2023/0284(COD) · In Force
194 submissions from 174 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 1,143 submissions on this file. Shown here: the 194 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
128 submissions from industry — companies and their trade associations — against 43 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 3.0 industry submissions for every one from civil society.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
Self-declared to the EU Transparency Register (snapshot 2 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 4 Dec 2023 — it ran from 14 Jul 2023.
How it got here
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned.
One block of text on this file was submitted, identically, by three or more organizations. Shared text is a fact about the filings; what it means is for the reader.
3 organizations: ArcelorMittal Deutschland, ArcelorMittal France, ARCELORMITTAL SPAIN
“The revision process of the ELVs Directive needs to aim at the following key objectives: 1. to transform the ELVD into a Circularity enabler promoting and ensuring design for recyclability of new vehicles and their parts; 2.”
Showing 25 of 194 submissions.
Vehicle production, use and disposal is associated with negative environmental impacts at every stage, and sometimes with negative social impacts. Tackling the problem of end-of-life vehicle waste is challenging and Zero Waste Alliance Ireland welcomes the effort of the EU Commission to address these issues.
ECOS, the Environmental Coalition on Standards, is an international NGO with a network of members and experts advocating for environmentally friendly technical standards, policies and laws. The old End-of-Life Vehicles Directive has been in force since 2000 with only minor changes and is in urgent need of a fundamental update to meet today's requirements in terms of circular economy and net zero emission targets.
The amendment to the EU Old Car Regulation pursues a correct objective (increasing the use of recycled plastics in the construction of vehicles) with a fundamentally incorrect approach contrary to the market economy (defining a rigid recycled content rate for certain components). At present, around 90 % of unregistered cars in Germany are exported as second-hand vehicles.
Filed in German · English published by the European Commission
· · filed 4 Dec 2023 · source
The Association of European Vehicle and Driver Registration Authorities (EReg), in general welcomes the European Commissions Proposal for an EU Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles [COM(2023) 451], published by the European Commission on 13 July 2023.
End-of-life vehicles (ELV) revision of EU rules, the opinion of the Polish Automotive Industry Association thanks to the possibility of consulting the European Commission’s proposal for a regulation on circularity requirements in the design of vehicles and end-of-life vehicles (ELVs), which we understand is the next step in the transformation of the EU economy towards sustainability, circularity and innovation.
Filed in Polish · English published by the European Commission
Polish Chamber of Insurance (PIU) supports proposed solutions aimed at systematizing requirements related to circular system of vehicle design stage and managing wrecks. We certainly endorse the goal of the proposal, which is to improve the quality of vehicles in the secondary market, encourage recycling, and achieve the most effective management of wrecks.
· · filed 4 Dec 2023 · source
We are a medium-sized plastic processor with 80 employees and we produce components for the automotive industry in the spray casting process that reliably perform safety-related tasks. Our work is characterised by quality, innovativeness and sustainable awareness. As family businesses, we are aware of our responsibility towards the environment and subsequent generations.
Filed in German · English published by the European Commission
United VDL represents the interests of trailer manufacturers 01, 02. Directive 2000/53/EC applies to motor vehicles of categories M1 and N1. The number of such vehicles registered throughout the territory of the Union is high and has enabled the establishment of a relevant network for the collection and treatment of used M1 and N1 vehicles.
Filed in French · English published by the European Commission
TecPart supports the EU’s overarching goal of achieving a carbon-neutal continent by 2050. This includes to a large extent the use of secondary raw materials and the related circular economy. Consequently, any recycled rate shall be based on the CO2 reduction scale. The full plastic waste stream in the open loop for secondary materials (by-products/PIR/PCR) must be allowed across different types.
Filed in German · English published by the European Commission
The Polish EKO-AUTO Vehicle Deconstruction Station Association was the only organisation in Poland to consult extensively on the draft Regulation. Between 3 and 20 October 2023, meetings were held throughout the country with the owners and staff of the dismantling centre (ELV). It should be stressed that the provisions of the draft Regulation are crucial for the continued operation of dismantling centres in Europe.
Filed in Polish · English published by the European Commission
AMCAR is fundamentally positive towards the European Commission's initiative and proposals for requirements and regulations that ensure a greater degree of reuse, recycling, and recovery concerning vehicles. However, AMCAR is deeply concerned about the very narrow definition of historical vehicles that will be exempt from the regulation.
Overall, Volvo Cars welcomes the Commissions proposal to revise the End-of-life Directive and Directive on the type-approval of motor vehicles regarding their reusability, recyclability and recoverability, published on 13 July 2023. The proposal aims at increasing the sustainability and circularity of motor vehicles from cradle to grave, an objective we fully support.
· · filed 4 Dec 2023 · source
The International Council of Tanners welcomes the efforts by the European Union to reduce the environmental impact of End of Life Vehicles. However, we are concerned that there has been no focus on the use of truly circular materials, such as leather, in place of problem materials, like plastic.
· · filed 4 Dec 2023 · source
Article 11: SBR wants to point out the lack of reusability in point 1.(F) where the word 'exchange' is only used in relation to another vehicle. It is imperative that digitally coded components are made available for reuse and repurposing. Article 13: SBR welcomes a circularity passport.
The FNA and National Coordination (both of which are subsequently referred to as ‘the FNA’) share a common purpose and the means of latting, which the European Commission proposes, in order to oblige the manufacturer to incorporate recycled materials into vehicle design and to take measures to reduce the environmental impact.
Filed in French · English published by the European Commission
· · filed 4 Dec 2023 · source
Glass for Europe welcomes the proposal to revise the legislation on end-of-life vehicles and is encouraged by the positive developments leading to enhanced circularity for automotive flat glass. We support the alignment of the definition of recycling with the Waste Framework Directive, which paves the way for more legislative coherence.
The Alliance of Minerals, Minerals and Metals (A3M) brings together French companies active in the production, processing and recycling of industrial metals and minerals. Our sector is one of the key suppliers to the automotive sector. Metals are present in automotive body (e.g. steel), batteries (e.g. lead, lithium, nickel, cobalt, copper), catalysts (e.g.
Filed in French · English published by the European Commission
The European steel industry would like to contribute to the circular economy through this piece of legislation concerning the automotive sector, which is the second largest demand sector for finished steel products.
The RDW welcomes the proposed Regulation on circularity requirements for vehicle design and end-of-life vehicle management. The RDW is in favour of the manufacturer issuing, in addition to the digital CVO, a circularity passport for each vehicle in order to understand how vehicle parts can be safely removed or replaced.
Filed in Dutch · English published by the European Commission
1. The important role of remanufacturing and all authorised economic operators should be acknowledged e.g. in relation to handling removed parts, for evaluation and access to software to enable upgrades or software updates during remanufacturing. The proposal infers waste management operators are the only actors handling removed parts and that all material operations are done within waste management.
The Spanish Automobile Manufacturers' Association (ANFAC) is firmly committed to advancing the EU towards a modern, resource-efficient, and competitive economy. We welcome the European Commission's Proposal for a Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles (ELVs).
Motor vehicles constitute a significant repository of valuable materials. This makes the automotive industry a pivotal player in saving resources and curbing carbon emissions through circular economy practices. In this context, the EEB welcomes the proposal for a Regulation on Vehicle Design and End of Life Management (VDEoL), notably: The extension of the scope to cover vehicles beyond passenger cars Requirements…
· · filed 4 Dec 2023 · source
As a research institute for circular economy solutions in the plastics processing sector, we would like to draw your attention to the following issues: 1. Recognition of the use of post-industrial waste would be urgently needed: Justification – Multiple processing of plastics (whether post-consumer or post-industrial) will in any case lead to a reduction in material properties.
