South Africa: End-of-Life Vehicle Strategy Takes Shape

• South Africa is developing a legal framework to determine when vehicles are retired, ensuring their disassembly and recycling to prevent landfill pollution.
• The Automobile Association proposes retiring vehicles 15 years and older due to unroadworthiness, while Naamsa advocates for a 'health assessment' based on roadworthy tests, not age.
• The Motor Industry Staff Association warns that without this framework, South Africa risks losing access to its European export market due to new EU circularity rules requiring recycled content and full lifecycle responsibility.
• Non-compliance with EU standards could jeopardize R291 billion in export revenue and hundreds of thousands of jobs.
• Socioeconomic factors and affordability issues present challenges, but the strategy is also driven by concerns over high road fatalities linked to vehicle condition and the absence of regular roadworthiness inspections.

Failure to comply with these emerging international standards could jeopardize South Africa's substantial automotive export revenue, valued at R291 billion, and threaten hundreds of thousands of jobs.

South Africa is currently in the process of developing a comprehensive end-of-life vehicle (ELV) strategy and an accompanying legal framework. This initiative aims to establish clear guidelines for when vehicles in the country's fleet will be officially "retired" and no longer permitted for use on public roads. A core objective of this SA vehicle retirement framework is to ensure that vehicles reaching the end of their operational lifespan are systematically disassembled and recycled, thereby mitigating their environmental impact and preventing the accumulation of automotive waste in landfill sites.

The Automobile Association (AA) CEO, Bobby Ramagwede, indicated that the AA advocates for an initial retirement age of 15 years and older, citing that this demographic represents the highest proportion of unroadworthy vehicles. However, Ramagwede acknowledged that determining the precise age will necessitate extensive discussions, given the significant socioeconomic considerations at play within the South African context. The development of this strategy is poised to introduce new legal requirements for vehicle owners and the automotive industry alike, impacting everything from vehicle registration to disposal.

While the AA proposes an age-based approach, Tshetlhe Litheko, Chief Policy Officer at the automotive business council Naamsa, presented a contrasting view. Litheko stated that vehicle retirement should not be solely dependent on age, but rather on a thorough "health assessment" of the vehicle. He explained that with the average age of vehicles in South Africa hovering around 15 years, the critical factor is a vehicle's fitness for continued operation, as determined by rigorous roadworthy tests, rather than its chronological age.

This proposed strategy forms the second phase of the AA's SaferCarsForAfrica programme, a collaboration with Global NCAP. The AA has identified that South Africa, despite being an established automotive market, lacks a specific dispensation addressing the age of its vehicle population, a factor directly linked to road safety. Ramagwede emphasized that the condition of vehicles is a significant contributor to road safety concerns, highlighting the absence of regular annual roadworthiness inspections as a critical gap in protecting road users. He noted that a dispensation for classic cars would likely be included in any final framework.

The Motor Industry Staff Association (Misa) has underscored the urgent necessity of this framework, warning that its absence could jeopardize South Africa's access to its primary export market. Martlé Keyter, Misa's CEO of Operations, revealed that approximately three out of every four vehicles exported from South Africa are destined for Europe. The European Union's new vehicle circularity rules, Regulation 2026/1738, entered into force on August 13, 2026, and will mandate the use of recycled materials, circular design principles, and full lifecycle responsibility from manufacturers.

Failure to comply with these emerging international standards could jeopardize South Africa's substantial automotive export revenue, valued at R291 billion, and threaten hundreds of thousands of jobs. Ramagwede pointed out that regions like Europe and the ASEAN bloc already maintain clear parameters for deeming vehicles unroadworthy, often tied to age (e.g., 10 years, or 8-12 years with testing, leading to mandatory scrapping at 12 years), based on safety, emissions, and general condition, not just functional ability. This highlights the global shift towards South Africa automotive circularity and stricter Misa vehicle export requirements.

The implementation of such a strategy in South Africa presents a complex challenge, particularly given the country's significant affordability issues. Ramagwede acknowledged that while vehicle retirement based on age or condition is a "hot potato" due to these economic realities, the current situation sees a high number of road fatalities, with substantial evidence suggesting a link to the poor condition of vehicles on the road. The lack of consistent, annual roadworthiness inspections means there are currently no effective guardrails to ensure vehicle safety.

Despite these challenges, the development process is moving forward. Tshetlhe Litheko confirmed that Naamsa is actively collaborating with Toyota Tsusho on a research study for the end-of-life vehicle strategy, indicating ongoing efforts to shape the future of vehicle retirement and SA car recycling law within the country. This collaboration suggests a multi-stakeholder approach to navigate the technical, economic, and social complexities inherent in establishing a robust end-of-life vehicle system.

Lawyers and compliance officers in the automotive sector should closely monitor the development of South Africa's end-of-life vehicle strategy, as it will introduce new legal requirements for vehicle retirement, disassembly, and recycling, potentially impacting manufacturing, import, and export operations, particularly concerning EU circularity rules.

Source: Reporting based on industry and association statements