The EU Commission's draft published in July 2023 addresses the environmental problems caused by the European automotive industry. Due to its high consumption of resources, the automotive industry in Europe has a very large environmental footprint. This sector alone accounts for almost 19 percent of total European demand for steel, 10 percent of the total consumption of plastics and a significant proportion of demand for aluminium, copper and glass. With the proposed regulation, the EU Commission hopes to minimise resource consumption and climate-damaging emissions in the automotive industry. In addition to an annual saving of 12.3 million tonnes of CO₂ emissions by 2035, 22,100 new jobs are also to be created.

Scope of the draft
The switch from combustion engines to electric vehicles tends to shift the focus away from the utilisation phase when considering the environmental impact. From an environmental perspective, the manufacturing and recycling phases are much more sensitive than in the past and therefore require an adapted legal framework. Last but not least, the EU Commission's proposal promotes the use of recyclates. In future, 25 percent of the plastic used to construct a new vehicle should come from recycling. In turn, 25 percent of this must be recycled from end-of-life vehicles. This is to be welcomed and should be standardised for other materials as soon as possible. According to the draft, transparency in the life cycle of a vehicle should also be increased. End-of-life vehicles should be easier to trace throughout the EU and the export of unroadworthy vehicles should be prohibited. The scope of the measures will also be extended to new vehicle categories such as motorbikes and lorries.

Necessary additions and expansions
However, all these measures will not be sufficient to compensate for the additional resources required for ever larger and heavier vehicles. Hence, something must also change in automotive design. The trend towards larger and heavier vehicles inevitably means that the batteries required will also have to be larger and therefore more environmentally harmful materials will be needed. In its current position paper, AK is therefore calling for binding specifications for vehicle weight and size as well as smaller batteries in addition to a focus on the circular economy in order to reduce the carbon footprint and the consumption of raw materials.

Although new vehicle categories are included in the draft, vehicle classes from the agricultural sector should continue to be excluded. In AK’s opinion, a circular economy should encompass all sectors and that these exemptions should therefore be removed from the regulation. The industry needs incentives to pursue innovative approaches and make commercial vehicles more sustainable. This will not happen with further exemptions.

Retrofitting combustion engines for climate protection
in the event of engine damage, it should be possible to convert vehicles with combustion engines to battery or fuel cell electric drives instead of having to dispose of the entire vehicle as an end-of-life vehicle. The EU Commission's proposal should be amended to allow professional suppliers to have retrofit kits for vehicle models approved in a standardised procedure. However, in order to promote repairs, it must generally be possible to simply replace components. It must be ensured that repairs can be carried out by brand-independent workshops. It must also be possible for consumers to have vehicles repaired even if this is considered uneconomical.

With all the issues and considerations associated with this, it is important that authorities exist, which monitor the implementation of this regulation by manufacturers. However, due to a lack of resources, the national type approval authorities mentioned in the proposal, will hardly be able to monitor the recovery and recycling quotas of the major vehicle manufacturers. Experience with exhaust-manipulated diesel cars has also shown that the willingness of national authorities to monitor manufacturers' obligations is very limited. AK is therefore in favour of having this market surveillance of vehicle manufacturers carried out by EU institutions such as the European Environment Agency or the Joint Research Centre.

Where do we go from here?
The transition towards a circular economy in the EU is one of the most important tasks in the coming years. Only by using resources more carefully can we make our economic system sustainable and achieve the goals of the Green Deal. The automotive industry is one of the key industries for achieving this. The EU Parliament and the Council are currently being called upon to position themselves on the current proposal. In any case, AK will continue to campaign for a socially just and ecological reorganisation of this sector.

Further Information:
EU Commission: Circular economy – EU Commission presents a regulation for the recycling of vehicles
EU Commission: Circular economy action plan
AK EUROPA Position Paper: Circularity requirements for vehicle design and management of end-of-life vehicles
AK EUROPA: Two new Directives within the Green Deal aim to strengthen consumer rights and the circular economy
AK EUROPA: New regulations for textile waste: Learning from mistakes
A&W Blog: Eine Verkehrswende in der EU braucht mehr als schöne Worte (A transport transition in the EU needs more than fine words)   (German only)
A&W-Blog: Die Kreislaufwirtschaft als Weg zu nachhaltiger Erwerbsarbeit (The circular economy as a path to sustainable gainful employment - A&W-Blog (awblog.at)   (German only)