  assumptions  were  made  for  the  purpose  of 
estimating magnitudes and are far from being accurate "model" forecasts. The shifts 
considered  for  calculating  the  impacts  of  the  policy  options  are  more  of  an  expert 
estimate than a correct calculation. 

3.4.4  Analysis 

Here, the question shall be answered, what are the likely impacts of each of the short-listed 
options. Sub-chapter 3.4.4.1 shows selected impact categories.  

318 It is uncertain which components are being reused. We apply a general reuse rate that is identical for all materials in the 
vehicle. In practice, it is possible that components of one material are more often reused than components of another 
material resulting in different reuse rates per material. This cannot be displayed due to lack of data of the components (and 
their material composition) that are being reused.  

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3.4.4.1  Selection  of  potential 

impacts  and 

list  of  affected 

stakeholders 

According  BRG  Tool  #18  the  impact  assessment  potential  impacts  “should  be  screened 
objectively  in  order  to  identify  all  potentially  important  impacts  –  considering  both 
positive/negative,  direct/indirect,  intended/unintended  as  well  as  short/long-term  effects”. 
Some  of  the  categories  are  cross-cutting  and  can  be  analysed  from  different  angles  (for 
example employment, income distribution, impacts on consumers or environmental impacts). 
A (well-justified) choice should then be made on the most significant impacts to be retained 
for a more thorough analysis.  

The full list of key impacts to screen is displayed in section 6.6.2.5 in Annex I. The total list of 
selected impacts for this sub-part of the impact assessment can be found in 6.2.1 in Annex I, 
however, find an attribution of impacts to measures and affected stakeholders in the following 
table.  

Expected affected stakeholder groups are: 

•  Vehicle owners 
•  Producers/manufactures (and in some cases their supply) incl. SMEs 
•  EoL  stakeholders319  (garages,  ATFs/non-authorised  dismantlers,  shredders,  used  car 
dealers, industries involved in processing/recycling of waste arising from ELVs treated in 
the EU), incl. SMEs 

•  For  individual  measures  (mainly  under  policy  option  C):  Customs  Services,  National 

vehicle registers, insurances 

•  Public authorities on various levels (MS & EU) 

ACEM (2021) report a high rate of SMEs among the PTW manufacturers: ‘9 small enterprises 
cover 20% of the market, medium (=4) cover 30% of the market, three big producers cover 
the other half.’ among the EoL stakeholders a high SME rate is expected generally.  

Table 3-84 Measures, their relevant impact categories, vehicles specifics in the 
measures and affected stakeholder 

Measure  Name 

Relevant impact category 

Vehicle specifics  Affected 

stakeholder 

A1 

A2 

A3 

Info 
recycler 

to 

MS  reporting 
on ELV 

One-off 
reporting  on 
EoL 

•  Administrative burden 
•  Costs for OEM and ATFs for 
Reporting and providing 
information 

•  Benefits through reporting 

Independent 

Manufacturers 

MS  specific,  highest 
effort  expected 
for 
PTW 

MS authority 

ATFs/dismantlers 

MS  specific,  highest 
effort  expected 
for 
PTW 

MS 

Manufacturers  

EoL stakeholder 

B1 

Haz subst 

•  Administrative burden for 

authorities 

Independent, 
individual 

but 
for  PTW 

Manufacturers  and 
their suppliers 

319 Some of the measures can affect the total EoL management chain, some measures might only affect one of the groups 
within the EoL stakeholders, if so, this shall be indicated explicit.  

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Measure  Name 

Relevant impact category 

•  Administrative burden for 

business operators: supply 
chain management 
•  Env benefits from heavy 

metal restrictions 

•  Revenues for dismantlers 

and recyclers from recycling 

•  Health effects (?) 
•  Costs for OEMs for change 

of design 

B2 

ATF 

•  Environmental benefits from 

formalised treatment 
•  Burden for ATF through 

authorization 

•  Administrative burden 
•  Distribution effect 

(economic): externalized 
costs will be internalized 
•  Distribution effect: informal 
jobs to be formalized 

•  Administrative burden 
•  Additional burden for 

consumers in managing an 
ELV 

B3 

CoD 

Vehicle specifics  Affected 

stakeholder 

compared 
vehicles 

to  other 

EoL stakeholders 

MS  specific,  highest 
effort  expected 
for 
PTW 

Vehicle 
ATFs/dismantlers 

owners 

MS  specific,  highest 
effort  expected 
for 
PTW 

Vehicle 
ATFs/dismantlers 

owners 

C1 

3R TA 

•  Administrative burden for 

Independent  

Authorities  

authorities 

•  Administrative burden for 
business operators 

•  Costs for OEMs for change 

of design 

•  Competition effects 

Manufacturers  

C2 

D4CE 

•  Costs for OEMs for change 

Independent 

Authorities  

C3 

3R targets 

Manufacturers  and 
their suppliers  

Independent 
but 
individual per vehicle 
category 

Authorities 
Manufacturers 

EoL Stakeholder 

of design 

•  Competition effects 
•  Developments in the internal 
market, incl. innovation 

•  Administrative burden  
•  Environmental benefits from 
increase of reuse and 
recycling 

•  Revenues for dismantlers 

from spare parts 

•  Revenues for dismantlers 

and recyclers from recycling 
•  Costs for OEMs for change 

of design 

C4 

Traceability 

Independent 

Authorities  

•  Administrative burden 
•  Distribution effect: informal 
jobs to be formalized 

474 

Vehicle owners 

EoL stakeholders 

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Measure  Name 

C5 

Export  

Vehicle specifics  Affected 

stakeholder 

Independent, 
however,  unknown 
for PTW 

Authorities 

EoL stakeholders 

Illegal operators 

Relevant impact category 

•  Additional burden for 

consumers in managing an 
ELV 

•  Administrative burden 
•  Revenues from exported 
used lorries <-> lost 
revenues from missing 
vehicles and exported used 
lorries 

•  Distribution effect: informal 
jobs to be formalized 

•  Developments in the internal 
market, incl. innovation 

C6 

EPR 

•  Costs for OEMs for change 

Independent  

Authorities 

of design  

•  Administrative burden for 

business operators to set up 
system 

•  Distribution effect 
(economic): EPR 

Manufactures 

EoL stakeholders 

In  the  next  section  selected  impacts  are  assessed.  The  structure  the  assessment  was 
prepared  according  to  the  impact  categories:  From  Table  3-84  one  can  read  under  which 
impact categories the respective measures are treated; if possible, a differentiation between 
different vehicle categories is made in the description or calculation of the impacts.  

According  to  Better  Regulation  Guidelines,  in  an  impact  assessment,  all  relevant  impacts 
should be assessed qualitatively and quantitatively whenever possible. In this case, as for the 
other chapters, the quantification of impacts was initially not possible for a number of impact 
categories, especially where costs are concerned. Efforts were made in the study to obtain 
quantitative  data  however  quantifiable  data  was  not  always  available  on  time.  A  further 
analysis  of  the  economic  impacts  of  the  scope  extension  is  however  provided  in  Annex  I, 
chapter Fehler! Verweisquelle konnte nicht gefunden werden. to provide further clarity. 
From  the  expected  impacts,  there  are  those  that  can  be  quantified  and  others  where 
quantification is not possible, they will be qualitatively described and assessed within the next 
chapters. The quantitative analysis focusses on the types and dimensions of the materials 
retrieved  from  ELVs  other  than  M1  and  N1.  Based  on  this,  it  is  possible  to  quantify 
environmental impacts in the baseline (the year 2022) and for future reuse-recycling-recovery 
scenarios (2030320).   

Equally,  the  types  and  dimensions  of  materials  retrieved  allow  quantifying  the  economic 
benefit that recyclers can generate from the sale of the secondary raw materials. For various 
other impact indicators, a quantification is not possible; where applicable, this is explained in 
relation to the impact indicator below. 

320 The year was chosen because it is expected that after the legislative process and possible transition periods, the measures 
could apply to new vehicles from 2030 onwards. 

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3.4.4.2  Environmental impacts 

Currently,  negative  impacts  on the  environment are  associated  with some  of the  identified 
problems: Because the potential to contribute to the CE of a large share of vehicles is not 
exploited  yet,  because  there  is  no  incentive  to  design  for  circularity,  and  because  of  the 
expected  increase  of  the  total  amount  of  vehicles,  vehicles  designed  and  treated  at  EoL 
currently may cause environmental harm. This is waste that is not treated in line with higher 
levels of the waste hierarchy. I.e., more resources are needed than necessary, e.g., if a spare 
part  is  a  new  one  instead  of  a  refurbished  one. Also,  it  is  about  the  amount  of  hazardous 
waste from end-of-life vehicles as well as emissions of exhaust gases or leaking liquids in 
treatment facilities that do not meet certain environmental standards – in the EU and outside 
if  used  vehicles  are  exported.  The  different  possibility  of  the  policy  options  to  prevent  this 
harm shall be evaluated in the following.  

From measures, B1 (heavy metal restrictions), B2 (ATF), C3 (3R targets), C4 (traceability), 
C5  (export  restrictions)  and  partly  A1  (information  for  waste  management  operators), 
environmental benefits are expected to be levered directly. For some measures, A2, A3, B3, 
C1, C2, and C6 explicitly, no direct environmental benefits are expected but these measures 
represent a means for that the measures with direct environmental benefits may work more 
effectively:  The  information  requirement  on  EoL  (A3)  and  3R  type-approval,  Design  for 
circularity  and  EPR  (measures  C1,  C2  and  C6)  support  the  benefits  from  increase  of 
circularity. Reporting of ELVs (A2), certificates of destruction (B3) as well as an EPR (C6) 
contribute  to  lesser  environmental  burden  from  missing  vehicles  and  export,  i.e.,  to 
environmental benefits from formalised treatment (see below).  

3.4.4.2.1  Material quantities from ELVs for options A, B and 

C 

In a first place, the measures proposed to achieve the objective in relation to circularity impact 
the amount of materials to be retrieved from end-of-life vehicles by formalized waste manage-
ment under EU-wide rules. Already today, materials are retrieved from ELV that are not in 
scope of ELVD, but the dimensions are unclear. Materials expected from waste PTW, lorries 
and buses in 2020 are displayed above (baseline description). In 2030, material quantities 
from waste lorries, busses and PTW are expected to add to 984,12 - 4673,70 Million tons of 
material (calculation based on expected ELVs and material compositions per vehicles). These 
are split between the different materials as indicated in the table below. 

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Table 3-85 Material quantities from waste lorries, buses and PTW in 2030 in mio tons 

Range_min 
[mio tons] 

Range_max 

[mio tons] 

%_lorry 

%_bus 

%_PTW 

Plus  compared  to 
absolute 
2020 
(relative) 

Alu_2030 

Copper_2030 

Glass_2030 

Iron_2030 

Other_2030 

Plastics_2030 

Rubber_2030 

Steel_2030 

157,2 

8,5 

15,4 

75,1 

106,1 

118,3 

35,5 

468,0 

346,4 

26,6 

20,9 

446,0 

452,2 

288,6 

261,6 

2831,4 

34% 

70% 

41% 

90% 

85% 

69% 

81% 

84% 

34% 

5% 

58% 

10% 

13% 

18% 

6% 

8% 

31% 

25% 

1% 

0% 

3% 

13% 

13% 

8% 

37,1 (117%) 

3,1 (121%) 

2,6 (117%) 

48,2 (123%) 

50,7 (122%) 

34,8 (121%) 

27,0 (122%) 

301,7 (122%) 

Source: calculation based on expected ELVs in 2030 and material compositions per vehicles for which data can be found in the Annex I. 

Percentages per vehicle are the same than in the baseline with few individual variances, details in Annex I, Table 6-13. The data is shown 
in Figure 3-45 and the Annex, Table 6-12. 

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Figure 3-45  Expected material quantities from PTW, buses and lorries arriving at 
EoL in 2019 and 2030 in million tons 

500,0
450,0
400,0
350,0
300,0
250,0
200,0
150,0
100,0
50,0
0,0

30,0

25,0

20,0

15,0

10,0

5,0

0,0

3000,0

2500,0

2000,0

1500,0

1000,0

500,0

0,0

Min Max

Average

Source: Data in Table 6-12. 

The expected amounts of materials are the same in all options. However, the question is 
how these material streams are being influenced in relation to their direction (e.g., export) or 
at  what  level  of  the  waste  hierarchy  they  are  treated  (e.g.,  reused  or  recycled  versus 
recovered).  A  measurable  impact  on  these  indicators  is  only  expected  to  be  observed  in 
relation to Option C (see more explanations in the course of the analysis) The measures C2 
(design  for  circularity)  and  C3  (3R  targets)  bundle  measures  to  be  taken  in  relation  to 
circularity  and  offer  many  different  possibilities  for  regulation,  ranging  from  circularity 
measures chosen by industry (pledges, strategies), to (further) information requirements e.g., 
on  material  composition  or  on  novel  materials  for  which  there  are  currently  no  recycling 
facilities,  and  to  clear  targets  for  recycled  content  of  certain  materials,  or  3R  targets.  In 
general,  from  well-tailored,  ambitious  but  achievable  targets  in  relation  to  circularity,  it  is 
expected that more waste is prevented, e.g., the longevity of vehicles increases, and that an 
increase in the use of spare parts in repairs and new vehicles, an increase of the general 
turn-over for used and new spare parts, and increased amounts and higher quality of recycled 
material  can  be  observed.  As  a  result,  recovered  materials  and  losses  would  decrease. 
Because  the  underlying  conditions,  i.e.,  the  number  of  ELVs,  in  some  cases  the  material 
composition of vehicles, the current recycled material quantities, and the current reuse rate 
are unknown, it is not possible to decide what exactly "well-tailored, ambitious but achievable 
targets”  are,  and  to  assess  the  concrete  benefits  and  costs  of  changes  in  the  above-
mentioned indicators. Also, effects of the circularity measures on M1 and N1 vehicles have 
not been observed, but only calculated and described (see above). 

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3.4.4.2.2  Benefits  from  increase  of  circularity  (reuse  and 

recycling) 

The  impact  category  of  environmental  benefits  resulting  from  an  increase  of  reuse  and 
recycling are expected to unfold their potential only in Option C (in relation to measures C2-
3). Measures in Options A and B (A1 and B1-2 specifically) only indirectly result in potentially 
higher  reuse  quota  or  increases  in  the  amounts or  quality  of recycling  which  might  not  be 
monitorable,  e.g.,  for  the  scope  extension  with  information  requirements  (A1-3),  a  slight 
increase of reuse and recycling might be the result due to the awareness of stakeholders for 
ELVs  other  than  M1  and  N1.  In  that  sense,  assumptions  have  been  made  as  to  reuse, 
recycling and recovery quotas in the different policy options.  

As described in the current situation and problem description above, stakeholders mentioned 
a higher reuse quota for lorries and PTW specifically, the amount of reuse of parts was not 
mentioned  by  stakeholders.  For  PTW,  data  on  reuse  exists  from  the  survey  provided  by 
SMOTO (2021). It was shown that dismantling for reuse can be between 10% (if dismantled 
at car dismantling facilities) and 90% (for privates/semi-professionals). Without information 
about the reuse rate, it is not possible to conclude on recycled quantities neither, because 
material in component parts that have been dismantled are no longer available for recycling. 
This means, at least an estimate for the reuse rate allows the quantification which show then 
an estimate of the benefits of circularity. For the baseline, the reuse quota for PTW, lorries, 
buses  and  trailers  is  estimated  at  30%  on  average  (in  the  EU  and  across  different 
dismantlers)321. In order to make such a rough estimate, in Option C, two average reuse rates 
were selected, and two variants calculated in the following. Neither of these represent reality, 
but  it  is  expected  that  the  average  situation  is  in  the  corridor  between  these  two  variants. 
Based on the detailed assumptions in Table 3-83 (Annex I), material quantities associated 
with reuse, recycling, recovery and losses are calculated for a PTW (type Le3A2), a lorry (12 
GVW) and a bus (12 GVW) with two variants for a reuse quota of 40% and one of 70%. In 
case of the 40%-variant, it is assumed that on average, the reuse rate in the baseline (30% 
on average) is high compared to the possibilities with the current market conditions. Thus, 
measures would entail a slight but not substantial increase. In the 70%-variant, it is assumed 
that the baseline is the lower limit of what is possible (on average) with the current market 
conditions. In this case, measures of Option C could entail a significant increase of reuse. 
Recycling rates were defined and continuously used for the purpose of this IA, see chapter 
3.4.3 (Annex I). 

For each policy option, see the material quantities arriving at different EoL steps for PTW, 
buses  and  lorries  in  the  figures  below.  Please  note  that  due  to  the  missing  material 
composition of trailers, no assessment of benefits from increase of circularity for trailers could 
be calculated. 

321   For cars and vans a reuse quota of 5% is assumed in the model calculating the impacts of measures under main objective 
“circularity”. 

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Figure 3-46  Material quantities for a powered two-wheeler (type Le3 A2) with with 
40% reuse in 2030 (top) and 70% in 2030 (down)  

B
1

C
1

A
1
/
e
n

i
l

e
s
a
B

A
1
/
e
n

i
l

e
s
a
B

B
1

C
1

A
1
/
e
n

i
l

e
s
a
B

B
1

C
1

B
1

C
1

A
1
/
e
n

i
l

e
s
a
B

Reuse

High Quality Recycling

Energy Recovery

Losses

Steel

Aluminium

Iron

Copper

Glass

Plastic

Ruber

Other

160.000

140.000

120.000

100.000

80.000

60.000

40.000

20.000

0

180.000

160.000

140.000

120.000

100.000

80.000

60.000

40.000

20.000

0

B
1

C
1

A
1
/
e
n

i
l

e
s
a
B

A
1
/
e
n

i
l

e
s
a
B

B
1

C
1

A
1
/
e
n

i
l

e
s
a
B

B
1

C
1

B
1

C
1

A
1
/
e
n

i
l

e
s
a
B

Reuse

High Quality Recycling

Energy Recovery

Losses

Steel

Aluminium

Iron

Copper

Glass

Plastic

Ruber

Other

Source: calculated at Oeko-Institut (2022), description chapter 6.9, and recycling rates in chapter 

3.4.3 (Annex), data for variant with 40% reuse in Annex,  

Table 6-14. Recycling rates in 3.4.3 

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Figure 3-47  Material quantities for 12 t GVW lorry with 40% reuse in 2030 (top) and 
70% in 2030 (down) 

800.000

700.000

600.000

500.000

s
n
o
t

400.000

300.000

200.000

100.000

0

1.000.000

900.000

800.000

700.000

600.000

s
n
o
t

500.000

400.000

300.000

200.000

100.000

0

BAU/1A

1B

1C

BAU/1A

1B

1C

BAU/1A

1B

1C

BAU/1A

1B

1C

Reuse

High Quality Recycling

Energy Recovery

Losses

Steel

Aluminium

Iron

Copper

Glass

Plastic

rubber

Misc.

BAU/1A

1B

1C

BAU/1A

1B

1C

BAU/1A

1B

1C

BAU/1A

1B

1C

Reuse

High Quality Recycling

Energy Recovery

Losses

Steel

Aluminium

Iron

Copper

Glass

Plastic

rubber

Misc.

= 

BAU 

business-as-usual 

shorter. 
Source:  calculated  at  Oeko-Institut  (2022),  description  chapter  6.9,  and  recycling  rates  in  chapter 
3.4.3 (Annex), data for variant with 40% reuse in Annex,  

baseline; 

used 

its 

as 

= 

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Table 6-14. Recycling rates in 3.4.3 

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Figure 3-48  Material quantities for buses (12 GVW) with 40% reuse in 2030 (top) and 
70% in 2030 (down) 

140.000

120.000

100.000

s
n
o
t

80.000

60.000

40.000

20.000

0

s
n
o
t

180.000

160.000

140.000

120.000

100.000

80.000

60.000

40.000

20.000

0

Baseline
/ 1A

1B

1C

Baseline
/ 1A

1B

1C

Baseline
/ 1A

1B

1C

BAU /
1A

1B

1C

Reuse

High Quality Recycling

Energy Recovery

Losses

Steel

Aluminium

Iron

Copper

Glass

Plastic

Misc.

rubber

Baseline
/ 1A

1B

1C

Baseline
/ 1A

1B

1C

Baseline
/ 1A

1B

1C

BAU /
1A

1B

1C

Reuse

High Quality Recycling

Energy Recovery

Losses

Steel

Aluminium

Iron

Copper

Glass

Plastic

Misc.

rubber

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= 

BAU 

business-as-usual 

shorter. 
Source:  calculated  at  Oeko-Institut  (2022),  description  chapter  6.9,  and  recycling  rates  in  chapter 
3.4.3 (Annex), data for variant with 40% reuse in Annex,  

baseline; 

used 

its 

as 

= 

Table 6-14. Recycling rates in 3.4.3 

There are green-house gas emission savings associated with the material quantities that are 
reused, recycled or recovered. These are shown in Figure 3-49. The CO2 benefits for reuse, 
recycling and energy recovery were calculated as described in the Annex I (section 6.9).  

Figure 3-49  Savings of greenhouse gas emissions through EoL treatment for 
expected number of ELVs in the EU per year (Global Warming Potential) in million 
tons of CO2-eq. with 40% reuse in 2030 (top) and 70% in 2030 (down) 

PTW (weighted average)

Lorry (12t GVW)

Bus (12t GVW)

BAU / 1A

1B

1C

BAU / 1A

1B

1C

BAU / 1A

1B

1C

0

-0,5

-1

-1,5

-2

-2,5

-3

-3,5

0

-0,5

-1

-1,5

-2

-2,5

-3

-3,5

re-use

high quality recyling

energy recovery

PTW (weighted average)

Lorry (12t GVW)

Bus (12t GVW)

BAU / 1A

1B

1C

BAU / 1A

1B

1C

BAU / 1A

1B

1C

re-use

high quality recyling

energy recovery

Assumption: PTW = weighted average over different L-types, lorries = exemplary model with 12 GVW, buses = 12t GVW 
BAU = business-as-usual = baseline; used as its shorter. 
Source: calculated by Oeko-Institut. Data in Annex I, Table 6-15. 

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As initially mentioned, for Option A & B, no direct benefits in terms of material quantities and 
green-house gas emission savings can be identified compared to the baseline.  

For Option C, in the variant with a 70% reuse rate in 2030, the following total greenhouse 
gas emission savings (total) are expected:  

•  2,72 million tons of CO2eq for PTW,  
•  3,09 million tons of CO2eq for lorries, and  
•  1,88 million tons of CO2eq for buses.  

Compared to the greenhouse gas emission savings in the baseline, in 2030, this results in 
savings (difference between baseline and Option C with 70% reuse) of 

•  433 000 tons of CO2eq for all PTW, or 0,278 tons per end-of-life PTW. 
•  562 000 tons of CO2eq for all lorries, or 2,134 tons of CO2eq per end-of-life lorry, and 
•  257 000 tons of CO2eq for all buses, or 8,186 tons of CO2eq per end-of-life bus.  

Based on the figures above, benefits from increase of circularity can be expected from Option 
C (C3 Reuse & Recycling and C2 Design for circularity). For Option C, in contrast to B, the 
provisions on reuse and recycling (currently Art. 7) shall apply to all vehicles by definition of 
this measure. However, SMOTO (2021) brings forward the concern that the common reuse 
practices could be undermined by the perceived focus of the current ELVD on recycling rather 
than reuse. Stakeholders contributing through the OPC questionnaire stated that immediate 
application  of  the  following  measures  was  not  feasible:  Material-specific  recycling  targets 
(22% of stakeholders for motorcycle and 18% for trucks), a reuse target (23% of stakeholders 
for motorcycle and trucks each) as well as recycled content target (18% of stakeholders for 
motorcycle and 23% for trucks). 

Indirect (long-term) benefits can be expected from information requirements (Option A) and 
C1 Type approval based on the assumption that measures to increase circularity follow after 
the information has been gathered.  

For  motorcycles,  type  approval  requirements  are  supported  by  stakeholders:  A 
recyclability target is preferred whereas recycled content targets and reuse targets 
are explicitly not recommended for motorbikes (EUROFER 2021b). To substantiate 
the 3R type approval requirement, an anonymous stakeholder (motorbike manufacturer, OPC 
contribution) proposed a list of non-reusable parts for motorcycles in addition to those listed 
in Art. 8 of the 3R Type approval Directive for M1 and N1: Wheel suspension (front/rear) incl. 
triple clamp, swing arm and all damping parts, handlebar, all kind/material of rims, sub-frame, 
and all kind/ material of fuel tank. 

3.4.4.2.3  Environmental benefits from formalised treatment 

Direct  impacts  expected  relate  to  environmental  benefits  from  an  increase  of  the 
environmental performance during treatment of ELVs in authorized treatment facilities, e.g., 
exhaust gas emissions or leakage of hazardous liquids when preventive measures are not 
sufficient. 

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In the baseline, 822 - 3825 mio tons of waste from ELVs occur 
from PTW, lorries and buses. Some MS require that vehicles 
other than M1 and N1 are treated in ATFs, e.g., lorries in Spain, 
motorcycles in Italy322. ‘Given the short time that has elapsed since the regulation entered 
into force, there is no evaluation of the changes that have occurred in the material flows of 
these  vehicles  (trucks  and  motorcycles),  nor  are  there  any  impact  evaluations’,  says  a 
representative of Ministerio para la Transición Ecológica y el Reto Demográfico, Italy (2022). 
However, in some MS PTW, lorries, trailers and buses are not in the scope of general waste 
regulation  nor  any  specific  EoL  regulation.  Further,  it  is  unclear  to  which  extent  treatment 
facilities for vehicles other than cars and vans, though they might follow general requirements 
for waste treatment, have the same standards than ATFs according to the criteria set out for 
ATFs  in  the  ELVD.  From  this  vague  information,  the  share  of  the  waste  volume  that  is 
currently  managed  in  according  with  sufficiently  high  standards  compared  to  the  waste 
volume that is not handled properly cannot be derived. In the baseline it is clear that used 
vehicles are exported to non-EU countries. From the list of importing countries of lorries and 
considering countries with comparable waste management standards for other vehicles, it is 
assumed, that waste management standards in importing countries are not equal to those in 
the EU in countries where regulation exists.  

As a result, in some MS and countries importing used vehicles, it is not ensured that liquids 
of  ELVs,  exhaust  gas  emissions  from  treatment  or  hazardous  waste  are  managed  in  an 
environmentally sound manner.  

In Option A, very little additional environmental benefits are expected from formalized EoL 
management. A small improvement may result from recyclers and dismantlers being more 
aware  of  pollutant  concentrations  in  certain components  if  manufacturers  were required  to 
report on them under the A1 requirements (information for waste management operators). 
The reporting obligation for recyclers could be However, information requirements for MS on 
the numbers of ELVs as well as the one-time reporting obligation on EoL contribute to making 
the problem tangible and quantifiable. Also, the problem of non-harmonization of rules in the 
different MS will be visible. It is not expected that there are differences for different vehicle 
categories.  

The ATF requirement in Option B will improve the environmental conditions of treatment in 
those MS that currently have no regulation for ELVs other than cars and vans, or in those MS 
that  only  have  waste  management  rules  for  one  of  the  vehicle  categories,  e.g.,  only  for 
motorbikes. Option B would extend this to all L-Type approved vehicles. For those vehicles, 
that arrive at dismantlers, requirements on depollution are being followed resulting in lower 
risk for leakage of hazardous liquids or hazardous substances in general to the environment, 
and  higher  efficiencies  in  exhaust  gas  control  processes,  i.e.,  less  emissions  to  the 
environment,  can  be  expected.  Due  to  the  differences  in  MS,  no  EU-wide  picture  can  be 
drawn as to the extent of the improvement. Also, the requirement to treat ELVs in an ATF 
does not necessarily increase the number of vehicles arriving at dismantlers.  

Also in Option B, the combination of A1 (Information for waste management operators) and 
B1 (restriction of the four heavy metals) would ensure that recyclers know which parts contain 
which pollutants, and certain hazardous substances, actually the four heavy metals, would 
no longer be contained in the vehicles or only in cases specified by exemptions listed in Annex 
II, so that it can be assumed that the amount of hazardous waste decreases or can be better 

322 The legislative decree D.Lgs 152/06, Article 231 ‘End-of-life vehicles not covered by D.Lgs 209/03’, details how motorcycles 
must be managed, e.g., the technical requirements of the ATF motorcycles and for the dismantling phases (depollution and 
demolition) are the same. 

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separated  due  to  the  information  about  the  concentrations  of  hazardous  substances  in 
specific  components.  Differences  for  the  different  vehicles  are  expected  in  the  sense  that 
amount  and  type  of  prevented  hazardous  waste  will  differ  per  vehicle  category  based  on 
different material composition due to vehicle category specific requirements for the materials 
used,  e.g.,  for  PTW,  materials  are  exposed  to  weathering  directly,  longer  lifecycles323, 
different  operating  conditions  (e.  g.  temperatures,  vibrations,  wetness,  dirt  etc.),  higher 
technical characteristics (e. g. revolution speed of engine). 

It should be noted that Option B has not any influence on the 
amounts of vehicles exported which is currently ~35% of the 
expected waste lorries, 20% of waste buses and an absolute 
number of ~75,000 used (semi-)trailers per year. Thus, it is expected that neither the amount 
of (hazardous) waste nor the environmental conditions of recycling in receiving countries of 
export does change compared to the baseline. For PTW the number of exported vehicles is 
unclear.  

Measures C4 and C5 have an impact on the benefits from formalised treatment in Option C. 
From measure on advanced traceability, it is expected that this results in an increase of the 
number  of  vehicles  treated  in  ATFs,  thus,  less  environmental  problems  (explained  above) 
associated  with  vehicles  of  unknown  whereabout  within  the  EU.  From  measure  on  export 
restrictions,  it  is  expected  that  this  results  in  an  increase  of  vehicles  arriving  at  European 
dismantlers, thus, leading to less environmental problems associated with exported vehicles 
in importing countries.  

3.4.4.3  Economic impacts 

Some of the problems can be explained with market failures, e.g., it might be economically 
viable  to  export  used  cars  than  to  repair,  refurbish  or  recycle  them  in  Europe,  however, 
external costs associated with the export are not included in this calculation and there are 
small signs that the export of used vehicles might decrease in the future. Arguments were 
presented above. 

As a consequence, measures proposed to target the problems have economic implications. 
Then, a number of regulatory failures was identified, e.g., the missing incentive to design for 
circularity,  insufficient  harmonized  across  the  EU,  and  inconsistency  between  scopes  of 
ELVD and 3R Directive. In these three cases, the highest burden is on the environment. It is 
inherent  in  some  of  the  measures  proposed  to  address  these  problems,  that  they  are 
associated  with  administrative  burden  for  manufacturers,  EoL  stakeholders  as  well  as 
authorities on different levels.  

In the field of economic impacts, various burden, e.g., costs, and developments in the markets 
can be considered for OEMs, ATFs, particularly for SMEs, and costs for public authorities are 
expected at this stage. To compare the efficiency of the measures, particular attention will be 
given to differences in costs for OEMs and in costs for MS authorities: As many OEMs are 
expected to be SME (distributors of Cat. N and O vehicles, body builders for trailers and semi-
trailers,  small  motorcycle  manufacturers  or  repair  shops,  etc.),  attention  shall  be  given  to 
differences also to OEMs in this respect.  

323 ACEM (2021): “15 years; cars’ lifetime is 11.5 years, thus, at least 4 years difference which means that Motorcycle ELVs 
are elder than car ELVs and will therefore longer contain SVHC materials which are not yet banned for motorcycles. As 
consequence residual amounts of SVHC due to recycling have to be tolerated (e.g., lead in aluminium alloys) for the use of 
quality-assured secondary materials” 

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3.4.4.3.1  Economic impacts for manufacturers 

This section covers six impact categories:  

1)  Costs for manufactures for the change of the design of vehicles, e.g., 

different material choices,  

2)  Administrative costs for manufactures,  
3)  Competition effects,  
4)  Developments in the internal market, incl. innovation,  
5)  Effects on SMEs, and 
6)  Costs of an EPR. 

For  this  section,  it  should  be  noted  that  no  information  is  available  on  the  magnitude  of 
economic  effects  or  on  differences  between  vehicles.  In  the  interviews,  stakeholders  only 
emphasised that the introduction of regulations for new vehicles would have costs but did not 
detail  the  dimension.  The  following  table  (Table  3-86)  is  included  to  provide  at  least  an 
indication  based  on  the  consultant’s  overview.  With  regard  to  the  differences  between  the 
options,  the  table  summarises  the  explanatory  text  following  the  table.  The  differentiation 
between  the  vehicle  categories  can  only  be  assumed.  Where  one  vehicle  category  is 
assumed  to  be  different  than  the  other  categories,  the  boxes  are  marked  in  green  and 
explained below the table.  

Table 3-86 Comparison of economic impacts for manufacturers of different vehicle 
categories compared to the baseline (0 = no/little impact, +/++/+++ = low, medium, 
high costs/impact) 

Type of 
costs/effect* 
Option 

Design 

PTW manufac. 

Lorry 
manufac. 

Bus 
Manufac. 

Trailer 
manufac. 

A 

0 

B 

+ 

C 

++ 

A 

0 

B 

+ 

C 

++ 

A 

0 

B 

+ 

C 

++ 

A 

0 

B 

+ 

C 

++ 

Manufac. of 
currently exempt 
vehicles** 
A 

C 

B 

0 

+ 

+++a 

Administr. 

+++b  ++ 

+++  ++  ++  +++  ++  ++  +++  ++  ++ 

+++ 

++ 

++ 

+++c 

++ 

++e 

0 

0 

0 

+e 

++f  ++f 

? 

./. 

./. 

+ to +++ 

Competitiv. 

Innovation 

0 

0 

0 

++ 

+d 

++d 

SMEs 

++f 

++f 

? 

0 

0 

0 

0 

0 

+ 

EPR + fees 

./. 

./. 

+ to 
+++ 

./. 

./. 

++ 

+ 

+ 

+ to 
+++ 

0 

0 

? 

0 

0 

? 

./. 

./. 

++ 

+ 

? 

+ to 
+++ 

0 

0 

0 

0 

++f  ++f 

./. 

./. 

++ 

+ 

? 

+ to 
+++ 

a) While it is assumed that reasonable 3R targets, recycled content and other design requirements can be defined for PTW, 
lorries, buses and trailers, it is also assumed that 3R type approval puts higher costs for changes in the design on second-/third-
stage manufacturers of multi-stage build vehicles. 
b) Due to the B2C market of PTW, it is expected that reporting on EoL as well as monitoring and reporting the number of ELVs 
could be more effort compared to the other vehicle categories. 
c) It is clear that administrative costs of 3R type approval are high for all vehicles, whether there are even more costs of second-
/third-stage manufacturers of multi-stage build vehicles, however, is unclear. 
d) PTW are a consumer good compared, they have various differences in the materials used and, in view of the consultant, the 
sector is least prepared for ELVD requirements compared to the other vehicle categories assessed. Thus, developments in the 
market including innovation are highly expected. 
e) Based on the current exemption for multi-stage-built vehicles, so far, manufacturers did not have to consider ELVD/3R 
Directive requirements. Thus, developments in the market including innovation are highly expected. 
f) High SME rate compared to lorries. For buses, the distribution of SMEs compared to bigger businesses is unclear.  

(*) Types of economic effects relate to the impact categories mentioned in the text directly before this table. 
(**) stakeholders in the field of vehicles that are currently exempted from ELVD or 3R Directive, mainly producers of bodywork 
or components built on base vehicles (second-/third-stage manufacturers).  
Source: own assumptions. 

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Costs for manufacturers for change of design 

Compared to the baseline, additional costs for manufacturers in relation to changes of the 
design of vehicles are not expected in Option A. However, such costs occur in Option B based 
on B1 (restriction of the four heavy metals) and in Option C based on measures C1 (3R type 
approval), C2 (Design for circularity), and C3 (3R targets.)  

For Option B, it is expected that materials exist on the market that are free of the substances 
prohibited under the ELVD today due to car and van manufactures requesting such material 
since the introduction of the ELVD. From the comparison of the material composition (Figure 
2-29), it is acknowledged that not all materials used in PTW, lorries, buses and trailers are 
identical or used in identical amounts compared to cars and vans, e.g., wood, textiles, certain 
plastic parts. However, on the market, it is expected that heavy metal-free material for the 
manufacturing of vehicles can be supplied, and there is the possibility to apply for exemptions 
(see administrative costs for manufacturers). What might cause an issue is the fact that the 
vehicles have in common  

Costs for the change of the design are expected higher in Option C than in Option B as there 
are on the one hand the restriction of the four heavy metals but on the other hand additional 
design requirements such as possible recycled content targets and/or requirements from 3R 
targets that have an impact on the material composition of the vehicles. Currently, measures 
C1-C3 are defined too vague due to missing information for PTW, lorries, buses and trailers, 
and  a  decision  on  comparable  measures  for  vans  and  cars  has  not  been  taken  so  far. 
Therefore,  no  more  indication  of  costs  that  have  to  be  borne  by  manufacturers  for  design 
changes can be provided at this point of time. If the design requirements set in the future ELV 
legislation and controlled through the 3R type approval (under measure C1) are not adapted 
to the vehicle specificities, measure C1 is expected to entail high cost for design changes; 
e.g., if possible 3R targets for a vehicle type do not correspond to what is achievable (although 
it is unclear what is achievable and demanding at the same time). 

Available information does not allow drawing conclusions whether relative costs for changes 
in the design, e.g., in relation to the total manufacturing costs of the vehicles are comparable 
for different vehicle categories.  

Administrative costs for manufacturers  

This  includes  costs  for  reporting/providing  information  which  is  part  of  all  three  options 
(Option A, B and C). Providing information for waste management operators (A1) are regular 
administrative  costs  that  come  with  every  new model,  information  for  the  one-off reporting 
foreseen under measure A3 is a one-off cost. Impacts if implementation of a digital product 
passport as one form of providing information to recyclers are evaluated in Deloitte (2022)324. 
Costs for providing information are not connected with direct benefits (as no requirements on 
design or EoL are foreseen in Option A). Other administrative costs are coupled to every new 
vehicle developed.  

324 The total costs of a potential digital product passport have been modelled using different data transmission standards and it 
has been evaluated which stakeholders would be burdened with which costs.  

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Table 3-87   Admin. Costs (AC) for lorry and PTW manufacturers in Policy Option A  

Activity 

Type of obligation  Manufacturers 

Information to waste 
operators 

Information to waste 
operators 
Maintenance online 
platform for 
information sharing  

Submission of 
(recurring) reports per 
type-approved 
vehicle* 
Submission of 
(recurring) reports* 
Submission of 
(recurring) reports  

Lorry manufacturers and 
their suppliers ( ~ 14**) 

PTW manufacturers (~16**) 

PTW manufacturers 
(~16**), not relevant for 
lorries as voluntarily 
implemented in the baseline 

Total AC 

0***  

9.869 

3.041**** 

Assumptions:  (*)  three  type  approvals  per  year;  (**)  assumptions  displayed  in  the  Table  in  the 
annex.  (***)  100%  of  AC  already  covered  by  the  baseline;  (****)  total  annualised  one-off 
costs 
administrative 
Source:  

Table 6-17 and Table 6-18 (Annex I). 

Costs for the management of the supply chain occur with Option B for hazardous substances 
(restriction of the four heavy metals) and additional supply chain management costs occur 
with  Option  C  for  changes  in  the  design,  e.g.,  recycled  content  targets.  Requirements  in 
Option B and C could imply the one-time search for and contracting of new suppliers.  

Table 3-88   Admin. Costs (AC) for all non-passenger car vehicle manufacturers (~30 
companies) in Policy Option B325 

Activity 

Type of obligation 

Days of work 

Total AC 

Contribution to the development of vehicle 
specific Annex II of ELVD (for lorries + 
trailers; busses; L-cat vehicles) 
Supply chain management 

Application for general 
authorisation or 
exemption  
Notification of (specific) 
activities or events  

3 

1 

6.168 

6.516* 

Assumptions: 

(*) 

total 

annualised 

one-off 

administrative 

costs  

Source:  

Table 6-17 and Table 6-18 (Annex I). 

Relevant  in  Option  C  only,  costs  occur  associated  with  changes  in  the  type-approval 
processes. In 3R Directive-related interviews, stakeholders indicated that the manufacturers 
have departments working in the general type-approval, e.g., in relation to security-related 
aspects etc. For such departments, the 3R type-approval would be an additional task. This 
task consists of the preliminary assessment of the manufacturer (independent of the models 
and  regularly  every  2  to  3  years)  and  model-specific  type-approval,  thus,  the  recyclability 
calculation plus other 3R Directive, Annex I requirements. In both cases, the main task is to 
collect, store and prepare information in a certain way that technical services and Member 
State competent authorities can perform their checks. The questionnaire for the stakeholder 
interviews in relation to the 3R Directive were prepared in a way to retrieve quantitative data, 
e.g., when asking how much time is required for the preparation of documents for a 3R type 

325   For a full calculation and further assumptions, see  

Table 6-17 and Table 6-18 (Annex I). 

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approval, or in relation to implementation costs.326 As no information was obtained through 
the stakeholder consultation, and as type-approval documents are non-disclosed generally, 
no  quantification  of  the  administrative  costs  for  manufacturers  could  be  presented  initially. 
However, a more detailed calculation is presented in Annex I.  

Examples for administrative costs listed by the motorcycle manufacturers’ association (ACEM 
2021)  are  ‘operational  fees  for  database  to  document  recycling  relevant  information  of  all 
models (per OEM per year), effort for vehicle documentation in database, efforts on analysis 
of material compliance, efforts on application for exemptions, costs for set up and operation 
of return systems and effort for type approval based on additional documentation obligations’. 
ACEM  (2021)  also  explains  that  ‘the  costs  cannot  yet  be  quantified  in  detail  (but  can  be 
compared to the efforts that car manufacturers have had in the past).’ Though this information 
is from the motorbike manufacturers association (ACEM), it is expected that manufacturers 
of other vehicle categories have the same costs.  

Competitiveness 

It  is  assumed  that  reporting  requirements  (Option  A)  and  the  requirements  in  Option  B 
(restriction of the four heavy metals, ATF and CoD) does not have any implications on the 
competitiveness of the manufacturers of vehicles. Thus, this impact category plays a role only 
for Option C. Changes to design may affect the competitiveness of vehicles, though this is 
assumed to affect manufacturers similarly. This is not to say that the competitiveness of some 
will  not  be  affected,  but that the  same requirements  apply to  all  and  in  this  sense that the 
provision shall not create unfair competition. Until the measures are decided and come into 
force,  it  is  possible  that  certain  manufacturers  will  voluntarily  start  implementing  certain 
strategies.  It  became  clear  that  the  industry  is  already  dealing  with  some  requirements  in 
detail,  e.g.,  heavy  metal  restrictions  and  related  Annex  II  exemptions  (BMW  Group  2022; 
SCANIA 2022). Other than voluntary preparatory action for a potential regulation might be 
green  public  procurement.  The  public  procurement  authorities  might  include  certain 
requirement in tenders for vehicles, e.g., buses for public transport or PTW for police, lorries 
for  logistic  services.  It  cannot  be  ruled  out  that  the  voluntary  preparatory  work  of  some 
companies will have an impact on competition until it comes into force. 

Thus, the question  is how the  introduction of  new design requirements  (measures C2  and 
C3) will affect the competitive position of EU manufacturers against manufacturers from other 
key markets. At this point of time, the measures C2 and C3 are not yet fixed in the sense that 
no  target  values  for  any  3R  targets  nor  recycled  content  targets,  and  no  decision  on  due 
diligence  requirements  or  requirements  on  non-recyclable  materials  etc.  exist  in  general, 
especially  not  for  vehicles that  could  possibly  enter  the scope  of the  legislation. Of  cause, 
more  and  ambitious  requirements  might  weaken  the  position  of  manufacturers  of  the  EU 
compared to non-EU business operators, however, being able to communicate repairability 
rates, reuse quota, or number of spare parts based on circularity requirements imposed might 
even  strengthen  the  businesses’  position  in  the  market  based  on  the  assumption  of 
consumers being highly interested in sustainable practices. 

326   We provided optional answers, e.g., <0.5 years full time equivalents (FTE), 0.5 – 2 FTE or >2 FTE per each 3R TA, 
facilitating manufacturers can provide data on a non-confidential basis. However, requested information and data was not 
provided and/or declared non-disclosed. The stakeholder involvement and their contribution are described in Annex II and 
Annex III. 

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Developments in the internal market, incl. innovation 

When regulations are introduced, a market inevitably changes because different companies 
are differently prepared for the changes. Nevertheless, all rules in the European market apply 
to all business operators. It is expected that the measures from options A and B will have little 
impact  on  the  vehicle  manufacturers'  market.  Assuming  that  the  specific  targets  for  the 
measures in Option C are based on the feasibility of the sector, which claims to already have 
high reuse rates and uses similar mostly recyclable materials as used in cars and vans, it can 
also be assumed that Option C will have little economic impact on the internal market. In any 
case, with the introduction of circularity measures from Option C, there is an opportunity for 
innovation,  but,  as  the  market  already  sees  itself  in  line  with  the  CE  objectives,  these 
measures are not considered to be an extraordinary innovation driver for manufacturers of 
vehicles with the exception of PTW manufacturers. PTW are a consumer good; they have 
various  differences  in  the  materials  used.  In  view  of  the  consultant,  the  sector  is  least 
prepared for ELVD requirements compared to the other vehicle categories assessed. Thus, 
developments in the market including innovation are expected. 

Effects on SMEs 

Small  and  medium-sized  enterprises  (SMEs)  are  mainly  engaged  in  the  production  and 
supply of components for the production of PTW and trailers. Many SMEs are also involved 
in body work for base vehicles (in relation to multi-stage-built vehicles). The structure of the 
business sector for buses is unclear.  

The main administrative costs, e.g., the cost of reporting (Option A), are similar regardless of 
the size of the company, these costs therefore burden SMEs proportionally more than large 
companies.  In  result,  Option  A  is  a  high  burden  for  SMEs.  Option  B  also  involves 
administrative costs related to the supply chain management of hazardous substances (the 
restriction  of  the  four  heavy  metals),  but  it  is  expected  that  the  market  for  hazardous 
substance-free components exists, and it is a one-off cost. Option B therefore does not imply 
much more additional effort for SMEs than option A. The impacts of Option C on upstream 
supply chains and small businesses are unclear until more precise targets for the measures 
are agreed. Because the PTW, lorries, buses and trailers sectors claim themselves already 
circular in relation to reusability for example, it is possible that SMEs' businesses may not 
need to change incredibly. But that is speculation at this point. 

Costs of an EPR 

There are two types of costs here: those incurred for the establishment and structure of the 
EPR, e.g., the formation of a producer responsibility organisation (PRO); the other costs are 
the  fees  that  the  producers  would  have  to  pay.  The  vehicle  manufacturers  in  Europe  are 
already  networked,  PROs  already  exist  in  some  MS  and  expertise  on  EPR  is  presumably 
available; it will also be possible to join forces with the EPR/PRO for M1 and N1, if there is to 
be  one.  It  is  likely  that  for  the  first  type  of  costs  (set-up  and  structure)  there  will  not  be 
significantly more costs than in the baseline. The fees cannot be named at this stage, nor can 
they be given an order of magnitude. they depend on what obligations there will be for the 
ATFs/waste operators and whether these will be economically viable for the ATFs or not. It is 
clear that the fee for different vehicles will be different because it depends, for example, on 
the amount of material or the complexity of how easily something can be dismantled. There 
is the principle of modulation of fees, so that there could be a wide range of fees.  

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As presented above, two Member States included PTW in their EPR or set up a 
voluntary  EPR,  whereas  in  France  the  corresponding  law  only  applies  from 
01.01.2022. An evaluation of costs and benefits is not yet available due to the short 
time. The Dutch voluntary EPR for scooters for mopeds and mopeds up to 50 cubic 
centimetres, the Scooter Recycling Nederland (SRN), was founded in 2011 (Auto Recycling 
World 2021). ‘The network exists of 180 delivery points and 65 scooter dismantlers (mostly 
cars dismantlers that do scooters as a side job). Aim is collection without costs for the last 
owner  and  sustainable  recycling.’  (EGARA  2022b)  The  system  is  voluntary  at  present. 
According to the SRN webpage (BOVAG; RAI 2022), 25 000 scooters were scrapped at drop-
off  points  of  1.2  million  scooters  in  the  Netherlands.  No  costs  for  construction  and/or 
maintenance could be obtained from the interview with ARN as SRN's "big sister". 

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3.4.4.3.2  Economic impacts for EoL stakeholders 

This section covers six impact categories:  

1)  Revenues for dismantlers from spare parts and for dismantlers and recyclers from 

recycling; 

2)  Revenues & lost revenues from missing vehicles and exported used vehicles; 
3)  Administrative burdens on businesses, 
4)  Competition effects,  
5)  Developments in the internal market, incl. (investments in) capacities, and 
6)  Effects on SMEs. 

The following table is included to summarise the explanatory text following the table. In some 
cases, the differentiation between the vehicle categories can only be assumed. Where one 
vehicle category is assumed to be different than the other categories, the boxes are marked 
in green and explained below the table.  

Table 3-89 Comparison of economic impacts for EoL stakeholders compared to the 
baseline (0 = no/little impact, +/++/+++ indicates the expected level of effects, but not 
whether positive or negative) 

PTW dismantler**  Bus, trailer, 

Recycler 

Shredder 

Type of effect* 

Option 

A 

B 

C 

lorry 
dismantler*** 
B 

A 

C 

Admin. costsa 

++ 

+++ 

+++ 

++ 

+++ 

+++ 

A 

0 

B 

0 

Spare parts and 
recyclingb 
Missing v. and 
exportc 

Competitivenessd 

Internal markete 

./. 

./. 

+ 

0 

./. 

./. 

+ to 
+++ 

++ 

? 

+++ 

+++ 

+++ 

SMEsf 

++ 

++ 

? 

./. 

./. 

+ 

0 

+ 

./. 

./. 

+ to 
+++ 

C 

+ 

+ 

A 

0 

./. 

++ 

./. 

./. 

+++ 

./. 

./. 

+++ 

./. 

+++ 

+ 

0 

+ 

+ 

++ 

++ 

0 

0 

+++ 

+++ 

B 

0 

./. 

./. 

0 

+ 

C 

+ 

+ 

+++ 

++ 

++ 

+ 

? 

./. 

./. 

? 

./. 

./. 

? 

a) ./. 
b) the sector claims a high reusability; thus, dismantlers will profit more from measures introducing measures for increased circularity. Still, 
based on the claim, this is not a triple plus because if it is right, that reusability is already high, then, compared to the baseline there will be 
medium changes.  
c) only relevant in Option C and lack of data for PTW; in general perceived highly relevant 
d) in Option A, an increase in the competitiveness is expected based on additional information (A1), however, this affects mainly dismantlers 
and recyclers. Option B (measure B2) introduces a difference between informal and formal dismantlers for dismantlers, this will have an 
influence, which is however unknown 
e) Together with the competitiveness changes in the internal market are expected, however, with differentiation between dismantlers on the 
one side and recyclers and shredders on the other side, still they would receive a lot more material from ELVs, e.g., if export was restricted 
(measure C5). 
f) Share of SMEs in the sectors highly unsure, however, expected higher for PTW than for buses, lorries and (semi-) trailers, and higher for 
dismantlers than for recyclers and shredders.  

(*) Types of economic effects relate to the impact categories mentioned in the text directly before this table; (**) Business 
operators; (***) all three vehicle categories require from an ATF to have enough space and respective tools, thus, it is 
assumed that this is one category of dismantlers. It might be possible that some are specialized in only some of the vehicle 
categories.  
Source: own assumptions. 

Administrative costs for EoL stakeholder  

In  Option  A,  specifically  burdens  dismantlers  in  relation  to  reporting  and  providing 
information. The reporting to Eurostat is done a little bit differently by all MS, respectively they 
collect the data differently, which have to be entered into the tables for the reporting. However, 

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they often base their data on the CoDs issued by the ATFs. In A2, MS are supposed to report 
on the waste PTW, lorries, buses and trailers arriving at dismantlers. Here, MS may need to 
deviate  from  their  typical  data  collection  process  and  ask  dismantlers  directly,  who  in  turn 
must report. However, some MS may even already collect this data, e.g., in Italy and France, 
where  PTW  are  included  in  the  scope  of  the  respective  ELV  legislation.  It  will  be  slightly 
different in each member state how much additional burden is placed on dismantlers. See the 
quantification in the table below. 

Measures  of  Option  B  might  entail  additional  administrative  burden  for  ATFs  for  the 
authorization process as well as efforts associated with the issuing of CoDs/management of 
(de-)  registration.  FORS  (a  Polish  Recycling  Association)  speaks  for  the  practice  of 
certificates of destruction for end-of-life motorcycles (FORS 2021). As reported elsewhere, 
today  in  some  MS  dismantlers  are  already  committed  to  the  general  requirements  of  the 
Waste Framework Directive (WFD). If this is the case, a formalization process to become an 
ATF  according  to the (current) rules  of the  ELVD  is  probably  not  a  significantly  expensive 
process: Still, a third-party expert must be hired once, and all documents must be compiled. 
The situation is different if dismantlers do not yet work according to the standards of the WFD. 
It can be assumed that the situation of such informal operators is very different, i.e., the costs 
for a conversion to an authorized operation will be very different. Current costs for ATFs for 
the formalization process under ELVD are not known, as the requirement for car ATF has 
been in place since the coming into force of ELVD. See the quantification in the table below. 

Table 3-90   Yearly Admin. Costs (AC) for the EU dismantling sector (~4 500 ATFs327) 

Activity 

Type of obligation 

Days of work 

Total AC 

A2 

B2 

B3 

Reporting on treated ELVs to 
MS authority 
Authorisation process 

Notify vehicle registers 

Submission of (recurring) 
reports  
Certification of products or 
processes 
Notification of (specific) activities 
or events  

1 

925.200 

5 min per ELV* 

3.700.800 

10 min per ELV** 

5.809.237 

Assumption:  (*)  3  250  000  ELVs  (=sum  of  waste  lorries,  buses,  trailers  and  L-cat  vehicles).  (**) 
assuming  that  in  1/3  of  the  EU  MS  CoD  requirements  exist  in  the  national  legislation.  Further 
assumptions 
Annex. 
Source:  

in 

Table 6-17 (Annex I). 

With possible changes in the numbers of ELVs and changes in the material volumes arriving 
at recyclers a certain level of management can be expected in Option C. Compared to option 
B, this is not specifically a higher burden. 

Used  spare  parts  and  material  for  recycling  and  related  revenues  for  EoL 
stakeholders 

The impact category of revenues for dismantlers and recyclers from spare parts and recycling 
is only relevant in relation to the bundle of measures of Option C. In Option A and Option B, 
minimal changes in the baseline are expected as to additional amounts of spare parts for sale 
or increased amounts of material for recycling. This is due to measures A1 (information to 
recyclers) and B1 (restriction of the four heavy metals), because if the dismantlers receive 

327 Taking into account that 15% (per unit) of vehicles are not in scope today and assuming the identical additional share for 
ATFs might be required for the dismantling of PTW, lorries, buses and (semi-)trailers, this results in a number 4.500 ATFs 
being required for vehicles other than M1 and N1 (assumed authorised facilities for M1 and N1 vehicle treatment: ~ 30 000). 

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more  (and  targeted)  information  on  these  hazardous  substances  and  on  the  material 
compositions  of  components,  and  if  they  can  be  sure  that  the  vehicles  do  not  contain  the 
heavy metals restricted through ELVD, they probably take more targeted decisions regarding 
the removal of certain components. At the same time, this must always be weighed against 
the effort resulting from removing additional parts from the end-of-life vehicles. It is therefore 
assumed that the changes in the material flows are minimal for measures A1 and B1 each, 
but even in combination. Probably, additional revenues for EoL stakeholders will be marginal 
too. Other measures from Option A, the information requirements on ELVs (A2) and the one-
off reporting describing the status-quo in the EoL markets and material streams therein (A3) 
will also have little to no impact on recycled volumes or additional profit opportunities for EoL 
stakeholders.  The  impacts  of  the  introduction  of  the  ATF  requirement  (B2)  in  Option  B  in 
relation  to  material  to  be  recycled  or  amounts  of  used  spare  parts  in  the  market  are  also 
assessed marginal, as outlined before, this requirement is more about formalization of the 
EoL  and  prevention  of  pollution  of  informal  dismantling.  However,  generally,  it  can  be 
expected  that  the  extension  of  scope  as  such  (which  is  foreseen  in  all  Options)  rises  the 
attention and awareness of the sector. Voluntarily future-proof decisions could be taken by 
industry stakeholders resulting in (unforeseeable) benefits for circularity. 

Option  C  is  the  policy  option that  has  influences  on  the  number  of  available  (used) spare 
parts,  increase  in  the  quality  of  recycled  material  and  amount  of  recycled  material  (mainly 
measure C2 and C3). Changes in these indicators, influence the economic impacts for EoL 
stakeholders.  At  this  stage,  data  is  lacking  as  to  define  the  exact  measures  (neither  the 
measures themselves nor the ambition level of the targets). 

To provide at least one example in relation to spare parts in lorries, the baseline 
described by Saidini et al. (2018) is used to calculate revenues generated through 
the  second-hand  sale  of  dismantled  components  today.  Saidini  et  al.  (2018) 
conclude that ‘redistribution of second-hand components is a profitable business, e.g., when 
a Volvo FH Globetrotter is dismantled properly (95% of its weight, i.e., 7,000 kg), the overall 
resale of spare parts can reach 40,000 euros.’ Based on these numbers using the expected 
waste  lorries  in  2020,  revenues  from  the  sale  of  spare  parts  from  lorries  in  the  EU  are 
calculated to 5.3 billion Euro, an additional amount of 3.0 billion Euro is lost revenue for the 
European EoL stakeholders due to missing vehicles (Table 3-91). 

Table 3-91 Calculation of revenue from resale of spare parts  

Expected  waste  lorries  >  3,5t  in  2020  (Oeko  model  based  on 
PRIMES) 

207130  # 

Missing vehicles (see Figure 2-25) 

36%  % 

Lorries dismantled in EU (64% of the expected waste lorries) 

132563  # 

Resale of spare parts per vehicle (Saidini et al. 2018) 

40000  Euro 

Revenue from resale of spare parts in the EU 

 5.302.539.862   Euro 

Lost  revenue  from  resale  of  spare  parts  through  missing 
vehicles 

 2.982.678.672   Euro 

The study does not provide an additional information as to the amount of material or revenue 
that  can  be  generated  from  the  “rest”  of  the  lorry  after  having  dismantled  components  for 

Source: indicated in the lines of the tables. 

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second-hand sale. Also, from this information it is difficult to conclude on expected impacts 
of measures from Option C in relation to the numbers. If reuse was supported through the 
introduction of measures, it is expected that the revenue increases, however, there is the risk 
that measures, such as a separate recycling target, could jeopardize current repair and reuse 
practices  as  ATFs  could  compete  with  such  operators to  ensure  fulfilment  of the recycling 
target. In such a case, revenues from spare parts decrease. 

In  relation  to  recycling,  hypothetically,  based  on  the  expected  numbers  of  ELVs  in  2020 
(baseline)  and  2030  (Option  C)  using  the  material  composition  and  current  prices  for 
secondary raw material, the revenues generated from the materials from ELVs if they were 
recycled  (assuming  100%  recycling)  can  be  calculated.  However,  this  calculation  is 
misleading in various ways: First, it does not take into account reuse rates, which however 
are unknown at this point of time. Then, prices for secondary raw material are volatile, and 
especially  are  expected  to  change  over  the  course  of  the  next  years,  thus,  calculating 
revenues is not providing a profound statement of the impacts.  

Thus, as it is not possible to calculate impacts on the material and component parts indicators, 
and to derive changes in the costs and revenues for EoL stakeholders. In Option C, another 
measures in relation to circularity is C1, i.e., the introduction of the 3R Type-approval for new 
vehicle categories. It is clear that the introduction of 3R type approval does not impact the 
amounts of spare parts, material recycled or their quality directly. Rather it is a tool to ensure 
that other measures in relation to design for circularity are being checked when new types 
enter the market. 

Missing and exported used vehicles 

Currently, used vehicle dealers and ATFs are selling used vehicles for export. The baseline 
in terms of numbers and importing countries is described in the problem description (chapter 
2.4.3.1). On average these were 156 959 lorries (incl. road tractors)328, 9 326 buses and 75 
074  trailers  per  year.  For  PTW,  there  is  not  dada.  With  these  exports,  these  operators 
generate revenue.  

Different priced for exported lorries per kg are provided by the Dutch Ministry of 
Infrastructure and Waste management and provided in the Annex I, Table 6-19. In 
Western  Africa,  the  price  is  0.99  €/kg  (lowest  in  comparison  of  the  regions),  the  expected 
price for exports to Western Europe is 9.79 €/kg (highest in comparison), the average of the 
median  prices  of  all  regions  is  3.11  €/kg.  For  lorries,  the  provided  prices  can  be  used  to 
calculate  the  revenue  from  used  vehicles  per  year  (for  157  000  exported  lorries  using  an 
average weight of 8500 kg per lorry): 1.3 billion € to 13.1 billion € with an average of 4.1 billion 
€ per year. At the same time, business operators in Europe loose revenues from materials in 
missing  vehicles  or  that  are  exported  as  “used  vehicles”.  In  the  baseline,  for  lorries,  it  is 
expected that 502 425 tons of material are lost due to missing traceability (assuming 34% of 
unknown whereabouts according to Mehlhart et al. 2017) and 1.1 million tons due to Extra 
EU  export  (based  on  export  data).  With  the  current  prices  for  recycled  materials  (and 
assuming 100% recycling), this adds to 99 million Euro for the lost material due to missing 
traceability and another 218 million Euro for the lost material of exported lorries (Table 6-15 
and  

328 80120 road tractors, 76839 lorries 

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Table  6-16,  Annex  I329).  This  comparison  is  insofar  misleading  that  other  stakeholders, 
namely  used  vehicle  dealers  and  ATFs  generate  revenue  from  sales  of  exported  material 
than  from  sales  of  recycled  material  in  the  EU.  Nevertheless,  the  difference  in  revenues 
indicates the reason for the high export figures: In terms of the overall economy, at current 
prices, recycled material can only generate about 10% of the revenues per year made with 
exports. In addition, In the workshop, it was mentioned ‘that the export of old trucks in Africa 
or other countries will be more and more difficult because of more complex exhaust emission 
control  system  in  trucks,  more  hybridization  of  engines  and  other  technical  reasons.  The 
second use of trucks will be more difficult even if the road infrastructure is more and more 
developed  in  these  countries.  Renault  Trucks  want  to  develop  a  network  of  specialized 
companies of treatment of trucks.’ (Eric Lecointre, Workshop 2022). 

Except  for the  numbers from  trade  statistics  on the  export  of  used  buses,  such 
detailed numbers as for lorries are not available, e.g., the prices for exported used 
vehicles. In the baseline, for lorries, it is expected that 101.000 tons of material are 
lost due to missing traceability and 100 000 tons due to Extra EU export. With the current 
prices for recycled materials (and assuming 100% recycling), this adds to 35,5 million Euro 
for  the  lost  material  due  to  missing  traceability  and  another  35,0  million  Euro  for  the  lost 
material of exported lorries (Table 6-15 and  

Table 6-16, Annex I). 

The average number of exported trailers is known (see above), assuming a typical 
vehicle weight of 5820 kg (Annex I, Table 6-8), the weight of the exported trailers 
can  be  calculated  to  440  000  tons  per  year.  This  is  slightly  less  than  half  of  the 
weight of exported lorries. Whether prices for exported trailers are comparable to prices for 
lorries is not known, so we cannot conclude that half of the weight is half of the revenue. Also, 
the distribution of different types of trailers and their material composition is not known, there 
is also a lack of knowledge in relation to trailers of unknown whereabout in the EU, and it is 
assumed that extrapolating the number of missing vehicles from passenger cars to trailers 
does not give the right picture. 

No data is available as to assess this situation for PTW. 

In Option A and Option B, no change in the baseline is expected. The introduction of a CoD 
(B3)  will  probably  help  to  build  the  base  for  additional  measures  (C4  and  C5)  providing  a 
monitoring indicator, but introduction of B3 is expected to not change the situation as such.  

Option C is the policy option that has influences on the above-mentioned markets. Especially, 
measures C4 and C5 will support in reducing the tons of material from missing vehicles and 
increase  the  amount  of  material  from  ELVs  treated  in  the  EU.  However,  it  is  unlikely  that 
measures  under  option  C  influence  the  revenues  in  such  a  way  that  the  money  currently 
earned from the export of used vehicles (calculated in the baseline, i.e., 4.1 billion Euro per 
year for used lorries) leads to a higher profit for the EoL stakeholders to the same extent. At 
the same time, it is unlikely that the potential profits calculated above in the scenario that the 
exported  and  missing  vehicles  were  recycled  in  Europe  today  (for  lorries,  in  the  baseline 
calculated  to  ~10%  of  the  revenue  from  export  of  used  vehicles),  would  reflect  the  actual 

329 No priced for recycled iron, rubber and other waste included. 

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profits  at  the  time  of  the  introduction  of  Option  C.  There  are  many  reasons  for  this:  For 
example, the prices of secondary raw materials are expected to change over time, and the 
prices that can be obtained when exporting vehicles are expected to change as well. First 
signs of a change in the export market are visible, e.g., slightly decreasing export volumes, 
more restrictive import laws in African countries, statements like the one from Renault quoted 
above, or changes in the social perceptions in relation to material consumption overall. It is 
also  unclear  how  the  total  vehicle  fleets  would  behave  if,  for  example,  whether  an  export 
restriction would lead to (even) more repairs. Overall, impacts of measures of Option C are 
highly uncertain. 

Competitiveness & development of the internal market incl. treatment capacities 

It  is  assumed  that  reporting  requirements  (Option  A)  result  in  an  increase  in  the 
competitiveness  based  on  additional  information  (A1),  however,  this  affects  mainly 
dismantlers and recyclers, to a certain extent, but not shredders. Measures in Option A will 
probably  do  not  have  an  effect  on  the  existing  capacities  of  dismantlers,  recyclers  or 
shredders, or create changes in the market.  

Option  B  (measure  B2  ATF)  introduces  the  legal  difference  between  informal  and  formal 
dismantlers, this will have an influence, the level of the effect is however unknown. As the 
same requirements apply to all parties, the provision shall not create unfair competition, but 
ATFs  will  have  to  compete  against  the  businesses  of  informal  dismantlers  with  less 
administrative  burden  and  less  requirements  to  the  dismantling.  Also,  in  Option  B,  the 
requirement to be dismantled in ATFs requires providing the capacities for the treatment in 
authorized  facilities. In  total,  this  option  is  expected to  have  high  influences  on the  market 
situation as a total, especially for PTW, where it is expected that no ATFs exist compared to 
lorries (at least in some MS). 

For the treatment capacities for PTW, due to the unclear general situation of EoL 
treatment,  it  is  unclear  whether  investments  in  “new”  PTW-specific  ATFs  are 
required or whether current capacities for cars and vans can cover the dismantling 
of PTW given that only few are expected to be dismantled but repaired or used as 
‘spare parts depot’. A participant of the workshop warned that distances between ATFs might 
pose a problem in terms of availability and accessibility for the general public: ‘We would need 
to consider the geographical distribution of ATFs. It would not be economically viable to place 
ATFs in many places and this would affect consumers who need to dispose of an ELV’, FIM 
- Chris Hodder (Workshop 2022). A statement of ACEM (2021) speaks against the existence 
of such a problem explaining that ‘in the pre-treatment, thus depollution (battery and hydraulic 
oil, cooling fluid,…), there is no difference to cars. The same processes are used except for 
what does not exist in motorcycles (climate fluid, washing, …). In a recycling and dismantling 
centre  in  Munich,  cars  and  motorcycles  are  dismantled  with  the  same  processes.’  The 
consultant assesses the investment needs in PTW-specific ATFs rather low, but the additional 
material volumes to be expected at general (car & van) ATFs cannot be assessed.  

If  trucks  were  included,  the  Czech  Ministry  of  Environment 
(2021) sees “problems in their size and different composition 
of  materials”.  On  the  other  hand,  from  the  interview  with 
ANERVI/AETRAC, it has become clear that in Spain there are lorry-specific ATFs that are 
authorized and can also treat trailers. Depending on whether this is the same throughout the 
EU,  an  ATF  requirement  with  the  issuing  of  CoDs  (measures  B2  &  B3)  will  not  have  a 
significant impact on the market or its competitiveness. The situation for buses is unclear. 

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In Option B, for recyclers and shredders, the market could slightly change, however, as ELVs 
are only one input stream for recyclers and shredders, expected effects are only marginal.  

High  effects  are  expected  in  Option  C.  Changes  to  design  may  affect  recyclability.  In 
comparison  with  competitors  from  extra  EU  markets,  a  positive  effect  is  expected  for 
European dismantlers and recyclers. At this point of time, the measures C2 and C3 are not 
yet fixed in the sense that no target values for any 3R targets nor recycled content targets, 
and no decision on requirements on non-recyclable materials etc. exist in general, especially 
not for vehicles that could possibly enter the scope of the legislation, so the extent of such a 
positive effect cannot be assessed.  

It is also not clear how exactly measures C4 and C5 will be designed, however, what is clear 
is  that  both  measures  would  have  a  high  impact  on  the  number  of  ELVs  to  be  treated  in 
Europe. In the extreme case of an export ban, this number increases to 35% more lorries, 
20% more buses and about 75,000 trailers per year. A more detailed analysis can be found 
in  Annex  I,  section  6.10.2.  In  addition,  there  would  be  more  vehicles  whose  whereabouts 
would  be  clarified,  and  which  would  be  submitted  to  a  formalized  EoL  treatment.  This 
increases the input, may require additional capacity and possibly strengthens the business of 
dismantlers,  recyclers  and  shredders.  Whether  the  additional  revenue  from  such  business 
operations can cover the additional investment costs cannot be said because the number of 
volumes treated in the EU is unclear. Then, dependent on the details of the arrangement, an 
EPR (measure C6) could lead to a complete change of the business whereas the aim of an 
EPR is of course not to generate more profit for the waste operators per se but to off-set their 
costs when they exceed a certain limit. It can be assumed that the waste operators could be 
given more to do, for which they would also be paid accordingly. This means they would have 
to remove and/or recycle components that they have not removed so far because it was not 
economically viable for them to do so. However, the new legislation could require such work 
potentially financed by EPR fees that manufacturers pay.  

Effects on SMEs 

Small  and  medium-sized  enterprises  (SMEs)  are  expected  to  be  mainly  engaged  in  the 
dismantling;  however,  the  exact  structure  of  the  business  sector  is  unclear  for  all  vehicle 
categories.  As  pointed  out  in  relation  to  SMEs  that  are  working  in  the  manufacturing  of 
vehicles,  the  main  administrative  costs  burden  SMEs  proportionally  more  than  large 
companies.  In  result,  Option  A  is  a  high  burden  for  SMEs.  Option  B  also  involves 
administrative  costs related to  the  knowledge  management  of  the  restricted  heavy  metals, 
however,  dismantlers  engaged  in  car,  e.g.,  relevant  for  the  dismantling  of  PTW,  know  the 
procedures and “their” materials that are to be dismantled mandatorily. For lorries and trailers, 
ATFs already exist today. Option B therefore does not imply much more additional effort for 
SMEs than option A. As well addressed in the section on SMEs working in manufacturing of 
vehicles, the impacts of Option C are unclear. Because the PTW, lorries, buses and trailers 
sectors claim themselves already circular in relation to reusability for example, it is possible 
that SMEs' businesses may not need to change incredibly. But that is speculation at this point. 

3.4.4.3.3  Administrative burden for public authorities 

It is noted that all options inhibit administrative burden for public authorities. It is the nature of 
the extension of the scope which is part of all proposed policy options.  

The following is assumed for national public authorities: In Option A, measures A2 (reporting 
on  ELV)  and  A3  (one-off  reporting)  would  result  in  burden  for  Member  State  authorities: 
Actions related to measure A2 need to be reconciled with the current reporting process for 

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ELVs330 and potential decisions for cars and vans (Measure “Improve reporting obligations 
on the current vehicle market and the ELVs on their territory”, chapter 2.2.5.1.9). Some MS 
have started statistical data collection, for example, Spain included differentiated waste codes 
for different vehicle types in October 2021.331  

Yearly costs are estimated to 2.779 Euro332. The reporting obligations for end-of-life treatment 
of possibly additional vehicles in scope (A3) will require a one-off investment from MS for conducting 
the  reporting,  as  gathering  information  via  the  3R  type-approval  legislation,  e.g.,  on  the  intended 
recyclability rate of a new vehicle type, is not possible. These are calculated to add up to 38.910 Euro 
in total333. For a quantification, see Nr. 4 & 5 of  

Table 6-17 (Annex I).  

In  Option  B,  for  collection-related  requirements,  e.g.,  ATF  treatment  and  CoD,  administrative 
burden  dan  be  expected  for  national  public  authorities,  i.e.,  more  inspection/enforcement 
campaigns. Costs for such additional work in relation to cars and vans are expected to be 20 cents 
but  not  more  than  1  Euro  per  new  M1  or  N1  vehicle  registered334  (see  the  calculation  in  chapter 
3.2.5.9). Taking into account that 15% (per unit) of vehicles are not in scope today and assuming the 
identical additional share for ATFs might be required for the dismantling of PTW, lorries, buses and 
(semi-)trailers, this results in a number 4.500 ATFs being required for vehicles other than M1 and 
N1335.  Applying  the  same  efforts  (3  working  days  with  27  €  labour  costs),  checking  10%  of  the 
(additional) ATFs would account for ~ 300 000 € for the entire EU + plus reporting to the EU (measure 
A2). Registration data for lorries and trailers is only available for 2012 which is considered not recent 
enough to conclude on the costs per vehicle. For the overview of administrative costs,  

Table 6-17 (Annex I). 

In Option C, more administrative efforts associated with 3R type approvals (measure C1), 
including  enforcement  and  compliance  checks  with  3R  targets  (measure  C3),  design 
requirements  (measure  C2)  etc.  information  on  costs  for  such  type-approvals  for  national 
authorities from 3R type-approval Evaluation is non-disclosed. In addition, measures C4 and 
C5 inhibit costs for advanced traceability and for custom services of MS to control EU exports.  

330 The current Commission Decision (2005/293/EC 2005) requires the Member States to complete the tables 1-4 and to report 
in addition on “the current national vehicle market and the end-of-life vehicles on their territory”. This last aspect is detailed in 
a Eurostat guideline which is not legally binding. 

331 While 160104* is the EU waste code for ELVs331, in Spain, there are 160104*-10 (cars, vans) and 160104*-20 (other 
vehicles) Real Decreto 265/2021, Anexo VIII Codification Ler-Veh331 
332 Two days work assumed. MS already report on M1 and N1 ELVs, the format can be the same for 

other vehicles, thus, 75% of the costs occur in the baseline. For a quantification, see Nr. 4 & 5 of  

Table 6-17 (Annex I). 

333 Assuming seven days of work in 27 MS for four different vehicle categories. For a quantification, 

see Nr. 4 & 5 of  

Table 6-17 (Annex I). 

334 Based on the assumption of 10% of the ATFs being checked per year, assuming ~30.000 ATFs in EU, 3 full day effort for  
an inspection and average EU labour costs of 27€, and then the costs were allocated to almost 11 million newly registered 
cars (2019-2021). 

335 Assumed elsewhere for M1 and N1: 11 000 ATFs and 2 times more other facilities relevant for inspection 

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Administrative  burden  for  the  European  Commission  results  from  all  options  as  well.  In 
Option A, the EC has to provide its services from Eurostat for the reporting on the fleet, but 
if the format is not different from the cars and vans, the additional costs are estimated to be 
rather low. In Option A, a reporting format for MS has to be developed and the reports of MS 
on  the  EoL  of  the  vehicles  have  to  be  received  in  order  to  decide  next  steps  for  further 
regulation (or not) based on this. The benefit of such reporting is that information is provided 
by those stakeholders that have the best overview, though, it requires the responsibility of a 
central body with cross-sectoral expertise in circular economy that can create linkages or use 
examples from other sectors, to come to a better-informed choice. There is the risk for public 
authorities  that  OEMs  &  ATFs  cannot  provide  proprietary  information,  or  the  information 
provided may not cover relevant questions identified. In Option B, the EC incurs costs due 
to  possible  exemption  requests  for  the  hazardous  substance  (heavy  metals)  restrictions. 
Since it is expected that the process will be the same for all vehicle categories, there is no 
need to devise the format of exemption requests specifically for other vehicle categories.  

In Option C, the impact of the measures on the EC cannot be estimated, however, it can be 
pointed  out  here  that  if  general  measures  for  cars  and  vans  coincide  with  those  for  PTW, 
lorries, buses and trailers (though different target values might be agreed), costs will not be 
significantly greater than for a revision of the measures for cars and vans (circularity, 3R type-
approval, traceability, export, EPR; see the impacts for "circularity" and "missing vehicles" in 
the chapters before). The baseline with no extension of scope has the risk of additional costs 
in postponing the decision, e.g., resulting from additional personnel costs for organisation of 
stakeholder dialogue, and one regulation revision process is considered more time-effective 
than bringing up the ELV legislation again in the (near) future. 

3.4.4.3.4  Distributional effects (economic) 

One economic distribution effect comes into play in Option B (B1 Heavy metal restriction., 
B2 ATF & B3 CoD) and Option C (C4 advanced traceability & C5 export restrictions) which 
is  the  internalization  of  external  costs.  Internalizing  environmental,  e.g.,  resulting  from 
unformalized  treatment  (see  above),  and  health  costs,  e.g.,  resulting  from  hazardous 
substances  (see  below)  means  charging  them  to  the  polluters  ("polluter  pays  principle"). 
Currently, there are no sufficient economic incentives to reduce environmental pollution. This 
is a market failure ("misallocation") and an "externalization of these costs". Looking at Option 
A, not such a distribution effect will occur, as internalization of costs means actually paying 
the  costs.  Information  and  reporting  instruments  alone  do  not  lead  to  internalization.  In 
relation to Option B 

The strongest distribution effect is expected to result from a potential measure C6 in Option 
C: The EPR will shift costs that carry recyclers today to manufacturers, in relation to EPR for 
PTW, lorries, buses and (semi-)trailers, the costs are discussed in section 3.4.4.3.1 in relation 
to manufacturers and in section 0 in relation to benefits for recyclers. 

3.4.4.4  Impacts  on  stakeholders  in  the  field  of  vehicles  that  are 
currently  exempted  from  ELVD  or  3R  Directive  and 
impacts resulting from discrepancies between the scope 
of 3R Directive and ELVD  

This  chapter  deals  mainly  with  multi-stage-built  vehicles,  small  series,  special-purpose 
vehicles and new and reused components for vehicles, which are either explicitly in the scope 
of the 3R Directive or explicitly excluded. As explained in the evaluation of the 3R Directive 
in  Annex  II,  scopes  of  3R  Directive  and  ELVD  are  not  similar.  Currently,  multi-stage-built 

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vehicles, small series, special-purpose vehicles336 are excluded from the 3R Directive while 
new and reused components of M1 and N1 vehicles are part of the scope of the 3R Directive.  

