Vehicles and batteries, mobility

The vehicle stock in Germany in 2023 consisted of 48.8 million passenger cars and 3.6 million lorries. On average, there are around 1.1 passenger cars per household. Two trends can be observed that run counter to the principles of resource conservation and circular economy. Firstly, the share of large, heavy passenger cars and sport utility vehicles in new registrations continues to rise steadily. Secondly, the number of electronic devices and equipment installed in passenger cars is also increasing. The German Association of the Automotive Industry (VDA) puts the share of secondary materials in new cars at around 30 percent. Alternative business models to private car ownership currently play only a minor role. At the beginning of 2024, the Bundesverband Carsharing e.V. (German carsharing association, bcs) recorded just over 5.5 million participants in carsharing schemes in Germany. 

In the medium to long term, battery electric vehicles are expected to account for the majority of passenger cars and light commercial vehicles as a result of the EU fleet limit adjustment, which mandates that only zero-emission vehicles may be registered from 2035. The design, durability and circularity of batteries will be key to the sustainability of electric mobility in road vehicles. This includes electric vehicle and starter batteries (lithium-ion and future battery systems) as well as batteries in devices and light vehicles (LV batteries) and the raw materials they contain, including critical and strategic raw materials.

The following barriers hinder a circular economy in vehicles and batteries:

  • The repair network for electromobility-specific components in battery electric vehicles is currently inadequate. In addition, there is a lack of economically and environmentally sustainable guidance on repair and/or partial replacement of damaged batteries, particularly for independent workshops.
  • Forecasts on the development of waste battery return volumes (both collected waste batteries and battery production waste) vary widely, increasing the risk for circular business models. At the same time, the investment costs for building and equipping plants are very high (up to 100 million euros), and secondary materials face strong competition from primary raw materials, which are, on average, available at lower prices and enjoy greater market acceptance.
  • Construction often involves non-recyclable materials and inseparable material compounds or composites.
  • The location of a significant share of permanently decommissioned vehicles remains unclear. For more than ten years, approximately 150,000 end-of-life vehicles per year have likely been dismantled by unauthorised companies or illegally exported. Systematic enforcement must be strengthened in order to stop illegal vehicle exports, so that decommissioning end-of-life vehicles is only possible with a certificate of destruction and collection points must be authorised recycling facilities.

The following regulations and initiatives are currently in preparation and provide important frameworks for the objectives of the NCES in the area of vehicles and batteries. These conditions will be taken into account when implementing the NCES: 

  • At European level, the new Batteries Regulation (EU) 2023/1542 was published at the end of July 2023. For the first time, the EU Batteries Regulation takes into account the entire life cycle of batteries; the sustainability of the manufacturing and waste phases will be considered together in future. Among other things, the regulation sets minimum recycling targets and minimum recycled content targets for certain metals and introduces a digital battery passport. To ensure smooth alignment between the EU Batteries Regulation and Germany’s complex legal framework, the existing German battery legislation needs to be adapted. The Federal Government has therefore approved a proposal for an act to align national battery law with EU regulations. This is intended to replace the previous Batteries Act (Batteriegesetz, BattG) with a Battery Implementation Act (Batterierecht-Durchführungsgesetz, BattDG). In particular, responsibilities, procedural regulations and additional requirements for the management of waste batteries are clarified.
  • In July 2023, the European Commission proposed a comprehensive revision of the EU End-of-Life Vehicles Directive with the new End-of-Life Vehicles Regulation (ELVR), formally titled the Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles. This proposal includes provisions to improve circular vehicle design and facilitate better dismantling of components, introduces mandatory recycled content targets for plastics and plans recycled content targets for metals (once further studies have been completed). The regulation also aims to enhance the recovery of end-of-life vehicles through more stringent requirements for the separation and recovery of vehicle components. A digital vehicle passport is planned to record repair and dismantling information. Incentives, including economic incentives, will be introduced to promote reuse, remanufacturing and refurbishment. It is hoped that the collection of end-of-life vehicles will be improved through: the introduction of a digital certificate of destruction, which must be sent to the registration authority when an end-of-life vehicle is deregistered; the definition of clear criteria for differentiating between used and end-of-life vehicles; and requirements for the export of used vehicles. The Commission proposal for a regulation to improve the circularity of the automotive industry will also be extended to other vehicle classes. 

