Updated on August 2026

Automotive manufacturers, suppliers and importers face one of the most significant regulatory transitions in the history of EU vehicle chemicals management: Directive 2000/53/EC on end-of-life vehicles (ELV) is being replaced by Regulation (EU) 2026/1738, which entered into force on 13 August 2026 and will apply from 1 September 2028 (with certain provisions applying earlier and later). CIRS Testing provides a complete, up-to-date ELV compliance testing and consulting package that covers both the existing Directive 2000/53/EC obligations still in force today and the new requirements introduced by Regulation (EU) 2026/1738.

1. Regulatory Background: From Directive 2000/53/EC to Regulation (EU) 2026/1738

Directive 2000/53/EC set out measures to prevent waste from vehicles and to promote the reuse, recycling and other forms of recovery of end-of-life vehicles and their components, while restricting the use of hazardous substances in new vehicles. Its two core pillars were:

• Controlling the presence of four hazardous substances in vehicles: lead (Pb), cadmium (Cd), mercury (Hg) and hexavalent chromium (Cr(VI)); and
• Improving recovery rates for vehicle waste and promoting reuse and recycling of parts and materials.

The new Regulation (EU) 2026/1738 (published in the Official Journal on 24 July 2026, ELI: http://data.europa.eu/eli/reg/2026/1738/oj) replaces the Directive and significantly strengthens these requirements:

• Entry into force: 13 August 2026; application from 1 September 2028 (certain preparatory provisions applied from 14 September 2026);
• Repeal of Directive 2000/53/EC on 1 September 2028, although its Annex II substance rules and exemptions continue to apply until 31 August 2032; Directive 2005/64/EC is repealed on 31 August 2032;
• Extended scope: from 1 September 2028 the Regulation applies to M1 and N1 vehicles; from 1 September 2031 it extends to heavy-duty vehicles (M2, M3, N2, N3, O) and L-category vehicles;
• New substance ban: from 1 September 2032, any vehicle type newly type-approved under Regulation (EU) 2018/858, and new parts/components placed on the market for such vehicles, must not contain lead, mercury, cadmium or hexavalent chromium (Article 5(4)), unless covered by an exemption in Annex IV;
• ECHA's new role: the European Chemicals Agency (ECHA) assists the Commission in assessing substances of concern in vehicles (report due 14 February 2028), evaluates the technical and economic feasibility of alternatives to Annex IV exemptions, and supports restriction proposals under REACH for substances that hamper recycling (Article 5(2), (7)-(9));
• Circularity requirements: minimum recycled plastic content (15% by weight of post-consumer plastic waste for new types from 1 September 2032; 25% from 1 September 2036, of which at least 20% of the target must come from end-of-life vehicles or use-phase removed parts), recycled content declarations for permanent magnets, aluminium and steel, and a Digital Circularity Vehicle Passport (DCVP) mandatory from 1 September 2032;
• Export controls: from 1 September 2031, only used vehicles that are roadworthy and not end-of-life vehicles may be exported from the Union (Article 39);
• Interface with other legislation: new restrictions on substances of concern in vehicles are addressed under REACH (Regulation (EC) No 1907/2006); POPs requirements under Regulation (EU) 2019/1021 continue to apply; vehicle batteries are governed by the Batteries Regulation (EU) 2023/1542.

Key point for the supply chain: although Directive 2000/53/EC is repealed in 2028, its substance limits continue to apply through the new Regulation. From 2032 onwards, the Annex IV exemption list will be the only way lead, mercury, cadmium or hexavalent chromium may remain in newly type-approved vehicles. Every supplier of materials, parts and components to the automotive sector needs to know where these substances sit in its products, and whether any Annex IV exemption applies.

2. Key Compliance Timeline

3. Restricted Substances and Limit Values

3.1 EU ELV limit values (Annex IV to Regulation (EU) 2026/1738)

For materials, parts and components, the following maximum concentration values are tolerated in homogeneous material (a material of uniform composition throughout, as used in the ELV/RoHS regulatory framework):

Exemptions are listed in Annex IV to the Regulation, subject to defined scopes and expiry dates (e.g. lead in steel for machining purposes and in certain aluminium alloys, lead in batteries — now addressed under Regulation (EU) 2023/1542 — mercury in discharge lamps for headlight applications, Cr(VI) in corrosion preventive coatings, etc.). Some exemptions trigger removal/labelling duties where an average threshold of 60 grams per vehicle is exceeded.

