End-of-life vehicles: EU Regulation 2026/1738 and circularity data scattered across six systems
7 min read
A typical scenario, not our own case. A components manufacturer near Modena supplies die-cast aluminium parts, in the manufacturing sector, to a vehicle maker. Ahead of type-approval for a new model, the client asks what share of the material is recycled from post-consumer waste — not pre-consumer — because the regulation treats the two differently. The supplier’s engineering office knows the alloy used. Procurement knows which foundry the material comes from. Neither can say, with a document in hand, whether that recycled aluminium came from already-treated end-of-life vehicles or from scrap generated by the foundry’s own processing — the distinction the regulation demands.
The regulation that just entered into force, and the dates that matter
Regulation (EU) 2026/1738 of the European Parliament and of the Council of 8 July 2026, “on circularity requirements for vehicle design and on management of end-of-life vehicles”, was published in the Official Journal of the European Union L 2026/1738 of 24 July 2026. It repeals Directive 2000/53/EC on end-of-life vehicles and Directive 2005/64/EC on reusability, recyclability and recoverability: until now these applied only to passenger vehicles (M1) and light commercial vehicles (N1), “approximately 85 % of all vehicles registered in the Union” per recital 10; the new text extends, at least in part, the requirements on collection, treatment and mandatory part removal to motorcycles, heavy-duty vehicles and trailers too.
Article 59 sets two different clocks. Entry into force is “the twentieth day following that of its publication in the Official Journal of the European Union” — 13 August 2026, the same date the article explicitly assigns to the early application of Article 53. General application, however, is set for 1 September 2028. From that date the design requirements of Chapter II — removability of parts and components (Art. 7), restriction of hazardous substances (Art. 5), labelling of plastics and elastomers (Art. 12) — condition the type-approval of new vehicle types. Three further thresholds come later: from 1 September 2029, the circularity strategy (Art. 9); from 1 September 2032, the 85%-by-mass reuse-or-recycling rate and the 95%-by-mass reuse-or-recovery rate (Art. 4), the minimum 15% post-consumer recycled plastic content — with at least a fifth of that target coming from end-of-life vehicles or parts dismantled during use (Art. 6) — and the vehicle’s digital circularity passport (Art. 13).
Where the data actually sits
The regulation does not hand circularity to a single office: it spreads it across at least six systems that today do not talk to one another. The first is the engineering office’s PLM, home to the bill of materials, material choices and design for removability. The second is the supplier network: Article 4(2) lists, among the measures manufacturers must take — “collect the necessary data through the full chain of supply, in particular the nature and the mass of all materials used […]”; “establish procedures to verify the correctness and completeness of the information received from the suppliers”; “manage and document the breakdown of the materials” — an audit duty over data the manufacturer does not generate but must guarantee. The third is the type-approval office: manufacturers must “provide the type-approval authorities of the Member States and the Commission with a copy of the circularity strategy within 30 days”, and the Commission must “make the circularity strategies and any updates to those strategies publicly available, except for confidential information” (Art. 9). The fourth is the extended producer responsibility register (Arts. 16 and 19), usually kept by the environmental or legal office, not the technical one. The fifth is the network of authorised treatment facilities, third parties the manufacturer does not control: they “issue a certificate of destruction to the last vehicle owner upon delivery of the end-of-life vehicle […]” (Art. 25). The sixth is the competent registration authorities, which “cancel the registration of an end-of-life vehicle only after receiving the certificate of destruction” (Art. 25) — an event that, for a long-lived vehicle, the engineering office that designed it often never gets to see.
The same pattern — different systems that do not talk to each other — is already told for the battery passport: it is no accident that Article 13 requires the vehicle passport to be “aligned, interoperable and, where possible, integrated” with the battery one — and for packaging: the data is not missing, it sits with parties who never had a reason to exchange it.
The one piece of data no corporate system holds in full
The piece that is almost always missing is the proof, not the statement. A supplier can say how much recycled material it uses; proving it is post-consumer rather than pre-consumer — the distinction Article 10 requires stating “per material share” — means tracing back to the recycling plant, sometimes through two or three tiers of sub-supply the final manufacturer does not know by name. It is the same gap already told for CSDDD supply-chain due diligence: every link in the chain discovers it must, in turn, ask a supplier who has never put that data in writing before. Here the regulation itself admits the ground is not ready: the Article 10 declaration duty only starts on the first day of the month following twelve months from the date the Commission adopts the relevant calculation methodologies referred to in Article 6 — and today the Commission has only scheduled the one for plastic, due by 31 August 2028 (Art. 6(5)); for aluminium, magnesium and steel, no date appears yet in the text. The same uncertainty applies to the reuse, recyclability and recoverability rates of Article 4: until the Commission’s methodology, due by 28 February 2029 (Art. 4(3)), international standard ISO 22628:2002 applies. The digital passport meant to pull it all together — design, substances, recycled content, spare-parts catalogue — arrives only from 2032, and until then every manufacturer keeps the six pieces exactly where they have always been.
If tomorrow a type-approval authority or a lead client asked for the complete proof — from the alloy a supplier declares to the certificate of destruction for the last unit sold — how many of these six systems would you need to enter, and how long before you were certain the numbers added up?
See the service · Talk to an engineer
Where we stop
We give no legal advice on exactly which category-L, M2, M3, N2, N3 and O vehicles fall under each requirement: recital 10 states that the Regulation applies to them only “partially”, and the exact perimeter has to be read article by article against the relevant annexes. On penalties, Article 49 requires Member States to set them by 1 September 2029, “effective, proportionate and dissuasive”: the regulation fixes no amount, and — at the time of writing — we find no Italian implementing measure to check. As a regulation, it needs no transposition decree for its substantive rules; what remains is designating the national competent authorities (Art. 14) and the extended-producer-responsibility schemes, neither verified for Italy. The opening scenario is a typical model, stated as such: we do not describe how any real company actually operates.
The two axes, applied
Complying. The data collection “through the full chain of supply” that Article 4 demands becomes, in our system, a control that runs on the client’s documents and systems — bill of materials, supplier declarations, type-approval files — with an alert when a supplier changes its recycled-material source or when a declaration is no longer backed by the underlying documents. An exportable, dated file, ready for the type-approval authority or the lead client.
Deciding. The same system brings PLM, procurement, type-approval, the EPR register and the end-of-life treatment network together into a single operating model, on which AI agents execute decisions with a human operator in command: not just answering when the request lands, but knowing in advance which batch of recycled material is already traced and which still needs verifying. For large manufacturing companies, defence, public administration and healthcare. Always in two delivery modes: on-premises, on autonomous machines needing no deep integration into the client’s network, or dedicated cloud, with a dedicated VPN and a data centre in Italy — always with shared management.
From the first session, at no cost, comes the dated map of which circularity data is already available, which system holds it and who updates it — blank boxes included. It stays yours even if we do not go on together. Talk to one of our engineers.