Foreign vehicle manufacturers, importers, dismantlers, component suppliers and investors must prepare for the revised EU circularity and extended producer responsibility (EPR) framework. Regulation (EU) 2026/1738 addresses design for dismantling, re-use and recycling, management of end-of-life vehicles and responsibilities along the automotive value chain.
The 2026 regulation and its application dates
Regulation (EU) 2026/1738 entered into force on 13 August 2026. General application is scheduled for 1 September 2028, with certain provisions applying earlier or later. A legal assessment must therefore distinguish current obligations, transitional law, preparatory requirements and future duties.
Producer responsibility and operational structures
Depending on vehicle category and market role, a manufacturer, importer or other operator may need advice on take-back, treatment arrangements, producer responsibility organisations, documentation and contractual allocation. The analysis begins with the actual supply and collection chains and the legal position of the party entering the Italian market.
Components, waste status and recovery of critical materials
The regulatory framework seeks to facilitate removal, replacement, reuse, recycling and recovery of valuable materials. It creates legal questions concerning reused vehicle parts, the boundary between product and waste, record-keeping, collection contracts and authorisations. Technical testing and assessment of roadworthiness or part safety are separate specialist activities.
Industrial transactions and dispute support
Foreign counsel may require a focused Italian-law review for an acquisition involving a dismantling business, a supplier or a vehicle manufacturer: relevant permits, historical waste liabilities, environmental orders, administrative proceedings and risk allocation in the transaction agreement. We can also assess the legal basis of contested regulatory decisions.
Research-led Italian environmental counsel
Alfonso Maria Fimiani’s university research addresses product lifespan, extended producer responsibility and the second life of products. He has been admitted as IR Global’s exclusive Environmental Law member for Italy, with membership commencing on 28 November 2026. Overseas lead counsel can retain the wider mandate and refer only the Italian environmental-law component.
An initial enquiry should describe the vehicles or components, market and collection model, Italian operations, documents and legal deadlines. Circular economy and EPR · Environmental due diligence · Contact · Italiano · Français.
Primary source: Regulation (EU) 2026/1738.