At this point it must be explicitly mentioned that all policy options intend to extend the scope 
of  the  ELV  legislation  and  3R  Directive:  The  definition  of  the  policy  options  envisages  the 
inclusion for all L-, M-, N- and O-type-approved vehicles. First of all, this means that the policy 
options foresee the inclusion of multi-stage-built vehicles, small series and special-purpose 
vehicles  in  the  scope  of  the  new  ELV  legislation.  This  is  different  for  the  new  and  reused 
components that are not covered by the policy options, though they are in scope of the 3R 
Directive. 

The Table 3-84 names the various impact indicators for which the assessment was needed, 
if  a  proper  evaluation  of  what  the  measures  in  the  policy  options  have  as  an  impact  on 
stakeholders in the field of vehicles that are currently exempted from ELVD or 3R Directive: 
Administrative burden for authorities, mainly type approval authorities and technical services 
(can  be  authorities  or  non-authorities),  administrative  burden  for  business  operators, 
manufacturers specifically, costs for OEMs for change of design, and competition effects.  

It  is  anticipated  that  the  impacts  of  Option  A,  at  least  measures  A1  and  A3  would  be 
acceptable for the multi-stage-built vehicles and the special-purpose vehicles. It may not be 
proportionate for the small series. Option B could cause problems with regard to the heavy 
metal  restrictions,  e.g.  for  some  special-purpose  vehicles,  but  in  ELVD,  there  is  the 
mechanism of exemptions, so that they could be exempted from the necessary restrictions 
after evaluation of an exemption request. For the evaluation of the impact of the reporting on 
ELVs (A2) and the measures B2 (ATF) and B3 (CoD), too little is known about their current 
EoL treatment to be able to assess the advantages or disadvantages of such measures. 

Some  comments  at  the  stakeholder  workshop  dealt  with  the  multi-stage  built  and  special 
vehicles, especially with regard to the definition of possible 3R targets, i.e., Option C: E.g., 
‘please consider the special purpose and multi-stage vehicle, such as motorcaravans, when 
expanding the scope. The base vehicles are already subject to the requirements of ELV and 
3R  and  fulfil  the  requirements.  Including  special  purpose  vehicles  would  not  bring  any 
improvement with regard to the aims of ELV or 3R. The bodywork of the habitation area is 
dismantled separately and sent to waste management. The exemptions [from scope] are still 
urgently needed’ (Caravaning Industrie). One participant spoke about the challenges of 3R 
targets for wheelchair-accessible vehicles (OECVA) and ACEA added that they had provided 
info regarding the complexity of multi-stage type approval for HDV earlier. As described by 
stakeholders  and  earlier  in  relation  to  the  various  impacts  discussed  above,  Option  C 
appears to be associated with high uncertainties in the impacts for manufacturers of multi-
stage-built vehicles, small series, and special-purpose vehicles. 

Motorcycle  manufacturers  point  out  spare  parts  that  are  in  the  scope  of  the  3R 
Directive. ACEM (2021) says that “based on a requirement that spare parts need 
to be provided up to 15 years after production, motorcycles will need exemptions 
for spare parts for type approved vehicles already produced. The design for new 
parts is expensive especially for low volumes. This leads to the risk that material changes for 
spare parts would not be realised.” 

336 Special purpose vehicles are generally exempt from the 3R Directive too, however, they are as per EC guidance document 
in scope of ELVD, but exempt from Art. 7 provisions of ELVD. 

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Other than that, six written contributions to the OPC focus on historic cars: Current practice 
of exempting historic cars (due to small series) should be pursued. 

3.4.4.5  Social impacts 

Most of the measures in the policy options are not intended/invented to have a direct impact 
on aspects of the society, except for health benefits associated with formalized treatment and 
heavy metal restrictions. Rather, the measures increase the administrative efforts or change 
the  market  situation  in  a  way  that  jobs  and  the  general  public,  here,  vehicle  owners,  are 
effected, meaning that they are side effects.  

3.4.4.5.1  Jobs 

As  for  social  impacts,  mainly  distributional  effects  are  expected,  this  means  that  to  some 
extend jobs will be transferred from informal to the formalised sector, however, in most of the 
EU countries ELV other than M1 and N1 are treated under general conditions of the WFD. 

As  for  social  impacts,  mainly  distributional  effects  are  expected,  this  means  that  to  some 
extend  jobs  will  be  transferred  from  informal  to  the  formalized  sector,  this  is  the  case  for 
measures B2 and C4 & 5. However, in many EU countries ELV other than M1 and N1 are 
treated under general conditions of the Waste Framework Directive. Thus, assuming that the 
jobs  are  in  the  formalized  sector  already,  the  number  of  jobs transferred  to  the  formalized 
sector is marginal.  

It  is  expected  that  new  jobs  are  only  created  in  case  of  Option  C,  when  measures  were 
introduced to ban the export and to stop the existence of unknown whereabout, and when as 
a consequence the numbers of ELVs to be treated in the EU increases drastically. On the 
other hand, it is expected that none of the measures reduces the numbers of jobs in the sector 
in a way that is different from development in numbers of jobs in the baseline, where, e.g., 
through automatization in vehicle production, a (continuation of the) reduction in jobs can be 
expected. 

3.4.4.5.2  Health  benefits  from  formalized  treatment  and 

heavy metal restrictions 

Lead is the predominant heavy metal for which exemptions under ELVD are still 
allowed,  see  especially  the  exemption  for  lead  as  an  alloying  element. 
Hexavalent chromium might be used in corrosion preventive coatings in 
components presumably for trucks etc. It is assumed that Cd and Hg are 
rarely  used.  For  this  impact,  examples  for  the  damage  costs  from  lead  in  waste 
buses and motor scooters are calculated showing the impacts for the baseline: Lead is mainly 
in the batteries of vehicles (lead-acid batteries) but also as an alloying element in steel, thus, 
it is expected that the higher the steel content in a vehicle, the higher the lead content (not 
taking  into  the  battery).  From  Table  3-92  it  is  clear,  that  the  lead  indicated  in  the  material 
composition data for this specific motor scooter can be allocated fully to the battery – or lead 
in steel (at least steel content in this model is ~50 kg) – was not specifically indicated. In the 
case  of  buses,  the  share  of  lead that  can  be  allocated to  the  battery  is  just  over  one-third 
(Table 3-92). Another use of lead in larger vehicles, such as the buses, lorries and trailers are 
lead weights as balance correction weights. These used to be installed next to the tires, but 
it is expected that in such uses, lead has been replaced by other materials in recent years. 

Without taking into account the lead incorporated in the batteries, the amount of lead in waste 
buses in 2025 in the EU is expected to be ~2600 tons (Table 3-92, 7th line). Assuming an 

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efficiency of industrial emission control systems in shredders and recycling plants of 99,9%, 
the amount of lead that might be emitted from bus recycling in 2025 is 2,6 tons. Nedellec and 
Rabl (2016) calculated the costs for mortality and IQ losses per kilogram lead based on oral 
ingestion and inhalation of Pb compounds under typical conditions in Europe. The amount of 
damage costs for industrial emissions in the EU account for 29 343 € per kg Pb. The damage 
costs  for  emissions  from  treatment  of  waste  buses  for  the  year  2025  could  be 
77,5 million €.  

Table 3-92 Lead in waste buses and motor scooters in 2025 and related damage 
costs 

Midibus 
(12t GVW)  

Coach  (19t 
GVW) 

Motor  scooter 
50 cm3 engine 

Total weight [kg] 

8050 

13400 

93,62 

Total lead content [kg] 

90 

156 

0,82 

Lead % 

Lead (in batteries) [kg] 

1,12% 

1,16% 

0,88% 

34,5* 
(2 batteries assumed) 

0,86 

Lead in other materials 

55,5 

121,5 

Expected no. of waste vehicles in 2025 

28 061 

Lead in ELVs (without battery) in 2025** [kg] 

 828.662  

 1.814.003  

Possible  emissions 
(99,9% 
efficiency of industrial emission control systems) [kg] 

from  EoL 

treatment 

 829  

 1.814  

Damage costs in € in 2025 

77.543.743 

0 

0 

0 

0 

0 

(*) For buses, one battery à 30 kg with a lead content of ~25% lead (Pb) and ~35% lead oxide (assumed PbO) contains 17,25 
kg lead. For the scooter, battery weight is ~1,5 kg with the same lead content assumed, this results in 0,86 kg. 
(**) assuming that the waste buses are equally divided between midibuses and coaches. 
Source: Ricardo-AEA (2015) for buses, Ecoinvent for motorscooter, Nedellec and Rabl (2016) for damage costs. 

This  impact  is  not  a  pure  environmental  impact  but  rather  relates  to  human  health,  and 
implementation is rather an economic question, as the calculated damage costs need to be 
compared  to  costs  for  implementing  substance  restrictions.  From  stakeholders,  no 
information  was  obtained  as  to  the  costs  for  applying  for  exemptions  or  possible  re-
arrangements of supply chains in order to supply parts and components that do not contain 
the substances that are restricted. Stakeholders are of the opinion that current heavy metal 
restrictions cannot apply one-to-one to other vehicles but need their own evaluation (Karsten 
Kurz  –  Exide  Technologies),  more  generally,  stakeholders  call  ‘to  have  category  specific 
annexes  II’  (G.  Gehlisch,  Jörg  Kleffner  ACEM,  Karin  Alenius  –  ACEA).  In  addition  to 
exemptions  for  full  vehicles,  one  stakeholder  suggested  that  ‘exemption  on  the  substance 
restrictions for spare parts’ were needed ‘in order to not endanger longevity of buses, HDV, 
motorcycles and all other vehicles.’ (Dennis Eggeling, Vitesco) 

Comparison of the options (relevant measures B1, B2, C4 & C5):  

In option A, the heavy metals restrictions do not apply for vehicles that enter the scope, this 
means  that  damage  costs  remain  the  same  as  in  the  baseline.  At  the  same  time, 
manufacturers do not have additional costs for re-organizing suppliers, nor does the authority 
has costs in implementing the provision, e.g., commission consultancies in order to evaluate 

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exemption requests. In Option B & C, the heavy metals restriction does apply, for society, this 
means  that  the  expected  damage  costs  can  be  saved,  however,  manufacturers  will  have 
costs for supplier management and costs for applying for exemption mechanisms, authorities 
will have costs for studies to evaluate exemption requests and market surveillance. 

 PTW have different requirements for materials used, e.g., as materials are exposed 
to  weathering  directly,  longer  lifecycles337,  different  operating  conditions  (e.g. 
temperatures, vibrations, wetness, dirt etc.), higher technical characteristics (e.g. 
revolution speed of engine). ACEM (2021) says, ‘implementing new material restrictions is 
not  easy  and  motorcycle-  specific  exemptions  and  transition  times  are  needed.  There  are 
some synergies with cars in terms of the prohibited substances – some few suppliers are the 
same but most of the suppliers are different and often very small. Changes made for cars 
have not always been introduced for motorcycles’.  

3.4.4.5.3  Impacts for vehicle owners  

Option A doesn’t have any impact for vehicle owners in all vehicle categories.  

Private vehicle owners would mainly be affected from an inclusion of PTW into the 
ELVD. In the first place, in Option B and C, additional burden is associated with 
the management of (de-)registration and administrative efforts when the vehicle of a vehicle 
owner becomes an ELV. Then, the private should bring his ELV to an ATF and receive the 
CoD (Option B) or has additional efforts in relation to possible advanced traceability measures 
(Option C). Likely occurring in Option C, another aspect of additional burden for consumers 
might  be  potentially  higher  costs  for  new  vehicles,  e.g.,  ACEM  (2021)  says  that  ‘cost 
implications  are  foreseeable  and  might  be  a  challenge  for  producers  of  motorcycles 
(especially  those  with  small  production  volumes).  It  is  not  clear to this  date  whether these 
costs  would  affect  the  final  price  of  the  vehicle.’  Also,  in  relation  to  PTW,  spare  parts 
availability/accessibility  or  possibilities  for  informal  repair,  which  some  consumers  might 
perceive as an easy, quick and ‘unbureaucratic’ option, might be affected from measures in 
Option B (mainly the ATF requirement) or Option C, mainly C4 (advanced traceability) but 
also C3 (3R targets) might have an effect. For impacts from restricted exports and managing 
the vehicles of former unknown whereabout, it is unclear whether this could make selling an 
ELV more difficult or easier. 

In the sectors of lorries and trailers, businesses are expected to be the 
main  costumers.  Impacts  from  amendments  of  the  (de-)registration 
procedure (Option B) are assessed to be less substantial than for privates 
and their PTW. Reasons are that lorries and trailers are already treated in ATFs in some MS, 
e.g., in Spain, so businesses are familiar with registration procedures and ATFs. Then, the 
probability  is  high  that  a  business  does  not  only  own  one  vehicle  but  has  a  fleet  for  own 
transportation purposes or for providing lorries and/or trailers for leasing. In the latter case, 
the number of vehicles owned might even be higher. It is expected that the higher the number 
of vehicles owned, the less (administrative) effort is expected. In relation to measures under 
Option C, impacts on lorry and trailer owners might be the following: It is unclear how the 
acquisition costs for lorries could change if major changes have to be made in the material 

337 ACEM (2021): “15 years; cars’ lifetime is 11.5 years, thus, at least 4 years difference which means that Motorcycle ELVs 
are elder than car ELVs and will therefore longer contain SVHC materials which are not yet banned for motorcycles. As 
consequence residual amounts of SVHC due to recycling have to be tolerated (e. g. lead in aluminium alloys) for the use of 
quality-assured secondary materials” 

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selection  to  increase  recyclability.  As  a  consequence,  depending  on  changes  in  material 
composition, this could result in higher fuel costs in the use phase. It is then expected that 
the business segment is profiting from formalized spare parts market and repair services. For 
impacts from restricted exports and managing the vehicles of former unknown whereabout, it 
is unclear whether this could make selling an ELV more difficult or easier. 

Compared to the companies that own lorries and trailers, businesses operating or 
providing  buses  for  leasing  are  considered  smaller.  Here,  even  SMEs  might  be 
affected,  e.g.,  bus  service  providers  for  group  travelling  might  for  example  operate  their 
business with five to a dozen of vehicles. For such entrepreneurs, the administrative effort 
associated  with  bringing  ELVs  to  ATFs  (Option  B)  might  be  higher  than  for  lorry  owners, 
however, longevity of buses result in one bus of the fleet of the bus service provider arriving 
at EoL, e.g., every 10 years, and probably, bus service providers are possibly organized in a 
business association that could provide guidance for managing ELVs. In Option C, probably, 
impacts for owners of buses are similar to lorries and trailers in relation to vehicle acquisition 
costs  due  to  recyclability  requirements  (measures  C1  &  C2),  for  unclear  impacts  on  fuel 
consumption  in  use,  for  probably  more  transparent  and  possibly  more  easily  accessible 
availability of spare parts (C3), and for avoided exports (C5).  

3.4.4.5.4  Comparison of the options 

The five identified problems resulting in the analysis of an extension of scope of the ELVD 
are (1) that the potential to contribute to the CE of a large share of vehicles is not exploited 
yet,  (2)  as  for  cars  and  vans,  traceability  for  vehicles  not  in  scope  of  ELVD  is  not 
given/missing,  export  volumes  of  used  vehicles  are  high.  (3)  For  vehicles  not  in  scope  of 
ELVD,  there  is  no  legal  incentive  to  design  for  circularity,  (4)  the  current  legal  setup  is 
insufficiently harmonized across the EU, and (5) discrepancies were identified in the scopes 
of  ELVD  and  3R  Directive.  And  to  add,  (6)  problems  are  expected  to  increase  due  to  an 
expected increase of the total amount of vehicles.  

While of the above-mentioned problems, those numbered 3, 4 and 6 are equally relevant to 
all vehicle categories, in terms of problems numbered 1, 2 and 5 the most important aspects 
for different vehicle categories are: 

PTW:  

•  The  contribution  to  circular  economy  is  expected  high  in  terms  of reuse, but 
uncertainties  exist  for  other  EoL  routes  and  related  stakeholders,  incl.  their 
market shares, applicability of environmental standards, illegal operations, etc.;  
the legislation is insufficiently harmonized;  

• 
•  missing vehicles and export of used vehicles cannot be quantified. 

Lorries:  

•  The  lack  of  control  on  extra-EU  export  (~74%  of  expected  ELVs)  and 
transboundary shipment of ELVs within the EU, mainly because EVLs do not 
have to be reported by the MS;  

•  There is a lack of knowledge about EoL material flows;  
•  The use of lightweight, non-recyclable materials is probably relevant;  
•  The discrepancy between the scopes of ELVD and 3R Directive for lorries, being mainly 

multi-stage built vehicles, is relevant.  

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Buses:  

•  Lack  of  export  control  is  probably  a  considerable  problem,  though  in  smaller 

range as for vehicles for transport.  

•  Probably weight reduction plays a role, but details are not known.  
• 
It can be assumed that the circularity potential is not exploited. 

(Semi-)Trailers:  

•  There is a large mass of materials from trailers for which there is currently no 
information  available  on  their  end-of-life  (and  for  their  design).  It  is  therefore 
unclear whether the CE potential is exploited, where the levers for the CE lie, or whether 
there are problems with inadequate treatment.  

Market  and  regulatory  failures  drive  the  problems.  It  is  perceived  an  option  to  tackle  the 
problems associated with vehicles in general in a (revised) ELV legislation. The related main 
objective  is  to  ensure  a comprehensive  coverage  of the sustainable  production  and  waste 
management at EoL (dismantling, sorting, reuse, recycling, recovery, disposal) of all relevant 
vehicles  by  the  ELV  Directive.  Thus,  when  ELVD  is  aiming  at  the  promoting  a  circular 
approach  in  the  production  and  end-of-life  treatment  of  vehicles  and  that  all  vehicles  are 
collected and recycled, the objective is to ensure the promotion of circularity and collection & 
recycling for vehicles currently outside of the scope of ELVD as well.  

As the problems for PTW, lorries, buses and (semi-)trailers were found to be similar to those 
of cars and vans, the extension of scope to PTW, lorries, buses and (semi-)trailers has been 
considered  and  assessed  together  with  different  sets  of  requirements:  A  set  of  reporting 
obligations (Option A), reporting obligations and some requirements currently in place for M1 
and N1 vehicles (Option B), and an application of the full set of requirements that are under 
consideration for M1 and N1 as part of the IA as well. 

The comparison of the options is provided in a tabular format on the next page: Table 3-93. 

3.4.4.6  Efficiency, effectiveness, and coherence 

As  all  three  options  include  that  the  scope  of  the  legislation  shall  be  expanded,  however, 
under each option, a different set of requirements shall be set. Thus, the effectiveness, i.e., 
the extent to which the options may achieve the objective is coupled with the requirements 
which  shall  apply  for  the  different  vehicle  categories.  While  Option  A  is  supporting  the 
objective through providing additional information to decide what may be “a comprehensive 
coverage”, Option B is already targeting specific production and EoL management steps, e.g., 
the heavy metal restrictions are a design requirement allowing better sorting of hazardous 
waste. Then, Option C, is expected to fully support the objective, provided that the ambition 
level and targets of the measures will be formulated and worked out in a way that isn’t contra 
productive, e.g., high recycling targets while reuse is highly relevant. 

The  efficiency  describes  the  cost-benefit-ratio.  For  Option  A,  high  costs  are  expected  for 
OEMs, ATFs, incl. SMEs, and Member States which are not connected with direct benefits 
except  for  a  potential  small  increase  of  benefits  from  circularity  when  dismantlers  and 
recyclers know better the composition, location and hazardous substances contents. Thus, 
this  option  is  considered  highly  inefficient.  In  Option  B,  compared  to  Option  A,  though 
additional costs occur for various stakeholders, costs are probably not so much higher, but 
benefits  are  expected  from  heavy  metal  restrictions  and  formalized  treatment.  Finally,  in 

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Option C, it was identified, that measures cause high costs, which are not quantifiable, and 
unclear benefits (too many unknowns). 

In terms of the coherence of the options with overarching objectives of EU policies, all of the 
three options contribute to the goals set out in the Circular Economy Action Plan (European 
Commission  2020a).  The  lack  of  knowledge  is  greatly  affecting  authorities  in  fact-based 
decision  making  in  relation  to  measures  to  take  in  line  with  political  priorities.  In  terms  of 
individual  legislative  initiatives  and  existing  regulation,  relevant  legislations  to  ensure 
coherence with are REACH, the general type approval and 3R Directive specifically. It was 
identified that in the case of a change in the scope of ELVD without parallel changes in the 
scope  of  the  3R  Directive,  3R  Directive  cannot  be  used  as  a  means  to  further  implement 
additional  requirements  in  relation  to  measures  to  support  design  for  circularity.  As  a 
consequence, the regulator loses its mechanism to check compliance of design requirements 
supporting the ELV treatment. For chemical legislation, it should be avoided to have multiple, 
possibly contradicting requirements of different legislations for the same substances with the 
same scope (see this aspect covered under the aspect of hazardous substances specifically).  

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Materials available for reuse 
and recycling 
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Table 3-93 Comparison of the options for main objective 1  

Option → 

A 

B (+A) 

C (+B +A)  

A1 Info 
for 
recyclers 

A2 ELV 
reporting 

A3 EoL 
report 

B1 Haz. 
Subst. 

B2 ATF 

B3 CoD 

C1 3R TA 

C2 
D4CE 

C3 
3R 

C4 
trace. 

C5 
export 

C6 
EPR 

0 

n.a. 

Benefits from 
heavy metal 
restrictions 
(+++) 

0 

Benefits 
from 
formalised 
treatment 
(++) 

0 

+++ 

+++ 

n.a. 

Indirect  
(no data) 

Economic impacts for vehicle 
manufacturers 

Costs for providing information to 
recyclers and for the one-off EoL 
report 

Impacts for stakeholders 
affected from scope 
discrepancies between 3R and 
ELV Directive [1] 

Economic impacts for EoL 
stakeholders 

Costs for providing information 
for ELV reporting and one-off 
EoL report 

Costs in 
change of the 
design, 
administrative 
costs 
(- -) 
Costs in 
change of the 
design, 
administrative 
costs  
(- - - ) 

n.a. 

n.a. 

n.a. 

Authorization 
process  
(no data) 

Administrative 
burden 

Supply chain 
management; 
costs for 
changing the 
design,  
might apply 
for 
exemptions, 
if needed. 

Minimal 
benefits for 
management 
of less 
hazardous 
waste 

Economic impacts for SMEs 

Higher costs compared to bigger 
companies 

Higher costs compared to bigger companies 

(no data) 

(no data) 

(no data) 

(no 
data) 

510 

Benefits 
from 
increased 
circularity, 
e.g., less 
resources 
consumed 
associated 
with less 
CO2 
emissions  
Costs in 
change of 
the design, 
competition 
effects  
(0 to - -) 
Costs in 
change of 
the design, 
competition 
effects 
(0 to - - -) 
(- - - to 
+++) 

0 

n.a.  

 (- to 
- - -) 

 Benefits from 
vehicles 
formalized 
treatment, no 
leakage of 
hazardous 
fluids or less 
exhaust gas 
emissions 
from recycling 

n.a. 

(- - - to +++) 

(+ to 
+++) 

 
 
  
 
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Option → 

Administrative (economic) 
burden for public authorities 
(MS + EC or MS/EC only) 

EC for 
providing 
the 
concept 
(--) 

A 

MS for 
collection 
of data 
for 
Eurostat 
(- to - - -) 
[2] 

MS for 
collection 
of data (- 
-) 
EC for 
study  
(- -) 

EC for 
exemption 
evaluation 
and ensure 
compliance 
(if not 
through 3R 
Directive) 
(-) 

B (+A) 

MS for 
additional 
market 
surveillance 
(-) 

MS for 
registration 
processes  
(-) 

MS 
(- - - ) 
EC for follow 
up with 
UNECE 
(-) 

C (+B +A)  

n.a.  

MS 
and 
EC  

MS 
and 
EC 

MS 
or 
EC  

Distributional economic effect 

Social 

Effectiveness/Proportionality338  

Efficiency (cost benefit ratio) 

Coherence 

Abbreviation: n.a. = not applicable 

n.a. 

n.a. 

Low 

(0) 

Highly inefficient 
(- -) 

Contribution to closing the lack of 
knowledge hindering authorities 
in fact-based decision making 

Internalization of external costs, covered by 
EoL stakeholders, if not combined with EPR 
(C6) 

Health 
benefits from 
heavy metal 
restrictions 

Jobs transferred to the formal 
sector; additional burden for 
consumers in managing an 
ELV 

n.a. 

n.a. 

Internalization 
of external 
costs 

n.a. 

Increase of jobs due to an 
increase in the numbers of 
ELVs to be treated in the EU 

(No 
data) 

n.a. 

Medium 
(+) 

Low efficiency  
(+) 

Small contribution to CE 

Uncertain  
(- - - to +++) 

Uncertain: high costs but unclear benefits 
(- - - to +++) 

High contribution to CE 
probably not coherent with 3R Directive 

Notes: 
[1] includes multi-stage built, special purpose vehicles and small series  
[2] dependent on the system setup of ELV reporting in the Member States 
0: no impact; Costs or burdens: between 1 and 3 minus signs (-; --; or ---), indicating low (1 minus sign) and high (3 minus signs) costs or burdens; Benefits or savings: between 1 and 3 plus 
signs (+; ++; or +++), indicating low to high savings 

338 BRG Tool #5, Section 3: “The principle of proportionality under the Treaty regards the policy initiative itself and needs to be distinguished from an IA which can be ‘proportionate’ in terms 
of the depth of the analysis provided. It means that the action of the EU must be limited in its content and form to what is necessary to achieve the objectives of the Treaties that it intends to 
implement” 

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3.4.5  Conclusion  

Overarching conclusions 

To  address  the  above-mentioned  problems,  measures  proposed  under  Option  C  are 
concluded to have very high uncertainties under the various impact indicators as well as in 
relation to effectiveness and efficiency. This is particularly true as long as it is not clear which 
measures would actually be implemented for M1 and N1 vehicles. Furthermore, there is a 
risk that measures will not sufficiently support the achievement of the objective: As to specific 
requirements  under  consideration  for  M1  and  N1  vehicles  as  well  as  for  new  vehicles  in 
scope,  there  are  too  many  variants  of  measures,  reaching  from  soft  tools  to  far-reaching 
regulatory options, e.g., sub-options C2 (Design for circularity) or C4 (advanced traceability). 
Stakeholders have warned that separate recycling targets could jeopardize current repair and 
reuse  practices  as  ATFs  could  compete  with  such  operators  to  ensure  fulfilment  of  the 
recycling  target.  Such  argumentation  could  also  be  supported  by  Member  States  to  avoid 
infringement  proceedings.  From  the  inputs  of  stakeholders  (e.g.,  ACEM,  ACEA,  Swedish 
government  agencies),  it  is  assumed  that  if  the  same  level  of  ambition  proposed  for 
passenger cars is proposed for new vehicles in scope that it will create distortions, e.g., as 
reuse seems to be highly established, high recycling targets would set the wrong incentive. 
This could affect the possibility to achieve a recycling and recovery target. The assessment 
shows  that  some  measures  in  the  various  sub-options  in  Option  C  have  the  potential  to 
beneficially  contribute  to  achieving  the  objective,  e.g.,  a  reuse+recycling  target  (C3)  or 
advanced traceability (C4) and export restrictions (C5). However, ambition levels cannot be 
set at this point due to the lack of data. In addition, at this point of the assessment and with 
the information and data that is available, it is unclear whether the benefits will be higher than 
the burden. 

Option A is not recommended, as it is inherent to the nature of information requirements that 
economic burdens, i.e., costs for reporting and administrative burden, are high but benefits 
are not directly expected (highly inefficient). Indirectly, benefits from an increase of circularity 
can be expected, if the information gathered through these provisions will be used to design 
and implement measures based on the findings in the future. However, this is not foreseen in 
Option  A.  Compared  to the  problems  described and  the  extent  of  impacts  in  the  baseline, 
measures of Option A are considered not proportionate (low effectiveness), i.e., insufficient 
to contribute to the objectives in appropriate way.  

Option B is considered the preferred option. The strongest argument is the cost-benefit ratio 
(efficiency):  The  Option  includes  the  information  requirements  (A1-3)  for  which  economic 
burden  in  the  form  of  administrative  costs  can  be  expected  to  be  comparable  to  those  of 
Option A. However, measures B1-B3 result in environmental benefits, namely benefits from 
heavy  metal  restrictions  and  from  formalized  treatment.  These  measures  will  have  an 
additional  medium  economic  burden,  i.e.,  costs  for  supply  chain  management  and 
authorization  of  dismantling  facilities.  However,  the  total  economic  burden  of  Option  B  is 
considered appropriate in light of the objective it will reach and the problems that it will solve. 
At  the  same  time,  measures  provide  initial  environmental  benefit,  contribute  to  EU-wide 
harmonization and points the way that the sector of vehicles other than M1 and N1 shall follow 
in order to address the problems identified in all vehicle subsectors. This is described in detail 
below for all vehicle categories individually. 

The finding, that sub-options of Option C are assessed as generally beneficial provided that 
data is available to tailor them accordingly to the vehicle specifications, suggests, that these 
provisions might be considered for the future. This will include any new provisions to have 
been introduced for passenger cars.  

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Another  general  finding  is  that  regardless  of the option  chosen,  it  is  important  to  align  the 
scope of ELVD and 3R Directive, vehicle related aspects of this conclusion are referred to 
below. 

Vehicle specific conclusions 

PTW:  

•  Option A is even more inefficient for PTWs as in the sector, many companies are expected 
to  be  SMEs  thus,  reporting  will  burden  them  proportionally  more  than  it  does  bigger 
companies. 

•  Some of the measures in Option B are already implemented at MS level, e.g., Italy339. It 
is considered appropriate to follow MS approaches to achieve more harmonisation. 
•  Not enough information is available on PTW, in particular for circularity-related measures 
and for traceability-related measures in Option C, to conclude on a meaningful setup of 
targets/ambition level nor on respective impacts.  

•  When aligning the scopes of 3R Directive and ELVD, for PTW in particular, the question 

is whether the spare parts that are currently in the scope of the 3R Directive will 
also be in the ELVD scope.340 

Lorries (base-vehicle):  

•  Option A is considered inefficient, e.g., compared to other vehicles, as industry already 

exchanges information with recyclers (via IDIS).  

•  As  to  the  requirements  in  Option  B,  here  too  some  MS  have  measures  in  place,  e.g., 
Spain  has  established  ATFs  for  dismantling  of  lorries.  For  the  heavy  metals,  it  will  be 
proportionate to establish an individual Annex II, or vehicle category specific exemptions. 
Thus, a medium effort is expected to be needed to comply with measures proposed in 
Option B. 

•  The biggest problem in relation to lorries is the lack of control on extra-EU export (~74% 
of  expected  ELVs)  and  transboundary  shipment  of  ELVs  within  the  EU.  Measures  to 
address these problems are not part of Option B but only of Option C. Though considered 
an  important  measure,  the  impacts  cannot  be  ultimately  quantified.  Generally,  it  is 
assumed that such a measure has high impacts at macro-economic level.  

•  For  the  circularity-related  measures  in  Option  C,  as  for  other  vehicles,  not  enough 
information is available to conclude on a meaningful setup of targets/ambition level nor 
on respective impacts. 

•  For  the  base  vehicle  of  a  multi-stage-built  vehicle,  already  today  3R  Directive 
requirements are applicable. It is considered appropriate to continuously apply the rules 
to the base vehicle. 

Small series, special purpose vehicles and multi-stage-built vehicles: 

•  These vehicles contribute to the problems only to a small extent, as the number of vehicles 
in  these  fleets  is  small  and  various  small  volume  manufactures  are  involved.  It  is  not 
proportionate to expect high administrative costs for the fact that overall (also in the future) 
these vehicles can be expected to make little contribution to solving the problem.  
In  relation  to  these  vehicles,  it  is  of  enormous  importance  to  word-for-word  align  the 
scopes of 3R Directive and ELVD, see the various discrepancies described in Annex II. 

• 

339 Though impacts of the Italian legislation are not yet evaluated due to the short time since the coming into force 

340 This aspect was identified late in the study and therefore not assessed. 

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• 

It  is  thus  concluded  to  completely  exclude  small  series,  special  purpose  vehicles  and 
multi-stage built vehicles from ELVD and 3R Directive. 

Buses:  

•  Very little is known on the EoL of buses throughout the EU. Thus, information 

requirements under Option A might shed light on the unknowns.  

•  The impacts of any other measure/option are expected to be too uncertain to conclude 
on their efficiency. Whether as for the two vehicle categories above, Option B does (not) 
put so much additional burden on the sector and authorities, is unclear. 

•  Though  export  of  buses  is  considered  relevant  on  a  relative  scale,  i.e.,  export  of  used 
vehicles compared to expected ELVs, in absolute numbers, fewer buses are concerned 
compared  to  the  trailers  and  lorries.  It  is  considered  inappropriate  to  take  measures 
related to traceability and export (as in option C) for such vehicles.  

(Semi-)Trailers:  

•  See buses. 

3.4.6  Reporting and monitoring requirements 

Together with the investigation and decision on new provisions to apply to the vehicles newly 
in scope, it should also be considered how reporting is to be updated to accommodate any 
additional needs for information. 

The  reporting  of  relevant  information  for  dismantlers  and  recyclers  (A1)  is  a  task  for 
manufacturers of vehicles. At this point of time, the list of items to be informed about and the 
means to do so are not yet decided. The aspect has interrelations with other EU initiatives, 
such as the Digital Product Passport, and a comparable measure is proposed for M1 and N1 
vehicles  under  ‘circularity’.  It  is  recommended  to  align  the  measures  and  initiatives  in  this 
regard.  Reporting  of  ELVs  (A2)  will  result  in  additional  administrative  burden  for 
ATFs/dismantlers,  national  authorities,  registration  services  and  EU  authorities,  e.g., 
Eurostat. Setting up a new reporting system for waste PTW, lorries, buses and (semi-)tailers 
might be linked to and shall follow the same procedure than the reporting of waste cars and 
vans.  The  one-time  reporting  obligation  (A3)  is  subject  to  considerable  effort  for  the 
Commission  and  national  authorities  (development,  collection  of  data,  review  of  collected 
data) and to a lesser extend also for individual business operators who are responsible for 
providing the raw data, i.e., manufacturers reporting on their current circular design practices, 
and EoL stakeholders reporting the status quo of the treatment of PTW, lorries, buses and 
(semi-)trailers. As a first step, existing data on material flows of ELVs other than M1 and N1 
vehicles  shall  be  collected  to  identify  the  data  gaps  for  which  the  one-off  reporting  of  MS 
should provide additional insights. Effort for reporting can be massively reduced when based 
on  online  reporting  or  even  tracking  of  vehicles,  maybe  for  a  representative  collection  of 
vehicles.  

When looking at how the measures for heavy metal restrictions, ATF and CoD requirement 
are designed in the current ELVD, it is the responsibility of MS to ensure compliance, report 
and monitor. Where these measures are updated for M1 and N1 vehicles through measures 
discussed  in  other  chapters/in  relation  to  other  objectives  of  this  study,  a  harmonized 
approach  might  be  taken  for  new  vehicles  in  scope.  Otherwise,  current  design  of  these 
measures in ELVD might be taken over for the new vehicle categories.  

Provided  that  measure  A3,  the  one-off  reporting  on  EoL,  is  implemented  with  a  time 
advantage over Option C, the developed format might be evaluated in relation to the suitability 
for reporting and monitoring for measures in Option C afterwards. 

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4.  Overarching effects between the fields of action 

For  the  final  assessment  of  the  combination  of  the  preferred  options  it  is  important  to 
crosscheck the preferred options assessed above on overarching effects and whether they 
Options have adverse impacts.  

The  figure  below  provides  a  qualitative  overview  of  the  interrelations  between  the  areas 
assessed and the subsequent chapters a qualitative assessment of the overarching impacts. 

Figure 4-1  Interrelations 

Impact on:  Circularity 

Missing 
Vehicles 

EPR 

Hazardous 
substances 

ELVD  Scope 
extension  

Impact of: 

Design for 
circularity (3R 
TA and other) 

High quality 
reuse and 
recycling  

Missing 
vehicles 

EPR 

Hazardous 
substances 

ELVD Scope 
extension 

+/- 

(-) 

+ 

+ 

(-) 

(-) 

Currently n.a. 

(+)* 

Currently n.a. 

Currently n.a. 

Currently n.a. 

+ 

+ 

+ 

Currently n.a. 

Currently n.a. 

Currently n.a. 

Currently n.a. 

++ 

++ 

+ 

(+) 

*Will depend on which measures are implemented for other than M1 and N1 vehicles. 

4.1  Impacts  of  design  for  circularity  on  the  other  fields  of 

action 

4.1.1  On Missing vehicles 

for 

improved  design 

the  circular  economy  could  make  dismantling  parts 

An 
for 
remanufacturing, disassembly and recycling more attractive, thus increasing the profitability 
of dismantlers. This might make it attractive to direct ELVs to ATFs. However, this could also 
apply to illegal dismantlers and the linkage will only take effect with a delay of 15 to 20 years 
after the ELV Regulation enters into force. Judgement: no direct impacts 

4.1.2  On EPR schemes  

In the long-term advanced design for recycling might reduce costs for obligatory dismantling 
(e.g. traction batteries of EV are easier to dismantle). The required cost compensation could 
then decline: judgement: positive impact 

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In  the  mid-  to  long-term,  the  data  provided  by  OEMs  to  ATF  could  become  more  fit-for-
purpose through its harmonisation as well as when OEMs realise through dismantling and 
shredding tests, they perform what information would facilitate quicker dismantling. This could 
reduce  costs  for  obligatory  dismantling  and  in  turn  lead  to  a  decline  in  dismantling  costs: 
judgement: positive impact. 

4.1.3  On the Extension of the vehicle categories in scope of the ELV 

Directive 

Even  if  the  measures  considered  for  “design  for  circularity”  are  not  implemented  for  new 
vehicles in scope in the mid- to long-term, it could be expected that the circularity of “new 
vehicles  in  scope”  shall  increase,  as  some  manufacturers  of  M1  an  N1  vehicles  also 
manufacture other vehicle types. These would be expected at least in some cases to apply 
similar practices to the design of “new vehicles in scope”, leading in the far future at least to 
a small increase in circularity.  

4.2  Impacts of high-quality reuse and recycling on the other 

fields of action 

4.2.1  On Missing vehicles 

Demanding  requirements  aimed  at  ensuring  high-quality  recycling,  but  which  are  not 
economical for dismantlers and shredders, may result in fewer end-of-life vehicles being sent 
to ATFs and more end-of-life vehicles being treated by illegal companies. This can only be 
avoided if these additional compliance costs are covered by an appropriate EPR system. In 
this  respect,  the  combination  with  a  compensation  of  compliance  costs  is  inevitable  if  the 
objective of reducing the number of missing vehicles is not to be jeopardized. 

4.2.2  On EPR schemes  

Depending  on  the  level  of  requirements  EPR  schemes  and  producers  (and  subsequently 
consumers)  are  exposed  to  higher  cost  compliance  compensation.  Therefore,  the 
requirements need carful substantiation on efficiency and effectiveness.  

4.2.3  On the Extension of the vehicle categories in scope of the ELV 

Directive 

As it can be understood that at least some waste operators of passenger cars (ATFs but also 
shredder and subsequently recyclers) also treat some of the “new vehicle categories”, it is 
likely that improvements in the quality of recycling will have an impact also on the recycling 
of such vehicles.  

4.3  Impacts  of  reduced  number  of  missing  vehicles  on  the 

other fields of action 

4.3.1  On circularity 

The reduced export of old vehicles similar to ELVs will increase the volume of ELVs directed 
to ATFs and shredders and as such increase the circularity. If more ELVs are directed from 
illegal  treatment  within the  EU  to  ATFs  this  will  increase the  potential  for  reuse,  while  it  is 

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assumed that this will not impact the volume treated by shredders as the depolluted carcass 
is currently sent to shredder too. 

4.3.2  On EPR schemes  

In combination with requirements regarding the quality of reuse and recycling the reduced 
export  of  old  vehicles  similar  to  ELVs  will  increase  the  demand  for  compliance  cost  to  be 
compensated by producers and finally most likely to be covered by the consumers. 

4.3.3  On the Extension of the vehicle categories in scope of the ELV 

Directive 

As the problem of “missing vehicles” is understood to also be relevant for the “new vehicle 
categories”, measures to reduce the number of missing vehicles are also relevant for such 
vehicles, and when implemented would lead to a decrease in the number of missing vehicles. 
Nonetheless, should such measures not be applied for new vehicle categories in scope, it is 
still possible that some small benefits would incur, due to the increase in awareness of e.g., 
authorities  dealing  with  EU  trade  and  extra-EU  exports  to  such  problems,  and  due  to  the 
implementation of new practices to address the problems of missing vehicles. 

4.4  Impacts of EPR scheme on the other fields of action 

4.4.1  On circularity 

EPR  schemes  and  in  particular  compliance  cost  compensation  are  an  inevitable  element, 
necessary  for  the  functioning  of  challenging  requirements  aimed  at  ensuring  high-quality 
recycling, but which are not economical for dismantlers and shredders. 

4.4.2  On Missing vehicles 

EPR  schemes  is  a  supportive  element  to  reduce  the  number  of  missing  vehicles  and  has 
additional positive effects. 

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https://iopscience.iop.org/article/10.1088/1757-899X/1034/1/012087/pdf. 

Tabel, T.; Leistner, W.; Hollm, R. (2011): Einsatz einer Kompaktsortieranlage zur Metallausschleusung bei Schredderleichtfraktionen. 

Abschlussbericht. BMU-Umweltinnovationsprogramm. 

U.S. Department of Energy (2013): WORKSHOP REPORT: Trucks and Heavy-Duty Vehicles Technical Requirements and Gaps for Lightweight 

and Propulsion Materials. Online available at https://www.energy.gov/sites/prod/files/2014/03/f13/wr_lorries_hdvehicles.pdf, last accessed 

on 20 Apr 2022. 

van den Eynde, S.; Bracquene, E.; Diaz-Romero, D.; Zaplana, I.; Engelen, B.; Duflou, J. R.; Peeters, J. R. (2022): Forecasting global aluminium 

flows to demonstrate the need for improved sorting and recycling methods (137, pages 231-240). Waste Management (ed.). 

Villanueva-Rey, P.; Belo, S.; Quinteiro, P.; Roja, A.; Dias, A. C.: Wiring in the automobile industry: Life cycle assessment of an innovative cable 

solution. (204, Pages 237-246.). Journal of Cleaner Production (ed.). 2018. Online available at https://doi.org/10.1016/j.jclepro.2018.09.017. 

VITO & OVAM (2013?): Environmental impactassessment of recyclingroutes for automotiveglass. In collaboration with Manshoven, S.; an 

Vercalsteren; Vanderreydt, I.; Verlinden, L. and Loncke, P. OVAM (ed.). 

VW/Porsche (2022): Interview held on the 3R Directive on January 2022 as part of the 'Study to support the impact assessment for the review of 

Directive 2000/53/EC on end-of-life vehicles' with Oeko-Institit e.V & Fraunhofer IZM, 24 Feb 2022. 

Williams et. al (2020): Supporting the Evaluation of the Directive 2000/53/EC on end-of-life vehicles. under framework contract No. 

ENV.F.1.FRA/2014/0063. In collaboration with Williams, R., Mehlhart, G., Baron, Y. Keeling, W. and Petsinaris, F. Trinomics, Oeko-Institut 

e.V & Ricardo. European Commission, DG ENV (ed.). Online available at https://www.elv-evaluation.eu/fileadmin/elv-

evaluation/user_upload/elvd_evaluation_final_report_aug2020.pdf. 

Willman, A.; Wedberg, M.; Solheim, U. (2017): An evaluation of alloying elements in shredded steel scrap, Economic and environmental aspects 

of the recycling process for the steel scrap category E40. KTH Royal Institut of Technology. 

Wolff, S.; Seidenfus, M.; Gordon, K.; Álvarez, S.; Kalt, S.; Lienkamp, M. (2020): Scalable Life-Cycle Inventory for Heavy-Duty Vehicle 

Production. In: Sustainability 12 (13), p. 5396. DOI: 10.3390/su12135396. 

Workshop (2022): ELV IA Stakeholder Workshop 23/24.March 2022. 

Yellishetty, M.; Mudd, G. M.; P.G., R.; Tharumarajah, A. (2011): Environmental life-cycle comparisons of steel production and recycling: 

sustainability issues, problems and prospects. Volume 14, Issue 6, Pages 650-663 vol.: Environmental Science & Policy. 

Zhu, Y.; Chappuis, L. B.; Kleine, R. de; Kim, H. C.; Wallington, T. J.; Luckey, G.; Cooper, D. R. (2021): The coming wave of aluminum sheet 

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6.  Annexes  

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ANNEX I: ADDITIONS TO THE REPORT 

6.1  Detailed  current  situation  of  Specific  objective  1  (the 

scope of the Directive) 

6.1.1  Scope of the ELVD and road vehicles not in scope of ELVD 

and their fleet 

The ELVD covers passenger cars classified as M1341, light (< 3,5 tons) commercial vehicles 
classified  as  N1342  and  three-wheel  motor  vehicles  as  defined  in  Directive  92/61/EEC  but 
excludes  motor tricycles  (according  to  ELVD  Art.  2.1).  Other vehicles,  such  as  buses  with 
more  than  9  seats,  motorcycles,  commercial  vehicles  for  the  transport  of  goods  with  a 
maximum mass of more than 3.5 tons, trailers, powered two- and three wheelers and other 
vehicles (e.g. trains, boats and airplanes) are currently not covered by the ELVD. 

Table  6-1  lists  additional  vehicle  categories:  Lorries,  motorcycles,  (semi-)trailers,  road 
tractors,  special  vehicles  as  well  as  coaches/buses  as  part  of  the  Eurostat  dataset for the 
stock of road vehicles by category. Thereby, a road vehicle is running on wheels and intended 
for use on roads (European Commission; OECD; United Nations 2019). These types of road 
vehicles which are currently not in scope of the ELV Directive are described in the following:  

Table 6-1  Definition of types of road vehicles 

Vehicle type 

Definition 

Classes 
and 
categories  of  type 
approval343  

Bus 

A bus is passenger road motor vehicle designed to carry more 
than  24  persons  (including  the  driver),  and  with  provision  to 
carry seated as well as standing passengers 

Categories  M2  and  M3, 
dependent on weight 

Motor Coach 

Passenger  road  motor  vehicle  designed  to  seat  24  or  more 
persons (including the driver) and constructed exclusively for 
the carriage of seated passengers. 

Categories  M2  and  M3, 
dependent on weight 

Mini-Bus/-Coach  Passenger road motor vehicle designed to carry 10-23 seated 
or standing persons (including the driver).  

Categories  M2  and  M3, 
dependent on weight 

Heavy 
road vehicle 

goods 

Goods road vehicle with a gross vehicle weight above 3 500 
kg, designed, exclusively or primarily, to carry goods. 

Categories  N2  and  N3, 
dependent on weight 

ROAD  TRACTOR/SEMI-TRAILER  TRACTOR:  Road  motor 
vehicle designed, exclusively or primarily, to haul other road 
vehicles which are not power-driven (mainly semi-trailers) 

341 Category M1: Motor vehicles designed and constructed primarily for the carriage of persons and their luggage and 
comprising not more than eight seating positions in addition to the driver’s seating position. Vehicles belonging to category M 
1 shall have no space for standing passengers. The number of seating positions may be restricted to one (i.e. the driver’s 
seating position). See Regulation (EU) 2018/858. 

342 Category N1: Motor vehicles designed and constructed primarily for the carriage of goods and having a maximum mass not 
exceeding 3,5 tonnes. See Regulation (EU) 2018/858. 

343 According to Regulation 2018/858, if not specified differently 

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Vehicle type 

Definition 

Classes 
and 
categories  of  type 
approval343  

TRUCK/LORRY:  Rigid 
exclusively or primarily, to carry goods.344 

road  motor  vehicle  designed, 

Agricultural tractors are excluded. 

Trailers  (a)  and 
Semi-Trailers 
(b)345 

Goods  road  vehicle  designed  to  be  hauled  by  a  road  motor 
vehicle. 

Category 
dependent on weight 

O1-O4, 

Goods road vehicle with no front axle designed in such way 
that  part  of  the  vehicle  and  a  substantial  part  of  its  loaded 
weight rests on a road tractor.  

Goods 
motor vehicle 

road 

Any single road motor vehicle designed to carry goods (e.g. a 
lorry), or any coupled combination of road vehicles designed 
to carry goods (i.e. lorry with trailer(s), or road tractor with or 
without semi-trailer and with or without trailer). 

Various  powered 
two-/three- 
or 
four-wheelers 

Includes mopeds and motorcycles, for details, see Figure 6-1. 

Source: (European Commission; OECD; United Nations 2019) 

Refers to categories  

N2, or 

N2+O  (can  be  multiple 
types), or 

N3, or 

N3+O  (can  be  multiple 
types). 

Categories  L1e  –  L7e 
(Regulation 168/2013) 

344 See types of body of lorries in footnote 345. 

345 Types body of lorries or (semi-)trailers: Ordinary open box (with cover; flat), tipper, tanker (solid or liquid bulk), temperature 
controlled box, other closed box, skeletal container and swap-body transporter, livestock transporter, others. 

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The  variety  of  types  of  powered  two-/three-  and  four-wheelers  is  high,  and  the  types  are 
described and defined in a separate Type Approval Regulation, Regulation (EU) No 168/2013 
(compared to the Type Approval Regulation No. 2018/858 for M, N, O, and T vehicles). The 
group of L-type approved vehicles, i.e., powered two-/three- and four-wheelers, consists of 
seven categories with sub-categories, see Figure 6-1. 

Figure 6-1  Overview of different types of L-type approved vehicles according to 
Regulation (EU) No 168/2013 

Source: ACEM 2021 

Some vehicles that share similar elements and components with L-category vehicles are still 
outside the scope of EU Regulation No. 168/2013. These are off-road vehicles and vehicles 
intended for use by physically disabled people which are covered by the Machinery Directive 
(Directive 2006/42/EC), vehicles exclusively intended for sports competition (excluded from 
both  the  scope  of  the  Machinery  Directive  and  that  of  the  Type  Approval  Regulation  (EU) 
168/2013) and non-type approved e-bikes. These are defined as road vehicles with two or 
more wheels and are often propelled by the muscular energy of the persons on that vehicle, 
in  particular  by  means  of  a  pedal  system,  lever  or  handle  (e.g.,  bicycles,  tricycles, 
quadricycles  and  invalid  carriages).  Type  Approval  Regulation  (EU)  168/2013)  includes 
cycles with a supportive power unit (e.g., E-bikes and pedelecs with a cut-off speed above 25 
km/h). 

Assessment of robustness and completeness of fleet data 

Different data sources for fleet data for vehicles other than M1 and N1 have been checked. 
Different references show individual characteristics or inconsistencies which makes it difficult 
to display an overview based on one data source:  

•  The fleet, based on PRIMES Data (European Commission 2022b) is available with a time 
interval of 5 years, i.e., for 2010, 2015, 2020 etc., for cars, vans, heavy duty trucks and 
buses. The categories of trailers, powered-two wheelers and special-purpose vehicles are 

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not included, as a consequence, to provide a full picture for road vehicles is not possible 
to be based on this data source only. 

•  Data is available for all vehicle categories in the Eurostat dataset ‘stock of vehicles by 
category’ (tran_r_vehst). However, for studies in relation to the implementation of Green 
Deal’s activities, the European Commission has been using specific modelling tools other 
than Eurostat datasets346. Further, the Eurostat dataset is not consistent with the L-type-
approval  categories  of  (EU)  168/2013.  If  it  is  assumed  that  motorcycles  stand  for  all 
powered two- and three wheelers (all L categories), as a result, it must be assumed to be 
an underestimate.  

•  The following references have been checked to substantiate the fleet data, especially in 

terms of L-type approved vehicles:  
o  Additional data (ACEA (2021c) and O'Brien (2021) cited in EC (2022c)) suggests that 
there is a higher number of PTWs than the number reported from Eurostat.  347 For 
this  study,  it  is  assumed  that  the  motorcycles’  number  from  Eurostat  stand  for  all 
powered  two-  and  three  wheelers  (all  L  categories),  assuming  that  this  is  an 
underestimation  in  order  not  to  mix  references  with  possibly  different  ways  of 
collecting the data. In this recent report by the European Commission (2022c), data 
provided  for  L-type-approved  vehicles  is  26.963.668  motorcycles,  10.972.219 
mopeds, 444.544 others, and 360.000 small scale e-scooter for 2019 except for small 
scale e-scooters which is data from 2021. This sums up to 38,7 million units whereas 
the Eurostat data reports 22, 3 million units in stock in 2019. All numbers are based 
on statistical releases of industry associations, thus, for this report, the numbers shall 
not be used but only data available from EU modelling. This is to maintain consistency 
with other EC interventions under the Green Deal. 
In  the  stakeholder  consultation,  the consultants were  provided  with  motorcycle  and 
moped registration data for 2018 and 2019 which is available online (ACEM 2022). 
But,  on  the  one  hand  side,  calculating  the  stock  based  on  registrations  involves 
considering  various  assumptions,  thus,  such  data  would  not  be  considered  very 
profound,  and  on  the  other  side,  again,  using  statistical  releases  of  industry 
associations contradicts the consistency with the existing models for EU interventions 
under the Green Deal.  

o 

o  There is data on powered two wheelers available from the EU modelling in the EU 
Reference Scenario 2020 (European Commission 2020b). There, data is presented 
as the ‘activity’ in giga passenger kilometre (Gpkm). It was not possible to convert the 
data into PTW in units. Though, the trend in these data shall be used to calculate how 
the  fleet  evolves  in  the  future.  Thus,  projections  are  fully  compatible  with  the  EU 
reference scenario.  

o  To  fill  the  gap  in  terms  of  L-category  vehicles,  available  stock  data  for  electric  L-
category vehicles from Huismann and Bobba (2021) has been checked. Vehicle units 
and tonnage is provided for small personal light electric vehicles (PLEVs), e-scooters, 
e-bikes, e-mopeds and e-motorcycles348. It should be noted that PLEVs, e-scooters 
and  the  majority  of  e-bikes349  are  non-type  approved.  Using  the  data  provided,  in 
2020, the sum of type-approved e-bikes, e-mopeds and e-motorcycles accounts for 
1,79 – 2,04 million units or 8 766 – 10 245 tons. This number can rarely be compared 

346 https://ec.europa.eu/clima/eu-action/climate-strategies-targets/economic-analysis/modelling-tools-eu-analysis_en (last 
accessed 18.07.2022) 

347 (2022c) cites (ACEA 2021c) which reports about 27 million motorcycles and 11 million mopeds, and (O'Brien 2021) reports 
about 360,000 small-scale e-scooters.  

348 Tables S 17 and S18 in Huismann and Bobba (2021) 

349 Huismann and Bobba (2021): In terms of e-bikes, ‘the majority of products is represented by EPAC25’ (<250W, classified 
as conventional [non-type approved] e-bikes. For this study, it shall be assumed that 10% of the e-bikes are type-approved. 

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to the Eurostat number for motorcycles (22,3 million units and ~ 4 million tons in 2019), 
as the drive trains for these motorcycles counted in the Eurostat data is not available. 
It can be expected that type-approved e-bikes and e-mopeds (1,69 – 1,94 million units, 
+  ~8%  on  top  of  the  Eurostat  data)  are  not  included  in  the  Eurostat  data,  thus, 
theoretically might be added, numbers for the same vehicles with combustion engines 
are  not  available  separately.  It  can  be  assumed  that  in  2019/20  mopeds  with 
combustion engines were more common than e-mopeds, however, for e-bikes, there 
exists no version with combustion engines. The number of unreported L-cat vehicles 
in addition to the reported motorcycles (via Eurostat) can be expected to be ~10-15% 
more.  

•  For trailers, no information other than EUROSTAT data is available.  

To conclude, a mix of Eurostat data and PRIMES data is used for the description of the current 
situation (cells in bold in Table 6-2). This is concluded to be able to set in context and compare 
all vehicle categories not in scope of ELVD but not only trucks and buses for which fleet data 
is available from PRIMES. A comparison of data sources is provided in Table 6-2 and Table 
6-3 below. From the data below, based on PRIMES fleet where possible and Eurostat where 
PRIMES data is not available, it can be concluded that 17% by unit, ~ 47 million, or 33% by 
mass, 159 million tons of vehicles are not in scope of ELVD. For the forecast and development 
of the fleet, PRIMES data is used for the buses and lorries. For L-type approved vehicles, the 
forecast is modelled in line with the trend for PTW as in EU Reference Scenario 2020 starting 
with the stock data for motorcycles obtained from Eurostat (as explained above). The data 
from Huismann and Bobba (2021) suggests that at least ~10% of additional PTW (by number) 
could be in the stock, however, exact data is lacking. For trailer no other data than Eurostat 
is available. The future stock was extrapolated based on the trend in Eurostat data from 2015-
2019.

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Table 6-2  Share of vehicle type in EU 27 (black writing – currently in scope; blue writing – currently not in scope) 

Vehicle type 

Frequency, 
Eurostat 2019 [1]  

% by unit 
(Eurosta
t, 2019) 

Frequency  Euro  7 
IA/PRIMES  where 
available 2020 [2] 

typical 
weights 
[tons] 

%  by 
unit 
(PRIME
S, 
2020) 

total  weight 
2019 
in 
based 
on 
Eurostat 
[tons] 

total  weight 
2020 
in 
based 
on 
PRIMES 
where 
available 
[tons] 

% 
weight 
2019 

by 

%  by 
weight 

Passenger  cars 
type) 

(M1 

241.713.654 

74,4% 

238.189.752 

74,0% 

1,2 [a] 

290.056.385 

285.827.702 

54,0% 

54,1% 

Lorries N1 type [3] 

28.822.549 

8,9% 

30.047.145 

9,3% 

2,4 [b] 

69.174.117 

72.113.148 

12,9% 

13,6% 

Lorries  N2,  N3 
(road 
above 3,5t) 

tractor, 

type 
lorries 

6.995.989 

2,2% 

6.218.833 

1,9% 

8,25 [c] 

57.716.913 

51.305.372 

10,8% 

9,7% 

Motorcycles 

22.296.012 

6,9% 

see Eurostat 

6,9% 

0,183 [c] 

4.080.170 

4.080.170 

0,8% 

0,8% 

other L-cat. Vehicles [4]  2.229.601 
(assumed) 

0,7% 

assumed 

0,7% 

0,183 [c] 

408.017 

408.017 

0,1% 

0,1% 

Trailers 
trailers 

and 

semi-

18.250.515 

5,6% 

see Eurostat 

5,7% 

5,25 [c] 

95.815.204 

95.815.204 

17,8% 

18,1% 

Motor  coaches,  buses 
and trolley buses 

775.375 

0,2% 

703.368 

0,2% 

10,75 [c] 

8.335.281 

7.561.206 

1,6% 

1,4% 

Special vehicles 

3.743.390 

1,2% 

see Eurostat 

1,2% 

3 [b] 

11.230.170 

11.230.170 

2,1% 

2,1% 

Sum 

324.827.085 

321.678.616 

536.816.257 

528.340.990 

[1] Most recent data is from 2019. Compared to data from 2016 which was shown in the Evaluation Report, i.e., Williams et. al (2020), shares of vehicle types vary maximum ±1%. 
[2] The PRIMES Model provides data for every 5 years, thus, data for 2019 is not available. 
[3] “10.0 % of which 90 % are “light” (N1 type)” Williams et. al (2020) resulting in ~9 % of lorries being under the scope of the current ELVD 
[4] assumed 10% of motorcycles, see explanation in the text above.  

Source: Eurostat 2021, downloaded 20.04. 2021; PRIMES: European Commission 2022b 
Note: (a) average based on Table 6-34; (b) personal estimate; (c) based on data displayed in chapter 6.1.3.. 

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Table 6-3  Comparison of data from Eurostat and PRIMES 

scope 
in 
ELVD_unit 

of 

in  scope  of  ELVD 
_weight 

in  scope  of 

not 
ELVD_unit 

in  scope  of 

not 
ELVD_weight 

EUROS
TAT 

83,3% 

66,9% 

16,7% 

33,1% 

PRIMES  83,4% 

67,7% 

16,6% 

32,3% 

Source: calculated based on Table 6-2. 

6.1.2  Argumentation for scope of the assessment  

In addition to M, N, O and L-type approved road vehicles, other vehicles exist for the purpose 
of transportation of goods and passengers. These are ships, planes and trains, agricultural 
and mobile machinery, military and space vehicles, and non-type approved (electric) bicycles. 
These vehicles have in common the characteristic that they are non-road vehicles, with the 
exemption of non-type approved (electric) bicycles. 

Against the background of the objective of the study, i.e., to derive and assess measures to 
tackle identified shortcomings of the current ELV Directive, it is worth looking at these other 
vehicles.  However,  the  relevance  of  non-road  vehicles  for  the  ELV  Directive,  specifically 
planes, was already discussed in the context of the ELV Directive Evaluation Study (Williams 
et. al 2020).  

Current regulation of non-road vehicles:  

•  Non-type approved e-bikes: Regulated under RoHS and WEEE, and its batteries to be 

regulated with the Battery Regulation proposal 

•  Ships: The end of life of ships is addressed in an own regulation,  
•  Planes: often planes are not disposed of in the EU; a lot of parts are leased so there is a 
huge  remanufacturing  scene/market;  high  shares  of  composites,  GLARE,  titanium  and 
specific alloys (corrosion resistant, high strength, low weight like Al-Li, etc.) 

•  Trains are few, e.g., there are ~300 operating long-distance trains in Germany that run 
for  40  years  approximately.  That  is  considerably  less  than  the  annual  limits  of  the 
definition  in  the  type  approval  of  what  are  small  series,  which  are  specially  exempted. 
Generally, there is little waste, and a high recyclable fraction is expected 

•  Agricultural and non-road mobile machinery (NRMM): These are low volume, high variety 
vehicles, meaning that it is typical for such vehicles to be produced in small series and in 
a wide range of models for specific purposes. Vehicles are for the most part heavy duty 
with long service life. These are difficult to address with “general”, overarching measures, 
Vehicles used in agricultural and forestry activities such as all-terrain vehicles (ATVs) and 
Side-by-sides (SbS) belong to the so called “T-category” and are subject to a specific type 
approval regulation (EU Regulation 167/2013) 

•  Military purposes & space: RoHS und REACH do not apply to applications designed solely 

for military purposes and/or for space.  

•  For  all  of  the  above  vehicle  types:  Their  type  approval  is  separate  from  that  of  road 
vehicles and in particular does not address objectives of the 3R type approval. Potential 
changes  to  the  current  provisions  of  3R  type  approval  regulation  will  not  impact  the 
increase of circularity of these vehicle categories. 

With the vision to ELV regulation introducing reuse and recycling targets, etc., and 3R type 
approval  for  the  new  vehicles  in  scope  in  a  mid-term  perspective,  it  is  important  that  ISO 
22628  applies.  This  ISO  standard  is  for  road  vehicles,  so  far  unclear  if  other  recyclability 

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calculation methods exist; even if so, this increases complexity, and it is questionable whether 
an ELV regulation will be the most efficient to regulate non-road vehicles. 

6.1.3  Material composition of motorcycles, trucks and buses at their 

end-of-life 

There  is  no  general  comprehensive  summary  of  data  on  the  material  composition  of  the 
vehicles not in scope of ELVD available but only compositions of individual models in specific 
studies, e.g., LCA. An overview of LCA studies in the automotive sector is provided in Figure 
6-2, showing that only few (84) out of 347 reports identified contain detailed datasets. The 
Figure also shows that few papers were found for vehicles other than passenger cars. Thus, 
the conclusions drawn in relation to material-specific & weight-related materials not covered 
by the ELVD are subject to high uncertainties.  

Figure 6-2  Overview of a literature research of LCA studies in the automotive sector. 

Source: (Hill 2020) 

It is not only the case that there is no general comprehensive summary of data on material 
composition, but there is also no specific data for the different drivetrain technologies. The 
analysis in this problem area therefore has shortcomings in the sense that only one material 
composition  is  available  for  calculation  of  material-specific  and  weight-related  conclusions 
despite data for the fleet that can distinguish, at least for buses and lorries, between different 
drivetrains. 

PTW 

Table 6-4  Material composition of PTW 1: Data for motor scooter (50 cubic cm 
engine) 

Material 

Amount  Unity 

alkyd paint, white, without solvent, in 60% solution state 

aluminium, cast alloy 

aluminium, wrought alloy 

chromium 

copper, cathode 

ethylene 

lead 

534 

0,39 

4,55 

9,67 

0,15 

0,64 

1,17 

0,82 

kg 

kg 

kg 

kg 

kg 

kg 

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Material 

nickel, class 1 

Palladium 

platinum 

polyethylene, high density, granulate 

polypropylene, granulate 

polyvinylchloride, emulsion polymerised 

polyvinylchloride, suspension polymerised 

reinforcing steel 

steel, low-alloyed, hot rolled 

sulfuric acid 

synthetic rubber 

wire drawing, copper 

zinc 

Sum 

Amount  Unity 

0,09 

0,00 

0,00 

14,50 

6,97 

0,29 

1,98 

42,23 

6,28 

0,05 

2,80 

0,64 

0,37 

93,62 

kg 

kg 

kg 

kg 

kg 

kg 

kg 

kg 

kg 

kg 

kg 

kg 

kg 

kg 

Source: Ecoinvent Database 

Table 6-5  Material composition of PTWs 2 

components  main 

material 

L1e-B;  
average (n=7) 

L3e-A1;  
average (n=7) 

L3e-
A2+A3;  
average 
(n= 15) 

L5e;  
averag
e(n=2) 

L6e;  
averag
e (n=4) 

Example 
vehicles 

Scooter 
(50cubic 
engine) 

Scooter 
(125 
cubic cm engine) 

Motorcycl
es 

Three-
wheelers 

Quadricy
cles 

cm 

Fluids 
(Oil, 
breaking  fluids, 
Cooling 
fluids,…) in kg 

irrelevant  for 
3R 

1,57 

Batteries in kg 

irrelevant  for 
3R 

1,37 

Bulbs in kg 

irrelevant  for 
3R 

0,20 

Steel in kg 

steel 

40,59 

Aluminium 
kg 

in 

aluminium 

17,90 

2,54 

4,41 

2,70 

2,98 

3,87 

4,30 

5,92 

0,18 

0,25 

0,19 

96,48 

93,40 

134,30 

65,83 

75,70 

83,54 

2,71 

0,20 

60,49 

38,59 

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components  main 

material 

L1e-B;  
average (n=7) 

L3e-A1;  
average (n=7) 

L3e-
A2+A3;  
average 
(n= 15) 

L5e;  
averag
e(n=2) 

L6e;  
averag
e (n=4) 

0,16 

4,62 

0,00 

0,20 

3,90 

4,39 

2,13 

6,90 

0,80 

3,25 

1,75 

2,98 

11,07 

8,35 

17,53 

1,69 

1,75 

1,15 

Copper in kg 

copper 

Wire  harnesses 
in kg 

copper 
(+plastic) 

0,17 

0,99 

Catalytic  con-
verter in kg 

varying 

1,29 

Screws in kg 

steel 

Tyres in kg 

rubber 

1,21 

6,89 

elastomeric 

0,62 

thermoplasti
c 

9,69 

0,29 

2,61 

3,17 

2,26 

9,47 

1,36 

19,57 

15,15 

31,50 

23,99 

foam 

1,10 

2,29 

2,25 

4,25 

3,16 

Saddle 
(cladding) in kg 

textile/ 
leather 

0,43 

glass 

0,14 

0,46 

0,09 

0,43 

0,35 

0,48 

0,55 

0,00 

0,10 

84,16 

146,09 

212,09 

235,10 

281,71 

Source: (ADEME and SURPLUS MOTOS 2022) 

Table 6-6  Material composition of different bus models  

Midibus (12t GVW) [kg]  

Coach (19t GVW) [kg] 

Rubber 
seals 
and others in kg 

ABS  polymers 
(fairings, 
lighting 
devices…) in kg 

Saddle 
(upholstery) 
kg 

in 

Lighting 
devices in kg 

average 
weight 

total 

Buses 

Iron 

Steel 

High strength (HS) steel 

Aluminium 

Copper 

Plastics 

1273 

5667 

476 

2544 

34 

1174 

449 

1999 

117 

2940 

20 

1200 

536 

 
 
 
 
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Rubber 

Glass 

Water 

Lead 

glass-fibre reinforced plastics 

Other 

TOTAL 

Trucks 

211 

367 

36 

90 

0 

621 

8050 

Source: EC 2015 

388 

300 

120 

156 

0 

1269 

13400 

Table 6-7  Material composition of different truck models (in kg) 

Van  
(5t GVW) [kg] 

Rigid  Truck  1  
(12t GVW) [kg] 

Rigid  Truck  2  
(12t GVW) [kg] 

Artic  Truck 
(40t GVW) [kg] 

(Curtainsider)  

Steel 

1279 

3204,8 

3466 

Aluminium 

141 

152,3 

400 

119,3 

159,1 

728,5 

280,7 

88,7 

5.133 

55 

517 

20 

41 

214 

350 

1537 

6.200 

9215 

519 

1543 

70 

43 

815 

844 

1501 

14.550 

Source: EC 2015 for rigid truck 1; Wolff et al. 2020 for other truck models. 

232 

23 

14 

249 

69 

294 

2.301 

Iron 

Copper 

Glass 

Plastics 

Rubber 

Other 

Total  

Trailers 

Body types of lorries or (semi-)trailers:  

tipper  
tanker (solid or liquid bulk)  
temperature controlled box  

•  Ordinary open box (with cover; flat)  
• 
• 
• 
•  other closed box  
•  skeletal container and swap-body transporter  
• 
•  others 

livestock transporter  

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Main materials of trailers: steel, plastics, light metals such as aluminium, textiles (for curtains), 
wood.  

Table 6-8  Overview of (semi-)trailers’ weights 

Type of (semi-)trailer  

Weight in kg 

Volume trailer in sliding curtain design 

Profi Liner for steel transport with drop sides 

Profi Liner 5 in sliding curtain design 

Chassis with appropriate locks for the transport of containers 

Profi Liner (long truck type 1) 

Steel swap body 

2-axle refrigerated trailer 

3-axle refrigerated semi-trailer in double-decker design 

2-axle platform trailer in sliding curtain design 

2-axle platform trailer in building material design 

Average 

7600 

6660 

5940 

4760 

6800 

2640 

7720 

7840 

4530 

3710 

5820 

Source: Factsheets downloaded from https://www.krone-trailer.com/download/datenblaetter/ (12.05.2022) 

6.1.4  Practise of reuse 

for  PTW, 

Compared to passenger cars, stakeholders interviewed reported that the practice of reuse is 
more  established 
trucks  and  buses  (ACEM  2021;  ACEA/Volvo  2021; 
ANERVI/AETRAC  2021).  This  is  supported  through  reuse  statistics  for  PTW  in  Finland 
(SMOTO 2021) and best-practice examples for heavy duty vehicles from literature (Saidani 
et al. 2018). The reuse rate of the parts for PTW at Finish operators specialized in the handling 
of motorized two-wheeled vehicles (‘MC dismantlers’) was found between 60 and 70%. At 
around 95%, the reuse rate is even higher for practitioners at motorcycle clubs (‘hobbyists’). 
On the other side, at operators specialized in car handling the reuse of parts from PTW is low 
at around 10% (Figure 6-3) Statistics are based on 720 motorized two-wheelers dismantled 
in 11 motorcycle and 20 car dismantling facility, 1 builder, 1 motorcycle club.  

538 

 
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Figure 6-3  Reuse level of motorized two-wheelers in Finland 

Source: SMOTO (2021) based on 720 PTW dismantled in 11 motorcycle and 20 car dismantling facility, 1 builder, 1 
motorcycle club. 

Looking at lorries, according to ANERVI/AETRAC (2021), ‘there is a specialized market for 
parts  from  lorries  across  Europe.  There  is  a  high  demand  for  spare  parts,  there  is  good 
communication  around  the  spare  parts  established.’  A  flowering  market  for  spare  parts 
suggests that repair and reuse play an important role in the end-of-life treatment. A study by 
Saidani et al. (2018) supports this statement:  

• 

• 

• 

• 

‘Redistribution of second-hand components is a profitable business, e.g., when a Volvo 
FH Globetrotter is dismantled properly (95% of its weight, i.e., 7,000 kg), the overall resale 
of spare parts can reach 40,000 euros.’  
‘In 2012 Caterpillar’s remanufacturing programme took back over 2.2 million end-of-life 
units  for  remanufacturing,  representing  73,000  tons  of  materials,  and  including  6,000 
different remanufactured products.’ 
‘In  the  UK,  50%  of  all  heavy  vehicles  reaching  their  end-of-life  are  reused  or  resold  in 
other countries with major refurbishment; 43% are remanufactured to extend their lifespan 
in the UK.’ 
‘More than 93% of all materials in a standard DAF lorry can be reused.’ 

6.1.5  Analysis of exports of vehicles 

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Table 6-9  Extra-EU Export (incl. GB) 

.
c
e
D

-
.
n
a
J

0
1
0
2

.
c
e
D

-
.
n
a
J

1
1
0
2

.
c
e
D

-
.
n
a
J

2
1
0
2

.
c
e
D

-
.
n
a
J

3
1
0
2

.
c
e
D

-
.
n
a
J

4
1
0
2

.
c
e
D

-
.
n
a
J

5
1
0
2

.
c
e
D

-
.
n
a
J

6
1
0
2

.
c
e
D

-
.
n
a
J

7
1
0
2

.
c
e
D

-
.
n
a
J

8
1
0
2

.
c
e
D

-
.
n
a
J

9
1
0
2

.
c
e
D

-
.
n
a
J

0
2
0
2

.
c
e
D

-
.
n
a
J

1
2
0
2

Sum 

Yearly 
average 

Used road tractors* 

128659  73207 

90576  81295  71163  89173  57144  51247  57216  87358 

83579  90822  961439 

80120 

Used  vehicles 
transport* 

for 

71351 

71458 

89066  93728  76231  69739  55363  54666  94103  112637  66410  67311  1145955  76839 

Used buses for > 10 
persons 

Used 
semi-trailer 

trailer  and 

35921 

8722 

9838 

7226 

6944 

5661 

5901 

5450 

5705 

7339 

3993 

9218 

111918 

9327 

152020  138968  73628  69194  64024  58052  77331  52074  55570  57502 

50935  51589  900887 

75074 

Note: (*) for ‘lorries’, road tractors and vehicles for transport have been added. 
Source: EU trade statistics, European Commission (2022a), , Product Codes: 87012090 (used road tractor); 87021019, 87021099, 
87029019, 87029039 (used buses); 87042299, 87042399, 87043299 (used lorries); 87163980 (used trailers) --> see  

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Table 6-10. 

541 

 
 
 
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Table 6-10 Declaration of trade statistic numbers evaluated 

87012090 

Road tractor  Road tractors for semi-trailers, used 

87042299 

Used  vehicle 
for transport 

Motor vehicles for the transport of goods, with compression-ignition internal combustion piston engine "diesel or semi-diesel engine" of a 
gross vehicle weight > 5 t but <= 20 t, used (excl. dumpers for off-highway use of subheading 8704.10, special purpose motor vehicles 
of heading 8705 and special motor vehicles for the transport of highly radioactive materials) 

87042399 

Used  vehicle 
for transport 

Motor vehicles for the transport of goods, with compression-ignition internal combustion piston engine "diesel or semi-diesel engine" of a 
gross vehicle weight > 20 t, used (excl. dumpers for off-highway use of subheading 8704.10, special purpose motor vehicles of heading 
8705 and special motor vehicles for the transport of highly radioactive materials) 

87043299   Used  vehicle 
for transport 

Motor vehicles for the transport of goods, with spark-ignition internal combustion piston engine, of a gross vehicle weight > 5 t, used (excl. 
dumpers for off-highway use of subheading 8704.10, special purpose motor vehicles of heading 8705 and special motor vehicles for the 
transport of highly radioactive materials) 

87021019 

Bus 

Motor vehicles for the transport of >= 10 persons, incl. driver, with only diesel engine, of a cylinder capacity of > 2.500 cmÂ³, used 

87021099 

Bus 

Motor vehicles for the transport of >= 10 persons, incl. driver, with only diesel engine, of a cylinder capacity of <= 2.500 cmÂ³, used 

87029019 

Bus 

Motor vehicles for the transport of >= 10 persons, incl. driver, with spark-ignition internal combustion piston engine, of a cylinder capacity 
of > 2.800 cmÂ³, used (excl. with electric motor for propulsion) 

87029039 

Bus 

Motor vehicles for the transport of >= 10 persons, incl. driver, with spark-ignition internal combustion piston engine, of a cylinder capacity 
of <= 2.800 cmÂ³, used (excl. with electric motor for propulsion) 

87163980  

Trailers 

Trailers and semi-trailers for the transport of goods, used (excl. self-loading or self-unloading trailers and semi-trailers for agricultural 
purposes,  tanker  trailers  and  semi-trailers,  and  trailers  and  semi-trailers  not  designed  for  running  on  rails  for  the  transport  of  highly 
radioactive materials [Euratom]) 

A more detailed analysis can be found in Annex I, section 6.10.2.  

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6.1.6  Multi-stage type-approval processes  

The  manufacturing  practices  of  trucks,  lorries,  semi-trailer  tractors  and  trailers  require  the 
multi-stage  type  approval  as  referred  to  in  Regulation  2018/858/EU.  ACEA/Volvo  (2021) 
explains (Excerpt from Interview Documentation):  

“General information 

•  Manufacturers applying for a whole-vehicle type-approval may choose the multi-stage 
procedure (article 22(1)), namely a procedure where “one or more approval authorities 
certify  that  […]  an  incomplete  or  completed  type  of  vehicle  satisfies  the  relevant 
administrative provisions and technical requirements” (article 3(8)). 

•  The procedure may be used both by single and multiple manufacturers. When used 
by single manufacturers, it should not be a way to circumvent the requirements applicable 
to vehicles built in a single stage (article 22(6)). 
•  Multi-stage type approval shall be granted for:  

o  an incomplete or completed type of vehicle, as long as it conforms to the particulars 
in the information folder detailed in the Regulation’s article 24 and that it meets the 
technical requirements laid out in Annex II; 

o  complete vehicles that have been converted or modified by another manufacturer after 

their completion.  

•  Annex IX sets out the specific obligations for manufacturers and approval authorities to 

be followed during multi-stage type-approval procedures. 

Application procedure for multi-stage EU-type approval  

•  Each manufacturer should apply for EU type-approval in respect of a particular type of 

vehicle to one approval authority within one Member State (article 23). 

