The position paper provides a comprehensive overview of challenges and offers key recommendations from the European automotive supply industry. It outlines our priorities for the proposal, currently under discussion within the European institutions:
• Technology-neutral recycled content targets: Achievable and aligned with the EU’s decarbonisation goals, these targets are an effective circularity measure. To ensure the production of newly type-approved vehicles, the Commission should assess the availability of recycled plastics after the adoption of the Regulation to determine the necessity of a more flexible approach to the origin of secondary plastic feedstock.
• Harmonised calculation methodology for recycled content: We urgently call for EU-harmonised rules for calculating and verifying chemically recycled content using chain of custody (e.g. mass balance approach).
• Addressing legacy substances: ELVR must tackle the issue of accumulated legacy substances, aligning with other relevant automotive substance legislation.
• Streamlined information requirements: Clear reporting thresholds and requirements are essential for effective compliance.
• Acknowledging the role of remanufacturing: The regulation should better recognise remanufacturing and its operators. We recommend adopting the industry-agreed definition of “Remanufacturing” and defining the different activities during the treatment process separately in Article 3.
• Removal of parts for reuse or remanufacturing: This process should remain driven by market demand and ecological feasibility.