FEAD strongly supports the Council’s continued recognition that pre-consumer and biobased plastics must not count towards the recycled content targets. Including such materials would divert attention from real recycling efforts and create a false sense of progress. Post-consumer plastic waste must remain the baseline to support meaningful investment in ELV recycling and ensure measurable circularity.
However, we are particularly concerned about attempts to lower the Commission’s proposed targets for recycled plastic content and to delay their implementation, which could significantly weaken the incentive to invest in high-quality plastic recycling from end-of-life vehicles (ELVs).
’Europe must maintain its momentum in advancing circularity in the automotive sector and remain committed to the objectives referred to in the title of the legislative proposal. The Regulation should fully recognise the pivotal role of Authorised Treatment Facilities (ATFs) and recyclers and ensure the timely and effective enforcement of circularity targets‘, said Paolo Campanella, Secretary General of FEAD.
FEAD fully supports the 25% recycled plastic content target by 72 months after the entry into force of the Regulation (with a 25% closed-loop requirement), as originally proposed by the Commission. These figures are not only achievable, but essential to stimulate investments in the sector.
FEAD strongly supports the inclusion of provisions ensuring that recycled content qualifying towards targets must be recovered from post-consumer waste and processed in facilities that meet EU environmental, climate, and health standards. This includes both installations within the Union and in third countries – provided that the latter adhere to equivalent environmental safeguards. This approach is essential to guarantee the prosperity of the European industry.
To ensure an effective Extended Producer Responsibility (EPR) system, the full recycling chain (including Authorised Treatment Facilities (ATFs), mechanical and post-shredder FEAD
recyclers) must have a voice in the governance of Producer Responsibility Organisations (PROs). FEAD stresses that transparency and fair competition can only be guaranteed when all actors are involved.
To grant a clear distinction between collection points and ATFs, the Regulation needs to recognise the ATF as the only authority able to issue the Certificate of Destruction.
ELVs should be transferred to ATFs within a reasonable timeframe of 30 days. To secure the appropriate treatment of ELVs, mandatory proper contractual relationships between collection points and ATFs should be set.
