The EU End-of-Life Vehicle Regulation Is Live: Recycled Content Starts at 15%, but Tyre Elastomers Do Not Count Yet

In one line: Regulation (EU) 2026/1738 entered into force on 13 August 2026, replacing a Directive that had stood for more than two decades. It sets mandatory recycled-plastic-content targets for new vehicles — 15% from 2032, rising to 25% from 2036 — and brings chemical recycling in, counted via mass balance. One provision bears directly on recovered carbon black: tyre elastomers are currently excluded from those targets, with the Commission required to review the question by 31 December 2033. For rCB, this is a window that the text explicitly holds open.

1. Not an amendment — a change of instrument

Directive to Regulation is the key difference: a directive must be transposed into national law, whereas a regulation is directly applicable — leaving no room for divergence between member states. This has become the EU's standard approach in circular-economy legislation.

2. Recycled content: numbers, object, and origin restrictions

The "at least 20% from end-of-life vehicles" rule is the design's pivot: it prevents manufacturers from meeting targets with externally sourced recyclate while continuing to bury their own vehicles. It ties the recycled-content target to a closed-loop collection system.

3. 🚨 The core point: tyre elastomers are excluded

This is the paragraph most readers should take away.

Under the current text:

• Elastomers from tyres do not count towards the recycled-content targets — at least initially. The wording in Article 6(3) is that the weight of plastic in each new vehicle type, and the weight of recycled plastic referred to in paragraphs 1 and 2, "shall exclude elastomers from tyres and from thermosets other than polyurethane foams used for cushioning"
• Used parts may count, but tyre elastomers may not. The distinction is not "recycled or not" — the material category is treated separately

One detail worth carrying: the exclusion covers not only tyre elastomers but also thermosets other than polyurethane foams used for cushioning. Both are excluded by the same paragraph — missing the second category overstates how much recycled content can be counted.

The Commission's obligations and deadlines:

The two assessment points are different in kind — do not merge them. The 2031 assessment asks "can the targets actually be met" (supply and cost); the 2033 review asks "should tyre elastomers be counted in". The first is an execution-risk early warning; the second is the question that decides rCB's eligibility.

How to read this:

1. "Does not count" is not permanent exclusion — it is deferral to a defined review point
2. It establishes a conditional path: demonstrate technical maturity and environmental performance first, then discuss inclusion
3. Until then, the driver for rCB entering the EU automotive chain does not come from this regulation — it may come from CBAM carbon costs, from manufacturers' own Scope 3 targets, or from recycled-content requirements on other tracks

Put differently: the market reads (EU) 2026/1738 as "rCB's European opportunity", but the legal text does not say that. Treating "may be included later" as "already included" when planning capacity is the single most likely misjudgement on this track.

4. How chemical recycling counts: a pending decision

Chemical recycling is allowed to count towards the recycled-content targets, via a mass balance approach.

But it is conditional: the Commission must adopt an implementing act setting out the calculation and verification methodology by 31 August 2028. Until that act exists, the treatment of chemical recycling is not finally settled.

This mirrors the Battery Regulation's pattern: targets first, methodology later (the battery methodology only appeared as a draft in August 2026). When planning capital expenditure, treat "methodology pending" as an explicit risk item, not a to-do.

5. Other key milestones

The "reporting before thresholds" pattern is clearest on permanent magnets — you are required to report data before being told what the standard is. It also means data capability is the real precondition for this compliance cycle.

6. China's side, placed alongside

On the same question of where end-of-life tyres go, the two sides use different levers:

The two are not comparable in dimension: the EU measures how much recycled material is in a new vehicle; China sets how many tonnes are processed per year. One is a content measure, the other a throughput measure.

For rCB, however, one conclusion follows directly: China's plan lists pyrolysis to chemicals alongside tyre retreading and reclaimed rubber as one of three technology pathways — meaning pyrolysis is explicitly within the national industrial catalogue, backed by a quantified aggregate target to 2030. Domestic rCB demand therefore does not depend entirely on when the EU's door opens.

7. Boundaries and definitions

1. The key conclusions here have been checked clause by clause against the Official Journal text of (EU) 2026/1738 (EUR-Lex, ELI: reg/2026/1738, read directly on 2026-10-11). Provisions confirmed verbatim include: Article 6(3) — the weight "shall exclude elastomers from tyres and from thermosets other than polyurethane foams used for cushioning"; Article 6(5) — "by 31 August 2028, the Commission shall adopt an implementing act … to establish the methodology for the calculation and verification", with mass balance applying to recycled plastic from non-mechanical recycling; the Article 5 assessment "by 14 August 2031" of whether manufacturers are on track with the Article 6(1) targets; and the review "by 31 December 2033" of bio-based plastic content and tyres-derived elastomers. These clauses carry confidence A.
2. "Tyre elastomers do not count" describes the current text, not a permanent arrangement. The 2033-12-31 review is the legal point at which that status could change — but a review is not inclusion.
3. This piece does not cite any commercial analysis firm's estimate of EU recycled-plastic demand. Such estimates dominate the top of public search results, but their data basis and method are not transparent and they do not meet this site's sourcing floor.
4. China's 210 million tonnes is a 2030 target, not a current volume.
5. Nothing here constitutes a feasibility judgement on any specific project.

Data sources

Sourcing floor: all data here comes from public governments / international organisations / official bodies. No commercial data vendors enter the data table.

Grade key: L1 = government / international organisation / intergovernmental body / customs; L2 = international standards bodies / regulated exchanges / state think tanks; L3 = industry associations / company self-disclosure / official media relay (grey — original source must be cited); L4 = commercial data vendors / self-media (prohibited in this project).

Entries marked "—" are published here for the first time. Their confidence is A, based on a direct reading of the Official Journal text of (EU) 2026/1738 on 2026-10-11 (see section 7, item 1).

Data as of 2026-10-11. Individual records can be retrieved by record ID via the on-site data index or the MCP endpoint.