Driving cars in a cycle
What does it take to make cars recyclable? They must be available after as long a period of use as possible, the raw materials used must be recovered and reutilized to build new cars. That's exactly what the European Commission's new draft End-of-Life Vehicle (ELV) Regulation envisions.
The new ELV focuses on stricter measures for the use of recycled plastics, the recovery of end-of-life vehicles and the export of used cars. The European Commission (EC)(a)was guided by the realization(b) that the existing ELV Directive has not improved the use of recyclate, that only small amounts of plastics continue to be recycled, and that about one-third of cars disappear from European roads each year, presumably via export.
In response, the EC published its long-awaited draft legislation this summer(c), which is now being commented on by the European Parliament and the European Council before negotiations begin on the final legislative text between the three institutions. The proposal is intended to replace the existing ELV directives from 2000 and 3R (type approval regarding reusability, recyclability and recoverability) from 2005 and will then become directly applicable law in all member states, as it is no longer a directive but a regulation (legislative act)(d).
Why does it need regulatory guidance at all?
As with many transformations, the circular economy needs an effective push to compete economically against a long-established system that is primarily oriented toward demand rather than the impacts of our lifestyles. This push can work via economic incentives until circular economic models are established and competitive, or as in this case, via legislative demands that then set the framework accordingly for all, thereby establishing the circular models.
In its impact assessment(e) on the draft law, the EC assumes an additional cost of about 1 billion euros per year if the framework conditions are fully applied, which is likely to lead to rising car prices. This is a consequence on the way to recyclable cars, which – in the case of appropriate pricing – would be at least partially compensated by saved greenhouse gas emissions.
How should the draft be assessed?
From the perspective of a plastics manufacturer like Covestro that wants to become fully circular, the draft goes in the right direction and addresses the key points for improving the recyclability of plastics used in cars. Specifically, the better availability of end-of-life cars as a waste source for new plastics, the specifications for the treatment of end-of-life cars especially for dismantling as a source for specific recycling processes of single plastic fractions, the ban on landfilling of plastic mixtures after a shredding of end-of-life cars as a source for thermochemical recycling processes and, of course, the use quota for recycled plastics as a demand commitment for recyclates.
A large number of details are still missing for a final evaluation and, in particular, successful implementation, partly in the draft itself, for example through formulations that leave broad scope for interpretation, such as what is counted as plastic, but also aspects such as the calculation of the recyclate quota via mass balances for chemical recycling processes. Accordingly, the draft is also a work order from the EC to itself to define these crucial details for successful implementation.
Furthermore, the question arises as to why other sensible approaches to a circular economy are not taken into account or are economically disadvantaged. This applies, for example, to waste from the manufacturing phase (so-called post-industrial waste) or sustainably obtained bio-based raw materials, which, like carbon capture and utilization (CCU) technology, also close the carbon cycle and thus reduce dependence on fossil raw materials. Their contribution to the circular economy is jeopardized by the exclusive focus of the use rate on end-consumer plastic waste (so-called post-consumer waste) as a source. Additions in the sense of a holistic circular economy would be useful here.
What is needed now?
In order to successfully implement an automotive circular economy, all partners along the automotive value chain must make their expertise available, either directly or via their associations, so that the draft, which is heading in the right direction, becomes a successful and implementable transformation impetus that the partners can then also consistently implement in the following years. In addition, a plastics manufacturer must adapt to the new requirements already outlined in order to be prepared and to be able to make its contribution to successful implementation.
(a) Proposal for a Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles (europa.eu)
(b) End-of-life vehicles Regulation (europa.eu)
(c) Improving design and end-of-life management of cars (europa.eu)
(d) Regulation (European Union) - Wikipedia
(e) Proposal for a Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles (europa.eu);
EUR-Lex - 52023SC0256 - EN - EUR-Lex (europa.eu;
resource.html (europa.eu)