•  The application should include the information folder set out by article 24 and a declaration 

by the manufacturer certifying that: 
o 

the manufacturer has not applied for an EU type-approval for the same type to any 
other  approval  authority,  and  no  other  approval  authority  granted  the  manufacturer 
such an approval;  

the manufacturer has not revoked an application for a type-approval of that type. 

o  no approval authority has refused to grant type-approval of that type;  
o  no approval authority has withdrawn type-approval of that type;  
o 
In addition, applications for multi-stage approval should also include: 
o  For  the  first  stage:  the  information  folder  (detailed  in  article  24)  and  the  EU  type-
approval  certificates,  UN  type-approval certificates  or,  if  applicable,  the test  reports 
that are relevant to the state of completion of the base vehicle;  

• 

o  For the second and subsequent stages: the information folder (detailed in article 24) 
and the EU type-approval certificates or UN type-approval certificates relevant to the 
current stage of completion, along with a copy of the EU whole-vehicle type-approval 
certificate that was issued at the preceding stage of construction, as well as full details 
of any changes or additions that the manufacturer has made to the vehicle. 
•  The EU type-approval for the final stage of completion shall only be granted after the 
approval authority has verified, in accordance with the procedures laid down in Annex IX, 
that  the  type  of  vehicle  approved  at  the  final  stage  meets  all  applicable  technical 
requirements at the time of the approval. 

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Procedures to be followed during multi-stage type approval: 

o  Obligations and responsibilities of manufacturers (Article 13 and Annex IX) 
o 

In  the  case  of  multi-stage  type-approval,  and  in  addition  to  ensuring  that  vehicles, 
systems,  components  and  separate  technical  units  have  been  manufactured  and 
approved  in  accordance  with  article  5  and  Annex  II,  manufacturers  are  also 
responsible  for  the  approval  and  conformity  of  production  of  the  systems, 
components  or  separate  technical  units  they  may  have  added  and/or  modified 
(article 13).  

o  Manufacturers of the previous stage shall provide information to manufacturers of 
the  subsequent  stage  regarding  any  change  that  may  affect  component  type-
approval, system type-approval or separate technical unit type-approval or the whole-
vehicle type-approval (article 13). 

o  Given  the  degree  of  cooperation  required  the  multi-stage  type-approval  procedure, 
manufacturers  involved  in  the  process  should  be  able  to  supply  and  exchange 
relevant information and documents between them, including details of relevant 
system, component and separate technical unit type-approvals and of vehicle parts 
that form part of the incomplete vehicle but have not yet been type-approved. Before 
granting  first  and  subsequent  stage  type-approvals,  approval  authorities  should 
ensure  that  arrangements  enabling  the  sharing  of  this  information  exist 
between manufacturers (Annex IX).  

o  Each manufacturer is responsible for its own stage of construction and not for the 
ones  before  it,  except  where  the  manufacturer  modifies  relevant  parts  to  such  an 
extent that the previously granted type-approval is not valid anymore (Annex IX). 

•  Selected obligations of the approval authority (Annex IX) 

o  The  approval  authority  should  verify  that  all  issued  EU  type-approval  certificates 
correspond to the prescribed requirements and should make sure that the vehicle 
specifications and data are included in the data in the information packages and in the 
EU type-approval certificates issued in accordance with the relevant regulatory acts. 
o  The approval authority should carry out inspections of vehicle parts and systems 
on  a  selected  sample  of  vehicles  to  be  approved  to  verify  that  they  are  built  in 
accordance with the vehicles’ information package (including the information folder as 
per article 24, test reports and other relevant documents). 

•  Other selected applicable requirements (Annex IX) 

o  Multi-stage type-approvals shall be granted on the basis of the state of completion 
of the type of vehicle and shall incorporate all type-approvals granted at earlier stages. 
o  For the whole-vehicle approval, the Regulation applies in the same manner as if the 
approval would have been granted to the manufacturer of the base vehicle, namely 
the vehicle that is used at the initial stage of procedure.” 

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Figure 6-4  Step 1 of multi-stage type approvals: Base vehicle 

Source: ACEA/Volvo Interview 

Figure 6-5  Step 2 of multi-stage type approval: Bodybuilder 

Source: ACEA/Volvo Interview 

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6.2  Detailed  results  of  the  impact  analysis  for  Specific 

objective 1 (the scope of the Directive) 

6.2.1  List for selected impacts 

Based on the list of key impacts to be considered displayed elsewhere in this annex 6.6.2.5. 
the following list of impacts has been selected for the impact assessment of the scope.  

•  Administrative burden for public authorities 
•  Benefits through reporting 
•  Environmental  benefits  from  formalized  treatment  &  heavy  metal  restrictions/less  (hz) 

waste in receiving countries of export 

•  Health benefits from formalized treatment and heavy metal restrictions 
•  Administrative  burdens  on  businesses:  Costs  for  OEM  and  ATFs  for  Reporting  and 

• 

providing information 
Impacts for businesses:  
o  Costs for OEMs for change of design 
o  Burden for ATFs for authorization  
o  Revenues for dismantlers from spare parts 
o  Revenues for dismantlers and recyclers from recycling 
o  Revenues  from  exported  used  lorries  <->  lost  revenues  from  missing  vehicles  and 

exported used lorries 

o  Burden on stakeholders in the field of vehicles that are currently exempted 

•  Environmental benefits from increase of increase reuse and recycling  
•  Distribution effect: informal jobs to be formalized Employment -> Social/benefits for health 

and safety in receiving countries of export 

•  Distribution effect (economic): EPR + externalized costs will be internalized 
•  Additional burden for consumers in managing an ELV 

546 

 
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1 

Van 
(5t 
GVW
)  
1 

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6.2.2  Quantification of material streams  

Table 6-11 Material compositions of example lorries, buses, and L-type approved vehicles in kg (Summary of tables in chapter 
6.1.3) 

[kg] 

Lorries 

Rigid Truck 2 
(12t GVW)  

Curtain-sider (40t 
GVW) 

Buses 
Midibus (12t 
GVW)  

Coach (19t 
GVW) 

L1e-
B  

L-type-approved vehicles 
L3e-
A1  

L3e-A2+A3 

Car 

L5e 

L6e   Passen
ger car 

n= 

Steel 

Alumini
um 
Iron 

Copper 

Glass 

Plastic
s* 
Rubber 

Other 

Total  

1 

1 

1 

1 

7 

7 

15 

2 

4 

1 

3204,8 

1279 

3466 

152,3 

141 

400 

232 

119,3 

159,1 

23 

14 

728,5 

249 

280,7 

69 

88,7 

294 

5133,4 

2301 

55 

517 

20 

41 

214 

350 

1537 

6200 

9215 

519 

1543 

70 

43 

815 

844 

1501 

14550 

2116 

2940 

449 

20 

367 

1200 

211 

747 

8050 

6143 

41,8 

62,7 

2544 

17,9 

38,6 

1273 

34 

300 

1174 

0,0 

1,2 

0,1 

9,7 

388 

6,9 

1545 

3,4 

0,0 

2,9 

0,1 

19,6 

9,5 

7,3 

13401 

81,0 

140,6 

99,7 

95,2 

65,8 

75,7 

137
,3 
83,
5 
0,0 

0,0 

4,8 

0,6 

0,0 

3,9 

4,6 

0,0 

0,1 

15,2 

31,5 

11,1 

8,4 

6,5 

13,3 

203,6 

227,9 

24,
0 
17,
5 
5,6 

272
,6 

608,4 

108 

114 

10,8 

28,8 

240 

25,2 

69 

1204,2 

Based on data from 

(Wolff et al. 2020) 

(Ricardo-AEA 2015) 

(Ricardo-AEA 
2015) 

(ADEME and SURPLUS MOTOS 
2022) 

(Bouter et al. 
2020) 

Note: Material compositions represent an average based on ‘n’ examples (see line 2). 
(*) it is assumed that this represents thermoplastics. Foams and elastomers were included in “others” where primary data indicated these materials specifically. 
Source: as indicated in last line. 

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Table 6-12 Quantification of materials out of scope for stock 2020, expected ELVs in 2020 and expected ELVs in 2030 

for Stock 2020 

min (Van) 

max (curtainsider) 

min(midibus) 

max (coach) 

min (L1eB) 

max (L6e) 

min_total 

max_total 

total weight 

Steel 

Aluminium 

Iron 

Copper 

Glass 

Plastics 

Rubber 

Other 

total weight 

Steel 

Aluminium 

Iron 

Copper 

Glass 

Plastics 

Rubber 

Other 

2301 

8947,9 

986,4 

1623,1 

160,9 

97,9 

1742,0 

482,7 

2056,8 

14550 

64468,0 

3630,9 

10794,8 

489,7 

300,8 

5701,7 

5904,6 

10501,0 

8050 

1640,7 

2279,6 

348,1 

15,5 

284,6 

930,5 

163,6 

579,2 

13401 

4763,1 

1972,6 

987,1 

26,4 

232,6 

910,3 

300,8 

1198,0 

81,0 

932,0 

399,1 

0,0 

25,8 

3,2 

216,1 

153,5 

76,6 

272,6 

3060,9 

1862,6 

0,0 

102,3 

2,2 

535,0 

390,9 

124,6 

11520,5 

3665,1 

1971,2 

202,2 

385,7 

2888,6 

799,9 

2712,6 

72292,0 

7466,1 

11781,9 

618,3 

535,7 

7147,0 

6596,4 

11823,6 

for ELVs expected in 2020 

min (Van) 

max (curtainsider) 

min (midibus) 

max (coach) 

min (L1eB) 

max (L6e) 

min_2019 

max_2019 

2301 

271,2 

29,9 

49,2 

4,9 

3,0 

52,8 

14,6 

62,3 

14550 

1953,8 

110,0 

327,2 

14,8 

9,1 

172,8 

178,9 

318,2 

8050 

59,4 

82,5 

12,6 

0,6 

10,3 

33,7 

5,9 

21,0 

548 

13401 

172,4 

71,4 

35,7 

1,0 

8,4 

32,9 

10,9 

43,4 

81,0 

55,9 

23,9 

0,0 

1,5 

0,2 

13,0 

9,2 

4,6 

272,6 

183,5 

111,7 

0,0 

6,1 

0,1 

32,1 

23,4 

7,5 

386,4 

136,3 

61,8 

7,0 

13,5 

99,4 

29,8 

87,9 

2309,7 

293,1 

362,9 

21,9 

17,7 

237,8 

213,3 

369,1 

 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
STUDY TO SUPPORT THE  
IMPACT ASSESSMENT FOR THE REVIEW OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

for ELVs expected in 2030 

min (Van) 

max (curtainsider) 

min(midibus) 

max (coach) 

min(L1eB) 

max (L6e) 

min_2030 

max_2030 

total weight 

Steel 

Aluminium 

Iron 

Copper 

Glass 

Plastics 

Rubber 

Other 

2301 

336,6 

37,1 

61,1 

6,1 

3,7 

65,5 

18,2 

77,4 

14550 

2425,0 

136,6 

406,1 

18,4 

11,3 

214,5 

222,1 

395,0 

8050 

66,4 

92,2 

14,1 

0,6 

11,5 

37,6 

6,6 

23,4 

13401 

192,6 

79,8 

39,9 

1,1 

9,4 

36,8 

12,2 

48,5 

81,0 

65,1 

27,9 

0,0 

1,8 

0,2 

15,1 

10,7 

5,3 

272,6 

213,8 

130,1 

0,0 

7,1 

0,2 

37,4 

27,3 

8,7 

468,0 

157,2 

75,1 

8,5 

15,4 

118,3 

35,5 

106,1 

2831,4 

346,4 

446,0 

26,6 

20,9 

288,6 

261,6 

452,2 

Source: Material compositions: Table 6-11; vehicle stock in 2019: Eurostat (2021); expected ELVs: Oeko Model. 

549 

 
 
 
 
 
 
 
 
 
 
 
 
 
STUDY TO SUPPORT THE  
IMPACT ASSESSMENT FOR THE REVIEW OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

Table 6-13 Shares that vehicle categories have in the total sum of material quantities 
from waste lorries, buses and PTW (data for Figure 3-41) 

Av_Lorry 

Av_bus 

Av_PTW 

%_lorry  %_bus  %_PTW 

Alu_2020 

69,96825 

76,943262 

67,79012361 

33% 

36% 

32% 

Alu_2030 

86,84204055 

85,98713018 

78,97537168 

34% 

34% 

31% 

Copper_2020 

9,8591625 

0,757647 

3,838364164 

68% 

Copper_2030 

12,23683299 

0,846700407 

4,471687325 

70% 

5% 

5% 

27% 

25% 

Glass_2020 

6,0427125 

9,3583435 

0,163021282 

39% 

60% 

Glass_2030 

7,499994411 

10,45831799 

0,189919499 

41% 

58% 

Iron_2020 

188,1721875 

24,160521 

Iron_2030 

233,5524575 

27,00033519 

0 

0 

89% 

11% 

90% 

10% 

Other_2020 

190,2924375 

32,157906 

6,031406466 

83% 

14% 

Other_2030 

236,1840345 

35,93772837 

7,02657765 

85% 

13% 

1% 

1% 

0% 

0% 

3% 

3% 

Plastics_2020 

112,7973 

33,308407 

22,51209189 

67% 

20% 

13% 

Plastics_2030 

139,9998957 

37,22345862 

26,22654643 

69% 

18% 

13% 

Rubber_2020 

96,7894125 

8,4042695 

16,31926212 

80% 

Rubber_2030 

120,1314894 

9,392102659 

19,01191092 

81% 

Steel_2020 

1112,495175 

115,8778995 

119,6784395 

83% 

Steel_2030 

1380,788445 

129,4981233 

139,425166 

84% 

7% 

6% 

9% 

8% 

13% 

13% 

9% 

8% 

Averages calculated based on minimal and maximal values in Table 6-12. Shares were calculated using the average amount 
of the lorries compared to the total average.  

550 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STUDY TO SUPPORT THE IMPACT ASSESSMENT  
FOR THE REVIEW OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

Table 6-14 Material quantities from vehicles arriving at EoL in 2030 (variant with 40% reuse quota) 

tons 

Reuse 

High Quality Recycling 

Energy Recovery 

Losses 

Baseline/ 1A  1B 

1C 

Baseline/ 1A 

1B 

1C 

Baseline/ 1A 

1B 

1C 

Baseline/ 1A  1B 

1C 

Powered Two wheeler (L3e-A2) 

Steel 

27953 

27953 

37271 

64572 

64572 

55347 

0 

0 

0 

652 

Aluminium 

30750 

30750 

41000 

60987 

60987 

55349 

10224 

10224  6150 

538 

Iron 

0 

0 

0 

0 

0 

0 

Copper 

2233 

2233 

2977 

4429 

4429 

4019 

Glass 

258 

258 

345 

0 

0 

233 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

782 

603 

Plastic 

7079 

7079 

9438 

4955 

4955 

4955 

10984 

10984  9202 

578 

Rubber 

Other 

0 

0 

Bus (12 GVW) 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

15518 

15518  17242  1724 

9128 

9128 

10142  1014 

Steel 

19907 

19907 

26542 

45985 

45985 

39416 

0 

0 

0 

464 

Aluminium 

27659 

27659 

36879 

54857 

54857 

49786 

9197 

9197 

5532 

484 

652 

538 

0 

782 

603 

578 

1724 

1014 

464 

484 

99 

66 

559 

0 

0 

447 

284 

0 

0 

0 

398 

0 

84 

38 

Iron 

4224 

4224 

5632 

9758 

9758 

8364 

Copper 

188 

188 

251 

373 

373 

339 

Glass 

3453 

3453 

4604 

0 

0 

3107 

0 

0 

0 

0 

0 

0 

0 

0 

0 

99 

66 

8056 

8056 

3798 

Plastic 

11289 

11289 

15052 

7903 

7903 

7903 

17517 

17517  14676  922 

922 

0 

551 

 
 
 
STUDY TO SUPPORT THE IMPACT ASSESSMENT  
FOR THE REVIEW OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

Reuse 

High Quality Recycling 

Energy Recovery 

Losses 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

21083 

21083  23425  2343 

2343 

6617 

6617 

6617 

0 

0 

0 

0 

tons 

Misc. 

rubber 

Lorry (12 GVW) 

Steel 

253010 

253010  337347  584454 

584454 

500960 

0 

0 

0 

5904 

5904 

5060 

Aluminium 

12024 

12024 

16032 

23847 

23847 

21643 

3998 

3998 

2405 

210 

Iron 

31579 

31579 

42105 

72947 

72947 

62526 

Copper 

9418 

9418 

12558 

18680 

18680 

16953 

Glass 

12561 

12561 

16747 

0 

0 

11304 

0 

0 

0 

0 

0 

0 

0 

0 

0 

210 

737 

0 

632 

737 

3296 

3296 

1884 

29308 

29308 

13817 

Plastic 

57513 

57513 

76684 

40259 

40259 

40259 

89241 

89241  74767  4697 

4697 

Misc. 

Rubber 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

73868 

73868  73868  0 

0 

21008 

21008  23342  2334 

2334 

0 

0 

0 

Source: calculations by Oeko-Institut (2022) 

552 

 
 
 
STUDY TO SUPPORT THE IMPACT ASSESSMENT  
FOR THE REVIEW OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

6.2.3  Quantification of impacts 

Table 6-15 GWP benefits as discussed in chapter 0 (in million tons of CO2 equivalents)  

Reuse quota 

PTW (weighted average) 

Lorry (12t GVW) 

Bus (12t GVW) 

40% 

re-use 

high 
recycling 

quality 

BAU/1A 

1B 

1C 

BAU/1A 

1B 

1C 

BAU/1A 

1B 

1C 

-0,857 

-0,867 

-1,173 

-1,027 

-1,027 

-1,369 

-0,606 

-0,606 

-0,808 

-1,196 

-1,210 

-1,109 

-1,263 

-1,263 

-1,123 

-0,840 

-0,840 

-0,763 

energy recovery 

-0,233 

-0,236 

-0,174 

-0,237 

-0,237 

-0,199 

-0,182 

-0,182 

-0,135 

Sum 

-2,287 

-2,312 

-2,456 

-2,527 

-2,527 

-2,691 

-1,628 

-1,628 

-1,706 

Delta BAU-C 

0,169 

0,165 

0,078 

70% 

re-use 

high 
recycling 

quality 

BAU/1A 

1B 

1C 

BAU/1A 

1B 

1C 

BAU/1A 

1B 

1C 

-0,857 

-0,867 

-2,052 

-1,027 

-1,027 

-2,396 

-0,606 

-0,606 

-1,415 

-1,196 

-1,210 

-0,555 

-1,263 

-1,263 

-0,562 

-0,840 

-0,840 

-0,381 

energy recovery 

-0,233 

-0,236 

-0,113 

-0,237 

-0,237 

-0,130 

-0,182 

-0,182 

-0,089 

Sum 

-2,287 

-2,312 

-2,720 

-2,527 

-2,527 

-3,088 

-1,628 

-1,628 

-1,885 

Delta BAU-C 

0,433 

0,562 

0,257 

553 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STUDY TO SUPPORT THE IMPACT ASSESSMENT  
FOR THE REVIEW OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

Table 6-16 Expected losses of material and revenue due to unknown whereabouts and Extra EU Exports in 2020 

expected losses due to unknown whereabouts in 2020 

Extra EU Exports  

Motorcycles 

lorries 

buses 

used  motor-
cycles 

used lorries 

used buses 

[tons] 

Euro 

[tons] 

Euro 

[tons] 

Euro 

[tons] 

Euro 

[tons] 

Euro 

Steel 

 7.344.755  

 38.971  

 7.290.693  

no data 

                   673.542  

 38.512  

 7.204.772  

39.260  

305.985  

57.243.763  

126.006.324  

Aluminiu
m 

25.311  

 8.815.618  

 15.461  

 25.877  

 26.534.988  

                      34.033  

 25.572  

15.854.001  

34.898.201  

26.222.27
2  

Iron 

 -    

- 

 47.988   No data 

 8.125  

No data 

                   105.633   No data 

 8.030  

No data 

Copper 

 1.557  

 9.789.924  

 4.141  

 255  

 1.601.737  

                        9.115  

 252  

 1.582.860  

26.031.227  

57.300.551  

Glass 

 79  

 1.454  

 4.583  

 83.963  

 3.147  

 57.659  

                      10.089  

 3.110  

 56.979  

184.822  

Plastics 

 8.982  

 3.593  

 35.769  

 14.307  

 11.202  

 4.481  

                      78.735  

 11.070  

 4.428  

31.494  

Rubber 

 4.793   No data 

 27.519   No data 

 2.826  

No data 

                      60.574   No data 

 2.793  

No data 

Other 

 3.242   No data 

 60.979   No data 

 10.815   No data 

                   134.227   No data 

 10.688  

No data 

Sum 

 35.489.557  

                1.105.949  

 100.026  

83.225  

25.955.344  

502.425  

99.227.261  

101.219  

-    

218.421.391  

35.071.31
2  

Assumptions: 70% cast, 30% wrought aluminium. Revenues from materials as in table xx (under circularity), 34% unknown whereabouts according to (Mehlhart et al. 2017), export data as 
provided in the problem description 

554 

 
 
 
 
 
 
 
 
 
           
 
 
 
             
 
 
 
 
             
 
                   
 
                      
 
 
 
 
 
 
 
                               
           
 
 
STUDY TO SUPPORT THE IMPACT ASSESSMENT  
FOR THE REVIEW OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

Table 6-17 Administrative cost (recurrent) according to BRG model, scope extension  

ELV Impact assessment - subsection on scope 

No. 

Concrete activity 

   Policy Option 1A 

1a 

A1 

Information to 
waste operators 

1b 

A1 

Information to 
waste operators 

2  A2 

3  A2 

Reporting on 
treated ELVs to MS 
authority 
Reporting on 
treated ELVs to 
Eurostat 

Policy Option 1B 

4a  B1 

Supply chain 
management 

4b  B1 

Supply chain 
management 

5  B2 

Authorisation 
process 

6  B2 

Authorisation of 
dismantling facilities 

Type of 
obligation 

Description of 
required 
action(s) 

Target group 

HDV 
manufacturers 
and their 
suppliers 
L-cat 
manufacturers 

ATFs/ 
dismantlers 

Member 
States- waste 
authorities 

HDV 
manufacturers 
and their 
suppliers 

L-cat 
manufacturers 

ATFs/ 
dismantlers 

Member 
States- waste 
authorities 

Submission of 
(recurring) 
reports  

Submission of 
(recurring) 
reports  
Submission of 
(recurring) 
reports  
Submission of 
(recurring) 
reports 

Notification of 
(specific) 
activities or 
events  

Notification of 
(specific) 
activities or 
events  

Certification of 
products or 
processes 

Submission of 
(recurring) 
reports 

Filing forms 
and tables 

Filing forms 
and tables 

Filing forms 
and tables 

Filing forms 
and tables 

Retrieving 
relevant 
information 
from existing 
data 
Retrieving 
relevant 
information 
from existing 
data 

Filing forms 
and tables 

Inspecting 
and checking 
(including 
assistance to 
inspection by 
public 
authorities) 

f
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25,73 

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206  0 

25,73 

480,00 

206  3 

14 

16 

0 

48 

0 

100% 

0 

9.869 

0% 

9.869 

25,73 

480,00 

206  1 

4.500 

4.500 

925.200 

0% 

925.200 

25,73 

960,00 

411  1 

27 

11.102 

11.102 

75% 

2.776 

25,73 

480,00 

206  1 

14 

25,73 

480,00 

206  1 

16 

14 

16 

2.878 

0% 

2.878 

3.290 

0% 

3.290 

25,73  1.920,00 

822  1 

4.500 

4.500 

3.700.800 

0% 

3.700.800 

25,73  1.440,00 

617 

0,
1 

4.500 

450 

277.560 

0% 

277.560 

555 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
STUDY TO SUPPORT THE IMPACT ASSESSMENT  
FOR THE REVIEW OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

ELV Impact assessment - subsection on scope 

f
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7  B3 

Notify vehicle 
registers 

8 

B3 

Notify vehicle 
registers 

9 

B3 

Notify vehicle 
registers 

Business 
owners 

ATFs/ 
dismantlers 

Citizen 
owners 

Notification of 
(specific) 
activities or 
events  

Notification of 
(specific) 
activities or 
events  

Notification of 
(specific) 
activities or 
events  

Submitting 
the 
information 
(sending it to 
the 
designated 
recipient) 
Submitting 
the 
information 
(sending it to 
the 
designated 
recipient) 
Submitting 
the 
information 
(sending it to 
the 
designated 
recipient) 

25,73 

5,00 

2  1 

400.000 

400.000 

856.667 

33% 

573.967 

25,73 

10,00 

4  1 

2.024.242 

2.024.242 

8.670.504 

33% 

5.809.237 

25,73 

5,00 

2  1 

1.624.242 

1.624.242 

3.478.585 

33% 

2.330.652 

New administrative costs - 
Business (€) 
New administrative costs – 
citizens (€) 
New administrative costs – 
Member States (€) 
Total new administrative costs (€) 

11.025.241 

2.330.652 

280.336 

13.636.229 

Assumptions 

1a  Information to waste operators, 8 truck manufacturer in the EU (https://www.eea.europa.eu/data-and-maps/daviz/hdv-market-share-for-vehicle#tab-chart_1); BAU is assumed to be 100% 
of annual costs as reporting is already established on a voluntary basis; 3 new models per year; unclear whether already voluntarily existent for buses and trailers, therefore assuming 6 
"others" entities 

1b  16 motorbike manufacturers in the EU according to ACEM interview 

2  Taking into account that 15% (per unit) of vehicles are not in scope today and assuming the identical additional share for ATFs might be required for the dismantling of PTW, lorries, 
buses and (semi-) trailers, this results in a number 4.500 ATFs being required for vehicles other than M1 and N1 (~ 30 000) 

3  Reporting on treated ELV to Eurostat, MS already report on M1 and N1 ELVs, the format can be the same for other vehicles, thus, 75% of the costs occur in the baseline 

4a  For number of HDV manufacturers, see no 1a 

556 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
4b  For number of L-cat manufacturers, see no 1b 

5  For number of ATFs, see no 2 

STUDY TO SUPPORT THE IMPACT ASSESSMENT  
FOR THE REVIEW OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

6  Authorisation of dismantling facilities, assuming 10% of the ATFs being checked per year for number of ATFs, see no 2 

7  Vehicle owners to receive and store CoD documents, 0,4 Mio = sum of expected waste lorries, buses and trailers; Business owners assuming that in 1/3 of the EU MS CoD requirements 
exist in the national legislation 

8  ATFs to print and provide CoD to vehicle owners & notify vehicle registers 

9  Vehicle owners to receive and store CoD documents, 1.62 Mio = sum of expected waste L-cat; Citizen ownerships assuming that in 1/3 of the EU MS CoD requirements exist in the 
national legislation 

Table 6-18  Administrative cost (one off) according to BRG model, scope extension Fehler! Keine gültige Verknüpfung.

557 

 
 
 
STUDY TO SUPPORT THE  
IMPACT ASSESSMENT FOR THE REVIEW OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

Table 6-19 Prices (Euro) per kilo of HDVs exported from Netherlands  

Source: (Netherlands Ministry of Infrastructure and Water Management, Human Environment and Transport Inspectorate 2020) 

Examples  of  low-price  used  HDVs  exported  to  African  countries  from  the  same  study  (Dutch 
Ministry of Infrastructure and Wastewater) are:  

•  a Mercedes-Benz 1622 truck from 1994, with a weight of 7,500 kilos and a price of 2,950 (39 

Eurocents/kilo) 

•  a  DAF  truck  from  1996,  with  a  weight  of  6,720  kilos,  exported  for  a  price  of  8,300  Euros  to 

Ghana (1.24 Euro/kilo) 

•  a Scania truck from 1997, with a weight of 12,825 kilos, exported for a price of 18,300 Euros to 

The Gambia (1.43 Euros/kilo) 

•  a Renault Truckhead Premium 400 from 1999, with a weight of 6,430 kilos and a price of 6,000 

Euros (93 Eurocents/kilo) to Côte D’Ivoire  

•  a DAF truck AE65CC from 2002 with a weight of 11,180 kilos and a price of 7,250 Euros (65 

Eurocents/kilo) to Burkina Faso. 

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6.3  Detailed  current  situation  of  Specific  objective  2 

(circularity) 

6.3.1  Additional information on materials used in vehicles 

6.3.1.1  Glass 

Different types of flat glass are used in the production of vehicles (Glass for Europe 2022).  

•  Windshields are usually made of laminated safety glass, which consists of two or more 
curved sheets of glass sealed together with a plastic interlayer (polyvinyl butyral, PVB) 
inserted  between  them,  which  keeps  the  windshield  intact  in  the  event  of  a  collision. 
Laminated  safety  glass  is  more  complex  to  get  recycle-ready,  since  the  plastic  sheet 
needs to be removed prior to recycling. 

•  Side  and  rear  windows  are  generally  made  of  tempered  glass,  which  is  stronger  than 
ordinary  glass.  Tempered  glass  provides  enhanced  safety  as  it  fractures  into  small, 
relatively harmless pieces when it breaks. This type of glass is ‘purer’ as there is no plastic 
laminate  to  remove,  however  its  collection  is  more  difficult  as  it  can  shatter  in  small 
fragments during its dismantling from the car. 

The removal of the glass pieces from the vehicle is the first essential step (Glass for Europe 
2022) towards recycling. When removal is undertaken, it requires several minutes of manual 
work because fixed glazing is bonded to the vehicle body. Once removed from the vehicle, 
glass needs to be sorted by type, i.e. laminated, tempered, silver printed rear windows, etc. 
This separation must be with an adequate size, purity, and colour sorting system, to avoid 
contamination. The average time for this operation is of the order of 30-40 minutes per vehicle 
and involves a cost of approximately €1,000 per tonne. The decision regarding the treatment 
of end-of-life vehicles lies in the hands of dismantlers (Authorised Treatment Facilities, ATFs) 
which balance time, costs, and benefits. Currently, most of the glass in end-of-life vehicles is 
not recovered 

According to FEAD (2022), “the manual dismantling of glass in an end-of-life vehicle is time-
consuming and at the end of the process it is deposited in a container, where it breaks. The 
same result is obtained when separation is carried out destructively. In this case, however, 
collecting all the fragments can be more difficult and losses increase”. FEAD confirmed the 
20% loss rate assumed by the consultants when glass windows are dismantled destructively. 
“There are technologically more advanced systems that can achieve better results, but these 
technologies can only be afforded by large plants capable of processing a large number of 
vehicles  (>  10,000  per  year),  and  thus  amortise  the  investment  costs.  Most  Authorised 
Treatment Facilities (ATFs), however, are Small Medium Enterprises (SMEs) and work in a 
completely different way and with smaller equipment.” 

EGARA (2021) also referred to the advantages of destructive dismantling, stating that “the 
80%-20% percent rule may be wise to apply in some cases. Taking out most for low costs is 
much better than taking out 100% for sky high costs”. 

OVAM  (2012?)  performed  an  analysis  of  the  legislation  and  practice  in  other  European 
countries that shows that selective glass removal is not widely applied. A few examples of the 
situation in various Member States: 

• 

In most member states the shredder option is the preferred choice and glass is recycled 
mainly in the road construction sector. 

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• 

In  Flanders  and  Belgium,  glass  currently  follows  the  PST  route:  after  shredding  of  the 
discarded vehicle, which still contains the glass, the glass ends up in the mineral fraction 
which is then recycled into construction material. 

•  Denmark: The government claims that removal was applied in the past because two out 
of  three  shredder  facilities  could  not  demonstrate  convincingly  that  their  post  shredder 
glass  fraction  was  being  recycled.  As  a  result  of  technological  improvements,  today 
almost all of the glass passes through the shredder facilities. The post shredder fraction 
containing  the  glass  is  recycled  in  the  road  construction  industry.  Shredder  facility  HJ 
Hansen confirms that glass currently goes into the shredder. They ask about 100 Kroner 
(roughly € 12) extra for ELV including glass and plastic. According to HJ Hansen this is 
not  enough  to  cover  the  costs  for  manually  removing  the  glass  and  plastics  prior  to 
shredding the ELV. 

•  Germany: Some sources indicated that certain companies remove glass from ELV, but 
this was not confirmed (no response from these companies). Removed glass originating 
from glass repair companies is being processed at glass recycling facilities, which might 
create  the  assumption  that  this  includes  ELV  glass.  The  different  responses  seem  to 
indicate that removal took place in the past but is not widely practised today because in 
modern cars the windscreens usually are glued to the frame, which makes them hard to 
remove. One contact stated that the price offered by glass processing companies, whilst 
already receiving a large amount of glass from other sources, is not high enough to justify 
the costs (a so-called fee gate of € 0). Another contact mentioned a removal time of 30 
minutes for glass (own estimate), but he referred to Carglass, which feeds the assumption 
that this involves the removal time for reuse. A 2008 calculation carried out by the regional 
authorities  for  the  Baden-Württemberg  region  puts  glass  removal  costs  at  an  amount 
between € 4.60 and € 8 per ELV for the dismantler. This equals € 225 to € 350 per tonne 
of glass. PST is available in Germany (e.g. in Eppingen) at a cost between € 2.80 and € 
4.20 per ELV. 

•  France. In general it appears that ELV glass is not being removed. In France ELV glass 
will have to be removed in the future, namely as from 1 July 2013. However, there are 
signals  that  even  after  that  date  the  obligation  will  not  be  enforced  because  additional 
research is required to organise the removal process. Some people indicate that glass is 
already being removed from ELV within the INDRA network, the French key player in ELV 
recycling (500 000 wrecks handled in 2010), but this was not confirmed by INDRA (no 
response). France has had several studies carried out, among other things about glass 
removal.  For  reasons  of  confidentiality  not  all  the  information  was  revealed,  but  it  was 
indicated  that  removal  costs  range  between  €  6.00  and  €  8.00  per  ELV.  These  costs 
consist  of  €  1.00  to  €  1.25  for  collecting  and  processing;  €  5.00  to  €  6.75  for  labour 
involved in the dismantling procedure (based on an hourly wage of € 15 to € 20 and 15 to 
20  minutes  removal  time).  The  costs  are  exclusive  of  tools  and  storage  costs.  The 
calculation is based on a study carried out in 2003 and 2004. The figures are not totally 
reliable, first of all because they are outdated and secondly because government officials 
use different figures in several communications. 

•  Hungary:  Information  from  Hungary  came  from  one  source  only,  namely  a  member  of 
Egara. He stated that Hungary recently adopted legislation that makes glass removal prior 
to  shredding  mandatory,  but  that  the  follow-up  to  the  legislation  is  currently  being 
investigated.  In  view  of  the  fact  that  Hungary  only  just  managed  to  meet  the  recycling 
targets laid down in the ELV Directive and of the even higher targets to be met as from 
2016, it is not unlikely that Hungary has imposed the obligation so as to be able to comply 
with the 2016 targets. 

•  Netherlands: The Netherlands is one of the few countries where the removal of flat glass 
from  ELV  occurs  on  a  large  scale  thanks  to  financial  support  from  ARN.  ARN  has 
estimated the removal time of ELV glass at 18 minutes and pays the dismantling centres 

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a contribution of € 19. the system has resulted in large-scale removal of glass from car 
wrecks. In September 2011 the law was changed, abolishing the previously mandatory 
removal  of  glass  prior  to  shredding.  The  key  premise  of  the  new  legislation  is  that  the 
recovered  material  must  be  recyclable  and  that  in  terms  of  environmental  effects, 
shredding glass must be a proper alternative for removal prior to shredding. The centres 
indicate  that  if  the  financial  support  from  ARN  should  be  discontinued,  they  will  stop 
removing the glass. 

• 

•  Austria applies a legal obligation to at least remove the windscreen prior to shredding. As 
a general rule, the law allows other solutions provided that they are similar in terms of 
environmental  impact.  Despite  existing  PST,  Austrian  ELV  processing  companies  do 
remove the ELV glass. As far as we know they do not receive a financial contribution. The 
sector does not oppose to the legislation which came into being in consultation with the 
industry. 
In Poland it is mandatory to remove glass prior to shredding. This has been confirmed by 
both  the  government  and  the  federation  of  ELV  recyclers/dismantlers.  In  practice  it 
involves  a  system  of  manufacturer  responsibility  which  is  comparable  to  the  Dutch 
system. A contribution for ELV treatment of 500 Polish Zloty per tonne applies, roughly € 
120. Manufacturers and importers must pay the contribution for each newly produced or 
imported vehicle. The same amount is transferred to the authorised treatment facilities 
per tonne of processed ELV. The source of the calculation method for this contribution 
was not revealed. For comparison: in the Netherlands a payment applies of € 55 for all 
materials. 

•  Portugal:  National  legislation  dictates  removal  of  glass  prior  to  shredding  the  ELV. 
Manufacturer responsibility has been set up to organise the processing of ELV. Glass is 
being removed and recycled at a large scale. All of the glass has to be removed. In newer 
cars  with  glued  windscreens, the  glass  is removed  using  a  jig saw  which  cuts  into the 
glass  itself.  In  older  cars  either  the  same  technique  is  used,  or  the  rubber  is  cut.  No 
contribution  is  provided  for  glass  removal  (the  same  applies  to  other  fractions  to  be 
removed or depolluted). However, the umbrella organisation Valorcar has negotiated a 
‘good' price for glass removed from ELV: € 0 instead of a negative value of about € 35 - 
€  50  per  tonne.  Transport  costs  are  borne  by  the  ELV  recyclers.  Portugal  has  four 
shredder facilities, but no PST. PST is expected to be introduced in the future, after which 
glass most likely will no longer be removed. 

•  Spain: Glass removal is not mandatory in Spain if the glass is recycled after shredding. 
However, some regions impose an obligation of glass removal prior to shredding the ELV. 
According to Sigrauto (the Spanish association for treatment of discarded vehicles) these 
regions apply a stricter interpretation of the European Directive when it comes to glass 
processing. In view of the limited number of PST facilities in Spain, it is not unlikely that 
some regions impose glass removal prior to shredding in view of the absence of sufficient 
geographic  spread  of those  facilities.  There  is  neither  financial  compensation  for  glass 
removal, nor a positive gate fee for processing the removed glass. 

•  Sweden: Legislation dictates that glass has to be removed from ELV but to which extent 
this actually occurs is unclear. PST was not available at the time the legislation entered 
into force. 

There are technical obstacles to allow reuse of ELV glass cullet in the manufacture of new 
vehicle  glass  (flat  glass).  According  to  Glass  for  Europe  (2022),  the  Automotive  glass 
products necessitate the highest quality and purity to ensure unaltered visibility and safety. 
Contaminants in raw materials and cullet generate production defects but can also jeopardise 
the  glazing  structure  and  make  serious  damage  to  the  industrial  equipment7.  For  these 
reasons, the flat glass industry has the most stringent quality specifications for sourcing cullet. 
(Glass for Europe 2022) 

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Because quality specifications for recycled glass are not as strict in other glass sectors as in 
the  flat  glass  sector,  for  instance  in  container  glass  or  glass  fibre,  for  which  visibility  and 
transparency are not essential selling points, some flat glass cullet of automotive origin may 
be used by these glass sectors at a lower quality level and cost than what could be possible 
in flat glass manufacturing. (Glass for Europe 2022) 

6.3.1.2  EEC 

Groke et al. (2017) explains that based on their research, 30 most relevant components were 
identified  to  focus  on  in  their  study  as  having  the  highest  priority  for  dismantling  and  10 
alternative components which could be subject to dismantling if other parts of the list are not 
present in a vehicle, as well as the electric inverter of hybrid vehicles. He list of components 
is reproduced below. 

Restrepo et al (2017) analyses critical metals (CM) in passenger vehicles that are contained 
in  electronic  control  systems  (ECS).  For  analysis  purposes,  ECSs  are structured  into  sub-
layers comprising EE devices embedded in vehicles (sensors, controls and actuators). The 
ECS consist of electronic/electric parts that in turn contain EE components. The metals Ag, 
Au,  Pd,  Ru,  Dy,  La,  Nd,  and  Co  represent  the  endpoint  of  the  analysis.  The  flow  of  ELV 
analysed refers to reference year 2014 – from the perspective of 2017, the publication year 
of the analysis, the situation in 2022 may correspond to the material composition of ECS in 
vehicles newly put on the market by then. 

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The authors calculated the average (median) content of CM per selected EEC in passenger 
vehicles. Results (see Table 6-20) show that rare earth elements and cobalt reside almost 
exclusively  in  permanent  magnets,  which  are  predominantly  used  in  actuators  (electric 
motors). Other precious metals in turn occur in PWBs, that function as controllers in vehicles.  

Table 6-20 Distribution of CM mass in EE devices in an average passenger vehicle. 

Source: Restrepo et al (2017 SI) 

Note: All values in % 

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Further, Restrepo et al (2017): 

ECS-parts in Vehicles 

Material composition  

Number of 
occurrences 
per car 

Airbags 

Vehicle dynamics control 
systems* 
Sound system (incl. 
Radio/CD) 
Power windows 

Central locking/keyless 
access 
Power mirrors 

Driver information 
system/OBDS 
Daytime running lamps 

Electronic power steering 

Navigation system (incl. 
DVD) 
Electronic immobilizer 

De-activation of co-driver 
airbag 
Fog lights1 

Adaptive cruise control 

Light assistance 

Adaptive lights 

Stop-start system 

Manual H/AC 

Automatic H/AC 

Tire pressure monitoring 
system 

Multifunction steering 
wheel1 

Parking assistance 

Multifunction display1 

Multimedia socket1 

Pre-installation kits 

Third brake light1 

3 

2,6 

1,3 

0,9 

0,9 

0,75 

0,55 

0,55 

0,5 

0,5 

0,5 

0,5 

0,5 

0,45 

0,45 

0,4 

0,4 

0,4 

0,3 

0,3 

0,3 

0,3 

n.a. 

n.a. 

n.a. 

n.a. 

The CMs are located in various ECSs in vehicles, the most important of which (by mass per 
unit) are listed in the following table: 

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Number of 
parts per 
car 

Qualitative 
mass  
estimation* 

xl 

xl 
l  

  l 

  l 

xl 

 m 

 m 

 m 

 m 

 m 

 m 

 m 

 m 

 m 

 m 

 m 

 m 

 m 

m 

Device 
type  

Device name 

Actuator  

Radiator fan motor 

Actuator  

Alternator 

Actuator  

Air dam 

Actuator  

Starter motor 

Actuator  

Battery 

Actuator     Motor/Generator 

Actuator 

Multifunction display 

Main 
component  
containing 
CMs  
Magnet 

Magnet 

Others 

Magnet 

Others 

Magnet 

LCD 

Actuator 

Flaps in front splitter and/or rear diffuser  Magnet 

Actuator 

Rear airbrakes 

Actuator 

Rear spoiler 

Actuator 

Grill shutters 

Actuator 

Speakers 

Actuator 

Shock absorbers 

Actuator  

Hydraulic modulator 

Actuator 

Dashboard  

Actuator  Wheel brakes 

Actuator 

AC Compressor  

Actuator 

Electrical radiator blowers  

Actuator 

Electronic power steering motor  

Actuator 

Steering column adjuster  

Actuator 

Charge and discharge actuator  

Actuator 

Power inverter  

Actuator 

Radio  

Actuator 

Brake master cylinder 

Actuator 

Headlights  

Actuator 

2-4 wheel drive actuator  

Actuator  Windscreen wiper motor  

Actuator 

Rear wiper motor  

Actuator 

Defogger motor  

Actuator 

DC brushless motors  

Controller    Battery Management System  

Controller    Convertible Top Control  

Controller    Electronic Power Steering  

Controller    Electronic Valve Timing  

Controller   Energy management (EM)  

Controller   

ICE Control Module  

Controller    Entertainment Systems  

Controller    Lane keeping assistance  

Controller    Motor/Generator Control Unit  

Controller    On-Board Diagnostic Systems  

Controller    Power source management  

Controller    Transmission Control  

Others 

Magnet 

Magnet 

Magnet 

Solenoid 

Magnet 

PWB  

Others  

Magnet 

Magnet 

Magnet 

PWB  

PWB  

PWB 

Others  

Others  

Magnet 

Magnet 

Magnet 

Magnet 

Magnet 

PWB 

PWB 

PWB 

PWB 

PWB 

PWB 

PWB 

PWB 

PWB 

PWB 

PWB 

PWB 

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Device 
type  

Device name 

Controller    Engine Data Scan  

Main 
component  
containing 
CMs  

PWB 

Number of 
parts per 
car 

Qualitative 
mass  
estimation* 

Restrepo et al (2017) recommend “Dismantling these devices before ELV shredding, as well 
as post-shredder treatment of automobile shredder residue may increase the recovery of CMs 
from ELVs. Environmental and economic implications of such recycling strategies must be 
considered.” 

6.4  Detailed  results  of  the  impact  analysis  for  Specific 

objective 2 (circularity) 

6.4.1  Screening measures and separate discarded options 

The table below displays the criteria for screening.  

III. Screen your options and separate discarded options 

Why? 

To focus the analysis on the viable options. In choosing the options, it is important to focus 
on those elements that are most critical for the Commission to decide on (i.e., those with 
significant impacts). As with the problem analysis, you must ensure that the report remains 
focused and that it does not drown the major issues in a ‘flood’ of minor issues. 

Excluding options at this stage should be clearly justified. Reasons should be as clear, self-
evident  and  indisputable  as  possible.  The  report  should  explain  when  it  had  to  discard 
policy  options  favoured  by  stakeholders.  This  should  be  done  in  a  separate  section  on 
discarded options (if necessary, with further details in the annexes). 

The key criteria for screening the viability of your options are: 

Legal feasibility 

How? 

Options should respect the principle of conferral350. They should also respect any obligation 
arising from the EU Treaties (and relevant international agreements) and ensure respect of 
fundamental  rights.  Legal  obligations  incorporated  in  existing  primary  or  secondary  EU 
legislation may also rule out certain options. 

Technical feasibility 

Technological and technical constraints may not allow for the implementation, monitoring 
or enforcement of theoretical options. 

Previous policy choices 

350 Under this fundamental principle of EU law, laid down in Article 5 of the Treaty on European Union, the EU acts only within 
the limits of the competences that EU countries have conferred upon it in the Treaties. These competences are defined in 
Articles 2–6 of the Treaty on the Functioning of the EU. Competences not conferred on the EU by the Treaties thus remain 
with EU countries. 

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III. Screen your options and separate discarded options 

Certain options may be ruled out by previous policy choices or mandates by EU institutions. 
Unless there is compelling evidence that these choices should be revisited, there is no point 
in reinventing the wheel. 

Coherence with other EU policy objectives 

Certain options may be ruled out early due to poor coherence with other general EU policy 
objectives. 

Effectiveness and efficiency 

It may already be possible to show that some options would with certainty achieve a worse 
cost-benefit balance than some alternatives. 

Proportionality 

Some options may clearly restrict the scope for national decision-making over and above 
what is needed to achieve the objectives satisfactorily. 

Political feasibility 

Options  that  would  clearly  fail  to  garner  the  necessary  political  support  for  legislative 
adoption or implementation could also be discarded. This, however, does not mean that 
such options should not be mentioned or not be subject to at least a minimal assessment. 
Options superior to other options but lacking political feasibility may still be discussed at 
the legislative stage, which may increase their chances of being politically feasible. 

Relevance  

There is no point in retaining options that do not address the needs of the policy intervention 
as identified in the problem definition. 

Identifiability 

When  it  can  be  shown  that  two  options  are  not  likely  to  differ  materially  in  terms  of  the 
proposed  measures,  their  significant  impacts  or  their  distribution,  only  one  should  be 
retained. 

Source:  Better Regulation toolbox Tool #16, Textbox page 114 – 115 

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In the following the potential measures for circularity objectives 2.1 through 2.3 are assessed 
against these criteria and a justification is given for the case that an option is considered as 
discarded. The numbers in the column “Viability screening” refer to the numbering of the key 
criteria for screening as displayed in the table above.  

Table 6-21 Initial assessment of measures to identify discarded and short-listed 
measures 

Measure  

Viability 
screening 

addressing Specific Objective No 2.1 

Effectiveness  Comment, Discard justification 

2.1.a) OEM voluntary pledges 
campaign to increase 
circularity 

5. & 9. 

2.1.b) EC non-binding 
guidelines on how to improve 
circularity in vehicles 

5. & 9. 

2.1.c) Obligation for OEMs to 
develop and implement 
circularity strategy 

2.1.d) Improving the relation 
between the 3R Type 
approval process and ELV 
waste management 
performance: 

Revision of 3R Type Approval 
calculation 

General 

feasibility 

4.(*) 

Multi-stage vehicle inclusion 
in 3R Type Approval 

feasibility 
differs for 
vehicle 
categories 

Dismantling and shredding 
tests  

Low, as 
assumed to 
mainly motivate 
actions of 
OEMs already 
more advanced 
in circularity 
and has a risk 
of not leading to 
continuous 
improvements 
and benefits 

Unclear to what 
degree such 
guidance is 
applied and 
leads to 
improvements 

Flexibility 
related to how 
OEMs develop 
strategy and 
implement 
expected to 
increase 
efficiency  

Effectiveness 
could vary 
between the 
sub-measures 

Expected to 
ensure use of 
non-recyclables 
only when 
justified 
environmentally 

Limited 
effectiveness 
expected for 
some vehicle 
categories 

Higher results expected by enforcing 
measure 2.1.c  

 discarded 

Higher results expected by enforcing 
measure 2.1.c  

 discarded 

 Short list   

 Short list 

 Short list for trucks 

Low 
effectiveness: 

 Short list 

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Measure  

Viability 
screening 

Effectiveness  Comment, Discard justification 

2.1.e Submission of carbon 
footprint LCA data as part of 
the 3R type approval process 
to justify use of non-
recyclables 

Transition 
period will 
delay 
incurring 
benefits 

2.1.f) Obligatory reporting 
requirements on the use of 
materials that affect 
dismantling and recyclability 
to facilitate identification of 
incompatible practices 

impacts will 
incur slowly as 
only few 
vehicles tested 

Only effective in 
combination 
with measure 
2.1.d  

Improving 
communication 
on 
(in)compatible 
materials and 
techniques 
expected to 
lead to more 
effective design 
for circularity 

 Short list 

 Short list 

Short-list - Feasible for plastic and possibly 
also for NdFeB magnets (**) in the longer 
term. Situation for glass could be revisited 
in the further future  

 Short list 

Situation for rubber unclear as recycling 
technologies are under development  

 discarded 

Partially covered by other legislation, 
horizontal legislation more appropriate  

 discarded 

Supportive measure – will only result in 
improvements in combination with other 
measures 

 Short list 

Alignment of the definition and clarity on 
the status of the removed components 
shall reduce administrative burdens of 
(trans-national) shipment. 

 Short list   

2.1.g) Establishment of 
mandatory recycled content 
targets for materials used in 
cars 

Effective only 
for some 
materials 

2 for rubber 

2.1.h) Obligatory due 
diligence for materials used in 
vehicles 

8. & 9. 

Low at vehicle 
level 

2.1.i) Set out an obligation for 
OEMS to provide additional 
information on composition of 
cars, either through existing 
platforms of digital product 
passport 

addressing Specific Objective No 2.3 

2.3.a) Clarify definition of re-
use in the ELV Directive vs 
re-use and preparing for re-
use in the Waste Framework 
Directive 

Effectiveness 
will depend on 
the level of 
harmonisation, 
means of 
access and 
actual use of 
data by profiting 
stakeholders 

Moderate 

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Measure  

Viability 
screening 

Effectiveness  Comment, Discard justification 

A clear definition shall promote 
remanufacturing and help distinguish it 
from practices that do not achieve a 
minimum quality. Similarly, to measure 
2.2.a it shall reduce administrative burdens 
of (trans-national) shipment. A possible 
limitation of use of remanufactured 
components may occur in the case of their 
application in damaged newly 
manufactured vehicles and in construction 
of new vehicles since this issue is not 
legally clarified and for some OEMs is not 
considered as an option (due to definition 
of new vehicle). As described above, it is 
unclear if assembling an entire car from 
remanufactured parts is technically 
feasible. Additionally, some components of 
ELVs cannot easily be installed in new 
vehicles, once outdated. These technical 
aspects may limit the viability of some of 
the sub-measures, influencing the option 
to use remanufactured/used components 
in new vehicles. The option is still 
considered for assessment as it is 
considered to have a high effectiveness.  

 Short list   

It might be possible to achieve similar 
results by enforcing measure 2.2.b  

 discarded 

Good Public Procurements may have an 
added benefit of raising employee 
awareness to reuse and remanufacturing 
practices. However, implementation of 
GPP rules is an individual decision of MS. 

 discarded 

The market for reused components is 
dynamic – increasing demand is assumed 
to provide more flexibility to ATFs to 
decide on components to be dismantled as 
opposed to measures for increasing 
supply which could result in a high burden 
for storage without significant impact on 
the actual reuse/remanufacturing of 
components. 

 Short list   

Harmonising monitoring will allow 
understanding the actual volume of reuse 
in different MS on a comparable basis and 
could allow identifying where reuse could 
further be facilitated in the future through 
component specific targets. 

 Short list   

2.3.b) Introduce a definition of 
remanufacturing and specific 
provisions to support 
remanufacturing 

1., 2. & 7. 

Moderate to 
high 

2.3.c) Voluntary activities of 
OEMs and their suppliers to 
promote the application of 
reused and remanufactured 
components 

2.3.d) Voluntary activities of 
Member States to promote 
circularity 

5. 

5. 

Low 

Low 

2.3.e) Establish provisions to 
support the market of used 
spare parts 

1. 

2.3.f) Set up a separate 
(monitoring) target for re-
use/preparing for re-
use/remanufacturing 

Moderate to 
High (when 
combined with 
measures 2.2.f 
and 2.3.b) 

Moderate to 
High (when 
combined with 
measure 2.2.e 
and 2.3.b) 

570 

 
 
 
 
 
 
 
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Measure  

Viability 
screening 

addressing Specific Objective No 2.4 

Effectiveness  Comment, Discard justification 

2.4.a) Align definition of 
‘recycling’ with the WFD 

Moderate to 
high 

Alignment of the definition ‘recycling’ with 
WFD could potentially lead to higher 
quality recycling, however in some MS 
also requiring investments in such 
developments. 

 Short list  

2.4.b) Making it mandatory to 
remove certain 
parts/components before 
shredding to encourage their 
recycling 

2.4.c) Set material-specific 
recycling targets for a 
selection of materials 

2.4.d) Regulate shredder/post 
shredder facilities to ensure 
higher quality of recycling 

2.4.e) Increase (?) current re-
use and recycling targets 
and/or ban disposal or 
landfilling of waste from ELVs 

2.4.f) Revision of Commission 
Decision 2005/293/EC on the 
circularity aspects 

Moderate to 
High (when 
combined with 
measures 
2.3.a, 2.3.c, 
2.3.d, 2.3.e) 

Moderate to 
High (when 
combined with 
measures 
2.3.a, 2.3.c, 
2.3.d, 2.3.e) 

Moderate to 
High (when 
combined with 
measures 
2.3.a, 2.3.c, 
2.3.d, 2.3.e) 

Moderate to 
High (when 
combined with 
measures 
2.3.a, 2.3.c, 
2.3.d, 2.3.e) 

The selection of a single measure or a set 
of measures shall be concluded for each 
material separately in order to find the 
most suitable approach for increasing 
reuse and recycling of that material and 
related components. In the first screening 
all of measures are selected for the short 
list. Further specification will be performed 
in the next section or each material and at 
vehicle level and the impact analysis will 
support the final selection.  

 Short list 

Moderate 

 Short list 

*) Changes to the 3R Type approval that go beyond the requirements established in Regulation UN ECE 133 could affect the 
current equivalence of type approvals performed to comply with these legislations. This would either require the EC to promote 
a similar change in the international legislation or to withdraw from it, possibly affecting the movements of vehicles between 
the EU and other countries. 

**) Investigation for plastic has been conducted by the JRC, who will also lead a separate study where this measure may be 
considered for NdFeB magnets. This study shall not present the assessment in detail but only refer to such measures in terms 
of possible combinations with other measures, synergies and antagonistic relations. 

571 

 
 
 
 
 
 
 
 
 
 
 
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6.4.2  Additional results of the impact analysis 

6.4.2.1  Glass 

The figure below shows the related impacts of sending glass to different treatment routes. 
This calculated for the functional unit (all vehicle glass of a typical passenger car) in terms of 
global warming potential. 

Figure 6-6  Credits for Global warming potential (GWP) of different treatment routes for 
all windows, as compared to primary production (kgCO2eq) – functional unit: all vehicle 
glass of a typical vehicle (tCO2eq) 

Reuse

Recycling pre-shredder

Recycling post-shredder Backfilling after shredder

.

q
e
-
2
O
C
g
k

0

-5

-10

-15

-20

-25

-30

-35

Source: Own illustration  

572 

 
 
 
STUDY TO SUPPORT THE  
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6.4.3  Administrative costs for objective 2: circularity: 

573 

 
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Table 6-22 Administrative costs (recurrent) according to BRG model, circularity  

New administrative obligations

No.

Type of obligation (see 
below for typology)

Description of required action(s)

Target group

SMEs 
affected 
(Y/N)

Tariff
(€ per hour)

TIme 
(minutes)

Price
(€ per action) 
(P)

Freq 
(per year)

Override 
cost per 
entity used 

Number 
of 
entities

Total number of 
actions (Q)

P*Q (€)

Override costs 
where P*Q not 
used (€)

Equipment 
costs 
(€ per entity 

Total 
Administrative 
Costs

Business 
As Usual 
Costs

Total 
Administrative 
Burdens

Comments

SV11 SV2

Submission of (recurring) 
reports 

SV1a

Submission of (recurring) 
reports 

Filing forms and tables

ATFs

Filing forms and tables

ATFs

SV2a

Submission of (recurring) 
reports 

Submitting the information (sending it 
to the designated recipient)

ATFs

SV3a

SV4b

SV4c

SV4b

Submission of (recurring) 
reports 

Submitting the information (sending it 
to the designated recipient)

ATFs

Submission of (recurring) 
reports 

Submitting the information (sending it 
to the designated recipient)

Shredders/ PST operators

Submission of (recurring) 
reports 

Submitting the information (sending it 
to the designated recipient)

Steel recyclers

Submission of (recurring) 
reports 

Submitting the information (sending it 
to the designated recipient)

Shredders/ PST operators

SV11 SV2

Submission of (recurring) 
reports 

Submitting the information (sending it 
to the designated recipient)

Shredders/ PST operators

4A

4A

4A

Submission of (recurring) 
reports 

Inspecting and checking (including 
assistance to inspection by public 
authorities)

ATFs

Submission of (recurring) 
reports 

Inspecting and checking (including 
assistance to inspection by public 
authorities)

Shredders

Submission of (recurring) 
reports 

Inspecting and checking (including 
assistance to inspection by public 
authorities)

Recyclers

SV11 SV2

Submission of (recurring) 
reports 

SV1a

Submission of (recurring) 
reports 

SV2a

SV3a

SV4e

SV4b

SV4f

SV5b

Submission of (recurring) 
reports 

Submission of (recurring) 
reports 

Submission of (recurring) 
reports 

Submission of (recurring) 
reports 

Submission of (recurring) 
reports 

Submission of (recurring) 
reports 

Filing forms and tables

MS competent authorities waste

Filing forms and tables

MS competent authorities waste

Filing forms and tables

MS competent authorities waste

Filing forms and tables

MS competent authorities waste

Filing forms and tables

MS competent authorities waste

Filing forms and tables

MS competent authorities waste

Filing forms and tables

MS competent authorities waste

Filing forms and tables

MS competent authorities waste

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

N

N

N

N

N

N

N

N

26

26

26

26

26

26

26

26

26

26

26

480,00

960,00

206

411

1

1

180,00

77

52

1

1

12

1

1

1

1

1

960,00

960,00

480,00

960,00

411

411

206

411

2.400,00

1.028

0,00

0,00

0,00

480,00

480,00

720,00

480,00

960,00

960,00

0

0

0

206

206

308

206

411

411

720,00

308

300,00

129

26

26

26

26

26

26

26

26

Businesses

12.000

12.000

2.467.200

12.000

12.000

4.934.400

270.000

14.040.000

1.082.484.000

12.000

12.000

4.934.400

140

200

140

200

140

57.568

2.400

493.440

140

57.568

200

205.600

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

2,50

6.310.435

6.310.435

2,50

6.310.435

6.310.435

1,00

15.776.087

15.776.087

Public authorities

1

1

3

1

1

1

1

1

0

0

0

0

0

0

0

0

27

27

27

27

27

27

27

27

27

27

81

27

27

27

27

27

0

0

0

5.551

5.551

24.980

5.551

11.102

11.102

8.327

3.470

0

0

0

0

0

0

0

0

2.467.200

95%

123.360

4.934.400

60%

1.973.760

Aligning recycling definition with WFD, ATF Reporting on vehicle glass treatement to MS 
authority, Waste operators already report to MS on M1 and N1 vehicles, reporting of values 
shall not change signifiacntly, but more documentation will need to be provided
Monitoring reuse, ATF Reporting to MS authority on dismanteled parts/components for 
reuse/remanufactoring , Waste operators already report to MS on M1 and N1 vehicles, but the 
new reporting on reuse will be much more detailed

1.082.484.000

100%

0

Not to be included: Considered to be part of the baseline as operational costs as the revenues 
that are not precisely quantified certainly will outweight the reporting costs.
Support reuse market, Repair shops, We know that in some cases repair shops already apply 
reused parts, anyway the obligation could lead to an increase in such activities. 

4.934.400

70%

1.480.320

57.568

0%

57.568

493.440

75%

123.360

57.568

0%

57.568

205.600

10%

185.040

5.551

100%

0

5.551

60%

2.220

24.980

0%

24.980

5.551

70%

1.665

11.102

11.102

0%

0%

11.102

Obligatory dismantling, ATF Reporting to MS authority on mandatory dismantled 
parts/components either for reuse/remanufacturing or for recycling, ATFs already report but will 
have additional effort to provide data on weight and kind of dismantled components for 
reuse/remanufacturing and recycling. It is assumed that ATFs will dismantle more, thus higher 
effort. 
PST - general, Reporting obligation on PST capacities, We assume that the PRO will report on 
PST activities under its membership and that non-members will report individually

PST - copper level, Recycler reporting on quality of smelted steel batches, We assume that 
recyclers will report over time about the changing level of copper in steel smelted bateches - 
once a month. We assume that they test batches anyway and just need to compile and submit 
the data.

Disposal ban (PST plastic), Reporting obligation on the quality of residues (POP content), We 
assume that the PRO will report on PST activities under its membership and that non-members 
will report individually - currently not reported

Mutual RRR targets, Waste operators/PROs reporting on treated ELVs to MS authorities 
("calculation point"), The effort of the waste operators that will need to report will depend on how 
the reporting is determined. The calculation assumes involvement of all parties (conservative). 
The reporting also covers any burden for reporting related to material specific targets

2.4 Monitoring of material flows and compliance with RRR targets, Based on indication from 
Belgium (febelauto), Netherlands (ARN) and Ireland (ELVES) we conclude that the effort for this 
task is between less than 1 € and in maximum 5 € per new and used car first registered; share 
of the ATFs

2.4 Monitoring of material flows and compliance with RRR targets, Based on indication from 
Belgium (febelauto), Netherlands (ARN) and Ireland (ELVES) we conclude that the effort for this 
task is between less than 1 € and in maximum 5 € per new and used car first registered; share 
for the shredders
2.4 Monitoring of material flows and compliance with RRR targets, Based on indication from 
Belgium (febelauto), Netherlands (ARN) and Ireland (ELVES) we conclude that the effort for this 
task is between less than 1 € and in maximum 5 € per new and used car first registered; share 
for the recyclers/ end-processors.

Aligning recycling definition with WFD, MS Reporting on treated ELVs to Eurostat, MS already 
report on M1 and N1 ELVs, the format will not change from the baseline but only what values are 
reported under which part, all costs occur in the baseline.
Monitoring reuse, MS Reporting on treated ELVs to Eurostat, MS already report on M1 and N1 
ELVs, the format will change from the baseline but still MS just need to compile the data they get 
from ATFs and validate it.
Support reuse market, MS Reporting on treated ELVs to Eurostat, To implement enforcement 
against illegal sales of reused components, MS would need to inspect online sale platforms to 
ensure no illegal activities.
Obligatory dismantling, MS Reporting on treated ELVs to Eurostat, MSs already report and will 
use same format, however those not yet reporting. It is assume that ATFs will dismantle more, 
thus higher effort. 
PST - general, MS Reporting on treated ELVs to Eurostat, There is currently no reporting on 
PST capacities

11.102

PST - copper level and quality of steel fractions, MS Reporting quality of steel recyclates to MS, 
Newly introduced reporting based on recycler submitted data

8.327

0%

8.327

Disposal ban (PST plastic), MS Reporting on treated ELVS to Eurostat, There is currently no 
reporting on the quality of PST residues

3.470

10%

3.123

Mutual RRR targets, MS Reporting on treated ELVS to Eurostat ("calculation point"), MS will 
have higher costs as the reporting format will need to be udpated based on the calculation point 
principal and is expected to be slighlty more specific.

15.776.087

15.776.087

20%

12.620.869

15.776.087

15.776.087

20%

12.620.869

3.155.217

3.155.217

20%

2.524.174

New Administrative costs - Business
New Administrative costs - public bodies
Total new administrative costs (€)

37.301.089
62.520
37.363.609

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6.5  Detailed current situation of Specific objective 3 (missing 

vehicles) 

6.5.1  Facts on extra EU Export  

6.5.1.1  Destinations,  numbers,  and  value  of  the  exported  used 

vehicles 

As displayed in Figure 6-7, the total number of exported used vehicles from EU-27 to non-EU 
Countries is, according to customs data reported by Eurostat, changing from year to year. In 
the past decade the export peaked in 2012 with 1.4 million exported used vehicles, dropped 
to  680  000  in  2016  and  the  last  available  number  for  the  export  in  2020  is  870  000  used 
vehicles. 

As displayed in Figure 6-8 the total value of the exported used vehicles to non-EU Countries 
is € 6.14 billion in 2012 and dropped to € 3.85 billion in 2020. 

Figure 6-7  Number of exported used vehicles from EU-27 to non-EU Countries 

 1 600 000

 1 400 000

 1 200 000

 1 000 000

 800 000

 600 000

 400 000

 200 000

 -

Source: Eurostat, COMEXT (download 27.1.2022) 
CN codes considered: 87032190, 87032290, 87032390, 87032490, 87033190, 87033290, 87033390, (equivalent to vehicle 
category M1; 87042139, 87042199, 87043139, 87043199 for the transport of goods with a gross vehicle weight of < 5 t (while 
the N1 category covers such vehicle with a gross vehicle weight of < 3.5 t only). 

575 

 
 
 
 
 
 
 
 
 
 
 
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Figure 6-8  Total value of exported used vehicles from EU-27 to non-EU Countries 
  p

 (

) 

 7 000 000 000

 6 000 000 000

 5 000 000 000

 4 000 000 000

 3 000 000 000

 2 000 000 000

 1 000 000 000

 -

Jan.-Dec.
2009

Jan.-Dec.
2010

Jan.-Dec.
2011

Jan.-Dec.
2012

Jan.-Dec.
2013

Jan.-Dec.
2014

Jan.-Dec.
2015

Jan.-Dec.
2016

Jan.-Dec.
2017

Jan.-Dec.
2018

Jan.-Dec.
2019

Jan.-Dec.
2020

Source: Eurostat, COMEXT (download 27.1.2022); CN codes considered: see Figure 6-7 above  

Figure  6-9  displays  the  number  and  average  value  per  country  of  destination  for  the  year 
2020. It demonstrates high discrepancies in the characteristics of the exported vehicles:  

Very high numbers (more than 100 000 used vehicles per year) with comparable low value 
(less than 4000 €) are exported to Ukraine (UA) and Serbia (XS).  

Figure 6-9  Extra-EU exports of used vehicles in numbers and average value for 2020 

other Countries OECD Countries

ECOWAS

other Afrikan Countries

other European Countries

)
€
(
e
l
c
i
h
e
v

l

r
e
p
e
u
a
v
e
g
a
r
e
v
a

 160 000

 140 000

 120 000

 100 000

 80 000

 60 000

 40 000

 20 000

 -

 -

 20 000  40 000  60 000  80 000  100 000  120 000  140 000  160 000  180 000

XS 

UA 

Number of used vehicles exported

Source: Eurostat, COMEXT (download 27.1.2022); CN codes considered: see Figure 6-7 above 

Figure 6-10 displays more details for the countries with more than 20 used vehicles exported 
to (excluding Serbia and Ukraine mentioned before) and for the countries where the average 
value per used vehicles is reportedly less than 5500 €. The full details, displaying the country 
names and all data are displayed in Table 6-25 more below in this section. 

576 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Figure 6-10  Extra-EU exports of used vehicles in numbers and average value 
(zoom) for 2020 

other Countries

OECD Countries

ECOWAS

other Afrikan Countries

other European Countries

 5 500

 5 000

 4 500

 4 000

 3 500

 3 000

 2 500

 2 000

KG 

 1 500

 1 000

 500

)
€
(
e
l
c
i
h
e
v

l

r
e
p
e
u
a
v
e
g
a
r
e
v
a

SO 
BR 

PY 
CF 
ID 

IR 

TD 
BO 

AZ 

MG 

BA 

MK 

AL 

ME 

SD 
TZ 

ST 

BF 

KM 

HT 

GW 

LR 

AF 

ML 

GQ 

CD 
SL 

TJ 
GM 

CG 

NE 

GH 
GE 

SN 

TG 

CM 

BJ 

GN 

LY 

NG 

 20

 10 020

 20 020

 30 020

 40 020

 50 020

 60 020

Number of used vehicles exported

Source: Eurostat, COMEXT (download 27.1.2022); CN codes considered: see Figure 6-7 above  

6.5.1.2  Regulations for the import in receiving countries and share 

of used vehicles directed to these countries 

Africa  and  Eastern  Europe,  the  Caucasus,  Central  Asia,  and  Middle  East  are  the  main 
destination  for  the  EU  27  Export,  representing  91%  of  the  total  exported  used  vehicles. 
According  to  (UNEP  2020)  351,  5  countries  out  of  83  in  these  regions  have  established  an 
import ban for used vehicles. 17 importing countries have defined a minimum level regards 
the emission standard and 38 importing countries have established age limits for the import 
of used vehicles.  

The  UNEP  2020  report  applied  the  following  assessment  regards  the  ranking  of  the 
regulation:  

351 Baskin, J. et al. (2020), Used vehicles and the Environment. A Global Overview of Used Light Duty Vehicles: Flow, Scale 
and Regulation, published by United Nations Environment Programme (UNEP), 10/2020 

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29 countries are assessed by the UNEP 2020 report to have a very good or good regulation, 
or the import of used vehicles is banned.  

The Economic Community of West African States (ECOWAS) adopted on 5 September 2020 
a Directive, limiting the import of used vehicles to those with a minimum Euro 4/IV emission 
standard. The age limit for importing vehicles into the ECOWAS region is 5 years for light 
duty vehicles, two-wheel motor vehicles, tricycles and quadricycles and 10 years for heavy-
duty vehicles. A period of 10 years is granted to ECOWAS countries to adopt step by step.352 

In result the 15 ECOWAS countries can be considered as very good regulated as well.  

Table  6-23  below  displays  the  share  of  used  vehicles  directed  to  differently  regulated 
counties, and Table 6-24 displays the total and average value of the exported used vehicles 
in 2020. 

Table 6-23 Share of used vehicles exported in 2020 from EU-27 to differently 
regulated countries 

Countries 
mentioned as 
destination 

Share of the total 
number of EU-27 export 

Total export to Africa and Eastern Europe, the 
Caucasus, Central Asia, and Middle East 

Ban of import of used vehicles 
Good, very good regulated or the import of used 
vehicles is banned (UNEP 2020) 
Good, very good regulated or the import of used 
vehicles is banned (UNEP 2020) + ECOWAS 
Countries 
At least any regulation for the import of used vehicles 
by age or emission class (including ECOWAS 
Countries) 

82 

5 

29 

43 

59 

91% 

0.4% 

29% 

55% 

82% 

Source: UNEP 2020; Eurostat: COMEXT (download 27.1.2022); CN codes considered: see Figure 6-7 above 

352 Directive C/Dir.2/09/20 relating to the harmonization of the limits of gas and exhaust particle emission for light and heavy 
vehicles, two wheel vehicles, tricycles and quadricycles within the ECOWAS region. 

578 

 
 
 
 
 
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Table 6-24 Value of used vehicles exported in 2020 from EU-27 to differently 
regulated countries 

Total export to Africa and Eastern Europe, the 
Caucasus, and Central Asia and Middle East 

Ban of import of used vehicles 
Good, very good regulated or the import of used 
vehicles is banned (UNEP 2020) 
Good, very good regulated or the import of used 
vehicles is banned (UNEP 2020) + ECOWAS 
Countries* 
At least any regulation for the import of used vehicles 
by age or emission class (including ECOWAS 
Countries*) 

Total value of the EU-27 
Export  
(Million €) 

Average value of 
the EU-27 Export 
(€ per vehicle) 

  2 558 

  46 

  1 371 

3 226 

13 684 

5 462 

  1 703 

3 553 

  2 340 

3 279 

* Regulations not enforced yet for all ECOWAS countries for the displayed year 2020. 
‘Source: UNEP 2020; Eurostat: COMEXT (download 27.1.2022); CN codes considered: see Figure 6-7 above 

6.5.1.3  Age  and  periodic  roadworthiness  test  of  exported  used 

vehicles from the Netherlands 

A  Dutch  study353  assessed  the  characteristics  of  vehicles  dismantled  (=ELVs)  in  the 
Netherlands and vehicles exported to the top 12 countries in West Africa for the period 2017 
/  2018.  As  displayed  in Figure  6-11 for  both  groups  ELV  and  exported to  West  Africa,  the 
peak is on vehicles aged between sixteen and twenty years. This is quite different compared 
to Morocco: The youngest vehicles go to Morocco which introduced in 2011 an age restriction 
of five years and Euro 4 vehicle emission standards for imports of used vehicles.  

Only a minority of all exported used vehicles, also the youngest ones have roadworthiness 
certificate,  valid  for  more  than  one  month.  The  characteristics  regarding  the  valid 
roadworthiness test is similar for the vehicles dismantled in the Netherlands and the vehicles 
exported to 12 Countries in West Africa. 

353 Netherlands Human Environment and Transport Inspectorate, Ministry of Infrastructure and Water Management (2020): 
Used vehicles exported to Africa: A study on the quality of used export vehicles 

579 

 
 
 
 
 
 
 
 
 
 
 
 
 
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Figure 6-11  Age of dismantled (RDW_Dismantling LDVs) versus retrieved vehicles 
exported to West Africa. 

PRT: periodic roadworthiness test 

RDW: Netherlands Vehicle Authority 

LDV: are motor vehicles with at least four wheels for the carriage of passengers (no more than eight seats in addition to the 
driver’s seat) and for the carriage of goods (and having a maximum mass not exceeding 3.5 tonnes. HDVs are motor vehicles 
with at least four wheels for the carriage of goods or passengers and having a maximum mass exceeding 3.5 tonnes 

Source: Netherlands Human Environment and Transport Inspectorate, Ministry of Infrastructure and Water Management 
(2020): Used vehicles exported to Africa: A study on the quality of used export vehicles 
Data: combined Customs and RDW. © ILT-IDlab 

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6.5.1.4  Milage of exported used vehicles from the Netherlands 

As displayed in Figure 6-12 the peak in mileage for the dismantled vehicles is around 200,000 
km. For the export used vehicles to West Africa the milage is even a bit higher. 

Figure 6-12  Relative distribution of mileage of dismantled (RDW_Dismantling LDVs) 
versus retrieved vehicles exported to West Africa 

Source: Netherlands Human Environment and Transport Inspectorate, Ministry of Infrastructure and Water Management 
(2020): Used vehicles exported to Africa: A study on the quality of used export vehicles 
Data: combined Customs and RDW. © ILT-IDlab 

6.5.1.5  Regulatory aspects in the receiving countries 

More and more receiving countries established regulations for the import of used vehicles. 
When  looking  for  the  most  relevant  markets  for  the  EU,  Africa  and  Eastern  Europe,  the 
Caucasus,  and  Central  Asia  5  out  of  (54  +  18)  have  established  an  import  ban  for  used 
vehicles. 17 importing countries have defined a minimum level regards the emission standard 
and 28 importing countries have established age limits for the import of used vehicles. Details 
regard  the  selected  level  of  emission  standard  and  the  selected  threshold  by  age  are 
displayed in the table below. 

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Table 6-25 Export of Used Vehicles to non-EU-Countries in 2020: Numbers and Value 
per Country, Source: Eurostat, COMEXT (download 27.1.2022); Compilation: Mehlhart 
Consulting  

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Table 6-26 Regulatory limitations for the import of used vehicles for African countries 
(Source: UNEP (Baskin et al., 2020) 354 

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354 Baskin, J. et al. (2020), Used vehicles and the Environment. A Global Overview of Used Light Duty Vehicles: Flow, Scale 
and Regulation, United Nations Environment Programme 

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Table 6-27 Regulatory limitations for the import of used vehicles for Eastern Europe, 
the Caucasus, and Central Asia (Source: UNEP (Baskin et al., 2020) 355 

355 Baskin, J. et al. (2020), Used vehicles and the Environment. A Global Overview of Used Light Duty Vehicles: Flow, Scale 
and Regulation, United Nations Environment Programme 

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Table 6-28 Regulatory limitations for the import of used vehicles for Middle East 
(Source: UNEP (Baskin et al., 2020) 356 

356 Baskin, J. et al. (2020), Used vehicles and the Environment. A Global Overview of Used Light Duty Vehicles: Flow, Scale 
and Regulation, United Nations Environment Programme 

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6.5.1.6  Emission  standard  of  exported  used  vehicles  from  the 

Netherlands 

As  displayed  in  Figure  6-13  most  of  the  ELVs  dismantled  in  the  Netherlands  have  an 
emissions standard of Euro 2 or Euro 3 and by far most are petrol ICVs. For the used vehicles 
exported to West Africa the share of Euro 3 is higher, but the share of Euro 5 and Euro 6 is 
marginal. Compared to the ELV much more Diesel ICV are exported than Petrol ICVs.  

