ETRMA responds to the Commission’s consultation on end-of-vehicle regulation

05 December 2023

The European Tyre and Rubber manufacturers’ association (ETRMA) welcomes the opportunity to comment on the European Commission’s proposal on circularity requirements for vehicle design and on management of end-of-life vehicles.

The Ecodesign for Sustainable Products Regulation (ESPR) will set regulatory circularity requirements for tyre design and tyres have been listed as a priority product for first wave action under the ESPR legislation, according to the Joint Research Center's (JRC) preliminary study. Tyres could also be included in End-of-Life Vehicle regulation (ELVR). Therefore, it is of utmost importance to synchronise the legislations and avoid double regulations.

We call for:

  • Avoiding double regulation for ecodesign criteria
  • Consistent and harmonised definitions of remanufacturing/refurbishment across different legislations
  • Ensuring that parts and component removed from a vehicle suitable for reuse, remanufacturing or refurbishment, are not considered waste
  • Ensuring continued high level of End-of-Life Tyre management
  • Replacement tyres should be subject to the same Tyre Digital product Passport (DPP) obligations as the Original Equipment ones
  • Continued alignment of the ELVR on international regulations on  reusability/recyclability/recoverability of vehicles
  • Setting an interface with REACH and other chemical legislations to avoid inconsistency and administrative burden

Read our full input below.