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Association des Constructeurs Européens d'Automobiles

ACEA

ACEA is a professional association representing the interests of major European automobile manufacturers.

Lobbying Activity

Meeting with Edoardo Turano (Head of Unit Climate Action)

16 Jan 2026 · Cars and vans CO2 review proposal

Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra)

18 Dec 2025 · Automotive package

Meeting with Sophie Moonen (Head of Unit Competition)

11 Dec 2025 · Revision of the Technology Transfer Block Exemption Regulation (TTBER) and the accompanying Guidelines

Response to Updates in the Whole Vehicle Type Approval as regards Euro 7 and the list of alternative UN Regulations

10 Dec 2025

ACEA appreciates the opportunity to provide input to this consultation. Our feedback focuses on EU2018/858 Annex II specifically on the need to correct and align vehicle category definitions within the Euro 7 LDV regulations. Accurate categorisation is essential to ensure legal clarity, appropriate technical requirements, and consistent application across the EU market. ACEA feedback can be found in the document attached
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Meeting with András Gyürk (Member of the European Parliament)

10 Dec 2025 · Informal Exchange of Views with ACEA on the Automotive Package

Meeting with Pascale Piera (Member of the European Parliament)

10 Dec 2025 · Paquet automobile

Meeting with Antonín Staněk (Member of the European Parliament)

10 Dec 2025 · Automotive package

Meeting with Miguel Gil Tertre (Cabinet of Executive Vice-President Teresa Ribera Rodríguez), Terhi Lehtonen (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

3 Dec 2025 · Automotive Package

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

2 Dec 2025

The European Automobile Manufacturers Association (ACEA) welcomes the European Commissions proposal to amend Regulation 2018/858 by means of a delegated act on secure access to on-board diagnosis (OBD) and repair and maintenance information (RMI). This amendment is necessary to solve an existing conflict between the current type-approval framework Regulation 2018/858 and UN ECE Regulations 155 and 156 on cybersecurity and software updates respectively and helps to update the current rules to technical progress. ACEA suggests making additional amendments to the Commissions proposal to solve another conflict between the current type-approval framework Regulation 2018/858 and the proposed Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles (ELV Regulation). Please find our detailed comments and suggestions in the attached paper.
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Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič)

28 Nov 2025 · European automotive industry perspectives

Meeting with Markus Ferber (Member of the European Parliament)

26 Nov 2025 · Automotive Package

Meeting with François Kalfon (Member of the European Parliament) and RENAULT and

26 Nov 2025 · Paquet automobile

Meeting with Jens Gieseke (Member of the European Parliament) and European Community Shipowners' Associations

26 Nov 2025 · Austausch zu EU-Verkehrspolitik

Meeting with Elisabetta Gualmini (Member of the European Parliament) and ENEL SpA and Hydrogen Europe

26 Nov 2025 · ITRE Committee

Meeting with Andi Cristea (Member of the European Parliament)

26 Nov 2025 · Enhancing Europe’s automotive industrial competitiveness

Meeting with Rosa Serrano Sierra (Member of the European Parliament)

25 Nov 2025 · Decarbonisation of Transport

Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

17 Nov 2025 · 1)Small Affordable Cars initiative, 2) vehicle noise

Meeting with Silvia Bartolini (Cabinet of Executive Vice-President Henna Virkkunen)

14 Nov 2025 · Automotive package and ECAVA

Meeting with Mohammed Chahim (Member of the European Parliament)

13 Nov 2025 · Social Leasing EV's

Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis)

6 Nov 2025 · Simplification

Meeting with Elena Kountoura (Member of the European Parliament, Shadow rapporteur)

6 Nov 2025 · Meeting with ACEA representatives

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and Volvo AB and

5 Nov 2025 · Discussion on EU content requirement for heavy-duty vehicles (HDVs) in view of the upcoming Industrial Accelerator Act

Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and Volvo AB and

5 Nov 2025 · Discussion on EU content requirement for heavy-duty vehicles (HDVs) in view of the upcoming Industrial Accelerator Act

Meeting with Simone Ritzek-Seidl (Cabinet of Commissioner Apostolos Tzitzikostas)

5 Nov 2025 · ACEA input on CO2 Regulation and upcoming Corporate Fleet proposal

Meeting with Stéphane Séjourné (Executive Vice-President) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM.

Meeting with Maroš Šefčovič (Commissioner) and

28 Oct 2025 · EU-India trade relations

Meeting with Wopke Hoekstra (Commissioner) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM

Meeting with Edoardo Turano (Head of Unit Climate Action)

22 Oct 2025 · Open public consultation on the CO2 standards for light duty vehicles

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné), Joan Canton (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs), Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and

20 Oct 2025 · Made in Europe requirements Small affordable cars initiative

Meeting with Alexandra Mehnert (Member of the European Parliament, Shadow rapporteur)

15 Oct 2025 · Roadworthiness Package

European Carmakers Urge AI Exemptions and Simpler Digital Laws

14 Oct 2025
Topic — The Commission's Digital Omnibus Package aims to simplify digital regulations to provide business relief.
Message — ACEA requests aligning all data laws with the Data Act and exempting vehicles from AI rules. They also seek a single cybersecurity reporting platform and a twenty-four-month delay for high-risk AI.123
Why — Consolidating these rules would lower compliance costs and free up resources for technical innovation.4
Impact — Mid-sized companies lose potential benefits because ACEA opposes extending small-business exemptions to larger mid-caps.5
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Meeting with Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič) and European Association Automotive Suppliers and

8 Oct 2025 · US and EU Trade Relations concerning tariff rates on the European heavy-duty vehicles sector

Meeting with Viktória Ferenc (Member of the European Parliament)

2 Oct 2025 · Introduction, exchange of views

Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs), Stefan Fuehring (Head of Unit Secretariat-General)

30 Sept 2025 · Simplification, Small Cars Initiative

European Automakers Seek Simplified CBAM Compliance for Vehicle Manufacturing

25 Sept 2025
Topic — Certification rules for converting carbon prices paid abroad into CBAM certificates.
Message — ACEA wants flexibility maintained to use default emission values instead of actual data, without being obliged to seek actual figures first. They request simplified recognition of carbon prices already paid in third countries, with the Commission publishing standard values for foreign carbon prices.123
Why — This would avoid the practical impossibility of tracking actual emissions across their supply chains.4
Impact — Climate integrity weakens as automakers avoid detailed emissions tracking for imported components.5
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Meeting with Edoardo Turano (Head of Unit Climate Action)

25 Sept 2025 · HDV Task Force meeting

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné)

24 Sept 2025 · Automotive

Meeting with Edoardo Turano (Head of Unit Climate Action)

17 Sept 2025 · Upcoming meeting on HDV

Meeting with Silvia Bartolini (Cabinet of Executive Vice-President Henna Virkkunen)

8 Sept 2025 · Implementation of Automotive Action Plan and Automotive Dialogue

Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič)

8 Sept 2025 · Various matters relevant for the EU automotive sector.

Response to Clean corporate vehicles

5 Sept 2025

ACEA views on greening fleets both for light-duty as well as heavy-duty vehicles in attached document.
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Meeting with Kurt Vandenberghe (Director-General Climate Action)

3 Sept 2025 · Clean mobility

Meeting with Mechthild Woersdoerfer (Deputy Director-General Energy)

2 Sept 2025 · Energy legislation and policy / automative industry

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

25 Aug 2025 · preparation of the next meeting of the Strategic Dialogue on the Future of the Automotive Industry on 12 September

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

25 Aug 2025 · to follow

European carmakers urge full digitalization of battery information

1 Aug 2025
Topic — The consultation addresses updating product legislation to reduce administrative burdens through digitalization.
Message — The group calls for removing numerous articles requiring printed labels, stickers, and packaging markings. They propose strengthening the Battery Passport to serve as the central digital information hub.12
Why — A digital shift would eliminate outdated physical obligations that are inefficient and environmentally burdensome.34
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Carmakers oppose expanded roadworthiness testing requirements

25 Jul 2025
Topic — EU proposal to expand periodic vehicle inspections and data sharing requirements.
Message — The organization requests limiting data sharing requirements, avoiding new software checks, restricting noise measurements to visual inspection, and exempting older vehicles from electronic system tests. They argue current PTI operators don't use existing manufacturer data and that technical defects cause less than 1% of fatal accidents.1234
Why — This would avoid significant data compilation costs and reduce testing requirements for their vehicles.56
Impact — Road safety advocates lose stricter vehicle checks that could identify defects and fraud.7
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European automakers urge exclusion of vehicles from critical raw materials recovery regulation

25 Jul 2025
Topic — EU regulation listing products requiring critical raw materials recovery under new circular economy rules.
Message — The association requests that motor vehicles and batteries be excluded from the new regulation's scope. They argue existing sector-specific rules already provide comprehensive frameworks for circularity and critical raw material recovery in automotive.12
Why — This would avoid duplicate compliance obligations and preserve unified rules across EU markets.34
Impact — Environmental groups lose stronger enforcement mechanisms for critical material recovery from end-of-life vehicles.5
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Meeting with Michael Hager (Cabinet of Commissioner Valdis Dombrovskis), Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

23 Jul 2025 · Competitiveness Simplification agenda

European car industry backs battery due diligence delay

22 Jul 2025
Topic — EU regulation requiring manufacturers to implement due diligence for battery supply chains.
Message — ACEA supports postponing due diligence requirements but urges swift establishment of enabling conditions. The industry needs designation of notified bodies, comprehensive implementation guidelines, and legal certainty on reporting obligations before requirements take effect.123
Why — This gives manufacturers time to prepare and reduces risk of non-compliance.45
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Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

22 Jul 2025 · Challenges of EU automotive manufacturers in China

Meeting with Apostolos Tzitzikostas (Commissioner) and

17 Jul 2025 · Exchange on situation of automotive sector

Meeting with Apostolos Tzitzikostas (Commissioner) and

17 Jul 2025 · Corporate Fleets strategic dialogue

Auto Industry Demands Data Law Moratorium and Simplification

11 Jul 2025
Topic — EU strategy to streamline data sharing rules for AI development and cross-border flows.
Message — The organization requests a moratorium on new data access requirements and comprehensive review of existing legislation. They want all future data laws aligned with the Data Act to reduce fragmentation across over 20 conflicting EU laws governing connected vehicles.123
Why — This would reduce regulatory complexity and free resources currently diverted to compliance.45
Impact — Consumer groups lose potential new protections as manufacturers avoid additional data obligations.6
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Meeting with Maroš Šefčovič (Commissioner) and

11 Jul 2025 · Implementation dialogue on customs legislation - Rules of origin

Meeting with François Kalfon (Member of the European Parliament, Shadow rapporteur)

9 Jul 2025 · Décarbonation des transports

European automakers warn against local content requirements in decarbonization plans

8 Jul 2025
Topic — EU regulation to accelerate industrial decarbonization and create markets for low-carbon products.
Message — The organization requests gradual implementation with sufficient lead times, arguing that automotive supply chains are complex and global. They advocate for incentives over mandates and want careful consideration of how third-country production counts toward EU content. Different vehicle segments should receive differentiated treatment.1234
Why — This would avoid disruption to global supply chains and prevent increased manufacturing costs.56
Impact — European battery manufacturers lose protection from foreign competition and market development support.7
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Meeting with Rachel Blom (Member of the European Parliament, Shadow rapporteur)

8 Jul 2025 · Position Roadworthiness package + introductory meeting

Meeting with Alexandra Mehnert (Member of the European Parliament)

8 Jul 2025 · Roadworthiness Package

Meeting with Edoardo Turano (Head of Unit Climate Action)

8 Jul 2025 · E20 and FQD

European Auto Industry Demands EU Cloud Infrastructure Expansion

2 Jul 2025
Topic — New EU regulation on developing cloud and AI infrastructure capacity.
Message — The association requests an EU-wide policy framework with harmonised national strategies to expand cloud and AI infrastructure. They seek greater computing capacity, low-latency edge computing, and green data centres. This unified approach would reduce fragmentation and enable cross-border collaboration.1234
Why — This would reduce their dependence on non-EU providers and lower infrastructure costs.56
Impact — Non-European cloud providers lose market share to expanded EU-based infrastructure capacity.78
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Meeting with Stéphane Séjourné (Executive Vice-President) and

2 Jul 2025 · EU Clean Industrial Dialogue on Circularity

Meeting with Joan Canton (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

26 Jun 2025 · Exchange on the preparation of the Industrial Decarbonisation Accelerator Act in relation to the automotive industry

Meeting with Stéphane Séjourné (Executive Vice-President) and

25 Jun 2025 · Automotive Action Plan / TRADE

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and European Association Automotive Suppliers

25 Jun 2025 · Automotive

Meeting with Paolo Garzotti (Head of Unit Trade)

17 Jun 2025 · Meeting between DG TRADE and ACEA to prepare for the INTA hearing on the EU-Mercosur Agreement.

Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

10 Jun 2025 · Technical regulations for motor vehicles

European Auto Industry Seeks Open-Source AI Priority and Regulatory Relief

3 Jun 2025
Topic — EU strategy to boost AI adoption in strategic sectors and public services.
Message — The association requests minimal restrictions on open-source AI and preference for it in public projects. They seek exemptions from AI Act provider requirements for companies using open-source models commercially. They want automotive exempted from high-risk AI rules and a two-year extension for compliance timelines.12345
Why — This would reduce their AI development and compliance costs while maintaining market position.678
Impact — Consumer safety advocates lose stronger AI oversight in vehicles and autonomous systems.910
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Meeting with Mariella Masselink (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs), Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

28 May 2025 · Choose Europe agenda, and the Industrial Decarbonisation Accelerator Act

Meeting with Bjoern Juretzki (Head of Unit Communications Networks, Content and Technology)

27 May 2025 · Discussion about ACEA’s contribution to the ongoing work on the Guidance document related to in-vehicle data

Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič), Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič)

21 May 2025 · Relationship with the US and impact on automobile sector China

Meeting with Paul Speight (Head of Unit Environment)

21 May 2025 · ACEA TF REACH Meeting

Meeting with Eva Valle Lagares (Head of Unit Trade)

14 May 2025 · Discussion of developments in China's export control, data, and investment

Response to Methods, requirements and tests for type-approval of OBFCM devices, OBD and OBM systems of M1 and N1 vehicles and EVP

13 May 2025

The European Commission (DG GROW) has published its proposals for the first package of Euro 7 implementing acts for the type-approval of light-duty vehicles (cars and vans), which are due to be adopted by 29 May 2025 according to Article 14(8) of Regulation (EU) 2024/1257. ACEA has made a full and comprehensive review of the proposals in this public consultation, presented as justified amendments to the Commission proposals, and supplemented by additional documents to bring the necessary and comprehensive clarity. The deadline to adoption by 29 May 2025 is very tight, but the proposed implementing acts still require necessary amendment to provide robustness, clarity and proportionality for all involved stakeholders, i.e. manufacturers who must use these proposals to develop and homologate all future new vehicles they will produce in compliance with Euro 7, and type-approval authorities and technical services who must consistently and uniformly apply Euro 7. Ensuring clarity and robustness is critical now. In an already packed development and homologation schedule, manufacturers do not want to face a burden of re-approving due to amendments needed to repair that would come later in a second package of implementing acts. In these proposals for the Mia and the SIA, there are many areas that require attention before ACEA would see this as being ready for adoption. We therefore urge the European Commission, in completing these proposals with short delay, to carefully review and integrate all of the justified ACEA proposals which we propose in the interests of clarity and robustness, for all involved stakeholders who must deal with Euro 7. Of course, the proposals in this public consultation are only the first package. A second package is necessary to address issues such as brakes (applicable to all vehicle types requiring Euro 7 type-approval) and battery performance (applicable to all electrically chargeable vehicle types requiring Euro 7 type-approval). Industry has requested the European Commission adopt the second package by 1 January 2026, so that manufacturers would know all the technical regulatory elements of Euro 7 to give them reasonable chance to plan and gain Euro 7 type-approval for every single vehicle type they plan to place into the EU market before 29 November 2027. We still do not know when the second package will be adopted, but we are concerned it could be as late as Q2 2026. That would give manufacturers less than 18 months to ensure compliance and type-approve their complete portfolio to Euro 7, a massive challenge for manufacturers, but also for EU approval authorities who will be swamped with requests from vehicle manufacturers all demanding Euro 7 type-approvals in a relatively short space of time; We recall the problems in years 2017/18 when WLTP and RDE applied as new type-approval requirements. Newly produced vehicles were stored in fields and at airports because type-approval certificates could not be delivered on time to meet manufacturers model update/release plans. ACEA therefore requests that this first package is completed as soon as possible without sacrificing clarity, robustness and proportionality and urge the European Commission to make progress as soon as possible on the second package for light-duty vehicles and also for heavy-duty engines and vehicles.
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Response to Emissions type-approval methods, tests, requirements and methodologies for M1 and N1 motor vehicle categories