Figure 6-13  European emissions standards of dismantled (RDW_Dismantling LDVs) 
versus retrieved vehicles exported to West Africa 

Source: Netherlands Human Environment and Transport Inspectorate, Ministry of Infrastructure and Water Management 
(2020): Used vehicles exported to Africa: A study on the quality of used export vehicles 
Data: combined Customs and RDW. © ILT-IDlab 

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6.5.1.7  Global  air  pollution 

related  health 

impacts  of 

transportation sector 

Figure 6-14  Global PM2.5 and ozone concentrations in 2010 

Source: Anenberg, S.; Miller, J.; Henze, D.; Minjares, R. (2019): A GLOBAL SNAPSHOT OF THE AIR POLLUTION-RELATED 
HEALTH IMPACTS OF TRANSPORTATION SECTOR EMISSIONS IN 2010 AND 2015, published by: International Council 
on Clean Transportation 

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Figure 6-15  global PM2.5 and ozone concentrations in 2015 

Source: Anenberg, S.; Miller, J.; Henze, D.; Minjares, R. (2019): A GLOBAL SNAPSHOT OF THE AIR POLLUTION-RELATED 
HEALTH IMPACTS OF TRANSPORTATION SECTOR EMISSIONS IN 2010 AND 2015, published by: International Council 
on Clean Transportation 

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Figure 6-16  Change in transportation attributed concentration (TAC) PM2.5 and 
ozone and Black Carbon (BC): 2010 to 2015 

Source: Anenberg, S.; Miller, J.; Henze, D.; Minjares, R. (2019): A GLOBAL SNAPSHOT OF THE AIR POLLUTION-RELATED 
HEALTH IMPACTS OF TRANSPORTATION SECTOR EMISSIONS IN 2010 AND 2015, published by: International Council 
on Clean Transportation 

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Figure 6-17  Transportation attributed fractions (TAF) of PM2.5 and ozone death in 
2015 

Source: Anenberg, S.; Miller, J.; Henze, D.; Minjares, R. (2019): A GLOBAL SNAPSHOT OF THE AIR POLLUTION-RELATED 
HEALTH IMPACTS OF TRANSPORTATION SECTOR EMISSIONS IN 2010 AND 2015, published by: International Council 
on Clean Transportation 

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Figure 6-18  Total number of transportation-attributed PM2.5 and ozone death in 2015 
by world region 

Source: Anenberg, S.; Miller, J.; Henze, D.; Minjares, R. (2019): A GLOBAL SNAPSHOT OF THE AIR POLLUTION-RELATED 
HEALTH IMPACTS OF TRANSPORTATION SECTOR EMISSIONS IN 2010 AND 2015, published by: International Council 
on Clean Transportation 

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Regards the total impacts and trends the ICCT study357 concludes: “Figure 6-19 compares 
population  size  with  the  absolute  number  of  transportation  attributable  PM2.5  and  ozone 
deaths by trade bloc in 2015. These estimates are shown on a logarithmic scale to account 
for the substantial differences in population size among trade blocs and individual countries. 
The size of each point in Figure 13 corresponds to the transportation-attributable mortality 
rate per 100,000 population. In 2015, EU and EFTA countries along with those accounted for 
as  “Other  Europe”  (which  includes  Ukraine)  had  the  highest  transportation-attributable 
mortality rates, at approximately 12 deaths per 100,000 population. These elevated rates are 
likely attributable to a combination of factors, including high levels of transportation activity; 
high levels of LDV dieselization; and relatively high baseline incidence rates for diseases that 
are affected by air pollution. In contrast, trade blocs in sub-Saharan Africa, South America, 
Central America, the Caribbean, and the Middle East had comparatively low transportation 
attributable  mortality  rates.  Considering  the  increases  in  motorization,  freight  activity, 
urbanization,  total  population,  and  baseline  incidence  rates  of  diseases  affected  by  air 
pollution that are projected in many of these regions, coupled with the time it takes to turn 
over the entire existing vehicle fleet, we suggest that these regions take appropriate action to 
control  emissions  from  new  vehicles  before  health  damages  intensify  (i.e.,  increased 
transportation-attributable mortality rates, absolute burden, and associated welfare loss)” 

Figure 6-19  global PM2.5 and ozone concentrations in 2015 

Source: Anenberg, S.; Miller, J.; Henze, D.; Minjares, R. (2019): A GLOBAL SNAPSHOT OF THE AIR POLLUTION-RELATED 
HEALTH IMPACTS OF TRANSPORTATION SECTOR EMISSIONS IN 2010 AND 2015, published by: International Council 
on Clean Transportation 

357 Anenberg, S.; Miller, J.; Henze, D.; Minjares, R. (2019): A GLOBAL SNAPSHOT OF THE AIR POLLUTION-RELATED 
HEALTH IMPACTS OF TRANSPORTATION SECTOR EMISSIONS IN 2010 AND 2015, published by: International Council 
on Clean Transportation 

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6.6  Detailed  results  of  the  impact  analysis  for  Specific 

objective 3 (missing vehicles) 

6.6.1  Screening measures and separate discarded options 

The table below displays the criteria for screening.  

III. Screen your options and separate discarded options 

Why? 

To focus the analysis on the viable options. In choosing the options, it is important to focus 
on those elements that are most critical for the Commission to decide on (i.e. those with 
significant impacts). As with the problem analysis, you must ensure that the report remains 
focused and that it does not drown the major issues in a ‘flood’ of minor issues. 

Excluding options at this stage should be clearly justified. Reasons should be as clear, self-
evident  and  indisputable  as  possible.  The  report  should  explain  when  it  had  to  discard 
policy  options  favoured  by  stakeholders.  This  should  be  done  in  a  separate  section  on 
discarded options (if necessary, with further details in the annexes). 

The key criteria for screening the viability of your options are: 

Legal feasibility 

Options should respect the principle of conferral358. They should also respect any obligation 
arising from the EU Treaties (and relevant international agreements) and ensure respect 
of fundamental rights. Legal obligations incorporated in existing primary or secondary EU 
legislation may also rule out certain options. 

Technical feasibility 

How? 

Technological and technical constraints may not allow for the implementation, monitoring 
or enforcement of theoretical options. 

Previous policy choices 

Certain options may be ruled out by previous policy choices or mandates by EU institutions. 
Unless  there  is  compelling  evidence  that  these  choices  should  be  revisited,  there  is  no 
point in reinventing the wheel. 

Coherence with other EU policy objectives 

Certain options may be ruled out early due to poor coherence with other general EU policy 
objectives. 

Effectiveness and efficiency 

It may already be possible to show that some options would with certainty achieve a worse 
cost-benefit balance than some alternatives. 

Proportionality 

358 Under this fundamental principle of EU law, laid down in Article 5 of the Treaty on European Union, the EU acts only within 
the limits of the competences that EU countries have conferred upon it in the Treaties. These competences are defined in 
Articles 2–6 of the Treaty on the Functioning of the EU. Competences not conferred on the EU by the Treaties thus remain 
with EU countries. 

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III. Screen your options and separate discarded options 

Some options may clearly restrict the scope for national decision-making over and above 
what is needed to achieve the objectives satisfactorily. 

Political feasibility 

Options  that  would  clearly  fail  to  garner  the  necessary  political  support  for  legislative 
adoption or implementation could also be discarded. This, however, does not mean that 
such options should not be mentioned or not be subject to at least a minimal assessment. 
Options superior to other options but lacking political feasibility may still be discussed at 
the legislative stage, which may increase their chances of being politically feasible. 

Relevance  

There is no point in retaining options that do not address the needs of the policy intervention 
as identified in the problem definition. 

Identifiability 

When  it can  be  shown  that  two  options  are not  likely  to  differ  materially  in  terms  of  the 
proposed  measures,  their  significant  impacts  or  their  distribution,  only  one  should  be 
retained. 

Source: Better Regulation toolbox Tool #16, Textbox page 114 – 115

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In the following the potential measures are assessed against these criteria and a justification is given for the case that an option is considered 
as discarded. The numbers in the column “Viability screening” refer to the numbering of the key criteria for screening as displayed in the 
table above.  

Table 6-29 Initial assessment of measures to identify discarded and short-listed measures 

Measure  

Viability 
screening 

Effectiveness 

Comment, Discard justification 

addressing Specific Objective No 3.1 

MS  to  report  on  economic  incentives  for 
the  last  owner  of  an  ELV  to  deliver  it  to 
the 
amd  ATF 
administration, Level A 

the  CoD 

report 

to 

MS to implement economic incentives for 
the  last  owner  of  an  ELV  to  deliver  it  to 
amd  ATF 
the 
administration, Level B 

the  CoD 

report 

to 

Low 

 Short-list 

1. / 6. / 7. 

Would be effective 
but 
a 
needs 
mandate  beyond 
the  current  legal 
mandate 

The  implementation  of  a  European  wide  obligation  to  introduce  continuing  payment  to 
insurances schemes until permanent cancellation of a registration or the implementation of 
a European wide obligation to establish a premium pay out to the last owner is considered 
out of the scope of the European mandate (legal feasibility, subsidiarity).  

Alignment  of 
1999/37/EC on registration documents.  

terms  with  Directive 

Harmonisation  at 
EU level 

A 
 Short list 

formal 

aspect 

to 

resolve 

a 

discrepancy 

1. 

1. 

Introduction of new definition: “temporary 
deregistration”  

Establish EU wide harmonised registration 
procedures for vehicles  

Obligations  for  dismantlers  /recyclers  to 
check and report on ELVs / CoDs 

Improve exchange of information between 
registration  authorities  on  de-registered 
vehicles, ELVs and CoDs 

Precondition 
reporting 
collection target 

for 
and 

Legal  feasibility:  Currently  registration  procedures  are  considered  as  not  covered  by  EU 
legislation but an aspect of subsidiarity. As it is of high relevance for monitoring (of targets) 
it 
list. 
 Short-list 

short 

kept 

the 

in 

is 

Assessed  in  2017 
as most effective 

Legal  feasibility:  Currently  registration  procedures  are  considered  as  not  covered  by  EU 
legislation but an aspect of subsidiarity. As it is of high relevance it is kept in the short list. 
 Short-list 

As 
stand-alone: 
Limited,  depends 
on enforcement 

Of  high  relevance 
for 
complete 
reporting 

Short-list 

Short-list 

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Measure  

Viability 
screening 

Effectiveness 

Comment, Discard justification 

Include  Vehicle 
(VIN) in customs declaration 

Identification  Number 

A  specific  detail, 
in 
effective 
combination 

Might 
 Short-list 

require 

implementation 

in 

another 

regulatory 

environment 

(TAXUD) 

Establish EU vehicle registration database 

1. & 7. 

High 

Legal  feasibility:  Currently  registration  procedures  are  considered  as  not  covered  by  EU 
legislation but an aspect of subsidiarity. As it is of high relevance it is kept in the short list. 
Political feasibility: As experienced in the past there is strong opposition by the MS regards 
this 
option 
Short-list 

the 
Improve  reporting  obligations  on 
current  vehicle  market  and  the  ELVs  on 
their  territory  to  prove  that  all  ELVs  are 
directed to ATFs 

Establish  collection  target  based  on  the 
reporting  obligations  on 
the  national 
vehicle market  

High,  but  needs 
combination  with 
interoperability 
regards  intra  EU 
trade 

Short-list 

In principle the ELV Regulation anyhow says that all ELVs (=implicit 100% target) shall be 
collected  and  directed  to  ATFs.  As  far  as  the  reporting  obligation  on  the  current  vehicle 
market is considered as effective and connected to the aim to prove the whereabouts of the 
vehicles, then such explicit target is superfluous. An explicit target must be spelt out and can 
(by  technical  reasons  like  stock  effects  over  years)  not  achieve  100%.  As  such  it  would 
possibly even dilute the implicit 100% target. 

addressing Specific Objective 3.2: Reduce levels of illegal dismantling and illegal export of ELVs 

Exchange  on  MS  best  practice  (national 
incl. 
implementation  and  enforcement 
sector inspection campaigns) 

Voluntary  campaigns  on  export  of  ELVs 
with a focus on the current guidelines on 
distinction  between  ELVs  and  second-
hand 
shipment 
correspondents’ guidelines No9) 

vehicles 

(waste 

5. 

5. 

Low to zero 

The  criteria  of  effectiveness  and  efficiency  are  not  achieved  after  a  decade  of  attempts 
 discarded 

Low to zero 

The  criteria  of  effectiveness  and  efficiency  are  not  achieved  after  a  decade  of  attempts 
 discarded 

Obligation of OEMs to manage a Deposit 
Refund Scheme (DRF) for vehicles 

Potentially high 

Implementation will take time to become effective in all Member States. Possible unequal 
strength of negotiators (OEMs/ ATFs/ shredders) could lead to low DRF pay out and limited 
impact. 
Measure retained under the EPR package.  short list 

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Measure  

Viability 
screening 

Effectiveness 

Comment, Discard justification 

to 

the  national  approach 
Alternative 
above:  European-wide  deposit  refund 
scheme for vehicles: 

1. & 6. 

Potentially high 

The measure does not meet criteria of legal feasibility (subsidiarity) and proportionality. Very 
difficult  to  set  up  at  EU  level:  New  supervision  authority  at  EU  level  might  be  needed,  a 
complex set of negotiations with the stakeholders in the Member States on the correct level 
of 
expected 
 discarded 

pay-out 

DRF 

Binding  criteria  for  a  distinction  of  used 
vehicles / ELVs. 

Definition  of  minimum  requirements  for 
sector inspections 

MS reporting on fines for illegal operation 
of dismantling / shredding facilities and for 
selling  an  ELV  to  illegal  dismantlers  and 
for  dealers  (and  electronic  platforms) 
dealing with dismantled (used) spare parts 
from non-authorised facilities. 

Low/ medium 

Short list  

Low 

Short list  

Low  

The  more  effective  alternative  to  establish  harmonised  and  concrete  fines  and  penalties 
across EU is not coherent with the Legal feasibility (subsidiarity) principle and thus this less 
effective 
only  
 short list.  

remains 

option 

viable 

addressing Specific Objective No 3.3: Establish enforceable criteria to avoid the export of (used) cars which do not meet roadworthiness or minimal environmental 
standards 

Action at international level to support that 
(and  others)  become 
roadworthiness 
criteria for export of used vehicles. 

Low to zero 

While the measure has low to zero impacts at EU level it is important for the effectiveness in 
the receiving countries with the aim to encourage other exporters like United States, UK, and 
Japan  to  follow  the  request  Ms.  Andersen,  Executive  Director  of  UNEP,  which  said 
“Developed  countries  must  stop  exporting  vehicles  that  fail  environment  and  safety 
inspections and are no longer considered roadworthy in their own countries, while importing 
countries should introduce stronger quality standards” 

 short list.  

Promote  enforcement  actions  by  MS 
through EU funding and EU enforcement 
actions against environmental crime 

Set new conditions applying to the export 
outside  the  EU  of  used  vehicles,  with 
criteria  linked  to  roadworthiness  and  air 
emissions  as  conditions  for  authorising 
export 

5. 

Low to zero 

The  criteria  of  effectiveness  and  efficiency  are  not  achieved  after  a  decade  of  attempts 
 discarded 

Depending  on  the 
level 
the 
of 
conditions 

Short list 

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Measure  

Include  VIN 
customs 
number 
declaration  to  allow  for  better  traceability 
of cars exported outside the EU 

in 

Viability 
screening 

Effectiveness 

Comment, Discard justification 

Low to zero 

Might become relevant for monitoring / evaluation 

Short list 

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6.6.2  Scenarios for the shift between categories 

6.6.2.1  Categories of whereabout 

A) ELVs directed to ATFs and subsequently to shredders and reported by ATFs and 
MS (ATF, reported) 

B) ELVs directed to ATFs and subsequently to shredders but not reported (ATFs, not 
reported) 

C) ELVs directed to non-ATFs and subsequently to shredders, not reported (non-ATF) 

D) Used Vehicles exported (extra EU) and reported accordingly (Export, reported) 

E) Used Vehicles exported (extra EU) but not reported (Export, not reported) 

F) ELVs exported (extra EU), not reported (ELVs export, not reported) 

G) Missing vehicles = B) + C) + E) + F)  

6.6.2.2  How to read the table with the detailed changes in percent 

points 

The  table  below  demonstrates  how  shifts  between  the  above-mentioned  categories  are 
introduced to the model. The yellow cell indicates for instance a shift of 0.25 percent points 
(of the total number of ELVs) from category E (Export, not reported) to category D (Export, 
reported),  the  red  cell  displays  the  reverse  (redundant  information  and  is  therefore  not 
displayed later on). The total displays the change in percent points for the entire category. 
For instance, category D (Export, reported) receives in total 0.5 percent points more vehicles 
in the given year compared to the year 2019 where (at least for some of the categories) data 
is available. 

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6.6.2.3  Assumptions  and  first  results  for  the  shift  between 

“categories of missing vehicles” 

6.6.2.3.1  Baseline / Business-as-usual  

As mentioned above we expect for the baseline marginal effects only as we have experienced 
in the past – with a lot of attention by the EC – effectively no general change on the number 
of missing  vehicles  at  EU  level.  To  be  not too  pessimistic  we  consider  a  limited  shift from 
category B, C, E, F to category A, and also a slight shift from E and F to D. In result the share 
of missing vehicles declines by 2.4 percent points from 32.4% in 2019 to 30.1% (2040). In 
result the problem persists under Business-as-Usual conditions. The Figure below displays 
the detailed changes in percentage points  

share of missing vehicles

35.0%

30.0%

25.0%

20.0%

15.0%

10.0%

5.0%

0.0%

Baseline

2019*

2025

2030

2035

2040

6.6.2.3.2  Policy  option  3A:  Enhanced 

reporting  & 

enforcement 

The policy option 3A is relying on enhanced monitoring and reporting requirements to demon-
strate the whereabout of used vehicles and ELVs. It includes inter alia obligation for reporting 
on the changes in the vehicle fleet with the aim that such reporting shall prove that all ELVs 
are directed to ATFs. The MS have full flexibility to choose the measures to achieve this target 
either with an adjusted registration system or with penalties or with incentives or other means.  

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The main shortcoming of this options is that a single Member State alone has not all means 
at hand to complete the reporting form and thus can argue that he is by external reasons not 
able to fulfil his obligations. And might even cover with this argument his non-action in fields 
where the Member State would have opportunities to act and improve.  

Main missing aspects with this regard is the alignment definition of terms (e.g. for temporary 
deregistration) and the obligatory exchange of information of vehicles dismantled in another 
Member State as it was last registered and last not least the missing introduction of a more 
detailed / applicable definition of the term ELV. 

We expect a few more Member States to take action regards their registration system and 
also regards incentives / penalties. This will cause step by step a shift to the categories A and 
D (both decreasing the number of missing vehicles) and also a small shift from category E to 
F.  

According to our assumptions the share of missing vehicles will continuously decline by 7.2 
percent  points  from  32.4%  in  2019  to  25.2%  (2040).  Due  to  the  shortcomings  mentioned 
above  it  is  very  likely  that  the  Policy  Option  3A  is  at  risk  to  fail  in  generating  substantial 
improvements regards the share/number of missing vehicles. 

share of missing vehicles

3A

2019*

2025

2030

2035

2040

35.0%

30.0%

25.0%

20.0%

15.0%

10.0%

5.0%

0.0%

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6.6.2.3.3  Policy  Option 

3B 

Harmonisation 

and 

interoperability 

This option is aiming to improve collection by: 

• 

requiring that the national registrations systems be made interoperable.  

•  a harmonised approach between the MS regards national registration of vehicles 

• 

requirements regard incentives and penalties 

•  binding criteria on the distinction between used vehicles and ELVs 

Compared to option 3A, this option reduces the flexibility of MS. 

However, it does not include the reporting obligation on the changes in the vehicle fleet (as 
in Policy Option 3A) which is an important tool to prove that all ELVs are directed to ATFs.  

Policy Option 3B provides the tools for cooperation between the MS but a clear method for 
the calculation of the change in the vehicle fleet is missing. Therefore, the current problem 
that  a  comparable  performance  monitoring  by  country  regards  missing  vehicles  is  not 
possible will persist and cause limited incentive to improve the overall situation on missing 
vehicles. 

However,  as  by  the  interoperability  the  tools  are  available  for  complete  balance  of  the 
whereabout of vehicles we expect some frontrunners of the Member States to make use of it 
and  seek  to  improve  their  performance  regards  missing  vehicles.  Other  measures  regard 
permits and incentives will support this change.  

Overall, the effect of Policy Option 3B is considered as more effective than Policy Option 3A, 
while the missing national reporting on the performance regards missing vehicles is a major 
gap to generate full effectiveness of this policy option. 

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share of missing vehicles

35.0%

30.0%

25.0%

20.0%

15.0%

10.0%

5.0%

0.0%

3B

2019*

2025

2030

2035

2040

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6.6.2.3.4  Policy Option 3C: EU wide vehicle registration and 

export controls 

This  option  consists  in  fully  harmonising  the  elements  of  the  current  national  registrations 
systems relevant for the tracking of vehicles and for getting relevant information on export 
restrictions like the status of the roadworthiness certificate.  

In addition, this option includes the establishment of new criteria regulating the export of used 
vehicles  (also  those  which  are  not  explicit  ELVs),  to  ensure  better  traceability  and 
sustainability of these exports. More strict (extra-EU) export criteria, including the mandatory 
use  of  the  VIN  number  in  export  documents,  based  on  combined  roadworthiness,  age, 
emission level criteria set at EU level.  

The limitation of (extra-EU) export to vehicles with valid roadworthiness certificate will have 
massive effects on the extra EU export. The limitation of the export will have a sudden effect 
by the date of enforcement. Most likely exports of older vehicles (without valid certificate) to 
non-EU  Member  States  will  even  increase  in  the  period  before  the  restrictions  enter  into 
force.  For  the  assumptions  regards  the  shifts  between  the  categories  we  take  into 
consideration  that  the  enforcement  date  will  be  2027  and  the  adverse  effects  will  become 
effective in 2025 and the intended effects become visible in 2030. 

The adverse impacts in 2025 on the number of missing vehicles are caused by the shift from 
treatment in ATFs to the export (“last chance to export”) 

share of missing vehicles

3C

2019*

2025

2030

2035

2040

35.0%

30.0%

25.0%

20.0%

15.0%

10.0%

5.0%

0.0%

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6.6.2.3.5  Preferred Policy Option  

In the preferred Policy Option, all the elements for better tracking of the vehicles are in place:  

•  The  means  to  exchange  with  other  Member  States  on  export  and  import  and  on  CoD 

issued in another Member State than the vehicle was last registered.  

•  The reporting form and obligation to prove that all ELVs are directed to ATFs 
•  The harmonisation of the registration procedures in the different Member States including 

• 

introduction of harmonised definitions, e.g. for temporary deregistration. 
Incentives and penalties encouraging last owners, but also treatment operators to behave 
legally 

•  And last not least a better definition for ELV on the one hand and clear, applicable rules 

for the export of vehicles to non-EU countries. 

The combination of these measures generates many synergies, and the impacts are much 
stronger. However, the adverse effect of Policy Options 3C for the year 2025, that more used 
vehicles (and also ELV) might be sold shortly before the stipulations for the export to third 
countries enter into force, remain visible and we expect this effect visible in the statistics but 
also in the non-registered exports. 

share of missing vehicles

Pref. PO

2019*

2025

2030

2035

2040

35.0%

30.0%

25.0%

20.0%

15.0%

10.0%

5.0%

0.0%

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6.6.2.3.6  Additional effects in combination with measures in 

the context of EPR 

Several measures under the proposed measures support the aim to improve the collection 
and reduce the number of “missing vehicles as outlined in the section on the preferred Policy 
Option regards elements for the EPR scheme.  

Depending on the detailed design of the cost compensation and the level of the compensation 
and  enforcement  it  might  be  that  this  measure  strengthens  the  competitiveness  of  ATFs 
against the illegal sector. But undercompensating and strong enforcement might even cause 
the opposite.  

For the purpose of the impact assessment, we consider a slight positive effect on top of the 
preferred option  

share of missing vehicles

35.0%

30.0%

25.0%

20.0%

15.0%

10.0%

5.0%

0.0%

+EPR

2019*

2025

2030

2035

2040

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6.6.2.4  Results  of  the  scenario  calculations  regards  the  shift  of  number  of  whereabouts  between 

categories 

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Table 6-30 Change in categories of whereabouts for the different scenarios 

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6.6.2.5  Results  of  the  scenario  calculations  regards  recyclables 

and LCA credits 

The calculation is based on the following assumptions:  

•  Annex I section 6.9 on Description of the model to calculate the impact assessment:  

o  dynamic generation of ELVs 
o  split in ICV, HEV, PHEV and BEV  
o  Steady state efficiency for the recycling rate respectively loss rate (RR for glass = 0) 

•  Shift of vehicles from export to intra EU treatment. 
•  Without consideration of effects of measures to support circularity. 

Table 6-31 Resources for intra EU recycling in 2025/2030/2040 for the different Policy 
Options 

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Source: own calculations 

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Table 6-32 Credits for recycling due to shift from export (used and ELVs) to EU 
domestic treatment; LCA unit: GWP 100a [1000 t CO2 eq] 

The calculation is based on the following assumptions:  

•  Annex I section 6.9 on Description of the model to calculate the impact assessment:  

o  dynamic generation of ELVs 
o  split in ICV, HEV, PHEV and BEV  
o  Steady state efficiency for the recycling rate / respectively loss rate (RR for glass = 0) 
o  Credits for recycled materials 

•  Shift of vehicles from export to intra EU treatment. 
•  Without consideration of effects of measures to support circularity. 

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Source: own calculations 

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6.6.3  Overview of key impacts to screen 

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6.7  Detailed  current  situation  of  EPR  schemes,  PROs  and 
fees / taxes applied in the MS for the management ELVs 

6.7.1  Questions to the Member States in March 2022 on EPR 

The following questions were sent in March 2022 to the Member States:  

1. Does a fee or tax apply in your country, which is used to financially support the recycling 
of ELVs? If so, please specify:  

•  What is the level of the fee? 
•  For which vehicles does the fee apply?  
•  For what purpose can the collected fees be allocated?  
•  Who is managing the fund (e.g., which organisation, which stakeholders are involved)? 

2. Does an EPR System exist in your country? If so, please specify:  

3. Please indicate the number of Producer Responsibility Organisations (PRO) involved or if 
the EPR is maintained by each single producer individually (direct contracting of producers 
with ATFs)?  

4. Is the EPR System operating in a way which is consistent with the minimum requirements 
of the Waste Framework Directive Art 8a? 

14 Member States replied to the questionnaire: BE, MT, FR, SE, DE, IE, SK, FI, ES, NL, HR; 
LT; CZ, EL. 

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6.7.2  Details for the countries where fees / taxes are mentioned 

6.7.2.1  Austria  

The PRO OECAR charges its members in 2022 with € 3.10 per vehicle placed on the market; 
The minimum fee per brand and year is € 500, the maximum per brand and year is € 15.500 
(net)359. 

The PRO Österreichische Schredder charges its members in 2022 with € 1.50 per vehicle 
placed  on  the  market  plus  an  annual  lump  sum  of  €  100.  The  fees  are  used  for  the 
management of the PRO. 

6.7.2.2  Czech Republic  

No recycling taxes or fees apply for new imported or produced vehicles in the Czech Republic.  

A recycling fee is established for used vehicles in the Czech Republic. Vehicle owners pay 
the recycling fee pay when registering used vehicles as specified below:  

The fee is determined by compliance with the limit values of exhaust emissions:  

CZK 3 000 (app. 120 €) if the emission limits EURO 2, 

CZK 5 000 (app. 200 €) if the emission limit values EURO 1, 

CZK 10 000 CZK (app 400 €) in case of non-compliance with the emission limits under a) and 
b). 

The fee does not apply to vehicles that meet minimum emission limit values EURO 3. 

The fee is paid to support the collection, treatment, recovery, and disposal of ELVs and their 
parts, for infrastructure development and for support of alternative fuel vehicles. The fee is 
payable for the first registration of selected vehicles in the Czech Republic. If the vehicle is 
already  registered  in  the  Czech  Republic,  owner  is  obligated  to  pay  a  fee  for  the  first  re-
registration of vehicles. 360 

6.7.2.3  Finland 

In Finland we have only one PRO for ELV's: Suomen Autokierrätys Oy (Finnish Car recycling 
Ltd).  Producers  (producer  =  the  manufacturer  or  importer  of  the  vehicle  in  a  professional 
capacity) who want to join the PRO have to pay a joining fee (only once) and an annually fee. 
These  fees  are  same  for  producers  who  import new  cars  and  producers  who  import  used 
cars. Both of those fees are depending on the amounts of imported cars. The joining fee is 
300 € for those producers who has imported 49 or less cars / previous year, 600 € for 50-99 
imported cars; 1200 € for 100-199 imported cars; 1500 € for 200-999 imported cars and 2000 
€ for 1000 or more imported cars. The amount of annually subscription fees varied in 2014 
from  minimum  3,20  €/car  for  those  producers  who  imported  more  than  3000  cars/year  to 
maximum 18,92 € for those who imported ten or less cars/year. These annually subscription 
fees cover mainly the administration costs of PRO. There are no additional recycling fees.361 

359 https://www.oecar.at/, accessed: 2022-03-22 

360 Survey of the EC in 2014/2015 

361 Survey of the EC in 2014/2015 

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6.7.2.4  France 

As  reported  in  the  ELV  Expert  Group  meeting  the  31  March  2022,  France  adopted  two 
relevant  legislations  with  this  regard:  the  “Anti  Waste”  bill  (2020)362  and  the  “Climate  and 
Resilience”  bill  (2021)363.  The  “Anti  Waste”  bill  established  the  obligation to  have signed  a 
contract with vehicle manufacturers or PROs to collect, depollute or treat hazardous waste 
from ELVs. The “Climate and Resilience” bill established the obligation to producers to ensure 
free collection of vehicles at holder’s premises and an ELV return bonus to the last vehicle 
holder  paid  by  vehicle  manufacturers  or  PRO  if  it  improves  ELVs  collection  efficiency 
(compensate the gap of economic competitiveness with illegal sector). The level of cost for 
the producers is not known jet. 

6.7.2.5  Republic of Croatia  

According to Croatian ELV legislation, legal or natural person who imports new or used motor 
vehicles or produces motor vehicles and puts them on the market in the Republic of Croatia 
is  obliged  to  pay  ELV  management  fee  to  Croatian  Environmental  Protection  and  Energy 
Efficiency Fund, in the amount of 0,60 kn/kg (€ 0,08/kg).  

The Fund covers the costs of the entire ELV management system and ensures the fulfilment 
of the prescribed objectives of reuse / recovery / recycling: 

a) Compensation for the last owner when handing over an ELV to ATFs. the pay-out (for a 
complete ELV) is 1000 HRK/1000 kg (ca € 130/1000 kg). For an incomplete ELV the pay-out 
is 500 HRK/1000 kg (ca. € 66/1000 kg); 

b)  Compensation for the  collector -  for  collection,  storage,  and transport of  ELVs to  ATFs: 
150-450 HRK/1000 kg (≈ € 20-60/1000 kg) depending on the distance between the pick-up 
point and ATF; in the case of transport distance of more than 150 km: the fee amounts to 
0,80 HRK/km/t (≈ € 0,105/km/t) of vehicles transported364. 

6.7.2.6  Ireland 

Ireland announced for 2023 fees will be 20 € per unit (one-time payment). If a Producer were 
to self-comply, registration fees would be paid to local authorities. The fees paid to the PRO 
ELVES are used to support the operation and objectives of their operation – improving the 
processing  of  ELVs  in Ireland,  primarily  ensuring  ELV  reuse  and  recovery  targets  are met 
and delivering public awareness around the correct way to scrap a vehicle. 

6.7.2.7  The Netherlands  

The  Dutch  EPR  system  is  based  on  a  recycling  fee.  The  recycling  fee  is  a  fixed,  one-off 
supplement that every car buyer in the Netherlands pays when registering for the first time a 
car or light commercial vehicle. The price is the same for all cars, irrespective of the make or 
type, vehicle weight, motorisation or catalogue price. At the start of 1995 the former ‘disposal 
fee’ was 250 guilders. When the euro was introduced in 2002, it became €45. And it remained 

362 https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000041553759 Articles 18, 62 and 72 

363 https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000043956924 Article 32 

364 Survey of the EC in 2014/2015 

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the same until 2016. The funds are directed to ARN the Automotive Recycling Netherlands. 
As outlined in the report of Ademe (2019)  365 “This organisation set specific targets for ELV 
centres: xx% of rubber to be recovered from a car, yy% of plastic from bumpers, zz% of glass, 
etc. This led to a total recovery of 93.5% in The Netherlands. If an ELV centre achieved the 
dismantling targets, the centre received 75 euros per vehicle from the ARN. The difference 
between 45 and 75 euros is due to the volume of exports from The Netherlands, considering 
that half of the vehicles sold in The Netherlands are processed in that country. In 2012, the 
ARN decided to build a post-shredding sorting unit to separate the light fraction from shredder 
waste. This unit replaced “conventional” dismantling practices; nowadays, ELV centres are 
only  required  to  decontaminate  vehicles  before  sending  to  shredders.  The  ARN  no  longer 
subsidises  ELV  centres:  the  organisation  still  receives  the  money  due  from  the  first 
registration of cars, but this premium is used to support the post-shredding sorting unit which 
is not profitable at the moment”.  

In 2020 ARNs PST plant in Tiel is sold to the ESA (Euro Scrap Alliance)366.  

As  explained  at  ARNs  homepage367,  ARN  today  organises,  monitors  and  continually 
optimises environmentally friendly disposal and processing of end-of-life vehicles. All of the 
almost 300 partners in the recycling chain can function optimally through a fair distribution 
key. 

•  From fluid drainage installations to special boxes for transporting batteries: thanks to the 
recycling  fee  we  can  organise  these  issues  together.  ARN  facilitates  this  process  and 
provides practical solutions. 

•  Moreover, ARN spends a part of the recycling fee to help the development of vehicles 
that are easier to dismantle, on protocols for safe dismantling of electric vehicles and on 
new, innovative recycling techniques and procedures. 

Since 2017, the recycling fee has decreased by €2.50 each year. It is currently (2022) €30. 

6.7.2.8  Poland 

From  2005  to  2015  all  natural  persons  placing  vehicles  on  the  Polish  market,  as  well  as 
smaller importers, were required to pay a charge of PLN 500 (just under 110 €)368 for each 
vehicle. The manufacturers and importers marketing large quantities of vehicles (those who 
were required to ensure the vehicle collection network) were exempt from the duty. The funds 
were deposited by the National Fund for Environmental Protection and Water Management.  

Operators  of vehicle  dismantling  facilities  receive  subsidies  in  the  amount  of  PLN  500  per 
each ton of correctly processed waste (ELV). Owing to the limits on the subsidies of 200.000 
€ for 3 years, the operators of vehicle dismantling facilities received state aid for about 500 
vehicles per year. If more ELVs were processed at the facilities, the operators did not receive 
any reimbursement for the processing costs or state aid for the vehicles above the limit. 

365 ADEME (Eric LECOINTRE), Deloitte Développement Durable (Alexis LEMEILLET, Radia BENHALLAM, Antoine HENRY, 
Marie FILLION, Rafael BASCIANO), In Extenso Innovation Croissance (Victoire ESCALON, Beatriz BERTHOUX). 2019. 
Final report: Global Overview of Incentive Schemes aiming to bring ELVs through Authorised Processing Channels. 119 
pages. 

366 EUWID Recycling and Waste Management 18 March 2020: ARN sells post-shredder treatment plant in Tiel to Remondis 
subsidiary 

367 https://arn.nl/en/car-recycling/the-recyclingfee/ accessed 2022-06-22 

368 based on the exchange rate of 2.11.2021, taken form https://de.ex-rate.com/convert/pln/500-to-eur.html 

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Over  PLN  2  billion  have  been  collected  during  the  entire  period.  However,  after  an 
amendment of the Act, most of the funds were spent on other projects, like water supply and 
sewage. 

On 1 January 2016, the Polish ELV Act was amended and the ELV Fund was abolished. The 
amendment  also  introduced  penalties  for  ATFs  in  a  situation  when  recovery  or  recycling 
levels are not achieved. ATF are obligated to pay for each kilogram missing for recovery and 
recycling levels: 

•  0,05 PLN for each missing kilogram needed for recovery level achievement. 
•  0,1 PLN for each missing kilogram needed for recycling level achievement. 

Penalties are doubled in case an ATF doesn’t reach the required levels for the next two years. 

The  same  amendment  introduced  an  obligation  for  car  importers  with  more  than  1000 
vehicles per year, to establish an ELV collection network consisted of three ATF or collection 
points (at least 1 ATF) in each province = 48 elements in the country. To what extent these 
ATF receive financial support from producers / importers is unclear. 

6.7.2.9  Portugal 

Producers/Importers of vehicles (any individual or corporation that places light-duty vehicles, 
new or used, on the national market for the first time) are obliged to: 

Register on the Integrated System of Environmental Licensing (SILiAmb) of the Portuguese 
Environment  Protection  Agency  (APA),  informing  as  to  the  type  and  quantity  of  vehicles 
placed on the national market; 

Ensure  the  existence  of  a  nationwide  network  of  authorised  centres  to  collect  and  recycle 
ELVs  produced  in  the  country.  This  responsibility  can  be  assumed  individually  (individual 
system) or collectively (integrated system). 

If the Producer/Importer opts to join the integrated system (SIGVFV), the responsibilities are 
transferred  to  VALORCAR  by  signing  a  contract.  This  contract  entails  the  payment  of  a 
Financial Provision to finance VALORCAR’s operations. 

The Financial Provision for each vehicle placed on the national market for the first time and 
covered by the current ELVD (M1 and N1 vehicles) is for new and used vehicles 1.2 €. For 
used vehicles produced (first registered) before 3/Feb/2010 the Financial Provision is 5,0 per 
vehicle369.  

Previously  (in  2014)  a fee  was  charged  for  new  vehicles  only.  The  fee was  not  applied to 
second-hand vehicles, which represent 14,7% (around 29 000 second hand vehicles) of the 
new vehicle market in 2014.370 

6.7.2.10  Slovakia  

In 2014 Slovakia reported to the EC having a recycling fund for ELVs. New and used vehicles 
placed  for  the  first  time  on  the  national  market  have  to  contribute  66,39  €/  vehicle  to  this 
fund371. 

369 https://www.valorcar.pt/en/vfv/fabricantes (accessed 2022-06-22) 

370 Survey of the EC in 2014/2015 

371 Survey of the EC in 2014/2015 

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In  the  meantime,  the  fund  was  abolished  and  the  PRO  Autorecycling372  is  charging  its 
members with 24 € per vehicle373. Not all producers / importers entered the PRO, individual 
systems are existing in parallel. 

6.7.2.11  Norway 

Norway has introduced risk sharing in relation to scrap price. 

From  1978  to  2006  ATFs  were  paid  by  the  Norwegian  government  for  depollution  and 
treatment of the ELVs. In 2007 the system was changed from state-run system to EPR. In 
2009 the different parties (manufacturers, importers, ATFs, shredders) agreed upon a long-
term  financial  risk  sharing  agreement.  The  agreement  establishes  a  risk  sharing  model  in 
dependence of the scrap prices (in case of low scrap prices ATFs receive compensation form 
EPR).  The  agreement  also  addresses  specific  long  distance  transport  cost  from  ATFs  to 
shredders.374  

No  recycling  tax,  but  a recycling  fee  of  62,50  NOK (8  EUR)  must  be  paid  to the  Producer 
Organisation.375  

6.7.3  Details for Member States with Deposit Refund Systems 

The current systems are not under an umbrella of EPRs but managed by public authorities. 
However,  we  mentioned  these  here  as  it  is  a  cost  neutral  (despite  management)  financial 
incentive to strengthen the competitiveness of the ATFs against the illegal sector and thus 
supports many of the objectives of the ELVD. To our knowledge only a minority of Member 
States have established such systems as displayed below.  

6.7.3.1  Norway  

The  deposit  refund  System  was  implemented  in  Norway  in  1978.  The  intention  was  an 
incentive for the last owner to deliver the ELV to an ATF. A fee of NOK 2400 (€ 250) is paid 
if a vehicle is registered for the first time. The pay-out of NOK 3000 (€ 315) is provided to the 
last  owner  upon  demonstration  that  a  CoD  is  issued.  The  system  is  managed  by  the 
Norwegian Tax Administration.376 

6.7.3.2  Denmark  

In  order  to  drive  legally,  the  car  owner  has  to  pay  a  mandatory  insurance.  On  top  of  the 
insurance  the  car  owner  pays  an  additional  fee.  The  current  rate  is  101  DKK/year,  the 
proposed future rate 85 DKK/year, in 2013 it was 65 DKK/year377. The extra money collected 

372 https://www.autorecycling.sk/ 

373 https://www.autorecycling.sk/dovoz-vozidla/ (accessed 2022-06-22) 

374 Siri Sveinsvoll (2019): The Norwegian ELV System, presentation held at the IV INTERNATIONAL CONFERENCE: 
DOMESTIC AND WORLDWIDE VEHICLES RECYCLING PRACTICE AND EXPERIENCE in Cracow, September 18th-20th, 
2019 

375 Survey of the EC in 2014/2015 

376 Siri Sveinsvoll (2019): The Norwegian ELV System, presentation 

377 Jens Michael Povlsen (2016): Improving ELV collection rates in Denmark-a story about a changed market, TAC meeting 22 
November 2016 

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is forwarded to the EPA, and finally to Danish EPR System378. The pay-out to the last owner 
was in the first year 1200 DKK per ELV, increased in 2002 to 1750 DKK, dropped in 2014 to 
1500 DKK and increased to a level of 2200 DKK per ELV in 2017. As displayed in the figure 
below  the  number  of  collected  vehicles  dropped  at  the  same  time  when  the  pay-out  was 
reduced in 2014 and increased again when the level of pay-out increased in 2017. In 2016 a 
comprehensive  study  assessed  diverse  impacts  of  services  and  incentives  on  the  ELV 
market379. 

Figure 6-20  Denmark: Pay-out for ELVs and number of ELVs collected 

y

)
V
L
E
/
K
K
D

(

t
u
o
-
y
a
p

 2 500

 2 000

 1 500

 1 000

 500

 -

 140 000

 120 000

 100 000

 80 000

 60 000

 40 000

 20 000

 -

d
e
t
c
e

l
l

o
c

s
V
L
E

2021*: 5 000 DKK only for diesels from pre-2006

pay out (DKK)

ELVs collected

Sources:  
https://www.dr.dk/nyheder/penge/1750-kroner-skrotte-bilen; 
https://fdm.dk/nyheder/bilist/2016-09-minister-vil-haeve-skrotpraemie;  
https://bilmagasinet.dk/bil-nyheder/nye-regler-saadan-faar-du-5-000-kr-i-skrotpraemie-for-en-gammel-dieselbil  

https://www.retsinformation.dk/eli/accn/B20140029305;  

378 Stig Thorlak, DPA (2017): Country Report: Hot topics in the Danish Dismantling Industry, presentation at the IARC 2017 the 
22.- 24 March 2017 in Berlin) 

379 Deloitte Consulting (September 2016): Udredning af skrotningsgodtgørelsens incitamentsstruktur ( 

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6.8  Detailed  results  of  the  impact  analysis  for  EPR  Scheme 

and economic instruments 

6.8.1  Screening measures and separate discarded options 

The table below displays the criteria for screening.  

III. Screen your options and separate discarded options 

Why? 

To focus the analysis on the viable options. In choosing the options, it is 
important  to  focus  on  those  elements  that  are  most  critical  for  the 
Commission to decide on (i.e., those with significant impacts). As with the 
problem  analysis,  you  must  ensure  that  the report remains focused  and 
that it does not drown the major issues in a ‘flood’ of minor issues. 

Excluding options at this stage should be clearly justified. Reasons should 
be as clear, self-evident and indisputable as possible. The report should 
explain  when  it  had  to  discard  policy  options  favoured  by  stakeholders. 
This  should  be  done  in  a  separate  section  on  discarded  options  (if 
necessary, with further details in the annexes). 

The key criteria for screening the viability of your options are: 

Legal feasibility 

Options  should  respect  the  principle  of  conferral380.  They  should  also 
respect  any  obligation  arising  from  the  EU  Treaties  (and  relevant 
international agreements) and ensure respect of fundamental rights. Legal 
obligations  incorporated  in  existing  primary  or  secondary  EU  legislation 
may also rule out certain options. 

How? 

Technical feasibility 

Technological  and 
implementation, monitoring or enforcement of theoretical options. 

technical  constraints  may  not  allow 

for 

the 

Previous policy choices 

Certain options may be ruled out by previous policy choices or mandates 
by EU institutions. Unless there is compelling evidence that these choices 
should be revisited, there is no point in reinventing the wheel. 

Coherence with other EU policy objectives 

380 Under this fundamental principle of EU law, laid down in Article 5 of the Treaty on European Union, the EU acts only within 
the limits of the competences that EU countries have conferred upon it in the Treaties. These competences are defined in 
Articles 2–6 of the Treaty on the Functioning of the EU. Competences not conferred on the EU by the Treaties thus remain 
with EU countries. 

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Certain options may be ruled out early due to poor coherence with other 
general EU policy objectives. 

Effectiveness and efficiency 

It may already be possible to show that some options would with certainty 
achieve a worse cost-benefit balance than some alternatives. 

Proportionality 

Some options may clearly restrict the scope for national decision-making 
over and above what is needed to achieve the objectives satisfactorily. 

Political feasibility 

Options that would clearly fail to garner the necessary political support for 
legislative  adoption  or  implementation  could  also  be  discarded.  This, 
however, does not mean that such options should not be mentioned or not 
be  subject  to  at  least  a  minimal  assessment.  Options  superior  to  other 
options,  but  lacking  political  feasibility  may  still  be  discussed  at  the 
legislative  stage,  which  may  increase  their  chances  of  being  politically 
feasible. 

Relevance  

There is no point in retaining options that do not address the needs of the 
policy intervention as identified in the problem definition. 

Identifiability 

When it can be shown that two options are not likely to differ materially in 
terms  of  the  proposed  measures,  their  significant  impacts  or  their 
distribution, only one should be retained. 

Source: Better Regulation toolbox Tool #16, Textbox page 114 – 115 

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In the following the potential measures are assessed against these criteria and a justification is given for the case that an option is considered 
as discarded. The numbers in the column “Viability screening” refer to the numbering of the key criteria for screening as displayed in the 
table above.  

Table 6-33 Initial assessment of measures to identify discarded and short-listed measures 

Measure  

Viability 
screening 

Effectiveness 

Comment, Discard justification 

1  Specification of general minimum requirements of Art 8/8a WFD: 

Obligations for the Member States 

1.1  Obligation  for  all  MS  to  establish 

national EPR schemes 

Pre-Condition  for 
effectiveness 

Precondition 
 Short list 

regards 

measures 

und 

2.1 

to 

2.9 

below 

1.2  MS  to  report  on  implementation  and 

enforcement regards EPR 

Pre-Condition  for 
effectiveness  

Unclear  to  what  extent  WFD  Art  8  /  8a  is  implemented  and  enforced  in  the  MS. 
A reporting obligation is required on the implementation and enforcement of Art 8 / 8a and the 
new 
specifications. 
 Short list 

introduced 

EPR 

1.3  MS 

to  establish  an 

independent 
competent authority (clearing house)  

Pre-Condition  for 
effectiveness 

Minimum requirements for the governance, the supervision, monitoring and moderation of the 
stakeholders 
 Short list 

2 

Specification of general minimum requirements of Art 8/8a WFD: 
Obligations for Producers to cover cost for 

2.1  Collection  of  vehicles  at  holder’s 
premises  and  abandoned  vehicles 
free  of  charge  for  the  last  holder. 
  specification  of  WFD  Art  8a(3) 
point (b) 

Possibly 
high 
effectiveness  but 
at high cost too 

2.2  Awareness  raising  of  last  holder  to 

deliver ELVs to ATFs 

Zero to medium  

Currently  the  last  holder  is  obliged  to  deliver  the  vehicle  to  an  ATF  (or  collection  point). 
Producers  are  responsible  to  offer  ATFs/  collection  points  sufficiently  close  (geographical 
coverage). 
responsibility;  
If all / abandoned vehicles are collected on cost of the OEMs at holder’s premise this might 
cause inefficient cost. The impact assessment shall assess the cost accordingly.  

system 

current 

share 

The 

of 

is 

a 

 Short list 

This might be the possibly more cost-effective measure compared to the previous 

 Short list 

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Viability 
screening 

Effectiveness 

Comment, Discard justification 

2.3a Establishment of a notification system 

for ELV, CoD and final cancellation 

Medium to high 

New 
IT 
 Short list 

Harmonisation 

burden 

will 

improve 

efficiency 

to 

of 

ATFs 

and 

producers;  
authorities 

2.3b.Support 

interfaces 
/  software 
international notification system 

to 

-/- 

According to previous policy choices the exchange between national registration authorities 
shall be a task to the Member States. It is deemed as politically not feasible and technically 
challenging  to  shift  this  obligation  to  producers.  The  Producers  shall  not  interfere  in  the 
cooperation of the national registration systems 

 discarded 

2.4  Monitoring  of  material  flows  and 
compliance with RRR targets 

2.5  Monitoring  and  reporting  on  illegal 

activities in the sector 

Training 
shredders)  

for  staff  of  ATFs  (and 

Provision  of  easy  access 
harmonised information 

to 

Fee modulation  

Compliance cost offsetting  

3. Advanced European EPR 

Low to medium 

Could be done in principle by public authorities as well, but under EPR expected much more 
efficient.  
 short list 

Low to medium 

in 
Effective 
particular 
for 
small  (and  SME) 
ATFs 

New burden to producers; Will increase efficiency of inspection campaigns 

 short list 

New  burden  to  producers:  will  support  and  encourage  ATFs  to  build  up  knowledge.  In 
particular for small ATFs the provision of such free training is of high relevance as to them it 
is 
bloc. 
 Short list 

relevant 

cost 

a 

medium 

 Short list 

Long  term  effects 
on design for CE 

 Short list 

Precondition 
circularity  

for 

 Short list 

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Viability 
screening 

Effectiveness 

Comment, Discard justification 

3.1  EPR  schemes  for  intra  EU  trade 
(delegated / implementing act) 

3.2  European  EPR  for  the  EU  market 

(feasibility study) 

4. Advance economic incentives 

4.1  Deposit  Refund  Schemes 

(DRF) 

manged by EPR scheme 

4.2 Green Public Procurement 

Depends  on  the 
details,  mid-term 
impacts  

Depends  on  the 
details,  mid-term 
impacts 

 Short list 

 Short list 

Potentially high  

As  discussed  under  the  section  “missing  vehicles”,  DRF  schemes  are  considered  as  a 
voluntary option and the MS might opt to establish it under the national EPR scheme or as a 
public fund. Insofar this option becomes superfluous  

 discarded 

Medium, 
term 

long-

 Short list 

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Measure  

Viability 
screening 

Effectiveness  Comment, Discard justification 

Advance economic incentives 

  Compliance cost offsetting 

  Deposit  Refund  Scheme  (DRF)  for 

vehicles 

  EPR schemes for intra-EU trade 

  European  DRF  for  the  European 

Market 

  Strengthening  the  relevance  of  the 
implement 
COD,  Level  B:  either 
strong  economic  incentives  as  listed 
or demonstrate equal effectiveness 

Fee  modulation  based  on  circularity 
features 

Precondition  for 
more 
challenging 
(high 
recycling  

quality) 

 short list 

Potentially  high 
if the premium is 
high enough 

Implementation will take time to become effective in all Member States. Possible unequal strength 
of  negotiators  (OEMs/  ATFs/  shredders)  could  lead  to  low  DRF  pay  out  and  limited  impact. 
  short list 

The  measures  is  not  in  conflict  with  proportionality  as  it  is  up  to  the  MS  how  the  economic 
incentives are established. 

 short list 

 short list 

High 

Difficult 
to 
achieve  a  level 
of  modulation 
influences 
that 
the 
purchase 
decision 

  Green public procurement 

Low  

GPP at EU level is for voluntary application and insofar guidance only. However, it does not harm 
providing such EU guidance and costs for the development of the guidance are limited to cost for 
the 
application 
 short list  

obligatory 

Potential 

later 

EC. 

for 

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6.9  Description  of 

the  model 
assessment (environmental) 

to  calculate 

the 

impact 

6.9.1  General description of the model 

The  development  of  the  model  represents  a  central  element  of  the  impact  assessment 
support study. The main task of the tool is to assist in the determination of impacts of applying 
policy  options  intended  to  address  shortcomings  identified  in  the  ELV  Directive.  Related 
changes in the Directive’s provisions and thus also the results of the model shall reflect the 
protection  of  the  environment,  the  promotion  of  the  circular  economy  and  the  smooth 
functioning of the internal market.  

The outcome of the model is not restricted to quantitative data outputs. As an analytical tool, 
relationships,  dependencies  and  linkages  between  different  stakeholders  or  operators  and 
also along the entire lifecycle of vehicles are identified, analysed and clarified. The mass flows 
from sales until the end-of-life stages of the vehicle’s life cycle play a key role in the model.  

A full range of impacts and thus a relevant share of the results of the policy options are directly 
linked and proportional to the mass flows. This applies especially to environmental impacts. 
Some economic data is directly linked to mass flows, too. 

The structure of the model is tailored to its purpose and the model is able to process a variety 
of  policy  options  from  different  areas  (e.g.  reuse  targets  and  specific  material  recycling 
targets). This required a flexible but simple approach. Such a pragmatic approach has also 
helped the study to focus on the actual task, namely the policy options and their impacts. 

The following sub-sections provide an overview of the structure and the characteristics of the 
model. 

6.9.1.1  Scope of the model 

With  the  focus  on  the  end-of-life  vehicles,  the  details  of  vehicle  production  become  less 
important. Therefore, the initial life cycle stages of resource extraction, material processing 
and vehicle assembly were aggregated to the common process of ‘vehicle production’. Thus, 
the mass flows start with the ‘sales’ stage which includes the carbon footprint of the vehicle 
production (e.g. carbon footprint, x kg CO2eq per vehicle; material footprint, x kg copper per 
vehicle). The vehicle life cycle ends with recycling and recovery of secondary materials.  

The geopolitical scope of the model covers the EU-27 and thus excludes the United Kingdom. 

6.9.1.2  Timeframe of ELV mass flows 

The model covers a period up to the year 2035. Results are available for the years 2020 to 
2035.  Not  extending  the  modelling  period  beyond  2035  seems  sensible  in  view  of  the 
unpredictable technical possibilities and developments, especially in the development of the 
vehicle fleet.  

As a starting point for comparison – mainly for developing, checking and adapting modelled 
vehicle mass flows – we use time series that go back to the year 2009 for all applications 
except for ICEVs which have been modelled back to 1990. The most recent data from Acea 

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are available for the reference year 2020. The future perspective is based on data from the 
Euro 7 impact assessment381. 

6.9.1.3  Types of engines 

For each individual life cycle stage, the mass flows are differentiated into the relevant engine 
types of ELVs. The following engine types are addressed in the model: Internal combustion 
engines (ICEs), battery electric vehicles (BEVs), Hybrid electric vehicles (HEVs) and Plug-in-
Hybrid electric vehicles (PHEVs). 

There is a wide variety of terms to describe the type of technology that moves a vehicle. This 
includes terms such as ‘powertrain’, ‘drive system’, ‘drive type’, ‘propulsion system’, etc. The 
terms all differ slightly in their definitions and with regard to the components contained in a 
vehicle.  In  this  study,  all  of  these  terms  are  used  synonymously  to  differentiate  between 
vehicles  powered  by  a  battery (BEV), by an  internal combustion engine (ICE)  or by both (PHEV, 
HEV). 

For the in-depth investigation of the fleet development in the passenger vehicle sector in the 
EU, the following propulsion systems are considered in the scenarios: 

ICE: vehicle with an internal combustion engine (diesel or petrol), 

• 
•  BEV: battery electric vehicle, 
•  HEV: hybrid electric vehicle, 
•  PHEV: plug-in hybrid electric vehicle. 

Passenger  cars  with  other  propulsion  systems,  such  as  fuel  cell  vehicles  (FCEV),  were 
excluded from this study, as only very few of these vehicles are expected to be in use during 
the period considered in the scenarios. In the context of this study, natural gas vehicles are 
treated as ICEs as they are based on the same principles using a different fossil fuel. FCEV 
are comparable to BEVs since they also contain a battery and an electric motor, resulting in 
a very roughly comparable resource demand (when excluding the fuel cell itself). 

6.9.1.4  Environmental Impact categories 

The environmental assessment is based on a life cycle approach. The entire life cycle of ELVs 
is  taken  into  account:  from  the  extraction  of  primary  resources  and  energy  sources,  the 
production of the vehicles to the recycling processes of the ELVs and disposal of materials at 
the end of the life cycle. 

A full range of impacts and thus a relevant share of the results of the policy options are directly 
linked and proportional to the mass flows. This applies especially to environmental impacts. 
Some economic data are as well directly linked to mass flows depending on the policy options 
that are selected for assessment. 

The main environmental impact category that is given as a default by the model is the global 
warming potential (GWP in t CO2eq) (CO2-equivalents = CO2eq). 

A further 10 environmental impact categories can be called up via the model, including e.g. 
acidification  potential,  ozone  layer  depletion,  photochemical  oxidation  or  eutrophication. 
These impacts are linked to individual life cycle stages of the mass flows, as described above 
for  the  example  of  the  production  footprint  linked  to  ‘sales’.  Other  life  cycle  stages  with 

381 Aeris Europe: Euro 7 Impact Assessment: The outlook for air quality compliance in the EU and the role of the road transport 
sector. 2021. Online available under https://aeriseurope.com/papers-and-articles/euro-7-impact-assessment-the-outlook-for-
air-quality-compliance-in-the-eu-and-the-role-of-the-road-transport-sector/ 

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relevant environmental impacts are ‘recycling’ and a comparison of the production of primary 
and secondary materials (e.g. steel, aluminium, copper, plastics and glass). 

LCA  studies  and  LCA  databases  are  the  source  for  the  calculation  of  the  environmental 
impacts.  If  available,  datasets  from  the  database  ecoivent  3.8  were  preferred.  The  used 
datasets from LCA databases and the used literature are listed in Table 6-37 to Table 6-39.  

6.9.2  Fleet model 

6.9.2.1  Material composition of the vehicles 

To  model  the  material  composition  of  passenger  cars,  data  from  JRC-RMIS382  on  the 
composition  of  passenger  cars  was  used,  supplemented  by  data  from  the  Greet  model 
(Argonne 2021) (see Table 6-34). The percentage composition was calculated down to the 
average weight of ELVs in the EU according to Eurostat.  

Table 6-34 Material composition of End-of-life vehicles (passenger cars) in kg after 
depollution 

Material  

Steel 

Cast Iron 

Wrought Aluminium 

Cast Aluminium 

Copper 

Magnesium 

Manganese 

Glass 

Average Plastic 

Rubber 

Glass Fiber-Reinforced Plastic 

Others 

Total 

ICEV 

 653  

 101  

 40  

 79  

 14  

 5  

8 

 24  

 159  

 41  

 9  

 5  

HEV 

 660  

 101  

 58  

 91  

 20  

 5  

8 

 21  

 129  

 34  

 4  

 6  

PHEV 

 621  

 96  

 76  

 93  

 23  

 5  

8 

 22  

 143  

 38  

 5  

 7  

EV 

 642  

 16  

 108  

 77  

 35  

 1  

7 

 26  

 166  

 39  

 5  

 14  

 1 137 

 1 137 

 1 137  

 1 137  

Source: Calculated with data from JRC-RMIS and Argonne 2021 and average weight according to Eurostat 

6.9.2.2  For  the  calculation  of  the  material  composition  of  other 
vehicles (see Table 6-4 through Table 6-7) other sources 
are used: 

Please see section 6.1.3 under this annex.  

6.9.2.3  Sales and Stock 

The model delivers mass flows based on the development of different types of vehicles. It 
includes  passenger  cars  with  a  variety  of  different  propulsion  types  (internal  combustion 

382 https://rmis.jrc.ec.europa.eu/apps/veh/#/p/viewer 

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engine  (ICE),  hybrid  electric  vehicles  (HEV),  plug-in  hybrid  electric  vehicles  (PHEV)  and 
battery  electric  vehicles  (BEV).  Furthermore,  the  model  also  includes  light  commercial 
vehicles, heavy commercial vehicles and buses. The fleet model for all vehicles is based on 
the  model  used  for  the  Euro  7  impact  assessment383.  The  data  were  supplemented  by 
additional information from other sources. The overall development has been cross-checked 
with scenarios used by the JRC. 

The  next  below  shows  the  sales  of  passenger  cars  in  the  EU  split  by  propulsion  types 
according to statistical data from ACEA and the predicted forecast according to Euro 7 impact 
assessment. 

Figure 6-21  Sales of passenger cars in the EU (2009-2035) 

Source: Own calculation on the basis of data from Aeris Europe 2021 and ACEA 2021 

Since this only covers the fraction of newly registered vehicles, the vehicle stock had to be 
modelled. To cover the accurate number of vehicles in the stock, the model takes into account 
all registrations dating back to 1990 based on ACEA data (ACEA 2009-2019, OICA 2020). 

The figure below shows the development of the stock of passenger cars in the EU split by 
propulsion types. 

383 Aeris Europe: Euro 7 Impact Assessment: The outlook for air quality compliance in the EU and the role of the road transport 
sector. 2021. Online available under https://aeriseurope.com/papers-and-articles/euro-7-impact-assessment-the-outlook-for-
air-quality-compliance-in-the-eu-and-the-role-of-the-road-transport-sector/ 

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Figure 6-22  Development of the stock of passenger cars int the EU 

Source: Own calculation on the basis of data from Aeris Europe 2021 and ACEA 2021 

6.9.2.4  EoL 

In order to determine volumes of ELVs, it is necessary to estimate the duration of the use 
phase of the vehicles.  

To describe the probability of a vehicle reaching its end-of-life, a Weibull distribution has been 
used. Since no long-term data on the lifetimes of EVs are currently available, estimates based 
on literature, interviews with the automotive industry and own expert judgement have been 
used  to  determine  reasonable  assumptions  for  the  lifetime  of  EVs  (Ricardo  2015,  Møller 
Andersen 2008, Buchert et al. 2017, Buchert et al 2019, Mehlhart et al. 2017). 

The figure below depicts the curve used for ICEs, EVs, PHEVs and HEVs. The distribution 
shows the probability of the number of years after which a newly registered vehicle reaches 
its end of life. Accordingly, e.g. 14% of all vehicles that have been registered 15 years ago 
will reach the EoL.  

Figure 6-23  EoL Weibull distribution for vehicles 

Source: Own representation 

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The model calculates the volumes of ELVs for each year based on the lifetime distribution 
shown above. This represents the total volume of ELVs available for collection.  

6.9.2.5  ELVs available for recycling in the EU 

The total volume available for recycling in the case of ELVs is reduced due to some losses. 
There  are  two  main  types  of  losses.  Firstly,  export  losses  and  secondly,  unknown 
whereabouts.  

In the assessment report of the ELV directive, Mehlhart et al. (2017) pointed out that in 2014 
app.  12  million  vehicles  were  estimated  to  become  ELVs  in  the  EU,  51%  of  which  were 
reported.  App.  10  %  of  the  used  vehicles  were  exported  (outside  the  EU)  and  39 %  had 
unknown  whereabouts.  It  is  assumed  that  half  of  the  unknown  were  exported  to  non-
Community  countries  and  half  were  dismantled  within  the  EU  without  reporting.  This 
assumption leads to an estimated export rate of 35 % which has been used for the baseline 
for HEVs and PHEVs since these vehicles are similar to ICEVs. BEVs, on the other hand, are 
expected to be exported to a lesser extent, since they require a charging infrastructure which 
is not available in all countries outside the EU. Hence, the export rate applied for used BEVs 
is 10 %. The figure below shows the development of ELVs available for recycling in the EU 
split by split by propulsion types. 

Figure 6-24  Development of ELVs available for recycling in the EU 

Source: Own calculation on the basis of data from Aeris Europe 2021 and ACEA 2021 

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Table 6-35 ELVs available for treatment (PTW, lorries, buses, trailers) 

EoL 

2020 

2021 

2022 

2023 

2024 

2025 

2026 

2027 

2028 

2029 

2030 

motorcycles 

1336572 

1362667 

1388348 

1413449 

1437763 

1461075 

1483176 

1503903 

1523145 

1540863 

1557104 

lorries 

buses 

Trailers 

212025 

216992 

222048 

227193 

232418 

237708 

243023 

248291 

253441 

258410 

263158 

28061 

28449 

28822 

29182 

29527 

29859 

30177 

30483 

30780 

31070 

31359 

1007722 

1039377 

1072220 

1106517 

1142498 

1180362 

1220275 

1262369 

1306737 

1353423 

1402422 

Source: Calculated as M1 and N1 ELVs based on stock data from the PRIMES model for lorries and buses, calculated based 
on Eurostat and linear forecast according to development from 2015-2019 for trailers; calculated based on Eurostat using the 
trend in the EU Reference Scenario for PTW. 

6.9.3  Reuse 

In  case  of  reused  parts  or  materials  in  the  model  Since  the  model  includes  detailed 
information  related  to  material  compositions  of  the  different  vehicles,  it  allows  for  the 
estimation  of  recycling  potentials.  In  the  case  of  reused  parts,  an  environmental  credit  is 
calculated based on the environmental burdens of primary production of the corresponding 
material. 

6.9.4  Recycling 

Since the model includes detailed information related to material compositions of the different 
vehicles, it allows for the estimation of recycling potentials.  

The  recycling  of  the  end-of-life  vehicles  is  modelled  in  different  steps:  depollution, 
dismantling,  shredding,  post-shredder  technologies  (PST)  and  material  specific  recycling 
processes.  The  steps  of  depollution,  dismantling  and  shredding  were modelled  using  data 
from Sander et al. (2020). The PST was calculated using data from JRC. 

The following table shows the efficiency rates for different materials that have been used in 
the model. In the second column (‘Recycling rate (ASR + PST)’) recovery rates from shredder 
(ASR) and post shredder treatment (PST) from literature and interviews are given for different 
materials.  In  the  third  column  (‘Recycling  rate  (specific  process)’)  recovery  rates  for  the 
materials specific recycling processes are given, e. g. the recovery rate for steel recycling in 
an  electric  arc  furnace.  The  percentages  refer  to  the  input  that  goes  into  the  shredding 
process and the specific recycling process, respectively, not to the original composition of the 
ELVs. 

The efficiency rates here only include those quantities that were recovered as material, not 
of those quantities where, for example, glass was used for backfilling or aluminium was used 
as a reducing agent in steel recycling.  

Table 6-36 Efficiency rates for different materials in ASP + PST and in the material 
specific recycling processes 

Material  

Efficiency rates (ASR + PST) 

Efficiency rates (specific 
process) 

Steel 

Cast Iron 

Wrought Aluminium 

99% 

99% 

85% 

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Cast Aluminium 

Copper 

Glass 

Average Plastics 

PP 

PUR 

Nylon 

PE 

ABS 

PET 

85% 

85% 

0% 

24% 

40% 

0% 

0% 

40% 

37% 

0% 

94.5% 

76.3% 

99.5% 

95.0% 

95.0% 

95.0% 

95.0% 

95.0% 

95.0% 

95.0% 

Source: Recycling rates ASR: own estimations according to data from Sander et al. 2020; PST: JRC 2021; Materials specific 
recycling rates: ecoinvent 3.8 

6.9.5  LCA data 

The calculation of the environmental impacts of ELVs takes into account different life cycle 
stages,  including  upstream  processes.  Results  are  generated  according  to  different 
environmental  impact  categories.  The  calculation  presented  in  this  study  is  based  on  the 
ecoinvent  database  (ecoinvent  3.8),  the  “openLCA”  (openLCA  2022)  LCA  tool  and  further 
literature  data.  The  quantification  of  environmental  impacts  of  ELVs  focuses  on  material 
production (incl. upstream processes such as mining and further processing, regardless of 
whether inside or outside the EU) and the recycling of the end-of-life vehicles. Detailed results 
of the calculations are presented for selected impact categories in Table 6-40 to Table 6-43. 

The  following  sections  describe  the  applied  methodology  and  main  assumptions  used  for 
quantifying the environmental impacts of batteries. 

Generally,  quantifications for  this  simplified  approach  could  not  be  newly  developed  within 
the scope of this study. This means that no primary data, e.g. from producers or recyclers, 
were collected and no new and detailed LCA was developed for individual production and 
recycling  processes,  but  rather  LCA  data  were  extracted  from  literature  sources.  The 
calculation presented is based on these literature data and the ecoinvent database (ecoinvent 
3.8). 

Although  much  literature  is  available  addressing  the  environmental  impacts  of  ELVs,  its 
usability for the present calculation is limited for various reasons, including:  

the level of detail is not sufficient to extract relevant data;  

• 
•  different functional units are applied;  
• 
• 

relevant input factors are not compatible to the scope of the present calculation; and/or  
results are given in aggregated parameters instead of individual impact categories. 

A full range of environmental impacts is directly linked to the mass flows in the model. The 
total  environmental  impacts  are  proportional  to  the  mass  flows  and  are  calculated  via  the 
model  for  the  different  policy  options.  The  main  environmental  impact  category  that  was 
evaluated  via  the  model  and  addressed  in  the  report  is  climate  change  (global  warming 
potential GWP in kg CO2-eq.). 

A further 10 environmental impact categories can be called up via the model: 

Abiotic depletion potential of mineralic resources (ADPelem. in kg Sb eq.) 
Abiotic depletion of fossil fuels (ADP in MJ) 
Acidification (AP in kg SO2 eq.) 

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Eutrophication potential (EP in kg PO4---eq.) 
Fresh water aquatic ecotoxicity (FAET in kg 1,4-DB eq.) 
Human toxicity (in kg 1,4-DB eq.) 
Marine aquatic ecotoxicity (MAET in kg 1,4-DB eq.) 
Ozone layer depletion potential (ODP in kg CFC-11 eq.) 
Photochemical oxidation (POCP in kg C2H4 eq.) 
Terrestrial ecotoxicity (TET in kg 1,4-DB eq.) 

The impacts are linked to individual life cycle stages of the mass flows as described above 
for the example of the production footprint linked to ‘placed on the market’. Other life cycle 
stages with relevant environmental impacts are ‘recycling’ and a comparison of the production 
of primary and secondary materials (e.g. steel, aluminium, copper, plastics).  

The  primary  production  of  vehicles  was  calculated  from  the  material  composition  of  the 
vehicles with data for the primary production of these materials and the energy and material 
demand for the manufacturing of the vehicles.  

The recycling was calculated from the energy and material demand for the recycling process 
and the refining of the recovered materials. Credits for the recovered materials were given for 
the avoided primary production. 

The  data  for  the  primary  production  and  the  recycling  was  taken  from  the  LCA  database 
ecoinvent  3.8  and  specific  LCA  studies  and  supplemented  by  information  from  the 
stakeholder surveys. Data and the data sources, which have been used for the modelling of 
the primary production of materials and the recycling of the vehicles used, are listed in the 
following tables. 

