Stronger Remanufacturing Framework Needed in Council’s ELV Regulation Position

In response to the Council’s adoption of its position on the End-of-life Vehicles (ELV) Regulation, CLEPA, the European association of automotive suppliers, calls for greater policy clarity and stronger support for automotive remanufacturing and inclusive recycling targets.  

“As essential players in the automotive value chain, suppliers are advancing sustainability and circular economy through innovative remanufacturing and material reuse. However, without a consistent regulatory framework, these efforts risk being undermined. The ELV regulation must be built on a realistic and innovation-friendly foundation,” said Benjamin Krieger, Secretary General of CLEPA.  

“Circularity is more than just recycling. It’s about keeping products and materials at their highest value for as long as possible,” Krieger added. “To unlock the full potential of the circular economy, we need legal clarity on remanufacturing and realistic targets for recycled content that reflect industry capabilities.”  

Key policy requests  

1. Strengthen support for remanufacturing 

• Adopt a clear and inclusive definition of remanufacturing that recognises products returned to same-as-new condition with full warranty. 

• Ensure consistent terminology for cores and components, aligned with EU type-approval rules. 

• Avoid language that misrepresents remanufactured parts as lower quality. 

• Clarify the legal distinction between waste and parts for remanufacturing not only for end-of-life vehicles, but also for vehicles still in use. 

2. Expand scope of recycled plastic targets 

• Include both pre- and post-consumer plastic waste in the recycled plastic content target (Article 6), especially from automotive production. 

• Ensure a comprehensive plastics definition, covering thermosets and elastomers. 

• Guarantee technology neutrality, giving equal weight to chemical and mechanical recycling. 

• Include a review clause to adjust targets based on feedstock availability and technological progress. 

• CLEPA supports a 25% target, provided these conditions are met. 

CLEPA remains committed to working constructively with EU institutions to ensure the ELV Regulation supports Europe’s sustainability goals without compromising innovation or industrial competitiveness.