Statement – 12^th November 2025

Used parts sales

In the proposal for a circular vehicle regulation, article 31 3. Refers to a list in Annex VII part E, excluding certain parts from reuse. These parts are sold as to today without any problems. The mentioned parts are pyrotechnical parts as in airbags, retainers and their electronics, emission parts like exhausts, cats and particle filters, steering locks and some electronical systems like immobilisers and ECUs.

It’s totally unclear where this prohibition comes from. We are not aware of any unsafe situations in traffic as a result of sales of these parts. We are aware of the the Takata airbag problem for some brands and types of vehicles, but it would be enough to make a list of types that should not be sold. Just forbidding to reuse any airbag is not reasonable. Why emission parts cannot be reused is really puzzling and confusing. Why would an older car need an expensive new cat of filter if used is available? Why is it forbidden to reuse a muffler? What evil is tackled by this restriction?

Besides this, if a car was in an accident and some airbags would deploy, only the deployed ones will be replaced at repair. So what’s the difference between those airbags and reused airbags? Even an expiration date does not lead to any replacing of airbags. Inspection protocols could be drawn up for safety components (one for each type of part), and the dismantling company should apply them and declare that they have been applied when selling the part. A used airbag is better than no airbag at all and It will only lead to cars driving without them if airbags are no longer supplied by OEMs and if used ones are forbidden to sell.

The illegal sector will flourish and will sell anything, forbidden or not. It will worsen unfair competition. ATFs already have many costs and this will only lead to less income. It will also lead to increased criminality. Airbags but even cats will become what radios used to be. Cars will be broken into to steal parts. Consumers will suffer from broken in cars and stolen parts. And they will be driven to illegals for cheap replacements.

ATFs can’t even take out all value as parts are digitally locked or interchange is unclear. ATFs can’t even get all ELVs. Forbidding to sell perfectly good parts is total unnecessary destruction of capital. The footprint of both parts as cars (if they cannot be repaired and maintained for reasonable prices or if arts are no longer available) will increase significantly and with no purpose.

We could live with the restriction that safety parts need to be built in by professionals, we see the importance of traceability, we can do checks, but we see no reason or use in a total prohibition. EGARA is of opinion that every part that can be reused, should be reused. A law that prohibits reuse without any motivation or enables OEMs to lock parts and frustrate interchange is not a green, sustainable or circular law, it’s just greenwashing as it prevents actual sustainability and circularity and it facilitates illegals.