Table 6-37 LCA data: Used datasets from ecoinvent 3.8 for primary production of 
materials 

Material  

Used dataset from ecoinvent 3.8 for primary production 

Steel 

steel production, converter, low-alloyed | APOS, U 

Stainless Steel 

market for steel, chromium steel 18/8, hot rolled | APOS, U - GLO 

Cast Iron 

market for cast iron | APOS, U | GLO 

Wrought aluminium 

aluminium ingot, primary, to aluminium, wrought alloy market | APOS, U 

Cast aluminium 

aluminium ingot, primary, to aluminium, cast alloy market | APOS, U | GLO 

Copper 

Glass 

Zinc 

market for copper, cathode | APOS, U | GLO 

market for flat glass, uncoated | APOS, U - RER 

market for zinc | APOS, U | GLO 

Magnesium 

market for magnesium | APOS, U - GLO 

ABS 

market for acrylonitrile-butadiene-styrene copolymer | APOS, U - GLO 

Liquid Epoxy 

market for epoxy resin, liquid | APOS, U | RER 

GPPS 

HIPS 

HDPE 

LDPE 

LLDPE 

polystyrene production, general purpose | APOS, U | RER 

polystyrene production, high impact | APOS, U | RER 

market for polyethylene, high density, granulate | APOS, U - GLO 

market for polyethylene, low density, granulate | APOS, U - GLO 

market for polyethylene, linear low density, granulate | APOS, U > GLO 

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Nylon 6 

Nylon 66 

PC 

PET 

PP 

market for nylon 6 | APOS, U - RER 

market for nylon 6-6 | APOS, U | RER 

market for polycarbonate | GLO 

market for polyethylene terephthalate, granulate, amorphous | APOS, U - GLO 

market for polypropylene, granulate | APOS, U - GLO 

PUR Flexible Foam 

market for polyurethane, flexible foam | APOS, U - RER 

PUR Rigid Foam 

market for polyurethane, rigid foam | APOS, U - RER 

PVC 

Rubber 

Carbon Fiber-
Reinforced Plastic 

Glass Fiber-
Reinforced Plastic 

Nickel 

PTFE 

Platinum 

Silicon 

market for polyvinylchloride, suspension polymerised | APOS, U - GLO 

market for synthetic rubber | APOS, U - GLO 

market for carbon fibre reinforced plastic, injection moulded | APOS, U | GLO 

market for glass fibre reinforced plastic, polyester resin, hand lay-up | APOS, U 
- GLO 

market for nickel, class 1 | APOS, U | GLO 

market for tetrafluoroethylene film, on glass | APOS, U | GLO 

market for platinum | APOS, U - GLO 

market for silicone product | APOS, U | RER 

Gold primary 

market for gold | APOS, U 

Silver primary 

market for silver | APOS, U 

Tin primary 

market for tin | APOS, U 

Brass primary 

brass production | APOS, U 

Palladium primary 

market for palladium | APOS, U 

Table 6-38 LCA data: Used datasets from ecoinvent 3.8 for secondary production of 
materials 

Material  

Used dataset from ecoinvent 3.8 for secondary production 

Steel 

steel production, electric, low-alloyed | APOS, U 

Wrought aluminium 

treatment of aluminium scrap, wrought alloy, post-consumer, prepared for recycling, 
at remelter | aluminium, | APOS, U 

Cast aluminium 

treatment of aluminium scrap, cast alloy, post-consumer, prepared for recycling, at 
refiner | APOS, U 

Copper 

Glass 

HDPE 

PET 

treatment of copper scrap by electrolytic refining | APOS, U 

(Own LCA for glass recycling with confidential data from industry) 

polyethylene production, high density, granulate, recycled | polyethylene, high 
density, granulate, recycled | APOS, U 

polyethylene terephthalate production, granulate, amorphous, recycled | 
polyethylene terephthalate, granulate, amorphous, recycled | APOS, U 

Platinum 

treatment of automobile catalyst | platinum | APOS, U 

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Table 6-39 LCA data: Used datasets from ecoinvent 3.8 for different process steps 

Used dataset from ecoinvent 3.8 for different process steps 

passenger car production, petrol / natural gas | APOS, U 

passenger car production, electric, without battery | APOS, U 

market for sheet rolling, steel | APOS, U - GLO 

market for sheet rolling, aluminium | APOS, U - GLO 

market for wire drawing, copper | APOS, U - GLO 

market for tempering, flat glass | APOS, U - GLO 

market for coating powder | APOS, U - RER 

market for light emitting diode | APOS, U - GLO 

market for lubricating oil | APOS, U - RER 

market for printed wiring board, mounted mainboard, desktop computer, Pb 
free | APOS, U - GLO 

treatment of waste plastic, mixture, municipal incineration | waste plastic, 
mixture | APOS, U 

market group for electricity, medium voltage | electricity, medium voltage | 
APOS, U - GLO 

market group for heat, district, or industrial, natural gas | heat, district or 
industrial, natural gas | APOS, U - GLO 

market group for heat, district or industrial, other than natural gas | heat, district 
or industrial, other than natural gas | APOS, U - GLO 

643 

 
 
 
 
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Impact category 

Unit 

Steel 

Stainless 
Steel 

Cast Iron 

Wrought 
aluminium 

Cast 
aluminium 

Copper 

Glass 

Rubber 

Table 6-40 LCA data: Primary production of materials I 

Carbon 
Fiber-
Reinforced 
Plastic 

Glass Fiber-
Reinforced 
Plastic 

PTFE 

Silicon 

Abiotic depletion 

kg Sb eq 

3.4E-05 

1.6E-04 

5.9E-06 

1.9E-05 

1.9E-05 

2.4E-03 

8.3E-06 

4.9E-05 

2.2E-04 

3.5E-05 

2.3E-04 

2.5E-05 

Abiotic depletion 
(fossil fuels) 

MJ 

1.9E+0
1 

4.6E+01 

1.8E+01 

1.8E+02 

1.8E+02 

6.8E+01 

1.0E+01 

7.4E+01 

8.9E+02 

5.8E+01 

1.3E+02 

Acidification 

kg SO2 eq 

7.3E-03 

2.4E-02 

6.3E-03 

1.1E-01 

1.1E-01 

1.0E-01 

8.4E-03 

1.3E-02 

4.0E-01 

1.8E-02 

5.5E-02 

4.5E+01 

1.2E-02 

Eutrophication 

kg PO4--- 
eq 

3.8E-03 

7.6E-03 

2.7E-03 

2.7E-02 

2.7E-02 

3.8E-01 

1.1E-03 

3.8E-03 

1.2E-01 

5.7E-03 

1.4E-02 

4.0E-03 

Fresh water aquatic 
ecotox. 

kg 1,4-DB 
eq 

6.0E+0
0 

Global warming 
(GWP100a) 

kg CO2 eq 

2.1E+0
0 

Human toxicity 

kg 1,4-DB 
eq 

3.2E+0
0 

Marine aquatic 
ecotoxicity 

kg 1,4-DB 
eq 

7.0E+0
3 

1.5E+01 

1.4E+00 

1.4E+01 

1.4E+01 

7.7E+02 

2.5E-01 

1.3E+00 

3.6E+01 

1.5E+00 

7.8E+00 

1.7E+00 

4.4E+00 

1.8E+00 

1.9E+01 

1.9E+01 

6.5E+00 

9.7E-01 

2.7E+00 

8.3E+01 

3.9E+00 

1.3E+02 

2.9E+00 

7.7E+01 

1.6E+00 

1.2E+01 

1.2E+01 

1.2E+03 

3.7E-01 

1.8E+00 

3.2E+01 

4.7E+00 

3.0E+01 

1.6E+00 

1.7E+04 

2.7E+03 

5.6E+04 

5.6E+04 

8.7E+05 

1.4E+03 

2.9E+03 

1.1E+05 

4.4E+03 

2.6E+05 

7.4E+03 

Ozone layer 
depletion (ODP) 

Photochemical 
oxidation 

kg CFC-
11 eq 

kg C2H4 
eq 

Terrestrial 
ecotoxicity 

kg 1,4-DB 
eq 

9.2E-08 

1.9E-07 

8.7E-08 

5.8E-07 

5.8E-07 

4.0E-07 

9.3E-08 

5.3E-07 

2.0E-06 

3.5E-07 

4.3E-03 

1.9E-06 

9.5E-04 

1.1E-03 

8.1E-04 

6.7E-03 

6.7E-03 

2.0E-03 

2.7E-04 

7.0E-04 

1.8E-02 

1.1E-03 

4.4E-03 

7.1E-04 

2.3E-03 

7.5E-02 

6.6E-02 

3.5E-02 

3.5E-02 

1.5E-01 

6.6E-04 

3.8E-03 

2.5E-01 

5.6E-03 

2.0E-02 

5.1E-03 

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Impact category 

Unit 

ABS 

Liquid 
Epoxy 

GPPS 

HIPS 

HDPE 

LDPE 

LLDPE 

Nylon 6 

Nylon 66 

PC 

PET 

PP 

Table 6-41 LCA data: Primary production of materials II 

Abiotic depletion 

kg Sb eq 

2.8E-06 

5.5E-05 

4.4E-07 

4.4E-07 

1.4E-05 

1.4E-05 

1.5E-05 

6.5E-05 

3.0E-06 

1.7E-06 

3.7E-05 

1.4E-05 

Abiotic depletion 
(fossil fuels) 

MJ 

8.7E+0
1 

8.0E+01 

7.8E+01 

7.8E+01 

7.1E+01 

7.3E+01 

7.0E+01 

1.0E+02 

1.1E+02 

9.2E+01 

6.8E+01 

Acidification 

kg SO2 eq 

1.3E-02 

1.7E-02 

1.1E-02 

1.2E-02 

7.8E-03 

8.7E-03 

7.5E-03 

3.0E-02 

2.9E-02 

2.5E-02 

1.1E-02 

7.3E+01 

7.6E-03 

Eutrophication 

kg PO4--- 
eq 

Fresh water aquatic 
ecotox. 

kg 1,4-DB 
eq 

Global warming 
(GWP100a) 

Human toxicity 

kg CO2 eq 

kg 1,4-DB 
eq 

2.2E-03 

6.9E-03 

9.4E-04 

9.9E-04 

2.0E-03 

2.6E-03 

2.0E-03 

6.8E-03 

7.7E-03 

2.5E-03 

3.1E-03 

1.9E-03 

4.7E-01 

3.6E+00 

6.8E-01 

6.7E-01 

6.3E-01 

7.5E-01 

6.4E-01 

3.0E-01 

2.5E-01 

2.2E-01 

1.2E+00 

6.1E-01 

4.5E+0
0 

4.6E+00 

3.6E+00 

3.6E+00 

2.3E+00 

2.5E+00 

2.2E+00 

9.1E+00 

8.1E+00 

8.1E+00 

3.1E+00 

2.3E+00 

4.1E-01 

8.0E+00 

3.5E-01 

3.8E-01 

8.4E-01 

9.4E-01 

9.8E-01 

4.6E-01 

4.2E-01 

4.2E-01 

2.1E+00 

7.9E-01 

Marine aquatic 
ecotoxicity 

kg 1,4-DB 
eq 

1.6E+0
3 

4.7E+03 

3.7E+03 

3.6E+03 

1.5E+03 

1.9E+03 

1.4E+03 

1.4E+03 

1.1E+03 

9.0E+02 

2.7E+03 

1.4E+03 

Ozone layer 
depletion (ODP) 

Photochemical 
oxidation 

kg CFC-
11 eq 

kg C2H4 
eq 

Terrestrial 
ecotoxicity 

kg 1,4-DB 
eq 

7.5E-08 

6.5E-07 

2.9E-09 

3.4E-09 

5.2E-08 

4.7E-08 

6.0E-08 

1.2E-08 

7.4E-09 

1.7E-08 

1.0E-05 

3.9E-08 

7.5E-04 

2.3E-03 

7.5E-04 

7.3E-04 

6.8E-04 

1.4E-03 

5.6E-04 

1.4E-03 

1.4E-03 

1.4E-03 

6.8E-04 

4.4E-04 

1.3E-03 

6.4E-03 

5.4E-04 

6.7E-04 

1.5E-03 

2.1E-03 

1.5E-03 

9.6E-04 

7.0E-04 

2.7E-02 

4.0E-03 

1.3E-03 

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Impact category 

Unit 

PUR 
Flexibl
e Foam 

PUR Rigid 
Foam 

PVC 

Zinc 

Magnesium 

Nickel 

Platinum 

Gold 

Silver 

Tin 

Brass 

Palladium 

Table 6-42 LCA data: Primary production of materials III 

Abiotic depletion 

kg Sb eq 

1.4E-05 

6.8E-05 

3.7E-05 

1.5E-03 

5.2E-05 

2.2E-03 

3.6E+00 

6.1E+01 

8.5E-01 

2.7E-02 

9.4E-03 

8.9E-01 

Abiotic depletion 
(fossil fuels) 

MJ 

8.2E+0
1 

9.8E+01 

5.0E+01 

3.1E+01 

1.1E+03 

2.3E+02 

1.0E+06 

5.7E+05 

5.8E+03 

1.2E+02 

8.0E+01 

Acidification 

kg SO2 eq 

2.2E-02 

2.6E-02 

8.9E-03 

2.2E-02 

2.3E-01 

1.8E+00 

4.1E+03 

3.8E+02 

4.9E+00 

9.8E-02 

3.4E-01 

1.9E+05 

2.0E+03 

Eutrophication 

kg PO4--- 
eq 

5.5E-03 

1.1E-02 

3.2E-03 

1.3E-02 

1.6E-01 

6.4E-02 

4.5E+02 

5.8E+02 

4.8E+00 

9.1E-02 

1.1E-01 

6.9E+01 

Fresh water aquatic 
ecotox. 

kg 1,4-DB 
eq 

1.5E+0
0 

Global warming 
(GWP100a) 

kg CO2 
eq 

5.2E+0
0 

3.0E+00 

1.3E+00 

1.2E+01 

2.9E+01 

1.6E+02 

2.8E+05 

7.5E+05 

5.6E+03 

8.1E+01 

1.9E+02 

5.0E+04 

5.0E+00 

2.4E+00 

2.7E+00 

4.5E+01 

1.8E+01 

6.9E+04 

4.9E+04 

5.0E+02 

1.0E+01 

6.6E+00 

1.3E+04 

Human toxicity 

kg 1,4-DB 
eq 

9.7E-01 

4.2E+00 

1.8E+00 

1.1E+01 

8.3E+01 

1.2E+02 

2.3E+05 

6.7E+05 

4.9E+03 

6.8E+01 

3.4E+02 

3.9E+04 

Marine aquatic 
ecotoxicity 

kg 1,4-DB 
eq 

6.6E+0
3 

7.1E+03 

2.8E+03 

3.6E+04 

6.6E+04 

1.5E+05 

3.9E+08 

1.2E+09 

7.3E+06 

9.2E+04 

2.3E+05 

6.6E+07 

Ozone layer 
depletion (ODP) 

Photochemical 
oxidation 

kg CFC-
11 eq 

kg C2H4 
eq 

Terrestrial 
ecotoxicity 

kg 1,4-DB 
eq 

2.6E-08 

8.2E-07 

1.1E-06 

1.7E-07 

5.9E-06 

1.7E-06 

3.3E-03 

2.9E-03 

5.2E-05 

5.8E-07 

9.8E-07 

3.0E-03 

1.0E-03 

4.9E-03 

5.0E-04 

7.1E-04 

3.4E-02 

8.5E-02 

1.4E+02 

1.2E+01 

1.6E-01 

2.9E-03 

1.3E-02 

7.9E+01 

5.5E-03 

1.4E-02 

3.8E-03 

1.8E-02 

4.1E-02 

3.1E-01 

2.5E+02 

9.7E+02 

3.8E+00 

7.4E-02 

2.2E-01 

4.6E+01 

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Impact category 

Unit 

Table 6-43 LCA data: Secondary production of materials 

Steel 

Aluminium wrought 
alloy 

Aluminium cast alloy 

Glass 

HDPE 

PET 

Platinum 

Abiotic depletion 

kg Sb eq 

1.1E-05 

1.9E-04 

7.5E-05 

4.2E-08 

7.0E-06 

6.1E-06 

7.2E-01 

Abiotic depletion 
(fossil fuels) 

MJ 

6.6E+00 

Acidification 

kg SO2 eq 

2.6E-03 

3.6E+01 

1.6E-02 

6.4E+01 

3.0E-02 

1.6E-01 

4.7E+00 

8.0E+00 

2.0E+05 

3.5E-05 

1.9E-03 

2.5E-03 

1.5E+02 

Eutrophication 

kg PO4--- 
eq 

Fresh water aquatic 
ecotox. 

kg 1,4-DB 
eq 

Global warming 
(GWP100a) 

Human toxicity 

Marine aquatic 
ecotoxicity 

Ozone layer 
depletion (ODP) 

Photochemical 
oxidation 

Terrestrial 
ecotoxicity 

kg CO2 
eq 

kg 1,4-DB 
eq 

kg 1,4-DB 
eq 

kg CFC-
11 eq 

kg C2H4 
eq 

kg 1,4-DB 
eq 

1.6E-03 

7.2E-03 

8.4E-03 

5.8E-05 

4.1E-03 

2.3E-03 

4.1E+01 

1.9E+00 

5.0E+00 

3.3E+00 

1.1E-02 

2.1E+00 

8.1E+00 

9.4E+04 

6.4E-01 

3.5E+00 

4.2E+00 

1.4E-02 

4.9E-01 

8.2E-01 

1.8E+04 

1.5E+00 

4.3E+00 

3.7E+00 

7.5E-03 

1.4E+00 

1.6E+00 

8.4E+04 

2.3E+03 

1.1E+04 

6.0E+03 

2.4E+01 

9.5E+03 

4.2E+04 

6.4E+07 

4.8E-08 

1.7E-07 

2.1E-06 

1.2E-09 

3.7E-08 

6.6E-08 

1.6E-03 

1.4E-04 

2.8E-03 

1.4E-03 

1.4E-06 

1.2E-04 

1.5E-04 

8.8E+00 

2.3E-03 

2.1E-02 

5.6E-02 

3.4E-05 

1.2E-02 

4.9E-03 

6.6E+01 

647 

 
 
 
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6.10  Ad-hoc contributions to the impact assessment of the EC: 
Further details on economic impacts of measures related 
to the proposed scope extension  

6.10.1  Background 

The  purpose  of  this  ad-hoc  contribution  to  the  impact  assessment  of  the  EC  is  to  provide 
further  details  on  economic  impacts  of  potential  measures  related  to  a  proposed  scope 
extension:  

•  Mandatory treatment of additional vehicle categories at ATFs 
•  Roadworthiness certificate with implication on exports 
•  Minimum requirements for the extended producer responsibility for L-category vehicles, 

lorries, buses, and trailers  

•  Advanced  waste 

treatment 

requirements  of 

the  mandatory 

removal  prior 

to 

shredding/PST (example of glass) 

6.10.2  Measure  “Roadworthiness  certificate  with  implication  on 

exports” 

6.10.2.1  Overview of the total exports for categories considered for 

the scope extension 

Available data provided by Eurostat for the relevant categories are displayed in Table 6-44. 

Table 6-44 Total Export (used and new) of HDV from EU27 to extra EU27 in 2022 

CN code  

Million Euro  Distinction  of  new 
and used possible 

Total export: „vehicles for the transport of goods“  
Thereof 
"diesel or semi-diesel engine" of a gross vehicle 
weight <= 5 t  
park-ignition internal combustion piston engine, of 
a gross vehicle weight <= 5 t 
"diesel or semi-diesel engine" of a gross vehicle 
weight > 5 t but <= 20 t 
"diesel or semi-diesel engine" of a gross vehicle 
weight > 20 t 
with spark-ignition internal combustion piston 
engine, of a gross vehicle weight > 5 t 

8704 

14 677 

870421 

6 431 

870431 

496 

870422 

870423 

1 832 

4 330 

870432 

21 

Dumpers for off-highway use 
Others 

870410 
difference 

763 
801 

Source: Eurostat 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

no 
no 

Note (1) for the green cells: The vehicles with a weight of up to 5 t are considered as N1384, accordingly exports of 6 928 
million € are considered under the IA for the existing scope and not under the scope extension.  

384 Unfortunately the Eurostat definitions do not exactly match with the vehicle categories: N1 vehicles have a  maximum gross 
weight of 3.5 tons. 

648 

 
 
 
 
 
 
 
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Note (2) For off-road-dumpers and „others“ Eurostat does not provide detailed information on the share / value of used 
vehicles therefore no detailed economic impact assessment regards economic impacts of the exports of used vehicles can be 
derived. 

Table 6-45 Total Export (used and new) of trailers from EU27 to extra EU27 in 2022 

Total export: 
„Trailers and semi-trailers“  

CN code  

Million Euro 

Distinction  of 
new  and  used 
possible 

1 577 

Yes 

87163930, 
87163950, 
87163980 

Source: Eurostat 

Table 6-46 Total Export (used and new) of buses from EU27 to extra EU27 in 2022 

Total export: 
„Motor vehicles for the transport of >= 10 persons, 
incl. driver “  

CN code  

Million Euro 

Distinction  of 
new  and  used 
possible 

8702 

800 

Yes 

For the L-type approved vehicles according to Regulation (EU) No 168/2013, Eurostat does 
not provide information on export of used L-type vehicles. 

Source: Eurostat 

6.10.2.2  Methodology to assess the share of vehicles which might 
not pass the future requirement of a valid roadworthiness 
certificate 

The  vehicle  categories  870422,  870423,  870432,  871639xx  and  8702  (highlighted  in  the 
above  tables  in  blue)  are  assessed  at  the  level  of  the  8-digit  CN-codes  with  the  following 
approach: 

1.  Identification of the average value of the intra EU trade with new vehicles per CN code as 

displayed in Table 6-47. 

2.  Definition of a function on the share of non-eligible vehicles, depending on the distance 

to the average value of a new vehicle as displayed in the Figure 6-25. 

3.  Calculation of the number of non-exportable vehicles with the above function. 

4.  Estimation for the economic impact. 

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Table 6-47 Average value per vehicle of the intra-EU trade with new vehicles per CN 
code 

CN code 

Intra EU trade 

Euro per new 
vehicle 

Numbers per year 

Motor Vehicle for the transport of goods 

"diesel or semi-diesel engine" of a gross 
vehicle weight > 5 t but <= 20 t, new 

"diesel or semi-diesel engine" of a gross 
vehicle weight > 20 t, new 

87042291 

51 285 

62 340 

87042391 

94 706 

39 687 

with spark-ignition internal combustion piston 
engine, of a gross vehicle weight > 5 t, new 

87043291 

72 604 

276 

„Trailers and semi-trailers“, new 

87163930 
87163950 

9 229 

369 771 

„Motor vehicles for the transport of >= 10 persons, incl. driver“, 

diesel engine, >2500cm3, new 
diesel engine, <2500cm3, new 
with spark-ignition internal combustion piston 
engine, > 2.800 cm³, new 
with spark-ignition internal combustion piston 
engine, < 2.800 cm³, new 

87021011 
87021091 
87029011 

156 873 
50 290 
87 088 

87029031 

22 026 

16 075 
4 906 
1 028 

109 

Source: Eurostat 

Note: Average per year for the period 2013-2022 (10 years) 

Figure 6-25  Function on the share of non-eligible vehicles per country, depending 
on the distance to the average value of a new vehicle 

Growth function

]

%

[

l

s
e
l
c
i
h
e
v
e
b
a
t
r
o
p
x
e
f
o
e
r
a
h
S

100

90

80

70

60

50

40

30

20

10

0

S= 97; k=0.002; B(0)=3

0

10

20

30

40

50

60

70

80

90

100

Average value of extra EU export to a distince country in % of 
intra EU average value  

Source: own calculations 

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The function displayed above includes the following logic:  

The  share  of  exportable  vehicles  is  assessed  for  each  receiving  extra  EU  country.  If  the 
average value of the exported vehicle is close to the average value of the intra EU trade, then 
it  is  assumed that the majority  is  in  good  condition  and  can  have  or  get a  roadworthiness 
certificate.  However,  we  consider  a  certain  maximum  share  as  exportable  as  the  field 
experience demonstrates that we will find in any cross border here and there also an ELV 
(this applies for intra EU trade too). E.g. if the average value per vehicle of the exports to a 
receiving country is more than 50% of the average value per vehicle of the intra EU trade 
than we assume a maximum number of exportable vehicles of 97% (S=97).  

When the average value of the exported vehicle falls below 25% of the value of the intra EU 
trade value per vehicles we see a sharp decline in the share of exportable vehicles. But even 
if the average per vehicle might be very low, there might be a number of new vehicles included 
in the trade. E.g. if the average value per vehicle of the exports to a receiving country is about 
10% of the average value per vehicle of the intra EU trade than we assume that still a share 
of 18% could have or get a roadworthiness certificate and can be exported. 

When applying this logic for each receiving non-EU country the overall results for the total 
export are displayed in the table below. 

Table 6-48 Average number of exportable and non-exportable vehicles depending on 
the average value of the exported HDVs, trailers and buses 

Extra EU-trade 

CN code  

Exportable 
41 975 

Non-Exportable 
52 243 

87042299 

21 585 

42 312 

Motor Vehicle for the transport of 
goods 

"diesel or semi-diesel engine" of a  
gross vehicle weight > 5 t but <= 20 t, 
used 
"diesel or semi-diesel engine" of a  
gross vehicle weight > 20 t, used 

with spark-ignition internal combustion 
piston engine, of a gross vehicle weight 
> 5 t, used 

87042399 

8 477 

87043299 

11 913 

„Trailers and semi-trailers“, used 

87163980 

58 064 

„Motor vehicles for the transport of 
>= 10 persons, incl. driver“, 

2 516 

diesel engine, >2500cm3, new 

87021019 

1 859 

diesel engine, <2500cm3, new 

87021099 

562 

with spark-ignition internal combustion 
piston engine, > 2.800 cm³, new 

87029019 

95 

with spark-ignition internal combustion 
piston engine, < 2.800 cm³, new 

87029039 

* 

Source: own calculations 

* = not sufficient data available  

Note: Average per year for the period 2013-2022 (10 years) 

651 

6 684 

3 248 

3 440 

4 253 

3 131 

1 055 

67 

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6.10.2.3  Economic impacts for exporters 

Considering an assumed profit (not turnover) of 500 to 1000 € per vehicle for the exporter in 
Europe. This might cause a reduction of profits for these exporters of about: 

•  26 to 52 million € per year for exporters of HDV.  
•  1.7 to 3.4 million € per year for exporters of trailers  
•  2.1 to 4.3 million per year for exporters of buses 

Validity of the estimation  

Underestimation 

An underestimation might be caused, as the results are based on export data as available 
from Eurostat (COMEXT) and not all exports might be reported to customs services. 

Overestimation 

The economic impact might be an overestimation as the reduction in exports of very old and 
cheap HDV, trailers and buses might be compensated by the following to effects: 

•  As there is a demand for spare parts for such (very) old vehicles in the receiving countries, 
the  functional  /  usable  spare  parts  might  be  dismantled  in  Europe  and  shipped  to  the 
receiving counties. 

•  As the demand for used (and cheaper) HDVs trailers and buses in the receiving countries 
will continue, the exporters might shift to (younger, better) HDVs, trailers and buses, which 
will have a roadworthiness certificate when being exported. 

Conclusion 

We  assess  that  the  market  flexibility,  expressed  in  the  section  on  overestimation,  is 
dominating  the  statistical  effects  described  in  the  section  on  underestimation  above. 
Therefore,  it  is  likely  that  the  negative  impacts  described  in  Section  6.10.2.3  represent  an 
overestimation (worst case scenario) and the impacts are less harmful to the exporters. 

6.10.2.4  Economic impacts for recyclers 

Considering a functioning market for very old used trucks and buses we assume that the pro-
fits for the recyclers are lower than the profits for the exporters and thus exporters are cap-
able to pay higher prices to the last owner in the EU. Thus we consider additional profits for 
the recycling sector of 400 to 800 € per vehicle which might be in addition recycled in the EU.  

This might cause an increase in profits for recyclers of about: 

•  21 to 42 million € per year for exporters of HDV. 
•  1.4 to 2.7 million € per year for exporters of trailers  
•  1.7 to 3.4 million per year for exporters of buses 

Validity of the estimation  

Underestimation 

The profit might be underestimated and closer to the profits of the exporters. 

Overestimation 

The economic impact might be less, as the reduction in exports of very old and cheap HDV, 
trailers and buses might be compensated by the following to effects: 

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•  As the demand for used (and cheaper) HDVs trailers and buses in the receiving countries 
will continue, the exporters might shift to (younger, better) HDVs, trailers and buses, which 
will have a roadworthiness certificate when being exported. In result the recyclers do not 
receive the estimated additional number of vehicles 

Conclusion 

The positive impacts might be less relevant. As the impacts on exporters and recyclers have 
a strong relation the difference in the impacts on exporters and recyclers will remain stable. 
This difference reflects the profit achieved with substandard exports. 

6.10.3  Measure “Mandatory treatment of additional vehicle categories 

at ATFs” 

6.10.3.1  Methodology & assumptions 

Table 6-49 Methodology and key assumptions for calculating costs and revenues of 
mandatory treatment of additional vehicle categories at ATFs 

Revenue 
ATFs 

of 

Costs of ATFs 

Job creation at 
ATFs 

-  Tonnage of different materials which in addition compared to the baseline is sent to 

reuse * Revenues for reuse for these materials 

-  Tonnage of hulk which in addition compared to the baseline is sent to shredders * 

number of EoL vehicle type  

-  Dismantling time for reuse for the specific vehicle type * labour costs 

-  Total dismantling time * number of EoL vehicles  

/ number of working days per year (assuming that 200 days/year = 1 job) 

-  For the number of EoL vehicles:  

o  For L-types it is assumed that a) the major share is currently taken back 
by dealers and then either sent to shredders or to dismantlers for further 
treatment, and b) the major share is not subject to exports at their EoL, 
i.e. there are no additional vehicles being treated at ATFs  

o  For lorries and buses it is assumed that a) the majority is already treated 
in ATFs and b) they are subject to exports, i.e. only the share of EoL 
lorries and buses which will not get a roadworthiness certificate for export 
anymore will be new / in addition be treated at ATFs under this policy 
option.     

Revenues  of 
recyclers  

Costs 
recyclers 

of 

-  Tonnage of different materials which in addition compared to the baseline is sent to 

recycling * Revenues for these materials  

-  No additional costs are expected. If there will be more recycling material in future for 
the recycling facilities due to the scope extension, then there will also be an increase 
in benefits/jobs; recycling facilities are already in place, i.e. they are currently cost-
effective; if they would have to invest in new facilities, there would be enough 
recycling material so that this would be profitable again.  

6.10.3.2  Calculation of costs and revenues for the scope extension 

to L-category vehicles  

6.10.3.2.1  Input data for the calculations 

The  following  data  is  used  to  calculate  the  costs  for  the  scope  extension  to  L-category 
vehicles. 

Table 6-50 shows the calculated number of L-category vehicles reaching the End of Life for 
the different years. According to the IA supporting study (Baron et al. 2022), for PTWs there 

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are no codes for the trade in used products, i.e., the aspect of export of 2nd-hand (“used”) 
vehicles as part of the problem of vehicles of unknown whereabouts cannot be studied for 
this vehicle category. However, information from an expert interview suggests that the export 
of PTWs is not a business case (age of vehicles usually higher and material value being lower 
compared to cars). Thus, for the further calculations it is assumed that these L-categories are 
not a relevant subject to exports and below number of vehicles reaching EoL will be treated 
in the EU. 

Table 6-50 Number of L-category vehicles reaching End of Life 

Number of vehicles reaching EoL

2022

2025

2030

2035

2040

"Motorcycles"

1.388.348

1.461.075

1.557.104

1.624.242

1.701.058

Source: OEKO model 

According to the IA supporting study (Baron et al. 2022), figures as to the numbers of PTW 
already treated in ATFs cannot be provided due to the lack of statistical or other quantitative 
data; as far as it is known, there are no specific PTW recyclers. Compared to other types of 
vehicles,  such  as  cars,  PTW  have  no  chassis.  Thus,  a  component  which  represents  a 
considerable amount of vehicle’s material is not available. This means that the material from 
PTWs that could potentially be sent to shredder after removal of components is very little. In 
general, car dismantlers say that they would gladly take the PTWs [if they would get them]. 
Standard tools  can  be  used,  dismantling  is  easy,  no  investments  nor  additional  training  of 
recyclers is needed. Car recyclers receive accidental PTW but not the end-of-life PTW. 

According to an expert interview, for example for scooters, treatment at ATFs does not seem 
to take place at large scale so far as there is no system for collection and the treatment seems 
to  be  not  yet  profitable for  ATFs;  i.e., smaller  EoL  mopeds might  be  largely  going  into  the 
scrap without proper treatment of fluids. On the other hand, another expert interview assumes 
that for the larger motorcycles, the EoL vehicles are not understood as waste by the vehicle 
owners but are rather brought back to the dealers in connection with replacement purchases; 
dealers are either dismantling components as spare parts by their own, or sending the EoL 
PTWs  to  shredders  or  directly  to  dismantlers  (usually,  in  Member  States  the  number  of 
dismantling  sites  is  much  higher  than  the  number  of  shredder  sites,  i.e.  it  might  be  less 
logistical effort for the dealers to send the EoL motorcycles to dismantlers). 

Based  on  this  information,  it  is  assumed  that  the  above  number  of  L-category  vehicles 
reaching  EoL  is  already  today  to  a  relevant  extent  treated  by  ATFs,  shredders  and/or 
recyclers, i.e. there is no effect of the policy option PO6B requiring mandatory treatment of L-
category vehicles in ATFs is not expected to have a considerable impact on the total number 
of ELVs treated.  

Table 6-51 shows the calculated tonnage of materials of L-category vehicles sent to reuse 
building the baseline for calculations. 

Table 6-51 Tonnage of materials of L-category vehicles sent to reuse (baseline) 

L-types 
tonnage of materials sent to reuse (=> ATFs) [tons] 
Steel
Aluminium
Iron
Copper
Glass
Plastic
Rubber
Other

year

year

year

year

year

2022
132136
86978
0
5887
537
27709
14008
10503

2025
134177
88313
0
5962
538
28419
14200
10734

2030
136871
90075
0
6060
539
29357
14454
11040

2035
142773
93959
0
6321
563
30622
15077
11516

2040
149525
98403
0
6620
589
32071
15790
12061

Source: OEKO model 

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Although it is assumed that dismantling at ATFs builds a business case for reuse, there are 
no legal obligations in place which formally require proper treatment of L-category vehicles 
from ATFs. For this step, therefore, the costs for ATFs are calculated. For the dismantling 
time at ATFs, the same time is taken as for M1/N1 vehicles which is estimated at 60 minutes. 
According to an expert interview, the dismantling time of L-categories is rather similar to that 
of cars as also similar components have to be treated for depollution (fuel, motor oil, hydraulic 
oil, brake fluids etc.).  

The labour cost – regardless of the vehicle type – is calculated with EUR 35 per hour.   

Table 6-52 shows the calculated tonnage of materials of L-category vehicles sent to recycling, 
building the baseline for calculations. 

Table 6-52 Tonnage of materials of L-category vehicles sent to recycling (baseline) 

tonnage of materials sent to recycling [tons] 
Steel
Aluminium
Iron
Copper
Glass
Plastic
Rubber
Other

2022
92495
60885
0
4121
376
19397
14008
10503

2025
93924
61819
0
4173
377
19893
14200
10734

2030
82123
54045
0
3636
324
17614
14454
11040

2035
85664
56375
0
3793
338
18373
15077
11516

2040
89715
59042
0
3972
354
19242
15790
12061

Source: OEKO model  

6.10.3.2.2  Calculated  costs,  revenues  and  socio-economic 
impacts  at  ATFs  for  the  proposed  mandatory 
treatment of L-category vehicles 

Table  6-53  summarises  the  calculated  costs  of  ATFs  due  to  the  proposed  measure  of 
mandatory  treatment  of  L-category  vehicles  in  authorised  treatment  facilities,  considering 
effectiveness rates for the effect of the policy options and expected implementation period of 
5 years after entry into force (EIF). 

Table 6-53 Calculated costs at ATFs due to the proposed mandatory treatment of L-
category vehicles at ATFs 

Costs of ATFs (EUR)
L-types
Effectiveness rates Policy Options & Implementation
PO6B: ATF requirement effectiveness (M30a)

PO6C: +EPR (M31) 

PO6B/PO6C: 
Implementation share towards +5 yrs EIF

Costs of ATFs (M EUR)

PO6B: ATF requirement effectiveness (M30a)

PO6C: +EPR (M31) 

2022
48.592.172 €

-                

20%

12%

25%

2022

-2,4

-2,6

-                

2025
51.137.612 €
2025
20%

-                

2030
54.498.639 €
2030
30%

-                

2035
56.848.473 €
2035
40%

-                

2040
59.537.020 €
2040
50%

12%

25%

2025

-2,6

-4,1

12%

50%

2030

-8,2

-11,4

12%

75%

2035

-17,1

-22,2

12%

75%

2040

-22,3

-27,7

It is further assumed that the recycling treatment of L-categories will not be changing under 
the  proposed  policy  options  compared  to  the  current  situation,  assuming  that  all  EoL  L-
category vehicles are already today going to recyclers. 

Source: OEKO model  

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6.10.3.3  Calculation of costs and revenues for the scope extension 

to HDVs (trucks)  

6.10.3.3.1  Input data for the calculations  

The  following  data  is  used  to  calculate the  costs  and  revenues for  the  scope  extension  to 
HDVs. Table 6-54 shows the calculated tonnage of materials of HDVs sent to reuse. It might 
be underestimated as the market for used spare parts is important in the HDV segment and 
the assumption might even be that reuse represents a higher share than recycling (cf. Table 
6-56).  

Table 6-54 Tonnage of materials of HDVs sent to reuse 

year

HDVs (trucks)
tonnage of materials sent to reuse (=> ATFs) [ton  
Steel
Aluminium
Iron
Copper
Glass
Thermoplast
Rubber
Other

2022
213485
10145
26646
7947
10598
48529
0
0

year

year

year

year

2025
228542
10861
28525
8508
11346
51951
0
0

2030
338917
16106
42301
12616
16825
77041
0
0

2035
371746
17666
46399
13838
18455
84504
0
0

2040
397769
18903
49647
14807
19747
90419
0
0

Source: OEKO model 

The ATF revenues per material that is sent to reuse are listed in Table 6-55 below. However, 
initially, there was only a revenue value for the remaining vehicle hulk of a M1/N1-type. As a 
proxy,  therefore,  the  relation  of  the  weight  of  an  average  HDV  compared  to  the  average 
weight  of  M1/N1  vehicles  was  taken  to  get  an  approximate  value  for  the  revenue  of  the 
average remaining HDV hulk.  

Table 6-55 Assumed ATF revenues per material sent to reuse 

ATF revenues per component/material [€/ton]
iron/steel
aluminium
iron/steel
copper
glass
plastic
rubber
Other
vehicle hulk 
Average or typical weight M1/N1 [tons]
Average or typical weight trucks

revenue of vehicle hulk HDV (sent to shredder)

130 €
850 €
130 €
4.200 €
-
 €
400 €
 €
-
-
 €
110 €
1,8
8,25

504 €

Source: OEKO model  

The dismantling time of HDVs at ATFs is expected to be higher as the 60 minutes estimated 
for M1/N1 vehicles. Although one literature source gives the example of needing six to seven 
days to dismantle a truck385, this seems to be extraordinary long. For the further calculations, 
the dismantling time of HDVs is according to expert interviews rather estimated at being two 

385 https://www.recyclingproductnews.com/article/1481/end-of-life-truck-recycling  

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working days. The labour cost – regardless of the vehicle type – is calculated with EUR 35 
per hour.  

Table 6-56 shows the calculated tonnage of materials of HDVs sent to recycling. 

Table 6-56 Tonnage of materials of HDVs sent to recycling 

tonnage of materials sent to recycling [tons] 
Steel
Aluminium
Iron
Copper
Glass
Thermoplast
Rubber
Other

2022
493151
20122
61552
15762
0
33970
0
0

2025
527932
21541
65893
16873
0
36366
0
0

Source: OEKO model 

2030
503292
21743
62817
17032
11357
40447
0
0

2035
552043
23850
68902
18682
12457
44364
0
0

2040
590687
25519
73725
19990
13329
47470
0
0

The  assumed  recyclers’  revenues  per  material  that  is  sent  to  recycling  are  given  in  Table 
6-57. 

Table 6-57 Assumed recyclers’ revenues per material sent to recycling 

Recycler revenues per material (market value of scrap) [€/ton]

iron/steel
aluminium (medium value of aluminium cast & aluminiu  
iron/steel

copper

glass
plastic
rubber
Other

187 €
1.064 €
187 €

6.286 €

-
 €
400 €
 €
-
 €
-

Source: OEKO model 

Table 6-58 shows the calculated number of HDVs reaching the End of Life for the different 
years. However, according to the IA supporting study (see section 2.4.3.1), on average, 80 
120 used road tractors and 76 839 used vehicles for transport were exported per year, with 
both vehicle groups together relating to about 74% of expected waste lorries (data from 2020). 
This percentage was applied to calculate the number of exported vehicles for the following 
years.  According  to  calculations  based  on  Eurostat  statistics,  see  Table  6-48  “Average 
number  of  exportable  and  non-exportable  vehicles  depending  on the  average  value  of  the 
exported HDVs, trailers and buses”, from a total of 94 218 trucks (which is a little bit lower 
than  the  below  assumptions  of  164  315  exported  trucks),  about  52  243  trucks  are  non-
exportable (= 55%); thus, we applied this share of 55% to the exported trucks which will not 
get a roadworthiness certificate anymore, i.e. will remain new/in addition in the EU for proper 
treatment at ATFs. 

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Table 6-58 Number of HDVs reaching End of Life, being exported and being treated 
new/in addition in EU ATF due to proposed policy option of export restrictions 

Number of vehicles reaching EoL

"lorries"

Number or share of vehicles exported

Number or share of vehicles to be treated new, 
i.e. in addition in EU ATF due to proposed policy 
option of export restrictions

2022

222048

2025

237708

2030

264382

2035

289992

2040

310292

164315

175904

195643

214594

229616

2022

2025

2030

2035

2040

HDVs (trucks)

90373

96747

107604

118027

126289

Source: OEKO model  

It is assumed that there is an existing market for the treatment of HDVs in ATFs for those 
vehicles not being exported. Thus, the costs and revenues for the treatment of HDVs due to 
the proposed scope extension will only apply to those HDVs which are currently exported but 
would in future not get a roadworthiness certificate anymore, i.e., would have to stay in the 
EU for proper treatment at ATFs and be sent to recycling afterwards. 

6.10.3.3.2  Calculated  costs,  revenues  and  socio-economic 
impacts  at  ATFs  and  recyclers  for  the  proposed 
mandatory treatment of HDVs  

Table 6-59 summarises the calculated revenues, costs and expected number of jobs that can 
be  created  at  ATFs  due  to  the  proposed  measure  of  limiting  exports  of  HDVs  without 
roadworthiness  which  would  lead  to  additional  HDVs  that  have  to  be  treated  at  European 
ATFs. It is expected that the revenues of materials sales to reuse will exceed the additional 
labour costs of the treatment.  

658 

 
 
STUDY TO SUPPORT THE IMPACT ASSESSMENT  
FOR THE REVIEW OF DIRECTIVE 2000/53/EC ON END-OF-LIFE VEHICLES 

Table 6-59 Calculated revenues, costs and job creation at ATFs due to the proposed 
mandatory treatment of HDVs at ATFs 

Revenues of ATFs

Steel

2022

2025

2030

2035

2040

11.295.516 €

12.092.154 €

17.932.093 €

19.669.102 €

21.045.967 €

Aluminium

3.509.786 €

3.757.320 €

5.571.928 €

6.111.659 €

6.539.483 €

Iron

Copper

Glass

1.409.825 €

1.509.255 €

2.238.154 €

2.454.955 €

2.626.806 €

13.584.746 €

14.542.836 €

21.566.339 €

23.655.383 €

25.311.294 €

-

 €

-

 €

-

 €

-

 €

-

 €

Thermoplast

7.900.441 €

8.457.635 €

12.542.273 €

13.757.192 €

14.720.215 €

Rubber

Other

vehicle hulk
Total revenues ATFs for HDVs
Costs of ATFs
HDVs
Job creation ATFs

HDVs

-

-

 €

 €

-

-

 €

 €

-

-

 €

 €

-

-

 €

 €

-

-

 €

 €

45.563.248 €
83.263.562 €
2022
50.609.095 €
2022

48.776.683 €
89.135.884 €
2025
54.178.398 €
2025

54.250.136 €
114.100.922 €
2030
60.258.002 €
2030

59.505.128 €
125.153.420 €
2035
66.094.952 €
2035

63.670.572 €
133.914.337 €
2040
70.721.693 €
2040

904

967

1076

1180

1263

Source: OEKO model 

It is further assumed that due to the additional EoL HDVs staying in the EU due to the export 
limitations  of  vehicles  without  roadworthiness,  also  the  recycling  treatment  of  HDVs  will 
increase under the proposed policy options compared to the current situation; the respective 
revenues are displayed in Table 6-60. 

Table 6-60 Calculated revenues of recyclers due to limiting the exports of HDVs 

Revenues of recyclers

2022

2025

2030

2035

2040

Steel

Aluminium

Iron

Copper

Glass

Thermoplast
Rubber

Other

37.533.263 €

40.180.368 €

38.305.019 €

42.015.472 €

44.956.615 €

8.713.629 €

9.328.174 €

9.415.903 €

10.327.984 €

11.050.958 €

4.684.631 €

5.015.023 €

4.780.956 €

5.244.068 €

5.611.160 €

40.324.810 €

43.168.794 €

43.574.788 €

47.795.702 €

51.141.469 €

-

 €

-

 €

-

 €

-

 €

-

 €

5.530.309 €
 €
-

5.920.344 €
 €
-

6.584.693 €
 €
-

7.222.526 €
 €
-

7.728.113 €
 €
-

-

 €

-

 €

-

 €

-

 €

-

 €

Total revenues recyclers for HDVs

96.786.641 €

103.612.703 €

102.661.359 €

112.605.752 €

120.488.315 €

To these costs and revenues, the following effectiveness rates for the measures under the 
policy options and the implementation period are applied, see Table 6-61. 

Source: OEKO model  

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Table 6-61 Effectiveness rates for policy options and implementation period 

Effectiveness rates Policy Options & Implementation
PO6B: ATF requirement effectiveness (M30a) 
and export requirements linked to 
roadworthiness certificate (M30b)
PO6C: +EPR (M31) 
PO6B/PO6C: 
Implementation share towards +5 yrs EIF

20%

12%

25%

2025

20%

12%

25%

2030

30%

12%

50%

2035

40%

12%

75%

2040

50%

12%

75%

6.10.3.4  Calculation of costs and revenues for the scope extension 

to buses 

6.10.3.4.1  Input data for the calculations 

The  following  data  is  used  to  calculate the  costs  and  revenues for  the  scope  extension  to 
buses. Table 6-62 shows the calculated tonnage of materials of buses sent to reuse. For 2035 
and  2040,  no  data  was  available  in  OEKO’s  model,  therefore,  the  increase  of  material 
between  2030  and  2025  (=33%  increase)  was  calculated,  assuming  a  further  half  of  this 
increase by the year 2035. 

Table 6-62 Tonnage of materials of buses sent to reuse 

Source: OEKO model  

The ATF revenues per material that is sent to reuse are expected to be the same as in Table 
6-51  above.  However,  there  was  only  a  revenue  value  for  the  remaining  vehicle  hulk  of  a 
M1/N1-type. As a proxy, therefore, the relation of the weight of an average bus compared to 
the average weight of M1/N1 vehicles was taken to get an approximate value for the revenue 
of the average bus hulk, see Table 6-63. 

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Table 6-63 Assumed ATF revenues per material sent to reuse 

ATF revenues per component/material [€/ton]
iron/steel
aluminium
iron/steel
copper
glass
plastic
rubber
Other
vehicle hulk 
Average or typical weight M1/N1 [tons]
Average or typical weight buses

revenue of vehicle hulk HDV (sent to shredder)

130 €
850 €
130 €
4.200 €
 €
-
400 €
 €
-
-
 €
110 €
1,8
10,75

657 €

Source: OEKO model  

The dismantling time of buses at ATFs is expected to be higher as the 60 minutes estimated 
for M1/N1 vehicles and the 2 working days estimated for HDVs. As there is no information 
available, it is assumed that the dismantling takes double the time of dismantling a truck, i.e., 
four working days. The labour cost – regardless of the vehicle type – is calculated with EUR 
35 per hour.  

Table  6-64  shows  the  calculated  tonnage  of  materials  of  buses  sent  to  recycling  (same 
expected  increase  for  2035  as  explained  above).  The  assumed  recyclers’  revenues  per 
material that is sent to recycling are the same as in Table 6-57 above. 

Table 6-64 Tonnage of materials of buses sent to recycling 

tonnage of materials sent to recycling [tons] 

Steel

Aluminium

Iron

Copper

Glass

Plastic

rubber
Misc.

2022

45985

54857

9758

373

0

2025

45985

54857

9758

373

0

7903

7903

0
0

0
0

Source: OEKO model  

2030

39416

49786

8364

339

3107

7903

0
0

2035

45919

58001

9744

395

3620

9206

0
0

2040

n.a.

n.a.

n.a.

n.a.

n.a.

n.a.

0
0

Table 6-65 shows the calculated number of buses reaching the End of Life for the different 
years. However, according to section 2.4.3.1, on average, 9 327 used buses were exported 
per  year,  this  relates  to  about  34%  of  expected  waste  buses  (data  from  2020).  This 
percentage was applied to calculate the number of exported vehicles for the following years. 
According to calculations based on Eurostat statistics, see Table 6-48 “Average number of 
exportable  and  non-exportable  vehicles  depending  on  the  average  value  of  the  exported 
HDVs, trailers and buses”, from a total of  

6 769 buses (which is a little bit lower than the below assumptions of 9 800 exported buses), 
about 4 235 buses are non-exportable (= 34%); thus, we applied this share of 34% to the 
exported buses which will not get a roadworthiness certificate anymore, i.e. will remain new/in 
addition in the EU for proper treatment at ATFs. 

661 

 
 
 
                         
                         
                         
                     
                         
                         
                         
                         
                         
                         
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Table 6-65 Number of buses reaching End of Life, being exported and being treated 
new/in addition in EU ATF due to proposed policy option of export restrictions 

Number of vehicles reaching EoL

2022

2025

2030

2035

2040

"buses"

28822

29859

31359

32972

35057

Number or share of vehicles exported

9800

10152

10662

11211

11919

Number or share of vehicles to be treated new, i.e. in 
addition in EU ATF due to proposed policy option of 
export restrictions

2022

2025

2030

2035

2040

buses

6174

6396

6717

7063

7509

Source: OEKO model  

It is assumed that there is an existing market for the treatment of buses in ATFs for those 
vehicles not being exported. Thus, the costs and revenues for the treatment of buses due to 
the proposed scope extension will only apply to those buses which are currently exported but 
would in future not get a roadworthiness certificate anymore, i.e., would have to stay in the 
EU for proper treatment at ATFs and be sent to recycling afterwards. 

6.10.3.4.2  Calculated  costs,  revenues  and  socio-economic 
impacts  at  ATFs  and  recyclers  for  the  proposed 
mandatory treatment of buses  

Table 6-66 summarises the calculated revenues, costs and expected number of jobs that can 
be  created  at  ATFs  due  to  the  proposed  measure  of  limiting  exports  of  buses  without 
roadworthiness  which  would  lead  to  additional  buses  that  have  to  be  treated  at  European 
ATFs. It is expected that the revenues of materials sales to reuse will exceed the additional 
labour costs of the treatment.  

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Table 6-66 Calculated revenues, costs and job creation at ATFs due to the proposed 
mandatory treatment of buses at ATFs 

Revenues of ATFs

Steel

2022

2025

2030

2035

2040

554.327 €

554.327 €

739.102 €

861.054 €

n.a.

Aluminium

5.035.852 €

5.035.852 €

6.714.470 €

7.822.357 €

n.a.

Iron

Copper

Glass

117.624 €

117.624 €

156.832 €

182.709 €

n.a.

169.272 €

169.272 €

225.696 €

262.936 €

n.a.

-

 €

-

 €

-

 €

-

 €

n.a.

Thermoplast

967.271 €

967.271 €

1.289.694 €

1.502.494 €

n.a.

Rubber

Other

vehicle hulk
Total revenues ATFs for busses
Costs of ATFs
busses
Job creation ATFs

busses

-

-

 €

 €

-

-

 €

 €

-

-

 €

n.a.

 €

n.a.

n.a.

n.a.

4.055.769 €
10.900.115 €
2022
6.914.529 €
2022

4.201.658 €
11.046.004 €
2025
7.163.250 €
2025

4.412.799 €
13.538.593 €
2030
7.523.215 €
2030

4.639.785 €
15.271.336 €
2035
7.910.196 €
2035

4.933.124 €
4.933.124 €
2040
8.410.299 €
2040

123

128

134

141

150

Source: OEKO model  

It is further assumed that due to the additional EoL buses staying in the EU due to the export 
limitations  of  vehicles  without  roadworthiness,  also  the  recycling  treatment  of  buses  will 
increase under the proposed policy options compared to the current situation; the respective 
revenues are displayed in Table 6-67. 

Table 6-67 Calculated revenues of recyclers due to limiting the exports of buses 

Revenues of recyclers

2022

2025

2030

2035

2040

Steel

Aluminium

Iron

Copper

Glass

Thermoplast
Rubber

Other

1.841.942 €

1.841.942 €

1.578.808 €

1.839.311 €

n.a.

12.502.343 €

12.502.343 €

11.346.664 €

13.218.863 €

n.a.

390.847 €

390.847 €

335.012 €

390.289 €

n.a.

502.466 €

502.466 €

456.020 €

531.263 €

n.a.

-

 €

-

 €

-

 €

-

 €

n.a.

677.089 €
 €
-

677.089 €
 €
-

677.089 €
 €
-

788.809 €
 €
-

n.a.
n.a.

-

 €

-

 €

-

 €

-

 €

n.a.

Total revenues recyclers for busses

15.914.687 €

15.914.687 €

14.393.592 €

16.768.535 €

-

 €

As  for  HDVs,  also  to  these  costs  and  revenues,  the  same  effectiveness  rates  as  given  in 
Table  6-61  for  the  measures  under  the  policy  options  and  the  implementation  period  are 
applied to buses. 

Source: OEKO model  

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6.10.4  Measure “Advanced waste treatment requirements” 

Amongst  others,  a  proposed  policy  option  might  include  additional  requirements  of  the 
mandatory removal of materials and/or components prior to shredding/PST.  

6.10.4.1  Methodology 

EPR costs 

Assumption:  Glass  is  not  to  be  considered  as  reuse  material  under  policy  option  PO6B 
(currently not profitable to dismantle separately due to high effort of logistics); it rather is sent 
to recyclers for backfilling or use as construction material instead of high-quality recycling.  
Under PO6C, the separate dismantling of glass aimed at increasing high-quality recycling will 
be  calculated  for  HDVs  and  buses  =>  costs  &  revenues  for  ATFs  (plus  revenues  for 
recyclers); costs for ATFs = might be covered by EPR costs 

6.10.4.2  Calculation  of  costs  and 

for  separate 
dismantling  of  glass  windows  of  HDVs  and  buses  to 
increase its high-quality recycling 

revenues 

6.10.4.2.1  Input data for the calculations 

Table  6-68  below  summarises  the  assumed  input  data  for  the  calculation  of  costs  and 
revenues for the separate dismantling of glass windows of HDVs and buses. 

Table 6-68 Input data for calculating advanced treatment requirements, exemplified 
for separate dismantling of glass windows for increasing the potential of high-quality 
glass recycling 

Dismantling time of all glass windows of trucks 
[hours]

0,50

Cost difference (= additional costs) for ATF 
operators [€/tonne]

164 €

Assumed share of dismantled glass which goes 
to the high-quality recycling route

Costs of ATFs for storage and transport to 
recycler [€/tonne]

ATF revenues for glass sold directly to recyclers 
[€/tonne]

Additional revenue of recyclers compared to 
current use as backfilling material  [€/tonne]

Dismantling time of all glass windows of trucks 
[hours]

80%

45 €

10 €

16,50 €

1,48

Source: Different sources plus own assumptions  

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According to sections 3.1.8.1.4 and 3.1.8.1.4.2, for cars, an average of 6-8 minutes for the 
removal  of  all  glass  windows  (windscreen,  side  windows  and  rear  window)  is  reported. 
ADEME (2015) reported average dismantling times of 30 minutes according to an ATF survey 
(10 minutes on average for windscreen, 9.5 minutes for the side windows and 12 minutes for 
the rear window). As trucks have a similar number of windows, however, being larger, the 
higher dismantling time of 30 minutes is taken here. As buses have a higher number of larger 
side windows (assumed: 2x 6 side windows in addition), a higher dismantling time is taken 
here. 

According  to  section  3.1.8.1.4.2,  there  is  a  cost  difference  at  ATFs:  costs  when  glass  is 
dismantled and recycled separately (213€/tonne) compared to costs when glass is shredded 
and used for backfilling or construction (49 €/tonne).  

Further, it is assumed that not the total mass of glass material sent to reuse will be available 
for high-quality recycling: According to section 3.1.8.1.4, Table 3-37, there will still be a share 
of glass remaining in components (doors) for remanufacturing / reuse, a further share being 
shredded  and  recycled;  the  table  in  the  IA  supporting  study  takes  70%  of  high  quality 
recycling,  however,  assuming  13%  losses  of  glass  which  does  not  reach  the  ATFs  at  all 
(losses prior to ATFs); as the material sent to reuse already has deducted these losses, the 
70% share was related to the remaining glass reaching the ATFs, therefore resulting in 80% 
of glass going to high-quality recycling then.  

For the transport of glass from a dismantler to a recycler, 45 €/tonne were assumed for both 
storage and transport (see section 3.1.8.1.4.2). According to OVAM (2012), ATF revenues 
for glass sold directly to recyclers is 10 €/tonne. The additional revenue of recyclers compared 
to current use as backfilling material is calculated with 16.5 €/tonne, assuming 1.5 € revenue 
per  tonne  when  shredded  glass  is  sent  to  backfilling  (baseline)  and  18  €/tonne  when 
dismantled and sent as glass cullet for high-quality recycling. 

6.10.4.2.2  Calculated  costs,  revenues  and  socio-economic 
impacts  at  ATFs  and  recyclers  for  the  proposed 
separate dismantling and high-quality recycling of 
glass windows 

Table 6-69 Calculated revenues, costs and job creation at ATFs and recyclers due to 
the proposed separate dismantling and high-quality recycling of glass windows of 
HDVs for the years 2022 (baseline), 2025, 2030, 2035 and 2040 

Cost difference (= additional costs) for ATF 
operators [€]
Costs of ATFs for storage and transport to 
recycler [€]

1.738.127 €

1.860.711 €

2.759.347 €

3.026.634 €

3.238.502 €

381.540 €

408.449 €

605.710 €

664.383 €

710.891 €

Costs per EoL truck [€/ELV]

10 €

10 €

13 €

13 €

13 €

Revenues of ATFs from selling dismantled glass 
directly to recyclers [€]
Additional revenue of recyclers compared to 
current use as backfilling material  [€]

84.787 €

90.766 €

134.602 €

147.641 €

157.976 €

139.898 €

149.765 €

222.094 €

243.607 €

260.660 €

Job creation ATFs

69

74

83

91

97

Source: OEKO model 

665 

 
 
 
     
     
     
     
     
         
         
         
         
         
                   
                   
                   
                   
                   
           
           
         
         
         
         
         
         
         
         
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Table 6-70 Calculated revenues, costs and job creation at ATFs and recyclers due to 
the proposed separate dismantling and high-quality recycling of glass windows of 
buses for the years 2022 (baseline), 2025, 2030, 2035 and 2040 

Cost difference (= additional costs) for ATF operators 
[€]

566.236 €

566.236 €

754.981 €

879.553 €

n.a.

Costs of ATFs for storage and transport to recycler [€]

124.296 €

124.296 €

165.727 €

193.073 €

n.a.

Costs per EoL truck [€/ELV]

24 €

23 €

29 €

33 €

n.a.

Revenues of ATFs from selling dismantled glass directly 

27.621 €

27.621 €

36.828 €

42.905 €

n.a.

Additional revenue of recyclers compared to current 
use as backfilling material  [€]

45.575 €

45.575 €

60.767 €

70.793 €

n.a.

Job creation ATFs

27

28

29

30

32

Source: OEKO model 

6.10.5  Summary of costs and revenues for ATF treatment and export 

reductions 

For a basic policy option it is assumed that the required provision of dismantling information 
will not change the current market structure of ATFs and recyclers; it might result in a minor 
reduction  of  dismantling  times  due  to  better  information,  however,  this  is  not  calculated 
separately.  

In a more advanced policy option, the additional numbers of HDVs and buses to be treated 
in  ATFs  due  to  the  proposed  requirement  on  export  restriction  of  EoL  vehicles  without 
roadworthiness  will  cause  lost  revenues  for  exporters  and  additional  dismantling  costs  at 
ATFs.  However,  it  is  expected  that  there  will  also  be  additional  revenues  for  ATFs  from 
removed  materials  which  will  compensate  their  costs.  For  the  situation  of  shredders,  no 
information was available to calculate their additional costs or revenues.  

For the recyclers, no information was available on the costs of the measures, however, due 
to the additional material of the new vehicle types of the extended scope, the revenues of the 
recyclers will increase accordingly.  

6.10.6  References 

ICCT (2022): European vehicle market statistics 2021/22, Publisher: International Council on Clean Transportation (2022) 

OVAM (2012): Study into the processing of glass from End-of-Live Vehicles: Analysis of the legislation and practice in European countries, focusing 

on selective removal. In collaboration with Eijkelenburg, L.V. 

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6.11  Ad-hoc contributions to the impact assessment of the EC: 

Recycled content steel in new vehicles  

6.11.1  Background 

The purpose of this ad-hoc contribution to the impact assessment of the EC is to investigate 
the potential uptake of recycled steel in new vehicles and whether the scrap sector can deliver 
the required volumes accordingly. 

6.11.2  Supply 

6.11.2.1  Ferrous Metals steel scrap (E40) from ELV in the EU 

According  to  the  fleet  model  used  for  this  support  study  to  the  impact  assessment,  the 
following  number  of  vehicles  might  be  treated  in  the  EU  as  displayed  in  Table  6-71.  In 
consequence, the displayed mass of scrap becomes available if the preferred policy options 
as proposed by the EC are implemented in combination. The shares of Fe-scrap, steel (flat 
products and long products) and cast iron are calculated according to the data in Table 6-74. 

Table 6-71 Scenario for the total mass of ferrous scrap in the EU (preferred option) 

[1000 t] 
ELVs treated in the EU  
Fe-scrap (steel + cast iron)  
(without loses, without contamination) 
Fe-scrap (steel + cast iron) 
(with loses, without contamination) 
Thereof composed of:  
steel: 
flat products  
long products 
cast iron 

2025 
8 274 
8 065 

7 026 

5 994 
4 808 
1 186 
1 032 

2030 
10 083 
9 780 

2035 
11 728 
11 191 

2040 
12 638 
11 617 

8 521 

9 750 

10 121 

7 290 
5 859 
1 431 
1 231 

8 423 
6 815 
1 608 
1 327 

8 941 
7 344 
1 597 
1 180 

Source: Oeko model 

6.11.2.2  Which qualities might be achieved with different recycling 

approach? 

ArcelorMittal published a slide presenting the different qualities of scrap as displayed in the 
Figure 6-26 below. 

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Figure 6-26  Cu content in the Fe-scrap and scrap export outside EU 

Source: Philippe Russo / Jan Bollen (ArcelorMittal); presentation IARC - July 5th, 2022 

In the context of the research for this ad-hoc task, the study team visited a new processing 
line  of  a  major  player  in  the  steel  recycling  sector.  Although  the  front  runner  cannot  be 
disclosed (yet), which agreed to share the following information with the EC:  

“The input material to the plant is post-consumer steel scrap, mainly depolluted / dismantled 
ELVs, large appliances (category 4 of the WEEE Directive), mixed scrap.  

The new processing line produces a high-quality recycled raw material, the quality of which 
is  significantly  higher  than  that  of  a  classic  E40,  e.g.  with  a  Cu  content  of  <  0.1%.  Other 
accompanying  elements  such  as  Cr,  Mn,  Mo,  Ni,  Ti  are  also  adjusted  according  to  the 
required specifications and guaranteed accordingly. In addition, the material is virtually free 
of organic and mineral impurities. This high quality is necessary to increase the recycling rate 
in flat steel production.  

The planned full capacity of the new processing plant is over 300 000 t/a. A capacity of up to 
1.5 Mio t will be built by 2026.” 

6.11.3  Demand 

6.11.3.1  Weight of new vehicles 

Figure 6-27 displays the development of the average mass per powertrain. According to the 
forecast, it must be considered that battery electric vehicles in 2020 had a relative high share 
of small / mid-sized vehicles included as Renault’s Zoe was the top seller of BEV in 2020. In 
the coming years, the trend is likely to be that heavier BEV will be placed on the market. 

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Figure 6-27  Average mass in running order of new car registrations in the EU and 
the UK by powertrain type 

Source: ICCT (2022) 

Table 6-72 shows the average weights of the passenger cars for the different powertrain types 
in 2020 according to ICCT (2022). For the years 2025, 2030, 2035 and 2040, the same values 
were assumed. The number of new registrations is derived from the Oeko model. The mass 
flows were calculated from these two values. 

Table 6-72 Scenario for the total mass of vehicles PoM in the EU 

Average weight [kg], thereof 
average weight for: 
BEV 
HEV 
PHEV 
ICV Diesel 
ICV Gasoline 
Total new registrations 
[number], thereof: 
BEV 
HEV 
PHEV 
ICV Diesel 
ICV Gasoline 
Total mass flows [1000 t], 
thereof: 
BEV 
HEV 
PHEV 
ICV Diesel 
ICV Gasoline 

2020 

1457 

2025 

1457 

2030 

1457 

2035 

1457 

2040 

1457 

1696 
1455 
1921 
1625 
1315 
11 050 026 

387 130 
1 175 336 
334 140 
4 012 362 
5 141 058 
16 289 150 

656 573 
1 710 113 
641 883 
6 520 089 
6 760 492 

1696 
1455 
1921 
1625 
1315 
14 756 084 

1 472 273 
4 049 413 
983 754 
4 652 896 
3 597 749 
22 570 657 

2 496 975 
5 891 896 
1 889 791 
7 560 956 
4 731 040 

1696 
1455 
1921 
1625 
1315 
14 852 129 

6 215 999 
2 298 513 
2 019 242 
2 740 812 
1 577 563 
24 293 949 

10 542 334 
3 344 337 
3 878 964 
4 453 819 
2 074 496 

1696 
1455 
1921 
1625 
1315 
15 024 844 

15 024 716 
0 
128 
0 
0 
25 482 165 

25 481 919 
0 
246 
0 
0 

1696 
1455 
1921 
1625 
1315 
15 232 296 

15 232 275 
0 
20 
0 
0 
25 833 978 

25 833 938 
0 
39 
0 
0 

Source: New Registrations and Production: Oeko model; Average weight: ICCT (2022) 

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6.11.3.2  Ferrous metal in new vehicles (2025, 2030, 2035, 2040) 

To  model  the  material  composition  of  passenger  cars,  data  from  JRC-RMIS386  on  the 
composition  of  passenger  cars  was  used,  supplemented  by  data  from  the  Greet  model 
(Argonne 2021). The support study distinguished regards ferrous metals steel and cast iron.  

Based  on  a  literature  survey  and  stakeholder  interviews  Dworak  and  Fellner  (2022) 
distinguish different quality classes as displayed Table 6-73. Many more steel alloys / product 
definitions / standards exist. 

Table 6-73 Quality classes based on max. tolerable proportion of accompanying 
elements 

Quality class  Maximal content of 

Typical steel products in the class 

Q1 
Q2 
Q3 
Q4 

tramp elements 

<0,18 
0,18-0,25 
0,25-0,35 
>0,34 

Mainly cold rolled flat products 
Tubes, plates, hot rolled flat products 
Hot rolled bar products, slabs for the construction sector 
Reinforcing steel, rails, profiles 

Source: Dworak and Fellner (2022) 

For  the  different  applications,  different  quality  requirements  might  apply,  and  producers 
(customs of the steel mills) might define stricter requirements for their production purposes. 

6.11.3.3  Assumption for the share of flat steel and long products in 

new vehicles 

6.11.3.3.1  Long products in ICV 

Long products “are mainly formed into parts or components which are used, among others, 
in the energy sector, in mechanical engineering, in the construction industry, but above all in 
the automotive sector. In this article, we will focus on the passenger car sector: on average, 
165 kg of long products can be found in a passenger car (see also Figure 6-28). These are 
forged, machined, cold-formed, heat-treated, rolled as well as drawn parts. Main applications 
of  our  products:  Engine,  transmission,  powertrain,  steering  and  suspension.  Examples: 
Crankshafts,  connecting  rods,  fuel  injectors,  engine  mounting  bolts,  transmission  shafts, 
pinions,  wheel  hubs,  ring  gears,  steering,  axle  and  clutch  springs,  ball  studs,  wheel  caps, 
wheel nuts, flange shafts, ball bearings, cable pulls, drive shafts, windshield wiper arms, tire 
cords, and more.”387  

386 https://rmis.jrc.ec.europa.eu/apps/veh/#/p/viewer  

387 https://germany.arcelormittal.com/Innovation/Loesungen-aus-Stahl/Autos/Langstahlprodukte-in-ihrem-Fahzeug  

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Figure 6-28  Share of long products in ICV 

Source: ArcelorMittal (retrieved 27.04.2023)388 

In a previous publication in 2018, ArcelorMittal mentions a share of 44% of flat products and 
12% of long products and 44% other materials as displayed below in Figure 6-29 below. 

388 https://automotive.arcelormittal.com/products/long  

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Figure 6-29  Share of long products in ICE 

Source: Jan Bollen, ArcelorMittal (2018): New steels driving the circular economy, innovative solutions for future mobility, 
presentation at the International Automotive Recycling Conference, Vienna, 2018-03-14 

As a second source, a survey by Steelonthenet revealed an average total weight of 1440 kg 
per  passenger  car.  Of  this,  1085  kg  (75  %)  is  metal  (including  iron,  steel,  aluminium, 
magnesium, copper, and zinc), see also Figure 6-30. The steel content was 830 kg (58%). In 
this  assessment,  flat  steel  products  amount  to  667  kg  (46%)  and  long  products  to  163  kg 
(11%). 

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Figure 6-30  Share of metal content in passenger cars 

Source: Steelonthenet.com 389 (retrieved 2023-04-27) 

6.11.3.3.2  Long products in BEV 

Battery electric vehicles neither have a crank shaft nor a piston. Therefore, the assumption is 
that fewer long products are needed for BEV.  

To estimate the share of different steel qualities in BEV, the study team forwarded questions 
to Volkswagen, Porsche and Mercedes Benz and VDA, Voestalpine and ArcelorMittal.  

By 2023-04-27, only one reply was available from ArcelorMittal, estimating the share of long 
steel  in  BEV  at  about  100  kg/BEV,  compared  to  165  kg/ICE-vehicle.  Other  stakeholders 
replied that they will investigate the issue and will report accordingly. However, they have not 
replied at that time. 

For the purpose of this preliminary ad-hoc study, the study team assumes that the share of 
long steel for BEV will be 40% less compared to ICE vehicles. 

6.11.3.4  Assumptions for the modelling 

Due to the different quality requirements, the following table distinguishes between flat steel 
and long products. 

389 https://www.steelonthenet.com/files/automotive.html  

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Table 6-74 Considerations for the model calculations including break down for flat 
steel and long products for vehicles PoM (no variation over years considered) 

Material  
Steel 
Flat steel  
Long products  
Cast Iron 

ICEV 

HEV 

PHEV 

57.4% 
46.0% 
11.4% 
57.4% 

58.0% 
46.5% 
11.5% 
58.0% 

54.6% 
43.8% 
10.8% 
54.6% 

EV 

56.5% 
49.1% 
7.4% 
56.5% 

Source: Oeko model, expressed in %; additional assumptions for flat steel and long products 

6.11.3.5  Demand for the production of new vehicles 

The following tables show the total mass of the different ferrous products in passenger cars 
placed on the market (PoM) in the EU in the corresponding year according to the Oeko model. 
The mass share of ferrous products per vehicle has remained stable over the years for the 
different drive types, but the number of vehicles PoM to 2040 has been varied according to 
the Oeko model. 

Table 6-75 Scenario for the total mass of ferrous products in vehicles PoM in EU 

Total long products  
[1000 t], thereof: 

BEV 

HEV 

PHEV 

ICV Diesel 

ICV Gasoline  

Total flat products  
[1000 t], thereof: 

BEV 

HEV 

PHEV 

ICV Diesel 

ICV Gasoline 

Total cast iron [1000 t], thereof: 

BEV 

HEV 

PHEV 

ICV Diesel 

ICV Gasoline  

Total mass of ferrous products 

2020 

1 834 

2025 

2 536 

2030 

2 703 

2035 

2 827 

2040 

2 866 

73 

195 

69 

735 

762 

277 

671 

203 

852 

533 

1 170 

2 827 

2 866 

381 

416 

502 

234 

0 

0 

0 

0 

0 

0 

0 

0 

7 503 

10 379 

11 059 

11 570 

11 730 

298 

797 

282 

3 008 

3 118 
1 397 

9 

152 

54 

580 

1 134 

2 746 

829 

3 488 

2 182 
1 812 

35 

524 

159 

673 

4 787 

1 559 

1 702 

2 054 

957 
1 352 

148 

298 

326 

396 

11 570 

11 730 

0 

0 

0 

0 
357 

357 

0 

0 

0 

0 

0 

0 

0 
362 

362 

0 

0 

0 

602 
10 734 

421 
14 727 

185 
15 115 

0 
14 754 

0 
14 958 

Source: Oeko model, additional assumptions for flat steel and long products 

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6.11.3.6  How  much  more  uptake  of  post-consumer  ELV  scrap  is 

possible in flat products 

6.11.3.6.1  Research Project REDERS  

In 2021, ThyssenKrupp and TSR started work in the research project REDER with the aim to 
develop an advanced shredder technology, producing a steel fraction ready to be used in the 
flat steel production390. In the meantime, the new TSR shredder plant in Duisburg is operative. 
The plant is expected to process up to 450 000 tons of different input materials annually - 
such as end-of-life vehicles, mixed scrap or large household appliances391. 

6.11.3.6.2  Research Project MaterialLoop  

OEM Audi reported in March 2023 on the MaterialLoop research project, in which a recycling 
uptake rate of 12 percent is being achieved for deep-drawing steel. The research project is 
being implemented at running industrial sites, together with TSR for sorting and Voestalpine 
adding the scrap in the converter of the blast furnace. Studies carried out as part of the project 
show that the proportion of steel recycled from vehicles in the coil could be increased even 
further in the future392. 

6.11.3.6.3  Research Project Car2Car 

In April 2023, BMW reported about the research project Car2Car. The project will focus on 
several materials, including aluminium, steel, glass, copper, and plastic. According to BMW, 
“innovative dismantling and automated sorting methods should allow for far lag quantities of 
the resources to be recovered from ELVs to be made suitable for use in the production of 
new cars than has been the case to date.” 

In addition to several universities and trade groups, the Car2Car consortium partners include 
BMW,  Scholz  Recycling  GmbH;  Steinert  UniSort  GmbH;  Thyssenkrupp  Steel  Europe  AG; 
Salzgitter  Mannesmann  Forschung  GmbH;  Aurubis  AG;  Novelis  Deutschland  GmbH; 
Oetinger Aluminium GmbH; and Pilkington Automotive Deutschland GmbH. 

6.11.3.6.4  Full scale project at industrial scale 

In the context of the research for this ad-hoc project, the study team visited a new processing 
line  of  a  major  player  in  the  steel  recycling  sector.  Although  the  front  runner  cannot  be 
disclosed (yet), which agreed to share the following information with the EC: 

“The input material to the plant is post-consumer steel scrap, mainly depolluted / dismantled 
ELVs, large appliances (category 4 of the WEEE Directive), mixed scrap.  

The new processing line produces a high-quality recycled raw material, the quality of which 
is significantly higher than that of a classic E40, e. g. with a Cu content of < 0.1 %. Other 
accompanying  elements  such  as  Cr,  Mn,  Mo,  Ni,  Ti  are  also  adjusted  according  to  the 

390 https://www.thyssenkrupp-steel.com/de/newsroom/pressemitteilungen/steel-und-tsr-testen-innovatives-verfahren-zum-
einsatz-von-hochwertigem-schrott-im-hochofen.html  

391 https://www.euwid-recycling.de/news/wirtschaft/schrottrecycler-tsr-nimmt-in-duisburg-neue-aufbereitungsanlage-in-betrieb-
280423/  

392 https://www.audi-mediacenter.com/de/pressemitteilungen/aus-alt-mach-neu-projekt-materialloop-testet-
kreislaufwirtschaftspotenziale-von-altfahrzeugen-15205  

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required specifications and guaranteed accordingly. In addition, the material is virtually free 
of organic and mineral impurities. This high quality is necessary to increase the recycling rate 
in flat steel production. 

Compared  to  hydrogen,  the  material  is  already  available  today  and  can  thus  make  a 
significant contribution to CO2 reduction through its use in the steel industry. 

The recycled raw material can be used both in the blast furnace (BF) with 10-15% and in the 
converter with 25-30%. In total, the recycled raw material can feed 32-40% for flat steel and 
deep drawing steel.  

With the future electric arc furnace (EAF) route for flat steel, a recycling rate of up to 60% 
could be possible. 

The planned full capacity of the new processing plant is over 300 000 t/a. A capacity of up to 
1.5 Mio t will be achieved by 2026.” 

6.11.3.7  Total potential uptake of post-consumer uptake 

In order to identify the total potential uptake of recycled steel and iron from post-consumer 
scrap, three scenarios were calculated for the potential recycled content in flat product, long 
products and cast iron, see Table 6-76.  

Scenario  1  is  basically  a  kind  of  baseline,  where  no  uptake  of  post-consumer  flat  steel 
products is possible. Scenario 2 considers an advanced share of uptake in long steel products 
and  in  cast  iron  and  a moderate  increase  in the  uptake  of  post-consumer  scrap  in  the flat 
steel  production.  Scenario  3  takes  into  account  a  transition  of  the  steel  market  to  direct 
reduced iron and a subsequent EAF route for the flat steel and availability of high-quality post-
consumer scrap. 

Table 6-76 Considerations for the model calculations of Oeko Institut including 
potential recycled content rates for steel and cast iron 

Material 

Steel, thereof: 
  Long products 
   Flat products 
Cast Iron 

Recycled content 
Scenario 1 

Recycled content 
Scenario 2 

Recycled content 
Scenario 3 

50% 
0% 
50% 

75% 
15% 
75% 

Source: Own representation 

75% 
60% 
75% 

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Table 6-77 shows the calculated results for the total mass of potential uptake of recycled steel 
and iron from post-consumer scrap in the three scenarios based on the number of passenger 
cars PoM. 

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Table 6-77 Results for the total mass of potential uptake of recycled steel and iron 
from post-consumer scrap393 

Long products [1000 t] 
Total Scenario 1 
Total Scenario 2 
Total Scenario 3 
Flat products [1000 t] 
Total Scenario 1 
Total Scenario 2 
Total Scenario 3 

Cast iron [1000 t] 

Total Scenario 1 
Total Scenario 2 
Total Scenario 3 

2025 

1 233 
1 849 
1 849 

0 
1 568 
6 271 

906 
1 359 
1 359 

2030 

1 162 
1 743 
1 743 

0 
1 715 
6 861 

676 
1 014 
1 014 

2035 

938 
1 407 
1 407 

0 
1 877 
7 508 

178 
268 
268 

Source: Oeko model 

2040 

951 
1 426 
1 426 

0 
1 903 
7 612 

181 
271 
271 

6.11.4  Comparison of demand and supply for recycled content 

The following tables display the demand for the production of new vehicles and the demand 
for the different steel qualities. As demonstrated, flat steel can become the most in-demand 
material,  if  the  potential  uptake  of  60%  in  scenario  3  will  become  effective.  To  feed  this 
demand, the transition to EAF for flat steel production and the provision of high-quality steel 
scrap  with  low  copper  content  are  preconditions.  In  the  case  of  scenario  3,  the  supply  of 
recycled material from end-of-life vehicles will not be sufficient to meet demand in 2025 and 
2030. However, it is questionable whether the demand conditions in scenario 3 can be fully 
met in 2025 and 2030. 

Table 6-78 Comparison of total supply and demand for scenario 1394 

Scenario 1 [1000 t] 
Demand long products  
Demand flat products  
Demand cast iron  
Total demand  
Total Fe-scrap supply (with 
losses, without contamination)   

2025 

2030 

2035 

1 233 
0 
906 
2 139 
7 026 

1 162 
0 
676 
1 838 
8 521 

938 
0 
178 
1 116 
9 750 

2040 

951 
0 
181 
1 132 
10 121 

Table 6-79 Comparison of total supply and demand for scenario 2397 

Source: Oeko model 

Scenario 2 [1000 t] 
Demand long products  
Demand flat products  
Demand cast iron  
Total demand  
Total Fe-scrap supply (with losses, 
without contamination)  

2025 

2030 

2035 

2040 

1 849 
1 568 
1 359 
4 776 
7 026 

1 743 
1 715 
1 014 
4 472 
8 521 

1 407 
1 877 
268 
3 552 
9 750 

1 426 
1 903 
271 
3 600 
10 121 

Source: Oeko model 

393 The calculation is based on the number of passenger cars placed on market (PoM) in the corresponding year according to 
the Oeko model. 

394 The calculation for the demand is based on the number of passenger cars placed on market (PoM) in the corresponding 
year according to the Oeko model. 

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Table 6-80 Comparison of total supply and demand for scenario 3397 

Scenario 3 [1000 t] 
Demand long products 
Demand flat products 
Demand cast iron 
Total demand  
Total Fe-Scrap supply (with losses, 
without contamination)  

2025 

2030 

2035 

1 849 
6 271 
1 359 
9 479 
7 026 

1 743 
6 861 
1 014 
9 618 
8 521 

1 407 
7 508 
268 
9 183 
9 750 

2040 

1 426 
7 612 
271 
9 309 
10 121 

Source: Oeko model 

6.11.5  Outlook for a more comprehensive study 

For further assessment whether a recycling content target for vehicles might be meaningful, 
the study team sees the following aspects:  

Supply:  What  are  realistic  scenarios  for  the  ramp-up  of  advanced  shredder  technology? 
Consider  not  the  full  shredder  capacity  in  the  EU,  but  the  capacity  for  depolluted  ELVs, 
depolluted WEEE cat 4, and mixed scrap only. Investigate the total capacity and the volumes 
of the above-mentioned waste streams. Investigate the age of the existing shredder plants in 
the EU with the aim to assess the timing for the replacement of the current plants and the 
ramp-up to get sufficient capacities for high-quality steel-scrap with accompanying elements 
of less than 0.1%. Investigate required investment costs (and depreciation losses in case of 
very fast transition?)  

Relevant stakeholders / sources: EURIC, Eurofer, Galloo, TSR, Scholz Recycling and other 
operators of shredders (see also list of auto shredders in the EU395):  

Demand: What are realistic scenarios for the ramp-up of a) BF and converters capable of 
making  use  of  high-quality  steel  scrap,  b)  DRI  feed  EAF,  fully  integrated  for  flat  steel 
production. What might be the total demand of steel mills a) for the production of vehicles 
(instead  PoM  as  calculated  in this  report)  for  high-quality  scrap,  b)  beyond the  automotive 
industry (and including demand for export of products and export of steel)? Is the EU ETS-
sufficient to trigger the transition of the steel sector and to trigger the uptake of more scrap 
for the flat steel production, or is a recycled content target needed for flat steel or for specific 
products (like vehicles)? Relevance of import and export of scrap and products (intermediate 
products  like  flat  steel  and  final  like  vehicles)  and  timing  of  protective  regulations  for  EU 
industry. 

Relevant stakeholders / sources: Eurofer but also the steel producers themselves, like Tata, 
ArcelorMittal, ThyssenKrupp, Voestalpine and the EAF in Italy. 

Demand, quality aspects: gain deeper insight, beyond the copper content, with regard to 
potential  limitations  from  accompanying  elements  (other  than  copper)  or  opportunities  for 
steel alloying for the uptake of (high quality) steel scrap.  

Relevant stakeholders / sources: Eurofer but also the steel producers themselves, like Tata, 
ArcelorMittal, ThyssenKrupp, Voestalpine and the EAF in Italy. And furthermore, producers 
maintaining their own raw material specifications (like many OEMs in the automotive sector). 

Economic impacts for the sectors / industrial stakeholders, considering the global market 
for scrap, iron, steel, and products from iron/ steel. How to deal with imports and exports and 
what timing is needed to address these global market implications. 

395 https://www.recyclingtoday.com/article/rtge0914-european-union-auto-shredding/  

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Environmental impacts a) for the EU, b) from a global perspective 

Resource supply impacts: a) for the EU, b) from a global perspective 

Supply and demand: Develop coherent scenario(s) for the ramp-up of supply and demand 
under different policy scenarios. 

6.11.6  References 

Argonne (2021): Argonne National Laboratory. GREET Model: The Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation 

Model. 2021. GREET2: vehicle manufacturing cycle model of vehicle technologies. Available online: https://greet.es.anl.gov 

Dworak and Fellner (2022): J., Dworak, S., Fellner, J., Beermann, M. et al. Stahlrecycling – Potenziale und Herausforderungen für innovatives 

und nachhaltiges Recycling. Österreichische Wasser- und Abfallwirtschaft 75, 97–107 (2023). https://doi.org/10.1007/s00506-022-00903-3 

ICCT (2022): European vehicle market statistics 2021/22, Publisher: International Council on Clean Transportation (2022) 

Philippe Russo / Jan Bollen (ArcelorMittal); presentation IARC - July 5th 2022 

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6.12  Ad-hoc contributions to the impact assessment of the EC: 
the 

Assumptions 
introduction of criteria for the export of used cars 

impact  assessment  of 

the 

for 

6.12.1  Background 

The  purpose  of  this  ad-hoc  contribution  to  the  impact  assessment  of  the  EC  is  to  provide 
assumptions for the impact assessment of the introduction of criteria for the export of used 
cars. Background: In the context of the revision of the ELV Directive and the 3R Directive one 
measure  proposes  to  introduce  criteria  for  the  allowance  to  export  used  vehicles.  The 
preferred option proposes to introduce the requirement of a valid roadworthiness certificate 
for the vehicles to be exported to non-EU countries 

6.12.2  Abstract  

According  to  an  assessment  by  Dutch  authorities  for  the  years  2017/2018,  the  majority  of 
vehicles exported to top 12 countries in Africa are in conformity with emission standard Euro 
3  only  or  even  with  the  worse  emission  standard  1  or  2.  With  emission  standard  Euro  4, 
obligatory  for  vehicles  first  registered  by  January  2006,  a  significant  improvement  was 
achieved in the reduction of NOx emissions from gasoline engines. A similar break through is 
achieved with Euro 5 for Particulates (PM1) from diesel engines, effective for new vehicles 
first registered by January 2011. Most vehicles exported have only limited exhaust treatment 
and cause emissions at relevant levels for health at urban areas. 

In the context of export restrictions, it is often argued that it would be a waste of resources 
and  also  not  CO2-efficient  if  a  used  car  for  which  there  is  a  demand  /  market  in  extra-EU 
countries were to be scrapped "early" due to export rules.  

