JBCE Position Paper on the European Parliament Draft Report on the End-of-Life Vehicles Regulation Proposal

On 13 May 2025, JBCE published a position paper on the European Parliament's draft report on the proposal for an End-of-Life Vehicles Regulation (ELVR), with a focus on carbon fibres.

The main concern relates to the decision to list carbon fibres alongside heavy metals (e.g. lead, mercury) despite having a fundamentally different hazard profile.

JBCE therefore stresses that

• Carbon fibres are not classified as hazardous materials according to the WHO definition. The fibres are engineered with diameters typically ≥5μm, safely exceeding the WHO’s threshold for respirable fibres (<3μm). PAN-based carbon fibres, which dominate automotive and industrial use, are also resistant to cleavage and do not generate respirable fragments during processing.
• The ELV proposal is not the appropriate legal text to regulate substances of concern for chemical safety reasons, as chemical hazards to health and the environment are already addressed under the REACH Regulation. Any updates to the ELV text should be considered in the context of the current and future revision of this legislation.
• Adding further provisions on hazardous substances in the ELV text for chemical safety would create a second layer of legislation that would create legal uncertainty and affect the proper implementation in the Member States.

For more information, please contact info@jbce.org