The European Composites Industry Association (EuCIA), together with the key European manufacturers of carbon fibres (EU carbon fibre manufacturers: CIT (part of Toray Group), DowAksa, Hexcel, Mitsubishi Chemical Europe, Teijin Carbon), the European Automobile Manufacturer’s Association (ACEA), and TECH-FAB Europe, welcome the European Commission’s proposal to review the End-of-Life of Vehicles (ELV) Directive. Carbon fibre reinforced composite materials are enablers of sustainability and employed in a wide range of markets, including aerospace, renewable energy, marine, and defence. In particular, they play a crucial role in transportation applications, wind energy, aerospace…, where they deliver lightweighting and emissions reduction, enhanced safety, and longevity.

Carbon fibre enables the manufacture of high-performance, lightweight, and durable composite materials that are central to the EU Clean Industrial Deal objectives for decarbonisation, innovation, and industrial resilience in sectors critical to the green transition.

Carbon fibre is not classified as hazardous under World Health Organization (WHO) criteria, further underscoring its suitability for sustainable industrial development.

The European composites industry represents more than 150,000 jobs in Europe alone and the European manufacture of carbon fibre, a strategic raw material for the composites industry, is integral to this.

This paper articulates the material, environmental, and safety benefits of carbon fibre and calls for its
appropriate inclusion in the evolving European regulatory framework. We propose an adaptation of the
ELV regulation to better reflect these facts.

1. Carbon fibre: a circular, technologically essential material in Europe

• Carbon fibres combine exceptional stiffness, strength, and corrosion resistance with low weight and low thermal characteristics expansion. They are stronger than steel yet significantly lighter, making them indispensable in energy, transportation, aerospace and defence, and several consumer goods applications.
• Carbon fibre reinforced composite materials are recognised as essential to our European net zero transition and green industrial transformation through their use in the applications noted in Annex 2.
• Carbon fibre composites are circular materials that can be reused, repurposed and repaired thanks to their exceptional durability, as well as recycled through existing widely used processes, where the intrinsic fibre properties remain.

2. Safety profile: not hazardous under WHO criteria

• Carbon fibres are not classified as hazardous materials according to the WHO definition. The fibres are engineered with diameters typically ≥4μm, safely exceeding the WHO’s threshold for respirable fibres (<3μm). PAN-based carbon fibres, which dominate automotive and industrial use, are also resistant to cleavage and do not generate respirable fragments during processing.
• Further safe handling practices and standard dust control measures ensure a secure working environment.

Note: Carbon fibres are registered as articles under REACH. Their low hazard profile as detailed in Annex 1
means that only standard worker protection measures for material handling (e.g., gloves, PPE for dust
suppression) are required. More details are provided in Annex 1.

3. Proposed adaptation to the ELV Regulation proposal

We urge policymakers to recognise carbon fibre’s role in Europe’s sustainable industrial development
and ensure its fair and evidence-based inclusion in European regulations. We recommend the following
amendment:

Restrain from the intention to add carbon fibres to Article 5, since they are not equivalent to
lead, mercury, cadmium, or hexavalent chromium under the RoHS Directive (JCMA publication May 9th, 2025: https://www.carbonfiber.gr.jp/english/tech/pdf/JCMA_CF_Position_ELV_directive_amendment_EN.pdf)

Signatories:

The European Automobile Manufacturers’ Association, or ACEA, unites Europe’s 16 major car, truck, van and bus makers. We are the voice of the auto industry: a technological world leader and the backbone of the EU economy.
Composite Materials Italy (CIT) manufactures woven carbon, special fabrics, multiaxial, prepregs and UD tapes. We also formulate and apply our own resins, as well as other formulations depending on the designated use and areas of application: industrial, aerospace, automotive, sport and leisure, medical, building.
DowAksa, combines the strengths of two world-class companies, Dow, a global leader in providing materials science solutions, and Aksa, the number one producer of acrylic fibers. The 50:50 joint venture provides fully integrated solutions including product (from precursor to carbon fiber to prepreg), engineering, technology, and knowledge to carbon fiber and carbon fiber intermediates needs of industrial markets.
Headquartered in Brussels, the European Composites Industry Association (EuCIA) represents European national composites associations and industry-specific sector groups at EU level. With the support of its members, EuCIA is actively contributing to building an economically and environmentally sustainable European composites industry.
Hexcel Corporation is a global leader in development and manufacturing of lightweight, high- performance structural materials including carbon fibers, prepregs and other fiber-reinforced matrix materials, honeycomb, engineered honeycomb and composite structures. Hexcel products are used in variety of end applications including Commercial Aerospace (e.g., commercial aircraft), Space & Defense (e.g., military aircraft, space launch vehicles and satellites) and Industrial markets (e.g., wind turbine blades, automotive, recreational products). Hexcel products help its customers enhance performance of their products while reducing weight, which decreases fuel consumption and associated CO2 emissions.
Mitsubishi Chemical Europe offers and sells highly developed chemical-based products. The
portfolio includes performance polymers, carbon fiber & composites, polyester films, aluminum
and metal composite sheets as well as semiconductor solutions for a wide range of industries.

photo: EuCIA