Filed in German · English published by the European Commission
The ICCT welcomes the opportunity to comment on the 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 and repealing Directives 2000/53/EC and 2005/64/EC.
The European Tyre and Rubber manufacturers association (ETRMA) welcomes the opportunity to comment on the European Commissions proposal on circularity requirements for vehicle design and on management of end-of-life vehicles, and would like to highlight the following points: Avoiding double regulation for ecodesign criteria Regulatory Circularity requirements for tyre design will be introduced through the Ecodesign…
Please find attached Insurance Europe's response to the European Commission's public consultation on the proposed Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles, amending Regulations (EU) 2018/858 and 2019/1020 and repealing Directives 2000/53/EC and 2005/64/EC.
VinylPlus supports the high level of ambition shown by the European Commission in the End-of-Life Vehicles Regulation proposal. To reach the target, the recognition for chemical recycling, operating in a complementary manner to mechanical recycling, as well as a separate additional circular plastics target will all be needed.
Dear ladies and gentlemen, as a medium-sized manufacturer of technical plastic parts and valve systems for the automotive industry, fully support the position of the association TecPart e.V., which you will find in the annex. We would ask you to consider the claims and take them into account in the further process.
Filed in German · English published by the European Commission
· · filed 4 Dec 2023 · source
AEPSA, Association of Portuguese Enterprises for the Environment Sector, presents in the attached document its comments and contributions regarding the public consultation carried out by the European Commission (EC) on end-of-life vehicles review of EU legislation.
Filed in Portuguese · English published by the European Commission
FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the Commissions Proposal for a Regulation on end-of-life vehicles (ELVs Regulation) as part of the new Circular Economy Action Plan (CEAP) and the European Green Deal.
ASSOFERMET, is the Italian Association of scrap waste recovery facilities, processing ferrous and non-ferrous metal scrap by adequate recovery operations, some of our members are also Car Dismantlers. We would like to contribute to the public consultation with the position paper attached.
The Fédération Internationale de Motocyclisme (FIM), welcomes the opportunity to comment on the the European Commission's proposed revision of the End-of-Life Vehicle (ELV) Directive, a crucial piece of legislation that impacts not only the motorcycle industry but all road users.
Dear COM, We support your ambition to make the ELV regulation improve the areas you have identified, i.e. 1. Design circular: make design and production circular. 2. Use recycled content: increase the recycled content in new vehicles. 3. Treat better: improve the treatment of ELVs. 4. Collect more: collect more ELVs in the EU and improve quality of exported used vehicles. 5.
TSR Recycling welcomes the European Commission’s proposal for a new regulation on end-of-life vehicles and its objective of improving the recovery of end-of-life vehicles and strengthening the EU internal market. TSR Recycling operates around 100 steel and metal treatment plants in 10 European countries.
Filed in German · English published by the European Commission
France Assureurs welcomes the European Commission's proposal on circularity requirements for vehicle design and the management of end-of-life vehicles. French insurers pay out more than 7.5 million claims for property damage every year. With a view to preserving the environment and as part of their CSR policy, they promote the repair and use of reused parts wherever possible.
· · filed 4 Dec 2023 · source
The regulation proposal describes that manufacturers have an extended producer responsibility for their vehicles that are available on the market for the first time within the territory of a Member State. Manufacturers shall, individually or collectively, ensure that end-of-life vehicles are collected or collected (Article 16).
Filed in Dutch · English published by the European Commission
In the current inflationary environment, rising costs for spare parts and repair are a growing concern for motor insurers and their customers. Particularly with the rapid uptake of electric vehicles, repair costs are rising disproportionately due to the lack of supply in the market and additional safety measures compared to conventional vehicles.
· · filed 4 Dec 2023 · source
Leather is a circular material: One of the major advantages of leather over synthetic fibres is beyond doubt that it is biodegradable; depending on the article and the leather formulation, leather fibres in the natural environment develop into CO2 and organic nitrogen in a few weeks’ time, which additionally stimulates plant growth.
Filed in German · English published by the European Commission
· · filed 4 Dec 2023 · source
R.PLAST Plastic Preparation and Handels-GmbH is a medium-sized company with approximately 20 employees. We looked at the recycling of mass thermoplastics, mainly in the field of post-industrial production residues from the plastic processing industry. We are almost exclusively active in polypropylene and polyethylene, producing clean and varietal shelves and grinding products.
Filed in German · English published by the European Commission
· · filed 4 Dec 2023 · source
MKV GmbH Kunststoffgranulate is therefore a recycler manufacturer of technical plastic granules based on recycled material. We have been working on recycling technical plastics for more than 60 years, returning them to the manufacturing industry as a raw material.
Filed in German · English published by the European Commission
The ALPLA Group, with its headquarters in Hard, Austria, and 190 locations with 23,300 employees in 46 countries worldwide, is one of the leading companies in plastic conversion. We develop and produce innovative rigid plastic packaging solutions, while ensuring that our products become lighter, more durable and by 2025 fully recyclable.
Plastics play a crucial role in in the automotive sector, and contribute to the enhancement of vehicles safety, enable electrification, emissions reduction, and improve the overall environmental impact of the industry by making the components more durable, and lighter.
Input from the Norwegian Environment Agency (This is a summary - find our full input in the attached document) We welcome the European Commission's initiative to develop a more circular economy in the automotive sector through the proposed regulation on circularity requirements for vehicle design and the management of end-of-life vehicles.
· · filed 4 Dec 2023 · source
We express our support to revise the ELVD and to combine it with that of the 3R Type-Approval Directive. As a pivotal legislative tool to enhance the lifelong sustainability of EVs, this revision is key for the e-mobility transition and can accelerate the growth of a robust recycling value chain within the EU.
PCEP (the Polyolefin Circular Economy Platform), brings together actors from across the polyolefin value chain, united in our common mission to drive the transition to a circular economy for polyolefins - the most commonly used family of plastics. 71.4% of plastics packaging in Europe is made of polyolefins, accounting for 71% of collected plastic waste.
CONEBI Position on Commission Proposal for a Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles CONEBI, the Confederation of the European Bicycle Industry, representing the EU Bicycle, Pedal Assist E-Bike, Parts and Accessories Industries, would like to express its views on the Proposal for a Regulation on circularity requirements for vehicle design and on management…
As a thermoformer, we have been working for many years on varietal collection and recycling of waste generated in the production process. These own recycled materials are incorporated into new board materials and their recovery is a major economic factor for us.
Filed in German · English published by the European Commission
Subject: Draft European regulation on requirements for circular construction of vehicles and on the disposal of end-of-life vehicles in the current version Dear ladies and gentlemen Designsbüro Hein GmbH accompany their customers with the first idea of a product made of or with plastic from the first idea to the end of live. The focus is on the sustainable design of products and their energy-efficient production.
Filed in German · English published by the European Commission
Eurometaux, representing the European non-ferrous metals industry, supports the objectives of the End-of-Life Vehicles revised proposal to increase availability and improve raw materials quality recycling to enhance EU open strategic autonomy and resilience and facilitate the circular transition of the automotive sector. Metals are present in the car body (e.g. aluminium), car battery (e.g.
