The European Commission must adopt implementing acts establishing verification and certification methodology for recycled plastic content in new vehicles by a statutory deadline tied to the new End-of-Life Vehicles (ELV) Regulation. A separate instrument governing third-country materials is due by 31 December 2026. The provisional agreement on the ELV Regulation was reached in December 2025 and published following a positive vote from the European Parliament's committees on 25 February 2026. If the European Parliament Plenary and the European Council approve the agreement, it will become law.
Background
The shift from the previous ELV Directive to a directly applicable ELV Regulation represents more than a legal update - it reflects a broader policy move from end-of-life waste management toward lifecycle-based circularity. Under the former directive, Member States had to implement rules nationally; under the new regulation, rules apply uniformly across the EU, reducing fragmentation, improving legal clarity, and strengthening enforcement for automotive manufacturers, treatment operators, and other economic actors.
The automotive manufacturing industry is one of the most resource-intensive sectors in the EU, consuming approximately 6 million tonnes of plastics per year while making little use of recycled materials. Currently, only 19% of plastics from end-of-life vehicles is recycled. That figure underpins the rationale for mandatory recycled content targets and the accompanying verification framework now being established.
Details
The provisional agreement specifies that chemical recycling will be permitted to contribute toward targets using a mass-balance accounting methodology, in line with the Waste Framework Directive (2008/98/EC). The Commission must adopt an implementing act establishing verification methods for recycled content targets - including mass balance - within 24 months of the regulation's entry into force.
A separate, earlier verification instrument governs recycled material sourced from outside the EU. By 31 December 2026, the Commission must adopt implementing acts establishing the methodology for assessing, verifying, and certifying - including through third-party audit - recycled content recovered from post-consumer plastic waste collected or recycled in a third country. The assessment must consider standards of protection for the environment and human health, including standards ensuring that recycling is performed in an environmentally sound manner and quality standards for the recycling sector.
On recycled content targets, the regulation mandates a minimum 15% recycled plastic content in new vehicles six years after entry into force, rising to 25% ten years after entry into force. Twenty percent of these targets must be achieved by including plastics recycled from end-of-life vehicles or from parts and components removed during the vehicle use phase - so-called "closed-loop" recycling. Only recycled material derived from post-consumer waste counts toward the minimum recycled content targets.
Recycled material procured from outside the EU cannot count toward minimum recycled content targets for 48 months after the legislation's entry into force. Once permitted, stringent requirements - including independent third-party audits - are expected to limit the usable volume of overseas material.
The mandates apply to passenger cars, light commercial vans, regular heavy-duty vehicles, motorcycles, and special purpose vehicles, with the exception of small-volume manufacturers of heavy-duty special purpose vehicles.
Industry analysts have flagged polypropylene as the likely primary material through which compliance will be achieved. According to ICIS Plastic Recycling Analyst Mia McLachlan, "Recycled content mandates are expected to be met primarily through recycled polyolefins, supported by the wider availability of suitable waste feedstocks compared with other polymers used in the automotive sector." ICIS previously estimated that 0.5-0.6 million tonnes of recycled polyolefins would be required by 2040, with the majority supplied by recycled polypropylene.
Outlook
The regulation is expected to affect compliance, design, recycling, material data management, and circular economy strategies across the automotive industry. While it creates the legal basis for mandatory recycled content requirements for plastics, exact percentages and calculation methodologies remain to be defined through subsequent implementing acts. For vehicle manufacturers and their plastics supply chains, establishing robust chain-of-custody documentation and supplier audit frameworks before the verification methodology is finalized will be critical to meeting the phased content targets when they take effect.