13 May 2025

The European Commission (DG GROW) has published its proposals for the first package of Euro 7 implementing acts for the type-approval of light-duty vehicles (cars and vans), which are due to be adopted by 29 May 2025 according to Article 14(8) of Regulation (EU) 2024/1257. ACEA has made a full and comprehensive review of the proposals in this public consultation, presented as justified amendments to the Commission proposals, and supplemented by additional documents to bring the necessary and comprehensive clarity. The deadline to adoption by 29 May 2025 is very tight, but the proposed implementing acts still require necessary amendment to provide robustness, clarity and proportionality for all involved stakeholders, i.e. manufacturers who must use these proposals to develop and homologate all future new vehicles they will produce in compliance with Euro 7, and type-approval authorities and technical services who must consistently and uniformly apply Euro 7. Ensuring clarity and robustness is critical now. In an already packed development and homologation schedule, manufacturers do not want to face a burden of re-approving due to amendments needed to repair that would come later in a second package of implementing acts. In these proposals for the Mia and the SIA, there are many areas that require attention before ACEA would see this as being ready for adoption. We therefore urge the European Commission, in completing these proposals with short delay, to carefully review and integrate all of the justified ACEA proposals which we propose in the interests of clarity and robustness, for all involved stakeholders who must deal with Euro 7. Of course, the proposals in this public consultation are only the first package. A second package is necessary to address issues such as brakes (applicable to all vehicle types requiring Euro 7 type-approval) and battery performance (applicable to all electrically chargeable vehicle types requiring Euro 7 type-approval). Industry has requested the European Commission adopt the second package by 1 January 2026, so that manufacturers would know all the technical regulatory elements of Euro 7 to give them reasonable chance to plan and gain Euro 7 type-approval for every single vehicle type they plan to place into the EU market before 29 November 2027. We still do not know when the second package will be adopted, but we are concerned it could be as late as Q2 2026. That would give manufacturers less than 18 months to ensure compliance and type-approve their complete portfolio to Euro 7, a massive challenge for manufacturers, but also for EU approval authorities who will be swamped with requests from vehicle manufacturers all demanding Euro 7 type-approvals in a relatively short space of time; We recall the problems in years 2017/18 when WLTP and RDE applied as new type-approval requirements. Newly produced vehicles were stored in fields and at airports because type-approval certificates could not be delivered on time to meet manufacturers model update/release plans. ACEA therefore requests that this first package is completed as soon as possible without sacrificing clarity, robustness and proportionality and urge the European Commission to make progress as soon as possible on the second package for light-duty vehicles and also for heavy-duty engines and vehicles.
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Meeting with Zala Tomašič (Member of the European Parliament)

6 May 2025 · Future of the Automotive Industry

Meeting with Dario Tamburrano (Member of the European Parliament)

6 May 2025 · Decarbonizzazione dei veicoli leggeri

Meeting with Pierfrancesco Maran (Member of the European Parliament, Shadow rapporteur)

6 May 2025 · End-of-Life Vehicles

Meeting with Filip Turek (Member of the European Parliament, Shadow rapporteur)

30 Apr 2025 · The Carbon Border Adjustment Mechanism

Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs), Stefan Fuehring (Head of Unit Secretariat-General)

29 Apr 2025 · Exchange of views on the regulatory simplification for the automotive sector – second meeting

Auto industry seeks technical flexibility in eCall regulations

25 Apr 2025
Topic — EU regulation updating technical requirements for emergency call systems in vehicles.
Message — The industry requests flexibility to use older 3GPP Release 14 standards instead of mandating Release 16, more time for callback testing, and delayed implementation of software verification at periodic inspections. They argue the current timeline prevents continuous eCall deployment and creates unnecessary technical barriers.123
Why — This avoids costly hardware upgrades and allows existing systems to remain compliant.45
Impact — Emergency services may miss benefits from newer communication standards and faster network capabilities.
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Meeting with Rosa Serrano Sierra (Member of the European Parliament)

14 Apr 2025 · Challenges Automotive Sector

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs) and

10 Apr 2025 · Impact of US tariffs

Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič)

10 Apr 2025 · Trade policy in the automotive sector

Meeting with Stéphane Séjourné (Executive Vice-President) and

10 Apr 2025 · Impact of US tariffs

Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič), Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič)

4 Apr 2025 · Relationship with the US and impact on automobile sector

ACEA calls for alignment of extra-heavy lorry CO2 standards

3 Apr 2025
Topic — The consultation concerns creating new vehicle sub-groups for extra-heavy-combination lorries under CO2 regulations.
Message — The association wants vehicle sub-groups to align with the legal definition including all three-axle vehicles. They request the addition of two new 3-axle sub-groups and CO2 reduction targets for them. They also propose replacing long-haul mission profiles with regional profiles for certain heavy trucks.123
Why — Using accurate mileage and usage data would prevent disproportionate CO2 compliance requirements for truck manufacturers.45
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Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and Volkswagen Aktiengesellschaft and

2 Apr 2025 · Automotive

Meeting with Alexandr Vondra (Member of the European Parliament)

1 Apr 2025 · Commission's proposal for targeted amendment on CO2 emission performance standards for new passenger cars

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

31 Mar 2025 · Simplification

Meeting with Stefan Fuehring (Head of Unit Secretariat-General)

27 Mar 2025 · Exchange of views on the regulatory simplification for the automotive sector

Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

27 Mar 2025 · Exchange of views on the regulatory simplification for the automotive sector

Meeting with Filip Turek (Member of the European Parliament)

27 Mar 2025 · Legislative developments surrounding the automotive industry

Meeting with Christophe Kiener (Head of Unit Trade)

26 Mar 2025 · Exchange of views on the EU-India FTA negotiations

Meeting with Christophe Kiener (Head of Unit Trade)

26 Mar 2025 · Exchange of views on the EU-India FTA negotiations

Meeting with Tiemo Wölken (Member of the European Parliament)

24 Mar 2025 · Car CO2 Emissions (Staff level)

Meeting with Sophie Moonen (Head of Unit Competition)

24 Mar 2025 · Review of the Technology Transfer Block Exemption Regulation (TTBER) and its accompanying Guidelines – questions on the call for evidence and public consultation questionnaire

Meeting with Ekaterina Zaharieva (Commissioner) and

19 Mar 2025 · Industrial Action Plan for the European automotive sector and competitiveness of the sector

Meeting with Sabine Weyand (Director-General Trade) and

18 Mar 2025 · Meeting with ACEA (European Automobile Manufacturers’ Association)

Meeting with Sabine Weyand (Director-General Trade)

18 Mar 2025 · US and trade relations with China

Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

18 Mar 2025 · Euro 7 implementation, access to battery data

Meeting with Maria Isabel Garcia Catalan (Head of Unit Taxation and Customs Union) and Volkswagen Aktiengesellschaft and

6 Mar 2025 · Hybrid meeting - Discussion on the draft Guidance on CAM under the EU-UK TCA

Meeting with Jessika Roswall (Commissioner) and

3 Mar 2025 · Exchange of views on circular economy and sustainability in the automotive sector

Meeting with Maroš Šefčovič (Commissioner) and

3 Mar 2025 · EU Automotive Action Plan

Meeting with Maroš Šefčovič (Commissioner) and

21 Feb 2025 · High-level meeting with the Automotive industry

Meeting with Stéphane Séjourné (Executive Vice-President) and

19 Feb 2025 · Dialogue on the future of the automotive sector – Suppliers Session

Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

19 Feb 2025 · Exchange of views on the situation of the automotive industry

Meeting with Paul Speight (Head of Unit Environment)

19 Feb 2025 · Automotive TF REACH follow up on art 4.2 of the POPs Regulation

Meeting with Stéphane Séjourné (Executive Vice-President) and

19 Feb 2025 · Dialogue on the future of the automotive sector – Battery Session

Meeting with Elisabeth Werner (Deputy Secretary-General Secretariat-General) and

19 Feb 2025 · ACEA’s recommendations for the EU Industrial Action Plan for Automotive Sector

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall)

13 Feb 2025 · Automotive Action Plan

Meeting with Max Lemke (Head of Unit Communications Networks, Content and Technology)

13 Feb 2025 · Invitation to a High-Level Meeting on Technological and Digital Innovation – Strategic Dialogue on the Future of the Automotive Industry – 17/02/2025 16h-18h

Meeting with Wopke Hoekstra (Commissioner) and

12 Feb 2025 · Dialogue on the future of the automotive sector - Thematic Working Group on 'Clean Transition and Decarbonisation'

Automotive group ACEA urges extension of lead use exemptions

10 Feb 2025
Topic — The EU is consulting on lead exemptions in steel, aluminium, and copper alloys.
Message — ACEA requests alignment with previous decisions to avoid expiry dates considered unusually short and extremely challenging. They argue splitting exemptions only adds to the burden of industry.12
Why — This prevents production halts since technical solutions for lead-free alternatives are currently unavailable.3
Impact — Environmental groups lose out as lead remains in the electronics supply chain longer.4
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European Car Makers Demand Extension for RoHS Lead Exemptions

10 Feb 2025
Topic — This consultation reviews hazardous substance exemptions for lead in electrical and electronic components.
Message — ACEA requests aligning expiry dates with past decisions to avoid extremely challenging deadlines. They oppose splitting exemptions into complex sub-entries that increase industry burden.123
Why — Longer timelines reduce compliance costs and prevent disruption where technical solutions are missing.4
Impact — Environmental and health advocates lose if hazardous substance phase-outs are delayed.5
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ACEA urges extension for lead solder exemptions in electronics

10 Feb 2025
Topic — Review of RoHS Directive exemptions for lead in high melting temperature type solders.
Message — ACEA requests extending the proposed expiry dates and objects to the detailed splitting of exemptions. They argue current timelines are unrealistic and increase administrative burden without improving environmental protection.12
Why — The industry avoids technical disruption and high compliance costs while suitable lead-free alternatives remain unavailable.3
Impact — Environmental advocates lose the benefit of a more rapid phase-out of hazardous lead substances.4
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Meeting with Kurt Vandenberghe (Director-General Climate Action)

10 Feb 2025 · Automotive dialogue

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament)

6 Feb 2025 · Competitiveness of Automotive Industry

European car industry urges simplified Single Market and regulatory batches

30 Jan 2025
Topic — This consultation addresses removing regulatory barriers to strengthen the European Single Market.
Message — ACEA requests synchronizing regulations into batches to reduce complexity and vehicle approval costs. They propose a One-Stop Shop to ensure consistency across all new legislative acts.12
Why — This would lower business costs and prevent rushing compliance at the eleventh hour.3
Impact — Local governments lose flexibility to implement specific national road rules and incentives.4
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Meeting with Pascal Canfin (Member of the European Parliament, Shadow rapporteur) and Scania AB (publ)

27 Jan 2025 · End-of-life of vehicles Regulation

Meeting with Maria Isabel Garcia Catalan (Head of Unit Taxation and Customs Union) and Volvo AB and Ford Motor Company

24 Jan 2025 · Online meeting - Discussion on the draft Guidance on CAM under the EU-UK TCA

Meeting with Sophie Wilmès (Member of the European Parliament)

23 Jan 2025 · Automotive industry

Meeting with Jorge Vitorino (Head of Unit Trade)

15 Jan 2025 · Investment in EU FTAs and update on negotiations with India

Meeting with Roxana Mînzatu (Executive Vice-President) and

15 Jan 2025 · Skills and labour matters

Meeting with Wopke Hoekstra (Commissioner) and

15 Jan 2025 · Decarbonisation in the automotive sector

Meeting with Apostolos Tzitzikostas (Commissioner) and

15 Jan 2025 · Competitiveness challenges of the automotive industry

Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič), Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič)

15 Jan 2025 · Exchange of view on the challenges and the protection of the automotive industry.

Response to Technical specifications related to the format, frequency and quality of data on alternative fuels infrastructure

30 Dec 2024

ACEA welcomes the opportunity to provide feedback to the public consultation on the proposed Implementing Regulation Data on alternative fuels infrastructure technical specifications (format, frequency and quality) and would like to provide the following comments, specifically from the perspective of heavy-duty vehicles. Please see attached document.
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Auto Industry Seeks MCS Integration and Expanded Hydrogen Standards

30 Dec 2024
Topic — Standards for alternative fuel infrastructure including wireless charging and hydrogen supply.
Message — ACEA welcomes confirmation that megawatt charging system will be included once standardization completes. They request adding overhead contact line specifications for heavy trucks and including future high-flow hydrogen connector standards when available.123
Why — This ensures their heavy-duty vehicles can use infrastructure tested for long-distance operations.45
Read full response

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and Volvo AB and

19 Dec 2024 · HDVs and Buses main priorities

Meeting with Kurt Vandenberghe (Director-General Climate Action) and RENAULT

12 Dec 2024 · The 2025 CO2 target

European Automakers Demand Control Over Digital Product Passport Services

10 Dec 2024
Topic — EU rules for service providers managing digital product passports under sustainability regulations.
Message — ACEA wants flexibility to manage passport systems themselves rather than using external providers. They demand input on service content, terms, specifications and costs, and question why backup data must be shared with third parties when internal copies are possible.12
Why — This would let them avoid external service provider fees and maintain control over their data.3
Impact — Independent service providers lose potential revenue from mandatory backup and hosting services.
Read full response

Meeting with Stéphane Séjourné (Executive Vice-President) and

10 Dec 2024 · Priorities of Automotive sector

Meeting with Pierfrancesco Maran (Member of the European Parliament, Shadow rapporteur) and ADPA - European Independent Automotive Data Publishers Association

10 Dec 2024 · End-of-Life Vehicles Regulation

Meeting with Apostolos Tzitzikostas (Commissioner) and

10 Dec 2024 · Exchange of views on the EU industrial action plan for automotive sector

Meeting with Ana Vasconcelos (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

2 Dec 2024 · Accounting of greenhouse gas emissions of transport services 2023/0266(COD)

Meeting with Kurt Vandenberghe (Director-General Climate Action)

27 Nov 2024 · automobile sector issues

Meeting with Dario Tamburrano (Member of the European Parliament)

21 Nov 2024 · Priorità per la legislatura

Meeting with Christian Ehler (Member of the European Parliament)

21 Nov 2024 · Automotive Industry

Meeting with Valdis Dombrovskis (Executive Vice-President) and Mercedes-Benz Group AG

20 Nov 2024 · Ongoing negotiations between EU Commission and Chinese government in the context of EU anti-subsidy measures against imports of Battery Electric Vehicles form China; overall competitiveness of the EU automotive sector

Meeting with Valdis Dombrovskis (Commissioner) and Volkswagen Aktiengesellschaft and

20 Nov 2024 · High Level European Car Summit, organised by EPP and ACEA. EVP Dombrovskis was invited to give a speech.

Meeting with Jens Gieseke (Member of the European Parliament)

12 Nov 2024 · Austausch zu EU-Automobilpolitik

Auto Industry Seeks Simpler EU Battery Waste Transport Rules

8 Nov 2024
Topic — EU revision of waste classification list to address battery recycling processes.
Message — ACEA requests a Europe-wide standardization and simplification for transporting waste batteries across borders. They seek a 24-month transition period for implementing new waste codes. The organization argues current fragmented national rules create excessive administrative work and transportation costs.123
Why — This would reduce their compliance burden and lower transportation costs for recycling operations.45
Impact — Environmental regulators lose stricter oversight of hazardous battery waste movement across borders.6
Read full response

Meeting with András Gyürk (Member of the European Parliament)

8 Nov 2024 · Automotive industry priorities

Meeting with Kurt Vandenberghe (Director-General Climate Action)

5 Nov 2024 · Examining the critical enabling conditions for the transition — from recharging and refuelling infrastructure to energy grid capacity, fiscal incentives, and funding.

