The European Association of Motorcycle Manufacturers (ACEM) supports the “End of Life” (ELV) Directive.

The European regulation on "end-of-life" vehicles, known as the "ELV Directive," was adopted on September 18, 2000, with the aim of regulating the handling of 6-9 million tons of vehicle waste each year.

On March 16, 2021, the directive was updated with significant amendments in line with comprehensive changes and sustainability and environmental goals. From July 20 to October 26, 2021, a public consultation was held on the revised ELV rules. On July 13, 2023, the European Commission adopted a proposal for the ELV regulation, which was to be implemented by relevant authorities within 18 months. This means that the new regulation should be applied no later than early 2025. However, the EC also set a 60-month "transition period" to allow manufacturers, processors, and recyclers to adapt.

On December 12, 2023, the European Automobile Manufacturers Association (ACEA) published a "Position Paper" on the ELV Directive, giving its full support to the goals aimed to be achieved.

Now, on October 30, 2024, the European Association of Motorcycle Manufacturers (ACEM) has also issued its "Position Paper" fully supporting the sustainable inclusion of motorcycles in the "end-of-life" regulation.

In its statement, ACEM recalls that it has been a partner in implementing the ELV Directive for more than twenty years. Following the adoption of new ELV regulations last year, ACEM and its members will utilize the 60-month transition period to integrate more effectively into recycling processes and waste management, an inseparable part of the European circular economy.

In its "Position Paper," ACEM, with unwavering support for the regulation's goals toward sustainability and circularity, calls on legislators to consider ways to ensure smooth and sustainable implementation within the 60-month transition period proposed by the European Commission. They advocate excluding small motorcycle series to secure regulatory clarity and industrial competitiveness. ACEM also highlights the importance of establishing a legal framework governing producer responsibility, asserting that all requirements for manufacturers under the ELV Directive should apply only to vehicles produced after "+ 60 months" from the regulation's effective date. This is considered a critical timeframe for manufacturers to successfully adapt to the new regulatory environment.

ACEM believes this period is essential for the motorcycle industry, which is on the verge of extensive restructuring, the implementation of new manufacturing processes, and the integration of necessary software systems to meet ambitious sustainability goals.

"In practical terms, our members will have to build an entirely new organization, a new structure. They will need to adapt production protocols and significantly increase documentation related to compliance, particularly for vehicle type approval procedures. Without this adequate time (60 months), the risk of disruption is high, imposing unnecessary burdens on both manufacturers and the broader supply chain," ACEM states.

Although the ELV Directive was carefully prepared, ACEM warns of some "linguistic ambiguities" and calls on legislators to revisit Article 2.6 to ensure complete legality.

"As currently written, there is a risk of misinterpretation. Specifically, this means that 'Article 16' could be applied prematurely to motorcycles just 36 months after the regulation’s effective date. The Commission has clarified that obligations only take effect after 60 months, but confusion persists. Such uncertainty could undermine the industry’s ability to prepare and meet regulatory goals on time," ACEM cautions.

ACEM also advocates for ensuring "fair and balanced access when launching new models on the market, so that all actors proportionally bear dismantling costs."

"In addition, we support the introduction of financial guarantees for individuals as an integral part of the system, ensuring that costs are covered fairly and transparently, as in the case of the French ELV (Decret 2022-1495). These guarantees should be sufficient to cover costs for at least one year from the date of approval," concludes the ACEM statement.