FEAD reaction to Council’s adoption of the ELV General Approach: ambition must not be compromised
Brussels, 17 June 2025 – FEAD, the European Waste Management Association, welcomes the Council’s adoption of a General Approach on the proposed End-of-Life Vehicles Regulation (ELVR), but underlines several problematic clauses that need to be remedied during the Trilogue. While acknowledging the importance of progress in the legislative process, FEAD warns that diluting minimum recycled content targets and timelines undermines the Regulation’s ability to deliver true circularity in the automotive sector.
FEAD strongly supports the Council’s continued recognition that pre-consumer and biobased plastics must not count towards the recycled content targets. Including such materials would divert attention from real recycling efforts and create a false sense of progress. Post-consumer plastic waste must remain the baseline to support meaningful investment in ELV recycling and ensure measurable circularity.
However, we are particularly concerned about attempts to lower the Commission’s proposed targets for recycled plastic content and to delay their implementation, which could significantly weaken the incentive to invest in high-quality plastic recycling from end-of-life vehicles (ELVs).
’Europe must maintain its momentum in advancing circularity in the automotive sector and remain committed to the objectives referred to in the title of the legislative proposal. The Regulation should fully recognise the pivotal role of Authorised Treatment Facilities (ATFs) and recyclers and ensure the timely and effective enforcement of circularity targets‘, said Paolo Campanella, Secretary General of FEAD.
Targets and timelines must be preserved
FEAD fully supports the 25% recycled plastic content target by 72 months after the entry into force of the Regulation (with a 25% closed-loop requirement), as originally proposed by the Commission. These figures are not only achievable, but essential to stimulate investments in the sector.
Strong support for meeting European environmental criteria for recycled plastic
FEAD strongly supports the inclusion of provisions ensuring that recycled content qualifying towards targets must be recovered from post-consumer waste and processed in facilities that meet EU environmental, climate, and health standards. This includes both installations within the Union and in third countries – provided that the latter adhere to equivalent environmental safeguards. This approach is essential to guarantee the prosperity of the European industry.
Waste management value chain must be included in PROs governance
To ensure an effective Extended Producer Responsibility (EPR) system, the full recycling chain (including Authorised Treatment Facilities (ATFs), mechanical and post-shredder recyclers) must have a voice in the governance of Producer Responsibility Organisations (PROs). FEAD stresses that transparency and fair competition can only be guaranteed when all actors are involved.
Strengthen the role of the ATFs and the difference with the collection points
To grant a clear distinction between collection points and ATFs, the Regulation needs to recognise the ATF as the only authority able to issue the Certificate of Destruction.
ELVs should be transferred to ATFs within a reasonable timeframe of 30 days. To secure the appropriate treatment of ELVs, mandatory proper contractual relationships between collection points and ATFs should be set.
As the legislative process continues, FEAD calls on the European Parliament and Member States to ensure the final ELV Regulation remains fit for purpose – one that protects recyclers, fosters innovation, and ensures the recovery of valuable materials across Europe.
This Regulation is not just about cars; it’s about the future of European circularity.
For more information, please contact: info@fead.be
FEAD is the European Waste Management Association, representing the private waste and resource management industry across Europe, including 20 national waste management federations and 3,000 waste management companies. Private waste management companies operate in 60% of municipal waste markets in Europe and in 75% of industrial and commercial waste. This means more than 500,000 local jobs, fuelling €5 billion of investments into the economy every year.