Meeting with Radan Kanev (Member of the European Parliament)

22 Oct 2024 · Decarbonization of transport sector

ACEA Backs Battery Recycling Rules to Protect European Competitiveness

18 Oct 2024
Topic — Commission methodology for calculating battery recycling efficiency and material recovery rates.
Message — ACEA supports the current compromise to avoid high costs for new European gigafactories. They request clearer definitions for terms like "black mass" and "first recycler" to ensure practical legal certainty.12
Why — This approach shields emerging European battery producers from high costs during their initial manufacturing learning curve.34
Impact — Strict rules would benefit mature Chinese manufacturers while driving away investment from new European production sites.5
Read full response

Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

11 Oct 2024 · auto-industry

Meeting with Arash Saeidi (Member of the European Parliament)

9 Oct 2024 · presentation des priorité des constructeur automobile

Meeting with Jens Gieseke (Member of the European Parliament)

8 Oct 2024 · Austausch zu Umweltpolitik

Meeting with Alexandr Vondra (Member of the European Parliament)

8 Oct 2024 · CO2 emission performance standards for new passenger cars and vans, and heavy-duty vehicles respectively

ACEA warns heavy-duty vehicle emission tests could trigger unfair fines

6 Oct 2024
Topic — Procedures for verifying CO2 emissions and fuel consumption of heavy-duty vehicles in-service.
Message — ACEA demands a two-year monitoring period and opposes retroactive rules. They seek to remove additional audits for simulation methods.12
Why — This would lower compliance risks and prevent cumulative fines from retroactive regulations.3
Impact — Regulators and climate targets lose if verification stringency is reduced or delayed.4
Read full response

Meeting with Zala Tomašič (Member of the European Parliament)

1 Oct 2024 · Key Priorities for the European Automotive Industry

Meeting with Angelika Niebler (Member of the European Parliament)

1 Oct 2024 · EU Automotive Policy

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

30 Sept 2024 · implementation of the European Green Deal

Meeting with Dan Nica (Member of the European Parliament) and Volkswagen Aktiengesellschaft and

24 Sept 2024 · Hearing on Automotive Industry - S&D ITRE Working Group

Meeting with Christian Ehler (Member of the European Parliament) and Novo Nordisk A/S

23 Sept 2024 · Industriepolitik allgemein

Meeting with Angelika Niebler (Member of the European Parliament)

23 Sept 2024 · Competitiveness

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

23 Sept 2024 · General discussion on automotive sector.

Meeting with Valdis Dombrovskis (Executive Vice-President)

20 Sept 2024 · Situation of the EU automotive industry, EU anti-subsidy investigation into BEVs from China

Meeting with Sofja Ribkina (Cabinet of Executive Vice-President Valdis Dombrovskis)

20 Sept 2024 · Meeting with European car manufacturers

Meeting with Kurt Vandenberghe (Director-General Climate Action)

29 Aug 2024 · Automotive sector

Auto Industry Seeks Harmonised EU Road Data Access

26 Aug 2024
Topic — EU framework for deploying intelligent transport systems across member states.
Message — ACEA requests regular consultation of industry stakeholders, European-wide harmonised data access through National Access Points, and clarification of cooperative ITS scope. They oppose extending eCall to other vehicle categories without extensive evaluation.1234
Why — This would enable them to develop EU-wide services without navigating inconsistent data access across member states.56
Impact — Road safety advocates lose faster rollout of emergency calling systems to motorcycles and trucks.7
Read full response

Response to Amendment to the CO2 determination regulation for heavy-duty vehicles

31 Jul 2024

ACEA welcomes the opportunity to provide comments on the proposed draft regulation amending Regulation (EU) 2017/2400. This 3rd amendment presents an important set of provisions that aim to update and further expand the CO2 certification regulation for heavy-duty vehicles. While ACEA has already submitted extensive comments during the drafting process, a thorough examination of the proposal was not possible within the available time in the public consultation procedure. Therefore, we are providing the following preliminary comments and intend to offer additional remarks as soon as possible. For the detailed comments, please see attachment.
Read full response

Meeting with Roberto Vannacci (Member of the European Parliament)

17 Jul 2024 · Presentazione Associazione ACEA

Meeting with Kateřina Konečná (Member of the European Parliament) and European Cancer Organisation

17 Jul 2024 · Introduction of political priorities

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

4 Jul 2024 · Data / vehicle of the future

Meeting with Jens Gieseke (Member of the European Parliament)

26 Jun 2024 · Austausch zu Verkehrs- und Umweltpolitik

ACEA says vehicle block exemption remains fit for purpose

20 Jun 2024
Topic — The Commission is evaluating competition rules governing motor vehicle distribution and repair services.
Message — The association argues the current regulation remains effective and provides a stable framework for electrification. They suggest aligning competition guidelines with the Data Act rather than amending the regulation. Furthermore, they claim it is premature to change rules regarding agency distribution models.123
Why — The current rules offer a stable framework for manufacturers navigating electrification and digital shifts.4
Impact — Independent repairers may see limited competition gains if specific data access rules remain unchanged.5
Read full response

Meeting with Thierry Breton (Commissioner) and

12 Jun 2024 · Exchange on state of play automotive industry, route35 and expected developments

European Auto Industry Seeks Delay in Heavy-Duty Vehicle Reporting

8 Jun 2024
Topic — New monitoring and reporting obligations for heavy-duty vehicle CO2 emissions and fuel consumption.
Message — ACEA requests delaying the legal obligation for M3 and N2 vehicles from January 2024 to January 2025. They cite malfunctions in the VECTO reporting system that have caused disruptions. They also request immediate data format specifications from the Commission to avoid inconsistent submissions before the September deadline.123
Why — This would give manufacturers more time to fix technical problems and configure IT systems.45
Impact — Environmental monitoring is delayed, postponing the baseline for emissions tracking by one year.6
Read full response

ACEA urges simplified carbon footprint rules for EV batteries

28 May 2024
Topic — Methodology for the calculation and verification of life-cycle carbon footprints for EV batteries.
Message — ACEA recommends the 'cut-off' approach for end-of-life modelling instead of the complex Circular Footprint Formula. They also suggest including renewable energy certificates in electricity calculations to reduce reported emissions.12
Why — These changes would reduce administrative burdens and prevent significant impacts on battery production.3
Impact — Policymakers and environmental groups lose verifiable data on the future recycling impacts of batteries.4
Read full response

ACEA urges harmonised car labelling regulation for digital age

14 Apr 2024
Topic — Evaluation of EU rules regarding passenger car CO2 and fuel consumption labels.
Message — ACEA requests turning the directive into a regulation to address divergence across member states. They advocate for deleting outdated requirements like paper books and posters in favor of the internet. They also argue against adding real-world data which has a marginal impact on consumers.123
Why — This would reduce compliance costs and protect manufacturers from legal repercussions and lawsuits.45
Impact — Environmental groups and consumers lose access to detailed real-world emissions and air quality data.67
Read full response

Meeting with Maroš Šefčovič (Executive Vice-President) and

8 Apr 2024 · Dialogue on Clean Mobility

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Transport and Environment (European Federation for Transport and Environment) and

8 Apr 2024 · Energy market

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

3 Apr 2024 · Presentation of ACEA Manifesto

Meeting with Margrethe Vestager (Executive Vice-President) and

22 Mar 2024 · Discussion of current challenges facing the European Steel sector attended by private industry as well as Ministers and official representatives of Italy, Romania, Poland, Czechia, Belgium, Hungary and Luxembourg

Meeting with Maroš Šefčovič (Executive Vice-President) and

22 Mar 2024 · Clean Transition Dialogue with the Steel Sector

Meeting with Sabine Weyand (Director-General Trade)

6 Mar 2024 · EU/China trade, trade and competitiveness.

Meeting with Michael Kauch (Member of the European Parliament)

19 Feb 2024 · Standard Essential Patents

Meeting with Kurt Vandenberghe (Director-General Climate Action) and DAF Trucks N.V.

15 Feb 2024 · 1. CO2 standards heavy-duty vehicles - implications, implementation etc. 2. State and further development of the enabling conditions (infrastructure, cost parity measures, incentives etc.) 3. Industrial competitiveness 4. ACEA priorities for the next

Meeting with Nicola Danti (Member of the European Parliament)

12 Feb 2024 · SEPs

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

9 Feb 2024 · Access to Vehicle Data

Auto industry challenges modal shift assumptions in EU freight directive

12 Jan 2024
Topic — EU directive promoting shift from road freight to rail and waterways transport.
Message — ACEA requests the Commission reconsider statements on modal shift and ensure a level playing field between transport modes. They want the Handbook on external costs of transport updated with balanced methodology that includes all externalities from all modes equally, including rail-specific costs like scarcity and subsidies.1234
Why — This would prevent road freight from being disadvantaged compared to competing modes.56
Impact — Rail and waterway operators lose regulatory advantages if all externalities are counted equally.7
Read full response

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

19 Dec 2023 · Proposal for a Regulation amending the Type Approval Regulation

Response to Evaluation and revision of the Weights and Dimensions Directive

15 Dec 2023

ACEA, the European Automobile Manufacturers Association, strongly welcomes the Review of the Weights & Dimensions Directive published on 11 July 2023 as part of the Greening Freight Package. The Review of the Directive is one important element of the regulatory framework to facilitate the market uptake of zero-emission vehicles (ZEVs), namely battery-electric and hydrogen-powered trucks and buses. Zero-emission vehicles will only be adopted in the market at the necessary rate if transport operators can use them as seamlessly and at least as profitably as conventionally powered vehicles. This requires firmly putting them on a level playing field with conventional diesel-powered trucks and buses. The proposed Review incorporates several of ACEAs recommendations and strikes a good balance in establishing a level playing field with conventionally powered vehicles. However, further adjustments and improvements are necessary. See the attached Position paper for further details.
Read full response

Meeting with Magda Kopczynska (Director-General Mobility and Transport)

15 Dec 2023 · - Weights and Dimensions - Greening Corporate Fleets - Vehicle data

ACEA seeks safety exemptions for heavy-duty CO2 verification tests

14 Dec 2023
Topic — New rules defining how to verify CO2 emissions for trucks in service.
Message — ACEA wants to exempt technologies from being labeled artificial strategies if they ensure vehicle safety. They suggest using specific maintenance checklists when selecting vehicles for testing.12
Why — These changes would prevent legal penalties for using necessary engine protection software.3
Read full response

Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur)

14 Dec 2023 · Standard Essential Patents Regulation (staff level)

European Carmakers Seek Flexibility on Recycled Content Targets

4 Dec 2023
Topic — EU proposal requiring circularity standards and recycled materials in vehicle design and end-of-life management.
Message — ACEA requests adjustments to recycled content targets, including acceptance of both mechanical and chemical recycling, special thresholds for legacy substances, and inclusion of pre-consumer recycled content. They oppose mandatory dismantling requirements for certain components and seek clarification on extended producer responsibility obligations, arguing producers cannot be responsible for ensuring compliance of all waste operators without contractual relationships.123
Why — This would reduce compliance costs and provide more time to develop recycling infrastructure.45
Impact — Environmental groups lose stricter circularity standards and faster implementation of recycling requirements.6
Read full response

Meeting with Maroš Šefčovič (Executive Vice-President) and

30 Nov 2023 · Clean Transition Dialogue on Energy Intensive Industries

Meeting with Valdis Dombrovskis (Executive Vice-President)

28 Nov 2023 · 1) Competitiveness of the EU automotive industry 2) EU's anti-subsidy investigation into BEVs produced in China 3) Emission reduction in the transport sector

Auto industry seeks delay for eCall network transition

24 Nov 2023
Topic — Updating eCall emergency systems from 2G/3G to 4G/5G networks.
Message — ACEA and CLEPA request additional lead-time for updating existing vehicle types, proposing a mandatory date of January 2029 instead of January 2027. They argue this transition requires considerable technical expertise and administrative effort across all affected product lines.12
Why — This would give them more time to complete conversion across product lines without forced technical adaptations.34
Impact — Millions of existing vehicle occupants would lose safety equipment until upgrades are completed.5
Read full response

Meeting with Danuta Maria Hübner (Member of the European Parliament, Rapporteur for opinion)

21 Nov 2023 · Standard Essential Patents (COD 2023/0133) (Meeting with APA)

Meeting with Kurt Vandenberghe (Director-General Climate Action)

16 Nov 2023 · Implementation of the Green Deal

Meeting with Susana Solís Pérez (Member of the European Parliament, Shadow rapporteur)

16 Nov 2023 · Euro 7 meeting held by parliamentary assistant

Car manufacturers seek industry involvement in EU emissions framework

14 Nov 2023
Topic — EU regulation on calculating and reporting greenhouse gas emissions from transport services.
Message — ACEA requests involvement of Member States and industry experts in defining technical details of the proposal. They emphasize that new rules must align with existing regulations like CO2 standards for Heavy-Duty Vehicles and avoid duplication with reporting regimes already in place.12
Why — This would give them influence over technical specifications and reduce regulatory complexity.3
Impact — Other transport modes lose if road transport benefits from data gaps favouring their metrics.4
Read full response

Meeting with Susana Solís Pérez (Member of the European Parliament)

13 Nov 2023 · CO2 heavy duty meeting held by parliamentary assistant

Meeting with Alexandr Vondra (Member of the European Parliament, Rapporteur)

8 Nov 2023 · EURO 7

Auto industry seeks faster customs reform timeline

7 Nov 2023
Topic — EU revision of Union Customs Code to modernize customs framework and processes.
Message — The industry welcomes modernization but criticizes the extremely long implementation timeline extending to 2038. They want earlier delivery of Trust and Check Trader benefits, including self-assessment procedures and transit document exemptions. They oppose reducing temporary storage from 90 days to 3-6 days, warning this will disrupt supply chains for non-standard shipments like prototypes.1234
Why — Faster customs clearance would reduce supply chain delays and administrative burden for global manufacturers.56
Impact — Customs authorities lose flexibility in monitoring goods as shorter storage periods reduce oversight time.7
Read full response

Meeting with Elsi Katainen (Member of the European Parliament, Shadow rapporteur)

6 Nov 2023 · Weights and dimensions directive

Meeting with Sofja Ribkina (Cabinet of Executive Vice-President Valdis Dombrovskis), Zaneta Vegnere (Cabinet of Executive Vice-President Valdis Dombrovskis)

5 Oct 2023 · Launch of anti-subsidy investigation for BEVs.

Meeting with Susana Solís Pérez (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and Manufacture Française des Pneumatiques Michelin

21 Sept 2023 · Euro 7 meeting held by parliamentary assistant

Meeting with Katri Teedumäe (Cabinet of Commissioner Olivér Várhelyi), Szabolcs Horvath (Cabinet of Commissioner Olivér Várhelyi) and

18 Sept 2023 · Meeting on Battery Rules of Origin in EU-UK TCA

Meeting with Luc De Lobel (Cabinet of Commissioner Didier Reynders)

14 Sept 2023 · ACEA requested a meeting to discuss: Battery Rules of Origin in EU-UK Trade and Cooperation Agreement.

Meeting with Pablo Fabregas Martinez (Cabinet of Commissioner Adina Vălean)

1 Sept 2023 · Electric vehicle batteries in the EU/UK

Auto Industry Demands Weaker CO2 Testing Rules for In-Service Vehicles

14 Aug 2023
Topic — New EU procedures for verifying CO2 emissions of cars already on the road.
Message — ACEA requests reducing the number of vehicle families tested, increasing tolerance margins for test variations, and blocking retrospective application to pre-2021 vehicles. They argue the proposed testing methodology is based on insufficient data and unfairly penalizes manufacturers for natural test variations.1234
Why — This would reduce testing costs and shield them from penalties for older vehicles.56
Impact — Consumers and environmental groups lose stronger enforcement of manufacturers' CO2 claims.
Read full response

ACEA Urges Broader Scope for EU Standard Essential Patent Regulation

19 Jul 2023
Topic — New European rules to streamline licensing and royalties for standard essential patents.
Message — The regulation should apply to existing standards like WiFi and 5G multi-mode. Aggregate royalty determinations must be available on the implementers' sole initiative. The Commission should mandate licensing to all willing licensees across the value chain.123
Why — This reform would avoid excessive royalties and prevent production stoppages from injunction threats.45
Impact — Overseas patent holders and patent trolls would lose their ability to extract inflated royalties.67
Read full response

European Auto Industry Backs Cybersecurity Rule Delay to 2025

21 Jun 2023
Topic — Cybersecurity requirements for radio equipment under EU delegated regulation.
Message — The organization requests postponing the applicability date of cybersecurity regulations to August 2025. They support changing the implementation timeline for the radio equipment directive's cybersecurity provisions.1
Why — This gives automakers an extra year to implement cybersecurity requirements for vehicles.2
Read full response

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

13 Jun 2023 · EU-UK Trade and Cooperation Agreement; car industry; green transition; battery supply chain

Response to European Critical Raw Materials Act

9 Jun 2023

Please find attached detailed comments for the CRMA as well as associated NZIA. In general the industry welcomes the activities to facilitate and simplify procedures, but is aware of the subsidiarity and lack of EU competencies in that area - member states will be key to deliver. Streamlined and enhanced financial instruments are missing as well, especially for NZIA. Reporting obligations should be limited to minimum and not to be duplicated (similar actions required from industry as well as from the member states). There is no clarity how the reporting obligations (related to permanent magnets and recyclability) will be transposed in the the type-approval legislation.
Read full response

Meeting with Nicolas Schmit (Commissioner) and

5 Jun 2023 · The upskilling/reskilling challenges in the automotive sector in order to ensure a just transition across the ecosystem

European Truck Makers Demand Infrastructure Before Tougher CO2 Targets

17 May 2023
Topic — Review of EU CO2 emission standards for new heavy-duty vehicles to support zero-emission mobility.
Message — ACEA demands annual reviews of charging infrastructure and carbon pricing measures starting in 2025, not 2028. They argue current enabling conditions are insufficient even for existing 30% reduction targets. The industry wants penalties waived if infrastructure and policy support don't match manufacturer obligations.123
Why — This would shield manufacturers from massive penalties if infrastructure providers and governments fail to deliver.45
Impact — Climate goals lose urgency as manufacturers gain leverage to delay emission reductions citing infrastructure gaps.6
Read full response

Meeting with Kathleen Van Brempt (Member of the European Parliament, Shadow rapporteur for opinion) and Transport and Environment (European Federation for Transport and Environment)

11 Apr 2023 · Euro 7

Meeting with Alexandr Vondra (Member of the European Parliament, Rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

21 Mar 2023 · EURO 7

Meeting with Frans Timmermans (Executive Vice-President)

21 Mar 2023 · Green transition in automotive

Meeting with Thierry Breton (Commissioner) and

21 Mar 2023 · Euro 7, Route35, green transition of the automotive sector

ACEA Urges Delay of 2030 Ambient Air Quality Targets

14 Mar 2023
Topic — The European Commission is revising air quality standards to align with WHO guidelines.
Message — The association suggests a slightly later date for greater compliance should be considered. All industrial sectors must contribute to help achieve future air quality limits. Policy makers should prioritize supporting the renewal of the old vehicle fleet.123
Why — A delay prevents the diversion of financial resources away from electric vehicle development.4
Read full response

ACEA calls for predictable CO2 targets for light vans

13 Mar 2023
Topic — Updating the monitoring parameters and CO2 emission procedures for multistage vans.
Message — The association proposes adjusting the formula to align with passenger car regulations. They argue current calculations are unpredictable and provide zero legal certainty.123
Why — The proposed changes would provide manufacturers with necessary planning and legal certainty.45
Read full response

Meeting with Kateřina Konečná (Member of the European Parliament, Shadow rapporteur) and European Association Automotive Suppliers and

