New ELV Regulation 2026 – what changes in vehicle recycling and who does it affect?

What does the ELV Regulation change? Key points

The new rules shift the focus from recycling alone to vehicle design. The most important changes include:

• Design for dismantling (eco-design) – new vehicles are to be designed so that dismantling stations can easily remove parts for reuse and recycling.
• Targets for recycled content in plastics – a mandatory, increasing share of recycled plastics in new vehicles.
• Strengthened extended producer responsibility (EPR) – manufacturers finance the collection and treatment of end-of-life vehicles.
• Digital vehicle passport – a set of key data on materials, components and circularity.
• Ban on exporting vehicles classified as waste – aimed at curbing the practice of “disappearing cars”.
• Ban on blocking repairs through software updates – extending the lifespan of vehicles.
• Broader scope – the rules will cover not only passenger cars, but also, among others, motorcycles, trucks and special-purpose vehicles, with certain exceptions.

Who do the new ELV rules apply to?

The regulation imposes obligations on all links in the vehicle value chain:

• Vehicle manufacturers and importers – eco-design, data for dismantling and repair, financing the system for collecting and managing vehicles, recycled-content targets.
• Producer responsibility organisations (PROs) – effective collection of end-of-life vehicles by professional and licensed entities integrated into national networks, transparent and objective procedures for selecting partners.
• Authorized Treatment Facilities (ATFs) (=dismantling stations) and collection points – new requirements for collection, decontamination and dismantling of specified components and materials.
• Shredding companies and recyclers – traceability of parts and materials.
• Exporters and used-car dealers – obligation to demonstrate that the vehicle is not an end-of-life vehicle.
• Individual drivers – to a limited extent; mainly when selling a vehicle whose technical condition raises doubts.

Extended producer responsibility (EPR)

Manufacturers will be subject to EPR obligations – they will have to organise and cover the costs of collection, recovery and treatment of end-of-life vehicles. Importantly, fees will be modulated through eco-modulation: their amount will depend, among other things, on how easily a given vehicle can be recycled. This is a direct incentive for eco-design. These tasks can be carried out individually or collectively, through producer responsibility organisations.

Plastic recycling targets – specific figures

One of the pillars of the regulation is binding targets for the content of recycled plastics in new vehicle types:

In addition, at least 20% of this recycled content must come from end-of-life vehicles or used parts. In the future, the European Commission may introduce similar targets for steel, aluminium, magnesium and critical raw materials. The aim is to stimulate demand for secondary raw materials and reduce dependence on primary raw materials.

Digital vehicle passport

The regulation introduces a digital vehicle passport – a standardised set of information on materials, components and parameters relevant to the circular economy. It is intended to increase supply-chain transparency and facilitate dismantling, repair and recycling at the end of the vehicle’s life cycle.

Export ban and traceability of parts

To limit the practice of “disappearing cars” – it is estimated that around 3.5 million vehicles disappear without trace in the EU each year – a ban has been introduced on exporting vehicles classified as not roadworthy. Exporters will have to demonstrate, including through technical inspections and documentation, that the exported vehicle is not an end-of-life vehicle. Requirements for the traceability of parts and materials have also been tightened.

An important change for the parts market: tested and certified reusable parts will no longer be treated as waste, which will facilitate their legal trade and reuse.

Is the EU forcing roadworthy cars to be scrapped? Myth versus facts

There have been many misunderstandings surrounding the proposal. Below are the most important ones:

• Myth: „The EU will scrap my car because of worn brake pads or its age.”.
• Fact: the regulation does not introduce an age limit or mileage limit and does not require roadworthy cars to be scrapped. The status of a vehicle is determined by its actual technical condition, not its age.
• Myth: „When selling a used car, I will have to prove that it is not scrap.”.
• Fact: the obligation to provide an assessment or a valid roadworthiness test applies primarily to businesses. Transactions between private individuals require such a document only in special cases, such as a total loss.

The repair restrictions that have caused the most concern apply to a narrow group of cases where the repair would require the replacement of elements resulting in the loss of the vehicle’s original identification, such as the engine, gearbox or body forming the basis for identification. For a typical user and repair workshop, everyday repairs remain unchanged.

When does the ELV Regulation apply? Timeline

What should companies do now? 5 steps

1. Update agreements with PROs and partners – fulfilling extended producer responsibility (EPR) obligations through a producer responsibility organisation (PRO) provides the strongest assurance of effective and indisputable compliance with EPR obligations. Ensure transparent and objective selection criteria as required by the regulation.
2. Map your obligations – determine the role in which you operate, such as manufacturer, importer, dismantling station or exporter, and identify which requirements apply to you.
3. Prepare technical data – organise the information needed for dismantling, repair and recycling in view of the digital vehicle passport.
4. Review the recycled-content supply chain – plan how to reach the thresholds of 15% and 25% recycled plastics, including at least 20% from end-of-life vehicles.
5. Verify export processes – implement procedures confirming that a vehicle is not an end-of-life vehicle.