OpenLobby.EU
Explore

ADPA - European Independent Automotive Data Publishers Association

ADPA

ADPA aims to ensure fair access to automotive data and information needed for servicing, repairing and maintaining road vehicles.

Lobbying Activity

Response to Delegated Regulation on effective and secure access to On-Board Diagnostic and Repair and Maintenance Information

2 Dec 2025

ADPA supports the principles of the Delegated Act, which are reaching a fine balance between equally legitimate concerns on cybersecurity and competition, even if it considerably reinforces the position of vehicle manufacturers. ADPA recommends the European Commission to proactively, immediately and strictly enforce the measures in order to avoid potential abuses by dominant market players, in particular considering that the latter see their possibility to restrict the independent aftermarket reinforced. ADPA warns that the Delegated Act is only answering to some issues faced by the market and should not be considered as a final remedy; a number of regulatory measures still need to be taken to improve competition and consumers choice for the provision of aftermarket services which are essential for the safety and the sustainability of road mobility.
Read full response

Response to Apply AI Strategy

4 Jun 2025

ADPA supports any measure which can help the European Union to be truly a leader in Artificial Intelligence (AI). In this regard, the ambitions of the European Commission, as recently outlined, are a welcomed signal. ADPA considers that the automotive aftermarket, which is in charge of the roadworthiness of vehicles over their lifetime, can be a key enabler of AI-driven solutions, with a concrete and direct impact on the affordability, the safety and the sustainability of road mobility. However, several commercial and/or technical practices can hinder the deployment of AI solutions, or can turn AI into a problem rather than a solution. - AI is dependent on the availability of data, and in particular their latency, their granularity, their cost. However, in the automotive sector, vehicle manufacturers benefit from their gatekeeper position and can restrict competition. - Similarly, for the deployment of AI-based solutions, access to in-vehicle functions and resources is crucial. There is currently no direct and clear regulatory requirement for such access. - AI systems based on the free pillage of other creators content lead to unfair competition and endanger innovation. For AI to truly and fully materialise and have a positive impact on European consumers and businesses, the European Union must strengthen its regulatory framework, and enforce it. In particular, IPRs should be duly protected to ensure fair remuneration and accountability. In parallel, access to in-vehicle data, functions and resources should be granted to independent operators through different, complementary legislative instruments: the Data Act, the Motor Vehicle Block Exemption Regulation, and a sector-specific legislation.
Read full response

Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and Fédération Internationale de l'Automobile and

11 Feb 2025 · Action plan for the automotive sector

Meeting with Silvia Bartolini (Cabinet of Executive Vice-President Henna Virkkunen), Xavier Coget (Cabinet of Executive Vice-President Henna Virkkunen) and

14 Jan 2025 · The role of the automotive aftermarket in the EU Industrial Action Plan for the automotive sector

Meeting with Helena Hinto (Cabinet of Commissioner Apostolos Tzitzikostas) and Insurance Europe and

10 Jan 2025 · Introductory meeting

Meeting with Elena Sancho Murillo (Member of the European Parliament) and Vodafone Belgium SA and Shell Companies

10 Dec 2024 · Relevant issues to the ITRE Committee

Meeting with Andrea Wechsler (Member of the European Parliament) and BASF SE and

10 Dec 2024 · EU Energy and industry policy

Meeting with Pierfrancesco Maran (Member of the European Parliament, Shadow rapporteur) and Association des Constructeurs Européens d'Automobiles