3.2 Comparison with RoHS and China ELV

All values expressed by weight in homogeneous material. China's GB 30512-2014 applies to vehicles and parts manufactured in or imported into China.

3.3 "Homogeneous material" and testing strategy

Because the ELV limits are defined per homogeneous material, a compliant testing strategy requires correct material splitting before analysis: each homogeneous material (e.g. a polymer, a metal alloy, a coating) must be evaluated separately — concentration averaging across different materials is not permitted. CIRS Testing combines X-ray fluorescence (XRF) screening with wet-chemical confirmation on the correctly identified homogeneous materials to give a defensible, regulation-aligned compliance conclusion.

4. CIRS Testing ELV Compliance Services

4.1 Heavy metals testing — Pb, Cd, Hg, Cr(VI)

CIRS Testing provides full-scope testing of the four ELV restricted substances in materials, parts and components:

Note: Regulation (EU) 2026/1738 sets the concentration limits but does not prescribe specific analytical methods. CIRS Testing therefore applies internationally recognised standard methods validated for the automotive materials matrix, ensuring results are robust and audit-ready.

4.2 Homogeneous material splitting and sampling

• Identification of homogeneous materials within complex assemblies;
• Component disassembly and material separation per regulatory definitions;
• Sample preparation to avoid cross-contamination and ensure representative results;
• Test reports stating the exact material/matrix tested and the limit value applied.

4.3 Annex IV exemption assessment

• Screening of the parts list against the Annex IV exemption table;
• Verification of exemption scope and expiry dates against vehicle type-approval dates;
• Advice on labelling / making-identifiable obligations and on the 60 g-per-vehicle dismantling thresholds;
• Gap analysis for the 2032 new-type-approval deadline.

4.4 Supply chain substance data and IMDS

• IMDS data entry, review and correction (see our IMDS Service);
• Building and maintaining the parts–materials–substances data needed for the future Digital Circularity Vehicle Passport (DCVP), including information on parts containing exempted Pb, Hg, Cd or Cr(VI) (Article 13(2)(b));
• Supplier declaration management and GPM system support (see Automotive GPM Hazardous Substance Management System).

4.5 Related substance testing

In addition to the ELV four substances, CIRS Testing covers the regulatory portfolio relevant to vehicles and spare parts:

REACH — SVHC candidate list testing, Annex XVII restrictions (including PAHs), and support for upcoming vehicle-specific restrictions under the new Regulation;

POPs — testing per Regulation (EU) 2019/1021;

Batteries Regulation (EU) 2023/1542 — substance restrictions for vehicle batteries;

Asbestos — see our Asbestos Testing service;

PAHs — see our PAHs Testing service;

VOC / interior air quality — see our VOC Testing service;

Salt spray / corrosion — see our Salt Spray Testing service.

5. Why Choose CIRS Testing

Regulation-first approach: our experts work directly from the text of Regulation (EU) 2026/1738 and its Annex IV, not from outdated summaries of Directive 2000/53/EC;

Full analytical capability: XRF screening, ICP-OES/ICP-MS/AAS and specialised Cr(VI) methods under one roof, with homogeneous-material-based reporting;

Automotive domain knowledge: type-approval documentation, IMDS and GPM system support, and Annex IV exemption assessment;

Global reach: laboratories and support teams in China, the United Kingdom, the United States and Ireland, serving automotive supply chains worldwide.

CIRS Testing can provide professional testing as per the requirements of Directive 2000/53/EC and Regulation (EU) 2026/1738. Besides, we can render you one-stop solutions integrating consulting, testing and certification. Please feel free to contact test@cirs-group.com if you have any questions.

Disclaimer: This page is provided for general information only and does not constitute legal advice. For legally binding provisions, please refer to the official text of Regulation (EU) 2026/1738 on EUR-Lex.