In July 2023, the EC published a proposal for a regulation on circularity requirements for vehicle design and end-of-life vehicles (‘ELV regulation proposal’, document COM(2023)451).
FEICA argues that:
• the explicit and generalised mention of adhesives as an impediment to the dismantling and recycling in the ELV regulation proposal is inaccurate, as adhesives can allow for and even enable successful dismantling and recycling.
• the current wording constitutes an uneven playing field as other materials and bonding technologies which may prevent dismantling and/or recycling are not mentioned.
• the mention of specific materials or technologies which are to be considered in the circular design strategies and in fee modulation for vehicles should be provided, if at all, in secondary legislation or guidance only.
• any mention of specific materials or bonding technologies should be sufficiently specific and reflective of the existing practices, successes and limitations of end-of-life vehicle dismantling and recycling.