Zwickau: Vehicle recycling stopped being a waste file and became a design file on 13 August, when the Union’s new circularity regulation entered into force. Nothing binds manufacturers yet. The rules apply two years after entry into force, which puts the real date in August 2028 and leaves the industry roughly one product cycle to react.
Parliament approved the text on 18 June by 437 votes to 112 with 20 abstentions, and the Council adopted it on 29 June, closing a file that ran through trilogues from October to December 2025. The headline obligation concerns plastics. New vehicles must contain 15 percent recycled plastic six years after application and 25 percent after ten, and at least a fifth of that recycled content must come from end-of-life vehicles themselves. That works out at 3 percent closed-loop content at the six-year mark and 5 percent at ten.
The closed-loop share is the provision that will hurt. Post-consumer plastic from packaging is available and reasonably cheap. Plastic recovered from scrapped cars is contaminated, mixed, flame-retarded and collected through a dismantling chain that nobody built to feed automotive-grade compounding. Meeting 3 percent means creating a supply chain that barely exists, and compounders already warn carmakers that the volumes will not appear on their own.
Design obligations arrive alongside. Vehicles must be built for dismantling, must hit reusability, recyclability and recoverability targets, and must carry a circularity vehicle passport documenting materials and components through the vehicle’s life. Passports create the data that enforcement needs, and they hand dismantlers something they have wanted for decades, which is knowing what sits inside a car before they take it apart.
Dismantlers stand to gain the most and remain the least equipped. Authorised treatment facilities across the Union are mostly small operations running on scrap-metal margins, and the regulation asks them to separate polymers cleanly enough for a compounder to buy the output. That requires sorting equipment, offtake contracts and a price signal strong enough to justify both. Carmakers can meet a 3 percent target by paying for that infrastructure or by bidding for the small volume that already exists, and the second option costs less until the targets rise.
Two structural problems survive the regulation. Roughly a third of vehicles leaving European fleets never appear in scrappage records, and material that vanishes into unrecorded export cannot feed a closed loop. Enforcement capacity is the second, since verifying recycled content in a bumper takes laboratory work that national inspectorates rarely fund. The legislative file is complete, and recyclers read the targets as a demand signal. Whether the scrapyards deliver is a question for 2028.
