FIGIEFA expresses concern over a number of points of the Council Common Position on the End-of-Life Vehicles (ELV) Regulation proposal. While we welcome some good steps towards the broader objective of promoting circularity and sustainability in the automotive sector, we regret the continued inclusion of some ambiguous assessment criteria for end-of-life vehicles in the Council’s Common Position.
 
Despite some clarification of the text, Annex I retains criteria that appear to be technically unrealistic and socially unfair, thereby undermining Europe’s efforts towards a more circular economy.
 
Technically Repairable Vehicles Must Not Be Declared “Irreparable”
 
FIGIEFA regrets that the text still considers vehicles as “irreparable” when components such as tires, wheels, suspension, steering, braking, airbags or safety belts are “not technically repairable or replaceable”. This is confusing and misleading from a technical perspective as it disregards the current, safe, and cost-effective repair solutions that are standard practice in the over 300.000 workshops across the EU. Workshops routinely repair or replace these components, thereby prolonging vehicle lifespans and avoiding unnecessary waste.
 
Encouraging professional repairs wherever technically feasible is essential for minimising waste, reducing demand for new vehicle production, and supporting the long-term environmental efficiency of the sector.
 
“Economic Irreparability” Is Neither Justified Nor Fair
 
We are equally concerned about the inclusion of “economic irreparability” as a potentially determinant for classifying vehicles as end-of-life. Annex I, Part B, point (f) allows vehicles to be declared irreparable when the cost of repair exceeds the vehicle’s post-repair market value - even when the repair is technically feasible and safe.
 
This logic is socially regressive and environmentally harmful. In a time of rising new vehicle prices and strained household budgets, many vehicle owners - particularly in lower-income brackets - depend on affordable repairs to stay mobile. The proposed economic criterion could prematurely force these individuals to scrap otherwise reparable vehicles, compounding environmental waste and deepening inequality in access to mobility.
 
Call to Action: Protect Repairability and Empower the IAM
 
As the legislative process continues, FIGIEFA urges Member States and Council to reconsider their approach (on the occasion of the Trilogue) and the European Parliament to revise Annex I, clearly removing criteria that lack sound technical basis and disproportionately affect consumers. The future ELV Regulation must empower Europe’s repair sector and ensure that vehicles are considered as irreparable when genuinely beyond safe repair.
 
The independent aftermarket stands ready to contribute to a more sustainable automotive sector - provided the legislative framework enables, rather than hinders, its vital role.