Executive summary

The Directive 2000/53/EC of 18 September 2000 on end-of-life vehicles (hereinafter – ELV Directive) was never substantially amended since its adoption 20 years ago. It aims at minimising the impact of end-of-life vehicles on the environment. To this end, the ELV Directive sets out restrictions on the use of hazardous substances in new cars, obligations relating to the collection and treatment of ELV, as well as targets by 2015 for re-use/recovery and re-use/recycling.

Each year, around 11 million of vehicles leave the stock of registered vehicles in the EU, representing a potential of about 11 million tonnes of waste. The majority of waste from ELVs consists of ferrous and non-ferrous metals, with a growing share of plastic waste and electronic waste, reflecting the increasing use of lightweight materials and electronics in new cars,. These new materials and components present specific challenges for their recovery and recycling from ELVs. The growing number of electric vehicles on the EU market will further contribute to this trend and bring considerable new challenges for the ELV sector. The measures adopted to mitigate the impact of the COVID 19 pandemic on the automotive sector are also likely to accelerate the transition to electric mobility.

The evaluation of the ELV Directive takes this evolving context into account, as well as (i) the orientations set out by the European Green Deal, notably reflected in the EU Circular Economy Action Plan, and (ii) the recently adopted EU legislation on the waste framework directive and other waste streams.

In line with the EU better regulation principles, the evaluation looked at the effectiveness, efficiency, coherence relevance and EU added value of ELV Directive.

Effectiveness

The evaluation shows that the ELV Directive has been effective in the delivery of many of its initial objectives (notably elimination of hazardous substances from cars, increase in collection points for end-of-life vehicles, attainment of the recovery and recycling targets). The major problem in the implementation of the Directive is, however, the large number of “missing vehicles”, which represent about 35% of all de-registered vehicles each year. While around 6.5 million ELVs are reported to be treated according to the ELV Directive, approximately 4 million vehicles annually remain of unknown whereabouts, with a risk that a great proportion of them are not treated according to the requirements of the ELV Directive when they reach the end of their life. The flaws in the national vehicle registration systems, the lack of interconnection between the Member States on registration and de-registration of vehicles, as well as illegal treatment and export of ELVs appear to be the main reasons for this problem.

The evaluation also concludes that the provisions of the ELV Directive encouraging the design of new vehicles to facilitate their dismantling and recycling, as well as the use of recycled materials, are not sufficiently detailed, specific and measurable, and as such had a very limited impact on the design and manufacturing of new vehicles. The provisions requiring car producers to make available and share information on the materials and components contained in vehicles have been criticised for being insufficient to help properly companies in the repair, dismantling and recycling sectors performing their activities.

With regard to the targets on for re-use/recovery and re-use/recycling, most Member States reported that they have been met. The different options available for reporting on the attainment of the targets means that their quality varies across Member States, which questions the comparability of the achievements by the different Member States. In addition, the calculation is based on the overall weight of vehicles, which does not provide an incentive to recycle materials beyond metal waste, and results in suboptimal recovery and recycling of glass, plastics or critical raw materials. The fact that the definition of recycling is broader than in the rest of EU legislation and includes backfilling, as well as the absence of separate target for “re-use” are other shortcomings of the ELV Directive.

Efficiency

It is generally considered that the total benefits of the Directive outweigh its costs. The environmental benefits are linked to the safe treatment of ELVs, which avoid leakage of pollutants in the environment. The most important economic benefits of the ELV Directive have been to help consolidating the vehicle dismantling and recycling sector in the EU Member States and providing the consumers with the possibility to dispose of their ELV free of charge. There is no evidence nor claims that the ELV Directive has a negative impact on the competitiveness of the automotive industry within the EU.

The distribution of costs associated with the implementation of the ELV Directive is an issue with diverging views across the various stakeholders. There is notably no definitive data on the profitability of companies (mostly SMEs) from the dismantling sector, even though available information seems to show that their economic situation is generally fragile (which has been exposed during the COVID-19 crisis).

There is no evidence of unnecessary regulatory burden or costs stemming from the ELV Directive.

Relevance

The scope of the ELV Directive leaves out a stock of about 45 million of vehicles, e.g. motorcycles and trucks, which are not subject to any specific provisions with regard to how they should be treated at the end of their life.

The ELV Directive is not suited to ensure a high level of recovery and recycling of increasingly used valuable materials, such as gold, silver, palladium, tantalum and other rare earth metals, contained in the electric and electronic components. This is also the case for plastics or carbon-reinforced plastics.

Coherence

An important challenge for the ELV Directive today is to ensure better coherence with the European Green Deal and the Circular Economy Action Plan, notably in the eco-design of vehicles to facilitate re-use, remanufacturing and recycling, the promotion of more ambitious and specific targets for reuse and recycling, and the use of recycled content materials in the manufacturing of vehicles.

The evaluation also looks into the coherence of the ELV Directive with the EU policies on climate change and against air pollution, which are driving changes in the manufacturing of vehicles and accelerating the transition of the sector to electric models.

Unlike other waste stream specific legislation, there is no fully extended producer responsibility system established by the ELV Directive, meaning that the role played by producers in financing the costs of ELV management remains unclear.

The link with the future EU legislation on batteries is critical to ensure complementarity in the recycling of batteries and its link with other parts and components in vehicles.

Finally, better coherence is needed with the EU legislations on vehicle registration, as well as on car type-approval.

EU added value

The EU-added value of the Directive, in addition to harmonising environmental requirements, lies notably in the establishment of an EU framework, which ensured the smooth operation of the internal market for the automotive sector at large and avoided distortions of competition in the EU.

The elements presented in the evaluation of the ELV Directive will feed into the review of the ELV Directive, which is expected to result in a legislative proposal in 2022.