The European Copper Institute (ECI) welcomes the European Commissions (EC) ambition to bolster responsible production and recycling of vehicles, as well as maintain within the EU economy the value carried by this stream.
The Association of the Automotive Industry of the Czech Republic (AutoSAP) and its members supporting the objectives of increasing the use of recycled materials and reducing the consumption of primary materials in production, as well as the proper handling of end-of-life vehicles. This is already common practice in our industry.
Filed in Czech · English published by the European Commission
· · filed 4 Dec 2023 · source
Mack Kunststofftechnik GmbH & Co. KG. The climate protection and thus responsible management of the planet’s resources is a great asset for us as a family business, and we therefore support the EU’s goal of achieving a new carbon continent by 2050. Our draught pieces are technically demanding and several times excellent.
Filed in German · English published by the European Commission
The Association of the Forum for the Recycling of Automobilhodów (FORS), based in Warsaw, is the largest and oldest Polish NGO representing the ELV recycling industry. We have almost 200 members, most of which are operators operating dismantling centres for end-of-life vehicles. We have been operating for more than 25 years.
Filed in Polish · English published by the European Commission
· · filed 4 Dec 2023 · source
Dear Sirs, We have a comment to article 45 in the proposal, regarding Electronic systems. We would encourage the Commission to consider reusing existing mechanisms for the exchange of vehicle registration data. Eucaris is a well-functioning system where the relevant information is already exchanged between countries in Europe.
Cefic welcomes the proposed Regulation addressing circularity requirements for vehicle design and the management of end-of-life vehicles (ELV) aiming to replace the 3R type-approval and ELV Directives. As raw material supplier at the top of this value chain, the chemical industry would like to provide feedback on cross cutting aspects of the proposal: Performance and information requirements on substances of…
LMK's Recommendations; LMK is convinced that European regulators can improve the regulatory protection of historic vehicles by adopting the following recommendations in the upcoming legislative debate: 1) Ensure the recognition of historic vehicles and their exemption from the ELV category by the Member States when interpreting and enforcing waste and roadworthiness legislations; 2) Provide for the presumption that…
The Federation of Swedish Historic Vehicle Clubs, MHRF, welcome that the Commission has regarded the legitimate need to protect the historic vehicles, the culture heritage and thereby the movements efforts to preserve, protect and promote these vehicles.
PowerShift welcomes the Commission's plan to replace Directive 2000/53/EC with a Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles (ELV), as the Directive has not been successfully implemented across the EU. So we support a stronger legal framework and ambitious circular economy in the mobility sector.
MOCOM GmbH & Co. KG welcomes the Commission’s proposal for an EU Old Driving Stock Regulation, which is intended to be valid throughout Europe and aims to increase the circulation of vehicles, including their components and materials. At the same time, we are critical of some of the proposed points with regard to an environmentally sound design, as explained in the attached document.
Filed in German · English published by the European Commission
DUH welcomes the EUs intention to ensure end-of-life vehicles (ELVs) are managed sustainably and re-quiring the car industry to adopt a sustainable design and production of cars as part of the Regulation on Circularity Requirements for Vehicle Design and on Management of End-of-Life Vehicles (VDEoL).
SLO Chamber of Crafts and Business, Committee of End-of-Life Vehicles proposes: 1. Chapter IV, Section 2 of the amendment is designed to include all existing waste management operators (installations for the treatment and decommissioning of vehicles which, at the time of adoption of the Regulation, already meet the conditions, hold an environmental permit and already operate in a legal end-of-life management system)…
Filed in Slovenian · English published by the European Commission
Please find enclosed the joint opinion of the Bvse-Bundesverband Sekundärrohstoffe und Entsorgung e.V. – BDSV – Bundesvereinigung Deutscher Stahlrecycling- und Entsorgungunternehmen e.V. – Verband Deutscher Metallhändler e.V. (VDM)
Filed in German · English published by the European Commission
· · filed 4 Dec 2023 · source
As a motor vehicle service, we use the maintenance instructions developed and issued by vehicle manufacturers. The procedures contained therein shall clearly specify when and to what extent a component can be repaired in such a way that the vehicle complies with the requirements for approval and entry into service. Inter alia, the drive unit (engine+gearbox) is referred to as spare parts.
Filed in Polish · English published by the European Commission
Mazda Motor Europe supports the ambition of the European Green Deal to achieve a climate neutral, clean and circular economy by 2050. Already today, the car industry is committed to developing vehicles sustainably so that they can deliver exceptionally high recycling rates when reaching the end of their lives.
SUEZ welcomes the European Commissions proposal on the requirement for vehicle design and on management of end-of-life vehicles. The regulation would contribute to a more sustainable management of end-of-life vehicles by improving the circular design, ensuring more materials are recovered and recycled, making producers financially responsible, and better controlling the exports of used vehicles.
· · filed 4 Dec 2023 · source
Article 18 Paragraph 4 According to the Greek law (Law 4819/ Gov. Gazette 129A/2021) is not allowed for members of the board of any PRO to be employed in a managerial position of a waste management operation/company. Article 22 Paragraph 1 The mechanism of waste allocation between PROs in different Member States will add to bureaucracy and will be difficult to track logistically.
· · filed 4 Dec 2023 · source
For us, as a family business, climate action and thus the responsible use of our planet’s resources is a great asset, so we also support the EU’s goal of achieving a carbon-neutal continent by 2050. Our technically demanding and multiplely excellent components for the automotive industry are made of technical plastics for which there is currently no post-consumer waste stream.
Filed in German · English published by the European Commission
· · filed 4 Dec 2023 · source
ACEM recognizes the importance of the EU Commission's initiative to revise the ELV Regulation and include L-category vehicles. While we fully support the regulation's objectives towards sustainability and circularity, we urge co-legislators to consider: (1) Including all L-category vehicles for regulatory coherence; (2) Integrating L-category vehicles in the scope of article 5 to improve legislative coherence and…
The proposed criteria, which qualify a vehicle as EoL, are absolutely unacceptable. They are far too broad, including non-waste vehicles and eligible for repair. The adoption of these provisions will result in a serious infringement of the right of ownership and acquired rights of vehicle owners, as guaranteed by Article 17 of the Charter of Fundamental Rights of the EU, the right to property and, under Polish law…
Filed in Polish · English published by the European Commission
· · filed 4 Dec 2023 · source
Novelis, the worlds largest aluminium recycler that produces aluminium products with the highest amount of recycled content (double the industry average at around 61%), highly welcomes the chance to provide feedback on this proposal for a regulation.
DERICHEBOURG, a European player in automotive recycling DERICHEBOURG is a family-owned group, created in 1956 by entrepreneurs who were aware of the recovery potential of metal waste. Particularly present in France and Europe, with a dense territorial network, the group produced 6 million tons of recycled metals in 2022.
· · filed 4 Dec 2023 · source
Feedback: We would like to clarify when a vehicle is defined as an end-of-life vehicle and its export or further sale is restricted. The Finnish Compensation Inspectorate, SVT Oy, acts as an independent liquidator for the amount of damage and the accident in the event of damage suffered by injured parties.