9 Mar 2023 · ITS Directive Revision

Auto Industry Seeks Flexibility on Smart Tachograph Rollout

7 Mar 2023
Topic — Transitional measures for smart tachographs pending Galileo satellite authentication service availability.
Message — The industry requests extending deadlines for installing final tachographs to 9 months after satellite service launch, and allowing pre-produced vehicles with older units to be registered. They want flexibility to reduce retrofit costs and eliminate mandatory software updates on transitional devices.123
Why — This would avoid €58.5-89.8 million in hardware retrofit costs for vehicles awaiting completion.45
Impact — Enforcement authorities lose stronger position authentication during the extended transition period.6
Read full response

Meeting with Dimitri Lorenzani (Cabinet of Vice-President Maroš Šefčovič)

23 Feb 2023 · Discussion on EU industrial policy

Meeting with Cristina Rueda Catry (Cabinet of Executive Vice-President Valdis Dombrovskis)

17 Feb 2023 · SEP licensing-auto industry position

Meeting with Thierry Breton (Commissioner) and

10 Feb 2023 · Standard-essential patents for the automotive sector

European Automakers Warn Euro 7 Will Divert Investment from Electrification

9 Feb 2023
Topic — New EU emissions standards (Euro 7) for combustion-engine vehicles across all categories.
Message — ACEA requests significant amendments to Euro 7, arguing the proposal would force manufacturers to divert resources from zero-emission vehicle development back to combustion engines. They call for revised implementation dates and less stringent requirements, claiming the regulation's air quality benefits are marginal compared to fleet electrification.123
Why — This would allow manufacturers to focus capital on electrification and avoid costly compliance investments.45
Impact — Air quality improvements are delayed as older, more polluting vehicles remain on roads longer.6
Read full response

Meeting with Alexandr Vondra (Member of the European Parliament, Rapporteur)

1 Feb 2023 · EURO 7

Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis)

1 Feb 2023 · Critical Raw Materials Act

Meeting with Frans Timmermans (Executive Vice-President) and Volkswagen Aktiengesellschaft and

19 Jan 2023 · visit to see developments in electric mobility

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

20 Dec 2022 · Co2 standards trucks and buses

Meeting with Jens Gieseke (Member of the European Parliament, Shadow rapporteur)

13 Dec 2022 · Austausch zur EU-Verkehrspolitik

Auto industry urges voluntary approach to EU mobility data space

7 Dec 2022
Topic — EU proposal to create common European Mobility Data Space for transport data sharing.
Message — ACEA requests that the data space remain voluntary and industry-driven, based on existing standards. They want the Commission to support current initiatives without adding mandatory requirements or replacing existing platforms.123
Why — This would allow manufacturers to continue controlling their data sharing on commercial terms.45
Impact — Public authorities and third parties lose guaranteed access to vehicle data for transport planning.
Read full response

Meeting with Walter Goetz (Cabinet of Commissioner Adina Vălean)

7 Dec 2022 · Automotive transport

Meeting with Henrik Hololei (Director-General Mobility and Transport)

28 Nov 2022 · 1) Sustainable and Smart Mobility Strategy 2) Urban Mobility Framework

European auto industry seeks domestic raw materials capacity for electric transition

25 Nov 2022
Topic — EU proposal to strengthen critical raw materials supply chains for green transition.
Message — ACEA requests enhanced domestic capacity to extract and process critical raw materials, improved supply security through trade agreements, and strengthened recycling frameworks. They emphasize the need for strategic autonomy while maintaining open trade, and warn against mandatory recycled content targets that could disrupt e-mobility plans.123
Why — This would reduce their dependency on imports and ensure access to materials needed for electric vehicle production.45
Impact — Environmental and human rights advocates lose if standards aren't enforced on extraction practices.6
Read full response

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

8 Nov 2022 · introductory talk with the new appointed Director General Ms de Vries

Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis), Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

19 Oct 2022 · Automotive industry

Meeting with Lucia Bonova (Cabinet of Executive Vice-President Margrethe Vestager), Stina Soewarta (Cabinet of Executive Vice-President Margrethe Vestager)

18 Oct 2022 · Access to in-vehicle data, Data act, MVBER

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

6 Oct 2022 · ACEA Autumn reception

Meeting with Maroš Šefčovič (Executive Vice-President) and

6 Oct 2022 · Decarbonisation of the automotive sector

Meeting with Sabine Weyand (Director-General Trade)

6 Oct 2022 · Supply chain, Market access.

European Automakers Back Five-Year Extension of Competition Rules

28 Sept 2022
Topic — Renewal of block exemption rules for vertical agreements in motor vehicle sector.
Message — ACEA supports extending the current regulation until 2028, arguing it remains fit for purpose. They want the rules to provide a clear framework for confronting electrification and digitalisation challenges. They request explicit confirmation that complying with future vehicle data access rules will mean compliance with competition law.123
Why — This maintains regulatory certainty while allowing manufacturers to adapt business models for electrification.4
Impact — Independent repairers may face continued disadvantages accessing vehicle data during regulatory uncertainty.56
Read full response

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

28 Sept 2022 · transport

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

19 Sept 2022 · CO2 standards for trucks

Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur) and Twilio Inc. and Stichting Open Future

12 Jul 2022 · Data Act

European carmakers seek continued lead exemptions in vehicle components

1 Jul 2022
Topic — EU review of exemptions for lead use in end-of-life vehicle components.
Message — ACEA requests continuation of exemptions allowing lead in aluminum alloys, copper alloys, and certain batteries. They argue the exemptions are essential to enable production and sale of cars in Europe. They want the review aligned with the broader ELV Directive review and criticize the short transition period for 24V batteries.123
Why — This avoids costly redesign and retooling while maintaining current production processes and supply chains.45
Impact — Environmental and health groups lose faster phase-out of toxic lead in vehicles and waste streams.6
Read full response

European car manufacturers seek fixes to biodiesel approval rules

29 Jun 2022
Topic — EU regulation on emissions type-approval for heavy duty vehicles using pure biodiesel.
Message — ACEA wants the Commission to maintain existing universal fuel type-approval routes while creating an alternative pathway for dedicated engines running on specific fuels like B100. They argue the proposal doubles testing burdens and creates regulatory gaps around CO2 measurement.123
Why — This would preserve their flexible approval pathway and avoid doubled testing costs.4
Impact — Member states lose ability to mandate exclusive use of sustainable biodiesel.56
Read full response

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Volvo AB

28 Jun 2022 · Data Act, preparation of access to in-vehicle data, Euro 7

European Carmakers Urge Exemption for Battery Assembly from Industrial Emissions Rules

23 Jun 2022
Topic — Revision of EU Industrial Emissions Directive to reduce pollution from industrial facilities.
Message — ACEA requests that battery assembly be excluded from the revised Industrial Emissions Directive. They argue assembly activities have very low environmental relevance and should not face demanding regulatory requirements. They recommend regulating only environmentally significant battery production processes already covered.123
Why — This would avoid administrative burden and speed up electric vehicle production.4
Impact — Environmental groups lose comprehensive oversight of the rapidly growing battery manufacturing sector.
Read full response

Meeting with Kateřina Konečná (Member of the European Parliament, Shadow rapporteur)

21 Jun 2022 · Revision of the ITS Directive

ACEA Proposes Technical Adjustments to EU Vehicle Emission Rules

20 Jun 2022
Topic — Updating EU emission testing procedures for passenger and light commercial vehicles.
Message — ACEA recommends lowering hybrid utility factor values to reflect actual driving. They request using PEMS margins terminology and protecting sensitive engine documentation. The industry also seeks early voluntary compliance options for smoother transitions.123
Why — This provides stable carbon compliance planning and prevents unnecessary vehicle recalls.45
Impact — Market surveillance authorities would lose access to sensitive base engine data.6
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

1 Jun 2022 · Presented the role of DG GROW to support the business case for the green and digital transition and encouraged the car manufacturers to play their role as offtakers for European supply

European Auto Industry Seeks Exemption from Cyber Resilience Act

25 May 2022
Topic — New EU regulation setting horizontal cybersecurity requirements for connected products and services.
Message — ACEA requests that motor vehicles be excluded from the Cyber Resilience Act's scope. They argue existing UN Regulations 155 and 156 already provide comprehensive cybersecurity requirements for vehicles throughout their lifecycle. They want the Commission to conduct a gap analysis and only address identified gaps through existing sectoral legislation.123
Why — This would avoid duplicative compliance requirements and reduce administrative burdens for manufacturers.45
Impact — Consumers lose potential additional protections if sectoral rules have unidentified gaps.
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European carmakers seek three-year delay for Data Act

13 May 2022
Topic — EU regulation on fair access to and use of data across sectors.
Message — ACEA requests a 36-month implementation period instead of 12 months, clearer definitions of accessible data, and protections against forced disclosure of trade secrets. They want exemptions from providing free data access to commercial users and restrictions on third parties developing competing services with shared data.123
Why — This would reduce their compliance costs and protect competitive advantages from shared vehicle data.456
Impact — Third-party service providers lose immediate access to vehicle data for innovative services and applications.7
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ACEA urges end to selective SEP licensing practices

9 May 2022
Topic — Regulation on licensing of standard essential patents for standardized technologies.
Message — ACEA calls for mandatory licensing to all willing implementers regardless of supply chain position, reinstating Huawei framework protections, and preventing selective end-product-only licensing. They want upstream suppliers to receive licenses directly rather than forcing automotive manufacturers into negotiations.123
Why — This would let automotive suppliers negotiate licenses directly and avoid paying inflated royalties.45
Impact — Patent holders lose leverage to extract higher royalties from vehicle manufacturers under injunction threat.67
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European Carmakers Seek Higher Production Limits for Automated Vehicles

4 May 2022
Topic — EU technical requirements for type-approval of automated driving systems in fully automated vehicles.
Message — ACEA requests increased volumes under the Small Series approval scheme and elimination of production limits for Automated Valet Parking technology. They argue current restrictions threaten economic viability and market introduction of near-ready AVP technology.123
Why — This would allow manufacturers to commercialize automated parking technology without volume restrictions that threaten profitability.45
Impact — Regulators lose oversight controls designed to limit deployment while learning from initial implementations.6
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Meeting with Jens Gieseke (Member of the European Parliament, Shadow rapporteur)

3 May 2022 · Austausch zur Verkehrspolitik

Meeting with Sofja Ribkina (Cabinet of Executive Vice-President Valdis Dombrovskis), Zaneta Vegnere (Cabinet of Executive Vice-President Valdis Dombrovskis)

21 Apr 2022 · Steel safeguard, impact of Russia's war of aggression against Ukraine on the EU's automotive industry, critical raw materials

Response to Promoting sustainability in consumer after-sales

28 Mar 2022

Please find our feedback attached.
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European automakers seek weight and length exemptions for electric trucks

18 Feb 2022
Topic — EU rules on maximum weights and dimensions for heavy-duty vehicles.
Message — ACEA requests exemptions allowing zero-emission trucks to exceed current maximum lengths and weight restrictions. They argue battery and hydrogen storage requirements make current limits impractical for electric vehicles. They also want additional weight allowances extended to all vehicle configurations without restrictions.123
Why — This would improve driving range and reduce total cost of ownership for electric trucks.45
Impact — Road safety advocates lose as heavier, longer trucks increase infrastructure strain and accident risks.
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

10 Feb 2022 · Discuss Emissions standards and Timeline in General Safety

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean) and Transport and Environment (European Federation for Transport and Environment)

6 Dec 2021 · mobility and transport

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

6 Dec 2021 · Euro 7

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

The European Automobile Manufacturers Association (ACEA) welcomes the proposal to revise the Renewable Energy Use Directive (RED) and the Fuel Quality Directive (FQD). RED is one of the key cornerstones of an effective policy framework which supports and enables the transition to carbon-neutrality. ACEA’s position paper on RED-FQD is attached. The key issues are as follows: > RED must play its role in setting a pathway to 100% fossil-free fuels and energy for road transport, to help achieve climate neutrality of the road transport fleet by 2050 and give the right long-term signal to investors and industry. > In that respect, the proposal for only a 13% reduction in GHG intensity of renewable energy for transport by 2030 is not ambitious enough. In addition, we cannot understand why there are no targets beyond 2030. > ACEA asks for a greater level of ambition for 2030 and a roadmap beyond 2030 that leads to 100% fossil-free energy for road transport by 2045. > Other parts of the fit for 55 package will lead to increased costs for customers and operators for fossil-based fuels and energy. It is therefore essential that much greater amounts low carbon alternative fuels and energy, capable of being used in the new and older fleet, are widely available and attractively priced. > The proposals on electricity and system integration are a concern, especially the proposal to give third parties [free] access to vehicle battery management system (BMS) data. Such BMS data is vehicle manufacturer proprietary information and intellectual property, which cannot be disclosed without limitations. Raw BMS data is also not a reliable way to determine vehicle battery state of health. > Any request for data access has to be aligned with principles guiding other regulatory initiatives on vehicle data (safety, security and extended vehicle concept) and recognising the right of vehicle manufacturers to have a fair return on investment. > Batteries are being covered in several other regulatory initiatives (eg. the Battery Regulation). ACEA requests a synchronised approach when it comes to the disclosure of battery related information, not a patchwork of regulations. > The proposal on the FQD offers very little with regard to the first two words of the title of the Regulation, ie. “Fuel Quality”. > B10 (FAME) is meaningless, especially with other regulatory signals contrary to first generation biofuels. Encouraging already available renewable drop-in diesel alternatives, such as HVO, should be the focus. > ACEA will present a specific position paper on the FQD to outline what we would like to see improved in the FQD now in order to improve the quality of general market fuels available to all users of older and new vehicles and contribute to further improvements of pollutant and CO2 emissions.
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Response to Revision of the Energy Tax Directive

17 Nov 2021

The European Automobile Manufacturers Association (ACEA) welcomes the Commission’s proposal to the Council on the restructuring of the Union framework for the taxation of energy products and electricity. Within the fit for 55 package, the ETD is one of the key measures for an effective policy framework that supports and enables the transition to carbon-neutrality. ACEA’s position paper on ETD is attached. Our key observations are as follows: > Customers and operators may accept higher taxes on fossil fuels but not if low carbon alternative fuels capable of being used in the new and older fleet are not widely available and attractively priced. This illustrates how other parts of the fit for 55 package need to work > The impact of annual indexation over 10 years on the proposed minimum tax rates and the impact on businesses and national authorities appears excessive. ACEA would suggest a more flexible approach. > Low carbon sustainable biofuel/biogas have to meet minimum sustainability criteria (RED) so the level of sustainability compared to fossil should be reflected in rather lower minimum tax rates than proposed. In that respect, flexibility to apply exempt or lower tax on certain fuels should apply to any biofuel that achieves the RED sustainability targets. > Natural gas would suffer a big immediate hike in tax rates from 2023 and the impact on fleet operator TCO would be large. We would suggest a more flexible time-based approach for fossil-based natural gas. > We are cautious about removing the flexibility for member states to apply lower taxes to certain fuels used for the same transport purpose. > Taxes on electricity used to recharge vehicles should be no higher than taxes on electricity used for domestic consumption. If member states were to follow the ranking of taxes applied to fuels in Table A of Annex I, they should still be able to ensure that electricity for transport remains a low tax rate if they were to decide to increase taxes on low carbon fuels, RFNBO and advanced sustainable biofuels and biogas which, in the proposal, have the same minimum tax rates as electricity (at least at 2023). > Relating to the proposal in RED on system integration, the ETD should consider tax refunds for customers and operators for electricity bought and stored in vehicle batteries and which may be fed back into the grid.
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European Carmakers Demand Faster Charging Infrastructure Rollout

17 Nov 2021
Topic — EU regulation requiring deployment of alternative fuels infrastructure for zero-emission vehicles.
Message — ACEA demands significantly more ambitious charging infrastructure targets, requesting 7 million public charging points by 2030 instead of the Commission's proposal. They want higher power requirements (3kW for BEVs, 2kW for PHEVs) and faster implementation timelines. For heavy-duty vehicles, they seek earlier deadlines and more charging stations at truck parking areas.123
Why — This would ensure sufficient infrastructure to support their electric vehicle sales targets.45
Impact — Member states face higher infrastructure investment costs and accelerated deployment obligations.6
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Response to Extension of scope of procedures for determination of CO2 emissions of heavy-duty vehicles

12 Nov 2021

ACEA welcomes the opportunity to provide comments on the above-mentioned draft regulation amending regulation (EU) 2017/2400 as regards the determination of the CO2 emissions and fuel consumption of medium and heavy lorries and heavy buses and the introduction of electric vehicles and other new technologies. The extension to the new vehicle categories and technologies is fully supported by manufacturers who have been working intensively with the Commission, its services and consultants to ensure the regulation takes full account of the specificities of these vehicle segments, for example with respect to the multi-stage production procedures for buses. ACEA has provided regular feedback to earlier working drafts of the regulation and welcomes that many comments have already been integrated into the current draft. It is particularly welcome that sufficient lead times for the introduction of xEV powertrain technologies have now been integrated which facilitate the ambitious roll-out strategies of these new powertrain technologies. Please find detailed comments in the attached document.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