Based on the vision of a comprehensive circular economy for 2045 presented in Section 1.3, and complementing the guiding principle and overarching goals formulated in Section 2, the following additional goals apply to this action area:

  • Significantly increasing the recyclability of passenger cars: in EU negotiations under the ELVR, Germany supports requirements for vehicle longevity, repairability and high-quality recycling of individual materials.
  • Expanding the well-functioning legal market for used spare parts, continued use of the market, including by insurance companies, and effective adjustment of the market to the transition in drive systems.

Design for circularity of vehicles (durability, repairability and recycling)

The Federal Government supports the requirement in Article 9 of the European Commission’s proposed ELVR for manufacturers to develop circularity strategies. It will work to ensure these strategies include take-back concepts, specific provisions on the longevity and repairability of vehicles and all key components, the use of secondary raw materials (for both plastics and metals) and regular consultations with representatives from dismantlers, waste disposal operators and recyclers.

Establishing a platform for circular battery design

Establishing a platform for circular battery design in collaboration with industry, trade unions and the scientific community. The aim is to use battery design as a key lever to improve both secondary use and recyclability. A broad, participatory approach will be taken to define specific steps for improving circular battery design (for example, for electric vehicle batteries, which represent the largest market segment). To ensure the platform is established as quickly as possible and as recommended by the Alliance for Transformation the first implementation project will build on existing preliminary work such as the Circular Economy Initiative Deutschland (CEID), the Battery Pass and the platforms of the VDMA (the German association for mechanical and plant engineering) and the German Electro and Digital Industry Association (ZVEI). The platform’s activities will be coordinated and harmonised with those of the Länder. 

Strategic planning for recycling electric vehicle batteries

Under reporting obligations for producers and waste management operators set out in the EU Batteries Regulation, data will also be recorded on waste electric vehicle batteries regarding quantities that have been collected, prepared for reuse or repurposing and recycled. Data access and evaluation should enable forecasts of future capacity needs for recovery. Information on battery lifetime is particularly important here. This strategic knowledge helps ensure planning certainty for the necessary recycling and collection infrastructure. This also allows comparison between theoretical and actual waste battery take-back rates. Data on collection scheme efficiency can be used to assess suitability and improve incentive schemes. This can also help prevent new batteries that have not yet been used in a vehicle from being recycled, for example because the storage time has been exceeded or new battery systems have been introduced). Concepts and business models for second-life applications (such as remanufacturing, reuse, repurposing, or preparation for reuse or repurposing) of electric vehicle batteries should be further developed. Recycling processes must also ensure that the black mass obtained remains within the European market.

Improving information on the location of vehicles, including end-of-life vehicles / preventing illegal recovery and exports

Improving transparency regarding the location of vehicles, including end-of-life vehicles. Appropriate and proportionate measures will be developed to prevent a situation where the location of large numbers of permanently decommissioned vehicles cannot be determined, as is currently the case. These vehicles are consequently not being processed in accordance with the EU End-of-Life Vehicles Directive and the German End-of-Life Vehicles Ordinance (Altfahrzeugverordnung). New measures will also help secure the business operations of numerous accredited small and medium-sized dismantling businesses.

Further development of end-of-life vehicle recovery through separation requirements and metal removal obligations

Germany has consistently met the weight-based recycling targets for end-of-life vehicles for many years. However, higher-quality material fractions must be produced from vehicle recovery (as pure as possible and suitable for long-term circular use). It is therefore necessary to assess whether further requirements should be introduced for removing components (such as printed circuit board fragments and magnets) in dismantling facilities and whether obligations to remove metals from shredder residues should be implemented and enshrined in law.