Filed in Finnish · English published by the European Commission
Directive 2000/53/EC of the European Parliament and of the Council of 18 September 2000 was transposed into Spanish law by Royal Decree 1383/2002 of 20 December on the management of end-of-life vehicles, which established a series of preventive measures from the design stage of the vehicle to reduce and limit the use of hazardous substances in its manufacture and to facilitate the reuse, recycling and recovery of…
Filed in Spanish · English published by the European Commission
The European Automobile Manufacturers' Association (ACEA) is firmly committed to advancing the EU towards a modern, resource-efficient, and competitive economy. We welcome the European Commission's Proposal for a Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles (ELVs), which envisages a transformation towards enhanced sustainability, circularity, and innovation.
The Automotive Parts Remanufacturers Association [APRA] appreciate the new ELV-R with a clear target to support Automotive Remanufacturing. We as association highly support: 1. The request to collect relevant data out of design and development of a vehicle and to share them with waste management operators and repair and maintenance operators.
The National association for French OEM and Tier 1 suppliers (PFA) welcomes the Commission's proposal for a regulation of ELV and circularity requirements. The automotive industry is transitioning to fossil-free products and PFA members believe that in all their actions, they must consider how to reduce climate impact, use of the worlds resource more efficiently and conduct business more responsibly.
AVERE - the European Association for Electromobility welcomes the European Commissions proposal to revise Directive 2000/53/EC on end of-life vehicles and Directive 2005/64/EC on the type-approval of motor vehicles with regard to their reusability, recyclability and recoverability and to transform it into a Regulation.
Summary The intention of the proposal, in particular as regards the circular dynamics of end-of-life vehicles, is generally supported. Emphasis should be placed on the design of the future rules on the use of recycled materials in accordance with Article 6.
Filed in German · English published by the European Commission
The ECF supports the move to a better environmentally friendly industry and is working with its partners on many aspects to improve this including the materials used in the manufacture to enable a reduction in our effect on the environment. However, we feel the inclusion of trailers in the End-of-life vehicle Regulation will have a very minimal benefit with an out of proportion cost to the industry.
Plastic preparation has been producing technical plastics from a wide range of sectors for almost 20 years. These mainly include car motives, electronics and household. During this period, our primary field of activity has evolved to reduce and reprocess plastics from post-industry materials (PIR) and has been expanded over the last few years to include numerous post-consumer projects (PCR).
Filed in German · English published by the European Commission
· · filed 4 Dec 2023 · source
The proposals contained in Article 26 of the draft Regulation run counter to the respect of the right to property, which is guaranteed both by Article 17 of the Charter of Fundamental Rights of the European Union and by the Fundamental Laws of the individual Member States.
Filed in Polish · English published by the European Commission
· · filed 3 Dec 2023 · source
The Polish EKO-AUTO Vehicle Deconstruction Station Association was the only organisation in Poland to consult extensively on the draft Regulation. Between 3 and 20 October 2023, meetings were held throughout the country with the owners and staff of the dismantling centre (ELV). It should be stressed that the provisions of the draft Regulation are crucial for the continued operation of dismantling centres in Europe.
Filed in Polish · English published by the European Commission
· · filed 3 Dec 2023 · source
Dear Sir, this initiative undermines the human rights to private property and the freedom to manage human property. Everyone has the right to repair his or her own object, whether it is a washing machine, any car or a hammer. An official will never see better than the owner whether repairing an item is cost-effective or not.
Filed in Polish · English published by the European Commission
TO THE EU: Statement Hälsingland is one of the landscapes in Sweden associated with ambitious and knowledgeable vehicle renovators as well as talented and successful competitors. The car village in all its forms involves a large number of people, both among younger and older people.
Filed in Swedish · English published by the European Commission
· · filed 3 Dec 2023 · source
With the recycling quotas, the new ELV regulation provides clear guidelines for recycling. It is also important, right and necessary that automobile manufacturers are become responsible for developing more circular solutions in the plastics sector as well. However, there are still many definitional gaps and need for action in implementing the ELV regulation.
· · filed 3 Dec 2023 · source
I propose that the EU moves away from our cars once and for all. Vehicles should be designed for as long as possible. Downsizing makes vehicles unstable and emergency. Different eco-additives have the same impact on the durability of vehicles. Back to design in the 1980s and 90s when the best structures were designed. Electromobility is a utopia and there is no raison d’être on the free market.
Filed in Polish · English published by the European Commission
· · filed 3 Dec 2023 · source
I have to completely disagree with the following regulation. The entire document needs to be re-worked from the scratch. 1) transmissions and engines are replaceable parts of cars, the proposed document is contrary to EU free flow of goods; (2) the regulation is non-ecological. A car should be used and Repaired as long as possible; (3) forced assessment of the car as a ‘total loss’ is absurd.
Filed in Polish · English published by the European Commission
I also believe that this is a very bad directive. The EU is a communist creator. More and more bans on civil liberties.The European Union must be destroyed and buried underground like your trouble and life-threatening windmills! A prech with whom!
Filed in Polish · English published by the European Commission
· · filed 3 Dec 2023 · source
Popieram złomowanie wraków, ale nie wolno złomować samochodów, które da się naprawić, ponieważ naprawa i dalsze użytkowanie samochodu jest bardziej ekologiczne niż utylizacja i wyprodukowanie nowego. NIE ZŁOMUJCIE PRAWIE-DOBRYCH SAMOCHODÓW! ZŁOMUJCIE TYLKO ZNISZCZONE WRAKI!
The End of life vehicles Regulation (ELV) is an opportunity to make an important leap forward in an industry that is strategic for Europe. Tackling sustainability of vehicles in general, and plastics use in particular, is critical as the car industry is responsible for 10% of the overall consumption of plastics (6 million tons/year) in the EU.
Welcome. I am a Polish entrepreneur, I run the company TOP CAR, which repairs and sells second-hand cars from European Union countries, mainly from France and Germany. My company mainly buys second-hand cars from the 2016 yearbooks until 2023 with damaged engines and damaged body parts that have low mileage and damaged.
Filed in Polish · English published by the European Commission
· · filed 2 Dec 2023 · source
Club MC-Veteranerna Sverige responds strongly to ELV Regulation 2000/53/EC in its current form. We fully agree with the comments of the Swedish Motor Historical Federation in its reply to the Government Offices of Sweden (KN2023/03704).
Filed in Swedish · English published by the European Commission
NEW ELV DIRECTIVE: CONSIDERATIONS FROM THE COMPOSITES VALUE CHAIN PERSPECTIVE The European Composites Industry Association (EuCIA) welcomes the new ELV Directives objective to improve circularity in the automotive industry. The automotive industry has benefited for decades from the combination of exceptional mechanical properties and lightweighting of composites..
FER is the association of the recovery and recycling sector in Spain. Within FER there are large representation of car dismantler and 100% of the vehicle shredders and post- shredders industry in Spain. FER welcomes to this initiative of the COM to improve de circular economy of the vehicles. We attach the position of the Spanish recycling sector, and we are specially concern about two points: 1.
Although we agree with some measures, we believe that it is necessary for this proposal to be successful that it is necessary to modify part of its content, and for this Royal Decree 265/2021 of 13 April, on end-of-life vehicles published by Spain could be a good example. We attach a document with our comments
· · filed 1 Dec 2023 · source
— The rules must be applied to the same extent to imported vehicles as otherwise the European car industry would be severely disadvantaged vis-à-vis foreign manufacturers and the problem of the current under-use of enzymes would be externalised. — A recycled rate needs to be regularly assessed and, if necessary, adjusted.
