Manufacturing & Engineering UK-wide

Ongoing material duties for vehicle manufacturers: end-of-life recycling and restricted substances

A task guide for motor-vehicle manufacturers (SIC division 29) on the two ongoing material duties that continue beyond placing a vehicle on the market — end-of-life vehicle producer responsibility, and the restriction of chemical substances under UK REACH. Both are recurring duties to set up, not one-off checks.

Guide summary

You must set up two ongoing duties for as long as you make vehicles: end-of-life vehicle producer responsibility (free take-back, recycling targets, heavy-metal limits) and UK REACH (register substances, restrict hazardous chemicals). Set both up as recurring processes, not one-off checks. Breach is an offence.

  • Register as a producer for end-of-life vehicles
  • Join a compliance scheme for vehicle take-back
  • Design vehicles within heavy-metal limits (lead, mercury, cadmium, hexavalent chromium)
  • Register your chemical substances under UK REACH as required
  • Provide dismantling and material-coding information
  • Pass safety data sheets down the supply chain
  • Meet reuse, recycling and recovery targets each year
  • Keep records for both duties for as long as you sell vehicles
  • Northern Ireland uses EU REACH – check separately
  • Breach of either duty is an offence – civil sanctions or prosecution
On this page

Related guides in General Compliance

Getting a vehicle through type-approval and onto the market is not the end of your duties. As a motor-vehicle manufacturer (SIC division 29) you carry two ongoing material and lifecycle duties that run for as long as you place vehicles on the market: end-of-life vehicle producer responsibility, and the restriction of chemical substances under UK REACH. End-of-life vehicle producer responsibility applies UK-wide. UK REACH applies in Great Britain only (England, Scotland and Wales); Northern Ireland remains under EU REACH under the Windsor Framework, so if you place substances on the Northern Ireland market check the EU REACH position separately. Either way, set both up as recurring obligations, not one-off checks.

End-of-life vehicle producer responsibility

Because you place vehicles on the UK market, you are responsible for what happens to them at the end of their life. This means designing vehicles for recyclability and within the heavy-metal limits, providing free take-back of end-of-life vehicles through an authorised treatment facility network, meeting the reuse, recycling and recovery targets, and supplying dismantling and material-coding information. Plan the take-back arrangements and reporting before you scale production.

Restricted substances under UK REACH

The materials, coatings, adhesives and components your vehicles are made from engage UK REACH. Depending on volume and your role, you may need to register substances, observe restrictions on hazardous substances, meet authorisation requirements for substances of very high concern, and pass safety information down the supply chain. Vehicles are also subject to the heavy-metal limits that connect to the end-of-life vehicles regime, so treat the two duties together.

Set these up as recurring duties

Both duties continue for the life of your product range, so build them into your standing processes rather than treating them as a launch-time task.

  1. 1

    1. Register and join the right schemes

    Register as a producer for end-of-life vehicles and arrange take-back through an authorised treatment facility network, usually via a compliance scheme. Register the substances you place on the market under UK REACH as required.

  2. 2

    2. Design within the limits

    Design vehicles for recyclability and within the heavy-metal restrictions, and check that the substances in your materials are permitted, restricted or authorised under UK REACH before you specify them.

  3. 3

    3. Communicate the information

    Supply dismantling and material-coding information for end-of-life treatment, and pass safety data sheets and substance safety information down your supply chain.

  4. 4

    4. Report and keep records

    Meet the reuse, recycling and recovery targets and keep the producer- responsibility records up to date, and maintain your UK REACH registration and compliance records for as long as you place vehicles on the market.

What to do next

If you have not yet placed vehicles on the market, read the type-approval task guide first, then set up these ongoing duties alongside it. Run the sector compliance checklist to confirm both duties are in place. If you are unsure whether a substance is restricted, check it with the UK REACH Agency (the Health and Safety Executive) before you commit to a material.

Official sources

Statutory sources and regulators for end-of-life vehicles and UK REACH