This is part of AIAG's series recapping sessions from the 2024 Hybrid IMDS, Product Compliance & Sustainability Conference.
Are you in the know about the latest European Union (EU) legislation and the EU auto industry responses and actions? The session “EU Legislative Updates” covered this timely topic at the 2024 Hybrid IMDS, Product Compliance & Sustainability Conference.
(Also, early-bird registration is still available for the 2025 Hybrid IMDS, Product Compliance & Sustainability Conference from October 8–10, 2025, in Novi, Michigan.)
The “EU Legislative Updates” presentation was given by Matthew Griffin, Senior Technical Specialist for Hazardous Materials Compliance, Jaguar Land Rover. Here’s a closer look.
End-of-Life Vehicle Regulation (ELV-R)
EU elections brought a change of presidency in 2024 with a new parliament and commission. Switching from the Council’s Belgium agreement to a Hungarian proposal led to discussions on scope expansion and Annex VII.C mandatory dismantling, obligations on manufacturers to provide access to parts and components’ catalogue, and more. In 2025 Poland took over the presidency, and the Council adopted its position on the ELV regulation.
Substances of Concern
“The pressure continues to identify, declare, and reduce substances of concern (SOC) in products,” Griffin said. “However, SOC is not a defined class of substances, so it is still unclear what needs to be reported.”
The Ecodesign for Sustainable Products Regulation entered into force in 2024 and set the scene for what could be required going forward. Also, the Battery Passport, EU Taxonomy, and Corporate Sustainability Reporting Directive entered into force in 2023. During the 2023 Global Automotive Declarable Substance List (GADSL) workstream, a task force identified automotive-relevant SOCs for incorporation in the 2025 GADSL publication.
New REACH Annex XVII Restrictions 2024
The Perfluorohexanoic Acid (PFHxA) Restriction of 2024 says that automotive seat upholstery and convertible covers made with textiles, leathers, furs, and hides shall not be placed on the market starting in 2027.
Also, the 2023 Synthetic Polymer Micro Particle Restriction’s reporting and information obligations start in October 2025. The 2023 Formaldehyde Restriction’s obligations start in August 2027 with the first draft of the European Chemicals Agency (ECHA) Guidance published in 2024. The N,N-Dimethylformamide Restriction published in 2021 came into force in 2023.
Annex XVII Registry of Intentions
The ECHA published its Annex XVII Registry of Intentions, sharing what it intends to restrict next. It adopted its opinion on Medium Chain Chlorinated Paraffins (MCCP), shared its intention for Hexavalent Chromium; and is developing its opinion on PFAS, with restrictions expected to start around 2030.
“The infamous PFAS is such a hot topic,” Griffin said, noting a record 6,500 comments received during the six-month public consultation in 2023. The automotive industry is in the transport sector, which is due to be discussed in 2025.
“We can hope that the scope is going to change, but we need to prepare for the worst,” Griffin said. “Evaluate your PFAS usage, look at and test alternatives, and make sure you have compliant products to sell in the 2030 timescale.”
Restriction Calls for Evidence
To understand if there is a need for a restriction requirement, information is being gathered on Aromatic Brominated Flame Retardants, which is a concern for the automotive industry; Trixylyl Phosphate, which might not impact the industry; and PVC and PVC Additives, with PVC material not expected to be restricted, while certain additives may be restricted.
“These are in the very early formative stages at the moment, so we don’t have a restriction proposal announced,” Griffin said.
The EU Pop Restriction
There are three additions eminent to the EU Pop Restriction: Dechlorane+, UV-328, and MCCPs.
Dechlorane+ is a flame retardant used in a lot of the automotive industry’s electrical applications, and its restriction entered into force in 2025. “If you have any Dechlorane+ left in your parts, work with your suppliers to make sure they’re eliminated as soon as possible,” Griffin said.
UV-328 was identified as a persistent organic pollutant. While a five-year exemption for automotive applications goes to 2028 and a service part exemption applies until 2044, some Signatories, such as South Africa and Singapore, are not transposing the exemptions into their national regulations.
Restrictions proposed for MCCPs (Chlorinated paraffins with carbon chain lengths C14-C17) differ from REACH restrictions and can be confusing. The degree of chlorination dictates whether it will be a POP or not. A five-year exemption has been proposed for PVC in rubber or plastic insulation. Proposals for other exemptions go until 2036 and even 2041.
REGISTER TODAY FOR THE 2025 IMDS CONFERENCE
This topic and more will be covered at the 2025 Hybrid IMDS, Product Compliance & Sustainability Conference from October 8–10, 2025, at Suburban Collection Showplace in Novi, Michigan. Registration is now open, and the early-bird pricing goes until September 16, so don’t miss out.