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Alliance of European Car Dealers and Repairers

AECDR

Representation of the interests of authorised car dealers and repairers in Europe.

Lobbying Activity

Response to Revision of the CO2 emission standards for cars and vans

25 Sept 2025

Attached the Feedback of the Alliane of European Car Dealers and Repairers
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Response to Sustainable transport investment plan

3 Sept 2025

AECDR welcomes the Commissions initiative to present a Sustainable Transport Investment Plan (STIP). The need to close the persistent investment gap in sustainable mobility is urgent, not only to reach the Unions climate targets but also to strengthen the competitiveness and resilience of Europes industry. Technological neutrality It is essential that investments under the STIP remain technologically neutral. The decarbonisation of transport will require multiple solutions including battery-electric, hydrogen, renewable and low-carbon fuels, and future technologies still in development. Prioritising one technology risks lock-in and undermines innovation. A neutral approach will enable car dealers, repairers, and the wider mobility ecosystem to adapt and provide customers with the solutions that best fit their needs. Lessons from AFIR The Alternative Fuels Infrastructure Regulation (AFIR) has not delivered its full potential. Despite progress, insufficient ambition in terms of infrastructure deployment has slowed customer confidence and uptake of zero-emission vehicles. This demonstrates that without stronger targets, consistent investment, and clear market signals, infrastructure roll-out lags behind vehicle adoption. The STIP must therefore set a higher level of ambition than AFIR and ensure that financial and regulatory tools are adequate to trigger large-scale investment. Closing the investment gap for zero-emission mobility From the perspective of car dealers and repairers, the greatest barrier to customer adoption of zero-emission vehicles is hesitation linked to the availability and reliability of charging and refueling infrastructure. The STIP can play a decisive role in overcoming this barrier by creating the conditions for massive infrastructure deployment and reducing the risks associated with private investment. This will give dealers and repairers the confidence to recommend zero-emission solutions, and customers the assurance that switching is practical, reliable, and future-proof. Conclusion The Sustainable Transport Investment Plan is a timely and necessary initiative. By ensuring technological neutrality and addressing the shortcomings of AFIR, it has the potential to close the investment gap, accelerate the deployment of alternative fuels infrastructure, and empower Europes mobility sector to achieve climate targets while maintaining industrial competitiveness.
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Response to Clean corporate vehicles

1 Sept 2025

Promoting the ecologic transition of Automotive sector is a primary objective of the Alliance of European Car Dealers and Repairers (AECDR). In this framework, AECDR deems the EC's stated strategic objective of the proposed Corporate Fleet Regulation, namely that the enforced deployment of BEVs in corporate fleets is aimed at achieving decarbonisation targets, as misleading. All truly independent industry studies highlight that in the Well-to-Wheel and Life Cycle Assessment CO2 emissions calculation cycles the contribution of BEVs to decarbonisation is very partial. AECDR welcomes all measures promoting the decarbonisation process of Automotive sector namely the corporate fleets - according to a technology neutral approach. The haulage and logistic system and the passenger transport need to optimize all technologies decarbonizing the transport system, not only electric mobility, but also all renewable fuels, in particular Biofuels, Biomethane, BioLNG, E-fuels, hydrogen. Relating to the goal to foster the market of second-hand BEV, AECDR underlines that when used for long distances as is the case with corporate fleets the depreciation is even more significant, primarily due to: High obsolescence due to the rapid launch of new products and technologies Risk of battery pack deterioration Lack of a used EV market in most European countries, completely non-existent for trucks Any coercive measure that fails to take into account current market dynamics has the immediate effect of depressing demand. In the LDV corporate fleet sector, the expected effectcompared to favorable tax measures for BEVs and penalizing taxation for ICEVsis a unilateral change in corporate policies regarding corporate vehicles, severely penalizing workers. In the HDV haulage fleets, the expected effect is the loss of business competitiveness, due to the very high investment cost and the poor operating performance of the electric trucks. The most effective incentive measures are those that aim to reward the technological renewal of the fleet according to a "technological neutrality" perspective, leaving the choice of vehicle type to the company and the employee based on their actual professional needs.
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Meeting with Gabriele Bischoff (Member of the European Parliament)

