Early on 12 December, EU lawmakers struck a political agreement on new rules meant to make the automotive sector more circular – but the deal falls short of its promise, warn the European Environmental Bureau (EEB) and Environmental Action Germany (Deutsche Umwelthilfe, DUH). 

The text, agreed last night, updates and merges the outdated End-of-Life Vehicles Directive and the 3R Type-Approval Directive into a single Regulation on Circularity Requirements on Vehicle Design and on the Management of End-of-Life Vehicles [1]. It was billed as an opportunity to strengthen the EU single market, boost circularity and reduce environmental impacts associated with the design, production, use, and end-of-life treatment of cars.

The vehicle regulation introduces promising tools – including a Circularity Vehicle Passport, an EU-wide Extended Producer Responsibility (EPR) system, minimum recycled content requirements, and stronger rules on parts reuse and vehicle collection and treatment. In principle, these measures could help drive genuine decarbonisation and circularity. However, environmental organisations had already warned [2] that the negotiations started on weak foundations that did not confront the sector’s biggest challenges. Important gaps therefore remain: 

• No action to reduce the number and size of vehicles, a major driver of unsustainable material use; 

• continued prioritisation of recycling over more effective strategies such as durability, reuse, and repair; 

• and insufficient measures to hold producers accountable for used vehicles exported outside the EU. 

Caving to pressure from the automotive industry, negotiators further weakened the proposal. Lawmakers slashed recycled plastic content targets from 25% to 15% six years after entry into force, postponing the 25% requirement until a decade after the regulation takes effect. At the same time, mandatory treatment requirements were diluted, and key provisions – including safeguards against the export of old, non-roadworthy and polluting vehicles – were delayed.

The agreement now awaits formal approval by both institutions. 

Fynn Hauschke, Senior Policy Officer for Circular Economy and Waste at the EEB, said:   

“This deal is a textbook case of political backsliding under industry pressure. Instead of steering the automotive sector towards fewer, smaller, and more repairable vehicles, EU lawmakers chose to recycle old mistakes. By weakening key circularity requirements and scaling back ambition on recycled plastics, they’ve missed a crucial opportunity to put the automotive sector on a truly circular path.”  

Barbara Metz, Managing Director at DUH, said:   

“It is scandalous that the agreed vehicle regulation has such weak requirements for producer responsibility in the automotive sector. The anti-recycling cartel uncovered by the EU Commission this year shows that manufacturers must be subject to effective requirements to meet their recycling and reuse obligations. To reduce the environmental impact of cars over their full life cycle, manufacturers must be obligated to use resource saving designs, ensure reparability, and invest sufficiently in reuse and high-quality recycling of end-of-life vehicles.” 

 

Notes to editors

[1] Link to final agreement 

[2] Press release: Parliament votes on key waste and vehicle laws, but falls short of real solutions (September 2025) 

[3] Press release: Car recycling cartel exposed, NGOs demand accountability and transparency (April 2025) 

[4] Joint statement by environmental organisations, the insurance sector, consumer organisations, the automotive aftermarket, and the repair community concerning repair and repair-related design aspects (2025)  

Joint statement by glass producers, non-ferrous metal industry, and environmental organisations regarding measures to support the reuse of components and high-quality recycling of materials from end-of-life vehicles (2025)  

Joint statement by environmental organisations, think tanks, and recycling industry to boost the use of recycled steel in the automotive sector (2025)  

Joint statement by waste management and recycling industries, automotive suppliers, and environmental organisations in support of ambitious recycled content targets for plastics (2024)