Filed in German · English published by the European Commission
· · filed 1 Dec 2023 · source
The Association of International Motor Vehicle Manufacturers (VDIK) has represented the interests of international car and commercial vehicle manufacturers in Germany since 1952. This includes 46 brands from 13 different countries. They sell more than 1 million passenger cars annually. This is a market share of almost 40 %. In addition, VDIK members sell around 100.000 commercial vehicles.
Filed in German · English published by the European Commission
From 1999 to today, Ecoeuro Srl has operated as a point of reference at a national level for companies that wish to understand and correctly manage the activities related to End-of-Life Vehicles. Following the publication, which took place on 13 July, of the proposal for a European regulation on circularity requirements in the design of vehicles and in the management of ELV, Ecoeuro Srl has prepared the following…
Glass Fibre Europe, representing the continuous filament glass fibre manufacturing industry in Europe, welcomes the European Commission proposal to review the End-of-Life of Vehicles Directive. To our industry, it stands clear that glass fibre reinforced (GFR) composites must be sustainable to be part of our future.
Being a cross sector association with member companies operating in different industries and stages in the supply chain (electronics, chemicals, polymer, automotive , machinery, semiconductor, steel, nonferrous metal, textiles, ceramics, and glass products), Japan Business Council in Europe (JBCE) welcomes the opportunity to contribute to the Commission 's proposal regarding End of life Vehicles (ELV) revision of EU…
The Japan Automobile Manufacturers Association (JAMA) is a non-profit industry association comprising Japans fourteen manufacturers of passenger cars, trucks, buses and motorcycles. With climate change and other environmental issues being matters of global urgency, JAMA is committed to addressing relevant challenges in order to contribute to the European Union's policy objective of achieving climate neutrality by…
The TIV industrial association - The Trailer Industrie Verband e. V. (TIV), founded in 2015, represents the interests of manufacturers of O1 and O2 trailers (up to 3,500 kg maximum authorized mass, caravans excluded) and their suppliers. The association has its headquarters in Berlin.
FEDEREC is the professional federation of recycling companies. It represents 31 000 jobs that cannot be relocated, 1200 companies, from multinational companies to SMEs and SMEs, spread over the whole of France and whose activity consists of the collection, sorting and material recovery of industrial and household waste or trading/brokering of the First Issues of Recyclage (MPiR).
Filed in French · English published by the European Commission
Hello! I hereby wish to submit the Swedish Motorcyclist (SMC) contribution to the EU Regulation on end-of-life vehicles and type-approval. The SMC welcomes the proactive work to improve environmental performance and recycling of different types of vehicles and strategic components.
Filed in Swedish · English published by the European Commission
FEICA, the Association of the European Adhesive & Sealant Industry welcomes the EU Commission proposal for a regulation on circularity requirements for vehicle design and end-of-life vehicles. However, the explicit and generalised mention of adhesives as an impediment to the circularity of end-of-life vehicles is inaccurate and it also misses the crucial role that adhesives play in the overall sustainability, the…
· · filed 1 Dec 2023 · source
Andreas Becker, CEO of the Weber Group I believe that the following points should be taken into account: A single varietal grouping of waste streams from the different sectors (packaging, construction, electrical, car, etc.) must be possible (open loop) in order to build a sufficient amount of technological, environmental and economic recycling.
Filed in German · English published by the European Commission
European Aluminium welcomes the publication of the long-awaited proposal for a Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles (ELV) and looks forward to engaging with policymakers for the shaping of an effective and forward-looking ELV Regulation.
· · filed 1 Dec 2023 · source
I would like to ask you to bear in mind or assess the following points: A single varietal grouping of waste streams from the different sectors (packaging, construction, electrical, car, etc.) must be possible (open loop) in order to build a sufficient amount of technological, environmental and economic recycling.
Filed in German · English published by the European Commission
The BMW Group is committed to the goals of the Paris Agreement and is leading the way in circularity within the automotive industry. We underpin our commitment with ambitious targets for the use of secondary raw materials as well as with principles including Secondary First, which prioritizes the use of recyclates in development processes, and Design for Circularity, which takes a vehicles recyclability into account…
PRE advocates for the recyclability of plastic packaging by design and the inclusion of recycled content in parts and components for new vehicles placed on the market. Therefore, PRE welcomes the requirements of the EC proposal for all vehicles to be designed according to their end-of-life management.
Plastics Europe supports the high level of ambition shown by the European Commission in the End-of-Life Vehicles Regulation proposal. To reach the target, the recognition for chemical recycling, operating in a complementary manner to mechanical recycling, as well as a separate additional circular plastics target will all be needed. We therefore call for:
We as European Association of Manufacturers of Moulded PU Parts for the Automotive Industry (EURO-MOULDERS) contribute to the public consultation with the position paper that can be found attached. Along with that, our key points of the contribution: Article 3. The definition of plastics in article 3(9) of the draft ELVR should be amended to cover more plastics, including polyurethanes.
From the Spanish Association for the Environmental Treatment of End of life Vehicles (SIGRAUTO) constituted in 2002 and formed by the Spanish Association of Automobile Dismantlers and Recycling (AEDRA), the Spanish Association of Automobile and Truck Manufacturers and Importers (ANFAC) and the Spanish Federation of Recovery and Recycling (FER), we would like to convey the position of the sector and some…
· · filed 1 Dec 2023 · source
We as FEEI (Austrian Association for the Electric and Electronics Industry) are disappointed with the incomplete alignment between the proposed Regulation on circularity requirements for vehicle design and on management and the new Batteries Regulation. Therefore we request that: 1.
Exide Technologies is a manufacturer of lead and lithium based batteries for industrial and automotive application. Circularity and decarbonisation are the key elements of our business model, hence we very much appreciate the new EU Battery Regulation 2023/1542. Under Article 6 of the Battery Regulation, we will see a holistic assessment of substances of concern in batteries.
Following the publication on July 13 of the proposal for a European Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles, the Spanish Automobile Dismantling and Recycling Association (AEDRA ) and the Italian National Association of Car Dismantlers (ADA) have prepared the following position paper regarging the future compliance with the Regulation.
EuPC supports the European Commission's proposal for the revision of the rules on End-of-Life vehicles, specifically the commendable goal of attaining a minimum of 25% recycled content target for plastics in newly approved vehicles.
Opinion of the Japan Auto Parts Industries Association on Proposal for a Regulation of the European Parliament and of the Council of the European Communities on vehicle design circularity requirements and the management of end-of-life vehicles 1.
· · filed 1 Dec 2023 · source
Matthias Klein, director production and operations of the Weber Group, a global automotive supplier for plastic assemblies in the fields of interieur, exterieur and powertrain. In our view, the following issues should be taken into account in the revision of the Regulation: A single varietal grouping of waste streams from the different sectors (packaging, construction, electrical, car, etc.) must be possible (open…
Filed in German · English published by the European Commission
· · filed 30 Nov 2023 · source
I, Dr Thomas Zipp, write to you as the owner and advisory board chair of our 75 years old, successful family business that develops and produces innovative plastic solutions for the automotive sector. We are at the engineer, exterieur and powertrain at home.
Filed in German · English published by the European Commission
· · filed 30 Nov 2023 · source
In our view, the following points should be taken into account: A single varietal grouping of waste streams from the different sectors (packaging, construction, electrical, car, etc.) must be possible (open loop) in order to build a sufficient amount of technological, environmental and economic recycling.