The European Automobile Manufacturers Association (ACEA) welcomes the proposal to establish an emissions trading system for road transport. It is one of the key cornerstones of an effective policy framework which supports and enables the transition to carbon-neutrality. - Achieving the necessary emission reductions by 2030 and on the way towards climate neutrality requires unprecedented efforts by all stakeholders. Industry and policymakers on all levels must contribute and collaborate effectively to enable a rapid transformation. - Vehicle manufacturers have repeatedly expressed their commitment to climate neutrality by 2050 at the latest . They are already well on the way by providing an increasingly wide range of low- and zero-emission powertrain solutions across vehicle segments and use cases. - Cutting emissions of the road transport sector as whole at the necessary pace, requires the rapid deployment of zero-emission vehicles. But providing just the vehicles is not enough. In order to enable their operation, a sufficiently dense network of charging and refueling stations and clear economic signals are indispensable to give transport operators confidence to invest in zero-emission vehicles. - A coherent and effective policy framework is equally indispensable to facilitate the shift and help close the persisting TCO-gap (total costs of ownership) of zero-emission powertrain vehicles. Especially commercial road transport operations are almost exclusively driven by their focus on total costs of ownership. Only with the strong support of a policy framework that sets a price on carbon, will it be possible to encourage transport operators to choose low- and zero- (carbon) emission powertrain solutions over conventional diesel-powered vehicles. Transport operators will only invest in zero-emission vehicles if they can be operated as profitably and seamlessly as conventional powertrain vehicles. A self-standing emission trading system is instrumental for closing the TCO-gap of zero-emission vehicles, especially with respect to commercial vehicles. It is a one key element of the ‘Fit for 55’ package, without which the overall efforts to lower emissions, especially in the road freight transport sector cannot be effective. - In addition to the shift to new low- and zero-emission vehicles, all energy carriers and fuels used in road transport must be decarbonized quickly and be widely available to ensure that the current vehicle fleet can contribute to the necessary emission reductions. - Like all measures proposed in the ‘Fit for 55’ package, the inclusion of road transport in the ETS will only contribute to the overall emission reductions if it is implemented synchronously as part of a well-balanced package. Further comments can be found in the attached paper.
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ACEA urges more charging infrastructure to meet emission targets

8 Nov 2021
Topic — The consultation reviews CO2 emission performance standards for new cars and vans.
Message — ACEA demands that higher emission targets be matched by significantly more public charging infrastructure. They suggest delaying the 2035 phase-out goal until charging networks are guaranteed. Finally, they argue for maintaining exemptions for small-volume manufacturers.123
Why — Delaying targets and keeping exemptions would protect their business models from disproportionate costs.45
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Meeting with Thierry Breton (Commissioner) and

26 Oct 2021 · Transition to zero emission mobility; data

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

11 Oct 2021 · Preparation meeting with Commissioner

Auto Industry Seeks More Time for Vehicle Emissions Data

5 Oct 2021
Topic — New reporting requirements for heavy-duty vehicle CO2 emissions data collection.
Message — ACEA requests more time to provide retroactive data for vehicles already simulated, extending the deadline to September 2022. They also want to report certain data files separately from main monitoring reports to reduce IT system burden.12
Why — This would reduce IT system burden and provide adequate time for retroactive compliance.34
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Response to Revision of Combined Transport Directive

16 Sept 2021

The underlying principle in combining two or more modes of transport is efficiency. To stay competitive with respect to costs, all modes have to improve their efficiency. The achievement of a true internal market for rail, short sea and inland waterways transport services and the improvement of their full potential in terms of productivity is essential for a true intermodal or multimodal transport based on efficiency. Efficiency of non-road transport modes should not be achieved by limiting road transport. There should be no limitations applied to the share of road transport in combined transport. Transport modes are selected by shippers on the basis of sustainability, quality, cost and efficiency. The Directive has very little impact on the economic viability of combined transport. Other elements are much more important, such as volume availability, operational efficiency, customer service, reliability, frequency and technique used (accompanied versus unaccompanied, transhipment versus roll on-roll off). Therefore, road freight transport should not be disadvantaged against combined transport, rail, short sea or inland waterways because this will not solve the challenges of those modes. EU support should come in the form of a transparent, simple and aligned EU legal framework for combined transport which facilitates operations and encourages road freight transport operators and clients to use it, but not forcing to shift to combined transport.
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Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

10 Sept 2021 · Follow-up meeting, ongoing digital files

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

3 Sept 2021 · Preparation forthcoming meeting between Commissioner and ACEA

European Automakers Oppose Reversing Burden of Proof in AI Liability Rules

27 Jul 2021
Topic — EU proposal to adapt civil liability rules for damages caused by AI systems.
Message — ACEA requests that the burden of proof not be reversed in product liability cases. They argue the current Product Liability Directive is generally fit for purpose and covers AI-equipped products. They recommend non-binding guidance over new binding legislation.123
Why — This would prevent a surge in lawsuits and avoid financial burden on automakers.45
Impact — Victims lose easier paths to compensation for damages from defective AI-equipped products.6
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

16 Jul 2021 · Exchange views on: • Delivering on the European Green Deal – transition pathway (was “fit for 55”) • Euro 7/ VII (proposal on Euro 7/VII from ACEA) • Access to in-vehicle data • General Safety Regulation

Meeting with Laure Chapuis (Cabinet of Commissioner Kadri Simson)

12 Jul 2021 · - Share views on the upcoming Fitfor55 Package and expected released legislative proposals with possible impact on the automotive sector.

Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

6 Jul 2021 · FF55 and automotive sector

Meeting with Johannes Hahn (Commissioner) and

30 Jun 2021 · Electrification in the automotive industry and transformation of the European Automotive Sector.

Meeting with Frans Timmermans (Executive Vice-President) and Bayerische Motoren Werke Aktiengesellschaft

30 Jun 2021 · Automotive in the Fit for 55 package

Meeting with Adina-Ioana Vălean (Commissioner) and

30 Jun 2021 · Decarbonisation of road transport

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

25 Jun 2021 · Euro7; access to in-vehicle data

Meeting with Adina-Ioana Vălean (Commissioner)

7 Jun 2021 · Automobiles+ transport

Car Industry Seeks Year-Long Delay in Sustainability Reporting Rules

2 Jun 2021
Topic — New EU Taxonomy disclosure requirements for companies' environmentally sustainable activities.
Message — ACEA requests a one-year postponement of all reporting requirements to January 2023, citing insufficient time to adapt IT systems and unclear definitions. They want retrospective reporting limited to one year instead of five years, and removal of mandatory CapEx plan disclosure to protect competitive information.1234
Why — This would reduce costly IT system adaptations and protect business-sensitive information from competitors.56
Impact — Investors lose timely access to comprehensive sustainability data for allocation decisions.
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Auto industry warns REACH revision threatens European manufacturing competitiveness

1 Jun 2021
Topic — Revision of EU chemical registration rules to achieve toxic-free environment goals.
Message — The automotive industry requests simplified authorisation procedures, faster decision-making, and exemptions for legacy spare parts. They advocate for mandatory RMOA processes before risk management proposals and clearer substance identification in group restrictions. They oppose Mixture Assessment Factors as impractical for complex supply chains.1234
Why — This would reduce compliance costs and avoid production moving outside Europe.567
Impact — Workers and consumers face slower phase-out of hazardous chemical exposures.8
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Meeting with Valdis Dombrovskis (Executive Vice-President)

27 May 2021 · Trade policy review; Steel safeguard review; EU-US relations; Fit for 55 preparation

Meeting with Frans Timmermans (Executive Vice-President)

21 May 2021 · Green transition, decarbonisation of road freight

Meeting with Thierry Breton (Commissioner)

19 May 2021 · Euro 7, data, CO2 emissions performance standards

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

10 May 2021 · AFID review

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

10 May 2021 · AFID review

Meeting with Pauline Weinzierl (Cabinet of Commissioner Thierry Breton)

7 May 2021 · Review of the steel safeguards measures

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

7 May 2021 · Preparatory meeting for the 19/5 meeting between Commissioner Breton and ACEA

Meeting with Sofja Ribkina (Cabinet of Executive Vice-President Valdis Dombrovskis) and WindEurope and

29 Apr 2021 · Steel safeguard review

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

23 Apr 2021 · Zero emission freight

Meeting with Nicola Danti (Member of the European Parliament, Shadow rapporteur) and Stellantis

15 Apr 2021 · Data Governance Act

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

13 Apr 2021 · ACEA would like to give their views on : 1. The initiative on access to in-vehicle data. 2. The “Euro 7” legislation on emissions.

Meeting with Frans Timmermans (Executive Vice-President)

19 Mar 2021 · Exchange of views on European Green Deal in automotive

Auto industry seeks clarity on NIS 2 cybersecurity rules

17 Mar 2021
Topic — EU directive establishing common cybersecurity standards across member states.
Message — ACEA and CLEPA request clearer definitions of which entities qualify as 'essential' or 'important', guidance on how existing sector-specific rules like UN-ECE Regulation 155 interact with NIS 2, and more realistic reporting timeframes. They argue the 24-hour initial notification requirement is unrealistic and question why entities not deemed essential face the same obligations as those that are.123
Why — Clearer scope would reduce compliance uncertainty and avoid duplicative obligations with existing automotive cybersecurity rules.45
Impact — Delayed or weakened reporting could leave cybersecurity threats undetected longer across critical infrastructure.
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Auto industry seeks flexibility in EU battery regulation timeline

1 Mar 2021
Topic — New EU regulation on battery sustainability, performance and recycling throughout lifecycle.
Message — ACEA requests flexible implementation timelines aligned with automotive development cycles, recognition of existing vehicle regulations to avoid duplication, and flexibility on recycling targets. They argue the fragmented timeline with numerous delegated acts undermines robust legislation and fails to secure necessary lead times.123
Why — This would reduce compliance costs and preserve their three-to-five year product development cycles.45
Impact — Environmental groups lose stronger immediate standards for battery sustainability and circularity.
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Auto Industry Seeks Clearer Rules on Data Intermediaries

22 Jan 2021
Topic — EU regulation establishing framework for data governance and data sharing mechanisms.
Message — ACEA requests clearer definitions and scope in the Data Governance Act, particularly around data intermediation services. They want to ensure that internal corporate data arrangements are excluded from regulation. They propose inserting unambiguous definitions and moving vague exclusions from non-binding recitals into binding articles.123
Why — This would protect their existing vehicle data sharing model from new regulatory requirements.45
Impact — Third-party service providers lose potential regulatory protections for accessing vehicle data.
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European Auto Industry Contests EU Heavy-Duty Vehicle Emissions Correction Rules

12 Jan 2021
Topic — EU regulation correcting CO2 emissions calculations for heavy-duty vehicles misclassified as vocational.
Message — ACEA disputes Commission accusations of deliberate misclassification, arguing manufacturers merely declare vehicles as vocational based on available information. They demand manufacturers only face penalties if deliberate misconduct is proven, not for third-party modifications or registration errors. They request VECTO software updates and clearer correction procedures.123
Why — This would shield them from penalties for registration errors beyond their control.45
Impact — Environmental goals lose if manufacturers avoid declaring any vocational vehicles to dodge risks.6
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Response to Review of the Community Designs Regulation

18 Dec 2020

The European automobile industry is concerned about the Commission's suggestion to abolish design rights for automotive spare parts. We believe this would: - Deprive an innovative industry of fair returns on investment Vehicle manufacturers design, develop, engineer and test vehicles and parts. They set up a complex logistics and distribution system for their products and make parts available until ten years after the end of production of the vehicle. It is normal and efficient to reward these efforts with design rights on spare parts. Copiers take a free ride on these investments. They simply reverse engineer and sell the most profitable parts for as long as they are in demand. This is unfair competition. - Threaten European competitiveness and jobs The parts affected by this proposal (bonnets, bumpers, radiator grilles, wings, doors, lights) are almost exclusively produced by vehicle manufacturers in Europe today. If copying were permitted, an estimated 50,000 jobs would be lost to large copiers in Asia. This stands in sharp contrast with the Commission’s intention to implement a new industrial policy to strengthen the competitiveness of European industries. Thus, the EU would uniquely weaken its own automotive industry since none of the other major manufacturing countries (US, Japan, South Korea, China, Brazil, India, Russia) limit the design protection of automotive spare parts in this way. - Contradict its own IPR policy The proposal would abolish the design rights that currently exist in most Member States. It would permit the copying of spare parts in Europe while, at the same time, the EU is making considerable efforts to combat counterfeiting and piracy. The Commission’s approach is inconsistent and undermines its efforts to stop the copying of European products around the world. - Bring no consumer benefits The abolition of design rights does not necessarily lead to lower consumer prices. Various studies have shown that there is no link between spare parts prices and design protection. Any profits or cost savings that could result from the use of potentially cheaper copy parts are likely to end up in the pockets of parts traders, repairers and insurance companies. There is no consumer benefit if all this proposal does is shifting money from one industry to another. - Undermine vehicle safety Before they can be put on the market, vehicles and their component parts must meet an impressive series of technical requirements. Safety tests are an important part of this. However, the EU has absolutely no safety requirements in place for after-market parts. Clearly, a repaired vehicle must be as safe as one that is new. Components such as fenders, bonnets and tailgates are critical in meeting pedestrian safety requirements. This necessitates very carefully engineered components and controlled manufacturing processes. Currently vehicle manufacturers produce these parts themselves, or they are supplied by approved suppliers to exacting specifications to ensure the vehicle remains legally compliant. If such parts were to be copied without respect for the manufacturer’s specifications, this would make the vehicle non-compliant, damage the reputation of the manufacturer and reduce vehicle and road safety. - Work against the circular economy The EU strongly promotes resource efficiency, repair, re-use and recycling as part of its strategy to stimulate the circular economy. Vehicle manufacturers increasingly recover parts from vehicles that are no longer used or that have been involved in accidents, recondition them and offer them as remanufactured spare parts. Such parts are sustainable in that no new raw materials need to be used. They are also competitively priced. In our view, they represent a better and more sustainable option than copy parts produced outside the EU, which require the use of new raw materials, must be transported to Europe and are often made according to lower environmental standards.
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European carmakers seek changes to CO2 monitoring rules

13 Dec 2020
Topic — New EU regulation on monitoring real-world CO2 emissions from cars and vans.
Message — ACEA requests removing VIN collection requirements from real-world emissions data and eliminating the 15-year data retention period. They want to use existing ISC testing platforms instead of creating new ones under Article 14.123
Why — This would reduce data management costs and avoid maintaining databases with hundreds of millions of vehicle records.45
Impact — Regulators lose comprehensive long-term data needed to verify manufacturers' emissions claims over vehicle lifetimes.6
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Response to Climate change mitigation and adaptation taxonomy

11 Dec 2020

ACEA supports the overall objective of the Taxonomy Regulation to set a framework to facilitate sustainable investment. However, the European Commission’s proposals on the technical sustainability thresholds would potentially have severe impacts on the auto industry’s financing opportunities in the future. In fact, given their restrictive nature and future uses, the delegated acts could make it harder for manufacturers to obtain the necessary funding to help our industry transition towards a greener mobility. Content of the Delegated Acts: The sustainability definitions contained in the automotive technical screening criteria are loosely based on existing regulations and their definitions of low- and zero-emission vehicles. Nevertheless, the proposed thresholds go beyond existing regulations and only take minor subgroups of vehicles into account: Ultimately: • In the case for passenger cars and for vans, the eligibility of low emission vehicles (<50 gCO2/km) is limited until end-2025 based on the current Clean Vehicle Directive. The Clean Vehicle Directive’s main purpose is to foster the market penetration of low- and zero-emission vehicles among public authorities by artificially imposing green requirements in public tenders. It is unwise to assume that these artificially created markets are representative of the situation in the real world where said requirements are unfortunately missing. For this reason, the CVD is not an appropriate basis to be applied as the standard for the whole sector and would exclude from the taxonomy a number of technologies which can play a part in our short to medium term sustainability. Instead, the delegated acts should consider the CO2 fleet regulations as the legal basis for taxonomy thresholds and screening criteria and therefore extend the eligibility of low emission vehicles at least until 2030. • Similarly, ACEA requests modifications to the technical screening criteria for buses and coaches. Today, the Commission is imposing tyre requirements for the eligibility of these segments. Unfortunately, the requirements are not readily available in the market for buses and only 1 eligible type of tyre is available for coaches (only as a summer tyre). ACEA thus believes that more realistic thresholds should apply to these segments. • For freight transport, the reference to “vehicles not dedicated to transporting fossil fuels” remains ambiguous. When a manufacturer produces a vehicle, it does not know how the customer will be using their product. It is therefore impossible, at the moment of the production, for a vehicle manufacturer to fulfil the requirement above, which should be thus removed from the draft. Uses of the Technical Screening Criteria: Once again, ACEA believes that the technical screening criteria contained in the draft delegated acts have not been developed with a use-case of taxonomy in mind. It would be of paramount importance that the Commission complements the TEG’s report on the potential uses of taxonomy to provide non-binding guidelines on how taxonomy classifications should be used by the markets. Indeed, to this day, it remains unclear how the CapEx and OpEx will be integrated in the taxonomy calculations. Without knowing its uses, and with the current oversimplified suggestions made by the TEG, the taxonomy could greatly tarnish the reputation of the automotive sector portraying to investors incredibly low percentages of taxonomy alignment. This in turn could shift investments towards other sectors placing further obstacles in our path towards decarbonisation. Moreover, OEMs face an extremely tight schedule for the application of the new reporting requirements. The final technical screening criteria might only be known in 2021 and will have to be applied for the first time in 2022 with regard to the financial year 2021. Companies might have to apply these requirements retrospectively and will have only limited time to implement the new requirements internally.
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European automakers demand infrastructure and support for CO2 targets

26 Nov 2020
Topic — The European Commission is revising CO2 emission performance standards for new vehicles.
Message — ACEA insists that tighter CO2 targets require significant expansion of charging infrastructure. They also urge for continued super-credits and a stable investment period.123
Why — This strategy helps the industry avoid fines while maintaining market share for hybrids.45
Impact — Environmental organizations lose if climate targets are tied to slow infrastructure rollouts.6
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European Carmakers Push for Fuel Inclusion in ETS

