Asociación Española de Fabricantes de Remolques, Semirremolques, Cisternas y Vehículos Análogos
ASFARES
Representar y defender intereses comunes de los fabricantes españoles de remolques, semirremolques y carrocerías.
ID: 922490646675-25
Lobbying Activity
Response to Review of the CO2 emission standards for heavy-duty vehicles
19 May 2023
We appreciate the opportunity to participate in the proposed regulation. We share the project for the progressive reduction of the contribution of trailers and semi-trailers to emissions in combination with motor vehicles. However, the details of the proposal can be improved to adapt them to the reality of the sector in the following points. 1. Setting a target of -15% for semi-trailers is excessive, because the calculations in VECTO Trailer tool under the most favorable conditions and available options do not come close to those reduction levels. 2. There are no data on the average emissions of the current fleet that serve as a reference to know the specific reduction objective, so it is difficult to develop an adequate research program. 3. Setting generic objectives to semi-trailers does not take into account the variety of types and their real limit of improvement. Different values would be needed for each subgroup and there are not enough data to establish them at this time. 4. There is no gradual approach that allows progressive steps towards the objectives to reassess the evolution of the trailers. The reduction goal should have stages every five years. 5. The VECTO Trailer tool is still in trial period. It does not incorporate many emission reduction technologies and there is not much experience to evaluate the results set from actual trailers. 6. The emission network in modular configurations is not taken into account. Nor are those prepared for intermodality and the electrical traction axle need for changes in some regulations that allow its use. 7. There is a proposal to amend a directive to include trailers emissions in the calculation of tolls, that does not require the establishment of bonuses for lower emissions until the second half of 2030, so the emission reduction targets of carriers may not be synchronized with those of the manufacturers. For all these reasons, we support the CLCCR position. that proposes setting a 5% CO2 reduction target for all trailers in 2035, based on the potential that can currently be considered in VECTO for TRAILER, and increasing this target for individual trailer groups to 7.5% in 2040. It is also needed to include the effect of modular vehicle combinations and vehicles for intermodal transport. Finally, we propose a reduction in fines under Article 8, depending on net prices for trailers.
Read full responseResponse to Transitional measures for smart tachograph 2 regarding its use of OSNMA
7 Mar 2023
ASFARES, the Spanish Association of the Body and Trailer Building Industry, supports ACEA, CECRA and CLCCR joint position. Our belief is that the draft Commission proposal raises serious risks to both European bodybuilders and vehicle manufacturers by way of excessive retrofitting costs, and through a lack of lead time that may result in quality and reliability concerns. While the G2V2 (and transitional tachographs) remain unavailable, the number of incomplete vehicles produced and held in stock throughout Europe continues to rise every week, increasing the risk that retrofitting will be needed to replace older G2V1 tachographs (including their motion sensor) with transitional G2V2 tachographs (and new motion sensors), if those vehicles are not sold and registered by 21st August 2023. ASFARES believes that a delay can be justified by the fact that the current initiative regarding the Smart tachographs version 2 transitional measures regarding use of OSNMA is a legal addition to Commission Implementing Regulation (EU) 2021/1228, and is not only an amendment to Implementing Regulation (EU) 2016/799. So, it would need a new entry into force date and it would lead to change the date of application for newly registered vehicles from 21st August 2023 to more than two years after.
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