11th December 2025

Vehicle traceability

The importance of continuous registration of vehicle ownership

EGARA often advocated continuous registration of vehicle ownership through the whole EU, combined with vehicle obligations (tax, roadworthiness and insurance). Many (most) systems allow vehicles to leave at any moment without any consequences for the owner. This make vehicles disappear to the illegal sector if they do not re-appear. Only CODs (or worst case export outside EU) should end vehicle registration. It seems this was in a commission proposal to update the Registration Directive, which is very good and which we support, but seems to be erased by the council. It would affect traceability seriously if this element is deleted.

Unknown whereabouts
The figure below is not the most recent, but it shows every year 10-12million vehicles leave registration systems permanently of which more than 1/3rd with unknown whereabouts.

Source: Umweltbundesamt 2020

Traceability in Registration Directive
Article 6e specifically describes the continuous traceability from vehicles as the vehicle registers shall include information on any change to the ownership of vehicles. Someone needs to be responsible for a vehicle at all times. Article 6a seems to be erased by the council. It would affect traceability seriously if this element is deleted, as only temporary deregistration is followed in the council proposal (proposed article 8a). This way any other reason for deregistration means the vehicle is out of sight again.

Deregistration
If it were up to EGARA, a vehicle could only be deregistered permanently from a national system if:
– A COD is issued;
– A vehicle is re-registered in another national vehicle register.

Keeper/ownership
What is really important to solve, is the limbo a vehicle is in when exported and not re-registered (yet) somewhere. After being registered as exported, it must be somehow possible to keep track of the whereabouts of the vehicle and who is owner/keeper/responsible for the vehicle. Export needs to be banned as the legal escape from supervision and enforcement. Registration systems of member states need to be able to connect. These issues are not solved in the Commission proposal nor in the Council’s.

Suspension/Temporary deregistration
EGARA can support the technical definitions of suspension (as a result of being not roadworthy) or temporary deregistration (owner is still responsible, but as the vehicle is not in use, it’s exempt of vehicle obligations. But in both cases someone is always responsible for the vehicle. We even would suggest to connect some incentives to these statuses like an annual fee and renewal to prevent eternal temporary deregistration or suspension.

Continuous registration
EGARA hopes the EU is wise enough to recognize the necessity of a closed and continuous registration system in every member state. Elaborated laws are made trying to process ELVs (End of Life Vehicles) in a responsible way, but this starts with getting all ELVs in scope. As long as more than a third vehicles is missing because of unknown whereabouts, reporting about recycling is futile.

For the complete commission proposal see:
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52025PC0179