26 Nov 2020
Topic — EU Emissions Trading System expansion to new sectors for 2030 climate targets.
Message — ACEA requests that all energy carriers, particularly fuels, be included in an expanded EU ETS. They argue this would ensure CO2 emissions are priced appropriately and drive market uptake of alternatively powered vehicles.12
Why — Higher fuel prices would make electric vehicles more competitive against conventional cars.34
Impact — Fuel distributors face higher compliance costs and consumers pay more for petrol and diesel.5
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Response to Revision of the Vertical Block Exemption Regulation

20 Nov 2020

We support the Commission’s intention to further simplify and clarify the rules to reduce the risk of diverging interpretations and uneven enforcement. This should be done notably by including in the VGL the recent CJEU case law regarding the ban on sales on third-party platforms and clarifying the applicability hereof to high-quality branded products such as motor vehicles. We equally support the Commission’s endeavour to clarify the conditions under which resale price maintenance can be considered to create efficiencies and thus to fulfil the conditions of Article 101 (3), for example for new product launches. Regarding the specific rules the Commission is reviewing, our view is as follows: - Dual distribution: Agreements between independent importers who are active at the retail level and their distributors should be exempted. Such agreements have the same pro-competitive effects as agreements concluded by vehicle manufacturers who are active at the retail level. As regards the latter, the VGL explicitly recognize these pro-competitive effects. Both types of agreement should therefore be treated in the same manner. This is important since many motor vehicle manufacturers use wholly owned subsidiaries to distribute their vehicles in national markets and these subsidiaries frequently act also as distributors. Such dual distribution enables them to keep the pulse on the market and stay abreast of changes in customer demands. In particular, it is more efficient for large corporate customers such as leasing and rental companies as well as public authorities, to make agreements with manufacturers/importers even distributors can be and often are involved in and rewarded for the delivery of these vehicles. We believe this fosters rather than limits competition. We consider it neither necessary nor appropriate to limit the scope of the exception by introducing a threshold based on the parties’ market share in the retail market or other metrics. We believe this would be very complex, for example in the case of spare parts where market shares vary significantly from one part to another. In our view, this would greatly reduce legal certainty. - Active sales restrictions: We support the idea to expand the exceptions for active sales restrictions to give suppliers more flexibility to design their distribution systems according to their needs, in line with Article 101 TFEU. We equally agree with the suggestion to support ensuring more effective protection of selective distribution systems by allowing restrictions on sales from outside the territory in which the selective distribution system is operated to unauthorised distributors inside that territory. - Indirect measures restricting online sales: We believe dual pricing should no longer be regarded as a hardcore restriction. While online sales are still relatively limited in the auto sector, this may well change over the next decade. Without dual pricing, there is a serious risk that, as occurs already in other sectors, customers increasingly purchase online while using brick and mortar shops for product information and customer service. This will increase the risk of free-riding and make it difficult for the latter to achieve a return on their investment, which is much higher than that of online intermediaries/agents who are already active in the auto sector. We equally believe the imposition of criteria for online sales that are not overall equivalent to the criteria imposed in brick and mortar shops in a selective distribution system should no longer be regarded as a hardcore restriction. While there are currently no pure online retailers in the auto sector, we consider that online and offline sales channels are inherently different. This makes it difficult to assess when a divergence in the criteria used for each channel amounts to a hardcore restriction under the VBER.
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European carmakers seek flexibility on recycled content requirements

19 Nov 2020
Topic — Review of EU directive on collection, treatment and recycling of end-of-life vehicles.
Message — ACEA opposes mandatory recycled content targets for new vehicles, arguing material choices should prioritize CO2 reduction over circularity. They request at least five years implementation time for any new requirements, applying only to new vehicle types. They support automated digital systems for vehicle deregistration.1234
Why — This preserves their ability to choose lighter virgin materials for CO2 reduction.5
Impact — Recycling industries lose guaranteed demand for recycled plastics from vehicle manufacturers.6
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Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

20 Oct 2020 · Speech at ACEA’s webinar "Putting the EU auto industry back on track post-COVID"

Meeting with Adina-Ioana Vălean (Commissioner) and

15 Oct 2020 · E-mobility

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean) and Transport and Environment (European Federation for Transport and Environment) and Eurelectric aisbl

24 Sept 2020 · Mobility and transport

Meeting with Nicolas Schmit (Commissioner) and

24 Sept 2020 · Pact for Skills Roundtable with the automotive sector.

Meeting with Thierry Breton (Commissioner) and

23 Sept 2020 · Roundtable skills for the Automotive sector

Auto Industry Demands 25% Renewable Fuel Target by 2030

21 Sept 2020
Topic — Revision of EU Renewable Energy Directive to meet increased climate targets.
Message — ACEA requests a minimum 25% renewable fuel target by 2030, elimination of double counting, and promotion of drop-in synthetic fuels with a 5% target. They want low-carbon liquid and gaseous fuels treated equally based on actual CO2 reduction versus fossil fuels.123
Why — This would allow them to reduce fleet emissions using existing vehicles and delay electrification investments.45
Impact — Electric vehicle advocates lose as this shifts focus from electrification to fossil-compatible fuels.6
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Meeting with Michel Barnier (Head of Task Force Task Force for Relations with the United Kingdom) and European Association Automotive Suppliers

14 Sept 2020 · Meeting with the Task Force for Relations with the United Kingdom

Response to Empowering the consumer for the green transition

1 Sept 2020

ACEA, the European Automobile Manufacturers' Association, welcomes the opportunity to contribute to the initial roadmap consultation regarding the consumer policy and how strengthening the role of consumers in the green transition. In particular ACEA welcome policy option 2: a new stand-alone consumer protection instrument. An EU wide directive for the consumer information would avoid creating different sets of information for different EU countries. We share the hope that such a directive could be used as a blueprint worldwide. However unnecessary technical and administrative burdens should be avoided. It is also very important to consider that vehicle manufacturers make every effort to ensure that their customers are able to have their vehicles adequately maintained, serviced and repaired regardless of whether this occurs in the manufacturers' authorised repairer network or not. This is why they make available all necessary technical information, tools, equipment and training material to independent operators such as independent repairers, manufacturers and distributors of repair equipment, tools or spare parts, publishers of technical information, automobile clubs, roadside assistance operators, operators offering inspection and testing services, operators offering training for installers and manufacturers, or repairers of equipment for alternative fuel vehicles.
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Response to Review of the general product safety directive

1 Sept 2020

The European Automobile Manufacturers’ Association (ACEA) believes that the GPSD is still broadly fit for purpose and does not require a major overhaul. At the most, it could be revised in a targeted manner to update some of the definitions with a view to clarifying their applicability. In this respect, we consider it obvious, for example, that a product cannot be considered “safe” if it poses a safety risk that was caused by insufficient cyber-security protection.Likewise, we find it self-evident that software that is embedded or updated after the product has been placed on the market is part of that “product” insofar as this software is certified by the original producer. By contrast, we think the original producer should not be held liable for any safety risk posed by the subsequent incorporation of standalone software over which it has no control. This standalone software should be considered a “product” in itself. Its producer should be liable for any safety risk it creates. When a software update causes an important change to the product or modifies its original performance and has a significant impact on its functioning, we think the product could be deemed a new product. Where applicable, this could be addressed in technical product legislation. For motor vehicles, for example, the update of software relating to a part, system or component that forms part of the vehicle’s type approval and that modifies the functioning or behaviour of that part, system or component, will likely require a new type approval or an extension of the existing type approval under Regulation 2018/858 on the approval and market surveillance of motor vehicles and their trailers, and of systems, components and separate technical units intended for such vehicles. With respect to market surveillance and recalls, we would like to point out that the above mentioned Regulation 2018/858 contains new, detailed rules for motor vehicles that will start to apply on 1 September 2020. We feel these should remain unaffected by the revision of the GPSD.
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

ACEA welcomes LCA analyses as they are important procedures that can help to reduce a motor vehicle’s impact on the environment and believes that the studies made should be scientifically sound and compare equivalent systems. LCA can be a useful tool to address environmental issues and is applied as internal environmental system for systematically managing environmental improvements in the automotive industry. LCA studies shall be based on ISO 14040/44 as a commonly used methodology both in the automotive sector as well as for the political or regulatory focused discussions in order to ensure level playing field and understanding. Only globally accepted indicators should be included in impact assessments and single indicators should not be used in any LCA. The complexity of automobiles does not allow for comparisons of different car manufacturers in the framework of a mandatory reporting scheme. LCA should remain a voluntary tool and cannot be used as a regulatory instrument vis-á-vis automobile manufacturer, especially having in mind the enormous complexity of vehicles. The proposed EU initiative needs to consider the recommended use (recommended applications) of LCA/PEF/OEF as well as their limitations, which have been addressed by environmental authorities, science and LCA practitioners. Current PEF and OEF approaches show many unsolved key challenges and do not allow fair comparability for specific use cases and highly complex products such as vehicles from different OEMs. Existing, further developed or new alternative environmental declarations could be used instead of PEF/OEF, which • are rather basic; • are easy to understand and deliver reliable information; • consider major impact categories (which are derived from more generic LCA). Furthermore more clarity on the definition and scope of “green claims” is needed.
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Response to Update of concentration limit values of persistent organic pollutants in waste

6 Aug 2020

Preliminary comments to the European Commission Inception Impact Assessment related to the update of concentration limit values of persistent organic pollutants in waste as per the Annex IV and V of the EU Regulation 2019/1021 on POPs. Over the last few years, ACEA members have significantly reduced the volume and number of substances classified as persistent organic pollutants in new vehicles. This proactive approach has delivered results beyond legal compliance and supported initiatives to enhance the circularity of secondary raw material from polymeric source. The ten substances covered by this Inception Impact Assessment have been phased out from new vehicle production from the 4th July 2020 at the very latest, in line with the latest restriction of Pentadecafluorooctanoic acid (PFOA) its salts and PFOA-related compounds. Some of the ten substances however have never been used in the production of vehicles. In the case of decaBDE, ACEA members have phase out the substance in new productions by mid-2018, years before the Stockholm Convention prohibition entered into force. ACEA therefore anticipates that none of these substances would hamper the achievement of the Reusability, Recyclability and Recoverability targets set under the EU ELV Directive 2000/53/EC when the vehicles produced after this date reach the end of their useful life. Studies, such as reference number 3 in the document “Ares(2020)2794471”, have demonstrated that POP substances from specific waste streams (DecaBDE, PFOA, SCCP, HBCD) have concentrations below the current limit values listed in Annex IV of the EU Regulation 2019/1021. While the volume of these substances in waste streams is likely to be low, modern post-shredder technology is capable to separate and further refine the shredder light fraction resulting from the end-of-life vehicle recycling process to produce a cleaner source of secondary raw materials, as described in the report of the “Study on the Effects on ELV waste management as a consequence of the decisions from the Stockholm Convention on decaBDE”, Öko-Institut e.V., September 2018). The technical feasibility and relevance of enforcing more stringent limit values and the efforts required to analyse waste streams prior to recycling in large scale waste processing plants should be carefully assessed before setting new concentration limit values under Annex IV and V. Valuable secondary raw materials resulting from recycling can be produced in accordance with the limits set under the current Annex I of the EU Regulation 2019/1021 and play a significant role in the circular economy. ACEA and its members remain committed to the phase out of persistent organic pollutant from their new vehicles provided that sufficient lead time can be granted to bake the restrictions in their product development strategy.
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Response to Legislative framework for the governance of common European data spaces

31 Jul 2020

We believe that the following preliminary perspectives are needed before creating any ex-ante rules on data spaces. 1. CONTEXTUALISATION OF INDUSTRY LED INITIATIVES: Ex-ante regulatory intervention for B2B/B2G data sharing should not be a primary goal given the competitiveness of our sector, its high investment level into R&D and data sharing initiatives and is therefore deemed premature and disproportionate. Data markets are not the core business of vehicle manufacturers but rather a new ancillary and needed market development. Proving market failure and finding a balance between market forces and ex-ante rules is needed. See page 13 in the EC Communication on Data Strategy and footnote 39. 2. DATA SHARING IS KEY BUT A MOTOR VEHICLE IS NOT A BUSINESS/COMMUNICATIONS PLATFORM NOR A SMARTPHONE ON WHEELS : A vehicle is a means of transport, whose function is to bring people and goods safely from one place to another. It is vehicle manufacturer’s responsibility to ensure that the vehicle operates in a safe and secure manner, also when exchanging data with third parties. Types of data sharing for automotive: public good (e.g. SRTI in the data task force), C-ITS, components/suppliers, repair/maintenance, personalised services such as insurance, parking, geofencing, B2B, B2G, G2B, G2G. Our model for in-vehicle data sharing, called “extended vehicle model”, ensures safety, cybersecurity, trust and fair competition. Please refer to a competition law assessment of Professor Damien Geradin here: https://ssrn.com/abstract=3545817) 3. CLEAR OWNERSHIP OF REGULATORY MEASURES AT THE COMMISSION: There are many interlinks with sectorial approaches on data sharing versus the overall horizontal framework on common data spaces. Industry is best served with regulatory predictability and stewardship by one interface at the Commission services. E.g.: data sharing B2G/G2B is embedded in the ITS approach of DG MOVE (including various delegated acts). 4. ROLE OF INTERMEDIARIES: To promote competition, service providers can choose to access in-vehicle data through the vehicle manufacturer’s server or via ‘neutral’ servers that would gather data from vehicle manufacturers’ servers. Neutral server operator(s) will be required to have a B2B agreement with the vehicle manufacturer and implement state-of-the-art security and data protection measures. Data will be delivered to the neutral servers without undue delay and will be of the same quality as the data available on the vehicle manufacturer’s server. The neutral server operator(s) can negotiate with the vehicle manufacturer the inclusion of additional data fields and make these available on the neutral server(s) without revealing their usage or the requesting provider, creating thus new business models. 5. PUBLIC INTEREST: We look forward to the implementing act on high value data sets for the mobility cluster under the Open Data Directive. Public authorities can improve the discoverability of such data via the National Access Points under the ITS framework. However, B2G has a different logic than G2B. The report of the Expert Group on B2G data sharing shows interesting avenues on how to incentivise B2G data sharing. Still unanswered though is how to frame the concept of “public interest” (B2G) where we see a great variation between the local, national and European levels. 6. STANDARDISATION: In-vehicle generated data should not be standardised since this would impose a huge burden on manufacturers, impede their ability to innovate and may stifle competition without being indispensable for independent operators. Instead, metadata descriptions promote interoperability without imposing the burdens raised by the standardisation of in-vehicle data.
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Meeting with Kadri Simson (Commissioner) and

10 Jul 2020 · Exchange of views on energy system integration and hydrogen strategies.

European carmakers oppose new battery collection and design rules

9 Jul 2020
Topic — This consultation aims to update EU laws for a more sustainable battery lifecycle.
Message — ACEA opposes new collection targets and design requirements, preferring existing recycling systems. They also suggest that non-damaged batteries should not be treated as waste during transport.123
Why — Voluntary standards and flexible classifications would reduce compliance costs and regulatory hurdles.4
Impact — Third-party companies repurposing batteries would be forced to bear all liability costs.5
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Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

30 Jun 2020 · COVID-19 challenges for auto industry (knock-on effects re 'end of series' rules and pending type approval procedures)

Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

23 Jun 2020 · Automotive sector and recovery plan

Response to Chemicals strategy for sustainability

17 Jun 2020

As an industry committed to offer a safe working environment to its employees, while proposing safe articles to its customers, the automotive industry is fully supporting the announced zero pollution ambition for a toxic free environment. When producing complex articles, OEMs are at the far end of the regulatory chain, supporting all the conformity requirements initially related to products provided by the chemical industry. The new ambitions aiming to transform those tier-n suppliers towards innovative, responsible and sustainable industrial partners is one of the key conditions of success, given the details of what is called responsible and sustainable chemistry will be well defined and standardized so as to allow the introduction of global purchasing criteria with respect of the fair trade processes and while remaining competitive. To be well understood and implemented in the best conditions, this chemical strategy for sustainability needs to be built on existing European policy evaluations as well as already well-established international initiatives such as Stockholm convention about Organic persistent pollutants, Rotterdam convention about pesticides … which also lead to national specific adoptions and obligations. Therefore, a global governance needs to be considered especially to avoid regulatory overlapping which represents a major problem for the industry facing global scopes such as the REACH regulation, but also activity specific frames, such as the vehicle end of life directive, both introducing specific and barely consistent obligations for heavy metals for example. Even if the need for strengthening the regulation is existing, the regulatory tools would certainly be more efficient if the 40 pieces of legislation could be reconsidered with a prevailing aim of simplification, while including new topics. Those new topics must be well explained with clear definitions and well-defined substances lists including internationally recognized identification systems. The usual and historical approach of the automotive industry is referring for precise substances recognition systems such as CAS or EC identifiers and ongoing global industry relevant regulatory projects, such as the SCIP data base are using the same approach. To avoid multiple design and validation of a single part or component, the automotive industry needs to take on board the regulatory evolutions with a pace adapted to the specific time frame of a vehicle design and usage phase. Therefore, every extension of the frame, as well as new obligations such as communication or conformity duties need to be identified with at least a lead period of 5 to 8 years. REACH introduced an interesting upstream identification process for substances including public consultations. It could be efficient to adapt it to other substances regulations. Regarding the Union strategy for a non-toxic environment that is conducive to innovation and the development of sustainable substitutes, ACEA would like to make reference to the measures already brought forward by the industry. The "Sustainable Chemicals Criteria", as agreed by the automotive industry and supply chain partners, can serve as a best practice example for the implementation of a sustainable chemistry in large industries (see also Automotive Industry Guideline on REACH, Annex O; https://www.acea.be/publications/article/reach-automotive-industry-guideline). Finally, a further effort of communication about the existing substitutes would be of major importance, in order to avoid short term decisions to promote substances without sufficient knowledge, or aiming to disappear within a short period of time, and to tackle effectively the feasibility of the substitution based on each and individual use case. The entire approach will need to promote the competitiveness of the European industry on the local and international play field.
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Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

27 May 2020 · Impact of COVID-19 crisis on the European automotive sector (virtual)

EU Carmakers Urge Air Quality Assessment Before New Euro 7 Rules

26 May 2020
Topic — Proposed stricter emission standards (Euro 7) for all combustion-engine vehicles in the EU.
Message — The organization requests a top-down assessment of existing Euro 6/VI regulations and CO2 legislation impact before deciding on new rules. They argue separate regulations for light- and heavy-duty vehicles should be maintained, citing different business needs. They also seek global harmonization opportunities and guaranteed industry lead-time from when regulations are finalized.123
Why — This would delay or avoid substantial new compliance investments during economic recovery from COVID-19.456
Impact — Urban residents lose faster air quality improvements if fleet renewal is delayed by affordability concerns.78
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Meeting with Frans Timmermans (Executive Vice-President) and European Association Automotive Suppliers

13 May 2020 · Recovery and Green Deal in Transport

Meeting with Thierry Breton (Commissioner) and

13 May 2020 · Automotive industry

Meeting with Nicolas Schmit (Commissioner) and

7 May 2020 · Videoconference meeting on the situation of the automotive industry in the crisis, the Commission response to the crisis and initiatives on up-skilling and reskilling.

