COMMISSION STAFF WORKING DOCUMENT Subsidiarity Grid Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on circularity requirements for vehicle design and on management of end-of-life vehicles, amending Regulations (EU) 2018/858 and 2019/1020, repealing Directives 2000/53/EC and 2005/64/EC
Date: 2023-07-13
Institutions: Directorate-General for Environment, European Commission
Subjects: approval, circular economy, clean technology, environmental impact, extended producer responsibility, motor vehicle industry, technical standard, vehicle, waste recycling

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 13.7.2023  SWD(2023) 255 final  COMMISSION STAFF WORKING DOCUMENT Subsidiarity Grid Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on circularity requirements for vehicle design and on management of end-of-life vehicles, amending Regulations (EU) 2018/858 and 2019/1020, repealing Directives 2000/53/EC and 2005/64/EC {COM(2023) 451 final} - {SEC(2023) 292 final} - {SWD(2023) 256 final} - {SWD(2023) 257 final}  
 
 
Subsidiarity Grid 

1.  Can the Union act? What is the legal basis and competence of the Unions’ intended action? 

1.1 Which article(s) of the Treaty are used to support the legislative proposal or policy initiative? 

The  legal basis for this  proposal, which  replaces Directive 2005/64/EC and Directive 2000/53/EC,  is 
Article 114 of the Treaty of the Functioning of the European Union (TFEU). According to this Article, 
the  European  Parliament  and  the  Council  shall  adopt  measures  which  have  as  their  object  the 
establishment and functioning of the internal market. Article 114 TFEU is the legal basis of the overall 
regulatory framework on type-approval of motor vehicles, including of Directive 2005/64/EC.  

Article 192 TFEU is the legal basis for the Council and the European Parliament for taking action for 
preserving, protecting and improving the quality of the environment. Directive 2000/53/EC has this 
legal basis. 

Considering  that  the  proposal  merges  two  complementary  and  existing  instruments  into  one  and 
that  the  proposal  is  designed  to  set  out  requirements  which  both  govern  the  placing  on  the  EU 
market  of  motor  vehicles  and  their  management  at  end-of-life  and  that  both  those  objectives  are 
interlinked  in  an  inextricable  manner  as  the  requirements  at  design  and  end-of-life  mirror  each 
other, the most appropriate legal basis, which enables the smooth functioning of the internal market 
and the maintaining a high level of environmental protection, is Article 114 TFEU. 

1.2 Is the Union competence represented by this Treaty article exclusive, shared or supporting in 
nature? 

In the case of internal market policy, the Union’s competence is shared. Article 114(4) of the TFEU 
indicates  that  a  Member  State  shall  notify  the  Commission  if  it  deems  it  necessary  to  maintain 
national  provisions  after  the  adoption  of  a  European  harmonisation  measure  on  grounds  of  major 
needs1 or relating to the to the protection of the environment or the working environment. 

Subsidiarity does not apply for policy areas where the Union has exclusive competence as defined in 
Article  3  TFEU2.  It  is  the  specific  legal  basis  which  determines  whether  the  proposal  falls  under  the 
subsidiarity  control  mechanism.  Article  4  TFEU3  sets  out  the  areas  where  competence  is  shared 
between the Union and the Member States. Article 6 TFEU4 sets out the areas for which the Unions 
has competence only to support the actions of the Member States. 

2.  Subsidiarity Principle: Why should the EU act? 

2.1 Does the proposal fulfil the procedural requirements of Protocol No. 25: 

-  Has there been a wide consultation before proposing the act? 
- 

Is  there  a  detailed  statement  with  qualitative  and,  where  possible,  quantitative  indicators 
allowing an appraisal of whether the action can best be achieved at Union level? 

In order to collect evidence and ensure transparency, the Commission sought feedback from relevant 
stakeholder  groups  –  Member  States  and  national  authorities,  recycling  industry,  automotive 

1 The Treaty on the Functioning of the European Union, 2012. Article 36. 
2 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12008E003&from=EN  
3 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12008E004&from=EN  
4 https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:12008E006:EN:HTML  
5 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12016E/PRO/02&from=EN  

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industry  (including  vehicle  manufacturers,  component  suppliers  and  other  industry  stakeholders), 
steel,  aluminium  and  non-ferrous  industries,  plastic  producing  industry,  civil  society  (including 
consumer  organisations  and  environmental  NGOs)  and  citizens  –  through  multiple  consultation 
activities. 

