Circularity of vehicles: Design, production, end of-life and waste management

Summary:

The IA provides an integrated life cycle analysis of the benefits and costs/burdens of vehicles in the EU, from their design and production, to their end-of-life management. From a political and legal perspective, the choice of merging the revisions of two complex directives into one regulation, and the choice of the functioning of the internal market as sole legal basis seem duly justified in the IA. However, from a better regulation and transparency perspective, these choices entail considerable challenges. The definitions of both the problems and the objectives show some inconsistencies stemming from the complexity of the integrated issues at hand, which complicates the IA's intervention logic. In addition, the IA's narrative relies heavily on the results of complex 'custom made modelling' that structures the assessment, but whose analytical methods, underlying assumptions and limitations (and thus, uncertainties) are not always evident. This also affects the presentation and assessment of the 52 measures (featured under 16 options), which could have been more coherent and accessible.

A wealth of important information, explanations and evidence is featured in the annexes and/or the studies supporting the IA, rather than in its main text. These caveats notwithstanding, the comparative assessment and the selection of the preferred option package appear to be thorough and well substantiated. Altogether, without questioning the quality and the findings of this rich IA, it may well indicate the limitations of this type of integrated life cycle analysis as an accessible support tool for policymakers, in particular when the expected (cumulated) costs and benefits stretch over a range of different large policy areas, sectors and stakeholder groups. It is worth highlighting the importance of having these inherent limitations in terms of accessibility and transparency in mind when setting up an IA process and drafting the IA.

This briefing is part of the series Initial Appraisal of a European Commission Impact Assessment.

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