The European Automobile Manufacturers’ Association (ACEA) has released a position paper articulating its stance on the European Commission’s Proposal for a Regulation on circularity requirements for vehicle design and on the management of end-of-life vehicles (ELVs).
In this document, ACEA outlines its priorities and concerns regarding key aspects of the proposed regulation.
Minimum recycled content target
At the forefront of the Association’s priorities is the establishment of ambitious recycled content targets.
However, they emphasize that these targets must adhere to specific preconditions to be viable.
These include adopting a plastics definition from the European Commission’s Joint Research Centre, allowing both mechanical and chemical recycling, setting special thresholds for legacy Substances of Concern (SoC), and considering responsible bio-based feedstocks in the calculation.
ACEA strongly advocates for a technology-neutral approach to new recycling technologies.
Extended Producer Responsibility (EPR)
ACEA asserts that unlike consumer products, an ELV is a valuable asset.
The association argues that only contracted waste management operators should be entitled to claim a deficit compensation.
Furthermore, producers should have the right to define the collection system under their extended responsibility, with any approach contradicting free-market principles being rejected.
Circularity strategy
ACEA points out that many elements of the circularity strategy proposed in the regulation fall outside the scope of manufacturers.
The association recommends that, where relevant to vehicle manufacturers, the circularity strategy should be applied to the manufacturer as a whole rather than at the vehicle type level.
Mandatory dismantling
Regarding the proposed mandatory dismantling of ELVs, the Association questions the underlying criteria behind the list of parts and components subject to removal.
They advocate for a market-driven approach, where the removal of parts and components for reuse or remanufacturing should be based on market demand and ecological feasibility.
Lead time between publication and implementation of design-impacting delegated acts
The organization emphasizes the importance of providing a lead time of at least five years between the publication and implementation of design-impacting delegated acts.
This time frame is deemed necessary to accommodate the long development cycle of vehicles, ensuring manufacturers can comply with new requirements effectively.
New type-approval requirements
The position paper highlights concerns about the new type-approval requirements outlined in the ELV draft.
ACEA calls for clear clarification, tools, and processes to address the new demands placed on manufacturers and type-approval authorities.
Additionally, the association raises concerns about potential divergence from globally harmonized regulations and the need for transitional measures for existing approvals.
Multistage vehicles and dismantling information in type approval
They argue that extended producer responsibility requirements should extend to the bodywork of multistage vehicles.
Furthermore, the association suggests that providing dismantling information should be integrated into the type approval process for specific vehicle categories.
In conclusion, ACEA’s position paper provides a detailed insight into the European auto industry’s perspective on the proposed circular economy regulations.
The association seeks to balance environmental goals with practical considerations, advocating for clear and feasible measures that promote sustainability without unduly burdening manufacturers.