Stakeholders were in particular consulted at several occasions throughout the evaluation and impact 
assessment  processes,  which  served  as  a  basis  for  the  proposed  Regulation,  especially  via  open 
public consultations, targeted consultations, stakeholder workshops6 and bilateral meetings. 

2.2 Does  the  explanatory  memorandum  (and  any 

impact  assessment)  accompanying  the 
Commission’s  proposal  contain  an  adequate  justification  regarding  the  conformity  with  the 
principle of subsidiarity? 

The explanatory memorandum of the proposal and the impact assessment under chapter 3.3 contain 
sections on the principle of subsidiarity which set out in a detailed manner the reasons for which the 
action provided for in the proposal can best be achieved at Union level.  

The  impact  assessment  specifies  that  to  avoid  fragmentation  of  the  EU  market  the  proposal  is 
justified to ensure a well-functioning internal market. Without harmonisation on EU level there is a 
significant  risk  to  encounter  illegal  dismantling  activities,  environmentally  unsound  treatment 
causing  an  uneven  playing  field  between  economic  operators  and  significant  potential  loss  of 
valuable secondary raw materials from the ELVs is  

Furthermore, without active EU level regulatory intervention, only small-scale and local incentives to 
design and produce vehicles in a way which limits the use of primary materials and increase the use 
of  secondary  materials  are  expected,  as  there  are  no  legally  binding  provisions  on  the  design  for 
circularity of such vehicles today.   

Also, for the development of a sound infrastructure for the treatment for all vehicles in the EU, it is 
necessary  to  regulate  on  EU  level.  Finally,  only  an  EU  set-up  reporting  and  monitoring  mechanism 
can  result  in  transparency  and  data  comparability  across  the  sector,  which  is  necessary  to  assess 
possible future amendments.   

2.3 Based  on  the  answers  to  the  questions  below,  can  the  objectives  of  the  proposed  action  be 

achieved sufficiently by the Member States acting alone (necessity for EU action)? 

The problems cannot be sufficiently addressed by the Member States alone. Vehicles are high-value 
goods  that  cross  national  borders  within  the  EU  and  which  are  also  exported  to  third  countries. 
National  initiatives  would  inevitably  contribute  to  further  fragmentation  of  the  internal  market. 
Similarly,  the  environmental  concerns  are  widespread,  with  key  underlying  causes  being  common 
across all Member States and there being agreement that it would be an advantage to modernise the 
applicable rules of the sector. 

(a)  Are  there  significant/appreciable  transnational/cross-border  aspects  to  the  problems  being 

6 A public consultation was held during the evaluation of the Directive (https://ec.europa.eu/info/law/better-
regulation/have-your-say/initiatives/1912-End-of-life-vehicles-evaluating-the-EU-rules_en ); An inception 
impact assessment was published on 15 October 2020 for public feedback  and then during the impact 
assessment, a 14-week open public consultation was held between 20 July 2021 and 26 October 2021 
(https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12633-End-of-life-vehicles-revision-
of-EU-rules/public-consultation_en ).  

2 

 
 
 
                                                           
 
tackled? Have these been quantified? 

Vehicles  are  high-value  goods  that  are  traded  across  the  national  borders  in  the  EU.  There  is  a 
significant  number of  end-of-life vehicles that are,  instead of being treated, exported  as used cars. 
Furthermore,  the  final  treatment  of  end-of-life  vehicles  cannot  be  verified  for  1/3 of  all  end-of-life 
vehicles, as the whereabouts of those vehicles are unknown.   

(b)  Would national action or the absence of the EU level action conflict with core objectives of 

the Treaty7 or significantly damage the interests of other Member States? 

National action or absence of EU level action is, in a time period where the automotive sector is in 
full  transformation  due  to  the  electromobility  development,  likely  to  lead  to  different  regulatory 
setups and an uneven playing field for the operators active in the automotive sector, whether it is in 
the design and construction phase of a vehicle or whether it is in the end-of-life phase of a vehicle. 
Differences  in  treatment,  follow-up  and  reporting  among  Member  States  could  easily  lead  to  a 
patchwork of different national measures that could result in internal market fragmentation, with a 
risk of tailoring national legislation to suit local industry and increased compliance costs (passed on 
to  consumers)  for  both  component  suppliers  and  vehicle  manufacturers.  Such  differences  would 
contradict  the  core  objectives  of  Article  114  of  the  TFEU  of  ensuring  a  smooth  functioning  of  the 
internal market. 

