The undersigning organisations support the objectives of the proposal to improve the circularity of the automotive sector through measures such as design requirements for new vehicles and treatment obligations for end-of-life vehicles (ELVs), as well as improved definitions, information requirements, and enhanced traceability of ELVs.
While these new measures are welcomed, the signatories want to highlight the exceptional importance of steel in the context of the proposed Regulation and various new studies that provide robust evidence to support more ambitious measures that should be taken into consideration in the co-legislation process.
Specifically, the signatories demand a target of 30 % recycled content for steel from post-consumer scrap in all vehicles covered by the Regulation by 2030, increasing to 40 % by 2035. This target should include a share of recycled steel sourced from ELVs as well as a significant share of recycled steel sourced from local postconsumer scrap (i.e., made or processed in Europe).
Background: Steel in cars
The automotive industry is the second biggest consumer of steel in the EU with 17 % of European steel consumed – a typical car in the EU contains 800 kg of steel. Steel represents 16 % to 30 % of cars embedded emissions from the production phase depending on the type of powertrain.
At the same time, only 6 % of scrap steel from ELVs makes it back into new cars despite the significant climate benefits of secondary steel compared to primary steel. In fact, the European car industry continues to rely on high emission steel based on coal with an estimated emissions intensity more than double the EU average.
More broadly, the European Union is also underutilizing its valuable resources. In recent years, the amount of recycled steel scrap being used within the EU has declined, following the trend of decrease in EU steel manufacturing. This trend is largely driven by reduced demand from European industries – particularly the steel sector – and more favourable market conditions for recycled steel scrap in non-EU countries. Consequently, exports of recycled steel scrap have surged, with volumes more than doubling and reaching approximately 19.43 million tonnes in 2021, accounting for around 20 % of the total recycled steel scrap produced in the EU.
In its Steel & Metals Action Plan, the European Commission assesses that the first action to increase the usage of more steel scrap in the EU, is “to stimulate demand of such resources in Europe” and “to achieve this, scrap should be better sorted and treated to ensure its usability in high-quality applications such as automotive.” Against this background, it becomes obvious that improving the recycling of steel from ELVs and incorporating it in new cars will benefit both the EU’s climate ambition and contribute to its strategic autonomy and resilience.
Nevertheless, steel related measures in the proposed Regulation on Circularity Requirements for Vehicle Design and on Management of End-of-Life Vehicles fall short of harnessing these potentials, with co-legislators often citing a lack of empirical evidence and uncertainties. However, four recently published studies show that additional measures would be feasible and effective in contributing to improving the quality and quantity of steel recycled from ELVs and its use in new vehicles, with technologies that are technical and economically feasible already today:
- A report by the Mobility in Transition Institute on the potential of ELV deep-dismantling and use of copper depolluted recycled steel scrap. This study is the first output of a broader project looking at solutions to decarbonize automotive flat steel production and will be complemented by a report on industrial sorting techniques, whose assessment is still ongoing.
- A study by the Oeko-Institut, commissioned by T&E highlighting the potential for increasing the use of recycled steel in the EU automotive industry through steel recycled content targets in the new ELV Regulation.
- A paper by the International Council on Clean Transportation exploring strategies to improve the circularity of automotive steel in the EU.
- A paper by Sandbag proposing minimum recycled steel content targets for different types of flat and long steels, based on a study on the environmental, safety and structural aspects of automotive design.
The four studies demonstrate that increasing the share of recycled steel in car production offers substantial benefits for decarbonizing vehicle manufacturing – enabling up to a 20 % reduction in steel-related greenhouse gas emissions through a higher share of secondary steel. It also reduces Europe’s dependency on critical raw materials such as coking coal and iron ore, while significantly boosting the availability of copper within the EU.
The undersigned organizations therefore strongly urge the European Parliament and the Council to consider the new scientific evidence and to introduce strong measures that will increase the uptake of more recycled steel in the automotive industry. We are convinced that this will reduce the environmental impact of car production, increase the EU’s competitiveness, and lessen Europe’s reliance on strategic and critical raw materials.