Such arguments neglect national regulations of the importing countries to reduce the national 
emission  of  NOx  and  particles  and  the  shared  responsibility  of  exporters  and  importers  to 
enforce  such regulations.  Secondly,  it  neglects  the  (current)  lack  in  waste  management  in 
most of the receiving countries. And thirdly, it appears that, at least for the EU “scrappage 
premium”,  the  CO2-balance  of  such  scrappage  premium  was  positive.  While  not  100% 
comparable, the study team looked with this regard in evaluations of the scrappage premiums 
in 2008/2009: 

Two studies (ifeu (2009); HIS (2010)) assessed the impact of the “scrappage premiums” in 
2008/2009  and  concluded  it  had  positive  impacts  on  air  pollution  particularly  due  to  the 
scrapping  of  vehicles  with  EU  emission  standard  below  Euro  4.  Furthermore,  fossil  fuel 
consumption  was  reduced  significantly.  The  studies  further  compare  the  CO2  emissions 
during the use phase (either continuing use of the old used vehicle or emissions of the new 
subsidised vehicle) with the CO2 emissions caused by the production and recycling. In result 
the reduced emission during the use phase can compensate the emissions caused by the 
reduced lifetime. 

However,  within  the  limited  time  frame  of  this  study  to  provide  ad-hoc  support  to  the  ELV 
impact  assessment,  it  was  not  possible  to  develop  a  comprehensive  fleet  model  (and 
assumptions  for  future  developments  /  scenarios)  for  the  receiving  countries  and  to  use 
advanced assessment tools like LCA for a global impact assessment. However, a separate 
section  describes  the  tasks  that  need  to  be  performed  to  establish  such  quantitative 
modelling. 

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6.12.3  Economic impacts 

Economic impacts on commercial stakeholders in the EU are described in detail in section 
3.2.5. Particular impacts on ATFs can be found in 3.2.5.4 and on used car dealers in section 
3.2.5.5.  According  to  this  assessment,  ATFs  and  car  dealers  will  be  exposed  to  relevant 
losses of profits due to the introduction of the requirement to demonstrate that the car to be 
exported  has  a  valid  roadworthiness  certificate.  These  assessments  on  economic  impacts 
are “conservative” assumptions as it considers that all vehicles potentially falling today under 
the criteria “no roadworthiness certificate” or “not in compliance with the requirements in the 
receiving countries” will be not exported but scrapped in the EU. However, it is not unlikely 
that a certain share of the losses for dealers will be compensated by the export of vehicles in 
better condition and exporters might seek to get roadworthiness certificates for the vehicles 
for  export.  Insofar  the  economic  impacts  to  the  commercial  stakeholders  might  be  less 
harmful than described in the support study. In addition, the study team expects a continuing 
demand  for  qualified  spare  parts  for  vehicles  running  in  receiving  countries.  Since  this 
demand can no longer be met with end-of-life vehicles (two vehicles become one), the market 
for exporting used spare parts could grow.   

The  impact  on  consumers  is  not  addressed  in model  calculations  of  this IA  support study. 
However, it assumed that the demand in the EU for old vehicles in poor condition will decline 
and prices / revenues for the owners of such vehicles will decline too. This might be possibly 
compensated by increasing demand for mid-aged vehicles when a shift of the demand from 
non-EU countries becomes effective (see above). 

The economic impact for the receiving countries is not assessed in model calculations in this 
IA support study. Presumably, the demand for affordable vehicles in the receiving countries 
will persist. At the same time several governments aim to regulate the (emission) quality of 
the  imported  vehicles  either  by  age  or  emission  level  as  reported  in  section  6.5.1.2  and 
6.5.1.5. In 2020, 82 non-EU countries in Africa and Eastern Europe, the Caucasus, Central 
Asia, and Middle East, receive vehicles from the EU. 59 of the 82 countries have regulations 
for the import of used vehicles either by age or emission class (or both). 82% of the used 
vehicles exported to non-EU countries in Africa and Eastern Europe, the Caucasus, Central 
Asia,  and  Middle  East  are  exported  to  these  59  countries.  However,  most  of  them  face 
difficulties  in  enforcing  their  import  regulations  for  diverse  reasons.  Therefore,  the 
governments and the UN claim a joint responsibility of the importing countries and also the 
exporting countries (here EU).  

The governments for the receiving countries are well aware that prices for (younger) vehicles 
with less emission might increase the prices for transport.  

6.12.4  Environmental 

impacts  and  aspects 

regarding  circular 

economy 

Environmental impacts can be expected for different impact categories as  

•  Younger fleet, with more advanced emission reduction, will help to improve the air quality 
in the receiving countries (in particular in the cities where traffic congestion is often the 
norm) and support the advanced countries in their national strategy accordingly (“shared 
responsibility”).  

•  Since  in  non-EU  countries  repair  with  local  labour  and  with  used  components  is  more 
affordable than in the EU, vehicles exported to non-EU countries often have a service life 
of up to 30 years. If fewer EU vehicles are exported, this could shorten the lifespan of 
vehicles  first  brought  to  market  in  the  EU.  Shorter  lifetime  increases  the  demand  of 
resources for the production of additional vehicles. Shorter lifetime and at the same time 

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the same number of vehicles per capita in a global perspective is increasing the demand 
of resources (including non-renewable) for the production of vehicles.  

•  Younger fleet will possibly also consume less fuel per km and thus the consumption of 

fossil fuels during the use phase might be less than for an older fleet. 

•  Many of the receiving countries do not have effective recycling infrastructure in place and 
hence a lot of the recycling potential is lost when vehicles are exported to these countries. 
The  lack  of  a  recycling  structure  goes  hand  in  hand  with  a  lack  of  infrastructure  for 
depollution and waste disposal, e.g. for the treatment of waste oil, tyres, refrigerants from 
air-conditioning  systems  and,  last  but  not  least,  for  the  recycling  of  lead  batteries. 
Unfortunately,  the  dangerous  pollution  caused  by  this  lack  of  infrastructure  cannot  be 
reduced  by  the  requirement  that  exported  vehicles  be  accompanied  by  a  valid 
roadworthiness certificate.  
In cases where importing countries can enforce regulations on imported vehicles, vehicles 
not meeting national standards are impounded at the ports of entry and left to deteriorate. 
These vehicle ´graveyards´ present another environmental challenge to those countries 
that do not have the recycling facilities mentioned above.  

• 

In the following the assumptions for the above mentioned aspects are outlined: 

6.12.4.1  Emission-characteristics of vehicles exported to Africa 

The Dutch ILT-IDlab carried out in 2020 inter alia a desk study and assessed the vehicles 
exported to the top 12 countries in Africa in 2017 / 2018 (in total 30,083). These countries are 
three countries in North Africa (12,404 vehicles), eight (ECOWAS) countries in West Africa 
(17,868), and one country in East Africa (1,068 vehicles).396  

According to this study “the majority of used vehicles exported from the Netherlands to top 8 
West African countries have Euro standard 0, 1, 2, and 3.” One exception is Ghana, which 
also receives a significant share of Euro 4 vehicles. Another exemption is Morocco, strictly 
applying the import requirement that the maximal age of imported vehicles is 5 years and that 
the imported vehicles must comply with Euro 4 standard (Baron et. al (2020)). Details of the 
distribution of emission level for the assessed countries are displayed in Annex A.  

6.12.4.2  Euro emission standard and real-world emissions 

Emissions regulations in the EU date back to 1970. The regulations define acceptable limits 
for  exhaust  emissions  of  new  vehicles  sold  in  the  EU.  Table  B-1  in  Annex  B  displays  the 
emission standards Euro 1 to Euro 7 for passenger cars (Category M1) and Table B-2 to B-4 
display the emission standards Euro 1 to Euro 6d for light commercial vehicles (Category N1 
and N2) 

Because petrol and diesel engines produce different types of emissions, they are subject to 
different standards. 

However,  the  reals  world  emissions  of  the  vehicles  do  not  always  match  well  with  the 
standards as it became obvious in 2015 with the so called “diesel gate”. TNO has undertaken 
emission  testing  for  the  Dutch  government  continuously  since  the  1980’s.  There  are 
comprehensive programmes to test passenger cars, vans, trucks, buses and two-wheelers. 
The  main  purpose  of  the  measurement  programmes  is  to  determine  the  on-road,  in-use 

396 Source Used Vehicles Exported to Africa, Netherlands Human Environment and Transport Inspectorate, Ministry of 
Infrastructure and Water Management, 2020 

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emission  performance  of  vehicles  relevant  to  Dutch  air  quality.  The  emissions  factors  for 
different  road  types  and  congestion  levels  are  updated  annually  on  the  basis  of  new 
measurement results. The reports and the results are available on-line. In Annex B a table is 
displayed  summarising  the  main  results  for  NOx  and  exhaust  PM  emissions  (particulate 
mass).397  

Leaving aside for a moment all the specifics of the emission standards, the different methods 
used to measure emissions, and the reasons for continuous improvements, it can be seen 
from the real emissions reported by TNO that a significant improvement was achieved with 
the  introduction  of  Euro 4,  obligatory  for  vehicles  first registered  by January  2006  for  NOx 
from gasoline engines. A similar break through is achieved with Euro 5 for Particulates (PM1) 
from diesel engines, effective for new vehicles first registered by January 2011. For NOx from 
diesel engines, a relevant change in real emissions can only be observed with Euro 6 RDE.  

For more details refer to Table 6-81 and Table 6-82 below and to Annex C. 

Table 6-81 Changes in real-world emissions for passenger cars with petrol engine on 
urban roads  

Emission 
standard 

Euro 3  

Euro 4  

Euro 5  

Euro 6 

Unit 

NOx 

Particles (PM1) 

(g/km) 

0.15 to 0.21 g/km 

% change  
compared to 
Euro 3 

 -62 to -64 % 

-70 to -71 % 

-70 to -71 % 

0.0046 
0% 

-20% 

-20% 

Source: own calculations with data from: Ligterink, Norbert, TNO (2017): Real-word Vehicle Emissions; Discussion Paper No. 
2017-06; Prepared for the report “Strategies for Mitigating Air Pollution in Mexico City”  

Table 6-82 Changes in real-world emissions for passenger cars with diesel engine on 
urban roads  

Emission 
standard 

Euro 4  

Euro 5  

Euro 6  

Unit 

NOx 

Particles (PM1) 

(g/km) 

0.43 – 0.69 g/km 

0.033 to 0.051  

% reduction 
compared to 
Euro 4 

+ 45 to +56 % (!) 

-98 to -99% 

0 to -20 % 

-98 to -99% 

Euro 6 RDE 

-47 to -55 % 

-98 to -99% 

Source: own calculations with data from: Ligterink, Norbert, TNO (2017): Real-word Vehicle Emissions; Discussion Paper No. 
2017-06; Prepared for the report “Strategies for Mitigating Air Pollution in Mexico City”  

6.12.4.3  Conclusion on impacts on air pollution 

If roadworthy 

397 Source: Ligterink, Norbert, TNO (2017): Real-word Vehicle Emissions; Discussion Paper No. 2017-06; 
Prepared for the report “Strategies for Mitigating Air Pollution in Mexico City” 

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•  all gasoline vehicles sold from January 2006 (today, in 2023, 17 years old) comply with 

Euro 4 emission standard and 

•  all diesel vehicles sold from January 2011 (today, in 2023, 12 years old) comply with Euro 

5 emission standard. 

Compared  to  older  vehicles  or  vehicles  which  are  not  roadworthy,  e.g.  by  not  functioning 
exhaust  treatment,  the  above-mentioned  Euro  4  and  Euro  5  vehicles  reduce  the  emission 
level in the receiving countries, if they replace an older vehicle.  

The qualitative assumption for the impact assessment is that the measure to establish a valid 
roadworthiness  certificate  as  a  condition  for the export  will  accelerate  the  shift from  below 
Euro  4  to  vehicles  complying  with  Euro  4  and  better  and  thus  support  the  national 
governments  in  their  effort  to  improve  the  air  quality  in  African  cities.  The  problematic  air 
quality is outlined above in section 6.5.1.7 of this study.  

A  quantitative  modelling  will  need  assumptions  for  the  composition  of  the  total  fleet  (and 
possibly  a  breakdown  for  the  agglomerations  /  large  cities,  as  here  the  air  quality  is 
problematic) and the development of the composition of the fleet under BAU conditions and 
the development of the composition of the fleet under a policy option with criteria for the export 
of vehicles.  

6.12.4.4  Less emissions and fossil fuel consumption by a younger 

fleet 

In the context of export restrictions, it is often argued that it would be a waste of resources 
and  also  not  CO2-efficient  if  a  used  car for  which  there  is  a  demand / market  in  extra-EU 
countries were to be scrapped "early" due to export rules.  

At  first  glance  these  arguments  neglect  demand  of  the  importing  countries  to  reduce  their 
national  emissions  of  NOx  and  particles  and  the  shared  responsibility  of  exporters  and 
importers as mentioned in the sections before. Secondly it neglects the (current) lack in waste 
management in most of the receiving countries as mentioned in a separate section of this 
report.  

While  it  is  not  possible  in  the  given  time  to  develop  a  comprehensive  fleet  model  for  the 
receiving  countries  and  to  use  advanced  assessment  tools  like  LCA  for  a  global  impact 
assessment,  some  conclusions  might  be  taken  two  studies  evaluating  the  “scrapping 
premiums” during the financial crisis in 2008/2009.  

In  January  2009,  the  German  Federal  Government  introduced  an  "Umweltprämie”  (an 
environmental  bonus)  in  the  amount  of  €  2,500  as  part  of  the  Konjunkturprogramm  II  (an 
Economic Stimulus Programme). It was granted as a one-time state subsidy if a private owner 
purchases a new passenger car or annual car and at the same time demonstrably scraps a 
passenger car that is at least 9 years old and was previously registered to the owner for at 
least  1  year.  The  effects  of this  "Umweltprämie” on  the  environment  were  examined  in  an 
expert  report  by  ifeu  on  behalf  of  the  Federal  Ministry  for  the  Environment,  Nature 
Conservation and Nuclear Safety (ifeu 2009). Due to the premium pot of €5 billion, the study 
assumed around 2 million cars scrapped in 2009 and 2010, representing around 4.8% of the 
entire German fleet of passenger cars.  

The  results  show  that  the  Umweltprämie  led  to a  reduction  in  air  pollutant  emissions from 
motor vehicle traffic. When they were first registered, passenger cars had to comply with the 
standards in force at the time. This meant that they were allowed to emit considerably more 
air pollutants (nitrogen oxides, benzene, hydrocarbons, carbon monoxide and particulates) 
with their engine exhaust than they do today. The newly registered vehicles meet the limit 
value  levels  4  and  5  valid  in  2009  and,  as  diesel  passenger  cars,  usually  also  have  a 

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particulate filter. The older the old vehicle, the greater the difference in emissions compared 
to new vehicles. According to ifeu 2009, 9 % of benzene, 7 % of carbon monoxide, 5 % of 
nitrogen  oxides  and  just  over  4  %  of  diesel  particulate  emissions  from  the  entire  German 
passenger car fleet were saved (ifeu 2009). 

The CO2 emissions of new cars were calculated in ifeu 2009 at 160 g CO2/km. This value 
was 40 g/km and thus 20% below the average of 200 g/km for the scrapped passenger cars. 
The  difference  between  the  old  cars  and  the  new  cars  replacing  them  is  therefore  1.7  l 
petrol/100 km and 1.5 l diesel/100 km respectively. This resulted in a saving of around 340 
million litres of fuel or 1 million tonnes of CO2, if the emissions from fuel production are also 
considered. This CO2 saving corresponds to just under 1% of all passenger car emissions in 
Germany. The fact that this effect is so small is because the substituting passenger cars only 
account for 4 % of the mileage of all passenger cars. 

The CO2 emission caused by the production of a new vehicle and the recycling of a typical 
end-of-life  vehicle  was  assumed  to  be  4.5  tonnes.  This  environmental  burden  can  be 
depreciated over the distance driven or the age of the car. With an average use of 15.4 years, 
this amounts to 290 kg CO2 per year of life. If the car is scrapped one year earlier, i.e. at 14.4 
years  (average  age  of  cars  now  scrapped),  290 kg  CO2  remain  as  undepreciated  residual 
debt. This CO2 emission arises from the consumption of 100 litres of petrol. The residual debt 
can therefore be paid off with the saving of 100 litres of petrol and thus after 6,000 km, since 
the new cars consume on average 1.7 l/100 km less than the scrapped ones. After that, the 
new vehicle is in the plus in terms of CO2. (ifeu 2009) 

In  the  same  year  that  the  “Umweltprämie”  was  introduced  in  Germany  (2009),  scrapping 
incentives  have  been  enacted  in  thirteen  member  states  of  the  EU.  These  scrappage 
programs were in operation in markets that typically represent 85% of total vehicle sales in 
the EU. The 'typical' scheme required the scrapping of a vehicle with a minimum age of 10 
years and provided an incentive of € 1,500 for the purchase of a new car. In total, scrapping 
schemes have cost European governments a total of €7.9 billion in outlay plus the cost of 
administration. In a study published in 2010, IHS Global Insight, on behalf of DG Enterprise 
and Industry, examined the short- and medium-term effects of vehicle scrappage schemes 
introduced in Member States in 2009 in terms of economic, environmental and safety impacts 
(IHS Global Insight 2010a; IHS Global Insight 2010b). 

The  average  new  car  bought  in  2009  under  the  scrappage  scheme  has  estimated  CO2 
emissions of only 135.9 g/km, 18 g/km below the EU market average in 2008. According to 
the  calculations  (IHS  Global  Insight  2010a),  the  average  CO2  emissions  of  the  entire  fleet 
have  been  reduced  to  about  145  g/km.  This  means  that  1.05  million  tonnes  of  CO2  were 
saved at EU level during 2009 as a direct result of the scrappage schemes introduced. This 
corresponds to an average saving of 0.49 tonnes per additional vehicle sold. The cumulative 
CO2 emissions saved were estimated at a total of 1.79 million tonnes by the end of 2010 and 
2.3 million tonnes by the end of 2011. Under the programs, over one million Euro 1 and pre-
Euro 1 standard cars and almost one million Euro 2 cars were withdrawn from use and were 
replaced by a mix of 84% Euro 4 and 16% Euro 5 vehicles. This leads to a reduction in both 
NOx and particulate matter (IHS Global Insight 2010a). 

6.12.4.5  Increasing the demand of resources for the production of 

vehicles 

New  export  requirements  (valid  roadworthiness  certificate)  might  shorten  the  lifetime  of 
vehicles placed first at the EU market. Shorter lifetime increases the demand of resources for 
the production of additional vehicles. Different scenarios might apply for the replacement of 
these not exported EU vehicles in the receiving countries.  

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a)  The receiving countries replace these cars with newer used cars from the EU-Market 
(as far as the total service life remains as long as before (e.g. 30 years), this will not 
change in the global demand for resources). 

b)  The receiving countries seek to import the same kind of (old) used vehicles from other 

markets (US / Japan / China(?)). 

c)  The  receiving  countries  increase  the  share  of  new  vehicles  placed  on  the  market, 
possibly not EU-brands but other brands. The expected lifetime is to be assessed.  

In the studies of ifeu (2009) and IHS Global Insight (2010), the demand of resources was only 
taken into account with regard to the resulting emissions of CO2 and air pollutants. Results 
from the calculations of the used and recycled materials were not published. Other studies 
on this question could not be found in the time available. 

A  calculation  of  possible  additional  resource  consumption  depends  strongly  on  the 
assumptions  how 
for  changed  EU-export 
requirements and on the expected lifetime of vehicles placed on the market in the receiving 
countries. Different scenarios could be modelled based on an extended Oeko model. 

the  receiving  countries  will  compensate 

6.12.4.6  Lack  in  waste  management  and  lost  secondary  raw 
materials  due  to  missing  recycling  infrastructure  in 
receiving countries 

Many of the receiving countries have no effective recycling infrastructure in place and a lot of 
the recycling potential is lost when vehicles are exported to these countries. 

The problem anyhow exists, also without the import of (old) used vehicles. Thus, there is an 
urgent need to start establishing advanced recycling capacities (feeding national industries).  

Exports of (very) old vehicles increase the problem compared to the import of younger imports 
as the following assumption demonstrates:  

If the vehicle is imported at an age of 5 years and complies with Euro 4 (respectively 5 for 
diesel) it will possibly last another 25 years in the country of destination before becoming an 
ELV. An imported vehicle with an age of 18 years might last another 12 years in the receiving 
country before becoming waste. Thus, the waste generated for the same service is twice as 
much when old vehicles are imported.  

If  this  waste  cannot  be  treated  as  hazardous  waste  and  not  recycled,  the  impact  in  the 
receiving country is a risk of environmental pollution and for the global perspective secondary 
resources are wasted. 

6.12.5  What  tasks  need  to  be  performed  to  establish  quantitative 
the  beforementioned  environmental 

modelling  covering 
impacts 

For further assessment whether a shortened lifespan for vehicles might be meaningful, we 
see the following aspects: 

The  introduction  of  stricter  criteria  for  the  export  of  vehicles  to  non-EU  countries  will  be 
examined using the export of used cars from the EU to West Africa as an example. Here, the 
effects will be examined if the used cars are no longer exported but remain in the EU and are 
scrapped here instead. Based on the previous calculations with the Oeko model for recycling, 

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possible impacts can be modelled up to 2030/2040. A distinction would be made between 
impacts in the European Union and impacts in West Africa. 

Several options are possible for the modelling: 

•  A ban on the export of used cars to West Africa with a constant useful life in the EU. 
•  A ban on the export of used cars to West Africa with an extension of the useful life in the 

EU. 

Environmental impacts that should be considered: 

•  CO2 emissions 
•  Emissions of air pollutants 
•  Resource consumption for the production of new cars 
•  Secondary materials available from recycling 

For  the  modelling,  we  propose  to  extend  the  fleet  model  for  passenger  cars  in  the  EU  to 
include production phase and use phase. Furthermore, a simplified model of the car fleet in 
West  Africa  should  be  created  in  order  to  model  in  particular  the  current  and  perspective 
composition of the car fleet there (under BAU conditions and under policy option with criteria 
for the export of vehicles) and to be able to assess the resulting environmental impacts and 
resource flows. 

6.12.6  References 

Ifeu 2009: Abwrackprämie und Umwelt – eine erste Bilanz. Gutachten im Auftrag des Bundesministeriums für Umwelt, Naturschutz und 

Reaktorsicherheit (BMU). Fachliche Bearbeitung: Dr. Ulrich Höpfner unter Mitarbeit von Dr. Jan Hanusch und Dipl.-Phys. Udo Lambrecht. 

ifeu – Institut für Energie-und Umweltforschung Heidelberg GmbH. Heidelberg 2009. 

IHS Global Insight 2010a: IHS Global Insight: Assessment of the Effectiveness of Scrapping Schemes for Vehicles Economic, Environmental, 

and Safety Impacts. Prepared for European Commission, DG Enterprise and Industry, Automotive Industry. Final Report March 2010. 

Online available under: https://circabc.europa.eu/sd/a/bcc4c732-6f54-4047-b661-42a5f3d1c490/report_scrapping_schemes_en.pdf, last 

access 29 May 2023 

IHS Global Insight 2010b: IHS Global Insight: Assessment of the Effectiveness of Scrapping Schemes for Vehicles. Country Profile Annex. . 

Prepared for European Commission, DG Enterprise and Industry, Automotive Industry. Final Report March 2010. Online available under: 

https://circabc.europa.eu/sd/a/b34363fe-8903-4d9c-a2f1-aa38733f0500/report_scrapping_schemes_annex_en.pdf, last access 29 May 

2023 

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6.12.7  Annex A: EU vehicle emission standards of exported vehicles 

to selected countries 

Figure 6-31  EU vehicle emission standard of retrieved petrol vehicles exported to 
West African countries in the top 12 

Source / Data: combined Customs and RDW. © ILT-IDlab 

Figure 6-32  EU vehicle emission standard of retrieved diesel vehicles exported to 
West African countries in the top 12 

Source / Data: combined Customs and RDW. © ILT-IDlab  

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Figure 6-33  EU vehicle emission standard of retrieved petrol vehicles exported to 
other countries in the top 12 

Source / Data: combined Customs and RDW. © ILT-IDlab 

Figure 6-34  EU vehicle emission standard of retrieved diesel vehicles exported to 
other countries in the top 12 

Source / Data: combined Customs and RDW. © ILT-IDlab 

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Figure 6-35  EU vehicle emission standard of retrieved diesel vehicles exported to 
Lybia  

Source / Data: combined Customs and RDW. © ILT-IDlab 

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6.12.8  Annex B: Development of EU Emission standards 

Table 6-83 EU Emission standards for passenger cars (Category M) (a); g/km 

Source: https://en.wikipedia.org/wiki/European_emission_standards 

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Table 6-84 EU Emission standards for light commercial vehicles with <= 1 305 kg 
reference mass (Category N1, Class I), g/km 

Source: https://en.wikipedia.org/wiki/European_emission_standards 

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Table 6-85 EU Emission standards for light commercial vehicles with 1 305 – 1760 kg 
reference mass (Category N1, Class II), g/km 

Source: https://en.wikipedia.org/wiki/European_emission_standards 

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Table 6-86 EU Emission standards for light commercial vehicles with > 1760 kg 
reference mass max 3 500 kg (Category N1, Class III & N2), g/km 

Source: https://en.wikipedia.org/wiki/European_emission_standards 

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6.12.9  Annex  C:  Development  of  real  world  emissions  under  Euro 

emissions standards 

Table 6-87 Real emission standards for passenger cars (Category M) (a); g/km 

Source: Ligterink, Norbert, TNO (2017): Real-world Vehicle Emissions; Discussion Paper No. 2017-06; Prepared for the report 
“Strategies for Mitigating Air Pollution in Mexico City” 

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ANNEX II: ASSESSMENT OF THE 3R DIRECTIVE AND ITS EFFECTIVENESS  

submitted  as  part  of  the  study  request  “Develop  and  assess  options  to  review  Directive 
2005/64/EC and integration of the results into the impact assessment of the ELV Directive, to 
be performed under the study request No 070201/2020/839200/SFRA/ENV.B3” 

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7.  Assessment of the 3R Directive and its effectiveness  

7.1  Introduction 

7.1.1  Study objectives and scope of this report 

According to the terms of reference of this study398, a targeted review of the 3R Directive shall 
be performed. Its main part consists of an evaluation of the effectiveness of certain elements 
of the 3R Directive and their linkage to the ELV Directive, a proposal of policy options and 
related  measures  to  address  any  shortcomings  and  identified  needs  for  revision  and  their 
analysis.  This  report  presents  the  results  of  the  3R  Directive  evaluation  performed  in  this 
respect.  Other  parts  of  the  work  have  been  integrated  into  the  report  of  the  ELVD  IA 
Supporting  Study  (“main  study”)  performed  to  support  the  impact  assessment  of  the  ELV 
Directive  of the  European  Commission.  The following  table (Table  7-1)  details  the  general 
objectives, i.e., tasks specifying which parts are included in this report and which have been 
included in the main report (with cross references). 

Table 7-1  List of tasks and references to the location of contents in the reports 

Steps  Description 

Where  it  can  be 
found 

1 

2 

3 

4 

5 

Assessment of the effectiveness of the Directive 2005/64/EC with a view to 
ensure reusability, recyclability and recoverability of vehicles to be placed on 
the market. 

This report 

Identification of policy options and measures for reviewing the ELV Directive 
in relation to the 3R Directive shortcomings 

ELVD IA Supporting 
Study report, section 
3.1.2 

Analysis  of  the  environmental,  economic  and  social  impacts  of  the  policy 
options and related measures presented to review the Directive 2005/64/EC 
(task 2) 

ELVD IA Supporting 
Study report, section 
3.1.4 

The  assessment  of  the  interrelations  with  general  type  approval,  the  ISO 
22628: 2002 and other international regulations like UN ECE Regulation No. 
133. 

This report 

Stakeholder Consultation  

•  Stakeholder  consultation,  with  a  view  to  collecting  data  for  the  tasks 
above,  including  performing  10  targeted  interviews  with  stakeholders 
involved in the type approval procedures; and targeted consultation per 
survey  of  additional  stakeholders  (type  approval  authorities,  technical 
services, vehicle manufacturers and component suppliers)  

•  Contribution to the stakeholders’ workshop on issues of 3R type approval 

Directive. 

ELVD IA Supporting 
report, 
Study 
0Annex 
III: 
Stakeholder 
consultation 
(synopsis 
and this report (*) 

report), 

(*) A summary of the main results of the consultation of stakeholders on the 3R Type approval and its relation to the ELVD is 
included in this report. 

Source: Terms of reference 

398 Develop and assess options to review Directive 2005/64/EC and integration of the results into the impact assessment of the 
ELV Directive, to be performed under the study request No 070201/2020/839200/SFRA/ENV.B3 

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Thus, the scope of this report (annex to the main report) is the evaluation of the effectiveness 
of the 3R Directive (step 1 above) and the assessment of its interrelations with the ISO 22628: 
2002 and UN/ECE Regulation No. 133 (step 4 above). It concludes with a specification of the 
shortcomings and areas requiring revision. This work does not comprise a full evaluation, but 
only looks at the effectiveness of the Directive in achieving objectives and provisions related 
to its linkage with the ELVD. Areas identified under the evaluation (steps 1 and 4) were the 
focus in the development and analysis of policy options and measures addressed under steps 
2  and  3  above. Information  collected  through  the  interviews  and surveys  performed  under 
step 5 above has been integrated in the stakeholder consultation synopsis compiled for the 
ELVD  IA  Supporting  Study.  A  summary  of  input,  opinions  and  information  provided  by 
stakeholders is included in section 7.3. 

7.1.2  Methodology  

To develop the framework for the evaluation, the 3R Directive was screened to identify the 
various provisions and obligations related to the ELV Directive and potentially contributing to 
the circularity of vehicles and their link to design and end-of-life requirements. A summary of 
this screening process is detailed in section 7.2. 

The  following  was  initially  identified  to  focus  the  screening  stage  and  to  identify  how  the 
intention of the regulators is expressed in the origin and the objectives of the 3R Directive in 
relation to: 

•  The  scope  of  the  3R  type  approval,  whether  it  is  aligned  with  the  ELVD  and  how  this 

would be affected should the scope of the ELVD is to be extended. 

•  How ELVD design requirements (e.g. the ELVD Article 4(2) substance prohibitions) are 

taken into consideration in the 3R Type approval provisions and process.  

•  How ELVD end-of-life requirements (e.g. the reuse + recycling target of 85% and reuse 
+ recovery target of 95%, thereafter referred to as 3R targets) are taken into consideration 
in the 3R Type approval provisions and process.  

•  What information is collected as part of the 3R Directive processes and how does this 

relate to information that is needed for the implementation of the ELVD?  

On  the  basis  of  these  main  areas,  the  following  questions  have  been  formulated  for  the 
evaluation of the effectiveness of the 3R Directive: 

area 

Main 
screening 
evaluation 

for 
and 

The  origin  and  objective 
of the 3R Directive 

The scope of the 3R 
Directive  

ELVD design 
requirements 

Table 7-2  Evaluation Matrix 

Evaluation questions 

•  Does  the  3R  Directive  effectively  transpose  the  intention  of  regulators  in 

relation to Art. 7(4) of ELVD? 

• 

• 

Is the scope of the 3R Directive effective in ensuring that its provisions will 
be implemented in relation to the vehicles to which it applies? 
Is the scope of the 3R Directive aligned with the ELVD at present or in the 
case that the scope of the ELVD is to be changed in the future? 

• 

Is the way that the 3R Directive refers to the ELVD hazardous substance 
prohibitions and plastic coding provisions effective in terms of ensuring that 
vehicles put on the market comply with the related ELVD requirements? 
•  Will  the  way  that  the  3R  Directive  addresses  substance  prohibitions  and 
plastic  coding  remain  effective  in  case  such  prohibitions  (or  their 

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area 

Main 
screening 
evaluation 

for 
and 

Evaluation questions 

exemptions,  if  applicable)  and  coding  requirements  will  change  in  the 
future? 

• 

•  Will the way that the 3R Directive addresses substance prohibitions remain 
effective  in  case  such  prohibitions  (and/or  their  exemptions)  will  be 
regulated by another legislation (e.g. REACH? 
Is the 3R Directive effective in ensuring that vehicles put on the market are 
more circular? 
Is the 3R Directive suitable for ensuring in the future that vehicles put on the 
market will comply with future ELVD provisions on circularity (e.g. recycled 
content targets)? 

• 

ELVD 
requirements 

end-of-life 

Information 
collected 
through  the  3R  Directive 
processes 

Alignment  of 
Directive  with  the 
22628: 2002 

the  3R 
ISO 

Alignment and coherence 
with 
ECE 
Regulation 133 

the 

UN 

• 

• 

• 

• 

Is  the  3R  Directive  effective  in  ensuring  that  vehicles  put  on  the  market 
enable the reuse of their components and parts to the highest potential? 
Is  the  3R  Directive  effective  in  ensuring  that  vehicles  put  on  the  market 
enable the recycling of their components and parts to the highest potential? 
Is the 3R Directive effective in ensuring that vehicles put on the market are 
composed of materials that can be recycled to a sufficient degree? 
Is the 3R Directive effective in ensuring that vehicles put on the market can 
fulfil the ELVD 3R targets at present or in case their ambition is increased 
in the future?  

•  Would the 3R Directive remain effective in ensuring that vehicles put on the 
market comply with ELVD if requirements would be added to make certain 
waste  management  treatments  obligatory,  e.g.,  certain  post  shredder 
technologies? 

• 

• 

• 

• 

Is the 3R Directive effective in ensuring that ATFs have enough information 
on  vehicles  put  on  the  market  to  allow  their  waste  management  in 
compliance with the ELVD 3R targets? 

Is the use of the ISO 22628: 2002 in the 3R Type approval process effective 
in ensuring that type approved vehicles put on the market comply with the 
ELV provisions? 
Is the use of the ISO 22628: 2002 in the 3R Type approval process effective 
in achieving the objectives of the 3R Directive? 

Is the 3R Directive coherent with the UN ECE Regulation 133?  

For each of the areas identified, the evaluation considers how the current legal text affects 
the implementation of the 3R type approval and indirectly how it affects the implementation 
of the ELVD provisions related to the design of vehicles and their waste management. These 
are  looked  at  in  relation  to  the  effectivity  of  their  implementation.  As  the  framework  of  the 
assessment includes the linkage to the ELVD, to the ISO 22628: 2002 and to the international 
UN/ECE Regulation No. 133, coherence of these legislations and frameworks will also play 
a role. 

7.1.3  Structure of the report 

In relation to the structure of the report, this introduction is followed by three chapters: section 
7.2 describes the current situation. It explains the origin of the 3R legislation and interrelations 
with ELVD. Furthermore, it outlines the general Type approval legislation, the main provisions 
of the 3R Directive and the 3R type approval process, as well as the implementation or the 

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3R Directive. The section that follows (section 7.3) is a summary of the input, opinions and 
information  provided  by  stakeholders  in  the  stakeholder  consultation  in  relation  to  the  3R 
Directive specifically. The consultation strategy is described in the stakeholder consultation 
synopsis  report  of  the  ELVD  IA  Supporting  Study.  The  evaluation  of  the  results  of  the 
effectiveness of the 3R Directive is presented in section 7.4, structured in sub-sections that 
follow  the  main  areas  for  screening  and  include  an  evaluation  of  questions  listed  in  the 
evaluation matrix (Table 7-2). Finally, section 7.5 presents a summary of the main results. 

7.2  The current situation 

7.2.1  Background  to  the  3R  Directive  and  its  interrelations  to  the 
Regulation on Type approval and to the ELV Directive 

Directive  2000/53/EC  of  18  September  2000  on  end-of-life  vehicles  (hereinafter  ELVD) 
regulates the design and waste management of vehicles throughout their life cycle. Article 
7(4) of the ELVD required the Commission to amend Directive 70/156/EEC on type approval 
in order to make sure that vehicles “are re-usable and/or recyclable to a minimum of 85 % by 
weight per vehicle and are re-usable and/or recoverable to a minimum of 95 % by weight per 
vehicle”.  To  this  end,  Directive  2005/64/EC399  on  the  type  approval  of  motor  vehicles  with 
regard to their reusability, recyclability and recoverability (3R Directive) was adopted in 2005. 
This relates to steps 1 and 2 detailed in Figure 7-1.  

After two revisions, Directive 70/156/EC was repealed by Directive 2007/46/EC at first, and 
later by Regulation 2018/858/EU (see steps 3 and 4 in Figure 7-1 below). The changes made 
in  the  Regulation  on  Type  approval  following  the  amendment  prescribed  in  Annex  VI  of 
Directive 2005/64/EC have been maintained throughout the revisions. As a consequence, the 
Regulation on Type approval from 2018 further relates to the 3R Directive (step 5 in Figure 
7-1). Based on the amendment that 3R Directive, Annex VI stipulates for the general type 
approval that, if the manufacturer does not meet the requirements of the 3R Directive, no type 
approval shall be granted.  

Figure 7-1  Timeline of amendments of ELVD, 3R Directive and Directives and 
Regulation on   type approval 

Source: Own illustration, Oeko-Institut 2021 

The  3R  Directive  interrelates  the  lifecycle  steps  of  the  vehicle  design  and  end-of-life  by 
requiring that the design of a vehicle type be investigated to ensure that it will not hinder the 
achievement of the ELVD 3R targets that are otherwise relevant at the end-of-life stage of a 
vehicle. 

399 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 and amending Council Directive 70/156/EEC 

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It is noted that the 3R Directive (2005/64/EC) refers to Articles of the general type approval 
legislation in its previous version, i.e. Directive 70/156/EEC. However, some of these have 
become obsolete or requirements have changed since the Directive’s amendments in 2005 
and 2018. To give an example: When the 3R Directive came into force, the annual limits for 
Member  States  for  ‘small  series’  were  higher  than  the  limit  values  stipulated  in  the  2018 
Regulation400.  In  other  words,  the  consequences  of  certain  changes  on  the  3R  Directive, 
might not have been in the focus of the revisions of general type approval legislation, e.g., 
the lower limits for small series. 

7.2.2  Main  provisions  of  the  3R  Directive  and  relations  to  other 

policies 

In order to make clear what are the objectives and main provisions of the 3R Directive in its 
current version in terms of design, reuse, recycling and recovery, related articles and annexes 
and  relations  to  other  policies,  namely  ELVD,  general  type  approval,  WFD  and  Circular 
Economy Action Plan are described below. 

7.2.2.1  Objective of the 3R Directive 

The  3R  Directive  aims  to  ensure  that  type-approved  vehicles  placed  on  the  market  fulfil 
certain provisions of the ELVD, namely the 85% reuse and/or recycling and 95% reuse and/or 
recovery  targets  (Art.  7  of  ELVD,  Recital  1  and  Annex  I  of  3R  Directive).  Art.  1  of  the  3R 
Directive stipulates that ‘this Directive lays down the administrative and technical provisions 
for the type approval of vehicles covered by the Art 2 [the scope of 3R Directive], with a view 
to ensuring that their component parts and materials can be reused, recycled and recovered 
in the minimum percentages set out in Annex I. It lays down specific provisions to ensure that 
the reuse of component parts does not give rise to safety or environmental hazards’.  

In order to facilitate the treatment of vehicles at their end of life, ‘manufacturers should be 
requested to include [reusability, recyclability and recoverability] at the earliest stages of the 
development of new vehicles’ (Recital 2 of 3R Directive). This is rephrased in Recital 15 of 
the 3R Directive which states that ‘the objective of this Directive [is] to minimize the impact of 
end-of-life  vehicles  on  the  environment  by  requiring  that  vehicles  be  designed  from  the 
conception phase with a view to facilitating reuse, recycling and recovery’. Both Recitals point 
out to the importance of the design phase to ensure the effectiveness of the ELVD, in other 
words the importance of design for recycling. The Circular Economy Action Plan (COM(2015) 
614 final 2015) also emphasized the importance of the design phase when stating that ‘the 
Commission  will  also  propose to  revise the  rules  on  end-of-life  vehicles […]  linking  design 
issues to end-of-life treatment […] and improving recycling efficiency’.  

Therefore, the compulsory whole vehicle type approval system which covers all categories of 
vehicles shall include measures on reusability, recyclability and recoverability (Recital 4 of 3R 
Directive).  As  a  consequence,  manufacturers  shall  provide  new  and  additional  data  in  the 
processes of the general type approval which therefore shall be amended (Recital 13 of 3R 
Directive). 

400 In Directive 70/156/EEC, annual limits per Member State are 500 units for M1, N1, O1, O2, and 250 for M2, M3, N2, N3, 
O3, O4; except for mobile cranes which have a limit of 20 units. In Regulation 2018/858, the general type-approval regulation 
in force today, annual limits per Member State are 500 units for O1, O2, and 250 for M1, M2, M3, N1, N2, N3, O3, O4. The 
EU-wide annual limits are 1 500 for M1, N1, N2, N3, and 0 for other categories.  

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7.2.2.2  The scope of the 3R Directive  

The scope of the 3R Directive is detailed in Art. 2 ‘Scope’ and Art. 3 ‘Exemptions’. Vehicles 
in scope of the 3R Directive are M1 and N1 vehicles (explicitly named) as well as new and 
reused components of such vehicles. Special purpose vehicles, including as per definition (in 
Directive  70/156/EEC)  motorcaravans,  armoured  vehicles,  ambulances,  hearses,  trailer 
caravans,  mobile  cranes  and  others,  multi-stage  build  vehicles  of  N1  type  and  vehicles 
produced in small series, are exempted. The latter includes historic cars.  

Articles  2  and  3  of  3R  Directive  have  cross-references  to  the  Directive  70/156/EEC,  more 
specifically, to Part A of Annex II in relation to the definitions of M1, N1 vehicles and special 
purpose vehicles, and to Art. 8(2) in relation to exemptions (from general type approval) for 
vehicles produced in small series. 

The 3R Directive scope does not refer to the scope of the ELV Directive. 

7.2.2.3  Requirements addressing the design of vehicles 

Design  requirements  addressed  in  this  section  and  mentioned  in  the  3R  Directive  are 
hazardous substance requirements and plastic coding.  

Hazardous substance prohibitions under the 3R Directive 

Avoiding hazardous substances in vehicles contributes to minimizing hazardous waste and 
increases  the  recyclability  of  material  streams  at  the  end-of-life.  Hazardous  substance 
provisions, i.e., Art. 4(2) of Directive 2000/53/EC (ELVD), is/are referred to in Art. 6(2) of the 
3R Directive.  

Compared to other provisions of the 3R Directive, for the hazardous substance provision, the 
3R  Directive  sets  a  direct  link  to  the  ELV  Directive.  The  3R  Directive  obliges  the  Member 
States to ensure that ‘materials used for the construction of a vehicle type comply with the 
[hazardous substance] provisions’. Formulated in a very similar way, Art. 4(2) of the ELVD 
obliges  Member  States  to  ensure  that  ‘materials  and  components  of  vehicles  […]  do  not 
contain lead, mercury, cadmium or hexavalent chromium other than in cases listed in Annex 
II’ (of ELVD).  

Art. 9 of the 3R Directive addresses amendments of the type approval due to ‘scientific and 
technical  progress’  which  shall  follow  the  general  type  approval  update/amendment 
procedure (as described in the general type approval legislation, referenced as Art. 13(3) of 
Directive  70/156/EEC).  The  procedure  might  become  relevant  in  relation  to  hazardous 
substances, if an ELVD, Annex II exemption is not required anymore, or if technical progress 
newly requires the use of one of the substances prohibited through Art. 4(2) of ELVD. 

Plastic coding 

According to Art. 8(1) of the ELVD, ‘Member States shall take the necessary measures to 
ensure that producers, in concert with material and equipment manufacturers, use component 
and material coding standards, in particular to facilitate the identification of those components 
and materials which are suitable for reuse and recovery’. This requirement facilitates the end-
of-life  treatment  of  plastic  parts,  as  acknowledged  by  the  legislative  text,  but  it  is  to  be 
considered in the design of component parts, so it can be considered a design requirement. 
Annex IV point 3(f) of 3R Directive refers to this ELVD provision in the way that ‘the competent 
body  [within  the  preliminary  assessment  of  the  manufacturer]  shall  ensure  that  the 
manufacturer  has  taken  the  necessary  measure  to  mark  the  component  parts  made  of 

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polymers and elastomer […].’ For this purpose, the Commission Decision 2003/138/EC has 
established  component  and  material  coding  standards  for  vehicles  pursuant  to  Directive 
2000/53/EC (ELVD).  

Other aspects of design 

Next to the hazardous substances and the plastic coding, other decisions of manufacturers 
in relation to design are covered in different ways:  

• 

In some cases, the 3R Directive’s text makes references to some design aspects, e.g., 
for the selection of the reference vehicle according to Annex I, points 3 to 5, the trim levels 
as  well  as  available  optional  equipment  shall  be  decisive,  providing  examples  like 
upholstery,  EEE  equipment,  air-conditioning,  alloy  wheels  etc.  This,  however,  is 
understood to mean that in the choice of the vehicle version to be subjected to the 3R 
type approval process, that consideration of vehicle versions under a certain vehicle type 
with different trim levels (and also with different optional equipment) should ensure that 
all  vehicle  versions  of the  type  (with  differing trim  and/or  additional  equipment)  comply 
with the 3R provisions. In other words, it cannot be seen as a design requirement.  
•  While from the perspective of the ELVD, reuse, recycling and recovery targets relate to 
the end of life, the hypothetical character of the ISO 22628:2002 calculations (‘recycling 
shall be assumed’) inhibits looking at reuse, recycling, and recovery the other way around, 
from  the  design.  This  is  to  say  that  through  the  use  of  the  ISO  standard  calculation, 
recyclability of a material is considered based on an assumption whether its recyclability 
will reach maturity by the EoL of the vehicle, but it is not considered in the design phase 
as a criterion that requires  the material chosen for a certain component to be recyclable 
at the time of design. 
In the strategy for dismantling etc. that the manufacturer submits during the preliminary 
assessment, other design aspects might be addressed that relate to the strategic goals 
of  the  manufacturer.  Stakeholders  explained  for  example  that  this  strategy  refers  to 
recycled content in vehicles.  

• 

7.2.2.4  Requirements  addressing  the  waste  management  of 

vehicles  

The  Directive  addresses  the  waste  management  of  vehicles  through  the  reference  to  the 
ELVD  3R  targets.  The  provisions  of  the  3R  Directive  in  relation  to  reuse,  recycling  and 
recovery are listed in  

•  Art. 5 ‘Type approval provisions’ detailed in 

o  Annex I ‘Requirements’ which the manufacturer shall fulfil,  
o  Annex II ‘Information document for EC vehicle type approval’ which the manufacturer 
shall use to provide information to verify compliance with Annex I requirements,  
o  Annex III ‘Model of EC type approval certificate’ which is given to manufacturers when 

granting the type approval,  

•  Art. 7 ‘Reuse of component parts’, more specifically, Annex V ‘Component parts deemed 

to be non-reusable’.  

Annex I requirements include the 3R targets, the obligation to submit Annex A and Annex B 
documents of ISO 22628:2002, a declaration on dismantlable parts, incl. dismantling stage 
and process recommended for treatment, criteria for the selection of the reference vehicle, 
the obligation to make available vehicles and components to the type approval authority, and 
few others.  

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Under Art. 7, reuse is only ‘negatively’ addressed, i.e., component parts are listed which shall 
not be reused. No positive list of component parts proposed for reuse or any other provision 
supporting the reuse of specific parts exists. 

The  following  references  to  other  legislative  texts,  namely  Directive  70/156/EEC,  ISO 
22628:2002, and ELVD (Directive 2005/64/EC) are made: 

•  MS  shall  ensure  that  manufacturers  provide  the  requested  information  on  reusability, 
recyclability and recoverability pursuant to the general type approval application process 
of Art. 3(1) of Directive 70/156/EEC ‘Application for type approval’. 

•  When granting an EC general type approval based on Art. 4(3) of Directive 70/156/EEC 
‘The type approval process’, the 3R type approval certificate (Annex III of 3R Directive) 
shall be used. 
In the construction of vehicles covered by the general type approval, i.e. scope of Directive 
70/156/EEC, no component parts listed in Annex V shall be used. 

• 

•  Annex A and B of ISO 22628:2002 
•  Part C of Annex II to Directive 70/156/EEC  
•  The EC type approval certificate shall indicate that the (initial grant / extension / refusal of 
a) type approval is provided/refused ‘with regards to Directive 2005/64/EC’ (Annex III of 
3R Directive).  

•  The 3R Directive refers to the ELVD its definitions (Article 4) for end-of-life-vehicle, reuse, 
recycling,  energy  recovery  and  recovery.  Aside  from  the  direct  reference  to  the  ELVD 
substance prohibitions and plastic coding standards, this is the only direct reference to 
the  ELVD  in the  legal text (as  opposed to  in recitals  that show  an  intention  but  do  not 
guarantee its implementation). An indirect link is the repetition of the minimum reusable 
and/or  recyclable  as  well  as  the  recyclable  and/or  recoverable  mass  in  Annex  I  of  3R 
Directive.  However,  this  is  not  directly  linked  to  the  ELVD,  despite  originating  from  its 
provisions.  

7.2.3  The 3R Type-Approval Process 

Based on the amendments to Directive 70/156/EEC, Annex VI of the 3R Directive, general 
type  approvals  include  the  3R  type  approval.  Table  7-3  provides  an  overview  of  3R  type 
approval  specific  process  steps.  For  the  process  of  3R  type  approvals,  it  is  important  to 
differentiate between the preliminary assessment of the manufacturer (step 2 in Table 7-3) 
and  the  process  of  type  approval  as  such  (step  3  in  Table  7-3).  Initially,  Member  States 
appointed a ‘competent body’, criteria for the selection are described in Annex IV point 2 of 
3R Directive. It is expected that this was a one-time decision by MS with the coming into force 
of the national transpositions of the 3R Directive.

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Table 7-3  Type approval provisions and preliminary assessment of the manufacturer 

Step  Description 

1 

2 

MS appoints a „competent body“ 

Preliminary assessment  

Art.  Of 
3R 
Directive 

Related 
Art.  Of 
UN 
ECE 
133 

6(4) 

6.6 

•  Manufacturer recommends a strategy to ensure dismantling & 3R 
•  Ensuring  the  compliance  with  Art,  4(2)(a)  of  ELVD  (haz.  subst. 

6(3) 
6(2) 

6.5 
6.2 

• 

prohibitions) 
If  appropriate,  the  MS  "competent  body"  grants  the  certificate  of 
compliance  (appendix  to  Annex  IV)  which  includes  the  strategy  to 
ensure dismantling and 3R (see step 2), with a validity period of 2 years 
•  Manufacturer shall report any significant changes to the competent body 

6(5) & 6(6) 

6.3,  6.7 
6.8 
& 

6(7) 

6.9 

3 

Type approval  

•  Manufacturer fills in Annex II ("Information Document for EC vehicle type 

5(2) &  

3.1 -3.4 

approval")  

•  MS "competent body" checks against requirements in Annex I, e.g. 3R 

• 

calculations as in ISO 22628:2002, 
If  appropriate,  the  MS  "competent  body"  grants  the  type  approval 
certificate (Annex III) with a validity period of 2 years 

5(3)  
5(1) 

5(4) 

4.1                    

         4.2 

Preliminary Assessment 

The preliminary assessment of the manufacturer is described in Art. 6 of the 3R Directive (or 
Art. 6 of the UN ECE 133 document, see the comparison in the next chapter). In this stage, 
the Member State competent body performs checks to ‘ensure that the manufacturer has put 
in place the necessary arrangements and procedures’, the exact data and information to be 
checked, and how such data shall be prepared by the manufacturer for the purpose of the 
preliminary assessment is detailed in Annex IV of 3R Directive.  Some of the information to 
be checked is referred to in articles specifically, e.g., Art 6(2) refers to hazardous substances, 
other information to be checked is “only” referred to in Annex IV. In addition to the checks, in 
the  preliminary  assessment,  the  manufacturer  presents  a  ‘strategy  to  ensure  dismantling, 
reuse of component parts, recycling and recovery of materials’. In some cases, this strategy 
comprises of a few pages of text (VW/Porsche 2022). An interviewed stakeholder (Stellantis 
2022) reports on ‘the aim – to show how we support the recycling and the process globally – 
how  this  is  linked  with  design  of  the  car’.  The  strategy  was  sent  to  the  consultant  under 
confidentiality. However, an indication of content of the strategy can be provided. The text 
contains a description of how the OEM is managing the material composition data of a car, 
then, the commitment to integrate recycled material and to improve recyclability, in addition, 
that and how the OEM supplies dismantlers with information, and the commitment ‘to look at 
the recycling and its effect at the early stage of design’. It is important to understand that the 
dismantling information provided to dismantlers ‘is a completely different document than the 
strategy prepared to comply with 3R Directive Art 6(3)’. It is provided via IDIS. 

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3R type approvals 

Generally, type approvals are assessed (and granted) for the so-called ‘worst case’, thus, the 
selection of the worst case is not specific to 3R type approvals but is generally applied before 
any  vehicle  type  approvals.  This  is  specified  in  Recital  (58)  of  Regulation  2018/858401. 
However, it is again referred to in Annex I of the 3R Directive where the ‘worst case’ is named 
the ‘reference vehicle’ or ‘most problematic version within a type of vehicle’. Annex I of the 
3R  Directive  adds  criteria  to  the  list  of  selection  criteria  for  the  ‘worst  case’:  the  type  of 
bodywork, the available trim levels, and available optional equipment, e.g. leather upholstery, 
in-car radio equipment, air-conditioning, alloy wheels, etc.  

While OEMs select the worst-case variants / configuration of the vehicle type to be approved 
and compile data to prepare the necessary documentation for the process for the selected 
variant/  configuration  (step  3  in  Table  7-3,  first  bullet),  they  are  often  assisted  with  type 
approval  service  providers  (‘technical  services’).  In  the  case  of  a  certification  to  a  certain 
standard, technical services check the validity of the compiled data. From exchange with type 
approval service providers, it can be understood that in recent years (since 2015) at least one 
service provider also visits ATFs to see how vehicles are dismantled in practice. However, 
this will not necessarily be on vehicles that they type approve, but rather the vehicles being 
dismantled at the time of visit. They will look at: 

•  Disassembly instructions: availability and applicability/feasibility at the AFT, 
•  Principles and feasibility of the vehicle treatment, 
•  Sampling of parts and in terms of their mass (measurement), composition (= consistency 

of ISO 22628 calculation), and consistency with the supplier/OEM definitions 

•  Verification of polymer markings. 

As  part  of  step  3  (Table  7-3),  3R  calculations  as  prescribed  in  ISO  2268:2002  have  to  be 
performed. To conclude whether a material is recyclable, as specified in the ISO, OEMs use 
a  list  of “proven recycling  technologies”.  In  line with  the  ISO,  technologies  that  have  been 
successfully tested on a laboratory scale or above are considered to be “proven”. The list is 
managed by the automotive association. The assessment of recyclability is done on a yes/no 
basis: When a material is considered recyclable (technology readiness level 4 and above), 
its full amount is counted towards recycling. This disregards any material losses related to 
the efficiency of recycling technologies or the level of quality of the resulting recyclates. It is 
expected that 3R Type approval calculated rates will differ from the actual achievable ones. 
This is understandable due to the long lifetime of vehicles, however there is no guarantee 
that a material with a recycling TRL of 4 (laboratory scale) at the time of 3R Type approval 
will  be  recyclable  by  the  time  it  reaches  EoL.  Type  approval  authorities,  asked  about  the 
in  relevant 
appropriate 
environment) and above. 

least  6  (technology  demonstrated 

level,  recommended  at 

The ISO standard refers to additional lists of “proven technologies for fastening” and “proven 
technologies  for  dismantling”.  OEMs  probably  have  an  idea  of  relevant  technologies; 
however,  such  lists  are  not  used  in  the  type  approval  process  to  conclude  on  the 
dismantlability  of  a  part  and  its  potential  for  reuse.  The  reuse  of  parts  is  not  considered 

401 Regulation EU 2018/858, Recital (58): ‘When performing compliance verification testing, technical services should be able 
to choose the parameters of the tests freely and in a non-predictable manner from within the range provided for in the 
relevant regulatory acts. This should help them verify that the vehicles tested are compliant across the whole range of 
parameters, including the parameters that correspond to the worst case for the test’. UN Regulation 
E/ECE/TRANS/505/Rev.3 explains that ‘the approval authority shall apply the principle of "worst-casing", by selecting the 
variant or version from the specified type that for the purpose of testing will represent the type to be approved under the worst 
conditions.’ In the general type approval, the manufacturer shall explain and provide justification for the selection. 

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towards the calculation and in that sense though it can be concluded that the process may 
facilitate recycling and recovery, it is not clear why it is assumed to facilitate reuse. 

One  OEM  that  participated  in  the  interviews  indicated  that  in  2021  they  managed  9  type 
approvals (Stellantis 2022). From other interviews, e.g. VW/Porsche, it is understood that this 
number strongly varies between different years. 

7.2.4  Interrelation of the 3R Directive to the international regulation 
UN ECE Regulation No. 133 and to ISO 22628:2002  

ISO 22628:2002 

The  ISO  22628:2002  is  the  standardized  calculation  method  for  the  recyclability  and 
recoverability of road vehicles. In the introduction, the ISO explains that ‘as part of the road 
vehicle life cycle, it is essential that recovery issues [in other words: end-of-life requirements] 
be taken into consideration during the design phase for environmentally sound treatment to 
be  ensured.  […]  Recyclability/recoverability  rates  depend  on  the  design  and  material 
properties  of  new  vehicles,  and  on  the  consideration  of  proven  technologies  –  those 
technologies which have been successfully tested, at least on a laboratory scale’. The text of 
the standard consists of the definitions, explanations of variables, the calculation method in 
a written and a tabular format (Annex B) and how the data shall be presented (Annex A). In 
the definitions, ISO 22628 refers to ISO 1177 on Road vehicles – Masses – vocabulary and 
codes.  

Besides brand name and model (variant/configuration), basic data to be provided by the OEM 
includes the vehicle mass and a material mass (in kg) composition differentiating between 
seven different material classes: 

•  Metals 
•  Polymers (excl. elastomers) 
•  Elastomers 
•  Glass 
•  Fluids 
•  Modified organic natural materials (MONM) 
•  Others. 

Asked to specify example materials and their relative importance in the vehicle in the class of 
‘others’, Stellantis (2022) answered that they consider mainly electronic components in the 
class  of  ‘others’,  which are  very  small  and  have  complex  compositions and  ceramics;  ‘the 
amount of this category is less than 1% of the car weight.’ VW/Porsche (2022) explained that 
‘in  the  beginning  the  category  was  used for  parts  where  recyclability  potential  was  not  yet 
clear’ 

The calculation is done in five steps402: 

1. 

In the first step of the calculation, the masses of all component parts and all fluids dismantled (e.g., depolluted) 
in the step of the pre-treatment are added. These are listed explicitly and encompass fluids, battery, oil filters, 

402 Component parts and materials can only be counted once under one of the steps 1-4.  

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LPG tanks, CNG tanks, tyres and catalytic converters. According to Art. 5.3.1 of ISO 22628:2002, ‘for the 
purpose of the calculation, these component parts and materials are considered reusable or recyclable’. 

2. 

In the second step, component parts for dismantling ‘as declared by the vehicle manufacturer’ are listed with 
name  and  mass  in  kg.  However,  for  the  component  part  to  be  considered  reusable  or  recyclable,  (a) 
accessibility,  fastening  and  dismantling  technology  shall  be  assessed  in  relation  to  the  dismantlability,  (b) 
safety and environmental hazards shall be assessed in relation to reuse, and (c) material composition and 
proven  recycling  technology  shall  be  assessed  in  relation  to  recyclability.  From  the  sum  of  dismantlable 
components, a total mass of dismantled components is obtained. No material composition must be provided 
for the dismantlable component parts through the data presentation sheet.  

3.  Then,  in  the  third  step,  all  ferrous  and  non-ferrous  metals  which  have  not  already  been  accounted  for  in 

dismantled parts shall be taken into account and summed up – they are considered recyclable.  

4.  For the non-metallic materials, there is a recyclable and recoverable fraction. For the recyclable materials, 
technologies shall be provided by name together with the mass of material recycled from this technology. 
Then, a material is counted as ‘recoverable’ if it ‘can potentially be used for energy recovery’. The ISO contains 
the note that ‘technologies for energy recovery of polymers and elastomers are industrialized on a large scale 
world-wide. Therefore, polymers, elastomers and other MONM can potentially be recovered through those 
technologies’ 

5.  Finally,  the  recyclability  and  recoverability  rates  are  calculated  as  a  mass  fraction  in  percent.  For  the 
recyclability  rate,  pre-treated, dismantled,  metallic  and  recyclable non-metallic masses  are  included in the 
calculation. For the recoverability rate, the mass of the recoverable non-metallic material is included in the 
calculation in addition to the masses included in the calculation of the recyclability rate.  

The data presentation sheet is a one-page tabular document.  

UN ECE No. 133 

The  title  of  UN  ECE  regulation  No.  133  is  “Uniform  provisions  concerning  the  approval  of 
motor vehicles  with  regard to their  reusability, recyclability  and recoverability”.  This  is  very 
similar to the title of the 3R Directive “on the type approval of motor vehicles with regards to 
their reusability, recyclability and recoverability”. It is thus not surprising that the UN ECE 133 
has the same function at the international level as the 3R Directive has in the EU. A vehicle 
type approved on the basis of the UN ECE 133 can be placed on the EU market and does 
not need to go through the 3R Directive type approval process (and vice versa).  

As part of this study, a comparison has been made to see where differences are apparent 
between the two legislations. In 2018, (Mitic & Blagojevic 2018) wrote that “comparing with 
Directive 2005/64/EC, it was noticeable that all requirements were almost the same, and it 
was on the line with EU legislative and UN Regulations harmonization process.” VW /Porsche 
agree (‘there are no relevant differences between the two legislations’). In the stakeholder 
workshop403,  when  asked  about  the  equivalence  of  the  3R  Directive  and  the  UN  ECE 
regulation,  a  few  stakeholders  further  stressed  the  importance  of  the  similarity,  which  can 
help  ‘lean  up  the  necessary  documentation  activities’.  Still,  slight  differences  have  been 
identified in relation to the definitions of the 3R, mainly in relation to ‘recovery’. Definitions of 
the 3R in the various legislative texts are displayed in Table 7-4. ELVD and 3R Directive are 
more detailed in their definition of recovery than in the UN ECE 133 Document and the ISO 
22628.

403 Results of Slido question “For the purpose of obtaining an EU Whole Vehicle Type Approval, a certificate in accordance 
with UN Reg.133 is accepted as alternative to Directive 2005/64/EC. How important is it to keep such equivalence with UN 
ECE legislation and why?” 

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Table 7-4  Definitions in ELVD, 3R Directive, UN ECE 133 and ISO 22628 

ELVD  

3RD 

UNECE 133 

Reuse 

‘reuse’ means any operation by 
which components of end-of life 
vehicles are used for the same 
purpose for which they were 
conceived; 

Means reuse 
as defined in 
point 6 of Art. 
2 of ELVD 

Reuse means any operation by 
which components of end-of-
life vehicles are used for the 
same purpose for which they 
were conceived 

ISO 
22628 

Same as 
in ELVD 
/ UN 
ECE 

Recycling 

‘recycling’ means the repro-
cessing in a production process 
of the waste materials for the 
original purpose or for other 
purposes but excluding energy 
recovery.  

Recovery 

‘recovery’ means any of the 
applicable operations provided 
for in Annex IIB to Directive 
75/442/EEC404; 

Means 
recycling as 
defined in 
point 7 of Art. 
2 of ELVD 

Means the reprocessing in a 
production process of the 
waste materials for the original 
purpose or for other purposes 
but excluding energy recovery 

Same as 
in ELVD 
/ UN 
ECE 

Means 
recovery as 
defined in 
point 8 of Art. 
2 of ELVD 

Means reprocessing in a pro-
duction process of the waste 
materials for the original pur-
pose or for other purpose to-
gether with processing as a 
means of generation energy 

Same as 
in UN 
ECE 

Looking closely on the core of the 3R Directive, Annex I requirements, some minor differences 
can  be  identified,  see  Table  7-5.  This  table  compares  the  UN  ECE  133  and  3R  Directive 
Annex  I  requirements.  In  relation  to  the  Annex  I  requirements,  there  are  differences  in 
requirements  No. 2.2  reference  to  the  proven  technology  list,  No.  4  &  5  on  the  selection 
criteria for the reference/problematic vehicle (‘worst case’), and No. 10 and 11 in relation to 
the manufacturer’s declaration for compliance with hazardous substances prohibitions and 
parts’ coding.  

Table 7-5  Comparison 3R Directive and UN ECE 133 Annex I requirements 

UN ECE 133 

3R Directive 

1. Vehicles belonging to category M1 and those belonging to category N1 shall be so constructed as to be: 

(a) Reusable and/or recyclable to a minimum of 85 per cent by mass, and 

(b) Reusable and/or recoverable to a minimum of 95 per cent by mass, 

as determined by the procedures laid down in this annex. 

2. For the purposes of type approval, the manufacturer shall submit a data presentation form duly completed, 
established in accordance with Annex A to ISO standard 22628: 2002. It shall include the materials breakdown. 

2.1. It shall be accompanied by a listing of the dismantled component parts, declared by the manufacturer with 
respect to the dismantling stage and the process he recommends for their treatment. 

404 Previous version of the Waste Framework Directive, today, Directive 2008/98/EC 

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UN ECE 133 

3R Directive 

2.2.  The  process  shall  be  based  on  a  technology 
which  has  been  successfully  tested,  at  least  on  a 
laboratory scale (proven technology). 

X 

3.  For  the  application  of  paragraphs  1.  and  2.  of  this  annex,  the  manufacturer  shall  demonstrate  to  the 
satisfaction of the Type approval authority that the reference vehicles meet the requirements. The calculation 
method prescribed in Annex B to ISO standard 22628: 2002 shall apply. 

3.1. However, the manufacturer shall be in a position to demonstrate that any version within the vehicle type 
complies with the requirements of this Regulation 

4. For the purposes of the selection of the reference 
vehicles, a vehicle shall be selected with the following 
criteria: 

4.  For  the  purposes  of  the  selection  of  the  reference 
vehicles,  account  shall  be  taken  of  the  following 
criteria: 

(a) Lightest engine; 

— the type of bodywork, 

(b) Lightest manual gearbox; 

— the available trim levelsa, 

(c) Smallest tyres, no spare wheel; 

— the available optional equipment which can be fitted 
under the manufacturer's responsibilitya. 

(d) No trailer coupling; 

(e) No all-wheel drive; 

. 

(f) Bodywork saloon or station wagon; 

(g) (Leather trim). 

5. The manufacturer and the Type approval authority 
jointly  identify  the  reference  vehicle  in  accordance 
with the criteria listed under paragraph 4. above. 

5.  Should  the  type  approval  authority  and  the  manu-
facturer  fail  jointly  to  identify  the  most  problematic 
version within a type of vehicle, in terms of reusability, 
recyclability  and  recoverability,  one  reference  vehicle 
shall be selected, within:  

(a) each ‘type of bodywork’, as defined in point 1 of part 
C  of  Annex II  to  Directive  70/156/EEC  in  the  case  of 
M1 vehicles; 

(b) each ‘type of bodywork’, i.e. van, chassis-cab, pick-
up, etc., in the case of N1 vehicles 

6. For the purposes of calculations, tyres shall be considered as recyclable. 

7. Masses shall be expressed in kg with one decimal place. The rates shall be calculated in percent with one 
decimal place, then rounded as follows: 

(a) If the figure following the decimal point is between 0 and 4, the total is rounded down; 

(b) If the figure following the decimal point is between 5 and 9, the total is rounded up. 

8.  For  the  purposes of checking  the calculations  referred  to  in  this  annex,  the  type  approval  authority  shall 
ensure  that  the  data  presentation  form  referred  to  in  paragraph  2.  of  this  annex  is  coherent  with  the 
recommended  strategy  annexed  to  the  Certificate  of  Compliance  referred  to  in  paragraph  6.3.  of  this 
Regulation. 

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UN ECE 133 

3R Directive 

9. For the purposes of checks of the materials and masses of component parts, the manufacturer shall make 
available vehicles and component parts as deemed necessary by the type approval authority. 

10. For the purpose of identification of components in 
the recycling process, the manufacturer declares that 
processes  to  comply  with  the  labelling  of  plastic 
components  in  accordance  with  paragraph  3.3.  of 
Annex 5 to this Regulation, and the labelling of rubber 
components  in  accordance  with  paragraph  3.4.  of 
Annex 5 to this Regulation, apply to this vehicle type.  

11. For the purposes of informing about materials and 
substances  used  in  the  vehicle  construction  the 
manufacturer declares that processes to comply with 
the materials and substances restrictions apply to this 
vehicle type. 

x 

x 

a- 

i.e. leather upholstery, in-car radio equipment, air-conditioning, alloy wheels, etc. 

Source: Own compilation, Oeko-Institut e.V. 2022 

In addition, and in contrast to the process under 3R Directive, the process as laid out in the 
UN  ECE  133  includes  provisions  on  marking,  i.e.  the  competent  authority  provides  a 
communication form (UN ECE 133 Annex III) and a marking (according to UN ECE 133 Annex 
IV). This should not be confused with the plastic coding laid down in Commission Decision 
2003/138/EC. Instead, this marking refers to the country where the type approval has been 
granted. 

7.3  Summary  of  the  main  results  of  the  consultation  of 
stakeholders on the 3R Type approval and its relation to 
the ELVD 

In  total,  four  3R Directive-specific  interviews  were  conducted.  Answers  of  two  of  these 
interviews  cannot  be  cited  from  freely,  however  have  been  anonymized.  Additional 
information was received from three more organisations/stakeholder groups (see table Table 
8-4; one position paper, one interview in the main study was used to get specific information 
on  the  3R  Directive  (i.e.,  with  UNEP  and  UN  ECE  representatives),  and  one  e-mail  with 
additional explanatory information was received, in relation to the information provided in one 
of the specific interviews by a technical service provider). In the survey, five Member States 
participated (1 MS was interviewed, 3 provided the filled-out survey, 1 provided short input 
per email), and one OEM sent a confidential contribution. In the round of written feedback in 
April 2022 (after the stakeholder and MS workshop in March 2022) a further written contribu-
tion from Germany was received. For the survey and interviews the same questionnaire was 
used. The questionnaire was agreed on and is available to the European Commission. Based 
on the indication of a lot of stakeholders, most of the information cannot be cited in this report 
as information has been provided on a confidential basis or interview documentations have 
not been confirmed by interviewees. In such cases, aggregation or anonymization has been 
used where possible to allow consideration of the various inputs given. 

General comments in relation to the link and the possibility of merging of the two directives 
are described in the following:  

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In the course of the evaluation, the question was looked at – and stakeholder positions are 
mentioned, where applicable – from the perspectives of the main aspects of evaluation:  

•  Of  the  interviewed  stakeholders,  one  is  of  the  opinion  that  there  is  a  missing  link  and 

missing references between 3R Directive and ELVD.  

•  No stakeholder clearly indicated its preference to merge the 3R Directive and ELVD or 
that it would be meaningful. At least, two times China was provided as an example where 
one legal instrument is in place, however, the European market would be more diverse. 
Looking at the stakeholder groups that provided their input on this topic, it should be noted 
that the stakeholders rarely take the perspective of the end-of-life.  
In the inputs, the 3R Directive is not looked at in the same way as the regulator might 
have looked at it (i.e., as understood to be initially intended in ELVD Article 7(4 &5)), i.e., 
following  the  idea  to  use  the  type  approval  to  ensure  compliance  with  vehicle  design 
requirements  specified  in  ELVD.  Thus,  it  is  questionable  whether  the  interviewed 
stakeholders see the link between the two Directives as described in the section on the 
origin of the 3R Directive (see section 7.2.1).  

• 

•  For  Germany,  ‘it  is  important  that  existing  requirements  of  the  ELV  Directive  on  waste 
recovery  and  recycling  are  supplemented  by  corresponding  requirements  on  design  in 
the “3R type approval” Directive.’ (BMUV 2022) 

•  An ACEA position paper (ACEA 2022) (2022) refers to the positions of the automotive 
industry in relation to the merge of 3R Directive and ELVD: ACEA “call[s] for the current 
legal framework to be maintained.” Rather than focusing on recyclability, they would like 
to  see  their  engagement  in  the  field  of  emission  reductions  during  the  use  phase,  i.e., 
strategies focusing on light weight, acknowledged framing it Design for Sustainability.405  
•  Another argument put forward (anonymous stakeholder contribution) is that, currently, the 
responsibilities are distributed, i.e., recyclers fulfil the ELVD and manufacturers fulfil 3R 
Directive  requirements.  A  merge  of  the  Directives  producing  a  legislation  with  joint 
responsibilities could increase innovation times and create longer discussion processes.  
•  Stakeholders  are  of  different  opinion  in  relation  to  whether  the  3R  Directive  facilitates 

“high-quality” recycling.  

Other than this, questions were asked to understand better the role of type approval technical 
services’, the Type approval Authorities’ and the OEMs’ in the process of type approvals in 
general as well as the special part of the 3R type approval in particular. Where applicable, 
opinions of stakeholders are referenced in the section on the process and its implementation 
(section 7.2.3).  

A third cluster of question was asked regarding the possible future amendments of the ELVD:  

A number of aspects under discussion to enhance circularity of new vehicles discussed in the 
course of the ELVD revision were presented to stakeholders in the stakeholder consultation 
activities for this study. These include:  

•  Design requirements that affect repairability, repairability / durability, referring to recycled 
content or the use of certain materials, or possible restrictions or prohibition of materials 
which have a potential to render recycling particularly challenging. 

•  Amendment of the methodology of calculation of the potential for e.g. reuse, recycling, 
and recovery, e.g. to be aligned to a minimum Technology Readiness Level (TLR),  

405 ACEA „want to point out that necessary new and innovative materials for achieving the ambitious goals for targeted carbon 
neutrality in 2050 for vehicles might not have appropriate recycling technologies on industrial scale available yet.” 

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•  Obligations for OEMs and suppliers to support reuse of parts and components and high-
quality  recycling  and  to  identify  hazardous  components  or  materials  to  be  dismantled 
through making available more information, e.g. make digital keys digitally available in a 
non-discriminating  and  harmonised  manner  to  professional  operators  (e.g.  Authorized 
Treatment Facilities (ATFs) and free garages),  

•  Consideration of economic viability of (deep) dismantling, sorting (including shredding and 
post-shredding)  and  (high-quality)  recycling  via  a  link  to  the  enhanced  producer 
responsibility (EPR), e.g. through requirements to conduct dismantling tests with the aim 
to determine the duration of dismantling and the tools needed to dismantle certain parts 
of a vehicle at end-of-life 

•  Possible extension of the 3R type approval process to other vehicle types (e.g. trucks, 

busses, motorcycles). 

In general, little to no input was provided on impacts of introducing certain measures proposed 
to be changed in the 3R Directive.  

One stakeholder (anonymous stakeholder contribution) is of the opinion, that the scope of the 
3R Directive should be extended to include additional vehicles.  

Finally, in the stakeholder workshop, additional questions were asked through the use of an 
interactive application (slido):  

The following reproduces the main inputs provided through this format: 

•  Question:  ‘Since  its  adoption  in  2005,  do  the  economic  and  environmental  benefits 
achieved by the 3R Directive in your view outweigh the cost of its implementation?’ Of a 
total of 31 stakeholders who answered, 20 did not provide an answer, however of those 
that did, the majority (5 stakeholders) considered that benefits are high or that costs are 
low (3 stakeholders) or both (1 stakeholder). Only 2 stakeholders stated that benefits are 
too low and costs too high and 1 stakeholder that benefits are too low. 

•  Question: ‘How high do you estimate the added value of having EU harmonised rules for 
vehicle  reusability,  recyclability,  and recoverability, compared to  what  could  have  been 
achieved  at  merely  national  level?  In  the  chat,  please  explain  and  provide  supporting 
data.’ From 34 stakeholders that answered, 30 agreed that the harmonized rules have a 
higher or somewhat higher added value then the case of national legislation. Others did 
not know. 

•  Question: ‘In your view, does it make sense to move away from a type approval Directive 
on  vehicle  reusability,  recyclability  &  recoverability  to  a  type  approval  Regulation  on 
vehicle reusability, recyclability & recoverability? Please provide supporting data.’ Of 35 
stakeholders that answered, 21 state that it made sense to move to a regulation, while 1 
did not agree and the others did not know. 

•  Question: ‘Please indicate whether to consider inclusion of the following vehicles for RRR 
type-approval,  as  currently  these  are  exempt  (article  3).’  Of  33  stakeholders  that 
answered,  11  indicated  special  purpose  vehicles,  12  indicated  multi-stage  vehicles,  8 
referred to small series vehicles and 9 stated that the exemptions should not change. The 
rest dd not know. 

•  Question: ‘One of the objectives of the 3R Directive is to prevent safety and environmental 
hazards through restrictions on re-use of certain component parts (e.g., airbags, seat belt 
assemblies).  Has  this  objective  been  achieved  in  your  view?’  Of  34  stakeholders  that 
answered, 9 agreed that this objective was met, 5 did not agree and the rest did not know. 
•  Question: ‘Is it correct to assume that including multi-stage built vehicles in the scope of 
the 3R Type Approval would allow ensuring that they can achieve the 3R Targets, having 
a positive impact on the design and circularity of such vehicles?’ Of 31 stakeholders that 
answered, 13 agreed and 3 did not. The rest did not know. 

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•  Question: ‘Could data that needs to be accessible to ATFs be included in the Certificate 
of Conformity?’ Of 16 stakeholders that answered, 5 agreed and 4 did not. The rest did 
not know. 

7.4  Evaluation results of the effectiveness of the 3R Directive 

and its relation to the ELVD 

This  chapter  is  the  core  of  the  evaluation  report  as  it  provides  answers  to  each  of  the 
evaluation questions. For most of the evaluation questions, the analysis has been grouped. 
Each individual question is specifically addressed in the conclusion section of each group of 
questions. The question groups are as presented above. 

For  each  group  of  questions,  we  present  our  analysis  drawing  on  the  research  methods 
applied  such  as  literature  and  data  review,  Online  Public  Consultation  (OPC),  targeted 
surveys and targeted consultation in the form of interviews and the workshop.  

The evaluation is performed for three different possible cases: First (comprising the core part 
of the evaluation) the case of how the current version of the 3R Directive performs in relation 
to  the  questions;  secondly,  questions  are  assessed  for  the  case  in  which  the  ELVD  is 
amended but not the 3R Directive, in order to show the implications of this case; and finally 
(but not relevant for all questions) the case where ELVD and 3R Directive could be merged 
is referred to. 