Filed in German · English published by the European Commission
FIVA is following with interest the proposal by the European Commission on End-of-life Vehicles (ELVs) COM/2023/451 final. FIVA welcomes the introduction of the historic vehicle definition as provided by the Roadworthiness Testing Directive 2014/45/EU, as well as the exemption of historic vehicles from the ELV category.
· · filed 30 Nov 2023 · source
Dansk Autogenbrug (DAG), the Danish business association for auto recyclers, welcomes this proposal. This space only allows us to draw attention to matters which we assess will not sufficiently contribute to the fulfilment of the regulation or may work to the disadvantage of the efficiency of our industry: Art 6 However laudable these targets are, we fear in general that car manufacturers increasingly will want to…
· · filed 30 Nov 2023 · source
Please find attached a few proposals that would be very important to us: A single varietal grouping of waste streams from the different sectors (packaging, construction, electrical, car, etc.) must be possible (open loop) in order to build a sufficient amount of technological, environmental and economic recycling.
Filed in German · English published by the European Commission
· · filed 30 Nov 2023 · source
SAHK (The Historical Vehicle Association of Finland) and VMPK (Vintage Motorcycle Club of Finland) represent more than 13.800 enthusiasts of historic vehicles in Finland. Our goal is to preserve alive the historic vehicles motoring heritage in Finland for todays-people as well as for the future generations.
· · filed 29 Nov 2023 · source
FNADE, the French association for waste management and environmental services, fully supports the revision of the End-of-Life Vehicles Directive that makes a clear link between design issues and end-of-life treatment aiming to improve recycling efficiency and that requires mandatory recycled content.
· · filed 28 Nov 2023 · source
Transport & Environment, Europes leading clean transport campaign group, welcomes the Commissions proposal for a revised End of Life Vehicles law. This law is fundamental to ensure circularity of cars and greening of their production. The revised legislation should be as much about what goes into making a new car (low carbon and recycled materials) as about how its recycled at the end of its life.
· · filed 28 Nov 2023 · source
The new ELV Regulation is the basis for the further development of recycling of end-of-life vehicles. It provides the justification for taking steps in this regard and brings the circular economy closer. Scooter Recycling Nederland (SRN) aims to ensure responsible and high-quality dismantling and recycling of motorised mopeds.
Filed in Dutch · English published by the European Commission
· · filed 28 Nov 2023 · source
The Commission’s proposal for a regulation on circularity requirements for vehicle design and end-of-life vehicle management Summary KAK rejects the Commission’s proposal. In practice, the proposal would make it impossible for vehicle occupants to care for the rolling cultural heritage. The proposal seriously restricts the right to property.
Filed in Swedish · English published by the European Commission
· · filed 27 Nov 2023 · source
Modified Motorcycle Association of Finland MMAF wishes to state the following: Modified Motorcycle Association of Finland MMAF is recommending to leave motorized two-wheelers (L-class) out of the ELV-Directive. All we know and by our sister organization SMOTOs study on the reuse level of motorized two-wheeled vehicles 2021 are giving results that the ELV-Directive will make recycling of motorcycles worse, than the…
· · filed 27 Nov 2023 · source
Finnish Motorists’ Association (SMOTO) is not in favour of extending the End-of Life Vehicles Directive to motorised two-wheelers. The effects of the directive would be more negative and would reduce the actual reuse of parts. By our study in 2021 ELV Directive does not improve the recycling on motorised two-wheelers. On the contrary, it makes the recycling worse.
Filed in Finnish · English published by the European Commission
· · filed 27 Nov 2023 · source
Richards and Jerrom Ltd is a business, based in Tipton in the West Midlands, focussed on the recycling of end of life vehicle engines and gearboxes (EWC 16:01:17) to produce environmentally friendly raw materials for supply to metal manufacturers. Our customers require high specification aluminium ingots, clean cast iron, steel and other non ferrous metals.
Overall, AirClim strongly supported the adoption of ambitious measures to tackle the continuing problem of 'missing vehicles'. AirClim also supports stricter requirements on the export of used vehicles, to avoid used vehicles which are not roadworthy, generate air pollution and present health risks are exported from the EU to third countries.
· · filed 27 Nov 2023 · source
My view is that the EU should not decide what I should own or not, even when I sell inheritance or similar. Absurd that the EU should decide which vehicles to own, buy or sell, or to decide at all what we do with our acquired property! The culture of conservation of historic vehicles in Sweden has nothing to do with the EU
Filed in Swedish · English published by the European Commission
The German automotive industry is fully committed to the Paris climate targets. The strategy of the German automotive industry to reduce the carbon footprint goes far beyond the use phase of a vehicle and covers the whole life cycle, from raw materials and production, repair, reuse and remanufacturing to recycling.
Filed in German · English published by the European Commission
MAIF, Frances 6th largest motor insurer, is a pioneer in the re-use of car parts. As such, MAIF : 1. Welcomes the measures concerning the recyclability of vehicles, but would like to see greater consideration regarding the reparability of parts / 2. Stresses the importance of making repair data accessible and supports the measures promoting vehicle traceability / 3.
We appreciate the possibility to comment on the European Commissions proposal for a Regulation that for the first time seeks to cover design and production of vehicles placed on the EU market in addition to end-of-life treatment.
· · filed 21 Nov 2023 · source
Protest against the EU proposal to amend the ELV Directive Scandinavian Off Roaders Sweden was created in 1975 and aims to care for and preserve off-road vehicles such as Jeep, Landrover, etc. Our association has everything from Willy’s war heaps from the Second World War to newer off-road vehicles. The majority of our members’ vehicles are jeeps older than 30 years and are counted as veterans.
Filed in Swedish · English published by the European Commission
· · filed 21 Nov 2023 · source
Suggestion: In Annex VII, part C, 7), proposal to add and roof, after the words side windows and before made of glass. Explanation: The suggestion is to extend the requirement to remove windows made of glass also to car roofs made of glass. This additional information aims at being fully exhaustive, to be sure that all parts made of glass in the vehicle are managed sustainably to be reused or recycled.
· · filed 20 Nov 2023 · source
The whole document is full of good ideas, processes and instructions, and brings lots of great improvements but is very light on enforcement and how these new rules are going to be monitored and enforced - if current practices continue then the legislation is worth the paper it is printed on because nothing will change.
· · filed 17 Nov 2023 · source
Opinion: We call for vehicles aged 30 or over to be exempted – unconditionally. Amendment of Article 2, 2 (d). Justification: The Veteran car village in Sweden is very large. Around 0,5 million vehicles are over 30 years old. As a hobby, 100 000 people have to renovate, manage, showcase and welcome millions of people in Sweden with these vehicles.
Filed in Swedish · English published by the European Commission
With currently more than 21 million members, ADAC e.V. is the largest automobile club in Europe and the second largest in the world. The four letters in its name stand for an association which offers its members assistance, protection and advice around the clock and is a powerful stakeholder on all mobility issues.
Filed in German · English published by the European Commission
As EUROBAT, we are disappointed with the incomplete alignment between the proposed Regulation on circularity requirements for vehicle design and on management and the new Batteries Regulation. We request that: 1. Restrictions of battery substances to be removed entirely from the scope of the proposed Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles.
Confartigianato Imprese is the most representative Italian organisation of crafts and micro and SMEs and one of the most important social partners in Italy. At national level, it counts 104 local associations, 21 regional federations, 1,206 offices and 10,700 employees, offering different types of services to over 1.5 million artists and small business owners and more 700.000 enterprises.
