The signatories – representing the waste management and recycling industry, automotive suppliers and NGOs – called on EU lawmakers to uphold the standards set by the Commission’s proposed Regulation on End-of-Life Vehicles (ELVR).
The statement made four specific calls to EU policymakers. Alongside FEAD and EuRIC, the full list of signatories included T&E, ecos, EEB, Mobi Lians, Forvia and Materiact.
Uphold the 25% recycled plastic content in new vehicles
The statement called for EU policymakers to uphold the 25% plastic content target for new vehicles.
The signatories said that the target aligns with what well-performing original equipment manufacturers (OEMs) can already achieve.
It added that the target provides the best cost-benefit balance, avoids excessive costs and supply shortages, while it also offers certainty for manufacturing planning, with some manufacturers already exceeding these levels.
Maintaining this recycled content target was also described as “an absolute precondition” for meeting the proposed 30% plastic recycling goal set under the ELVR proposal.
Accelerate implementation to reverse the current situation
Despite recent progress, the statement said that the demand for recycled plastic remains week due to current low virgin plastic prices and rising imports.
To reverse this situation, the signatories called for setting recycled content targets to take effect within 48 months of the regulation’s entry into force to drive immediate investments and expand recycling capacity.
They added that this can be achieved in two ways: by bringing forward the 25% recycled content obligation, or by setting intermediate targets at 48 months while keeping the 25% requirement at 72 months after the regulation’s entry into force.
Count only post-consumer waste toward targets
The statement warned policymakers that including post-industrial waste to meet the 25% target would undermine efforts to improve recycling of end-of-life vehicle plastics and would hamper circularity.
The signatories added that a meaningful contribution to environmental protection would not be guaranteed, as production waste (post-industrial or pre-consumer waste) is significantly purer (considering an overall assessment), than consumer-generated waste (post-consumer waste). Prioritising post-consumer waste in these targets was said to support ELVs recyclers in investing and scaling up their operations.
Ensure investment stability for innovation and recycling capacity expansion
To boost investment in R&D, innovation and the scaling of recycling capacities, the signatories urged policymakers to avoid lowering targets or adding revision/derogation clauses that could create uncertainty and disrupt critical investments.
The letter concluded that planning stability is essential to drive circularity and decarbonisation in vehicle production.
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