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Sidenote on the merge of the two Directives 

To  address  some  of  the  concerns  raised  by  stakeholders,  the  consultants  would  first  like  to  address  some 
aspects of the possible merging of the two directives. It should be noted that the merging – if decided by the 
legislator– shall be independent of the vehicle type, resulting in one legislation that covers all types of vehicles 
which were decided to be in scope of that legislation. In the view of the consultants, merging the directives is a 
matter  of  legal  decision  that  is  independent  of  the  decision  of  the  extension  of  scope  of  the  ELVD  and 
independent of whether the requirements set out in the 3R Directive shall apply to new vehicle types or not. 
Should the legislator decide for the option to continue with two separate directives and provided that 3R type 
approval requirements shall apply to vehicles other than M1 and N1, the scope of both directives would need 
to be extended. On the other hand, if the decision is taken to extend the scope of the ELV legislation to more 
vehicle types than M1 and N1, and if also the idea is followed to merge the directive, but if it is decided to not 
set 3R type approval requirements for all vehicle categories, it will be possible to express this decision in legal 
terms, e.g. through exempting some vehicles from certain articles of the legislation. 

7.4.1  The origin and objective of the 3R Directive  

7.4.1.1  Analysis 

The adoption of the 3R Directive was the result of the ELVD provision specified in Art. 7(4) 
‘that  the  European  Parliament  and  the  Council,  on  the  basis  of  a  proposal  from  the 
Commission, shall amend Directive 70/156/EEC [general type approval] so that vehicles type-
approved in accordance with that Directive and put on the market after three years after the 
amendment of the Directive 70/156/EEC are re-usable and/or recyclable to a minimum of 85 
% by weight per vehicle and are re-usable and/or recoverable to a minimum of 95 % by weight 
per vehicle’. It is assumed that the intention of regulators embodied in ELVD Art. 7(4) was to 
use the type approval process to ensure that vehicles placed on the market comply with the 
ELVD Art. 7 3R targets. Targets gradually increased from the time when the ELVD came into 
force, i.e., the values of 85% and 95% weren’t the initial targets, see ELVD Art. 7(2). Thus, 
further it can be assumed that the regulator had in mind to use the targets as a means to 
tighten the regulation of vehicles in relation to reuse, recycling and recovery. 

In the text of the 3R Directive, the importance of the 3R targets can be identified by the fact 
that they are named in Recital 1, in Art. 1 and that the targets are the first of the Annex-I-
provisions.  However,  except  for  the  Recital,  the  values  of  the  targets  are  written  down 
explicitly,  i.e.,  without  reference  to  the  ELVD.  There  is  no  ‘dynamic  link’.  For  the  current 
versions of the legislative texts, the values of the targets, i.e., 85% (reuse and/or recycling 
target) and 95% (reuse and/or recovery target), are identical in both the (current) ELVD and 
the 3R Directive. Thus, in relation to the targets, currently, no discrepancy between the two 
Directives exists, but the situation may change with amendments of the ELVD, should the 3R 
Directive not be amended accordingly. 

Following the assumed intention of the regulators formulated above, an amendment of the 
3R targets in the ELVD inevitably requires an amendment of the 3R Directive to be able to 
ensure the compliance of new vehicles put on the market with amended ELVD requirements. 
It  may  even  be  assumed  that  any  new  provisions  targeting  reusability  and/or  recyclability 
and/or recoverability, i.e., future amendments in the ELVD other than an amendment of the 
3R targets, would require the subsequent amendment of the 3R Directive as well.  

ELVD Art. 7(4) refers to 3R targets as the only provision for which the type approval shall be 
used  to  ensure  the  compliance.  In  addition,  Art.  7(5)  of  ELVD  states  that  amendment  of 
Directive 70/156/EEC should also take consideration that the reuse of components does not 
give rise to safety or environmental hazards. Though this is not considered by the consultant 
to refer to specific provisions of the ELVD, it is reflected in the 3R Directive in its Article 7 that 
refers to the list of ‘Component parts deemed to be non-reusable’ specified in its annex V that 
cannot  count  toward  recyclability  and  recoverability  rates  and  that  cannot  be  used  in  the 

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construction  of  vehicles  covered  by  type  approval  legislation.  Though  the  ELVD  prohibits 
hazardous substances (ELVD Article 4(2)) and requires the vehicle producers use component 
and material coding standards (ELVD Article 8), it does not refer to these provisions in article 
7(4 & 5) which addresses the amendment of Directive 70/156/EEC. Thus, references in the 
3R Directive to provisions on hazardous substance and plastic coding are considered as two 
examples where the 3R Directive goes beyond the objective formulated in ELVD Art. 7(4). 
The fact that additional provisions of the ELVD are being ‘checked’ through the type approval 
processes supports the assumption that the process of type approval was intended to and is 
suitable to check compliance with design requirements specified in ELVD. 

7.4.1.2  Conclusion 

Does the 3R Directive effectively transpose the intention of regulators in relation to Art. 7(4) 
of ELVD?  

Currently, due to the fact that the ambition level of the 3R targets is identical in the ELVD and 
the 3R Directive, it is concluded that the 3R Directive is effectively transposing the regulation 
intention  of  Art.  7(4)  of the  ELVD.  Nonetheless, in  case  of  an  amendment  of the  ELVD  in 
relation to the targets or other measures to support reuse and recycling, due to the lack of a 
dynamic reference to the ELVD, the intention of the regulators to use the type approval to 
ensure compliance with vehicle design requirements specified in ELVD would no longer be 
guaranteed without amending the 3R Directive.  

Though not part of the ELVD intention for the 3R directive, the same is also true for the ELVD 
material coding standards, where the 3R Directive only makes the reference to Commission 
Decision 2003/138/EC and not to any further coding standards, should these be introduced 
through other legal documents adopted according to ELVD Article 8.  

In  the  case  of  a  merge  of  ELVD  and  3R  Directive,  and  assuming  that  the  regulator 
continuously intends to use the process of type approval to ensure compliance with ELVD 
vehicle design requirements to support circularity, the future regulation will require (dynamic) 
references to the general type approval legislation. 

For  the  hazardous  substance  prohibitions,  also  not  part  of  the  ELVD  intention  for  the  3R 
directive, the case if different. Here, there is a dynamic reference to ELV Article 4(2)(a), which 
ensures  compliance  with  any  changes  in  the  substances  prohibited  through  this  article  or 
changes to the list of exemptions from these prohibitions listed in Annex II of the ELV. 

7.4.2  The scope of the 3R Directive 

The questions addressed in this section are: 

• 

• 

Is  the  scope  of  the  3R  Directive  effective  in  ensuring  that  its  provisions  will  be 
implemented successfully in relation to the vehicles to which it applies? 
Is the scope of the 3R Directive aligned with the ELVD at present or in the case that 
the scope of the ELVD is to be changed in the future? 

7.4.2.1  Analysis 

Currently, the scopes of ELVD and 3R Directive are similar but not identical, see section 2.4.2 
(main report) and section 7.2.2.2 (this report). Exemptions from the Directive vary among the 

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two  legislations.  Both  include  passenger  cars  classified  as  M1406  and  light-commercial 
vehicles classified as N1407 (< 3.5 tonnes) in the scope. The ELVD includes three-wheel motor 
vehicles but excludes motor tricycles, both defined in the type-approval of two- or three-wheel 
vehicles  and  quadricycles408.  The  3R  Directive  does  not  refer  to  the  three-wheel  motor 
vehicles but includes new and reused components of M1 and N1 vehicles. In terms of the 
exemptions,  small  series  and  multi-stage  built  vehicles  are  generally  exempt  from  3R 
Directive but not mentioned in ELVD. Special purpose vehicles are generally exempt from the 
3R Directive too, however, they are in scope of ELVD409 but exempt from Art. 7 provisions of 
ELVD. A tabular overview is provided in Table 7-6.  

The  fact  that  the  multi-stage  built  vehicles  and  small  series  are  not  specifically  mentioned 
under ELVD effectively means that the ELVD requirements, including the Art. 7 (3R targets), 
apply for multi-stage built vehicles and vehicles produced in small series, if M1 and N1 type-
approved.  An  example  for  multi-stage  built  M1  and  N1  vehicles  are  VW  camper-vans  (or 
comparable  vehicles)  manufactured  by  an  OEM,  Volkswagen  in  this  case,  but  where 
additional  exterior  or  interior constructions  for  camping  or  when  used  by  professionals  are 
done by a third party (e.g., Westphalia Mobil or Malibu Carthago410). For example, a munici-
pality or an energy/water provider could have such vehicles equipped for certain assignments. 
As long as the general vehicle form is that of M1 and N1 vehicles, such vehicles fall under 
the ELVD. On the one hand, these vehicles might be produced in small series, but in that 
case, there is no exemptions for them in the ELVD, thus, they need to comply with ELVD. On 
the  other  hand,  these  vehicles  might  comply  with  the  criteria  for  special-purpose  vehicles 
specified in the general type approval (Regulation 2018/858, Annex I Part A). If so, they are 
exempted from Article 7 provisions of ELVD (but not generally). To conclude, if multi-stage 
built M1 or N1 vehicles (whether produced in a small series or not) do not fulfil the criteria for 
special purpose vehicles, it is assumed that the compliance with the 3R targets, hazardous 
substance provisions etc. is not ensured. There is no statistical evaluation performed at EU 
level as to the extent of the problem, nor at MS level as the data is most likely not collected.  

Table 7-6  Comparison of the scopes of ELVD and 3R Directive  

Vehicles  

3R Directive  

ELVD  

Passenger cars (M1) 

Included 

Included 

Light commercial vehicles (N1) 

Included 

Included 

406 Category M1: Motor vehicles designed and constructed primarily for the carriage of persons and their luggage and 
comprising not more than eight seating positions in addition to the driver’s seating position. Vehicles belonging to category M 
1 shall have no space for standing passengers. The number of seating positions may be restricted to one (i.e. the driver’s 
seating position). See Regulation (EU) 2018/858. 

407 Category N1: Motor vehicles designed and constructed primarily for the carriage of goods and having a maximum mass not 
exceeding 3,5 tonnes. See Regulation (EU) 2018/858. 

408 Council Directive 92/61/EEC of 30 June 1992 relating to the type-approval of two or three-wheel motor vehicles (repealed 
by Directive 2002/24/EC, again repealed by Regulation (EU) No 168/2013 of the European Parliament and of the Council of 
15 January 2013 on the approval and market surveillance of two- or three-wheel vehicles and quadricycles) 

409 In its frequently asked questions chapter, the ELV Guidance Document (EU, 2005) clarifies that motor caravans are in 
scope. This is explained based on Directive 70/156/EEC which defines motor caravans as a special purpose M category 
vehicle. 

410 See for example: https://www.westfalia-mobil.com/en/, https://www.malibu-carthago.com/en/  

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Vehicles  

3R Directive  

ELVD  

Three-wheel motor vehicles as defined in Directive 
92/61/EEC411 

Not mentioned 

Included 

New and reused components of M1 and N1 vehicles 

Included 

Not mentioned 

Small series (includes heritage cars) 

Special-purpose vehicles (includes motorcaravans, 
armoured  vehicles,  ambulances,  hearses,  trailer 
caravans, mobile cranes and others) 

Generally 
exempted 

Generally 
exempted 

Not mentioned 

Art. 3(4) of the ELV Directive 
special-purpose 
exempts 
vehicles  from  the  provisions 
of Art. 7 ‘Reuse and recovery’ 
of the ELVD 

Multi-stage build vehicles 

Generally 
exempted 

Not mentioned  

M2-, M3-, N2-, N3-, and O-type-approved vehicles 

Not included 

Not included 

Source: ELVD and 3R Directive 

Against the background that for the revision of ELVD it is under consideration to amend the 
scope of ELVD, it should be noted that the articles specifying the scope and exemptions of 
the  3R  Directive  make  no  reference  to  the  ELVD  and  its  scope  (and  vice  versa,  which  is 
logical as the 3R Directive came into force after the ELVD, which has not been revised since 
it  came  into  force  in  2000).  However,  amendments  to  the  scope  of  ELVD  without  parallel 
amendments  in  the  scope  of  the  3R  Directive  could  create  regulatory  inefficiencies  for 
vehicles that newly enter the scope of ELVD and for which 3R targets, design requirements 
and other provisions checked through the 3R type approval apply. Though in hypothetically 
such requirements would need to be complied with, there is currently no other compliance 
mechanism  in  the  ELVD  applying  to  new  vehicles  put  on  the  market,  possibly  creating  a 
loophole or resulting in MS applying different efforts and methods to ensure compliance.  

In  the  case  of  a  merge  of  the  ELVD  and  3R  Directive,  it  is  assumed  that  the  combined 
legislation  would  generally  have  an  identical  scope  for  provisions,  incl.  3R  type  approval 
provisions. The various provisions to be included could also apply only to parts of the general 
scope, i.e., some vehicle categories of the future legislation, or exempt certain vehicles from 
certain provisions. However, this would then be the result of a conscious decision and not of 
legislation incoherencies. In such a case it is thus not expected that a merge would create 
extra inefficiencies, per se.  

7.4.2.2  Conclusions  

Is the scope of the 3R Directive effective in ensuring that its provisions will be implemented 
in relation to the vehicles to which it applies? 

As such, the 3R Directive is a stand-alone legislation because of the lack of a (dynamic) link 
to the articles specifying the scope of the ELVD. Looking at the 3R Directive as such, it is a 
legislation with a comprehensive scope, i.e., it is clearly defined what is in scope and what is 
exempt, and expressions used in the legislation are defined in relation to the general type 
approval  legislation  (in  its  version  of  1970).  The  scope  of  3R  Directive  covers  M1  and  N1 

411 See footnote 408 

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vehicles,  that  is  the  majority  of  road  vehicles  by  unit  (see  main  report).  Thus,  from  this 
perspective the scope of the 3R Directive is currently assumed to be effective.  

Is the scope of the 3R Directive aligned with the ELVD at present or in the case that the scope 
of the ELVD is to be changed in the future? 

The  scope  of  the  3R  Directive  is  not  aligned,  nor  dynamically  linked  (no  reference  to 
respective articles of ELVD) to the scope of the ELVD. Currently, the lack of alignment is in 
relation to M1 and N1 multi-stage built vehicles and vehicles produced in small series (if not 
special-purpose vehicles). ELVD requirements apply to these vehicles, but compliance is not 
checked  during  type  approval  processes  (because  of  an  exclusion  from  scope  of  the  3R 
Directive). Thus, it is concluded that the scope of the 3R Directive is not effective in ensuring 
that vehicles put on the market comply with design requirements formulated in ELVD, i.e. not 
effective in transposing the assumed regulators’ intention described above. 

In the case that the scope of the ELVD is to be changed in the future, without parallel amend-
ments  of  the  3R  Directive,  the  scopes  would  still  not  be  aligned,  however  the  range  of 
discrepancies would increase. To give an example, N2 and N3 vehicles are multi-stage built 
for  the  majority  of  vehicles.  If  they  should  enter  the  scope  of  ELVD,  assuming  that  the 
regulator would decide to further use the process of type approval for ensuring compliance, 
but the 3R Directive scope is not to be amended, their compliance would not be ensured. If 
multi-stage built vehicles continue to be excluded from the 3R Directive, for a considerable 
number  of  vehicles  the  compliance  with  certain  ELVD  requirements  will  not  be  ensured  – 
neither for the base vehicle, nor for the later assembled multi-stage components. Thus, it is 
recommended to have a dynamic link or cross-reference from the 3R Directive to the ELVD 
in relation to scope, ensuring amendments and alignment in case of change.  

In case of a merge of the directives, obviously, the legislation will have one scope only, it is 
recommended to regulate exemptions in relation to a single or multiple provisions, also with 
the obligation to perform 3R type approvals, rather than putting exemptions generally upfront 
(as currently applied in Art. 3 of 3R Directive). An example for the proposed way of regulation 
is the Art. 3(4) of the ELVD which exempts special-purpose vehicles from the provisions of 
Art. 7 (of ELVD).  

7.4.3  ELVD design requirements 

The questions addressed in this section are: 

• 

Is the way that the 3R Directive refers to the ELVD hazardous substance and plastic 
coding provisions effective in terms of ensuring that vehicles put on the market comply 
with the related ELVD requirements? 

•  Will the way that the 3R Directive addresses substance prohibitions and plastic coding 
remain effective in case such provisions (or their exemptions, if applicable) will change 
in the future? 

•  Will the way that the 3R Directive addresses substance prohibitions remain effective in 
case such prohibitions (and/or their exemptions) are moved to another legislation (e.g., 
REACH? 
Is  the  3R  Directive  effective  in  ensuring  that  vehicles  put  on  the  market  are  more 
circular? 
Is the 3R Directive suitable for ensuring in the future that vehicles put on the market will 
comply with future ELVD provisions on circularity (e.g., recycled content targets)? 

• 

• 

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7.4.3.1  Analysis 

As  mentioned  above,  the  main  design  requirements  in  addition  to  material  and  fastening 
technologies affecting the 3R are the hazardous substance restrictions, the plastic coding and 
where the text of the 3R Directive touches on a few smaller aspects, e.g., the trim level being 
a criterion for the selection of the reference vehicle.  

Hazardous substance and plastic coding provisions are specifically part of the checks to be 
performed  by  the competent  body  (3R  Directive, Annex  IV).  The  legal  text  states that  ‘the 
competent body shall ensure that the manufacturer has taken the necessary measures’ and 
that ‘the vehicle manufacturer shall be required to demonstrate’ that compliance is ensured. 
There  are  additional  explanations  as  to  what  is  accepted  as  a  necessary  measure,  e.g., 
supply chain management and communication with the manufacturer’s staff. It is expected 
that where the competent body is checking these requirements, they will find the requested 
information, as the legal text appears clear for this aspect. In both cases, that is point 3.1(f) 
of Annex IV for the coding and Article 6(2) of the 3R Directive and subsequently article 4.1 
and 4.2 of Annex IV for the hazardous substances, there is a reference made to the ELVD. It 
should be understood that these requirements being checked in the preliminary assessment 
means  that  they  are  not  checked  per  type  to  be  approved.  The  3R  Directive,  Annex  II 
(‘Information  Document  for  EC  vehicle  type  approval’)  does  not  contain  an  information 
request on hazardous substances and/or material coding. As a consequence, documents and 
data as to how the manufacturer organizes the information flows on hazardous substances 
and plastic coding in his value chain is being checked every ~ two years with the update of 
the preliminary assessment. But, for the types approved, there is no indication whether they 
contain  hazardous  substances,  e.g.,  where  ELVD  annex  II  exemptions  cover  the  use  of  a 
prohibited substance in a material and/or component part. On the other hand, the masses 
obtained in the steps of the ISO 22628 calculation, i.e., recyclability and recoverability are 
indicated for each new type to be approved. Even if this anticipates the question of alignment 
with UN ECE, looking at the UN ECE 133 Annex I requirements (Table 7-5) there are two 
additional points (point 10 and 11) that requests the manufacturer to declare that ‘processes 
comply with the labelling of plastic components […] and the labelling of rubber components’ 
as well as that ‘processes comply with the materials and substances restrictions’ applying to 
this vehicle type.  

To conclude on this aspect, it is assumed that the 3R Directive is effective in terms of ensuring 
that supply chain communication and management on hazardous substances and measures 
of plastic to be coded are being checked. It is assumed that these measures indirectly (but 
not  explicitly)  ensure  that  vehicles  put  on  the  market  comply  with  the  related  ELVD 
requirements. Though this topic was not raised as a problem for the implementation of the 
3R Directive, the question remains whether the checks in the preliminary assessment suit the 
intention (of ELVD and the role of 3R Directive), and whether it is intended to check design 
requirements in different steps of the process, i.e., hazardous substances and plastic coding 
in the preliminary assessment but not per vehicle type, and recyclability per vehicle type.  

In  addition  to  the  assessment  of  the  current  status  of  effectiveness  in  relation  to  design 
requirements, the questions of the evaluation refer to the future possible requirements and 
the  future  legislation  to  cover  the  hazardous  substance  requirements.  For  the  moment, 
coherence in relation to the substance prohibitions is ensured whenever the legal text of 3R 
Directive makes a reference to ELVD Art. 4(2) for the hazardous substances. In this case the 
3R Directive will remain effective. For the plastic coding, there is no reference to ELVD Art. 
8(1) but only to Commission Decision 2003/138/EC. Only the compliance with requirements 
amended  in  this  Commission  decision  would  be  ensured  at  present,  and  only  in  this  case 
would the 3R Directive remain effective in this case. However, compliance with any changes 

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to ELVD Article 8(1) or new coding standards introduced through other legislation adopted in 
line with ELVD Article 8 would not be ensured.  

In the case of merging ELVD and 3R Directive and should hazardous substance provisions 
of  the  ELVD  be  moved  to  another  legislation,  e.g.  REACH,  it  might  be  relevant  that  the 
(dynamic) reference to the legislation where hazardous substance provisions will be regulated 
in the future is amended to ensure compliance is checked through the 3R approval process. 
Alternatively, any legislation addressing prohibitions for vehicles in the future would need to 
address how compliance is to be ensured or how the future 3R type approval process works 
in relation to hazardous substance provisions. 

A second part of this analysis shall focus on whether the 3R Directive is effectively ensuring 
that vehicles POM are more circular and will comply with future ELVD provisions on circularity. 
One  instrument  to  ensure  circularity  of  vehicles  is  the  ‘strategy  for  dismantling,  reuse  of 
component parts, recycling and recovery of materials’. Generally, the manufacturer submits 
the strategy for dismantling etc. during the preliminary assessment. Though, the ‘strategies 
of the OEMs are approved by type approval authorities’ (VW/Porsche 2022), in practice this 
strategy does not go beyond commitments to certain strategic goals of the company and is 
not specific to the vehicles to be type-approved. It can be assumed that this is because there 
are no explicit requirements as to the content of the strategy, except for that it ‘shall take into 
account the proven technologies available or in development at the time of the application for 
a vehicle type approval’. The purpose of the dismantling strategy whether its implementation 
suits this 3R Directive goals can be questioned. Another means, for reuse specifically, is the 
Article 7 on reuse of component parts. However, this is only referring to what should not be 
reused (due to safety reasons), but not the other way around, i.e., the reuse of which parts 
should be encouraged, e.g. through provision of data as to dismantling method. Measures to 
increase  reuse  are  discussed  in  the  main  ELV  IA  report  (chapter  2.1.5.32.1.5.2).  Another 
instrument is of course the 3R targets, that will be analysed specifically in the next chapter. It 
can  be  said  at  this  point,  that  the  calculation  for  the  3R  targets  specifically  focuses  on 
recyclability and recoverability. To conclude on the evaluation question, it should clearly be 
mentioned  that  different  levels  of  the  waste  hierarchy  are  being  addressed  in  a  different 
manner in the 3R Directive. Prevention and reuse are not promoted through the 3R Directive 
(see  also  the  next  chapter).  Also,  3R  Directive  does  not  provide  an  incentive  to  improve 
recyclability with an increasing ambitious level, as long as the 3R targets are being reached 
across most of the MS. There is the clear finding here, that the 3R Directive is not effective in 
ensuring that vehicles POM increase in circularity. As for future provisions on circularity, the 
level of effectiveness will depend on whether or not the future provisions fine-tune or amend 
those that are already being covered with lower ambition today, e.g., amendments of the 3R 
targets or adding additional materials to be coded. If the 3R Directive is not amended in a 
way  that  it  supports  the  implementation  of  future  ELVD  provisions  on  circularity,  where 
applicable, it will only be possible to tailor these future ELVD provisions on circularity in a way 
that the support of 3R type approval checks for what is put on the market. 

In  this  respect,  it  should  be  mentioned  that  following  the  above-mentioned  intention  of 
regulation, the 3R Directive was set up as a market-control instrument to support ELVD, i.e., 
waste  legislation.  However, from  the  interviews  and  workshop  participants,  specifically  the 
MS representatives’ workshop, it became clear that the 3R Directive is more often connected 
to the general type approval legislation rather than to the ELVD, as usually, both are handled 
in the Member States in ministries of transport or economics. If expected by the regulator that 
in the future, the 3R Directive is a means to interlink design and end-of-life, and that the 3R 
Directive shall contribute to the ELVD objectives and effectively ensure that vehicles put on 
the market are more circular, such intention is to be made more explicit in the 3R legal text 
and to be communicated to stakeholders.  

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7.4.3.2  Conclusions  

Is the way that the 3R Directive refers to the ELVD hazardous substance and plastic 
coding provisions effective in terms of ensuring that vehicles put on the market comply 
with the related prohibitions (and with related exemptions) ELVD requirements?  AND  
Will the way that the 3R Directive addresses substance prohibitions and plastic coding 
remain  effective  in  case  such  prohibitions  (or  their  exemptions,  if  applicable)  will 
change in the future? 

It is concluded that the 3R Directive is effective in ensuring that vehicles POM comply with 
current  prohibitions  and  exemptions  of  hazardous  substances  and  with  plastic  coding 
standards. However, in the future, only compliance with the substance prohibitions would be 
ensured, based on the dynamic cross-reference in 3R Directive linking Art. 4(2) of the ELVD. 
Another  indicator  for  effectiveness  in  this  case  is  the  fact  that  the  hazardous  substances 
related  articles  in  ELVD  and  3R  Directive  formulated  in  a  very  similar  way.  Though  the 
wording of the articles could change, as long as the cross-references are kept, it is assumed 
that substance prohibitions will be effective.  

As for coding standards, compliance is only ensured as far as the 3R directive is linked to 
Commission  Decision  2003/138/EC,  however  compliance  with  changes  resulting  from 
amendments to ELVD Art. 8 would not be ensured.  

It should be noted that ELVD does not refer to the intention for 3R Directive check compliance 
with the hazardous substance prohibitions and the and plastic coding requirements. In both 
cases, the ensured compliance can be considered as an added benefit of the 3R Directive. 

Will the way that the 3R Directive addresses substance prohibitions remain effective in case 
such prohibitions (and/or their exemptions) are moved to another legislation (e.g. REACH)? 

As said above, the key for ensuring that 3R legislation is effectively addressing substance 
prohibitions is the direct cross-reference to Art. 4(2) in the ELVD. It is expected that it should 
be possible to add the direct cross-reference to another legislation, e.g., a respective article 
and/or  Annex  in  REACH.  However,  looking  at  the  fact  that  REACH  has  the  possibility  to 
prohibit  substances,  e.g.  substances  of  very  high  concern,  without  any  link  to  the  field  of 
application  of  the  substance,  it  is  expected  that  the  more  vehicle-specific  prohibitions  and 
exemptions are formulated, the better type approval authorities can connect the exemptions 
with their daily field of work.  

Is the 3R Directive effective in ensuring that vehicles put on the market are more circular? 

As the different R’s are differently addressed, and due to recyclability being the focus of 3R 
Directive,  it  is  concluded  that  the  3R  Directive  is  not  sufficiently  effective  in  ensuring  that 
vehicles POM are more circular. Furthermore, prevention is not an aspect of 3R Directive. 
However, based on the assumed intention of the regulator, the 3R Directive has the potential 
to contribute a lot to the circularity of vehicles in connecting EoL requirements with the vehicle 
type approval.  

Is  the  3R  Directive  suitable  for  ensuring  in  the  future  that  vehicles  put  on  the  market  will 
comply with future ELVD provisions on circularity (e.g., recycled content targets)? 

As  a  precondition  to  effectively  ensure  that  vehicles  POM  will  comply  with  future  ELVD 
provisions  on  circularity,  the  assumed  regulation  intention  formulated  earlier  needs  to  be 
confirmed by the regulators, e.g., through amendments / additions of Recitals. Moreover, for 
sure,  amendments  of  3R  Directive  in  relation  to  future  ELVD  provisions  on  circularity  are 

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necessary, e.g., providing additional information on components beyond 3R Directive Annex 
I (Requirements), Annex II (Information Document for EC vehicle type approval), and Annex 
IV (Preliminary Assessment).  

7.4.4  ELVD end-of-life requirements 

The questions addressed in this section are: 

• 

• 

• 

• 

Is the 3R Directive effective in ensuring that vehicles put on the market enable the reuse 
of their components and parts to the highest potential? 
Is  the  3R  Directive  effective  in  ensuring  that  vehicles  put  on  the  market  enable  the 
recycling of their components and parts to the highest potential? 
Is the 3R Directive effective in ensuring that vehicles put on the market are composed 
of materials that can be recycled to a sufficient degree? 
Is the 3R Directive effective in ensuring that vehicles put on the market can fulfil the 
ELVD 3R targets at present or in case their ambition is increased in the future?  

•  Would  the  3R  Directive  remain  effective  in  ensuring  that  vehicles  put  on  the  market 
comply with ELVD if requirements would be added to make certain waste management 
treatments obligatory, e.g. certain post shredder technologies? 

7.4.4.1  Analysis 

Article 1 of the 3R Directive clarifies that its objective is to ensure that the component parts 
and materials of vehicles that have been type-approved based on its rules can be reused, 
recycled and recovered, as a minimum fulfilling the 3R targets which are mentioned in Annex 
I  of  the  3R  Directive412.  For  this  purpose,  the  3R  type  approval  process  requires 
manufacturers  to  compile  various  data  on  the  vehicle  being  type-approved  as  a  means  of 
showing its potential reusability, recyclability and recoverability. This creates an impression 
that  all  of  the  3Rs  are  part  of  the  type  approval  process,  in  which  OEMs  need  to  provide 
evidence as to how they comply with the ELVD 3R targets. However, in practice, how the 
process  is  conducted  relates  differently  to  each  of  the  3Rs.  For  example,  looking  at  the 
general type approval legislative text where the 3R Directive is referred to, ‘recyclability’ is 
mentioned but not the other R’s. 

This can already be observed in the ISO 22628: 2002 that is prescribed as the standardised 
method for the calculation of the 3Rs. The scope of the ISO standard refers to its use for the 
purpose of calculating the “recyclability rate” and the “recoverability rate”. Reuse is covered 
by these two rates but is not specified individually and thus there is also no requirement to 
report on reuse individually in the calculation. The standard defines “reusability” separately 
and also specifies criteria for when a component can be considered as “reusable, recyclable 
or  both  based  on  its  dismantlability”,  however,  here  too,  there  is  no  obligation  for 
manufacturers  to  provide  separate  data  about  e.g.,  the  total  weight  and  composition  of 
components with a potential for reuse. Components removed for reuse or recycling prior to 
the shredder can be specified in the data provided on the “pre-treated” fraction and on the 
“dismantled”  fraction.  For  the  former,  the  standard  specifies  a  list  of  components  and 
materials  for  which  data  must  be  provided.  Many  of  these  component  parts  and  materials 
appear under the ELVD Annex I, part 3 and 4 (e.g., depollution and removal requirements), 
though not all. For the latter, i.e., the ‘dismantled fraction’, there is no specification, however 

412 The target of 85% and 95% is explicitly named in Annex I, as described before, however, neither in Art. 1 nor in the Annex I 
is there a link to the ELVD. 

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the  calculation  format  provided  in  Annex  A  of  the  standard  requires  that  data  provided  is 
specified  in  relation  to  a  specific  component.  In  practice,  it  is  understood  that  each 
manufacturer  will  specify  different  components  in  this  section,  “based  on  the  dismantling 
strategy”. This observation is based on documents submitted as examples of type-approval 
submissions  by  a  type-approval  Authority),  and  confirmation  with  other  stakeholders  (MS 
type-approval Authorities). It was further explained by an MS type approval authority that the 
strategies and insofar also the type of components specified for dismantling are often of the 
same kind in terms of the cost/benefit of dismantling of a specific component. i.e., highest 
material weights in relation to the lowest dismantling costs. However, different type approval 
documents  submitted  to  the  consultants  as  part  of  the  stakeholder  input  suggest  that  the 
number of components specified can vary greatly. Of two submission examples, one specified 
a  single  component  (material  composition  was  not specified)  and the  other close to  20,  of 
which all were composed of plastic aside from a reference to glass. Based on the component 
types and composition, the consultants assume that in the latter case the components were 
mainly considered dismantlable for the purpose of recycling. As dismantled components can 
be relevant for reuse and/or recycling, it is concluded that a vehicle can reach type approval 
without  actually  referring  to  components  that  are  relevant  for  reuse.  This  was  explicitly 
confirmed by an interviewed stakeholder and generally, most stakeholders stated that reuse 
of parts and components of ELVs is not facilitated through the 3R type approval. 

On  this  basis,  it  appears  that  despite  the  reference  to  the  reuse  and  recycling  target  and 
various references to reuse in the 3R Directive and the ISO standard, that the type approval 
process does not promote reuse in practice. In the legislative text, 'reuse' is only referred to 
in  relation  to  component  parts  which  shall  not  be  reused,  but  there  is  no  reference  to 
components, the reuse of which is to be promoted. Most stakeholders who were interviewed 
or  surveyed  (e.g.,  MS  type  approval  authorities  but  also  OEMs)  support  this  view  and 
specified  that  reuse  is  not  taken  into  consideration  in  the  type  approval  process.  Various 
stakeholders (e.g., (Stellantis 2022; VW/Porsche 2022)) explained that reuse is solely based 
on market demand and that, in principle, every part is reusable – however it is not possible in 
the design phase to estimate what will be reused when the demand is not yet known. This 
may explain why asking for specific quantities of reused parts under the 3R type approval 
calculation  is  meaningless.  However,  there  is  room  to  consider  how  the  3R  type  approval 
process could facilitate reuse. 

Looking at recycling, it is observed that a core part of the 3R type approval process is based 
on the specification of components and materials that are considered to be recyclable, i.e. 
through the requirement to calculate the recycling rate. This is addressed in the ELV “pre-
treatment” and “dismantled” fractions that are addressed in the ISO standard calculation, as 
explained  in  the  first  paragraphs  of  this  section  for  reuse.  It  is  also  addressed  in  the  ISO 
standard calculation section on “metal separation” (i.e., all metals separated from the vehicle 
through  shredding)  and  on  non-metallic  residue  treatment  (specification  of  recyclable 
materials). All materials considered to be recyclable are calculated to account for compliance 
with the “reuse and recycling” target. Two limitations are observed here in terms of the 3R 
type approval process facilitating recycling.  

•  For the case of materials for which there are no available recycling capacities in the EU 

at the time of type approval, the ISO standard specifies that a material will be 
considered recyclable when there are “technologies which have been successfully 
tested, at least on a laboratory scale”. The logic behind this is that vehicles have a long 
service life (15-20 years) in which it can be expected that a technology at laboratory 
stage would reach maturity in terms of available recycling capacities. However, it is 
observed that vehicles that have been type-approved may include materials in large 
amounts that are not recyclable at EoL. For example, the BMW placed first models of 
the i3 on the market in 2013, using carbon fibres as a main material for the vehicle body 

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instead of metal to reduce the weight of the vehicle413. In a comparison of the weight 
reduction effect with the Mazda 2, Marklines (2015) Automotive Industry Portal414 
estimates that the BMW i3 is “90kg (39%) lighter than that of a Mazda2-based steel-
made vehicle of the same size”. Nonetheless, according to this source, the BMW i3 
contains 68.5 kg of Carbon Fiber Reinforced Plastics (CFRP). Based on interviews with 
waste management operators, capacities for the recycling of this material are still not 
available for ELV waste management, resulting in a large share of the vehicle weight not 
being recycled (Egara 2021). Looking at other vehicles, most vehicles do not use CFRP 
and yet the 85% reuse and recycling target is not significantly “over-achieved”. It is thus 
assumed that the BMW i3 and similar vehicles using large amounts of CFRP have been 
type approved with the assumption that this material would be recyclable at EoL. The 
understanding that vehicle manufacturers constantly search for materials that could help 
reduce the vehicle weight to reduce vehicle emissions means that this could become a 
more significant problem in the future. In other words, there may be room to consider 
how such materials should be treated in the future under the 3R type approval process, 
to ensure that compliance with the 3R targets is not impaired. 

•  As for material that can be recycled, in such cases the ISO standard prescribes that the 
full weight of the material is considered for the calculation of the share of the vehicle that 
is reused and recycled. Consideration as to material losses during waste operations are 
not made, even though materials are not recycled at 100% efficiency. For example, 
EUROFER (27.10.21) stated that a level of 90% recycling is typically achieved for steel 
as each marginal increase results in a significant increase in the cost of treatment. In 
addition, there is no differentiation in this case between high quality recycling which 
generates secondary material that can be used in vehicle manufacture or equivalent 
uses, and between downcycling like backfilling or construction filling materials. For 
example, glass is sent with the ELV to the shredder in most MS, and is part of the 
mineral fraction generated from shredder heavy fraction used for backfilling or as a 
construction filling material (OVAM 2012?).  

Considering the development of vehicles towards increasing use of light-weight materials415 
and considering possible changes of the ELVD, (e.g., the increase of the reuse and recycling 
targets, changes the way that it is to be monitored and reported on or introduction of material 
specific  recycling  targets),  there  may  be  room  to  change  the  way  that  such  materials  are 
perceived. Against this background Type approval Authorities were asked if they perform any 
sort of monitoring of the differences between the achievability of the 3R targets in the type 
approval phase and at end-of-life. Most admitted to not performing such monitoring, or studies 
that  look  at  this  aspect.  Only  one  type  approval  service  provider  (but  not  the  authority) 
explained that they visit ATFs occasionally to see how dismantling is performed and check 
how  this  compares  with  the  data  provided  during  type  approval,  however  vehicles 
investigated were stated not to be the same as those for which the company had supported 
OEMs in the process of type approval. Here too, it could be relevant to consider how it can 
be ensured that recyclability reported during type approval sufficiently reflects the recyclability 
that can be achieved at EoL.  

Overall, the 3R Directive does not distinguish between treatment technologies, aside from the 
differentiation into pre-treated, dismantled, metal separation and non-metallic residue treated 

413 https://www.dw.com/en/bmw-sets-its-sights-on-innovative-carbon-fiber-future-with-i3-electric-car/a-17095180 

414 https://www.marklines.com/en/report_all/rep1419_201506 

415 Stellantis (2022): “There is larger importance in design considerations given to the use phase of vehicles, especially weight 
(to save on energy consumption); if the energy mix becomes ‘greener’, it might be that other aspects than use-phase would 
gain importance.” 

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fractions. As explained above, if a treatment type falls under the definition of recycling416, it 
will be counted towards achieving the reuse and recycling target. There is no prioritisation of 
technologies  that  achieve  higher  recycling  qualities  or  that  reduce  the  losses  of  certain 
materials.  

Finally, 3R Directive does not contain any reference to the prevention of waste. Prevention 
was  said  (Stellantis  2022)  to  be  part  of  design  but  not  really  measurable  during  3R  type 
approval (how  to measure  a  material not  used). It  was  also  explained (VW/Porsche  2022) 
that  ‘longevity,  durability,  reparability  and  light  weight  facilitate  the  prevention  of  waste’. 
Stakeholders asked in this respect were generally of the opinion that it was not the objective 
of 3R Directive to address waste prevention. However, in the waste hierarchy and Circular 
Economy, there is a clear preference for prevention (and reuse) measures over recycling.  

7.4.4.2  Conclusions  

Is the 3R Directive effective in ensuring that vehicles put on the market enable the reuse of 
their components and parts to the highest potential? 

Though the 3R Directive makes a reference to reuse through the requirement to show how 
the  3R  targets  are to  be  met,  based  on  the  information above,  it  is  concluded  that the  3R 
Directive is not effective in facilitating reuse per se. The method of calculation set out through 
the  reference  to  ISO  22628:  2002  refers  to  specification  of  components  that  can  be 
dismantled and reused, but it does not require manufacturers to address reuse separately in 
their 3R Type approval applications. It can be understood that manufacturers rarely refer in 
their  calculation  to  components  that  can  be  reused  as  it  is  not  possible  to  assume  what 
components will be dismantled and reused in practice at EoL. The effectiveness of the 3R 
Directive  can  be  assumed  to  decrease  even  more  should  the  ELVD  introduce  additional 
obligations on reuse, if they are not taken up under the 3R Directive as well. 

Is the 3R Directive effective in ensuring that vehicles put on the market enable the recycling 
of their components and parts to the highest potential?  AND  Would the 3R Directive remain 
effective in ensuring that vehicles put on the market comply with ELVD if requirements would 
be  added  to  make  certain  waste  management  treatments  obligatory,  e.g.  certain  post-
shredder technologies? 

Though the 3R type approval process requires manufacturers to specify recycled amounts 
separately, it does not require a differentiation between qualities of recycling (high quality vs. 
downcycling). It also does not require taking recycling inefficiencies into account. Insofar it 
cannot be considered effective in facilitating recycling of components and material parts to 
their highest recycling potential. Whether it would be effective in its current form in ensuring 
compliance of a vehicle with possible waste management obligatory treatment technologies 
will depend on how such technologies for high-quality recycling would be distinguished from 
recycling  technologies  with  output  of  lesser  quality  in  the  accounting  of  recyclability.  The 
effectiveness of the 3R Directive can be assumed to decrease even more should the ELVD 
introduce  additional  obligations  on  recycling  (e.g.,  material  specific  recycling  targets  or 
requirements on shredder and/or PST performance standards), if they are not taken up under 
the 3R Directive as well. 

416 Linked to the ELVD definition under Article 2(7): “‘recycling’ means the reprocessing in a production process of the waste 
materials for the original purpose or for other purposes but excluding energy recovery. Energy recovery means the use of 
combustible waste as a means to generate energy through direct incineration with or without other waste but with recovery of 
the heat”. 

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Is  the  3R  Directive  effective  in  ensuring  that  vehicles  put  on  the  market  are  composed  of 
materials that can be recycled to a sufficient degree? 

The  3R  Directive  does  not  sufficiently  differentiate  between  non-recyclable  and  recyclable 
materials as long as technologies are available at the laboratory stage and above. De facto 
this allows vehicles making use of high volumes of non-recyclable to be placed on the market 
in some cases, like CFRP which is increasingly used in vehicles to reduce their weight and 
for which there are currently lacking recycling capacities for vehicles in the EU. With the trend 
towards lightweight materials, this could affect the achievability of the 3R targets and should 
be addressed more effectively in the Directive to avoid this consequence. It also needs to be 
said, however, that an increase in use of a non-recyclable material in the vehicle fleet could 
be sufficient in some cases for recycling capacities to develop over time, having a positive 
effect of the 3R effectiveness in this respect over time. Here too, should any requirements be 
introduced in relation to non-recyclables (e.g., obligatory dismantling) it would be beneficial 
for  them  to  be  addressed  under  3R  Directive  so  as  to  at  least  ensure  that  the  use  and 
localisation of such materials is communicated to waste operators to ensure compliance with 
possible treatment requirements.  

Is the 3R Directive effective in ensuring that vehicles put on the market can fulfil the ELVD 
3R targets at present or in case their ambition is increased in the future?  

Considering the points raised above, there is already concern as to the achievability of the 
3R targets due to the increase in use of lightweight materials and other trends. Should the 
ELVD increase the ambition level of targets (e.g., increase of the reuse and recycling target, 
change  in  the  reporting  on  fulfilment  or  in  the  operations  considered  as  recycling  or 
introduction of material specific recycling targets), it can be assumed that the current practice 
would lose its effectivity in terms of preventing market entry to vehicles that cannot achieve 
the 3R targets and future related requirements. This is particularly the case as the current 
practice  of  checking  compliance  with  the  reuse  and  recycling  target  does  not  e.g.,  take 
account of recycling inefficiencies.  

7.4.5  Information collected through the 3R Directive processes 

The questions addressed in this section are: 

• 

Is the 3R Directive effective in ensuring that ATFs have enough information on vehicles 
put on the market to allow their waste management in compliance with the ELVD 3R 
targets?  

7.4.5.1  Analysis 

The question is whether information collected as part of the 3R Type approval could be used 
as  a  basis  for  increasing  data  accessibility  to  waste  operators  on  component  parts  and 
materials as well as if and how they could be dismantled to promote recycling. Another option 
is  that  such  information  could  feed  into  an  EPR  mechanism  to  allow  concluding  from  the 
dismantlability of vehicles to the necessity of financing certain waste treatment operations.  

Generally,  information  is  provided  in  the  two  steps  of  the  3R  type  approval,  this  is  i)  the 
preliminary  assessment,  and  ii)  the  type  approval  as  such.  Requirements  as  to  what  data 
must  be  provided,  is  listed  in  3R  Directive  Annex  I  (Requirements),  Annex  II  (Information 
Document  for  EC  vehicle  type  approval),  and  IV  (Preliminary  Assessment).  There  is  no 

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identifiable consistency in the information requirements referred to in Articles specifically, e.g. 
Art 4(2) refers to hazardous substances, or in the Annexes only.  

On the total list of information that a manufacturer compiles for the 3R Type approval, the 
following information would be useful and relevant to dismantlers and ATFs: 

• 

•  Strategy for dismantling, reuse, recycling and recovery. This strategy and the IDIS 
document are not directly interlinked (Stellantis 2022). Some OEMs do not have the 
same document at all, however, among the answers from OEMs, there was one 
(anonymous) saying that they provide to IDIS an adapted version of the strategy 
prepared to comply with 3RD Art 6(3). 
ISO 22628:2002 Annex A data presentation table. Not for all calculation steps of the 
ISO standard, but at least in some places, manufacturers indicate the components they 
expect to be dismantled, i.e., adding to the sum of dismantled parts. On the other hand, 
though a vehicle may in theory comply with the calculation standard, the lack of 
information on dismantling methods may affect what components can be removed prior 
to shredding in practice and thus how much will be reused or recycled at a higher level 
(quality and/or amount).  

•  The recyclability and recoverability rate. The rates are currently assumed to be met 
by the MS (see Figure 2-4 in main report), but this could change if the definition of 
recycling changes to exclude backfilling or other forms of downcycling or if targets 
ambition increases. 

•  Plastic coded parts and parts containing hazardous substances. As mentioned 

earlier, these two requirements are being checked in the preliminary assessment, thus, 
not per vehicle type, but only whether manufacturers handle data properly and 
completely over the value chain. This does not necessarily facilitate communication of 
information to the waste management sector (though more inherent when plastic coding 
standards are applied). 

•  3R Directive Annex II information on the general construction characteristics of the 

vehicle, on the power plant, transmission, and bodywork. 

In the process, all this data is provided to the technical service providers and the MS 
competent authorities. For some OEMs, the information is adapted, and for some OEMs, 
additional information is compiled for the communication to the ATFs. Industry voluntarily 
uses the IDIS platform for this.  

In terms of who should be targeted with measures or benefit from certain provisions, it 
should be noted that so far ATFs are not part of the stakeholders dealing with or profiting 
from the 3R Directive’s requirements. In the current version of 3R Directive, manufacturers 
are targeted to provide the data to the Type approval Authorities.  

7.4.5.2  Conclusions  

Is  the  3R  Directive  effective  in  ensuring  that  ATFs  have  enough  information  on  vehicles 
placed  on  the  market  to  allow  their  waste  management  in  compliance  with  the  ELVD  3R 
targets? 

In its current version, it is not the objective of the 3R Directive to collect information and to 
provide it to ATFs with a view to facilitating the 3Rs. Although data has been collected that 
might be of interest to ATFs, a more detailed comparison between IDIS data and 3R type 
approval  data  should  be  made  to  see  whether  the  information  collected  through  3R  type 
approval might offer any additional benefits to ATFs, who should be asked for their opinion.  

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7.4.6  Alignment of the 3R Directive with the ISO 22628:2002 

The questions addressed in this section are: 

• 

• 

Is the use of the ISO 22628: 2002 in the 3R type approval process effective in ensuring 
that type approved vehicles put on the market comply with the ELV provisions? 
Is the use of the ISO 22628: 2002 in the 3R type approval process effective in achieving 
the objectives of the 3R Directive? 

7.4.6.1  Analysis 

When the evaluation question refers to “ELV provisions” or “objectives of the 3R Directive” in 
the same sentence with the ISO 22628:2002, this specifically relates to ELVD Art. 7 in relation 
to the vehicles being ‘re-usable and/or recyclable to a minimum of 85 % by weight per vehicle 
and […] re-usable and/or recoverable to a minimum of 95 % by weight per vehicle’, and to 
the 3R Directive as the means to ensure the targets are met. Looking at the wording of the 
targets,  ELVD  refers  to  a  reusable  and/or  recyclable  and,  secondly  to  a  reusable  and/or 
recoverable target. This is a different wording compared to the final outcome of calculations 
according to ISO 22628:2002 which is a “recyclability rate” and “recoverability rate”. However, 
these  differences  in  “framing”,  also  in  relation  to  reuse,  are  not  perceived  to  result  in  any 
problems in the implementation, except for reuse not playing a role in the ISO calculations, 
as  admitted  by  stakeholders.  From  the  formulation  it  is  clear  that  this  can  only  be  a 
hypothetical recyclability and recoverability, since the various masses of materials included 
in the calculation are ‘considered recyclable for the purpose of the calculation’. As explained 
earlier, recyclability is a yes or no decision in the ISO standard, while in practice, it can be 
assumed  that  some  of  the  component  parts  dismantled  during  depollution  are  considered 
hazardous waste and thus are not being recycled. Hence, the rates calculated through the 
ISO norm do not represent the final shares of what is effectively recycled. But, from how the 
ELVD requirement is formulated, and given that no further discrepancy between the wordings 
of Art. 7 of ELVD, 3R Directive and ISO 22628 could be identified, it is concluded that the 
standard ensures that vehicles POM comply with the current provisions and objectives.  

However,  another  point  was  identified,  where  coherence  between  ISO  standard  and  EU 
legislation  (ELVD  &  3R  Directive)  was  not  ensured:  In  relation  to  the  assessment  of 
dismantled  component  parts  to  be  considered  reusable  or  recyclable,  (a)  accessibility, 
fastening and dismantling technology shall be assessed in relation to the dismantlability, (b) 
safety  and  environmental  hazards  shall  be  assessed  in  relation  to  reuse,  and  (c)  material 
composition  and  proven  recycling  technology  shall  be  assessed  in  relation  to  recyclability 
(requested in step 2 in the ISO calculation). Participants of interviews were asked how the 
classification  of  component  parts  into  reusable  parts  and  recyclable  parts  is  done. 
VW/Porsche (2022) answered that “the reusability of vehicle components is usually possible 
for all components unless they are explicitly excluded by law, or they are wearing parts. Which 
vehicle  components  are  actually  reused  depends  on  the  requirements  over  the  life  of  a 
vehicle.  This  cannot  be  foreseen  by  the  vehicle  manufacturer.”  This  suggests  that  the 
assessment of dismantled components to be considered reusable or recyclable according to 
the three criteria mentioned is of no particular importance for manufacturers in the compilation 
of the 3R type approval. It is unclear which of the requirements of the 3R Directive refers to 
or  even  covers  this  “ISO-step2-assessment”,  for  example  ‘accessibility’  and  the  fastening 
techniques is something that is not part of the 3R Directive. Requirements that could possibly 
cover this assessment could be Annex I, point 2 specifying that the data calculated through 
the ISO 22628:2002 shall be accompanied by a list of dismantled components with respect 

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to the dismantling stage and the process the manufacturer recommends for the treatment, 
and Annex I, point 8, that the type approval authority shall double check the calculation and 
the accompanied list against the dismantling strategy provided in the preliminary assessment. 
If one of these two points were included to cover the assessment, the connection can only be 
assumed. In the case of Annex I, point 2, the ‘dismantling stage’ referred to therein could be 
interpreted  as  the  information  on  the  accessibility,  and  the  ‘process  recommended  for 
treatment’ could be interpreted as the information on the proven recycling technology. Then 
one could argue that the material composition is provided via IDIS, however, especially in the 
first two cases, references are only vague and in addition, there is no direct mentioning of 
fastening  technologies  which  is  a  relevant  information  for  dismantling.  Furthermore,  as 
explained above, as there is no reference to components for which reuse is to be promoted 
(through  provision  of  such  data),  type  approval  submissions  can  differ  significantly  in  the 
number and type of components specific for possible dismantling.  

An additional aspect is noted in relation to the criteria for choosing the reference/ worst-case 
vehicle. Looking at the examples for the trim level and optional equipment provided in Annex 
I of the 3R Directive, it is assumed that the way the ISO is designed, it might not make a big 
(or rather no) difference in the recyclability rate whether you take a vehicle with a radio or a 
leather upholstery (two of the examples provided for trim level and optional equipment). Also, 
in terms of coherence, and if to look at the aggregated and hypothetical nature of the ISO's 
calculation  method,  it  can  be  concluded that  the ISO  calculation  will  not necessarily make 
apparent variances between slightly different versions of a vehicle type, when data which is 
used to calculate the recyclability rate is only inserted in the calculation in a very aggregated 
way.  

7.4.6.2  Conclusions  

Is the use of the ISO 22628: 2002 in the 3R Type approval process effective in ensuring that 
type approved vehicles put on the market comply with the ELV provisions?  AND  Is the use 
of the ISO 22628: 2002 in the 3R Type approval process effective in achieving the objectives 
of the 3R Directive? 

Yes, ISO 22628 is effective in calculating the targets set out in ELVD Art. 7 and, to the extent 
that it is intrinsic to such a methodology, it can also support the objectives of 3R Directive. 
However,  discrepancies are  expected  in the  different  levels of  aggregation:  Small  optional 
equipment, for example, plays a role in the selection of the reference vehicle, while the ISO 
methodology  will  not  be  able  to  display  the  differences  of  a  vehicle  type  with  this  optional 
equipment  being  added  or  not.  A  second  discrepancy  was  identified  in  relation  to  the 
assessment whether to consider a component reusable or recyclable. The method also does 
not allow taking account of recycling inefficiencies in terms of the 3R targets and this could 
lead  to  increase  ineffectiveness  in the future,  should  the  ambition  of  the targets  or  related 
recycling requirements rise. 

7.4.7  Alignment and coherence with the UN ECE Regulation 133 

The questions addressed in this section are: 

• 

Is the 3R Directive coherent with the UN ECE Regulation 133?  

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7.4.7.1  Analysis 

In fact, the evaluation question asks whether or not it is ensured that vehicles placed on the 
market after a UN ECE Regulation 133 type approval also comply with the relevant provisions 
that are required for vehicles that are type approved on the basis of the 3R Directive and vice 
versa. Similarities and differences between the 3R Directive and UN ECE 133 were shown 
earlier (chapter 7.2.4). To summarise, deviating aspects are the criteria for the selection of 
the worst-case vehicle (see table above) and, under UN ECE in the specific type approval, 
according  to  which  manufacturers  shall  additionally  declare  compliance  with  hazardous 
substances and plastic coding. This, however, only applies to the preliminary assessment in 
case of the 3R Directive. Another aspect is, that the definition of recovery in the UN ECE 133 
differs from that included in the 3R Directive and ELVD. The latter refers to a list of recovery 
processes agreed under the Waste Framework Directive. Hence, the definition in ELVD is 
more detailed than the UN ECE definition. However, it was neither mentioned by stakeholders 
nor  were  there  any  other  indications  that  pointed  out  or  concluded  that  this  discrepancy 
between  the  definitions  was  problematic.  As  the  3R  Directive  (2005)  has  mainly  been  the 
source  for  the  UN  ECE  Document  published  in  2014,  and  given  that  there  are  only  slight 
differences that are not substantial to the objectives and main provisions, it is assumed that 
the 3R Directive is generally coherent with the UN ECE Regulation 133. 

A stakeholder reported that his company was generally applying for type approvals under the 
UN  regulation.  Against  this  background,  VW/Porsche  (2022)  stated  that  ‘If  Europe  would 
change 3R type approval, also UN R 133 has to be amended’. Stakeholders also addressed 
the importance of this coherence in the workshop, explaining that it also made the process 
more  efficient  for  OEMs,  i.e.,  as  they  did  not  need  to  perform  the  type  approval  process 
multiple parts for the same vehicle type in different regions. It is thus very important to not 
lose  sight  of  the  fact  that  stakeholders  currently  use  both  legislations  for  the  same 
purposes/interchangeably and alternatively.  

7.4.7.2  Conclusions  

Is the 3R Directive coherent with the UN ECE Regulation 133?  

Yes,  the  comparison  of  the  3R  Directive  and  the  UN  ECE  Regulation  133  (chapter  7.2.4) 
showed and stakeholders confirmed that both legislations are considered identical in terms 
of the ambition level, except for minor differences explained above. 

7.5  Summary of the results 

Five points are identified to work effectively in the 3R Directive: These are (1) the intention of 
the  regulation  (in  the  current  wording),  (2)  the  comprehensive  scope  (looking  at  the  3R 
Directive individually), (3) ensuring market compliance with hazardous substance and plastic 
coding provisions, (4) effectiveness of ISO 22628 in calculating the targets set out in ELVD 
Art. 7, and (5) the interchangeably of the 3R Directive and the UN ECE legislation.  

Four aspects of ineffectiveness were identified: 

•  Comparing the scope of the ELVD and the scope of the 3R Directive, it was identified that 
they are neither aligned nor dynamically linked in relation to M1 and N1 multi-stage built 
vehicles  and  vehicles  produced  in  small  series  (if  not  special-purpose  vehicles).  ELVD 
requirements apply to these vehicles, but compliance is not checked during type approval 
processes (because of an exclusion from scope of the 3R Directive). 

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•  The 3R Directive is neither effective in ensuring that vehicles POM are more circular, nor 
in  facilitating  reuse  per  se.  It  is  also  not  considered  effective  in  facilitating  recycling  of 
components and material parts to their highest recycling potential. 

•  The 3R Directive does not sufficiently differentiate between non-recyclable and recyclable 
materials  as  long  as  technologies  are  available  at  the  laboratory  stage  (Technology 
Readiness Level 4) and above, creating a concern as to the achievability of 3R targets in 
the future. 

•  Because it is not the objective of the 3R Directive to collect information and to provide it 
to ATFs, the 3R Directive is not effective in ensuring that ATFs have enough information. 

On the basis of the list of inefficiencies, it is suggested that, even if ELVD was not amended, 
the  aspect  of  promotion  of  reuse  and  recycling  of  material  parts  to  their  highest  recycling 
potential  should  be  included.  Furthermore,  a  differentiation  should  be  made  between  non-
recyclable  and  recyclable  materials.  These  amendments  should  be  made  to  cover  current 
inefficiencies.  

In the context of the current revision of the ELV legislation it is important that account will be 
taken of the following additional inefficiencies if the ELVD, and the 3R Directive is not:  

• 

• 

If  the  3R  Directive  cannot  be  used  as  a  means  to  further  implement  additional 
requirements in relation to measures to support design for circularity, the regulator shall 
lose  its  mechanism  to  check  compliance  of  design  requirements  supporting  the  ELV 
treatment. 
If scopes will still not be aligned between the two legislations, the existing discrepancies 
that  exist  today  will  increase  in  the  future:  If,  for  example,  multi-stage  built  vehicles 
continue to be excluded from the 3R Directive but will be in scope of ELVD in terms of 
design requirements (haz. subst., plastic coding) or 3R targets applying to them, then, the 
compliance with certain ELVD requirements will not be ensured for a considerable number 
of vehicles, as the compliance cannot be checked through 3R type approval. 

•  Should  the  ELVD  increase  the  ambition  level  of  3R  targets,  it  is  assumed  that  the  3R 
Directive  would  lose  its  effectivity  in  terms  of  preventing  market  entry  to  vehicles  that 
cannot achieve the 3R targets. This could also be the case should additional provisions 
on recycling qualities and standards be introduced. 

At various moments of this targeted evaluation, the question arose as to merging the ELVD 
and  the  3R  type  approval  directive.  Should  merging  be  considered,  the  following  was 
identified as issues to keep notice of:  

•  Future regulation will require (dynamic) references to the general type approval 

legislation (Regulation 2018/858), assuming that the regulator continuously intends to 
use the process of type approval to ensure compliance with vehicle design requirements 
prior to their being put on the market. 

•  The legislation will have one scope only - it is recommended to regulate exemptions for 
specific vehicle categories in relation to a single or multiple provisions rather than 
putting exemptions generally upfront. An example for the proposed way of regulation is 
the Art. 3(4) of the ELVD which exempts special-purpose vehicles from the provisions of 
Art. 7 (of ELVD).  
It is very important to not lose sight of the fact that currently, stakeholders use 3R 
Directive and UN ECE 133 legislations alternatively for the same 
purposes/interchangeably. Consequences of a merging for this interchangeability should 
be considered. 

• 

•  As long as the cross-references are kept or revised according to different legislations, 
articles and annexes, it is expected that hazardous substance prohibitions and plastic 
coding will remain effective. 

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As  outlined  earlier  (Table  7-1),  possible  measures  will  be  integrated  in  the  policy  options 
under  the  main  study  of  the  ELV  Impact  Assessment.  The  following  measures  have  been 
identified to address the earlier mentioned inefficiencies:  
•  Under the Problem Area of “circularity” 

o  Measures to achieve specific objective 2.1: Improve design and production of 

vehicles to support reuse and recycling 
  2.1.d) Provisions for improving the relation between the 3R Type approval 
process and ELV waste management performance. (chapter 2.1.5.1.4) 

  2.1.e) Option for OEMs to submit life cycle data as part of the 3R type approval 
process to justify the use of materials where recycling is not yet established 
(chapter 2.1.5.1.5) 

  2.1.f) Obligatory reporting requirements on the use of materials that affect 

dismantling and recyclability to facilitate identification of incompatible practices 
(chapter 2.1.5.1.7) 

  2.1.h) Obligatory due diligence for materials used in vehicles (chapter 2.1.5.1.9) 
  The manufacture of vehicles and vehicle components makes use of numerous 

materials of both primary and secondary nature. Some of these are sourced from 
countries (outside the EU) where the local governing conditions and/or the level 
of performance of mining and processing facilities may not ensure the provision 
of human rights, the health of workers and/or of nearby residents, or the 
prevention of adverse impacts on the environment. Where the manufacture of 
vehicles has a high dependency on material sourcing from such countries, this 
can contribute to adverse impacts on society and on human health and the 
environmental. To prevent such impacts, vehicle manufacturers could be 
required to perform due diligence when sourcing materials to produce vehicles 
and their components from high- risk countries. This can be related either to 
primary materials that are sourced from conflict-affected or high-risk areas or to 
secondary materials sourced from countries that do not ensure a minimum level 
of environmental performance and/or of minimum social working conditions.  

At horizontal level, in relation to the sourcing of minerals from conflict-affected or high-risk 
areas, Regulation 2017/821/EU lays down supply chain due diligence obligations for Union 
importers of tin, tantalum and tungsten, their ores, and gold originating from such areas. The 
sourcing  of  e.g.,  tin,  tungsten,  tantalum,  niobium  and  gold  minerals  and metals  for  vehicle 
manufacture  would  be  addressed  through  this  Regulation,  making  an  ELV  obligation 
redundant. 

In some cases, there may be other materials used in vehicles sourced from countries that do 
not ensure that the sourcing and processing of such materials is environmentally and socially 
sound. For such cases, due diligence obligations could be included in the Directive, similar to 
those currently proposed for the new regulatory framework for batteries. This would include 
a  provision,  laying  down  obligations  for  OEMs  to  perform  due  diligence  on  the  supply  of 
certain materials (primary and secondary), and to declare on the risk of occurrence of adverse 
impacts and on strategies for their mitigation. Declarations on such actions, including third 
party verification would need to be made available to authorities as part of the type-approval 
process and for MS inspections. A list of materials (e.g., REE) for which this is to be obligatory 
would be included in the future legislation for vehicles, also specifying thresholds for each 
material  as  to  the  amount  of  use  contained  in  a  vehicle  above  which  the  obligation  would 
comply.  The  annex  would  be  updated  continuously,  in  relation  to  the  thresholds  and  if 
necessary, also as to the materials specified therein.  

There is also a need to consider the requirements set out in the Corporate Sustainability Due 
Diligence Directive. The CSDD is a horizontal legislation that focusses more generally on the 
behaviour of companies and addresses the entire value chain for all goods and services. It 

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will  implement  the  due  diligence  requirements  of  the  proposed  Batteries  regulation  by 
introducing a value chain due diligence related to raw materials (and goods and services) that 
are not covered in the Batteries Regulation. Both build on the OECD due diligence guidance, 
making implementation coherent.  

Expected outcome: It is currently not clear which materials could be addressed through a due 
diligence obligation to be included in the future ELV legislation. Materials addressed under 
other legislation (or in focus of future sectoral legislation such as the Batteries Regulation) 
are not used in large amounts in vehicles.  

In  parallel,  the  European  Commission  has  published  a  tender  to  review  the  functioning  of 
Regulation 2017/821/EU, which towards 2026 could both lead to adaptations in future due 
diligence requirements as well as in the materials for which such requirements are necessary.  

 
  2.1.i) Set out an obligation for OEMS to provide additional information on 

composition of cars (chapter 0) 

  But not: 2.1.c) Obligation for OEMs to develop and implement a circularity 

strategy for increasing the circularity of vehicles. This measure is regarded in 
addition to 3R Directive “strategy for dismantling, reuse, recycling and recovery”, 
see the full description in chapter 2.1.5.1.3. 

o  Measures  to  achieve  specific  objective  2.2:  Ensure  elimination  of  hazardous 

substances in vehicles 

o  2.2.a): Restriction of substances in vehicles 

This  measure  deals  with  defining  the means  to  generate  specific  limitations/restrictions  on 
substances  used  in  vehicles.  The  expected  mechanism  should  be  able  to  deal  with  the 
existing restrictions of the four heavy metals as well as with the exemption mechanism. At the 
same time, it should cover the restriction of additional substances.  

The  objective  of  this  measure  is  to  provide  legal  certainty  about  the  currently  restricted 
substances and their exemption, and the procedure for future substance restrictions and the 
exemptions mechanism.  

Furthermore, it should allow to restrict further substances in vehicles. This is relevant against 
the background that there is a general increase in the use of plastics, for example, due to its 
advantages for vehicles in terms of weight reduction. However, the use of plastics also raises 
concern as to the presence of hazardous chemical additives in such materials and with regard 
to the question as to how far this can pose technical difficulties for their recovery. Concerns 
on additives also apply to other materials such as rubber or textiles, though possibly used in 
lower amounts in these materials. This suggests that there may be a need to regulate the 
presence of additional hazardous substances that are used in vehicles, aside from the four 
heavy metals currently prohibited, e.g., certain flame retardants, plasticisers or surface-active 
agents such as PFAS. 

Three variants of this measure can be distinguished, these shall be treated as policy options. 
Thus, the detailed description of the measures can be found in the description of the policy 
options in chapter 3.1.4.8.2. For this measure, three alternative policy options are:  

POLICY OPTION 1A – RESTRICTIONS AND EXEMPTIONS UNDER REACH 

POLICY OPTION 1B – RESTRICTIONS AND EXEMPTIONS UNDER REVIEWED ELVD 

POLICY OPTION 1C – HYBRID APPROACH 

2.2.b: Improved communication on hazardous substances in the automotive value chain  

This  measure  addresses  the  communication  needs  at  the  end  of  life  of  vehicles  on  the 
hazardous  substances  to  allow  improved  reuse  and  recycling  by  sorting  (out).  An 

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improvement in the communication on hazardous substances in the automotive value chain 
would  also  contribute  to  the  elimination  of  hazardous  substances  in  material  fractions 
generated  by  the  ELV  waste  management  sector.  There  are  information  systems  in  place 
covering the details on material composition, however, the missing element is the availability 
of the information at waste treatment facilities on the one hand side, and the information for 
dismantling on the other side. Thus, there is a need for additional dismantling information for 
recyclers in addition to the current information provided by SCIP or GADSL in IMDS.  

This proposed measure is to introduce an obligation – to be added to the ELVD – that the 
information on the content of substances with hazardous classifications or substances under 
assessment for classification needs to be documented along the value chain. Should a need 
for depollution arise, the information on the content of hazardous substances would need to 
be made available to treatment facilities in a way that the information is linked to  

single parts/components,  

the location of the parts/components in the vehicle combined with dismantling information and  

to safe use instructions for dismantling and recycling processes.  

This  communication  would  enable  the  dismantling  prior  to  shredder,  combined  with 
subsequent decisions on whether to sort out components or materials, from the material flow, 
for disposal due to their content of hazardous substances (as is the case for parts containing 
the POP decaBDE) or to sort out such components or materials to allow their diversion to 
specific  treatment  that  allows  controlling  the  content  of  hazardous  substances  (e.g., 
separating  aluminium  wrought  and  cast  alloys)  or  eliminating  it  from  the  general  material 
stream.  

The  improved  communication  could  be  envisaged  according  to  three  possible  information 
schemes:  

Via  the  SCIP  database  as  a  centralised  European  Database:  The  SCIP  database  was 
recently established to collect information from companies on the contents of Substances of 
very High Concern of the REACH Candidate list in articles supplied to the EU market. These 
notification requirements under the SCIP database for SVHC comprise a current obligation 
and can be considered as the baseline.  
In order to serve as a measure on improved communication, the SCIP database would need 
further development and adaptations. 

Via  an  industry-driven  system,  e.g.,  based  on  GADSL/IMDS:  The  Global  Automotive 
Declarable  Substance  List  (GADSL)  was  developed  to  facilitate  communication  and 
exchange  of  information  regarding  the  use  of  certain  substances  in  automotive  products 
throughout the supply chain. The list only covers substances that are expected to be present 
in a material or part that remains in a vehicle at the point of sale. The GADSL specifies not 
only  substances  that  are  prohibited,  but  also  substances  that  are  under  assessment  and 
could  potentially  be  regulated  in  the  future.  In  this  sense,  the  GADSL  covers  substances 
beyond those, for which the use is to be notified to the SCIP database. 

In order to serve as a measure on improved communication, the GADSL/IMDS would also 
need further development and adaptations. 

Via  a  Digital  Product  Passport  (DPP),  which  is  most  likely  based  on  a  decentralised  IT 
architecture, as defined in the Proposal for a Regulation establishing a framework for setting 
Ecodesign requirements for Sustainable Products (ESPR). The information requirement on 
substances  of  concern  is  depicted  in  the  text  box  below.  The  information  might  be  made 

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available  via  different manners.  Due to the  complex  composition  of  vehicles,  a  DPP  or  an 
access to the information via the VIN number on a website or an application seems to be the 
most appropriate form of communication. However, a concrete development is still underway 
and so far not in place.  

Proposal for a Regulation establishing a framework for setting Ecodesign requirements for 
Sustainable Products (ESPR): 

Article 7 Information requirements 

[…] 

5.  The  information  requirements  referred  to  in  paragraph  1  shall  enable  the  tracking  of  all 
substances of concern throughout the life cycle of products, unless such tracking is already 
enabled  by  another  delegated  act  adopted  pursuant  to  Article  4  covering  the  products 
concerned, and shall include at least the following: 

(a) the name of the substances of concern present in the product; 

(b) the location of the substances of concern within the product; 

(c) the concentration, maximum concentration or concentration range of the substances of 
concern, at the level of the product, its main components, or spare parts; 

(d) relevant instructions for the safe use of the product; 

(e) information relevant for disassembly. 

o  Measures to achieve specific objective 2.3: Increase the re-use and remanufacturing 

rates of parts and components contained in cars 
  2.3.f) Set up a separate (monitoring) target for re-use/preparing for re-

use/remanufacturing (chapter 2.1.5.3.6) 

•  Under the Problem Area of “scope” 

o  Measures to achieve objective 1: Ensure a comprehensive coverage of the 

sustainable production and dismantling of all relevant vehicles by the ELV Directive 
  Obligation to give a CoD to the last owner of the vehicle 

In  combination  with  the  obligation  to  treat  vehicles  in  ATFs,  this  measure  shall  ask  that  a 
certificate of destruction (CoD) is given to the last owner of the vehicle (by the ATF), which 
would  be  necessary  for  deregistration.  At  a  minimum,  through  this  measure  the  same 
provisions  shall  be  established  for  vehicles  not  yet  in  scope  of  ELVD  as  for  M1  and  N1 
vehicles today.  

Among the measures to address the problem of missing vehicles (in relation to objective 3.1) 
the  OBLIGATIONS  FOR  DISMANTLERS  /RECYCLERS  TO  CHECK  AND  REPORT  ON 
ELVS/CODS is under consideration(see details under section 2.2.5.1.5). Dependent on the 
preferred option in relation to this measure (amongst others) it is still to be decided whether 
the new obligation to check and report ELVs on the number of CoDs shall apply to the waste 
operators dealing with new vehicles. 

The provision shall be formulated so as not to create obstacles for the reuse market.  

Vehicle specifics: not vehicle specific. 

Expected Outcome: This measure facilitates Member States to identify the extent of problems 
associated  with  missing  vehicles.  It  is  considered  a  contribution  to  closing  the  lack  of 
knowledge hindering authorities in fact-based decision making. 

Affected Stakeholders: Vehicle owners, ATFs/dismantlers 

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  3R TA provisions (chapter 2.4.5.1.6) in relation with targets for Reuse & 

Recycling (chapters 2.4.5.1.9) 

Sources for this section:  

•  VW /Porsche (2022) Interview  
•  Mitic, S and Blagojevic, I (2018) Mobility & Vehicle Mechanics, Vol. 44, No. 3, (2018), pp 

13-25 

•  ELV IA Main Study Interviews 
•  https://www.dw.com/en/bmw-sets-its-sights-on-innovative-carbon-fiber-future-with-i3-

electric-car/a-17095180  

•  https://www.marklines.com/en/report_all/rep1419_201506  
•  Relevant legislation  
o  ELV Directive 
o  3R Directive 
o  Regulation 2018/858 
o  Directive 70/156/EEC 
o 
ISO 22628:2002 
o  UN ECE 133 

Please note that other stakeholders interviewed requested that information stays confidential 
and that their answers shall not be cited.  

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ANNEX III: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) 

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8.  Consultation Strategy 

Within  the  preparation  of  the  impact  assessment,  the  consultation  of  stakeholders  aims  at 
capturing the views and ideas of relevant stakeholders, allowing them to provide relevant and 
robust information and data for assessing possible options for a new regulatory framework 
on ELVs, incl. the 3R type approval. The following synopsis report was prepared following the 
better regulation guidelines (Tool 55). It outlines the different steps and consultation activities 
which were conducted to feed into the assessment. 

8.1  Consultation objectives 

The objective is to ensure that stakeholders' views are sought on all key impact assessment 
aspects. The aim is to collect information from stakeholders in relation to the various problems 
and the measures proposed for achieving the objectives defined for each problem and their 
likely impacts. This information will complement information and data gathered through other 
sources (e.g., literature review, existing policy and position papers, Eurostat data and other 
statistical data sources, etc.). All inputs (data, information, etc.) from the consultation shall be 
incorporated into the impact assessment at appropriate points, i.e., information provided by 
stakeholders shall support the analysis of the problems, identification of options that could 
answer the objectives and their analysis.  

8.2  Stakeholders consulted 

Relevant stakeholders were grouped as follows:  

• 

Industry associations (automotive industry (OEMs) for different vehicle types including 
material  and  component  suppliers,  dismantlers  (ATFs),  shredders,  recyclers;  including 
small and medium enterprises). The experience and knowledge of the industry located at 
the  different  life  cycle  stages  is  very  important  to  assess  the  impact  of  the  alternative 
policy  options  because  the  measures  tailored  to  a  specific  life  cycle  stage  have 
interlinkages with other life cycle stages. Industrial operators constitute a well-structured 
sector.  There  are  several  organisations  at  EU  level  that  cover  individual  steps  of  the 
material and component supply, production, and different end-of-life management steps. 
These  organisations  and  their members (individual  companies)  are  able  to  convey  the 
different interests and views of their members and to provide important input (e.g., market 
developments and other data and information) for the assessment.  

•  Environmental  protection  organisations,  general  public,  consumers.  The 
contribution of environmental NGOs is of high interest to link the particular case of ELVs 
with  broader  considerations  of  circular  economy,  resource  efficiency,  transboundary 
shipment  of  (hazardous)  wastes,  pollution,  i.e.,  environmental  conditions  of  end-of-life 
management  etc.  End-users  and  consumers  directly  experience  the  impact  of  certain 
measures in their day-to-day life (e.g., amendments in vehicle registration processes, e.g., 
temporary  deregistration  or  repairability,  spare  part  availability  and  costs  of  repair).  Of 
particular interest is the fact that their views go beyond purely technical considerations.  
•  MS public administration. This group consists of government experts from all Member 
States, particularly environmental agencies, national EPR organisations, the registration 
and/or type approval authorities, market surveillance bodies. The experience of national 
administrations related to certain measures and options is highly specific and could be 
relevant.  National  administrations  were  consulted  through  a  survey  and/or  through  the 
participation in the meeting for Member States’ representatives. 

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•  Other stakeholders, e.g., academia, think tanks, etc., who may have a good knowledge 
and an interest in alternative options and their analysis and assessment were consulted 
on  specific  issues.  Specifically,  representatives  from  the  United  Nations  Economic 
Commission  for  Europe  (UNECE)  and  the  United  Nations  Environment  Programme 
(UNEP) were consulted on the impacts of European ELV framework revision in relation 
to international agreements. Another stakeholder group consulted in the group of other 
stakeholders  is  that  of  vehicle  insurance  companies  playing  an  important  role  at  a 
vehicle’s end-of-life in the case of accidents. 

Lists  of  stakeholders  to  be  consulted  for  the  impact  assessment  study  in  each  of  the 
consultation activities were provided to the European Commission (EC), aiming at a balanced 
representation of the stakeholder groups and the different stakeholders representing various 
sectors and areas. The list covered EU-wide associations and individual companies; different 
sectors from e.g., manufactures to environmental NGOs. An overview of stakeholders that 
participated in each consultation activity is provided in the sub-sections of the summary of the 
stakeholder consultation below. 

8.3  Consultation methodology 

For the consultation with various stakeholders, different tools were applied. The table below 
(6-28 next page) summarises the individual consultation methods and provides an overview 
of the overall consultation strategy.  

In comparison to the initial consultation strategy, the elements of consultation of MS as well 
as the follow-up consultation after the workshop were included as additional consultations. It 
was found that some MS have experiences with legislation addressing problems targeted in 
the  review  of  the  ELVD,  and  questions  arising  on  information  provided  by  stakeholders 
required  additional  contacting  to  clarify  their  contributions.  Furthermore,  the  consultation 
activities in relation to the study to develop and assess options to review Directive 2005/64/EC 
(3R Directive) and integration of the results into the impact assessment of the ELV Directive 
are summarized within this synopsis.  

Please note that contributions received in the context of the public consultations published on 
the ”Have Your Say” web portal cannot be regarded as the official position of the Commission 
and its services and thus do not bind the Commission. Furthermore, the contributions cannot 
be considered as a representative sample of the EU population.  

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8.4  Summary of stakeholder consultations process 

All consultation activities are summarized in the following. 

For some of the documentations of the stakeholder activities, no general publication is intended. However, the European Commission was 
provided with those documentations of stakeholder consultation activities not presented in this Annex, if not indicated differently by consulted 
organisations, i.e. where information was not disclosed. 

8.4.1  Feedback on the inception impact assessment 

An inception impact assessment setting the pathway for the revision of the ELVD was published on ec.europa.eu417 and open for public 
feedback  between  22  October  2020  and  19  November  2020.  The  feedback  received  stemmed  from  61  entries.  47  of  the  participants 
submitted an additional document along with their contribution. Submitted documents and entries on the feedback website were looked at 
and attributed to the different topics of the revision.  