Filed in Italian · English published by the European Commission
· · filed 6 Nov 2023 · source
The CNA – National Confederation of Crafts and Small and Medium-sized Enterprises (CNA), assigns to the Confederation of Riunded Autodemolishers (CAR), which brings together at national level the operators involved in the recovery and treatment of end-of-life vehicles.
Filed in Italian · English published by the European Commission
If the Directive becomes law in Sweden, our cultural heritage, history, will suffer tremendously harm, as well as a large number of businesses, the economy and the country’s level of technology, crafts and history will be severely affected. Therefore, the introduction of the Directive must be stopped!
Filed in Swedish · English published by the European Commission
· · filed 29 Sept 2023 · source
We also welcome the development regarding the EU's draft regulation for ELVs. What we believe must also be an important sub-point is increasing the reuse of used parts. To this end, recyclers must be given the opportunity to obtain adequate vehicles in order to obtain spare parts. In Germany, for example, most total loss vehicles are sold to neighboring EU countries.
The Finnish Innovation Fund Sitra supports the European Commissions proposed act on circularity requirements for vehicle design and the management of end-of-life vehicles. In Sitras view, the proposed act is key to advancing the data economy and the circular economy in Europe.
After a very long time the proposal for the new ELV regulation is a reality at last. As an ATF I must commend the EU for taking a significant step forward in addressing the environmental challenges associated with automobile disposal. The proposal demonstrates a strong commitment to sustainability, recycling, reducing the ecological footprint of the automotive industry and promoting the reuse of vehicle parts.
The Beryllium Science and Technology Association (BeST) represents the manufacturers, suppliers and users of beryllium metal, beryllium containing alloys and beryllium oxide ceramics in the EU market. BeST has the objective of promoting sound policies, regulations, science and actions related to the safe use of beryllium and to serve as an expert resource for the international community on the benefits and…
· · filed 21 Sept 2023 · source
We strongly support the EU proposal to address recycled plastic content targets in new passenger cars and light commercial vehicles. In line with Europe's aim to become a leader in the innovation space, we believe that the EU can advance its objectives to reduce plastic pollution by providing technical leadership to qualify first-of-kind technologies alongside traditional recycling technology solutions.
The revision of the ELV with inclusion of "circularity requirements" is welcomed. Indeed the need for Automotive OEM to create their own Circular strategy is positive, however, the key definition of circularity is perhaps not fully elaborated.
· · filed 31 Aug 2023 · source
Suggestion: In Annex VII, part F, 5), proposal to add ideally into flat glass or, if not possible, after the words shall be recycled and before into container, in the sentence Removed glass from the end-of-life vehicle, as a minimum, shall be recycled into container glass, fibre glass, or equivalent quality.
Dear colleagues, Well done so far! Pondering on the meaning of "homogeneous material" in Annex III of COM(2023) 451 final, kindly define or at least refer to Directive 2011/65/EU (RoHS) Art. 3 (20): "homogeneous material means one material of uniform composition throughout or a material, consisting of a combination of materials, that cannot be disjointed or separated into different materials by mechanical actions…
· · filed 19 Nov 2020 · source
The Czech Republic is aware of and approve the necessarity for an update of ELV directive, mainly because of increasing numbers of electric vehicles put on market these days and necessarity of dealing with electric vehicles at the end of their life time. Below are some points, which should be solved.
The revision of Directive 2000/53/EC, which was adopted in the twentieth century, has long been expected by the recycler environment. We are pleased to see that work is underway to amend the provisions of the Directive and that all economic operators responsible for achieving the objectives set out in the Directive are involved in the evaluation of the Directive.
Filed in Polish · English published by the European Commission
The GKV/TecPart — Verband Technische Kunsterzeugne e.V. welcomes the efforts of the European Commission to reform the End-of Life Vehicles Directive to meet future challenges, such as the transition to electromobility, the challenges of decarbonising society and protection of the environment.
Filed in German · English published by the European Commission
· · filed 19 Nov 2020 · source
Concordia Employers Confederation is endorsing the position of the European Automobile Manufacturers’ Association (ACEA) to support the European Commission’s initiative to ensure a better consistency with the objectives of the Green Deal, including the Circular Economy Action Plan and the European Climate Law.
The European Copper Institute (ECI) welcomes the opportunity to comment on the European Commission’s inception impact assessment on the End-of-Life Vehicles (ELV) Directive. One of the missions of ECI is to promote the sustainable use of copper in electric vehicles. One of the goals of the European Green Deal is the full decarbonisation of cars and vans by 2050.
The non-ferrous metals industry is one of key suppliers for the automotive sector. Metals are present in the car body (e.g. aluminium), car battery (e.g. lead, lithium, nickel, cobalt, copper), catalytic converter (e.g. platinum, palladium) or motor (e.g. copper) to name just a few applications.
EuRIC strongly welcomes the Inception Impact Assessment on the revision of Directive 2000/53/EC on end-of-life vehicles (ELVD) and its main objectives to increase the contribution of the automotive sector to the circular economy and to ensure that the ELVD is adapted to the current and future challenges faced by this sector.
The EEB welcomes the Commissions' objective to revise the ELV Directive, aiming at achieving reductions of negative social, economic and environmental impacts of the sector, and equally important to bring the sector closer to the approach of circular economy.
Plastics Recyclers Europe (PRE) represents the interest of the plastics recycling industry. Several of PRE members are specialized in treating the shredder light fraction resulting from the ELV treatment to produce plastics recyclate for use in the traditional plastics compounding and converting industries. A fraction of this material is already being used in the automotive supply chain.
The European Tyre & Rubber Manufacturers’ Association (ETRMA) and its members count around 4.300 companies in the EU, employing directly 360.000 people. We have strong presence in the EU and candidate countries with 93 tyre-producing plants and 17 R&D centres. EU production is estimated in 5.1 million tons of Tyres and 2.3 million tons of General rubber goods.
· · filed 19 Nov 2020 · source
About EPR we have some things to say about costs and value of the vehicle and about funds for extra costs because if we want to be more circular than we are, extra activities without extra income will not happen. The value in an ELV is mentioned often. We do not question the value, but taking it out brings costs.
The ELV Directive, which came into force 20 years ago largely delivered on its initial objectives due to the significant efforts made by the automotive and the recycling industry. The European Automobile Manufacturers’ Association (ACEA) fully supports the European Commission’s initiative to ensure a better consistency with the objectives of the European Green Deal, including the Circular Economy Action Plan and the…
The European Steel Association (EUROFER) welcomes the review of the Directive 2000/53/EC on End-of-Life Vehicles (ELVs). The Directive has contributed effectively to the improvement of the management of waste generated by discarded vehicles (ELVs) and to the establishment of ELVs recycling.
Veolia welcomes the revision of the ELV Directive as a way to increase the contribution of ELV management to the circular economy in line with the Green Deal and the Circular Economy Action Plan. The ELV Directive has been instrumental in better managing vehicles once they become waste and Veolia calls for an ambitious revision based on the following key principles: 1/ Facilitating dismantling and recycling by…
Ecoeuro s.r.l. is a service company capable of generating environmental, commercial and operational solutions for the development of activities linked to the dismantling of vehicles with new horizons throughout the world of car.
