Circular design of vehicles: real obligations for manufacturers and waste managers in 2026

Key data

If you manufacture vehicles or manage a vehicle end-of-life treatment center, the regulatory framework governing your activity has changed structurally. Regulation (EU) 2026/1738, in force since 24 July 2026, repeals Directives 2000/53/CE and 2005/64/CE and establishes a new regime for circular design and vehicle end-of-life management. What was published on 10 November 2026 is a correction of formal errors in the original text: the regulatory substance does not change, but its publication confirms that the regulation is fully in force and there is no room for delaying adaptation.

What does this regulation establish?

Regulation (EU) 2026/1738 comprehensively modernizes the European framework on vehicles at end of life. It replaces two directives that have been in force for decades and raises requirements both in the design phase and in the treatment phase at the end of the vehicle's life cycle.

The three pillars of the regulation are:

• Use of recycled materials: Manufacturers must incorporate recycled materials in the production of new vehicles, with specific requirements on minimum recycled content.
• Design for disassembly: Vehicles must be designed so that their components can be separated and recovered efficiently at the end of their useful life.
• Component traceability: A system for tracking materials and parts is required to verify the origin and destination of components throughout the entire chain.

Regarding the standards it modifies or repeals, the picture is as follows:

The correction published on 10 November 2026 only corrects formal errors in the text published on 24 July 2026. It introduces no substantive changes or new obligations.

Economic and operational impact

This regulation is not a minor update: it represents a redesign of processes for both manufacturers and treatment center operators.

For vehicle manufacturers, the operational implications include:

• Review of the material supply chain to incorporate recycled content.
• Engineering redesign to ensure component disassembly.
• Implementation of material and parts traceability systems, with direct impact on information systems and technical documentation.
• Adaptation of type approval processes, given that Regulations 168/2013 and 2018/858 have been modified.

For vehicle end-of-life treatment centers, the impact focuses on:

• Adaptation to the new waste management standards established by the regulation.
• Update of vehicle reception, disassembly and recovery procedures.
• Possible need for investment in equipment or training to meet material separation and recovery requirements.

Who does it affect?

• Vehicle manufacturers (cars, vans, two and three-wheeled vehicles included in the scope of Regulation 168/2013 and Regulation 2018/858).
• Waste managers specialized in end-of-life vehicles.
• Authorized treatment centers for vehicles at end of life.
• Supply chain providers of vehicle manufacturers that supply materials or components subject to recycled content requirements or traceability.
• Market surveillance operators affected by modifications to Regulation 2019/1020.
• Battery sector companies affected by modifications to Regulation 2023/1542.

Practical example

A vehicle end-of-life treatment center operating under the standards of the old Directive 2000/53/CE must comprehensively review its action protocol. That directive is no longer in force as of 24 July 2026: Regulation (EU) 2026/1738 has repealed and replaced it.

In practice, this means the center must verify whether its current reception, disassembly and waste management procedures comply with the new regulation standards. If it operated under authorization linked to Directive 2000/53/CE, it must check whether that authorization remains valid under the new framework or if it requires updating with the competent authority.

Similarly, a vehicle manufacturer that approves models under Regulation 2018/858 must review whether the circular design requirements of the new regulation affect current type approval files or models in development, given that that regulation has been modified.

What should companies do now?

1. Identify if you are within the scope: Verify whether your activity falls within the scope of Regulation (EU) 2026/1738 as a vehicle manufacturer, material supplier, waste manager or authorized treatment center.
2. Review current authorizations: If you operate under authorizations or certifications linked to Directives 2000/53/CE or 2005/64/CE, check their validity under the new regulatory framework.
3. Audit design and production processes: Manufacturers must assess the extent to which their current processes comply with requirements for use of recycled materials, design for disassembly and component traceability.
4. Update treatment center procedures: Treatment center operators must adapt their protocols to the new waste management standards of the regulation.
5. Review type approvals: Manufacturers affected by modifications to Regulations 168/2013 and 2018/858 must verify the impact on their type approval files.
6. Consult with specialized advisors: Given that the regulation modifies four standards and repeals two directives, the analysis of specific impact requires legal and technical review tailored to each company.

Official source

Consult complete regulation in official source

Notice: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202690963