417   https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12633-Revision-of-EU-legislation-on-end-of-life-vehicles 

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Figure 8-1  Affiliation of stakeholders (n=61) participating in the public feedback on the inception IA  

Source: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12633-End-of-life-vehicles-revision-of-EU-rules/feedback_en (access 16.06.2022) 

 provides input as to the various aspects referred to in the different contributions.  

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Table 8-1  Overview of different methods of the project’s consultation strategy 

What 

Public feedback418 

Online public 
consultation (OPC) 

Targeted consultation  Stakeholder 

workshop 

Consultation of Member 
States 

How 

Why 

No specific format of 
feedback required, 
additional written 
contributions 
possible 
To explain the 
approach and invite 
them to contribute 

Online Questionnaire 
Survey with the possibility 
to provide additional 
written contributions  

To validate/obtain data 
and information and to 
gain opinions on more 
detailed/specific aspects 

Web conference 
interviews 

2-day online meeting 

Ad-hoc survey and 1-day 
meeting 

To validate/obtain data 
and information and to 
gain opinions on more 
detailed/specific 
aspects 

To discuss specific 
aspects, validate 
findings, gather 
additional evidence 

To inform MS on 
measures and policy 
options, to discuss specific 
aspects, gather additional 
evidence and experiences 
from MS  

Who 

All stakeholders  

How data / 
information was 
used in the impact 
assessment 

Information used to 
structure the OPC 
questionnaire, to 
provide an initial 
overview of 
interested 
stakeholders 

Specific stakeholder 
groups 

Identification of opinions of 
specific stakeholder 
groups; participating 
stakeholders were invited 
to the stakeholder work-
shop; for stakeholders 
invited to the targeted 
consultation, identify 
topics to which the study 
team expected the 
interviewed stakeholder to 
contribute 

Selected key stake-
holders from specific 
stakeholder groups 
Validate assumptions, 
understand the 
situation of selected 
key stakeholders, 
information used for 
identification of 
measures and policy 
options for reviewing 
the ELV Directive, 
information used for 
the impact analysis of 
measures.  

Specific stakeholder 
groups 

Representatives / Experts 
of MS authorities 

Information used for 
revising the measures 
and policy options for 
reviewing the ELV 
Directive, information 
used for the impact 
analysis of measures. 

Learn from experiences of 
MS-specific legislation 
already addressing 
problems targeted in the 
review of the ELVD and 
with regards to the 
measures proposed on EU 
level 

Follow up 
consultation 
activities after the 
workshops 
Written feedback on 
the content presented 
in the workshop and 
written exchange  

To gather evidence 
that was requested in 
the workshop, to ask 
clarification questions 
on feedback, opinion 
and information provi-
ded, to request 
additional data 
Targeted stakeholders 

Used for the impact 
analysis of measures 

418   https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12633-Revision-of-EU-legislation-on-end-of-life-vehicles 

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Figure 8-1  Affiliation of stakeholders (n=61) participating in the public feedback on 
the inception IA  

Source: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12633-End-of-life-vehicles-revision-of-EU-rules/feedback_en 
(access 16.06.2022) 

Table 8-2  Number of contributions referring to the topics of review 

Topics of the review  
Missing vehicles 

Illegal exports 

Reporting vehicle fleet 

Reporting reuse – recycling 

Definition recycling 

Separate reuse target 

Material specific material targets 

Data accessibility 

Design for circularity 

Recycled target contents 

EPR system 

ELVD scope 

Coherence – substances 

Coherence – definitions 

No. of contributions referring to the topic 

47 

37 

24 

21 

12 

33 

31 

27 

24 

27 

22 

14 

11 

12 

The  feedback  can  be  found  on  https://ec.europa.eu/info/law/better-regulation/have-your-
say/initiatives/12633-End-of-life-vehicles-revision-of-EU-rules/feedback_en.  

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8.4.2  Open Public Consultation 

The stakeholder consultation was held between 20 July 2021 and 26 November 2021 as a 
public  EU  stakeholder consultation.  It  targeted  all  citizens  and  organisations.  The  EC  sent 
invitations to participate to various parties, including stakeholders identified for this purpose 
by  the  consultants.  The  consultation  was  launched  on  the  EU  public  consultation  platform 
and was publicly available throughout the consultation duration. The consultation took place 
in  the  form  of  an  online  survey  and  enabled two  forms  of  input: (a) through  a  stakeholder 
survey (a shorter questionnaire targeting input from “interested citizens with only a general 
interest in the area of end-of-life vehicles”, 10 questions in total; and a longer questionnaire 
targeting  input  from  individuals  with  “specific  knowledge  and/or  interest  about  end-of-life 
vehicles”, 43 questions in total; and (b) additionally, stakeholders were given the option to 
provide written input, e.g., position papers and evidence/data.  

In  total,  208  participants  took  part  in  the  survey  during  the  consultation  period,  see  their 
affiliation to stakeholder groups in Figure  8-2. Of  all the organisations  that provided  input, 
replies  to  the  questionnaire  were  received  from  two  organisations,  each  from  two 
representatives.419  

Figure 8-2  Answer to the question “I am giving my contribution as: …” (multiple 
options)  

22

15

19

Trade union

Public authority

Other

Non-governmental organisation
(NGO)
EU citizen

Ergebnis

Environmental organisation

Consumer organisation

Company/business organisation

Business association

Academic/research institution

6

7

2

1

3

67

66

0

10

20

30

40

50

60

70

80

A total of 57 stakeholders submitted written contributions in addition to the answers to the 
consultation survey questions420. The contributions were first screened to identify the main 
issues that they addressed. The following figure shows how many of the written contributions 

419 Ministry of the Environment of the Czech Republic, and Galloo (a company from the dismantling and recycling sector incl. 
shredder and PST operators).  

420 One stakeholder submitted 2 times answers to the consultation adding two different written contributions.  

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referred to a number of specific issues that were also referred to in the OPC survey and give 
a first indication as to the aspects addressed by stakeholders in this format. 

Figure 8-3  Key words of main aspects discussed in the written contribution (n=58) 

30

25

20

15

10

5

0

Notes: (*) including recycled content target 
The category ‘other’ includes: Handling of hazardous components/waste (n=2); (Recycling of) EV (n=6); Remanufacturing; Annex I of the EU 
Directive 2000/53/EC; batteries in electric cars, carbon footprint requirement; role of insurances; ATFs: More controls over ATFs, illegal ATFs 
are more cheaper, but without environmental standards (n=3); ASR (Automotive Shredder Residue); batteries are way more heavy than in the 
ELVD stated; Removal of tyres, batteries etc.  
Source: own compilation  

The obtained answers to the questions were processed via Microsoft Excel, written input was 
summarized per topic. Find a summary of the results in section 8.5. The complete evaluation 
of answers to the open public consultation is among the material that was provided to the 
European Commission.  

Identical answers to the OPC were received from 

•  VFSE  Automotiv  WG  (organisation  size:  micro),  EuPC  Automotive  Division  (micro), 
PlasFuelSys  (micro),  PLASTIC  OMNIUM  -  CLEAN  ENERGY  SYSTEMS  DIVISION 
(large) 

•  Two different individuals of the Ministry of the Environment of the Czech Republic 
•  DEMONTA  Trade  SE  (organisation  size:  medium)  and  Czech  Association  of  Circular 

Economy (large) 

8.4.3  Targeted stakeholder consultation 

A targeted consultation (interviews) was held starting in November 2021. The phase was split 
into two rounds of interviews:  

•  The main study interviews held in the period from 03 November to 03 December 2021. 
In  this  round,  the  consultants  conducted  20  interviews,  see  the  list  of  interviewed 
organisations  in  Table  8-3.  One  additionally  invited  stakeholder  (ANEC  BEUC)  did  not 
participate  due  to  the  questions  being  too  technical  for  the  stakeholder  group  they 
represent.  The  group  of  stakeholders  that  participated  in  the  main  study  interviews 
consisted  of  automotive  manufacturers  for  cars,  trucks,  vans,  buses,  and  motorcycles 
(n=3), suppliers of materials and (second-hand) components (n=6), stakeholders involved 
in  the  EoL  management  (n=7),  and  individual  other  stakeholders  including  a  PRO,  a 

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• 

registration  and  international  authority  each,  a  stakeholder  representing  insurance 
companies, and environmental NGOs. 
Interviews  held  in  relation  to  the  3R  Type  Approval  Directive  in  the  period  from 
17 December 2021 to 07 February 2022. The invited group of stakeholders consisted of 
automotive  manufacturers  (n=5),  type  approval  technical  services  (n=3),  type  approval 
authority/  market  surveillance  (n=2),  international  authorities  and  one  stakeholder 
conducting dismantling trials. Inputs were obtained from 8 out of 12 invited stakeholders 
(a few per written contribution only), see Table 8-4. 

The consultation phase was organised as follows: The interviews were distributed internally 
according to the focus of the respective associations or stakeholders and the work focus of 
the  experts.  The  interviewees  were  initially  contacted  indicating  the  goal and  scope  of  the 
study. When no answer was received, reminders were sent. Date and time for the interview 
were agreed on and consultants provided a web conference tool. An interview guideline was 
sent  to  the  stakeholders  in  advance  of  the  meeting.  Due  to  the  extent  of  the  main  study 
questionnaire, it was accompanied by an indication of the sections to which the study team 
expected  the  interviewed  stakeholder  to  contribute  (see  Table  1-1).  Other  sections  were 
included for transparency, and the interviewees could also contribute to the questions therein. 
Often, answers were received with specification of topics of interest for the stakeholders. In 
some cases, stakeholders responded to topics additional to those planned for the interview 
(not displayed in Table 1-1). Only in some cases, the whole questionnaire was subject of the 
interview. Protocols of results were prepared after the interview and sent for approval to the 
respective interview partner. Together with the approval, consultants asked for the permission 
to  cite  answers  given  in  the  interview  in  the  study  report.  If  rejected,  information  was  not 
included in the report.  

Table 8-3  Stakeholders invited to main study interviews, and indication of the 
sections to which the study team expected the interviewed stakeholder to contribute  

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x 

x 

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x 
x 

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x 
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x 

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Table 8-4  Stakeholders invited to interviews held in relation to the 3R Type Approval 
Directive 

#  Organisation name 

1 

United Nations Economic Commission 
for Europe (UNECE) 
Kraftfahrtbundesamt (Germany) 
2 
3  Ministère de la Transition écologique 

4 

5 

6 
7 
8 
9 

10 

France 
European Automobile Manufacturers’ 
Association (ACEA) 

BMW (manufacturer) 

VW (manufacturer)  
Porsche (manufacturer) 
Stellantis (manufacturer) 

TÜV Nord (Type approval technical 
service) 

IDIADA (Type approval technical 
service) 

11  Tech4You (operators of IDIS; 

dismantling trials) 

12  UTAC (Type approval technical 

service) 

Input 
provided  
Yes 

No 
Yes 

Yes 

No 

Yes 
Yes 
Yes 
No 

No 

Yes 

Yes 

Details of contact 

Aspects of 3R type approval covered under the 
interview in the ELVD IA main study 
Contacted but did not respond 
Interview held on 27.12.21 

Written input provided on 07.02.22 

No answer to various attempts to schedule an 
interview (contacted 10.12.21, reminder sent on 
27.1. and 10.02.22) 
Interview held on 14.01.22, with Porsche 
Interview held on 14.01.22, with VW 
Interview held on 17.12.21 
Scheduled interview was cancelled by TÜV 
Nord, alternative contact details were sent 
without a response when requesting to 
reschedule the interview 
Written input promised, questionnaire sent and 
response requested by mid-January, reminders 
sent on 27.1. and 10.2.22. No answer obtained.  
Interview held on 07.02.22 

UTAC provided additions to the Ministère de la 
Transition écologique, France 

See the positions of stakeholders mentioned in chapter 8.5. 

Approved interview documentations were gathered and distributed within the study team in 
order to use input of all interviews for developing the measures in further detail and assessing 
related impacts. The input from the targeted consultation has been taken into consideration 
for  the  preparation  of  initial  results  and  the  development  of  initial  measures  that  were 
presented  at  the  sectoral  stakeholder  meetings  as  well  as  the  MS  meeting  (see  sections 
below). 

Though in most cases stakeholders gave their consent to cite information provided through 
the interviews, confirmed interview documentation is not intended for publication itself. The 
documentations are among the material that was provided to the European Commission.  

8.4.4  Survey in relation to 3R Directive 

A 3R-Directive-specific survey was conducted with stakeholders on this subject in proximity 
to  interviews  (see  section  before).  The  survey  was  developed  similarly  to  the  interview 
questionnaires for consulting three different stakeholder groups: OEMs, technical services, 
and type approval authorities. For all three groups, questions on the link to the ELVD, on the 
process of type approval and on possible future amendments were identical, a stakeholder 

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group-specific set of questions was added to each one. The questionnaire was agreed on 
and is available to the European Commission.  

The survey was distributed to OEMs through requesting the association ACEA to send the 
survey  questionnaire  to  its  members.  The  European  Commission  assisted  in  sending  the 
questionnaire to type approval authorities. The survey was also forwarded to type approval 
technical services that had been initially identified but not interviewed. 

Four Member States participated (3 provided the filled-out survey, 1 provided short input per 
email), and one OEM send a confidential contribution. Additional information was received 
from three more organisations/stakeholder groups  

•  one position paper (from ACEA),  
•  one interview in the main study was used to get specific information on the 3R Directive 

(UN ECE/UNEP), and 

•  one  e-mail  with  additional  explanatory  information  was  received,  in  relation  to  the 
information  provided  in  one  of  the  specific  interviews  (from  MS  representatives  from 
France).  

In the round of written feedback in April 2022 (follow-up after the workshop in March 2022), 
a further written contribution from Germany was received.  

Based on the indication of a lot of stakeholders, most of the information cannot be cited in 
this  report  as  information  has  been  provided  on  a  confidential  basis  or  interview 
documentations have not been confirmed by interviewees.  

The positions of stakeholders are summarised in chapter 8.5.6. 

8.4.5  Stakeholder Workshop on 23/24. March 2022 

In cooperation with the Commission, the contractor prepared the stakeholder workshop and 
the Member States meeting (see the chapter on “consultation of MS” below). All meetings 
were organised as web conferences which were hosted by the consultants. In cooperation 
with the EC, the consultants prepared the agenda and an invitation letter, and the EC invited 
participants.  Stakeholder  contacts  from  the  targeted  consultation  were  provided  by  the 
consultants.  Further  selection  of  invitees  was  done  by  the  European  Commission,  e.g., 
participants of the open public consultation. Associations were invited, but, in comparison to 
the targeted consultation, more individual companies were present. The contractor prepared 
material  to  inform  participants  on  the  contents  of  the  meeting  which  were  send  around  to 
invited stakeholders beforehand. At the meeting, the contractor gave an input (presentation) 
on the current situation in relation to the problems, the measures under consideration, initial 
results, and topics for discussion.  

The  meetings  were  structured  according  to  the  topics.  The  agenda  is  provided  below. 
Meetings were facilitated by the consultant’s team members; minutes were prepared of each 
meeting. 

Table 8-5  Agenda of the stakeholder workshop 

EC: Welcome 

Day 1 - THU 23.03.2022 
9:00-
9:15 
9:15-
10:45 

Current situation + measures 
for Design/Reuse + 
Remanufacturing/Recycling 

  Day 2 – FRI 24.03.2022 

Presentation  

Presentation by 
the consultants, 
clarification 
questions 

9:00-
9:15 
9:15-
10:45 

EC: Welcome 

Current situation + measures 
+ analysis + first results for 
Recycled content - JRC 

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Presentation, 
clarification 

questions +  

Discussion 

 
 
 
  
 
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11:00 
-12:00 

Analysis method + first 
results for Design/Reuse + 
Remanufacturing/Recycling 

12:00-
13:00 

Discussion on Design/Reuse 
+ 
Remanufacturing/Recycling 

14:00 
-15:30 

15:45-
16:45 

16:45-
17:15 

Pre-conditions for Design/ 
Reuse + Remanufacturing/ 
Recycling: EPR + Access to 
Information (current situation 
+ measures + analysis + first 
results) 

Due diligence;  
Hazardous substances;  

NdFeB magnets.  
Overarching aspects 

Presentation by 
the consultants, 
clarification 
questions 
Discussion  

Presentation  

Discussion 

11:00 
-13:00 

14:00 
-15:45 

16:00-
16:30 

Current situation + measures 
+ analysis + first results and 
discussion for Missing 
vehicles + illegal exports 
Current situation + measures 
+ analysis + first results and 
discussion for Scope 

Wrap up for each objective 

Presentation, 
clarification 

questions + 

Discussion 
Presentation, 
clarification 

questions + 

Discussion 
Presentation  

Presentation  

Discussion  

16:30-
17:00 

Outlook - EC 

Presentation 

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Figure 8-4  Overview of composition of stakeholder registered* for the workshop 
(n=289) 

3 3

17

6

8

8

61

19

8

19

57

35

45

Automotive manufacturer

Associated industry

EoL management

Authorities (Env)

Authorities (Transport)

Authorities (other)

Automotive supply chain

Environmental NGO

Research

EPR/PRO

Consumer/privates

Insurance

Other/unknown

Note: The category of ”automotive manufacturers” includes manufacturers of all types of vehicles, incl. motorcycles, vehicles accessible to 
disabled people, caravanning industry, to name some. / The category of ”associated industry” includes, among others, all (secondary) raw 
material-related industry stakeholders. / (*) The numbers relate to the registrations for the workshop. Due to changing audience during and last 
minute requests before the workshop, it was not possible to analyse the composition of stakeholders in relation to their actual participation. 
Source: Own compilation 

Possibilities of participation in the meeting:  

•  To  gather  input  from  a  larger  audience  of  stakeholders,  and  additional  interaction  tool 
(app called Slido) was used during the workshop to survey the views of the participants 
on certain aspects. Slido questions were answered by participants in the course of the 
presentations of the consultants or in the days following the workshop. 

•  For oral contributions, stakeholders could write in the chat the essence of their comment 

and wait to be requested to speak.  

•  After the workshop, all participants had two weeks to submit additional information and 

data to substantiate their views (see section 8.4.7) 

A summary of discussed aspects per topic can be found in the summary of key positions of 
stakeholders in section 8.5.  

For each of the topics, the consultants took into account aspects that were discussed in the 
meetings,  and  where  (updates  of)  data  was  provided,  e.g.,  in  relation  to  the  material 
composition of L-type approved vehicles, these were feed into the calculation of impacts for 
the final report. 

The parts of the documentation of the stakeholder workshop not intended for publication and 
provided solely to the EC include: 

•  Participants list; 
•  Minutes of the meeting; 
•  Documentation of the chat of the online meeting; and 
•  Slido results. 

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8.4.6  Consultation of Member States 

The consultation of MS consisted of two elements: 

a)  Adhoc survey 

A questionnaire for Member State Experts was prepared covering the four topics:  

•  Management of Shredder Light Fraction (SLF) and Shredder Heavy Fraction (SHF),  
•  Fees or taxes to support recycling of ELVs,  
•  Enhanced Producer Responsibility (EPR) System,  
•  Waste management of other types of vehicles. 

The questionnaire was sent out to the MS in February with most MS sending answers prior 
to the workshop, and a few (2-3) sent afterwards . Answers to the questionnaire were provided 
by  15  MS,  namely  Lithuania,  Belgium,  Ireland,  Estonia,  Slovakia,  Greece,  Malta,  Finland, 
Croatia, Spain, France, Czech Republic, the Netherlands, Sweden, and Germany. Additional 
documents were received from Belgium only.  

As for the processing of the data, it is to be said that no statistical evaluation of responses 
was made, but responses are exemplarily summarized for two of the four topics as follows. 
Where  information  from  the  survey  is  used  in  the  main  report,  it  is  referenced,  and  all 
questionnaires are available to the EC. 

Management of Shredder Light Fraction (SLF) and Shredder Heavy Fraction (SHF). In 
6 MS, the disposal of untreated SLF/SHF in landfills is prohibited. 4 MS prohibit the disposal 
in landfills of fractions from post shredder treatment (PST). 4 MS (in case of BE only Flanders) 
allow to consider untreated SLF for the purpose of road construction, within which 3 consider 
it  as  recycling.  Selected  detailed  responses  showed  that  some  countries  defined  certain 
criteria for acceptance of waste at the landfill that have to be fulfilled (e.g., POP content in the 
residues or that the residues intended to landfill cannot be recycled of incinerated anymore). 
BE  (Flanders)  allows  the  disposal  in  landfills  of  fractions  from  PST,  however  the  costs  for 
disposal are higher than the costs for recycling or thermal treatment. Some countries admitted 
that due to a disposal ban in their countries the recycling rates of ELVs increased.  

Waste management of other types of vehicles. In ES, FR, CZ, BE (Flanders), and LT the 
waste management of motorcycles is governed by specific national legislation? This is not 
the case in SK, EL, MT, FI, HR, NL, DE, SE, and IE. In ES, CZ, BE (Flanders), and LT waste 
management of trucks is governed by specific national legislation. This is not the case in SK, 
EL, MT, FI, HR, FR, NL, DE, SE, IE. Of those that do not have specific national legislation, 
several countries (HR, FI, EL, NL, DE) indicated that the treatment of motorcycles and trucks 
is ensured and/or environmental permits for facilities are requested through general waste 
legislation.  Additional  information  on  waste  management  of  other  types  of  vehicles  was 
provided by 4 MS (LT, BE, CZ, DE). 

b)  Member State Workshop on 31. March 2022 

the  Commission, 

In  cooperation  with 
the  contractor  prepared  a  Member  State 
Representatives workshop in addition to the stakeholder workshop (see above). The meeting 
was organised as web conferences which was hosted by the consultants. In cooperation with 
the  EC,  the  consultants  prepared  the  agenda  and  an  invitation  letter,  and  the  EC  invited 
participants. The same material as for the stakeholder workshop was distributed among MS 
representatives  to  inform  participants  on  the  contents  of  the  meeting  beforehand,  also, 
representatives  of  the  MS  were  invited  to  participate  in  the  stakeholder  workshop.  Thus, 
assuming that MS representatives could inform themselves in the stakeholder workshop as 
well  as  with  the  provided  information,  at  the  meeting,  the  contractor  gave  a  very  short 

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additional input (presentation) the problems, the measures under consideration, and topics 
for discussion.  

The meeting was structured according to the topics. Additional three presentations were held 
by Member State representatives from France, Belgium, and the Netherlands. The agenda is 
provided in Table 8-6. Meetings were facilitated by the consultant’s team members; minutes 
were prepared and provided to the European Commission. 

Table 8-6  Agenda of Workshop with Member State Representatives 

9:00-9:30  EC Welcome Mattia Pellegrini (DG ENV), Mark Nicklas (DG GROW), Jade Vetters (DG 

GROW) 

09:30-
09:55 

09:55-
12:30 

13:30-
14:30 
14:30-
15:50 

French EPR Scheme Project for ELVs FR Ministry of Ecology, Sustainable Development and 
Energy: Bruno Miraval 

Objective 2: Circularity: Short presentations by the consultants, clarification questions and 
discussion-Moderation by Gael de Rotalier 
Point 2.1 -Design, Oeko: Yifaat Baron 
Point 2.1.g: -Recycled content targets for plastic, JRC: Thibault Maury 
Point 2.2 -Reuse, Oeko: Izabela Kosińska-Terrade 
Point 2.3 -Recycling, Oeko: Izabela Kosińska-Terrade 
Point 2.4 -Transparency and fair distribution of costs, Mehlhart Consulting: Georg Mehlhart 
Point 2.5 -Hazardous Substances, Oeko: Katja Moch 

Objective 1: Scope: Short presentation by the consultants, clarification questions and 
discussion (Oeko: Clara Löw)-Moderation by Jaco Huisman 
Objective 3: Missing vehicles: Short presentation by the consultants, clarification questions and 
discussion -Moderation by Jaco Huisman 
Point 3.1 -Vehicle tracking; Mehlhart Consulting: Georg Mehlhart 
Point 3.2 -Illegal dismantling and illegal exports, Mehlhart Consulting: Georg Mehlhart 
Point 3.3 -Criteria to prevent export of ELVs. Short presentation by the consultants, clarification 
questions and discussion, Mehlhart Consulting: Georg Mehlhart 

The Netherlands approach on exchange of information on vehicle registration with the example 
of EUCARIS, NL Vehicle Authority: Idske Dijkstra  

How Missing ELVs are addressed in Belgium (Flanders) through defined recognition criteria, 
BE The Public Waste Agency of Flanders (OVAM): Lies Verlinden 

15:50-
16:00 

Outlook-EC 

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Table 8-7  Overview of composition of Member State representatives registered* for 
the workshop 

Austria 

Belgium 

Bulgaria 

CROATIA 

Czech Republic 

Cyprus  

Denmark 

España 

Estonia 

Finland 

France 

Greece 

Germany 

Hungary 

Ireland 

Italy 

  Latvia 

  Lithuania 

  Luxembourg 

  Malta 

  Netherlands 

  Poland 

  Portugal 

  Romania 

  Slovakia 

  Slovenia 

  Sweden 

2 

4 

2 

2 

3 

0 

2 

1 

4 

5 

4 

0 

9 

2 

4 

6 

2 

2 

3 

2 

6 

1 

0 

2 

3 

1 

4 

(*) The number relate to the registrations for the workshop. Due to changing audience and last minute changes during the workshop, it was not 
possible to analyse the composition o stakeholders in relation to their actual participation. 

8.4.7  Follow-up after the workshop and ad-hoc consultation 

Discussions during the stakeholder workshop left open several questions and stakeholders 
were  asked  to  provide  information  on  certain  topics  at  the  end  of  each  meeting.  A  list  of 
associations  and  stakeholder  groups  that  submitted  additional  input  after  the  sectoral 
meetings is given below.  

List of stakeholders sending input after the workshop (n=39) 
•  ACEA/HDVs 
•  ADA 
•  Ademe 
•  BASF 
•  BMW 
•  CLEPA 
•  Copper Alliance 
•  Derichebourg Environment 
•  ECOEURO 
•  ECOS 
•  EEB 
•  EGARA 
•  Estonia (MS) 
•  ETRMA 
•  EuRIC 
•  EUROBAT 
•  EU Aluminium 
• 
FEDEREC 
• 
FEAD 
• 
FNA 
• 
FNADE 

•  Galloo 
•  German UBA (MS DE) 
•  German BMUV (MS DE) 
•  Glass4Europe 
•  Holger Luehn 
• 
INDRA 
• 
JRC 
•  Milan Lauko 
•  Mobilians 
•  OVAM (MS BE) 
•  PGM 
•  PRE 
•  Plastics Europe 
•  POCES 
•  Renault 
•  RWD (MS NL) 
•  Sweden (MS SE) 
• 
• 

TERRA 
Thomas Gardin 

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plus one stakeholders that wished to remain anonymous. 

In addition to other consultation stages, several stakeholders were consulted individually in 
terms  of  specific  aspects  of  interest  for  the  consultants.  A  list  of  individually  consulted 
stakeholders and the topic on relation to which they were contacted is provided below. The 
information provided was used for the impact analysis of measures and policy options. 

Table 8-8  Ad-hoc consultation of specific stakeholders 

Stakeholders 
contacted ad-
hoc 
ADEME 
German UBA 

Contacted 
Person 

Eric Lecointre 
Regina Kohlmeyer 

EURIC / Galloo  

Olivier Francois 

EGARA  

Henk-Jan Nix  

EUROFER 
UNEP 

Lubor Kalafus 
Francois Cuenot 

EU Aluminium 

MS 
representatives of 
Spain, France, 
Czech Republic, 
Belgium/Flanders, 
Lithuania, Italy 

Benedetta Nucci 
Patrik Ragnarsson 
Christian Leroy 
Fernando J. Burgaz 
Moreno, Bruno 
Miraval, Katerina 
Dostalova, Lies 
Verlinden, 
Kauzonas 
Mindaugas, Letteria 
Adella 

Contacted in relation to specific topic/s 

to 

recycling. 

Identify 
impacts  of 

Material composition of L-type approved vehicles 
Calculation of end-of-life trucks based on the Eurostat stock data 
Exchange about an UBA report in publication: Impacts of illegal 
the  environmental, 
end-of-life  vehicle 
economic  and  business 
the  unrecognized 
dismantling of end-of-life vehicles and the illegal transfer of end-
of-life  vehicles  and  derive  measures  to  address  potential 
impacts. 
Exchange  of  documents  related 
the  STAKEHOLDER 
WORKING  GROUP  ON  THE  REVISION  OF  2015  REUSE/ 
RECOVERY/RECYCLING  TARGETS  MINUTES  FROM  THE 
PLENARY MEETING OF 17 OCTOBER 2005 on the targets and 
alternative approaches.  
Regards existence and characteristics of EPR schemes across 
EU 
Regarding post-shredder technologies across the EU 
Copper impurities in steel  
About  an  international  initiative  to  define  and  develop  an 
internationally  unified  method  for  carbon  life  cycle  analysis 
(LCA) 
About the average weight of aluminium bumper carrier frame for 
the purpose to calculate the GWP for different bumpers. 

About  MS  specific  legislation  for  waste  management  of 
motorcycles  and/or  trucks,  e.g.,  on  evaluations  on  changes  in 
the material flows of waste powered-two-wheelers / motorcycles 
or waste trucks and/or assessments of the ecological, economic 
and/or social impacts of this regulation at national level 

8.5  Key positions of stakeholders on specific topics 

8.5.1  Circularity  

Design for circularity 

Statistical OPC 

On  the  question  if  there  should  be  an  obligation  on  vehicle  manufactureres  to  improve 
circularity  characteristics  of  a  vehicle  during  the  design  phase,  all  groups  of  stakeholders 

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agreed in over 50% to this question. Support was the lowest (51 %) in the category of the 
automotive manufacturers, where almost 25% did not support this option. The highest support 
was  registered  by  environmental  NGOs  (100%),  waste  management  operators  (93%)  and 
public authorities (86%).  

For more details please refer to ”Analysis of open public consultations” (Oeko-Institut e. V. 
2022). 

Written OPC 

Ten contributions mention the topic of (eco-)design specifically. One of the focus topics is the 
design for dismantlability which various stakeholders would like to see promoted through the 
new  regulation (VEOLIA,  EEB,  Federec,  INDRA,  FNADE)  whereas  others  have  objections 
such as:  

‘life cycle approach more efficient to promote circularity than imposing design requirements’ 
(Volvo); 

‘dismantling provisions must not impair the essential targets of safety, comfort, environmental 
performance such as fuel/electricity consumption, costs etc’ (Plastics Europe); and  

‘solutions on eco-design therefore should not be solely based on manual separation/sorting’ 
(EuRIC) stating that PST sorting should be taken into account.  

Design  for  circularity  could  be  supported  by  sensor-based  technology  (ECI)  and  free 
knowledge sharing and discussion between recyclers and manufacturers (EuRIC, FNADE; 
see also under ‘data availability’). 

Eco-Design is mentioned in combination with the 3R Type Approval Directive by EuRIC in 
terms of merging ELVD and 3RD; and by Federec and INDRA with regards to ‘practicability 
checks’ of recyclability under the 3R Type approval. Volvo suggests that ‘ELVD should focus 
instead on requiring OEMs to have a strategy to cover the 3 Rs’, which is already part of the 
provisions of Art. 6 of 3R Type Approval Directive.  

Another focus is on the means of eco-design to phase out hazardous substances mentioned 
by VEOLIA. Other stakeholders mentioned hazardous substances under the topics of ‘data 
availability’, in combination with recycled content targets or with regards to ‘coherence’.  

Individual aspects include ethical sourcing as part of material decisions in eco-design (ECI), 
less different polymers (‘there are currently 39 different 1types of basic plastics and polymers 
used to make an automobile’, and a proposal from FEAD to limit the use of non-recyclable 
materials based on The Plastics Industry Trade Association, 2016). 

It  should  be  noted  that  in  their  contributions  some  stakeholders  consider  recycled  content 
targets as part of the 3R targets, and some connect the recycled content targets with the topic 
of (eco-) design.  

Interviews 

Regarding non-recyclable materials, the vehicle manufacturing sector generally pointed out 
the benefit of using such materials for light weighting due to the benefits during the use phase 
in terms of emissions reduction. Stakeholders representing the waste phase referred to the 
obstacle that  large  amounts  of  such  materials raise  for  achieving targets  but  were  against 
their  prohibitions,  explaining  that  this  would  affect  innovation,  whereas  proven  materials 
would increase in use and at some point suffice to develop manufacturing (with less beneficia 
ones being used shortly and then abandoned). 

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ATFs referred to the phenomenon of locking components with digital keys (e.g., window wiper 
motor, injector, inverter, mirror, window motor, navigation, etc.) as a problem, explaining that 
it is an obstacle for reuse as a component removed without the key will not be reusable. The 
information does not have to be free, but the price should not be prohibitive for reuse practices 
of ATFs. This is understood to particularly affect establishments that work with multiple vehicle 
models and brands and that do not have contract with specific OEMs. Vehicle manufacturers 
on the other side claim that the locks are of importance for the safety of vehicles, anti-theft 
and provision of the data could disclose proprietary. It is not clear what type of data would be 
at risk. Components that are interchangeable between models and brands were also raised 
as  a  type  of  component  where  OEMs  are  reluctant  to  provide  data  (e.g.,  when  the  same 
supplier provides multiple vehicles models and brands with the same component) an where 
this can have an effect on the ability to reuse parts.  

As for IDIS, ATFs said that it contained a lot of information but that the level of detail is not 
always sufficient to support dismantling. Information is not available through IDIS for parts 
with reuse potential (the objective of IDIS is to support quick dismantling – ensuring that the 
component remains functional  is  not  always  in  line  with this  objective).  Though OEMs say 
that such data can be accessed under the RMI (Repair and maintenance information systems 
of the OEMs – each is individual to a certain OEM) ATFs complain about the cost of such 
data.  Here  too,  the  information  does  not  have  to  be  free,  but  the  price  should  be  fair  to 
encourage dismantling for reuse.  

Some stakeholders state that the 3R Directive calculation is too theoretical, recommending 
requiring OEMs to also specify how certain parts can be dismantled. The calculation should 
also reflect the ease or difficulty of recycling a part depending on whether it is a mono-material 
of not.  

Workshop  

During  the  workshop  the  issue  of  compliance  of  automotive  manufacturers  with  diverse 
regulations  was  brought  up  (ACEA).  Thus,  new  regulations  should  consider  the  other 
compliance  demands,  in  particular  for  passenger  safety  and  environmental  protections. 
Vehicles  typically  comply  the  existing  regulations  on  the  day  that  they  are  brought  to  the 
market. The changes in regulations that happen during the vehicle lifetime can be covered by 
post-shredder technologies. 

The  idea  to  combine  the  ELV  aspects  from  the  ELV  Directive  and  the  3R  Directive  into  a 
single regulation was also encouraged (ECOS). Additionally, it was proposed to bring the EU 
ELV  legislation  to  the  level  of  the  United  Nations  when  looking  at  lifecycle  provisions 
(UNECE).  

Definitions 

Statistical OPC  

Most  stakeholders  (56%)  agreed  or  agreed  strongly  that  the  ELV  definition  for  recycling 
should be aligned to that of the WFD as this would support a higher level of material recovery. 
Aside from the automotive producers that were mainly neutral, the majority in all stakeholder 
categories supported an alignment. Only 3% disagreed with this statement, however there 
was also a large share of stakeholders that were neutral (40 individuals) or that did not have 
an opinion (31 individuals) making for a total of 40% together with those that did not specify 
an answer (13 individuals). 

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Status of parts to be recycled/remanufactured must be clearly distinguished from waste and 
benefit from same conditions as spare parts. EU should establish a harmonized definition of 
waste and non-waste for reuse/remanufacturing purpose. 

Written OPC 
Coherence with the WFD is referred to in a general way (WEEE AUDITS; CRM Alliance) or 
by pointing out specific needs, e.g., to exclude backfilling from the definition of recycling 
(FNADE) or the need for harmonized definitions of waste and recycling in order to prevent 
distortions of competition due to different national implementation (FORS). Also, 
consistency with the landfill directive is mentioned (Plastics Europe). Definition of when a 
car becomes an ELV was also raised (Febelauto) also in the context of vehicles export 
(FEDEREC), where it should be required to present a valid technical control certificate to 
authorize their export. 

Interviews 

It  is  generally  agreed  that  the  definition  of  recycling  should  be  aligned  with  the  WFD  to 
exclude backfilling. Many stakeholders do not expect that this will change the achievability of 
the  3R  targets  as  backfilling  operations  are  not  so  common  and  does  not  cover  all 
downcycling  operations.  This  is  particularly  understood  to  be  relevant  for  glass,  which  is 
mainly considered recycled through the post-shredder mineral fraction.  

The  need  to  align  the  definition  of  reuse  with  the  WFD  was  raised  in  relation  to  the  later 
reference to ”preparing for reuse”. Changes to the definition could affect what is considered 
waste and what is considered a product and need to look into how they work with the definition 
of  ”end-of-waste”  to  ensure  that  obstacles  are  not  created  for  shipments  of  used  or 
remanufactured  parts.  A  definition  for  remanufactured  components  should  also  be 
introduced to strengthen how such parts are perceived in comparison to reused ones and to 
ensure that remanufacturing practices fulfil minimum requirements.  

A few stakeholders raised the need to define ELVs as compared to second hand vehicle so 
that the differences between these two categories is clearer and easier to enforce for customs 
to prevent illegal exports. 

Workshop  

As  shared  by  a car  manufacturer  representative (Renault), the  current  legal  definition  of  a 
new  product  does  not  allow  inclusion  of  remanufactured  parts.  This  means  that  a  new 
vehicle currently, in legal terms, may not contain remanufactured elements; the entire vehicle 
must be made new, though perhaps using recycled materials. This legal issue is not specific 
to vehicles. However, from a technical perspective, remanufactured vehicle parts are certified 
as  equivalent  in  functionality  and  reliability/safety/etc.  to  new  parts  and  could  therefore  be 
acceptable for use in new vehicles. This legal limitation restricts the sale of remanufactured 
vehicle  parts  to  the  repairs  market.  Also,  there  is  anyway  a  limited  feedstock  of 
remanufactured parts because the long vehicular lifetime means that the current ELVs do not 
offer many parts for remanufacture. Additionally, the term and definitions of remanufactured 
parts should be included in the 3R Type-approval Directive.  

A definition of differentiating between pre- and post-consumer plastics would be helpful as 
well as applicable definitions of ‘open-loop’, ‘closed-loop’, etc. 

In Belgium, each total technical loss means the vehicle is an ELV, regardless of the price of 
repair in the home country or elsewhere. However, total economic loss is not considered in 

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the definition of an ELV; such vehicles may be exported from Belgium as damaged vehicles 
without any special conditions. 

Separate Reuse target 

Statistical OPC 

46% of the participants either agreed or strongly agreed with the implementation of a reuse 
target separately from the recycled target. This included all environmental NGOs, most waste 
operators (53% of the category) and most public authorities (68% of the category). 22% dis-
agreed or disagreed strongly with this option, with the automotive manufacturing sector most 
often providing these answers (51% of the category). 

On the question on which measures would contribute to increase the reuse of vehicles parts, 
the most common answers were: obligation for repair shops to offer customers used spare 
parts  as  an  alternative  to  new  ones,  obligation  for  ATFs  to  remove  certain  parts  of  ELVs 
before shredding to help increase reuse, obligation for car manufacturers to enable (e.g. the 
ATFs)  unlocking  parts  so  that  they  can  be  reused  and  dismantle,  and  obligation  for  car 
manufacturers to provide the dismantling centres (ATFs) information about which parts can 
be used as identical parts in other models of the manufacturer or even other brands. 

Written OPC 

When asked to explain their views, the more common views in support of a separate reuse 
target were that reuse is higher up in the EU waste hierarchy than recycling, also supporting 
circularity. Others explained that before a part is recycled it could be reused. Specific targets 
were explained to allow monitoring reuse, in relation to the “quantity of pieces reintroduced in 
the market” (an indicator of eco-design, and percentage of reuse and repairability) and as an 
indicator of the “efficiency of treatment operations of the authorized centres”. 

Of  those  that  disagreed  with  such  measures  it  was  explained  that  reuse  was  mainly 
economically motivated (if no one needs a particular spare part it’s better to recycle). Though 
reuse was stated to be important, as reuse is market driven it was questioned if targets would 
increase the amount of reuse. It was also said that vehicles that are recycled are often too 
old (20 years) for re-use of parts as well as mentioning that this was also the case for vehicles 
after  a  crash.  Though  reuse  is  said  to  be  practiced  commonly  by  ATFs,  one  stakeholder 
explained that it may not be reported to “avoid reporting taxable income in the ATFs”. 

Additionally,  separate  reuse  target  worsening  quality  and  safety  risks  witnessed  in  the 
informal refurbished vehicles market. Reuse and recycling should be considered as on par 
equivalents if separate targets for each were to be created. 

Interviews 

Regarding  reuse,  many  stakeholders  spoke  against  the  idea  of  separate  targets  for  reuse 
and recycling, explaining that fulfilment of the one may have negative effects on the other. 
Obligatory dismantling to promote the reuse of parts was explained to create significant costs 
while not esurient the level of reuse would actually increase. ATFs explained that they need 
flexibility to look at the demand on the market and respond through deciding what components 
to  reuse  and  which  ones  not  to.  This  was  due  to  fluctuations  in  the  demand  for  reused 
components but also in the quality of components of some models. The example was given 
(EGARA) of the engine, where some models may have frequent malfunctions, in which case 
ATFs would avoid their reuse as a minimum guarantee could not be ensured. In some models, 
malfunctions  are  very  rare,  so  that  dismantling  for  reuse  would  result  in  the  engine  being 
stored  for  years,  also  creating  large  costs.  Rather  ATFs  explain  that  measures  should  be 

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considered that increase the demand for reused parts, with ATFs than following suit to ensure 
sufficient supply. 

Workshops 

Participants commented that decisions concerning remanufacturing are of high relevance in 
a circular economy, with such processes being essential for encouraging recycling. However, 
it is not recommendable to strictly consider reuse targets for aspects that may not have market 
options; ELV parts should not be required to be removed before shredding where there is no 
market for reselling such parts. It could be useful to consider environmental issues, market 
forces and overall demand in the recommendation. 

A  target  for  reuse/  remanufacturing  of  parts  could  potentially  be  helpful.  However,  it  is 
necessary to consider the traceability of parts to know which ones would at all be suitable for 
reuse (as opposed to remanufacturing). It can be noted that the age of a used part may be 
much younger than the vehicle in which it is found. Safety should in particular be considered, 
especially for parts relating to vehicle safety (Romania). 

Material specific recycling targets 

Statistical OPC 

The  most  common  answer  to  this  question  (31  participants  or  15%)  supported  that  the 
establishment of material-specific recycling targets would increase the separate recycling of 
materials addressed by targets, their quality and revenues from sale of such materials while 
also  increasing  the  costs  of  recycling.  12  %  (24  participants)  answered  that  this  would 
increase separate recycling and secondary material quality while also increasing costs. The 
same share of participants estimate that such targets would only increase the recycling costs. 
From  47  respondents  in  the  automotive  manufacturing  sector,  72%  (34  individuals)  stated 
that this would increase costs, while 51% (24 individuals) state that it would increase separate 
recycling of materials. An increase in separate recycling was supported by all environmental 
NGOs,  85%  (5  individuals)  of  which  also  supported  that  it  would  increase  the  quality  of 
recycled materials. Public authorities supported the four options similar, with between 15 and 
11  individuals  (68-50%)  indicating  the  various  options.  Waste  management  most  often 
indicated  that  this  measure  would  support  separate  recycling  of  materials  (71%)  but  also 
increase the costs (60%). 

The vast majority (64%) of stakeholders agreed that material-specific recycling targets have 
an  impact  on  innovation.  This  was  the  most  common  answer  in  all  stakeholder  categories 
with most categories showing 60-70% agreement. Only 8% were against this, while the rest 
did not have an opinion (23%) or did not answer (5%). 

The most common answer to this question was either no answer (79 individuals or 38%) or 
that material specific recycling targets would lead to an increase in high quality recycling, in 
innovative  recycling  opportunities  and  processes  and  in  innovative  eco-design  of  products 
(59  individuals  or  28%).  The  distribution  of  answers  was  quite  similar  among  stakeholder 
categories. 

Written OPC 

When asked to provide detail on answers, one stakeholder stated that “Targets for the entire 
vehicle proved to be effective. Splitting the target into different material-specific ones should 
be done only for improving the quality of recycling and the effectiveness of the directive. They 
should  not  be  legally  binding”.  Against  the  measure  it  was  said  that  ”some  materials  are 
recoverable but without any outlet / market”. 

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Materials mentioned in the context of specific material recycling were the Platinum Group Metals (PGMs). For 
glass and plastics, it was mentioned that the costs of recycling are higher than revenues while for electronic 
components it was assumed that revenues were possible. In some cases, it was stated that this would allow a 
greater separation of certain materials prior to shredding, like plastics. 

Stakeholders provided also further details on the question on ”how material-specific recycling 
targets would impact innovation” and introduced negative (e.g. documentation/monitoring will 
be  impossible:  volume  flows  in  tonnes  range,  versus  quantities  in  milligram  range  to  be 
documented; limits the use new materials, e.g., non-recyclables like carbon fibre composite, 
until a viable solutions has been developed and implemented in Europe) as well as positive 
sides (e.g.: increase of development of post-shredding technologies as well as processing 
technologies of secondary raw materials, increase use of secondary raw materials). 

Interviews 

the 

When asked about the option of introducing separate material targets for reuse, many stake-
holders  explained  that  it  was  difficult  to  comment  on  the  targets  proposed  as  whether  a 
specific  value  was  achievable  depended  on  how 
targets  were  measured 
(EUROMETAUX). If recycling is to be measured based on the actual material that is included 
in  the  composition  of  a  specific  vehicle  or  based  on  a  theoretical  value  would  make  a  big 
difference.  Whether  reporting  is  on  the  total  inputs  of  a  materials,  the  amount  sent  by 
operators for recycling or the amount that is actually recycled affects the achievability of a 
target. Also, for some materials like aluminium, there are big differences in the total content 
between models. Luxury cars will have higher amounts but are also more often exported, so 
that an average value may be difficult to fulfil. For steel it was explained that 90% is already 
achieved. The rate could be increased, however every marginal increase from this level will 
also increase the costs significantly. On tyres, views were raised that the market is still very 
much developing in terms of recycling options. Some outlets could be considered to increase 
the total recycling, but have low acceptability with MS (e.g., rubber turf for playgrounds and 
sport fields): 

Workshop 

Material-specific  recycling  targets  should  be  seen  as  an  addition  to  the  common  targets, 
which are applicable for different actors at different legislative levels. The MS mainly report 
data from dismantlers, shredders and ATFs, data which is collected from different points in 
the recycling process. Ultimately, the recycling quota of the MS is reported, not dismantling 
rates. (Swedish EPA). 

Recycled content targets 

For key positions of stakeholders on a recycled content target content for plastic please refer 
to the respective report by the EC Joint Research Center.  

Statistical OPC 

There was one question on other materials (other than plastic) for which a recycled content 
target  should  be  considered  in  the  OPC.  Though  a  few  materials  were  mentioned  in  this 
respect  by  about  a  third  of  stakeholders  (e.g.,  aluminium,  glass  mentioned,  REE  but  also 
PGMs and steel), a larger share of stakeholders (45%) did not provide input, indicating the 
answers ”none”, ”no opinion” or just skipping the question altogether. 

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Interviews 

Regarding recycled content for other materials, for most metals it was explained that recycling 
was already quite high, and that a recycled content target would not change this much but 
rather  create  competition  between  (high  quality)  uses,  which  will  not  result  in  resource 
savings. Recycled content targets should only be considered where there is a market failure. 
Positive  views  were raised  for  plastics  and  in  some cases  for  glass  and tyres,  where  high 
quality recycling is low and where SRM is less common for use in vehicles 

Data accessibility 

Statistical OPC 

In  the  OPC,  when  stakeholders  were  asked  to  specify  what  kind  of  information  producers 
should provide free of charge to ATF, a large number of stakeholders (41%) specified all of 
the available options, namely, information on: 

•  where  dismantled  components  can  be  reused  (which  vehicle  or  brands,  models  and 

types).  

•  how to correctly remove parts with digital components and how to appropriately prepare 

them for reuse/ installation. 
the duration / effort for obligatory depollution  
the duration / effort for dismantling components for reuse 

• 
• 

There was furthermore strong agreement (over 70%) that manufacturers should provide such 
information in a fair and non-discriminatory manner and at reasonable prices (if any) to all 
ATFs.  Stakeholders  were  also  asked to  indicate  whether  vehicle  manufacturers  should be 
obliged to provide information on the content of certain substance groups to support plastic 
recycling. Here there was a diversity of answers, with a third having no opinion, but also with 
large support for information obligations on flame retardants (66%), plasticisers (49%) and 
stabilisers (46%). 

Written OPC 

Stakeholders  emphasised  the  importance  of  access  to  information  on  vehicle  contents  for 
dismantling and safe treatment of vehicles. Though some stakeholders stressed the need for 
data at model level, in some cases mentioning IDIS. The option to develop a Digital Product 
Passport was also mentioned as well as the option to use a RFID or a QR code.  

Interviews 

ATFs raise the difficulties that they experience with the availability of various data types. IDIS 
was said to include a lot of information however stakeholders of this sector complain that the 
level of data is not homogenous for all models and makes and that the amount of data on 
how to dismantle specific parts is not always sufficient to support the process. Availability to 
data  on  components  that  are  locked  with  a  digital  key  is  problematic.  Though  data  is 
understood  to  be  made  available  by  OEMs  for  a  cost,  ATFs  explain  that  there  is  no 
harmonised  system  and  rather  that  ATFs  need  to  register  for  multiple  systems,  each  with 
separate  costs.  For  facilities  dismantling  vehicles  of  multiple  brands  (and  also  for  repair 
shops) this makes the use of such data prohibitive as the costs paid for access will depend 
on how often a system is accessed. Access to data on the contents of hazardous substances 
may be available through the SCIP data base, but this is not practical to support removal of 
relevant  parts  during  dismantling.  Data  is  not  available  as  to  the  contents  of  hazardous 
substance at the level of the specific component in a specific model (except data on mercury 

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in components that need to be removed or lead in Pb-acid batteries. This is a problem for 
example for substances that are prohibited by the POPs Regulation (e.g., DecaBDE) resulting 
in the need to send plastics with a risk of containing such materials to incineration as the level 
of content cannot be determined during dismantling for each material part separately.  

Workshop  

The concern was raised that if the method for making data available to ATFs is in the form of 
a digital product passport (DPP), that this would probably not all the 250 million vehicles on 
the road that will take several decades to be treated. Either ATFs would not have data for 
these or IDIS will have to continue working even if it is not any more the solution and no new 
information  is  introduced.  Also,  in  relation  to  the option  of  a  DPP,  it  was mentioned  that  a 
single system would need to be developed, rather than having multiple DPP for the vehicle. 

8.5.2  Hazardous substances 

Statistical OPC 

The OPC had two questions on hazardous substances:  

The first on whether the revised ELV Directive should ban hazardous substances in vehicles, 
taking  into  account  that  restrictions  on  hazardous  substances  are  also  specified  in  other 
pieces of EU legislation (notably REACH). 66 of the responding stakeholders (32%) were of 
the  view that  all  substances  in  vehicles should  be  regulated  in the future  under  chemicals 
regulation. The same amount indicated that substances prohibited under ELV should remain 
there, but that future prohibitions should be addressed under chemical legislation. In practice 
this  would  mean  that  for  future  prohibitions,  64%  of  stakeholders  would  prefer  regulation 
under chemical legislation than under ELV. Only 20% (41 individuals) were of the opinion that 
substances in vehicles should continue to be regulated under ELV. For waste management 
operators,  public  authorities,  environmental  NGOs  and  dealers  and  repair  shopped  the 
distribution  between  these  answers  was  similar.  Automotive  producers  had  a  stronger 
tendency  to  support  the  options  where  chemical  legislation  would  be  used  for  future 
prohibitions as opposed to the ELV Directive. The situation was similar for citizens and their 
organisations and “others”. Only 6% had no opinion or did not provide an answer. 

To the second question, which, if any, additional criteria for evaluating exemptions from the 
list of substance prohibitions are necessary to allow a more differentiated assessment, the 
answers were quite variable. This is however also due to the fact that 7 different criteria were 
proposed  as  possible  answers  aside  from  “none”  and  “other”.  Most  combinations  were 
indicated 1-2 times, in some cases having support of 6-9 stakeholders. The most common 
answers were to indicate all criteria (46 individuals or 22%), none (30 individuals or 14%), no 
answer (28 individuals or 13%) and the “Criterion on comparison of the use of the restricted 
substance with that of available substitutes in terms of environmental and health impacts (15 
individuals or 7%). All other combinations received less support. 

Asked to provide additional detail, stakeholders stated that: 

•  No  exemption  to  the  list  of  substance  prohibitions  in  the  ELVD,  except  for  limited 
transition,  if  needed.  Substances  meeting  the  criteria  for  CLP  &  SVHC  under  REACH 
should be banned. The ELVD should allow for additional chemicals to be banned, 

•  The  prohibitions  and  Annex  II  of  ELVD  needs  to  be  aligned  with  other  EU  legislations 

(REACH, RoHS, Batteries) concerning hazardous substances (3 stakeholders), 

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• 

impossible to give a "single" answer to this incredibly complicated question: as for flame 
retardant: you prefer the vehicle burn, or the people are exposed to a possible endocrine 
disruptor chemical? the answer is not technical, it is political (courage) 

Other criteria mentioned:  

•  CO2 footprint assessment (2 stakeholders), 
•  To  check  whether  the  use  of  the  substance  creates  a  risk  impossible  to  manage  or 

prevents recycling, 

•  Full life cycle consideration for the existing substance & substitute (2 stakeholders), 
•  Balanced approach for chemicals management, climate aspects and circularity (2 stake-

holders), 

•  Technical and economic feasibility (2 stakeholders). 

Interviews 

Many  stakeholders  when  asked  about  the  options  of  having  all  prohibitions  under  one 
legislation (ELV or REACH), did not really consider this option. Though certain stakeholders 
prefer  REACH  for  (further)  substance  restrictions  (material  suppliers  and  recyclers),  they 
explain that they would rather leave the exemptions for the four heavy metals under ELV as 
the review mechanism is already established. Vehicle manufacturers were the only ones that 
clearly favoured the alternative of having all restrictions under ELV. Though some general 
statements were made as to costs of the exemption process or the environmental benefit that 
accrued so far from the prohibition of the 4 heavy metals, these were not quantified or e.g. 
explained in relation to how costs break down in to specific activities.  

Written OPC 

with regards to the prohibition of hazardous substances, coherence with REACH and CLP 
are  mentioned  in  support  of  less  hazardous  substances  (Anonymous,  FNADE,  Swedish 
Government), reminding to the current obligation for reporting in the SCIP database to assist 
recyclers  with  understanding  if  SVHCs  are  present  or  not  is  also  relevant  here.  (FNADE; 
Plastics  Europe),  for  the  assessment  of  hazardous  substances,  uses  and  exposure  as 
established for the risk assessment under REACH should be considered (Plastics Europe). 
Some stakeholder raised very singular aspects. 

Workshop 

The discussion on the hazardous substances part was surprisingly vivid.  

Some  participants  stressed  in  the  chat  that  they  prefer  REACH  as  central  legislation  for 
substance  restrictions  because  REACH  became  a  robust  legal  instrument  and  that  this 
horizontal  legislation  should  be  referred  to  in  all  product  legislation  that  restrict  the  use  of 
substances due to risks. Also the coherence issue was noted to avoid different interpretations 
of legislative text or different content of definitions.  

On  the  other  hand  it  was  argued  that  so  far  REACH  restriction  is  however  barely  covers 
chemicals  in  products  as  until  now  this  only  appears  for  textiles  and  PAH  in  rubber.  A 
participant from NGOs claimed that substances that meet the criteria for SVHC under REACH 
and meet the CLP criteria should be prohibited in the new ELV Regulation for supporting a 
toxic-free environment policy purpose. Other participants however reminded that the "hazard" 
approach  does  not  sufficiently  support  “a  true  circular  economy”  as  contaminants  might 
always remain in materials that are however embedded in the solid material and no health 
problem occurs. For this reason, the participant reminded to the risk approach, with exposure 
scenarios, which, in the case of a vehicle is relatively easy to define.  

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Besides, various participants reminded the difficulty of the time span until vehicles reach their 
end-of-life that makes the information on chemicals difficult (“How should the recycler and the 
automotive manufacturer know if they can use the material in a new car?” – “If you start now 
a digital product passport etc. the result will (perhaps) be visible/useful in 20years.”) To solve 
this problem it was proposed to define specific exemptions not only for spare parts but also 
for recycling material. Participants argued that though this would not be in line with the aim of 
a non-toxic environment of CSS, there is a risk that material will not be recycled because of 
legal risk or additional burden, which makes the circular business unprofitable. 

8.5.3  Collection / Missing vehicles 

Statistical OPC 

That a charge applicable to the owner during periods of temporary de-registration would help 
ensure that owners follow their obligation to report any change of ownership or export to the 
authority  was  strongly  supported  by  environmental  NGOs,  waste  operators  and  public 
authorities. Only 11% were against this measure, mostly represented by consumers and their 
organisations  who  would  also  be  the  most  negatively  affected  by  such  a  measure.  A  vast 
majority agreed that better traceability should be established between the EU Member States’ 
registration  systems  on  a  legal  status  of  a  vehicle  until  its  final  deregistration.  Including  a 
roadworthiness test as a condition was considered by the largest number of stakeholders as 
an appropriate measure to overcome the problem of ‘illegal exports’ of ELVs and of exports 
of  ELVS  as used vehicles.  Compliance  with  certain  environmental  criteria  was the  second 
most favoured, followed by conditions on maximum age or on maximum mileage. Among 14 
different  options  for  reducing  the  number  of  missing  vehicles,  over  half  of  the  participants 
(52%)  indicated  a  combination  of  at  least  6  of  the  various  options  which  shows  the  high 
support for the implementation of additional measures to reduce the problems related with 
missing vehicles. A total of 46 participants (22%) did not provide an answer, 17 of which were 
from the automotive producing sector.  

Results of a stakeholder consultation held in the course of the study on the ELVs of unknown 
whereabouts (Mehlhart et al. 2017) can provide additional insights as to the pros and cons of 
the various options. Due to former public consultations on the aspect of vehicles of unknown 
whereabouts, exported vehicles and collection, this OPC did not put a strong focus on this 
topic,  but  only  asked  the  questions  summarized  above.  To  display  a  comprehensive 
stakeholder feedback on the topic, the OPC results from a study in 2016 can be found in the 
following box: 

Excurse: Open Public Consultation in 2016 
The `Public consultation on potential measures to improve the implementation of certain aspects of Directive on end-of-life 
vehicles, with emphasis on vehicles of unknown whereabouts´ was open for twelve weeks from 29 June to 21 September 
2016. 
The objective of this public consultation was to receive the views of stakeholders concerned with the topics of the 
consultation. 
The online survey covers 6 topics below: 
1. Keeping track of vehicles within the EU (intra EU trade); 
2. Methods to achieve more complete reporting on extra EU export and ways to distinguish between exporting ELVs vs. 
used vehicle; 
3. Enforcement techniques to reduce illegal dismantling of ELVs at dealers and repair shops (garages) and actions to 
improve ATF compliance; 
4. Public awareness and incentives for ELV tracking and environmental risks; 
5. Aspects to improve coverage and data quality when reporting on ELVs (possible revision of the Commission Decision 
2005/293/EC); 
6. Persistent Organic Pollutants (POPs) and ELVs. 

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According to the conclusion from the OPC in 2016421, "there is a broad and joint understanding among all stakeholders that 
the current procedures need further improvement to keep track of vehicles and to strengthen the requirement to issue and 
present a CoD. This applies for the provision of evidence on the vehicles fate during a temporary de-registration and also 
applies for fines to owners which do not provide statement of whereabouts for such temporary de-registered vehicles. 
Most of the stakeholder support the implementation of economic incentives for instance fees or refund systems to ensure 
that ELVs are delivered to ATFs. Only car manufacturers and importers oppose such economic incentives. 
With regard to the extra EU export of used vehicles (some of them possibly to be considered as ELV) the proposal to make 
Correspondents Guideline No 9 legally binding, many stakeholders oppose this proposal. Several stakeholders argue that 
the current version is difficult to apply and adjustments are needed before making the stipulations legally binding. Also, the 
approach to ban the extra EU export of used vehicles was not supported by the stakeholders. Instead, the stricter 
enforcement of inspections (when exporting) cooperation between IMPEL, police and customs services and the adjustment 
of reporting on waste shipment found strong support by all stakeholders. 
With regard to the fight against illegal treatment within the EU the majority of stakeholders acknowledged the need for 
action in particular the need for national/ regional authorities to perform regular inspections of the sector (not only ATF and 
shredders but with a broader scope for garages, repair shops and spare part dealers) to identify illegal operations. 
Comments expressed the concern that improved burden to ATF only might even cause adverse effects (more illegal 
operator) and inspections should carefully focus to support legal operating facilities. 
The proposal to establish minimum requirements for such inspection activities is less supported and partly rejected by the 
car manufacturers and importers. Again, proposals to establish economic incentives to strengthen the legally operating 
sector are opposed by the car manufacturers and importers. The proposal to improve the reporting mechanism when 
issuing a CoD and upon arrival of an ELV at ATFs or shredder facilities was in general supported, including the 
establishment of electronic notifications to the registration authorities. 
Supporting public awareness for the management of ELVs is considered as relevant by the stakeholders. While penalties 
to car owners not fulfilling their duties are supported by the vast majority of stakeholders, incentives based on funds/ 
deposits are again opposed by the car manufacturers and importers. 
With regard to the very specific questions how to address aspects of the unknown whereabouts in the Commission 
Decision 2005/293/EC the number of contributing stakeholders decreased slightly however beyond 100 contributors 
provided their option accordingly and supported effectively all proposals with a vast majority or at least did not oppose.” 
All replies of the stakeholders to the manyfold questions in details can be found in the mentioned report “Assessment of the 
implementation of Directive 2000/53/EU on end-of-life vehicles (the ELV Directive) with emphasis on the end-of-life 
vehicles of unknown whereabouts422” published by the EC in 2017. 

Written OPC 

The topic was of high interest for stakeholders providing written input. Of 57 contributions, 15 
contained  information  or  opinion  on  vehicles  of  unknown  whereabouts,  13  on  (de-
)registration, and additional 6 on reporting. Contributions on these topics were received from 
all stakeholder groups.  

Workshop 

Topics discussed at the workshop following the presentation of the consultants on the topic 
of missing vehicles were the  

•  The suitability of road-worthiness test where various stakeholders have different opinions 

on details of the use of such test, however, it is seen a ”key question”; 

•  ELV  registration  competencies,  e.g.,  a  MS  representative  pointed  out  that  EU-wide 
information exchange (database) on CoDs accessible by the EU registration authorities 
would  be  an  effective  tool,  industry  agreed.  It  was  clarified  that  EUCARIS,  the  data 
exchange mechanism for vehicle data in Europe, does already have a CoD-message in 
place  to  exchange  the  CoD-info  across  Member  States.  EUCARIS  is  used  by  all  EU 
Member States, however the CoD-message is currently not being used;  

•  vehicles  deregistration,  e.g.,  in  relation  to  the  limitations  of  temporary  deregistration, 
harmonized rules, and automotive industry requested that an automatic deletion from the 
registration  systems  after  seven  years  for  example  like  in  some  MS  should  not  be 
continued 
recyclers pointed out to the responsibilities of insurance companies and  

• 

421 Mehlhart et. al (2017) 

422 Mehlhart et. al (2017) 

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• 

total technical loss status, but also the definition of an ELV compared to used vehicles 

In general, many stakeholders engaged in the debate. Many of the stakeholders participating 
in the debate shared perspectives and experiences from MS, e.g. from Sweden or Germany 
(MS representatives), the Netherlands (stakeholders engages in repair and dismantling and 
EPR), Belgium (representative of the EPR system) or Latvia, Poland, France etc. (recyclers). 
It  was  pointed  out  by  industry  that  national  systems  may  pass  their  competences  and 
jurisdiction to the higher level. Further, a representative of the Dutch EPR said that a good 
cooperation between the Ministry of Environment and Ministry of Infrastructure/transportation 
(etc.) is key […] to be able to monitor ELVs. Another idea presented by stakeholders were 
‘massive  citizens 
to  dispose  your  ELV’  (recycler  + 
legal  way 
manufacturers).  

information  about 

8.5.4  EPR System 

Statistical OPC 

In the OPC, most stakeholders agreed that in order to ensure a high quality of recycling, that 
it  is  necessary  to  compensate  the  ATFs  for  their  dismantling  efforts,  which  are  not 
economically  viable  under  the  current  conditions.  This  was  mainly  supported  by  included 
environmental  NGOs  and  consumer  organisations,  waste  management  operators,  public 
authorities, and citizens but also a fair share of automotive producers (32%). When asked in 
more detail, 56% of all stakeholders agreed that producers should compensate the ATFs for 
their dismantling efforts and for appropriate treatment and disposal of these wastes. Here, 
waste management operators were the most prominent in their support of this aspects. 

Written OPC 

A few written contributions addressed Extended Producer Responsibility aspects, some only 
as  a  simple  need  that  has  to  be  implemented  and  others  with  more  elaboration.  Several 
stakeholders explained the purpose of an EPR scheme to be to affect the design of products 
so  that  they  result  in  less  negative  environmental  impacts.  Others  see  the  EPR  scheme 
mainly as a funding opportunity to e.g. to balance costs for dismantling in particularly when 
secondary materials are more expensive than virgin materials, to boost investment in high-
quality  PST  through  economic  incentives.  One  stakeholder  raised  the  concern  that  the 
creation of an EPR monopoly in which producers have power over where finances and ELVs 
end  up  could  end  up  limiting  the  free  and  fair  competitiveness  of  the  current  network  of 
dismantlers and shredders. 

Interviews 

Waste  management  operator  look  at  the  establishment  of  an  EPR  positively,  in  particular 
where  it  is  necessary to  support the financing  of  components  of  materials  that  need  to  be 
dismantled and treated in a way that is not economical. Though EPRs is exist for some MS, 
a  difficulty  was  raised  that  they  are  usually  run  by  OEMs  without  involving  ATFs  in  their 
management. The difficulties in managing funds for a European EPR were raised in light of 
the frequent exports between countries and also the different costs that waste management 
results in in each country that would make setting a single fee for an EPR fund at EU level 
tricky.  

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Workshop 

Participants commented that there are concerns about what entity has authority over EPR 
schemes.  A  few  stakeholders  mentioned  that  funds  have  not  shown  big  advantages  to 
support the economic feasibility of ATFs and stated that the processes that ATFs should treat 
vehicles  and then  producers  have to cover  negative market value  vehicles  is the  direction 
that  the  EPR  should  develop,  with  it  being  established  in  the  Directive.  In  contrast  it  was 
mentioned  that  funds  were  effective  in  compensating  unprofitable  labour  (material 
dismantling), allowing the dismantler to compete more effectively with the illegal sector and 
being less dependent on enforcement. A few stakeholders raised the aspect of the CoD and 
the need for more enforcement to lower illegal exports leading to less vehicles being treated 
in  the  EU.  The  EPR  was  mentioned  as  an  option  to  address the  problem  of cars  going to 
other continents and not just for ensuring financial feasibility of ELV treatment.  

8.5.5  ELVD Scope 

Statistical OPC 

For  almost  all  stakeholder  categories  participating  in  the  OPC,  over  50%  of  the  individual 
answers were in favour of extending the Directive additional vehicles. The highest support of 
this option was given by environmental organisations (100%), public authorities (90.9%) and 
waste management stakeholders (85.7%). On the question which additional vehicles should 
be  included  into  the  scope  of  the  ELV  Directive,  the  majority  was  in  favour  of  adding 
motorcycles  and  trucks  with  a  higher  preference  for  trucks  from  the  waste  management 
operators and a higher preference for motorcycles from the manufacturers.  

Avoidance of environmental harms to the environment thanks to minimum requirements for 
end-of-life treatment, increased resource recovery and increased recyclability were the top 3 
important  advantages  of  extending  the  scope  of  the  ELVD  largely  supported  by  all 
stakeholder  categories.  Individual  stakeholders  explained  that  including  them  in  the  scope 
would increase the  supply of recycled materials and  lead to better  dismantling, that heavy 
vehicles  are  exported  to  a  larger  extent  than  cars  and  reuse  of  spare  parts  is  not  as 
developed. And illegal vehicle dismantling, and unfair competition take place. This should be 
dealt  with  in  the  legislation.  One  third  had  no  opinion  on  disadvantages  of  the  scope 
extension.  The  most  supported  individual  answers  were  that  “These  other  vehicles  (e.g., 
motorcycles and trucks) have features which are different from the vehicles covered by the 
ELV  Directive,  so  that  the  provisions  of  the  ELV  Directive  are  not  adapted  to  these  other 
vehicles”  (62  individuals  or  30%)  and  “Higher  burdens  for  SMEs”  (48  individuals  or  23%). 
Answers were distributed relatively evenly between the various categories. The stakeholders 
themselves  relativised  their  statements  on  disadvantages  when  asked  to  detail:  Though, 
“motorcycles are small, so it will be a lot of work for a very small amount of materials”, and 
“trucks  are  big  and  require  specialised  facilities  for  dismantling”,  stakeholders  say  that 
“recycling facilities  are  suitable  for  all  of the  ELVD  scope”. “Today these vehicles  [it  is  not 
clear which] are already treated in authorized facilities even if they are not covered by the 
scope  of  the  Directive.”  Or:  “The  ELV  change  will  result  in  some  system  changes  and 
investment costs. It however involves an investment for the future. If the demand for recycled 
material is successfully established, it will pay itself back.” 

More than one third of the stakeholders did not have an opinion on / did not know the areas 
where compliance for motorcycles and/or trucks would be difficult, and 15% said there are 
none.  About  20%  support  that  the  following  measures  may  be  difficult  to  comply  with: 
Material-specific  recycling  targets  (45  individuals  or  22%),  reuse  target  (47  individuals  or 
23%), and recycled content target (38 individuals or 18%). 

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Written OPC 

Various stakeholders from the motorcycles sector contributed additional information: ACEM 
emphasises  that  the  sector  consists  of  many  SMEs  that  have  no  experience  with  the 
requirements  of  the  current  ELVD.  Besides  the  quantitative  results  from  a  survey  on  the 
numbers  of  recycled  motorcycles  in  Finland,  SMOTO  brings  forward  the  concern  that  the 
common reuse practices could be undermined by the perceived focus of the current ELVD 
on  recycling  rather  than  reuse.  An  anonymous  stakeholder  (motorbike  manufacturer) 
proposes  non-reusable  parts  for  motorcycles  in  addition  to  those  listed  in  Art.  8  of  the  3R 
Type approval Directive for M1 and N1423. FORS (a Polish recycling association) speaks for 
the practice of certificates of destruction for end-of-life motorcycles. A recyclability target is 
preferred whereas recycled content targets and reuse targets are explicitly not recommended 
for motorbikes (Eurofer). 

For  trucks,  Swedish  Government  considers  it  important  to  distinguish  between  light  and 
heavy-duty  vehicles.  If  trucks  were  included,  the  Czech  Ministry  of  Environment  sees 
“problems in their size and different composition of materials”. Generally, for new vehicles in 
scope,  the  regulation  should  prevent  the  phenomenon  seen  for  missing  vehicles,  i.e.,  the 
avoidance of the EU end of life treatment requirements (Swedish Governmental Agencies).  

Six  contributions  focus  on  historic  cars  and  motorcycles.  Current  practice  of  exempting 
historic cars should be pursued.  

Interviews 

Relevant interviewees are ACEA and ACEM presenting the manufacturers of trucks and L-
type  approved  vehicles,  and  ANERVI/AETRAC,  EuRIC  and  EGARA  representing  the  EoL 
stakeholders. To describe the status quo of the dismantling of lorries, the main messages in 
the interviews were that lorries are not just bigger cars, that depollution is in practice in some 
MS,  that  lorry  recycling  infrastructure  is  different  in  different  MS,  and  that  ATFs  that  can 
manage a lorry also manages trailers. As for the status quo of EoL treatment of motorcycles, 
it was noted that reuse is important, that L-type approved vehicles have no chassis which is 
relevant for the definition of what is an ELV. Then, a very small number of L-type approved 
vehicles  are  returned  to  recyclers,  and  that  there  is  no  statistics  on  motorcycles,  e.g.,  no 
separate waste code, right now.  

In relation to potential regulation covering additional vehicles, the clear message was sent 
that vehicles different to M1 and N1 vehicles require specific rules, e.g., that the same 3R 
targets could not apply, and that these vehicles potentially require different exemptions from 
heavy metal restrictions (or new substance restrictions). 

Workshop 

Views  differed  on  exemptions  for  hazardous  substances  in  additional  vehicle  categories. 
Vehicle  manufacturers  were  in  favour  of  a  category  specific  Annex  II,  i.e.,  to  review  the 
application of existing Annex II bans per vehicle category. The issue was also brought up in 
relation  to  multi-stage  built  vehicles,  incl.  wheelchair  accessible  vehicles.  There  is  also 
difficulty if more than one vehicle category applies to a vehicle. 

Stakeholders broadly support that it is currently not foreseen to recommend applying the 3R 
Type approval Directive to multi stage built vehicles.  

423 wheel suspension (front / rear) incl. triple clamp, swing arm and all damping parts, handle bar, all kind/material of rims, sub-
frame, all kind/material of fuel tank 

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In the workshop, various participants of all stakeholder groups commented on the presented 
data and/or provided additional data (on the calculation of the fleet of motorcycles and lorries, 
on  actual  fleet  data  from  Spain  and  Germany,  ).  ACEA  is  currently  performing  a  study  on 
lorry, with results expected in September 2022.  

A representative from the European Environmental Bureau (Environmental NGO) stated that, 
if  the  scope  of  these  Directives  is  currently  being  discussed, the  discussion  should  not  be 
limited to a scope for only on-road vehicles. 

8.5.6  3R Type Approval and its relation to the ELVD 

Current  situation.  Questions  were  asked  to  understand  better  the  role  of  type-approval 
technical  services’,  the  type  approval  authorities’  and  the  OEMs’  in  the  process  of  type-
approvals in general as well as the special part of the 3R type-approval in particular. Because 
this is more for the understanding of the current situation, the answers are not summarised 
here. Stakeholder statements were used in Annex II of the main report when describing the 
process. 

Effectiveness.  Type  approval  authorities  state  that  the  Directive  generally  facilitates  the 
achievement  of  the  3R  targets.  This  is  also  supported  by  OEMs.  However,  this  is  not 
supported  with  data.  Stakeholders  are  of  different  opinion  in  relation  to  whether  the  3R 
Directive facilitates “high-quality” recycling. There is no systematic monitoring or studies that 
compare  between  the  targets  reported  in  type  approval  declarations  of  OEMs  for  specific 
vehicle models and between their actual performance at end-of-life. Quantitative feedback is 
scattered:  

• The  number  of  3R  Type  Approvals  performed  per  MS  varies  largely:  Some  have  not
performed any TAs since Directive 2005/64/EC came into force (e.g., Latvia, Finland) but
do  report  on  Regular  TAs  for  second  stage  of  N  vehicles.  Some  perform  3R  Type
approvals regularly (6-9 per annum).

• One authority estimated the costs for the process at “< 0.25 years FTE per each 3R type

approval”

• Some MS collect fees for the TA and some do not – sum also depends on certificate type

•

(0-600 €).
3 of 5 MS agreed that the 3R TA should cover all stages of multi-stage vehicles (2 did not
answer the question)

A second cluster of question was asked around the possible future amendments of the ELVD. 
In general, little to no input is provided on impacts of introducing certain measures proposed 
to be changed in the 3R Directive. One stakeholder (stakeholder shall not be named) is of the 
opinion, that the scope of the 3R Directive should be extended to include additional vehicles. 
Reference to the preferred TRL level of recycling technologies accepted in the ISO calculation 
varied widely between 3-4, 6-7 and 9. 

On the  merge of  ELVD  and  3R  Directive. Of the  interviewed  stakeholders,  one  is  of  the 
opinion that there is a missing link and missing references between 3R Directive and ELVD. 
No stakeholder clearly indicated that the stakeholder preferred a merge of 3R Directive and 
ELVD or that it would be meaningful, MS that perform 3R Tas were against a merge with ELV. 
At least, two times China was provided as an example where one legal instrument is in place, 
however, the European market would be more diverse according to stakeholders. Looking at 
the  stakeholder  groups  that  provided  their  input  on  this  topic,  it  should  be  noted  that  the 
stakeholders rarely take the perspective of the end-of-life. An ACEA position paper (ACEA 
2022) refers to the positions of the automotive industry in relation to the merge of 3R Directive 
and  ELVD:  ACEA  “call[s]  for  the  current  legal  framework  to  be  maintained.”  Rather  than 
focusing  on  recyclability,  they  would  like  to  see  their  engagement  in  the  field  of  emission 

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reductions  during  the  use  phase,  i.e.,  strategies  focusing  on  light  weight,  acknowledged 
framing it Design for Sustainability.424 Another argument put forward (stakeholder shall not 
be named) is that currently, the responsibilities are distributed, i.e., recyclers fulfil the ELVD 
and  manufacturers  fulfil 3R  Directive  requirements.  A  merge  of  the  Directives  producing  a 
legislation  with  joint  responsibilities  could  increase  innovation  times  and  create  longer 
discussion processes.  

8.5.7  List of documents available to EC in addition to the synopsis 

Public feedback 

o
o

Feedback is available to the EC
Already 
available 
online 
say/initiatives/12633-Revision-of-EU-legislation-on-end-of-life-vehicles 

under 

https://ec.europa.eu/info/law/better-regulation/have-your-

Online public consultation (OPC) 

o
o
o

Export of data from online questionnaire is available to the EC
Stakeholders’ written contributions are available to the EC
Summary report already available under
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12633-End-of-life-vehicles-
revision-of-EU-rules/public-consultation_en.

Targeted consultation (main study + 3R type approval interviews) 

o Confirmed interview documentations
o
o

Additional studies or written input sent with the interviews
List of confidential or non-confirmed interview documentations

Stakeholder workshop 

Analysis of Slido (interactive tool) questions
o
o Documentation of the chat of the online meeting
Lists of attendees (contains personal data)
o

Consultation of Member States 

Answers of MS to ad-hoc survey are available to the EC
List of registrations425 of MS expert workshop (contains personal data)

o
o
o Documentation of the chat of the online meeting 

Follow up consultation activities after the workshops 

Stakeholders’ written contributions sent after the workshop are available to the EC.

o

424 ACEA „want to point out that, for the necessary new and innovative materials for achieving the ambitious goals of targeted 
carbon neutrality by 2050, there might not yet be available appropriate recycling technologies for vehicles on an industrial 
scale.” 

425 For technical reasons, we have not downloaded a list of attendees in this case. 

772 

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