(c)  To  what  extent  do  Member  States  have  the  ability  or  possibility  to  enact  appropriate 

measures? 

National measures would not be uniform and would thus not be appropriate to address neither the 
uniformisation of type-approval requirements for placing vehicles on the market nor the treatment 
of end-of-life vehicles in the organisation of treatment facilities on their territory. National measures 
on type-approval could entail uneven requirements for approving vehicle types. National measures 
applicable  on  end-of-life  treatment  could  encourage  waste  management  operators  to  lesser 
environmental  standards  to  attract  customers,  driving  down  environmental  protection  and 
fragmenting the market. The Regulation will lay down the minimum rules and the Member States will 
thus  retain  the  possibility  in  those  circumstances  to  adopt  or  maintain  national  rules  in  place, 
provided they comply with the minimum rules, such as the setting up of competent authorities or the 
requirements for the register for extended producer responsibility. 

(d)  How  does  the  problem  and  its  causes  (e.g.  negative  externalities,  spill-over  effects)  vary 

across the national, regional and local levels of the EU? 

The  production  of  vehicles  is  one  of  the  most  resource  intensive  industries  and  represents  a 
significant  impact  in  terms  of  use  of  raw  materials.  The  dependency  on  primary  materials  which 
originate  from  outside  the  EU  leave  the  automotive  sector  significantly  vulnerable  due  to  various 
types  of  supply  shortages.  A  significant  share  of  the  materials  used  in  the  construction  of  vehicles 
ends up, once the vehicle reaches its end-of-life, being landfilled or incinerated, leaving the circular 
potential of vehicles underdeveloped. Furthermore, the final whereabouts of around one third of the 
end-of-life vehicles remains unknown in the EU. The problem linked to vehicle construction will vary 
depending whether a manufacturer of vehicles or of vehicle parts and components are established 
and have production facilities in the region concerned. The problem linked to the end-of-life phase of 
a vehicle does not significantly vary between regions. However, it is common for used vehicles to be 

7 https://europa.eu/european-union/about-eu/eu-in-brief_en  

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traded  between  EU  Member  States,  so  that  they  become  end-of-life  vehicles  in  a  Member  State 
different from the one where they were registered for the first time and where EPR fees were paid 
by the manufacturers. To address this situation, the proposed regulation contains specific measures 
on  “cross-border”  EPR  mechanisms,  designed  to  ensure  that  waste  management  operators  in  the 
Member States where ELV are treated are not placed at disadvantage.  

(e)  Is the problem widespread across the EU or limited to a few Member States? 

While  the  magnitude  of  the  problem  differs  between  Member  States,  due  to  the  establishment of 
production facilities  for instance,  the  principal problems related to the supply of primary materials 
and to the collection and treatment of end-of-life vehicles, is widespread across the EU. This is why 
measures on EU level are necessary. 

(f)  Are Member States overstretched in achieving the objectives of the planned measure? 

Replacing  the  existing  Directives  Directive  2005/64/EC  and  Directive  2000/53/EC  by  a  Regulation 
means that many obligations under EU law, which are currently directed at Member States, will be 
imposed directly on economic operators. The proposed regulation would not therefore lead to major 
new burden or obligations on the Member States side. In addition, the proposed regulation foresees 
in  multiple  instances  that  digital  tools  should  be  put  in  place  to  alleviate  burden  and  improve 
cooperation and information sharing between relevant competent authorities in a Member State, as 
well as between Member States.  
For  additional  data  on  the  administrative  burden  and  costs  linked  to  the  proposed  regulation,  see 
response to point 3(2)(d) below and the impact assessment report.  

(g)  How  do  the  views/preferred  courses  of  action  of  national,  regional  and  local  authorities 

differ across the EU? 

The policy instrument of setting new rules on recycling of vehicles is recognized by national, regional 
and  local  authorities  as  a  key  tool  for  improving  the  recycling  of  end-of-life  vehicles.  This  is  even 
more  the  case  for  vehicle  manufacturing  as  vehicles  are  placed  on  the  market,  transported  and 
disposed  of  across  the  Union.  There  is  significant  support  from  the  markets  that  harmonised  and 
coherent  regulations  concerning  the  type-approval  of  vehicles  are  of  utter  importance  for  the 
effective protection of the environment and the functioning of the internal market. 

2.4 Based  on  the  answer  to  the  questions  below,  can  the  objectives  of  the  proposed  action  be 
better achieved at Union level by reason of scale or effects of that action (EU added value)? 