10 Dec 2024 · End-of-Life Vehicles Regulation

Response to Evaluation of the Motor Vehicle Block Exemption Regulation

24 Jun 2024

In times of recurrent crisis and important pressure on households and public budgets, maintaining and even increasing the levels of competition for such an important budget line as road mobility would preserve the purchasing power, while not increasing public expenditure, making it an exceptionally cost-effective public policy. To this end, a robust upgrade of the Motor Vehicle Block Exemption Regulation (MVBER) regime would be fully in line with the European Commissions objectives. Against this background, ADPA welcomes the European Commissions intention to evaluate the MVBER and its accompanying Supplementary Guidelines. ADPA strongly believes that both market developments (based on technical changes and commercial practices) and enforcement experience mandate to maintain and to modernise the MVBER regime to make it even more efficient and more future-proof, also in line with the European Commissions objectives for better regulation. ADPA recommends in particular the following points regarding the scope of the evaluation of the MVBER regime: - The pivotal role of the MVBER (in conjunction with other European legislation) and its essential role for independent operators and consumers alike should be assessed; - While digitalisation is an important factor for competition today and tomorrow, the legacy items such as access to technical information, servicing of vehicles under warranty and trade in spare parts still deserve close monitoring; - Commercial and technical barriers to competition, resulting in particular from new trends such as digitalisation and electrification, should be taken into account; - Legal uncertainties and inadequate alignment resulting from the coexistence of different legislations should be identified, as well as potential remedies; - The international lighthouse effect of the MVBER should be taken into consideration. In terms of procedure, ADPA recommends that: - The public consultation should take place no earlier than the last quarter of 2024, and last at the very minimum 12 weeks; - National Competition Authorities should continue to be closely associated with the review process; - The European Parliament, in its consultative capacity and given the political importance of the matter, should also be associated. ADPA provides more explanation in the attached document.
Read full response

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Insurance Europe and

4 Jun 2024 · Discussion on preparation of delegated act on conditions to access data for repair and maintenance activities

Response to Guidelines on exclusionary abuses of dominance

24 Apr 2023

Rules on abuse of dominance should be as clear as possible to ensure their correct understanding and their proper enforcement. Meaningful application of the competition framework is essential to actually materialise consumer choice and competitive prices, and therefore to really benefit to European consumers, innovation, economy and society at large. The automotive repair and maintenance sector contributes to making road mobility more affordable for citizens, businesses and public authorities. Vehicle manufacturers and their networks on one side, and independent, multi-brand operators on the other side, are active in the automotive aftermarket. The competitive pressure exerted by the more than 500.000 independent operators (many of them SMEs) and their 4,3 million employees has led to a greater choice of competitive and innovative services and solutions, contributing to the safety, environmental performance and overall roadworthiness of the more than 320 million vehicles on European roads. Without this effective competition, consumers would be captive of brand-specific aftermarkets, facing high costs of ownership/operation as a consequence of the relatively long lifetime of vehicles. Considering the high initial investment made when purchasing a vehicle, consumers tend indeed to repair it more than other complex products. Such costs are also often not fully taken into consideration at the moment of the purchase. Competition from independent operators is therefore essential in ensuring consumer welfare. However, independent operators are not only competing with vehicle manufacturers and their networks. They are also dependent to them to access essential inputs, which include technical information and vehicle-generated data relevant for the repair and maintenance of vehicles, as defined in the MVBER. Access to them is often made extremely complicated for independent operators, in particular data publishers, due to the use by vehicle manufacturers of a wide range of commercial and technical restrictive measures. Rightly, the amended Supplementary Guidelines to the MVBER state that Article 102 TFEU may be applicable where a vehicle manufacturer withholds from independent operators (including data publishers) such essential inputs. Indeed, data publishers play a critical role in the aftermarket value chain. Preventing them from performing their job has therefore a negative impact on competition in the automotive aftermarket. As independent operators (especially data publishers who commit to source their technical information to the vehicle manufacturers) are dependent on the vehicle manufacturers, they are often reluctant to take action to enforce their rights. Coupled to the fact that most independent operator are SMEs, it results in them suffering from a fundamental imbalance when negotiating with vehicle manufacturers, beyond the dominance inherent to 102 TFEU issues. When independent operators have tried to enforce their rights, the cases brought to the authorities have regularly been considered to have to little market relevance and have been dismissed. Not only did it result in a general lack of enforcement, but it ignored the bigger picture of the multitude of cases, sometimes similar, brought to various jurisdictions and showing the repeated challenges to competition in the automotive aftermarket. The European Competition Network might have here a role to play. The market would benefit from guidance on enforcement policy in individual cases, both in relation to content and process, to minimise the enforcement problems experienced by independent operators. In individual cases, Guidelines should create more legal certainty, in particular related to outright refusals and constructive refusals to supply essential inputs. In order to support the objective of vigorous enforcement, guidance on the (increased) use of interim measures and commitment decisions with the need to involve stakeholders, should be provided.
Read full response