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

6 May 2020 · Introductory meeting and presentation of ACEA concerns about future of automation and the Impact of Covid-19 on industry in general

Response to Revision of Alternative Fuels Infrastructure Directive

27 Apr 2020

In line with the overall contribution to the Green Deal implementation published by ACEA on 22 January (https://www.acea.be/publications/article/paving-the-way-to-carbon-neutral-transport-10-point-plan-to-help-imple), automobile industry considers investment into alternative fuels infrastructure absolutely essential and the proposal on the AFID review should be presented by the Commission even sooner than foreseen Q1 2021. A dense EU-wide network of charging points and re-fuelling stations – suitable for passenger cars and commercial vehicles – must urgently be deployed. This is one of the most important enabling conditions for achieving carbon neutrality: - There should be an ambitious review of the Alternative Fuels Infrastructure Directive (AFID), setting mandatory targets for charging points and re-fuelling stations at the national level with clear enforcement measures. Smart charging should also be promoted. - The AFID review should take account of the specific requirements of the heavy-duty segment, as their needs in terms of charging/fuelling capacity and location of infrastructure differs greatly from cars. - Form of a Regulation should be considered. - It is also crucial that the infrastructure is well maintained and can be relied upon to actually work; too often users encounter problems with its proper functioning. More detailed contribution from ACEA will be part of the public consultation.
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Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

23 Apr 2020 · Automotive industry and green deal

Response to EU rules on industrial emissions - revision

21 Apr 2020

ACEA welcomes the opportunity to provide comments to the Inception Impact Assessment for the revision of the Industrial Emission Directive (IED). As general comment ACEA would like to underline that, while the European Commission intends to modify the Directive, the IED has been just implemented and a lot of BREFs are not yet updated and did not entered into force yet. Industrial activities, with important investments, and long time of return, expect a certain stability in the regulation in order to plan and implement modification of production installations and to reduce environmental impacts. Too frequent changes in regulation could conduct to “investment leakages” (or investments in countries outside of Europe). The IED is already a complex regulation. The change from IPPC Directive to IED conducted to integrate in the new Directive some specific and technical Directive (LCP, VOC…) as annexes of the Directive making the IED more complex to understand and transpose. Adding other activities in the Directive’s scope would not help making the European legislation more comprehensive. Therefore, ACEA is not in favour of a new extension of IED perimeter. About Circular economy and contribution to industry’s decarbonisation, ACEA does not see Circular economy to be addressed in the IED which already covers several activities, with different environmental impacts. Therefore a generic regulation would not make sense or may even generate different understanding. If these thematic will be addressed within the IED, this should be part of BREF review, as it is partly started with recommendation about waste management, energy consumption and emission limit values proposed (the so called AEPL). In any case, overlapping with existing legislation (for example Waste framework directive, ELV directive…) must be avoided, and where reasonable, clear exemptions must be stated. ACEA believes that the most important topic of the proposed revision deals with the improvement of BREF revision process. ACEA strongly recommends improving the BAT process: a better-defined structure, with clearly defined responsibilities, rights and duties, and legal basis for transparency and decision making is certainly needed. Corresponding rules must be laid down in the IED. One proposal could be to have a specific TWG with EIPPCB to gather experiences of participants to some BREF revision in order to propose evolution of the revision process, and then maybe integrate some new thematic as circular economy principles and low carbon activity.
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Response to Climate change mitigation and adaptation taxonomy

20 Apr 2020

The European automotive sector is currently undergoing a disruptive transformative phase. The ongoing transition towards cleaner technologies aimed at decarbonizing our sector requires important investments in order to ensure that this disruptive change can be turned into new business opportunities. Therefore, ACEA welcomes the legislative proposal, understands its current scope and supports the 6 environmental objectives. However, the association would like to express some concerns regarding the content of the future Delegated Acts on taxonomy. More specifically, ACEA disagrees with some element related to the use of taxonomy as well as with the definition of sustainable economic activities contained in the latest TEG Report. Use of taxonomy ACEA believes that the technical screening criteria have not been developed with a use-case of taxonomy in mind resulting in potential mismatched between the objectives of the regulation - incentivising industry to decarbonize- and the likely outcome of current taxonomy - re-allocation of funding towards specific sectors/companies and not others-. The use of taxonomy criteria for other purposes than the objectives of EU Taxonomy regulation is a major risk for our industry. ACEA is particularly concerned by the evident objective of the TEG to classify companies based on their taxonomy alignment. The degree of environmental sustainability of a company for the purpose of investment will prove to be extremely complex. The European Commission needs to clarify how to use CAPEX/OPEX for taxonomy disclosure. Moreover, focusing primarily on the proportion of turnover originated by sustainable activities fails to account for the decarbonization efforts of industrial players: some companies invest in sustainable activities which do not translate immediately in product sales, revenues and turnover. The gap between the investment and turnover percentage may be long and certain uses of taxonomy do not take this into account. It also remains unclear who will be in charge of certifying whether an economic activity meets the sustainability criteria and can thus be labelled as “sustainable” and ACEA believes there ought to be a competent EU authority to govern the process. Automobile Technical Screening Criteria and the Delegated Acts The thresholds of the technical screening criteria which touch on automobile products rely on existing regulations and their definitions of low- and zero-emission vehicles, based on the principle of technological neutrality. Unfortunately: • In the case for passenger cars and for vans, the eligibility of low emission vehicles (>50 g CO2/km) is limited until 2025 based on the current Clean Vehicle Directive. Whilst ACEA understands the concept of transitional activities, we believe that such a tight phaseout would exclude from the taxonomy a number of technologies which can play a part in the short to medium term sustainability of our sector. The thresholds should be based on the CO2 fleet regulation as its legal basis which would extend the eligibility of low emission vehicles at least until 2030. • Similarly, ACEA believes there should be modifications to the technical screening criteria for busses. Today, no regulation for buses and coaches in terms of CO2 is available, therefore no CO2 values in g/pkm can be used. As soon as CO2 values are available in a comparable manner as for heavy duty trucks a rework of these definitions is possible. • For freight transport, to maintain consistency between EU Regulations, the metric used should be in line with the one presented in the legislation governing CO2 standards for HDVs. We therefore propose that the technical screening criteria should take into account CO2 emissions per tonne kilometre (g CO2/tkm) instead of the current formulation g Co2/km. Moreover, the eligibility should also be ensured for ‘Clean’ Heavy-Duty Vehicles as defined by the Clean Vehicle Directive.
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Meeting with Thierry Breton (Commissioner) and

20 Apr 2020 · the automotive industry ecosystem - recovery measures

Response to 2030 Climate Target Plan

2 Apr 2020

The initial input to the 2030 Climate target discussion is summarised in official ACEA reaction to the Green Deal that was made public already in January 2020 (see attached). It provides high-level summary of key policy areas that needs to be tackled to make the Green Deal objectives successful and goes much beyond the automotive sector only- the action plan is available at: https://www.acea.be/publications/article/paving-the-way-to-carbon-neutral-transport-10-point-plan-to-help-imple Detailed comments on the individual policy areas will be specified in the public consultation questionnaire.
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Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen) and European Association Automotive Suppliers

31 Mar 2020 · COVID-19 and challenges of restoring production (disrupted supply chains, differentiated de-confinement policies, demand stimulation, etc)

Meeting with Thierry Breton (Commissioner) and

26 Mar 2020 · COVID 19 & impact on automotive industry

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

25 Mar 2020 · Discussion on economic situation in automotive

European Auto Industry Opposes Retroactive Heavy-Duty Vehicle Data Requirements

16 Mar 2020
Topic — New data requirements for monitoring CO2 emissions from heavy-duty vehicles.
Message — ACEA argues that collecting data for vehicles produced from January 2020 onwards is an unnecessary retroactive burden. They recommend limiting verification to vehicles registered from July 2020, as earlier data quality checks are already in place.12
Why — This would avoid the cost and administrative burden of retroactively collecting six months of vehicle data.34
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Auto Industry Urges Reduced Verification Checks for Heavy-Duty Vehicles

16 Mar 2020
Topic — EU regulation on verifying CO2 emissions data from new heavy-duty vehicles.
Message — ACEA requests limiting vehicle checks to 2% instead of up to 10%, and advocates for a single-step communication of all engine certificates rather than repeated requests. They argue manufacturers cannot exclusively handle verification and correction of cryptographic hash data.123
Why — This would reduce administrative burden from multiple verification processes already required.4
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Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

19 Feb 2020 · Digitalisation & mobility,, ITS standards, data sharing, eprivacy, cybersecurity, cooperative, connected & automated mobiliy (CCAM)

Response to Climate Law

4 Feb 2020

Dear colleagues, please find attached consolidated ACEA contribution to the Green Deal and Climate Law roadmap.
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Meeting with Frans Timmermans (Executive Vice-President)

31 Jan 2020 · Green Deal and car industry

Meeting with Phil Hogan (Commissioner)

31 Jan 2020 · Trade Issues

European auto industry seeks exemption from new circular economy rules

20 Jan 2020
Topic — EU consultation on new Circular Economy Action Plan for sustainable resource use.
Message — ACEA requests that vehicles be exempted from new circular economy measures, arguing existing legislation already works well. They want recognition that the automotive sector already achieves high recycling rates and should not face double regulation.12
Why — This would shield them from additional regulatory requirements and compliance costs.3
Impact — Environmental advocates lose leverage to push stricter sustainability standards for vehicles.
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

18 Dec 2019 · Green Deal and car industry

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan)

17 Dec 2019 · Priority concerns of the ACEA

Meeting with Henrik Hololei (Director-General Mobility and Transport)

27 Nov 2019 · automotive

Auto industry urges延續 lead exemptions for electronics and glazing

20 Nov 2019
Topic — EU consultation on extending exemptions for lead use in vehicle components.
Message — ACEA requests continuing entry 8(g) unchanged until 2024 review and a new entry 8(k) for laminated glazing soldering. They argue lead remains essential for high-reliability automotive electronics with 15-year lifespans and 30,000 operating hours. Lead-free alternatives lack sufficient field experience and industrialization for mass production.1234
Why — This gives them more time to develop alternatives without risking field failures in safety-critical systems.56
Impact — Environmental groups lose faster phase-out of lead in vehicles and stronger recycling standards.7
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Response to Requirements for the type-approval of motor vehicles and trailers, systems, components and separate technical units

9 Nov 2019

ACEA welcomes the draft as it implements the requirements and answers many questions about the implementation of the new Framework Regulation. We have several comments on the draft we summarized in 3 documents related to: 1. Clarification needed about the requirements that apply as from 01/09/2020 2. Comments on the Annexes 3. Specific comments and proposals on the CoC Attached are the 3 documents containing the comments and proposals from our members.
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Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

7 Nov 2019 · Mobility in Europe - Introduction of ACEA Manifesto

Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

17 Oct 2019 · exchange of views on the latest developments in climate policy / road transport

Meeting with Sabine Weyand (Director-General Trade)

15 Oct 2019 · EU-US relations, Mercosur, Chine, EU Steel safeguard, Algeria

Meeting with Henrik Hololei (Director-General Mobility and Transport)

14 Oct 2019 · ACEA manifesto

Meeting with Margrethe Vestager (Commissioner) and Bureau Européen des Unions de Consommateurs

2 Oct 2019 · Roundtable to exchange on clean and smart mobility

Meeting with Michele Piergiovanni (Cabinet of Commissioner Margrethe Vestager)

20 Sept 2019 · Preparation for Roundtable

Automakers seek fair treatment for heavy vans in CO2 rules

10 Sept 2019
Topic — Amendment to EU regulation on CO2 measurement and reporting for light commercial vehicles.
Message — ACEA requests changes to ensure N1 vehicles with reference mass between 2,380-2,610 kg receive fair treatment. They argue the proposed approach would artificially change CO2 targets from 2021 by excluding these vehicles from 2020 baseline calculations while counting them for 2021 compliance.12
Why — This would prevent artificial tightening of their CO2 targets and maintain competitive fairness.34
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Auto industry urges technical fixes for 2020 emissions reporting

10 Sept 2019
Topic — EU regulation on reporting CO2 emissions from new passenger cars in 2020.
Message — ACEA proposes technical improvements and corrections to how CO2 emissions are calculated and reported for hybrid electric vehicles. They seek clarifications on testing procedures and reduced administrative burden for data submission.123
Why — This would reduce compliance costs and administrative burden for vehicle testing and reporting.4
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Auto industry seeks relief from retroactive CO2 data requirements

21 Aug 2019
Topic — Implementation rules for heavy-duty vehicle CO2 emissions monitoring and reporting requirements.
Message — ACEA requests clarity on retroactive data requirements and opposes requiring manufacturers to re-run simulations for vehicles processed before October 2019. They want the Commission to consult manufacturers before adjusting any data, arguing retroactive requirements contradict better regulation principles and impose substantial costs.123
Why — This would avoid costs from re-running simulations for thousands of vehicles.45
Impact — Environmental oversight is weakened if incomplete data prevents verification of emissions accuracy.6
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Response to Amendment to the emissions type approval testing for heavy-duty vehicles with portable emissions measurement systems

14 Jun 2019

On behalf of the European manufacturers of light and heavy-duty vehicles and engines impacted by the Euro VI emission legislation, ACEA is grateful to the Commission for finally bringing forward a proposal to address certain technical requirements in a new & final Euro VI step. ACEA provides the following key observations and attached file which contains a full detailed review of the Commission proposal for the Act & the Annexes – essentially how the Commission and the member states should change the proposal before it is decided in the Technical Committee Motor Vehicles (TCMV). Otherwise, we fear the text as proposed will not enable a consistent interpretation and application of the new regulation. It is vital that all EU approval authorities and all stakeholders have a common & clear regulatory text to work from – disputes in interpretation simply waste time and effort. COM interpretation notes will be the consequence if our constructive input is not seriously considered before a decision in TCMV. Clear & unambiguous regulation is even more important since this EU regulation will be transposed into UNECE Regulation No. 49 for use in many Contracting Parties outside the EU. Key issue - Article 1 point 11 (amending Article 17a): The proposal seeks to set the date of implementation of the complete new Regulation to vehicles with diesel & gas engines & such engines as from 1/1/21 for new types & 1/1/22 for all types. The proposal also recognizes that gas engines require more time to comply with the PN conformity factor for ISC testing so it provides a derogation, in effect a further regulatory sub-step for gas engines, that is proposed to be applicable from 1/1/23 for new types & 1/1/24 for all types of type 1a and 1b gas engines. However, any gas engines approved earlier than the derogated dates must still record a PN conformity factor. The proposed application dates for gas engines (the derogation dates) are appropriate and are appreciated. The foreseen development and engineering changes necessary for the product sign-off of new heavy-duty vehicles & engines to comply with this proposal have been explained by each manufacturer directly to the Commission & the readiness of manufacturers is not consistent. When we consider when this new Regulation might be published, i.e. possible decision in TCMV on 4 July, scrutiny of European Parliament & Council, publication is foreseen around end-2019 or in early Q1 2020. That then gives manufacturers only one year – that is not enough for a sound development process according to industry standard quality assurance programs & other requirements, such as product liability law, which requires industry to implement a strict product validation process. The dates of 1/1/21 & 1/1/22 set unrealistic application dates in relation to what all manufacturers must do to comply and sign-off new products. ACEA had previously requested dates for diesel engines at 1/9/21 (new types) 1/9/22 (all types) – that was our view in December 2018 but the proposal is delayed a further 6 months. Therefore, ACEA recommends the first dates to be moved to no earlier than 1/9/21 and 1/9/22. If a manufacturer would be ready earlier then he may choose to approve earlier – that is competition. Key issue - Article 1 point 11 (Article 17a derogation dates - gas engines): The proposed Table 1 Appendix 9 to Annex I of Regulation 582/2011 introduces a new row for Step E. However, while the table may cover all requirements, it does not specifically identify gas engines taking advantage of the derogation for PN - necessary for ISC. These gas engines would be Step E from [21/22] and will still be Step E from 23/24, but updated. So it would make sense to use “E” in two ways: “E” to identify what is applicable to diesel engines from 21/22 and to gas engines from 23/24 and “E-Temp” “to identify what is applicable to gas engines from 21/22. We therefore request these changes be made & the changes proposed in the attached file.
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Meeting with Timo Pesonen (Acting Director-General Internal Market, Industry, Entrepreneurship and SMEs)

