European Parliament’s ENVI Committee Vote on Compromise Text of the ELV Regulation

The text introduces new obligations for OEMs and will trigger important changes for automotive plastics:

– A recycled content obligation for the plastics fraction of new type-approved vehicles will apply. This will be of 15% by weight 6 years after the entry into force of the new Regulation (~end 2032) and of 25% 10 years after (~end 2036).

– The only recognized feedstock for “recycled content” is “post-consumer plastics”. Raw materials for plastics coming from other sources (such as bio-circular) cannot be counted towards achieving the recycled content target.

– 20% of the recycled content must be so-called closed loop, coming from plastics recycled directly from end-of-life vehicles (ELVs) or from parts removed during a vehicle’s use-phase.

❗️It is important to note that:

– This recycled content obligation will NOT apply to all new vehicles placed on the market as from 2032. Only to new type-approved vehicles (ie new models introduced to the market). The concrete implementation of the new obligation will therefore be very progressive. Many OEMs already made significant efforts in using recycled plastics as much as possible and should not be hugely affected by the 15% target.

– The obligations apply at the level of the total weight of plastics in the vehicle, not per type of plastic. OEMs can therefore choose how they will achieve this new obligation, presumably also looking at technical feasibility, availability and price of recyclates for different parts or types of plastics.

– “Polyurethane foam for cushioning” is specifically mentioned as having to be counted as part of the weight of plastics used as basis for recycled content calculations. However this will require more clarification from the European Commission as to what it means concretely. It is pretty clear that seat cushions should be counted. But what about other PU materials used to “cushion” or absorb shocks such as foams in battery cases?
After all, in terms of recycled content requirements, the difference is minute, but it creates unclarity.

Among the very good news: the text specifically underlines that chemical recycling and mass-balance allocation should be recognized as means of providing recycled content. This is a very welcome clarification and has been a strong ask from many branches of industry. It remains now to be seen how this will be implemented in secondary legislation to be adopted within 2 years of the entry into force of the new ELVR.

–> Read the compromise text of the ELV Regulation.