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean) and Fédération Internationale de l'Automobile and

16 Jan 2023 · Data Act Regulation and Specific legislation on ‘Access to in-vehicle data & functions’

Response to Review of the Supplementary Guidelines to the Motor Vehicle Block Exemption

30 Sept 2022

In times of recurrent crisis and important pressure on households’ and public budgets, maintaining and even increasing the levels of competition for such an important budget line as road mobility would preserve the purchasing power, while not increasing public expenditure, making it an exceptionally cost-effective public policy. To this end, a robust upgrade of the Motor Vehicle Block Exemption Regulation (MVBER) regime would be fully in line with the European Commission’s objectives, as announced by Executive Vice-President Margrethe Vestager: “Whatever the cause, we must act urgently to protect purchasing power by ensuring that markets continue functioning in spite of these challenges. This is the Commission's highest priority right now.” (Keynote speech by EVP Vestager at the BEUC conference on consumer protection in the digital age, 27 September 2022) Against this background, ADPA welcomes the European Commission’s intention to prolong the MVBER regime for 5 years and to update its accompanying Supplementary Guidelines to take into consideration technical progress. However, ADPA strongly believes that both market developments (based on technical changes and commercial practices) and enforcement experience mandate more extensive amendments to the Supplementary Guidelines. A more comprehensive update of the current rules would make the new regime more efficient and more future-proof, also in line with the European Commission’s objectives for better regulation. ADPA suggests in particular to significantly improve all provisions related directly or indirectly to the access of independent operators to technical information, which is a crucial element for a competitive aftermarket. In particular, the restrictive use of inappropriate benchmarks and the increasing scarcity of granular technical information should urgently be addressed to enable the whole independent aftermarket ecosystem to perform its job and to exert competitive pressure. ADPA also fully supports any additional measures which would improve access to spare parts, tools and trainings, avoid the misuse of warranties, and facilitate enforcement.
Read full response

Response to Type approval of motor vehicles regarding access to in-vehicle generated data

2 Aug 2022

ADPA, whose Members provide essential information for a vast majority of European workshops, warmly welcomes the initiative to legislate on the crucial issue of access to in-vehicle data, functions and resources. After careful consideration of the various Policy Options at hand, ADPA considers that only Policy Option 3 would fully release the automotive ecosystem’s digital potential and support EU’s political objectives. The independent operators, whose value chain in the EU accounts for over 4.5 million jobs and 500.000 companies (many of them SMEs), are essential for the servicing, repairing and maintaining of the 340 million vehicles on European roads, ensuring their safety and environmental performance over their lifetime. They are in direct competition with vehicle manufacturers for the provision of related services and products. As mobility becomes increasingly digitalised, access rights to in-vehicle data, functions and resources are essential to ensure equal opportunities for them to develop and market competitive and innovative solutions, offering a true choice to consumers. The Data Act, as it stands, includes useful provisions but still lets significant room for divergent interpretation in the automotive sector. Without a sector-specific legislation translating its general principles into concrete measures, legal uncertainty would remain high, hereby limiting innovation and competition. In order to perform their job in the digital era, independent operators need: - Non-discriminatory access to the in-vehicle data and resources which are technically available (as opposed to what is used by vehicle manufacturers or their partners, or what they choose to make available to their competitors. - An accompanying set of harmonised rules, as suggested by Policy Option 3, to avoid the creation of artificial barriers undermining the intent of the legislation. - In-vehicle access, with the ability to process data at the edge, when available for vehicle manufacturers or their partners. - Access to the dashboard or the human-machine interface, in order to safely interact with the consumers. - Direct management of the consent of consumers, without interposition of the vehicle manufacturers or their partners. - A mandatory, standardised set of data and functions as an initial step towards full access to the full extent of accessible data and functions, enabling independent operators to develop and market scalable multibrand solutions, and the European Union to take the regulatory lead and preserve European businesses’ interests, instead of letting hyperscalers take advantage of their position as platform providers to reinforce their commercial dominance. - Access to the OBD port, as an essential component for many servicing operations. - A dynamic governance framework, enabling the legislation to be updated and upgraded in a reactive manner depending on technological and commercial developments. Over the years, several studies have demonstrated that independent operators need such conditions. Most recently: - A study by Knobloch & Gröhn shows that the above-described technology-neutral requirements can be implemented, based on the capabilities of connected vehicles; these are rapidly evolving into software-defined vehicles, with increasing deployment of applications platforms enabling real time, on-board access to data, functions and resources. - A quantitative analysis conducted by Wolk Aftermarket Experts of the impact of the various Policy Options shows that only Policy Option 3 results in a lower cost for repair and maintenance for vehicle owners. It could lead to a reduction in the average annual cost of maintenance per vehicle of €200. If no legislative action is taken (i.e. if Policy Option 0 is chosen), it forecasts excess costs of €43 billion annually for vehicle owners and 23,000 fewer independent multi-brand workshops (most of them SMEs) by 2030 for the 7 European markets analysed, which represent 70% of the EU.
Read full response