2 Apr 2025 · Austausch

Response to Evaluation of the Motor Vehicle Block Exemption Regulation

24 Jun 2024

The Motor Vehicle Block Exemption Regulation plays a central role in maintaining a competitive, consumer-friendly and innovative motor vehicle industry in the EU. It contains important provisions for the motor vehicle sector which, for example, permit the branding of components by suppliers, allow workshops access to parts and prevent OEMs from unilaterally restricting the sale of spare parts to the aftermarket. AECDR welcomes this objective because it is an essential basis for the competitiveness of automotive repairers and recommends that these regulations be maintained and updated beyond 2028 in order to maintain a competitive aftermarket ecosystem and ensure affordable mobility for citizens and businesses in the EU. The MVBER therefore contributes to a balanced market environment that benefits both industry players and consumers. Main effects of the MVBER 1. competition The MVBER promotes competition in the motor vehicle sector by giving garages access to spare parts and technical information. This access helps to prevent monopolistic practices by vehicle manufacturers and to promote a competitive market environment. 2. freedom of choice for consumers By ensuring that consumers have a choice of service providers and spare parts, the MVBER will lead to more competition in the motor trade and potentially lower prices for consumers. 3. innovation Access to key inputs such as tools, training and technical information encourages innovation. Repairers can keep pace with technological advances and offer services that meet the changing needs of consumers. 4. sustainability of the aftermarket The MVBER supports the sustainability of the aftermarket ecosystem. Repairers, even within the same brand, can more easily compete for maintenance and repair contracts through access to OEM parts and information, significantly improving consumer choice (particularly of aftermarket services) and potentially leading to lower prices for the consumer. 5. legal certainty In the opinion of AECDR, the clear guidelines and rules of the MVBER ensure legal certainty and compliance with competition rules for the companies involved. In the opinion of AECDR, legal disputes are largely avoided by these clear rules and guidelines. Possible effects of the expiry of the MVBER 1. competition on the market In the opinion of AECDR, an expiry of the MVBER would have the consequence that manufacturers could control competition unilaterally, e.g. by making access to spare parts and technical information more difficult. This could lead to monopolistic practices and a less competitive market environment. 2 Innovation and technological development The MVBER concerns access to vehicle-generated data and updates for advanced systems such as ADAS and electric vehicle components. In the age of the software-defined vehicle (SDV) and in the global market for automotive software, this access to the necessary information and tools must also be guaranteed for all actors in the automotive supply chain in order to be able to compete fairly with manufacturers, in particular through access to data provided by software solutions and the possibility of updates to be carried out. An expiry of the MVBER could lead to monopolistic practices by vehicle manufacturers in such a way that, for example, the individual controls of the vehicle components integrated into their central systems are controlled by software solutions developed by them and access to these software solutions could be made more difficult or even prevented. Political demands and recommendations AECDR welcomes the ongoing safeguarding of a competitive automotive aftermarket in the EU for the benefit of consumers. To this end, the European Commission should emphasise the importance of effective access to essential inputs for aftermarket operators such as tools, training, technical information and vehicle-generated data. We are in favour of maintaining and updating the MVBER beyond 2028 to meet the challenges pose
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Meeting with Susana Solís Pérez (Member of the European Parliament)

6 Dec 2023 · the future of mobility in Europe

Response to Review of the EU rules on Motor Vehicle Block Exemption

28 Sept 2022

AECDR acknowledges the European Commission’s proposal to prolong the duration of the MVBER (Reg 461/2010) for five years. While this – together with some potential changes to the Supplementary Guidelines - provides a degree of legal certainty in challenging times, AECDR remains concerned that the narrow (aftersales-only) focus of this proposal will miss the more fundamental threat to competition that is rapidly materialising as a result of the complete transformation process currently affecting the automotive industry in Europe. In July 2022, the Commission published for public feedback a draft Regulation extending the period of validity of Regulation 461/2010, together with a draft Communication amending the Commission Notice containing the Supplementary Guidelines. These two drafts reflect the changes that the Commission proposes to implement following its evaluation of the MVBER regime, the findings of which are set out in the Commission’s Evaluation Report, together with the Commission Staff Working Document, both published on 28 May 2021. The Commission’s evaluation, which concluded on 28 May 2021, showed – according to the Commission - that the MVBER regime had been useful and remained relevant for stakeholders. The evaluation, or the Commission’s reporting of it, also observed that while automotive markets were likely to evolve in the coming years, there had been no material developments in the last decade that would justify a major revision of the MVBER regime (other than an update to reflect the importance that access to vehicle-generated data was likely to have on competition). In AECDR’s view, the Commission’s evaluation is flawed; it demonstrates a reluctance to act decisively and, as far as vehicle sales are concerned (which is a critical issue that the proposals avoid entirely), is based on out-of-date evidence/intelligence that does not reflect current market developments. The fact-finding study that the Commission conducted for the period 2007 to 2017 is not fit for purpose in light of the significant changes – for example ongoing OEM consolidation and the transition to direct distribution and agency models (genuine and pretend) - experienced in the automotive sector since then. Put simply, without prejudice to the efficacy of the MVBER in offering some certainty in respect of its limited scope, simply prolonging and tweaking it fails to address the wider and imminent harms that the sector - or, rather, customers of the sector and European consumers - will experience in the near future. It follows that other measures are required to guard against the use of excessively restrictive distribution models (e.g. non-genuine agency models) to limit competition on price and other parameters, and to reinforce the competitive independence of dealers and repairers that have previously ensured that consumers benefit from a highly competitive automotive market. AECDR would be happy to engage further with the Commission on this issue before competition in the sector is compromised on a permanent basis to the detriment of businesses, employees and consumers at the retail level. Without prejudice to the general observations set out above, AECDR comments on specific aspects of the Commission's draft proposals published on July 6, 2022 in the attached document.
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Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

Dear Sir or Madam, Thank you very much for the opportunity to provide feedback. Please find enclosed our position paper with regard to sustainable finance. Kind regards, Alliance of European Car Dealers (AECDR)
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