There  is  clear  added  value  in  setting  common  requirements  at  EU  level,  as  this  will  ensure  a 
harmonised  and  well-functioning  internal  market  across  all  Member  States  and,  therefore,  a  level 
playing field both for vehicle manufacturer and the operators involved in the management of end-of-
life  vehicles.  With  requirements  and  targets  set  at  EU  level,  the  move  towards  vehicle  design 
becoming more in line with the requirements of a circular economy will take place in a coherent way 
in  all  Member  States,  creating  a  larger  and  more  efficient  market.  By  EU  intervention  will  enable 
achieving  the  desired  result  of  further  improving  the  recycling  rates  of  important  resources, 
improving  the  security  of  supply  and  the  quality  of  recycled  materials,  as  rapidly  as  possible. 
Economies  of  scale  will  be  achieved  through  consistent  approaches  to  the  inclusion  of  recycled 
content in new vehicle design and to the recovery and availability of recycled critical raw materials. 
Harmonised criteria for the modulation of fees for the  extended producer responsibility, which will 
provide  an  additional  economic  incentive  for  compliance  and  increased  circularity.  Member  State 
action  alone  could  not  achieve  such  harmonisation  and  thus  economies  of  scale.  The  proposed 
measures will not go beyond what is necessary to provide regulatory certainty while ensuring a high 

4 

 
 
 
level  of  protection  of  human  health  and  of  the  environment.  EU  action  is  therefore  justified  and 
necessary.     

(a)  Are there clear benefits from EU level action?  

Yes,  the  impact  assessment  has  shown  clear  benefits  of  EU  action  both  concerning  environmental 
impacts as well as economic impacts, by improving circularity, reducing green house gas emissions as 
well as securing the supply for the automotive sector. 

(b)  Are there economies of scale? Can the objectives be met more efficiently at EU level (larger 

benefits per unit cost)? Will the functioning of the internal market be improved? 

Yes, especially the increased demand for recycled content will enable recyclers to produce recyclates 
with increased purity and quality  which can be  used as secondary raw materials. Furthermore,  the 
availability of recycled critical raw  materials, sourced from vehicles which reach their end-of-life in 
the EU, will improve with an enlarged system for recycling. 

(c)  What  are  the  benefits  in  replacing  different  national  policies  and  rules  with  a  more 

homogenous policy approach? 

For the type approval elements of the proposal, it is essential to apply the same requirements in all 
EU  Member  States  as  type  approvals  are  valid  throughout  the  EU  and  that  the  type-approval 
requirements  apply  uniformly.  For  recycling,  the  proposal  will  create  a  level  playing  field  in  the 
recycling  sector,  which  will  allow  competition  on  equal  conditions  among  the  waste  management 
operators in the Member States. 

(d)  Do  the  benefits  of  EU-level  action outweigh  the  loss of  competence  of  the  Member  States 
and  the  local and  regional  authorities  (beyond  the  costs  and  benefits of  acting  at  national, 
regional and local levels)? 

The  proposal  builds on existing  legislation and  complements the  rules  applicable  to  modernise  the 
regulatory framework and to make them more ambitious in their aim to respond to the concern to 
have  a  more  circular  economy.  Furthermore,  the  rules  of  the  proposal  aims  to  align  the  rules  on 
vehicles  with  other  existing  legislation,  such  as  the  Waste  Framework  Directive  2008/98/EC  and 
other  proposals  which  are  currently  under  negotiation,  including  the  Regulation  on  Eco-Design  of 
Sustainable Products and the Regulation on Critical Raw Materials.  

(e)  Will there be improved legal clarity for those having to implement the legislation? 

The proposal will as a  Regulation be  directly applicable  with clear rights  and obligations for clearly 
defined actors in the various phases of the supply chain and at the end-of-life phase. 

3.  Proportionality: How the EU should act 

3.1  Does  the  explanatory  memorandum  (and  any  impact  assessment)  accompanying  the 
Commission’s proposal contain an adequate justification regarding the proportionality of the 
proposal  and  a  statement  allowing  appraisal  of  the  compliance  of  the  proposal  with  the 
principle of proportionality? 