Meeting with Thierry Breton (Commissioner) and

16 Jun 2022 · Data Act ; in-vehicle data

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Insurance Europe and

10 Jun 2022 · Prep meeting for meeting with Commissioner Breton on 16/6

Meeting with Thierry Breton (Commissioner) and

27 Oct 2021 · Data

Response to Evaluation of the Motor Vehicle Block Exemption Regulation

19 Mar 2019

ADPA, the European Association of Independent Automotive Data Publishers, confirms the important role of the sector specific rules for maintenance and repair services. The Motor Vehicle Block Exemption Regulation (MVBER) and the Guidelines provided in practice protection against a number of distortions. Independent automotive data publishers are an important supplier of standardised multi-brand technical information for all independent operators, allowing them to compete in an efficient manner with the authorised networks. The Supplementary Guidelines (point 62) give an important description of ‘technical information’ and ‘independent operators’. ADPA Members have been relying since 2010 on this set of rules for accessing technical information, and they are a crucial basis allowing the automotive aftermarket ecosystem to offer competitive choice. For the Evaluation Roadmap, ADPA strongly suggests to pay particular attention to the specific situation of SMEs being the backbone of the automotive aftermarket and the European economy, often with very limited financial and legal resources to defend themselves against large market players. Genuine independent SME entrepreneurship is a special feature of Europe’s economic structure and guarantor for innovation, competition and consumer welfare. This should be considered when assessing the MVBER. The competitiveness of the aftermarket SMEs depends in large part on their ability to technical information. Independent repairers rely on a competitive independent multi-brand supply chain, which in turn rely on inputs from vehicle manufacturers. ADPA Members contribute directly to the efficiency of the aftermarket value chain by providing independent operators with standardised repair information, transforming the proprietary vehicle manufacturers’ ‘Repair and Maintenance’ systems into multi-brand products for easy practical use. Therefore we invite the Commission to include the competitive position of the many independent multi-brand operators along the supply chain in a more comprehensive way. The focus in the Roadmap and the qualitative/quantitative Study on the repair level is too restricted and does not capture the influence of the MVBER on the entire after-sales market and its competitive eco-systems. The complexity of the motor vehicle (aftermarket) sector and the nature of the respective economic activities should be taken into account as to allow for a better illustration of the different competitive conditions at each level of the supply chain. In a 5-10 years perspective, there will still be a “MVBER legacy vehicle park” with the need for maintenance, repair and spare parts and a vertically structured market requiring rules based on vertical restraints to ensure competition to the benefit of consumers. At the same time it is necessary to acknowledge that the motor vehicle is becoming more complex than ever before, and this brings more technically advanced abilities to prevent, restrict and distort competition which should be captured by a “MVBER 2.0”. Against this background it is important to note that there were a number of inefficiencies. For example, there were instances where it was still a problem to get from vehicle manufacturers datasets of technical information which are accurate, complete and up-to-date. This technical information is crucial for data publishers to be able to put on the market reliable, multi-brand services and if not received, this impacts negatively the ability to propose products and services enabling independent operators to compete with the authorised networks on an equal footing.
Read full response