Filed in Italian · English published by the European Commission
CEWEP welcomes the Commission's new initiative on the Revision of Directive 2000/53/EC on end-of-life vehicles, in order to update this current legislation and to improve its coherence with the aims of the green deal and the circular economy action plan. CEWEP would like to highlight the importance to maintain a holistic approach and to strike the right balance between policy goals (e.g.
The revision process of the ELVs Directive needs to aim at the following key objectives: 1. to transform the ELVD into a Circularity enabler promoting and ensuring design for recyclability of new vehicles and their parts; 2.
The Finnish Scrapdealers Association welcomes the Revision of Directive 2000/53/EC on end-of-life vehicles (ELV) as part of the new Green Deal. We support the goals of the ELV Directive and call for measures linking the ELV Directive with the objectives of the Plastics Strategy and adapting it to the challenges posed by new types of cars progressively entering the market.
With this position paper, EUROBAT would like to provide its expert input on the Inception impact assessment on the End-of-Life Vehicles Directive. Timing: the proposal is severely delayed First of all, we regret that the proposal is considerably delayed compared to the own Commission legal obligation to “review the ELV Directive, by 31 December 2020, and to this end, shall submit a report to the European Parliament…
The revision process of the ELVs Directive needs to aim at the following key objectives: 1. to transform the ELVD into a Circularity enabler promoting and ensuring design for recyclability of new vehicles and their parts; 2.
The revision process of the ELVs Directive needs to aim at the following key objectives: 1. to transform the ELVD into a Circularity enabler promoting and ensuring design for recyclability of new vehicles and their parts; 2.
· · filed 19 Nov 2020 · source
The FIA European Bureau welcomes the European Commission’s ambition to adapting the end-of-life vehicles (ELVs) rules to the objectives set out in the European Green Deal, as well as to considering the technological advances.
The Federation of Recycling Companies (FEDEREC) represents the authorised economic actors carrying out the recycling of end-of-life vehicles (ELVs), from the administrative care of the vehicle to the recycling and energy recovery of materials. In this respect, FEDEREC has a strong interest in the ongoing revision of Directive 2000/53/EC of 18/09/00 on ELVs.
Filed in French · English published by the European Commission
· · filed 19 Nov 2020 · source
It is important for Estonia that the ELV Directive allows for the deletion of end-of-life vehicles from the register under certain conditions, even without a certificate of destruction, as the ELV Directive does not contain any measures in case a motor vehicle no longer exists. The Commission intends to review the objectives and rules for end-of-life vehicles.
Filed in Estonian · English published by the European Commission
The Revision of Directive 2000/53/EC on end-of-life vehicles will lead to update this current legislation to economic reality and to improve coherence with the aims of the Green Deal and the Circular Economy Action Plan.
· · filed 18 Nov 2020 · source
The Netherlands welcomes the Inception Impact Assessment on the revision of the Directive on end-of-life vehicles. The Netherlands strongly supports a comprehensive scope of the revision, taking into account the full life cycle of vehicles from eco-design and the uptake of recycled content to recycling, and the consideration of vehicle types that are currently left out of the scope of the Directive.
The Critical Raw Materials Alliance (CRM-A) represents primary producers, traders and associations of raw materials that the European Commission has determined to be critical to the European economy (CRMs). The CRM-A has closely examined the Commission’s plan to review the ELV Directive and supports the aim to reassess it in light of the growing electric vehicle market and the increased use of new materials…
As a federation representing hazardous waste operators present on the whole chain, from collection to final treatment, ELVs are not directly our core business. Nonetheless, our commitment to ensure non toxic material cycles and limit the dispersion of pollutants in the environment grant us some legitimacy to share our key principles to reach the zero pollution ambition for a toxic-free environment called by the EU…
The European Carbon and Graphite Association (ECGA) is the representative association of EU carbon and graphite producers, including a wide variety of specialty graphite and carbon products for applications ranging from electric motors to modern battery technology.
FEAD, the European Federation for Waste Management and Environmental Services, welcomes the Revision of Directive 2000/53/EC on End-of-Life Vehicles as part of the new CEAP and the Green Deal. Historically, the vehicle composition is changed and is shifted towards light materials such aluminum and polymeric constituents to make the vehicles lighter and therefore less energy consuming and less polluting.
Currently, there are about 3 to 4 million vehicles per year whose whereabouts are unknown. In this context, the Platform for Electromobility, representing 39 organisations from industry and civil society committed to promoting e-mobility, welcomes the opportunity to comment on the Commission’s inception impact assessment on the End-of-Life Vehicles Directive.
The Association of the Automotive Industry (VDA) represents more than 600 companies in the automotive industry -manufacturers of motor vehicles and their engines, set-ups, installations, containers and vehicle parts and equipment -which produce in Germany. The automotive industry is the highest-turnover branch and generated a revenue of more than 435 billion euros in 2019.
· · filed 17 Nov 2020 · source
Dansk Autogenbrug (DAG) – representing the Danish auto dismantlers – is pleased to comment on the Commission’s plan and thoughts for a revision of Directive 2000/53/EC on end-of-life vehicles. On the whole, we fully agree to the aims and measures foreseen in the Impact Assessment of October, 2020.
The new Circular Economy Action Plan, published on 11 March 2020, puts waste management and, more specifically, the optimal treatment of end-of-life vehicles (ELVs) at the heart of the European Commission’s strategy.
Filed in French · English published by the European Commission
· · filed 17 Nov 2020 · source
The Federation of European Motorcyclists’ Associations (FEMA) thanks the European Commission for the opportunity to give its vision on the revision of the End-of-life Vehicles Directive (2000/53/EC). In FEMA’s view, the current Directive succeeded in preventing waste from vehicles, the reuse of parts from vehicles and improvement of the environmental performance of all economic operators involved in the life cycle…
· · filed 17 Nov 2020 · source
The ELV Directive Recital 10 states: Vintage vehicles, meaning historic vehicles or vehicles of value to collectors or intended for museums, kept in a proper and environmentally sound manner, either ready for use or stripped into parts, are not covered by the definition of waste laid down by Directive 75/442/EEC and do not fall within the scope of this Directive.
Wirtschaftsvereinigung Stahl welcomes the Commission’s efforts to reform the ELV Directive, including with regard to electro-mobility requirements. The Commission considers three options: • Improving the implementation and enforcement of the ELV Directive without changing its provisions • Targeted amendment of the ELV Directive by aligning it with EU waste legislation • Revision of the ELV Directive through…
Filed in German · English published by the European Commission
The comments on the amendments to Directive 200/53/EC are detailed in the attached document and concern: ERP, transposition in European countries, illegal export, illegal abandonment of vehicles, interaction with other directives, reuse of spare parts, illegal activities, certification.
Filed in Italian · English published by the European Commission
In the context of the revision of the End of Life Vehicle Directive European Aluminium would like to share its top priorities. The following points are focusing on issues that can improve the recycling of End of Life Vehicles (ELVs) in general and the recycling of aluminium from these vehicles in particular. 1. There is no need for minimum recycled content rates for materials like aluminium. 2.
Enel SpA, a multinational company in the energy sector and active in the e-mobility value chain, highly appreciates the EC initiative to revise the Directive 2000/53/EC on end-of-life vehicles (ELV) to prevent waste from vehicles, promote reuse, recycling and other forms of recovery of ELVs and their components so as to reduce the disposal of waste and improve the environmental performance of all economic operators…
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.