BIR Gothenburg 2026 – International Environment Council: Huge global ramifications for EU’s new ELV Regulation

On course to become law before the end of 2026, the EU End-of-Life Vehicles (ELV) Regulation is destined to have a massive impact on global automotive supply chains, it emerged at the latest meeting of the BIR’s International Environment Council (IEC), held on June 3.

Julia Ettinger, Secretary General of Recycling Europe, confirmed that a final agreement has been put forward and that, pending formal adoption by the European Parliament and Council, the new regulation is likely to enter into force during this year’s fourth quarter. This will be an ELV Regulation and not a Directive as before, which means “there is no wiggle room for member states to change anything”, she told delegates in Gothenburg.

A key element of the regulation is recycled content targets for plastics of 15% within six years and 25% within 10 years, with a closed-loop requirement stipulating that 20% of this material must come from ELVs. Recycled content targets in other legislation - such as single-use plastics and packaging - have had some success “and so we are glad to see them now also in the ELV Regulation”, she commented.

Another clause in the ELV Regulation calls for the European Commission to assess the feasibility of recycled content targets for steel, aluminium and critical raw materials too. At the same time, producers are asked to make declarations on the recycled content in their vehicles. Meanwhile, a mirror clause will require recycled plastics from countries outside the EU to have been treated in an equivalent way to the European level, based on an independent audit of facilities every five years.

Having noted that the new regulation asks for some parts of an ELV to be removed manually for placement on the remanufacturing or reuse market, Ms Ettinger welcomed a clause nullifying this removal requirement if costs are disproportionate. To underline the importance placed on reuse, the regulation also calls on vehicles to be designed for easy removal of parts.

Meanwhile, some treatment requirements enshrined in the regulation - including the sorting of aluminium into four different grades - will necessitate investment by recyclers, according to Ms Ettinger.

The guest speaker celebrated the decision to include recyclers - “for the first time in history” at European level - as observer members of the administrative Producer Responsibility Organisation. “We always believe that recyclers, because we are the ones supposedly benefiting from an EPR (extended producer responsibility) scheme, should have a say in the administration and the governance, so this is really a good step forward and allows us also to give our perspective in terms of the setting-up and the running of the EPR scheme,” she said.

BIR Director General Arnaud Brunet added that the world recycling organisation’s global position paper on extended producer responsibility and compliance schemes “made it very clear that we wanted recyclers to be associated with the governance of the EPR”.

Robin Wiener, President of the US-based Recycled Materials Association (ReMA), identified “a fundamental shift occurring within the automotive sector and the automotive supply chain” around issues of circularity, recycled content, disassembly and dismantling, traceability and materials recovery. “This is being driven in large part by the EU regulation,” she said, because of the global nature of supply chains.

Effects are already being seen in the USA where, historically, the plastics within automotive shredder residue have been landfilled because recycling them has been deemed technologically and economically unviable. “We believe that there will now be that demand,” Ms Wiener stated. “Because what we’re hearing from the EU automakers is that they see a problem with getting enough supply of the quantity and the quality that they need from just the EU market. So there’s going to be a growing demand for plastics from multiple sources.”

There has been an acceleration, she added, in the pace of government and company research in the USA into plastics recovery from ASR involving chemical as well as mechanical recycling.

Regarding the ELV Regulation’s requirement to remove certain parts prior to recycling, Ms Wiener said this raised the question of whether, in doing so, it makes it easier for dismantlers to take out parts containing valuable materials and thus change the economics of shredding. “We don’t know but it’s something we have to think about,” she said.

Having pointed to the new regulation’s verification requirements as a “huge challenge”, Ms Wiener also said she was “nervous” about other countries following the EU’s lead, particularly in Mexico where there is talk of a law involving traceability and recycled content requirements for vehicles.

“We need deeper collaboration with the automakers - that is incredibly important,” concluded Ms Wiener. “We need it on a global level because these are global vehicle platforms. And so through BIR’s leadership, I'm hoping that we could have that kind of discussion.”

The focus of the meeting switched to the implications of a sliding scale methodology for green steel. Having affirmed BIR’s position that recycled steel maximisation across all production methods offers the most immediate, commercially viable and scalable solution for producing green steel, Trade and Environment Policy Officer Alexandra Vartan expressed the “very considerable concern” that the sliding scale creates “a very uneven playing field” which “penalises recycled steel-based production”.

This approach opens up the possibility that an electric arc furnace inputting approximately 80% recycled steel and a blast furnace using 20% recycled steel could receive equal benefit under the green steel classification despite the former’s substantially lower emissions. This could “very much undermine the credibility of the green steel labelling”, she argued.

Earlier in the meeting, IEC Chairman and Recycling Europe’s President Olivier François expanded on the European aluminium scrap export debate at the BIR Non-Ferrous Metals Division meeting in Gothenburg. He noted that, in December last year, European Commission Vice President Stéphane Séjourné told a Brussels press conference that he wanted recycled aluminium to stay in Europe so as to make the price go down. Such a statement is “short term”, said Mr François, and fails to recognise that lower prices impact whether the recycling industry conducts its environmentally important work.

He pointed to evidence from the plastics sector of the potentially negative consequences of regulation based on emotion: a recently-imposed export ban has impacted prices for recycled plastics at a time when they should be “sky-rocketing” given the elevated costs of oil.