The  proposed  measures  are  intended  to  provide  the  regulatory  certainty  needed  for  both  vehicle 
manufacturers  and  operators  active  in  the  waste  management  sector,  such  as  to  encourage  the 
investment  into  circular  design  and  recycling  techniques  and  facilities  necessary  to  respond  to  the 
requirements of a circular economy focused on resilience of the supply chains. As such the proposal 
also ensures the smooth functioning of the internal market and a high level of protection of human 

5 

 
 
health  and  the  environment.  The  objective  of  this  initiative  is  to  modernise  and  strengthen  the 
existing  legislative  framework  to  allow  for  economies  of  scale  through  common  approaches,  while 
giving industry and Member States the necessary flexibility, where this is necessary. 

The principle of proportionality has been taken into account in the design of all measures contained 
in the proposed Regulation, as exemplified by the progressive extension of the scope of the existing 
legislation to new vehicles, or the transition periods foreseen for all new requirements, so as to allow 
industry and all relevant stakeholders to adapt. More information is found in Annex 8 to the impact 
assessment report. 

Overall, the proposed measures represent a step change from the existing regulatory framework and 
do  not  go  beyond  what  is  necessary  to  ensure  a  regulatory  compliance  while  guaranteeing  the 
protection of human health and the environment. 

3.2 Based  on  the  answers  to  the  questions  below  and  information  available  from  any  impact 
assessment,  the  explanatory  memorandum  or  other  sources,  is  the  proposed  action  an 
appropriate way to achieve the intended objectives? 

The evaluations preceding the current have revealed that a harmonisation is necessary in the form 
of a Regulation, rather than revising the current Directives 2000/53/EC and 2005/64/EC.  

To further promote the move to a low-carbon and circular economy and remove existing barriers to 
the smooth functioning of the  internal market, a new  comprehensive  set of regulatory solutions is 
needed,  including  requirements  which  apply  directly  to  businesses.  The  move  to  a  Regulation 
provides the required assurance for direct and harmonised application and enforcement throughout 
the EU of automotive manufacturers’ and recyclers’ obligations. 

A Regulation will ensure obligations are implemented at the same time and in the same way in all 27 
Member  States.  The  same  requirements  for  all  market  players  will  provide  the  necessary  legal 
certainty and reduce distortion of competition, and send clear signals to non-EU market actors, when 
placing  vehicles  on  the  EU  market.  Furthermore,  the  Commission  will  have  a  mandate  to  develop 
implementing measures to flesh out the Regulation further, where necessary, allowing for common 
rules to be  set swiftly. In some  instances, the Regulation will lay down the minimum rules and the 
Member States will thus retain the possibility in those circumstances to adopt or maintain national 
rules in place, provided they comply with the minimum rules.  

(a)  Is the initiative limited to those aspects that Member States cannot achieve satisfactorily on 

their own, and where the Union can do better? 

Yes, the initiative is limited to the objective of improving circularity of vehicles that cannot be 
sufficiently  achieved  by  the  Member  States  acting alone  without  putting  at  risk  the  proper 
functioning of the internal market. 

(b)  Is  the  form  of  Union  action  (choice  of  instrument)  justified,  as  simple  as  possible,  and 
coherent with the satisfactory achievement of, and ensuring compliance with the objectives 
pursued  (e.g.  choice  between  regulation,  (framework)  directive,  recommendation,  or 
alternative regulatory methods such as co-legislation, etc.)? 

The  use  of  a  Regulation  is  considered  to  be  appropriate  in  that  it  provides  the  required 
assurance  for  direct  and  harmonised  application  and  enforcement  throughout  the  EU  of 
automotive  manufacturers  and  recyclers  obligations  while  not  requiring  transposition  into 
Member States’ legislation. 

6 

 
 
 
 
 
 
This  proposal  replaces  in  one  Regulation  two  existing  Directives  which  makes  the  desired 
amendments  and  alignments  to  later  legislation,  codifies  those  amendments  with  the 
unchanged provisions of the earlier acts, and repeals those acts. 

(c)  Does the Union action leave as much scope for national decision as possible while achieving 
satisfactorily the objectives set? (e.g. is it possible to limit the European action to minimum 
standards or use a less stringent policy instrument og approach?) 

Yes, the concrete  application of the  rules and the setting up of the recycling infrastructure 
will allow member Sates sufficiently to take the necessary decisions. The proposal lays down 
minimum rules on a number of issues where it is potentially not necessary to have complete 
harmonisation. 

(d)  Does  the 

initiative  create  financial  or  administrative  cost  for  the  Union,  national 
governments,  regional or local authorities, economic operators or citizens? Are these costs 
commensurate with the objective to be achieved? 

