Beyond road signs: how the EU can steer circular vehicle design

This article is the second in a series analysing various aspects of the new EU Regulation on Vehicle Design and End of Life Management. The first piece investigated the potential and roadblocks for the regulation to set the automotive sector on a circular path. It was originally published by Auto Recycling World.

The automotive sector is heavily resource-intensive, accounting for 19% of the EU’s overall steel consumption and 10% of its plastics consumption. Car manufacturing also drives the demand for aluminium alloys and copper, and relies on resources derived from over 60 raw materials, including critical raw materials. As the sector takes a necessary turn towards electric vehicles to lower its footprint, the major environmental impacts of vehicles are shifting from the use phase to production, with a surge in demand for materials like lithium and copper. In this context, boosting circularity in the automotive sector is more important than ever.

To address this challenge, the new EU law on vehicles design and end-of-life management proposed by the European Commission includes extended design requirements to be fulfilled by vehicle models to be allowed on the EU market. Measures such as a new methodology to assess reusability, recyclability and recoverability, minimum recycled content targets for plastics, and better availability of information through a Circular Vehicle Passport for actors at the end-of-life stage will ease disassembly and incentivise material circulation. However, the lack of provisions addressing durability, the weak measures on repairability and reuse, and the limited ambition regarding the use of secondary materials present significant missed opportunities for value retention and resource saving.

Towards a lighter future 

In brief, the proposal lacks effective measures to reduce the environmental and social impact of vehicles along their entire lifetime. The ongoing trend of designing increasingly larger cars, loaded with a growing array of electronic components, is causing the environmental footprint of vehicles to soar. Conversely, embracing ‘light designs’ could significantly reduce material consumption per vehicle, while still meeting the highest safety and comfort standards. This is confirmed by a recent report, showing how downsizing electric vehicles is the single most effective measure to reduce demand for critical metals (19-23%).

Revealing environmental footprints  

It is not clear why the proposal does not require the disclosure of the environmental or carbon footprint of vehicle production and end-of-life management. Revealing such information would be a practical step to tackle the environmental impacts of vehicles: it would facilitate the differentiation of vehicles in terms of their climate impacts and enable other measures such as performance requirements for the carbon footprint. At the same time, such a requirement would align the information requirements under the Circularity Vehicle Passport with other Digital Product Passports, like those proposed for Batteries in the EU Batteries Regulation. 

Making them durable 

The proposal also neglects the importance of durability as a key ecodesign strategy to drive down the environmental impact of vehicles by extending their lifespan. The EU vehicles law must mandate the Commission to develop a detailed methodology to calculate and assess the durability and repairability of key components, and introduce additional measures to support this, such as the mandatory disclosure of durability information and minimum durability requirements for components. 

Making them repairable and reusable 

Regarding repairability and reusability, the proposal requires vehicles to be designed in a way that does not hinder the removal of certain parts by authorised treatment facilities at the end-of-life stage, and for electric vehicle batteries and e-drive motors to be readily removable in a non-destructive manner. Besides, it orders manufacturers to provide a ‘circularity strategy’, including a non-binding list of actions they commit to carry out to make sure that the end-of-life treatment is done in accordance with the law, e.g., measures to promote the reuse of parts and components. 

However, additional measures are needed to drive up modular design strategies, minimal need for specialised tools, and the widespread and long-term availability of wear and spare parts and components, including software, at fair and non-discriminatory prices. A minimum availability period of wear and spare parts as well as for software updates, e.g., 20 years, would be an effective way to ensure this. Additional measures may also include a standardized repair index, to enable comparisons between vehicles in terms of their repairability and associated costs. 

Besides, the provisions on the removal and replacement of specific parts and components should not be limited to the end-of-life stage: all parts and components should be removable and replaceable throughout the vehicle’s operational life by both independent workshops and mechanics affiliated with car manufacturers. The vehicle repair market must remain open, competitive, and affordable. 

Driving up recyclability and the use of recycled material 

The introduction of a new methodology to assess minimum requirements for reusability, recyclability and recoverability of vehicles is expected to enhance vehicle recyclability. However, the long implementation period for this method only planned to enter into force 3 years after the adoption of the final text – and limited requirements for the use and traceability of substances that pose risks to human health and the environment represent a missed chance to drive up recyclability, and a serious risk of reinjecting toxic chemicals in the recycled materials. 

The inclusion of recycled content targets for plastics is another positive step toward material circulation. However, the lack of recycled content targets for other relevant materials such as steel, aluminium and critical raw materials is a missed opportunity. At least due dates for respective feasibility studies – currently planned to be published 2 and 3 years after the final text is adopted – should be moved forward. Furthermore, better incentives are needed for high-quality recycling for various materials from vehicles, for instance by associating quality standards to the recycling achievements. 

On the path to circular design 

While certain provisions on vehicle design may function as road signs guiding the industry towards a circular future, the proposed law still lacks the horsepower to propel the sector towards reducing its environmental footprint – or tire tracks. A stronger focus on resource-efficient designs that boost longevity, repairability and reusability is needed to ensure the sector can cruise within planetary boundaries.

About the authors: Fynn Hauschke is a waste policy expert at the European Environmental Bureau (EEB), Europe’s largest network of environmental citizens’ organisations. Roberta Arbinolo is a communications expert, coordinating the EEB’s communications on circular economy. Andrea Kostrowski is a circular economy expert, specialised in waste prevention, ecodesign and batteries at EEB member organisation Deutsche Umwelthilfe (DUH).