As indicated in the impact assessment report, the costs and revenues for the different stakeholders 
affected  by  proposed  regulation,  calculated  per  vehicle  and  for  all  stages  of  the  process  (type-
approval, design, production, collection, waste treatment, export), are estimated as follows:  

 For vehicle manufacturers, the net costs linked to production and design, primarily related 
to plastic recycled content, would represent roughly 26 EUR per vehicle (N1,M1, 392 million 
EUR  adjustment  costs,  38  million  EUR  administrative  burden  for  the  manufacturer  and  23 
million EUR administrative burden for authorities). In addition, the costs linked to collection 
and treatment (150 million EUR not covered by revenues, including administrative burden for 
treatment of 42 million EUR) which could potentially be covered by the manufacturers under 
the EPR schemes would amount to 12 EUR per new vehicle. The total costs (580 million EUR) 
for  manufacturers  (production  +  EPR  fees)  of  39  EUR  per  new  vehicle  are  expected  to  be 
ultimately covered by the consumer when buying a new vehicle. These are short to medium-
term costs for the EU automotive industry. The preferred option would also reduce its energy 
and  strategic  raw  material  dependencies  and  provide  for  important  savings.  While  these 
revenues cannot  all  be  quantified, they  are  expected  to  be  significant  and  spill  over  to  the 
whole  automotive  supply  chain  (see  section  8.3  of  the  impact  assessment  report  for  more 
elements on this point);  
 For the waste treatment sector, the costs (530 million EUR) for ATFs of 44 EUR per vehicle, 
mainly from dismantling efforts, slightly outweigh anticipated revenue increases (490 million 
EUR)  of 40 EUR  per  vehicle.  Similarly,  for  shredders,  the  101  EUR  of  extra  cost  per  vehicle 
(1,230  million  EUR  in  total)  mainly  from  new  investments  in  better  sorting  technologies 
compares against a 92 EUR of revenue potential (1,120 million EUR). In these two cases, the 
differential  between  costs  and  revenues 
is  expected  to  be  covered  by  fees  from 
manufacturers  under  EPR  schemes.  It  is  important  to  stress  that  the  situation  will 
considerably  differ  between  Member  States  and  economic  operators,  depending  on  the 
current treatment technologies used (esp. availability of PST) and labour costs. For recyclers, 
due to increased materials availability (incl. CRMs removed) and improved prior separation in 
previous  stages,  the  revenue  potential  of  49  EUR  per  vehicle  (440  million  EUR)  clearly 
outweighs a 29 EUR per vehicle cost increase (770 million EUR). The combined administrative 
burden for treatment operators is 3.50 EUR per new vehicle. The preferred option would also 
reinforce and boost the recycling sector, encouraging its modernisation and expansion. The 
preferred option would favour innovation in new processes and technologies, for sorting and 
high-quality recycling, building on current research156 .  
 For specialised car and heavy-duty vehicle exporters, the revenue loss is expected to reach 

7 

 
 
 
around 47 EUR per new vehicle sold (570 million EUR); 
  For consumers, in addition to a likely increase in prices of new vehicles of around 39 EUR 
per  vehicle  (aforementioned  580  million  EUR),  they  might  also  expect  a  decrease  in  prices 
when  selling  second-hand  cars  due  to  reduced  export  there  of  12  EUR  per  vehicle  (150 
million EUR), but should also be able to benefit from cheaper prices for used spare parts due 
to all measures designed to support their recovery and sales;  
 The administrative costs for public authorities (23 million EUR) dealing with type approval, 
vehicle registration, customs control and ECHA) are 1.40 EUR per vehicle.  
  The  total  one-off  administrative  costs  are  2.45  million  EUR  for  manufacturers  and  1.55 
million EUR for authorities. 

Overall, the total annual revenues generated by the proposed Regulation is 5.2 billion EUR in 2035, 
including 2.8 billion EUR of CO2 credits, against a cost of 3.3 billion EUR, leading to a 1.8 billion net 
revenue. 

More information on these costs and revenues can be found in the impact assessment report. 

(e)  While  respecting  the  Union  law,  have  special  circumstances  applying  in  individual  Member 

States been taken into account? 

As  stated  above,  the  problem  linked  to  the  needs  of  the  vehicle  manufacturing  and  construction 
differs  between Member  States,  due  to  the  establishment of  production  facilities  for  instance,  the 
principal problems related to the supply of primary materials and to the collection and treatment of 
end-of-life  vehicles,  is  widespread  across  the  EU.  From  this  point  of  view  the  no  specific 
circumstances what would apply in individual MS which need to be considered in the proposal. 

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