14 Jun 2019 · Discuss common priorities for the future of Automotive industries and the EU Commission

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström)

24 May 2019 · EU-US relations; Mercosur negotiations; steel safeguards

Response to Commission Regulation amending Annex XIV to REACH

20 May 2019

ACEA, European Automobile Manufacturers' Association, would like to take this opportunity to highlight our concerns regarding the inclusion of ADCA in the proposal to amend Annex XIV of Regulation 1907/2006. ADCA is a blowing agent that decomposes at approximately 200°C during manufacturing of plastic and rubber parts. Traces of unreacted ADCA in quantities below < 0.1% might remain. Those reaming particles are always strongly bounded inside the matrix of parts and consequently are not bioaccessible during the normal use of articles. The potential risk of using of ADCA is then strictly limited to industrial sites. We believe that alternative policy measures should be considered to boost ongoing efforts to minimize exposure in the workplace. We consider that the introduction of an Occupational Exposure Limit (OEL) is the most optimal Risk Management Option. In the automotive sector, ADCA is widely used to produce the plastic and rubber parts, such as trims, coated fabrics, sealing gaskets, noise and vibration reduction. The listing ADCA on Annex XIV would have the economic impact on not only automotive manufacturers, but also the manufacturers, including SMEs, of plastic and rubber parts. And it may cause delocalizing activities, with new investments and updates of equipment being focused outside the EU. Therefore ACEA calls for - The European Commission to set all the necessary steps to establish an Occupational Exposure Limit value at European Level. - The REACH Committee to support the exclusion of ADCA from Annex XIV. In addition, ACEA also requests the derogation for the use of the substance in the production of spare parts for vehicles that are no longer in serial production. Because only limited testing for potential alternatives is possible for legacy spare parts. Comprehensive system and vehicle testing is not possible for these types of parts, as the vehicles they will be used in are no longer in production. Without the requested derogations, the supply of legacy spare parts will be severely compromised, which is in strong contradiction to the overall strategic goals of the circular economy. The automotive industry has a responsibility to its customers to support the longevity of their current vehicles by ensuring that these products can be serviced, repaired and maintained in such a manner as to not be detrimental to their function, safety and reliability. Extending the lifetime of a vehicle is essential to reducing costs for consumers, as well as conserving natural resources and energy.
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Meeting with Miguel Arias Cañete (Commissioner) and ASOCIACIÓN ESPAÑOLA DE FABRICANTES DE AUTOMÓVILES Y CAMIONES

8 May 2019 · Latest developments in the EU in the field of Mobility

Meeting with Léon Delvaux (Cabinet of President Jean-Claude Juncker)

6 May 2019 · Ongoing trade negotiations

Response to Evaluation of the Motor Vehicle Block Exemption Regulation

18 Mar 2019

The European Automobile Manufacturers' Association (ACEA) represents the 15 major Europe-based car, van, truck and bus makers: BMW Group, CNH Industrial, DAF Trucks, Daimler, Fiat Chrysler Automobiles, Ford of Europe, Honda Motor Europe, Hyundai Motor Europe, Jaguar Land Rover, PSA Group, Renault Group, Toyota Motor Europe, Volkswagen Group, Volvo Cars, and Volvo Group. ACEA considers that the Block Exemption Regulations applying to the automotive sector (Regulations 461/2010 and 330/2010) have been very effective in making the distribution and servicing of motor vehicles more efficient and in promoting competition and innovation to the benefits of consumers. These Regulations have made it possible for vehicle manufacturers to optimise the organisation of their networks in a manner that combines network efficiency with customer convenience. This is due mostly to the significant flexibility that these Regulations offer to vehicle manufacturers to determine the structure of their networks. This has made it easier to manage dealer networks and to adapt them on an ongoing basis to technological developments and to changing customer expectations in terms of quality and services. This contrasts with the previous sector-specific Regulation 1400/2002, which contained various provisions protecting dealers, thus letting the interest of individual dealers prevail over the efficiency of networks as a whole and over the pursuit of effective competition. Therefore, we see no valid reason to re-introduce contract law provisions in EU competition law nor to treat motor vehicles differently from other products in terms of sales agreements. The flexibility provided by the current Regulations will continue to be of crucial importance having regard to the rapid evolution of automotive products and services, particularly in terms of electrification and digitalisation, and the changing needs and expectations of our customers. ACEA therefore believes that the principles set forth in Regulations 330/2010 and 461/2010 should be maintained without fundamental changes. Nonetheless, the legal certainty of the current framework could be increased by including certain provisions of the Guidelines in the actual Regulations. In the same vein, the text of the Guidelines could be amended to reflect the competitive situation in the aftermarket as well as recent developments in EU case law, notably with respect to sales on online marketplaces.
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Response to Evaluation of the 2011 White Paper on Transport

7 Mar 2019

European Automobile Manufacturers’ Association (ACEA) thanks Commission’s DG Move for the publication on 7 February 2019 of the Evaluation Roadmap and welcomes the invitation to stakeholders to provide their views. The attached paper highlights several key considerations for DG Move to take into account when preparing an evaluation of the 2011 White Paper on Transport Policy. A more comprehensive paper on these and other topics on Transport Policy is currently under preparation in ACEA and will be ready for the 12-week public consultation that the Evaluation Roadmap is announcing.
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Auto industry seeks tech flexibility in C-ITS regulation

7 Feb 2019
Topic — EU regulation on deployment and operational use of cooperative intelligent transport systems.
Message — ACEA requests technology neutrality, allowing market-driven choices for C-ITS communication technologies. They want participation in expert groups and clearer definitions of key terms like C-ITS stations and operators. The industry seeks urgent clarification on data protection legal basis and opposes mandatory Common Criteria certification for entire C-ITS stations.123
Why — This would reduce compliance costs and preserve flexibility for over-the-air software updates.456
Impact — Road safety advocates lose standardized security requirements for connected vehicle systems.7
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Response to Sustainability requirements for batteries

5 Feb 2019

ACEA acknowledges the Commission’s efforts to establish an innovative and competitive European battery value chain and to foster safe and efficient development and use, together with high sustainability requirements for batteries placed on the EU market. However, ACEA would like to express its concerns regarding the intended regulation of batteries and accumulators used in electric vehicles under the ecodesign framework. Sustainability requirements of Batteries placed on the EU market are already addressed and regulated within the framework of Directive 2006/66/EC, including obligations for recycling quota and extended producer responsibilities. These requirements are expected to be strengthened and extended (i.e. re-use, remanufacturing, or 2nd-life applications) with the ongoing revision of this directive. Batteries are further regulated by the ELV Directive, which currently is also under review. Any double regulation or further overlap between both these Directives and the ecodesign Directive should be avoided as it would inevitably lead to increased administrative burden to both the European automotive industry and batteries industry. ACEA furthermore believes that the intended regulation of electric vehicle batteries under the ecodesign Directive 2009/125/EC is legally doubtful as Article 1 (3) stipulates that the Directive does not apply to means of transport for persons or goods. Consequently, in the FAQ of the Directive it is stated that “It follows that an implementing Regulation should not apply to products that are designed only for use in a means of transport for persons or goods” (Q21). Regarding increased energy efficiency measures and durability of electric vehicle batteries, ACEA would like to point to the competitive nature of these criteria which are market- and customer-driven and are therefore pointless to regulate. Any design-related requirement would hinder technological innovation and neutrality, which are essential elements for the development of a technology which is currently in its infancies but undergoes a major ramp up. Despite the Commission’s activities to establish European battery production capabilities, it is economically vital to keep battery value chains global. A responsible regulation must therefore address sustainability requirements that apply to raw materials, components and batteries manufactured and recycled beyond the European boundaries. ACEA is concerned that ill-defined measures, like the prescriptive PEF methodology, could become a major trade barrier for the sourcing of automotive batteries. The automotive industry acknowledges the merits of LCA as a voluntary method to assess the environmental profile of a vehicle across its entire life cycle and to support target-oriented product development. However, the LCA approach is intended for internal purposes only and shall not be used for comparison of automotive products from different manufacturers. ACEA supports the development and implementation of sustainability aspects to improve the social, ethical and environmental performance of automotive supply chains. Since 2012, 10 leading automotive companies are pro-actively developing the highest standards to improve sustainability in the global automotive value chains. Those activities, coordinated by CSR Europe, already include the sourcing of raw materials for batteries (https://drivesustainability.org/).
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Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

25 Jan 2019 · CO2 proposal for HDV’s

Response to Commission Implementing Act on on-board weighing equipment

18 Jan 2019

Ladies and Gentlemen, We thank DG MOVE for the opportunity to comment the Implementing Act draft in addition to the work done before in the expert group and would like to comment on the issues below. Please find attached the file with our comment.
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Meeting with Cecilia Malmström (Commissioner)

7 Dec 2018 · EU-US trade relations

Response to Evaluation of the Industrial Emissions Directive

4 Dec 2018

ACEA welcomes the activity of the European Commission to give a feedback to the roadmap on the IED REFIT. With regards to the roadmap ACEA has identified 3 key points that are relevant for its effective process. • The BREF review process appears to penalise proactive contributions. Where sectors have made significant contributions they appear to have become the focus and have received more BAT-AELs than those which have provided less contributions. The process does not promote proactive behaviour. • There are inherent flaws in the BREF review / BAT-AEL process. The questionnaires provide evidence of day to day operations. Achievable operational levels should not be applied as BAT-AELs. No site should be operating at their emission limit value as a general rule and Operators would always aim for a level of comfort between their achievable level and their emission limit. Reporting values to the Author team in questionnaire responses could be at or close to process design. Where these are then used as BAT-AELs there may not be any technical options left for Operators to further improve their performance and retain a level of comfort from the stated BAT-AEL. • Although the BREFs (and the IED process) take cross media effects into account, they do not necessarily consider cross-policy or wider (societal, economic etc.) impacts into account. Industrial emissions have reduced dramatically over the years and, whilst industry will continue to work hard to minimise its environmental impact, focus needs to incorporate other sectors, both in considering the direct impact of each sector and the combined effects of sector policies. Furthermore, ACEA considers that some additional points should be highlighted by questions in order to collect more information on particular issues: • Chapter effectiveness - BREF elaboration process, and BAT conclusion: This process has to be checked in detail and shall include a focus on cross media effect (definition, integration in BAT definition: example VOC emission and CO2 emission in STS BREF) • Chapter efficiency - Difference between MS implementation: Focus on base report, and transposition into Member States regulation (scope of the base report, installations concerned, update of the base report) • Chapter coherence - This complex chapter has to be reinforced with questions to address the topics (1) Consistency with transversal BREFs and (2) the scope of application of different BREFs (example separation between STM and STS BREF)
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Response to Urban Mobility in the EU

3 Dec 2018

KEY RECOMMENDATIONS FOR SUSTAINABLE URBAN MOBILITY: 1. Acknowledge that efficient mobility and transport is a fundamental requirement of cities: policies should aim at improving traffic fluidity rather than at restricting it 2.Ensure that all proposed policy initiatives are mode neutral, cost-effective and coherent with other targets 3.Implement and promote technologically neutral policies in order to avoid market fragmentation and misallocations of resources; none of the technical options should be discarded in cities as this reduces the potential for overall technological progress 4.Promote an integrated approach involving all stakeholders (local governments, local business community, citizens, public transport providers, automotive industry) for a safer, cleaner and more efficient mobility 5.Develop new interconnections with other modes, integrated with other public modes and innovative public transport concepts that include flexibility, quality, efficiency and affordability 6.Provide supportive local policy framework and private-public partnerships for companies to launch innovative business models and new urban mobility technologies 7.Evaluate all the existing solutions –including the many simple, inexpensive ones–for improving urban safety and environment. Prioritise the most cost-effective 8.Encourage measures that promote optimised vehicle use, including car-sharing 9.Encourage fleet renewal for cleaner and safer vehicles while maintaining their affordability 10.Reassess existing Access Restriction Schemes (ARS)to ensure they are fair and justified and are based on maximum harmonisation, simplicity, stability, integration and acceptability 11.Use the vehicle emissions standards in force as a basic criterion for granting access or determining the size of fees where Low Emission Zones (LEZs) are in place 12.Promote ITS through harmonisation of systems and development of infrastructure 13.Define common standards to facilitate the introduction of new technologies and services
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Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and

15 Nov 2018 · Possible safeguards

Meeting with Tomas Nejdl (Cabinet of Commissioner Corina Crețu)

12 Nov 2018 · Implementation of the European Battery Alliance and regional development

Meeting with Xavier Coget (Cabinet of Vice-President Jyrki Katainen)

5 Nov 2018 · Exchange on EU safeguard measures on steel and cooperation with China on car standards

Response to Legislation on end-of-life vehicles - evaluation

30 Oct 2018

Mandatory dismantling To achieve both separation of SVHCs from the ELV waste stream and provision of certain materials for further recycling, the Automotive Industry (AI) proposes the application of available post shredder technologies (PST) rather than making the dismantling of parts mandatory. This applies not only to plastics but also to electronic parts, which content of precious metals decreased significantly in the past. The high and in most parts unnecessary effort for deep manual dismantling would jeopardise the profits of legally-operated authorised treatment facilities (ATF) and expose the sector to the risk of an increasing number of illegal operators, thus having the opposite effect than intended. Extended Producer Responsibility (EPR) The AI is assuming successfully its EPR by setting up systems for the take back of ELV free of charge for the last owner. The responsibility of ELV treatment is shared between the different economic operators: • Manufactures/Importers set up take back systems, provide information about recycling and dismantling, reduce the amount and number of hazardous substances while improving and certifying the recyclability of vehicles • Last owners have the obligation to deliver ELV to ATF • ATF take back ELV, depollute them and monitor recycling • Authorities provide licenses to ATF, manage the registration/deregistration system and enforce regulation, eg close illegal ATF Key success factors of an improved EPR scheme are the development of a central database for registration/deregistration of vehicles in all MS, but not the creation of any fund-system to financially incentivize last owners or treatment operators. Unknown whereabouts The Automotive Industry considers the problem unknown whereabouts a statistical gap. It is important to make a distinction between ELV, which are hazardous waste and “used vehicles”, which are a product. In Europe, mostly used or deregistered cars are exported and that is not an illegal activity but following the principles of free trade of goods. An introduction of additional legal requirements would become obsolete if authorities enforce or strengthen the existing system for issuing CoD to improve statistical data sources. Another useful measure is the introduction of penalties (eg continuation of taxes and/or yearly registration fee, limiting temporarily deregistration) when CoD haven’t been issued or used properly. Material specific recycling quota and recycled content Based on the current practice the automotive recycling chain is already achieving outstanding recycling results. Material recycling of about 85% for one of the most complex consumer products serves as proof for an environmentally sound treatment of ELV. Therefore, it is understood that material specific recycling targets will not provide any improvement for the overall quota nor for the environment. Moreover, it must be assumed that both the measurement and monitoring of material specific quota will be methodologically and technically very challenging and economically questionable. Material restriction - Overlap with other legislation The AI is concerned about the fact, that the restriction of substances in vehicles is regulated by an increasing number of overlapping legislation (eg ELV, RoHS, REACH, POP) considering different scopes, exemptions and introduction dates. Generally, the “repair as produced” must be always considered and the introduction of new substance restrictions must be linked to the type approval process. Socio-economic aspects must become accepted assessment criteria for section specific exemptions. EU added value Adding costs to the European ELV recycling process, which is one of the most advanced and effective processes globally, may further reduce competitiveness of the European ATF, mainly SME. This may even increase the tendency to export used vehicles to other non-EU regions and may table the question on added value as an EU Member State.
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Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

22 Oct 2018 · Safeguard measures / steel tariffs

Response to Cars correlation procedure — transitional rules on test conditions and results

16 Oct 2018

The views of ACEA to the public consultation are shown in the attached document which makes reasonable and practical drafting proposals directly in the Commission proposal, supported by an explanatory note at the end of the document. The comments provided to the proposal to amend Regulation (EU) 2017/1153 (passenger cars) are also applicable, in general to Regulation (EU) 2017/1152 (light-commercial vehicles) with some further checking in respect of Class III light-commercial vehicles.
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ACEA Demands More Time for Truck CO2 Reporting Changes

10 Oct 2018
Topic — The European Commission is updating technical rules for heavy-duty vehicle CO2 emissions.
Message — The association seeks sufficient lead times for updating manufacturing IT systems. They also urge removing the 'grams per kilometer' metric to avoid misleading customers.12
Why — Extending the implementation deadline would lower immediate compliance and technical infrastructure costs.3
Impact — Environmental progress suffers if misleading metrics encourage buyers to choose less efficient vehicles.4
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Meeting with Matej Zakonjsek (Cabinet of Commissioner Violeta Bulc)

20 Sept 2018 · mobility package

Response to Evaluation of EU legislation on design protection

31 Jul 2018

The European automobile manufacturers believe that the review of this Directive should in no way lead to the removal of design rights for spare parts that exist in the EU today. In our view, abolishing such rights would: - Deprive an innovative industry of a proper return on its investment Vehicle manufacturers design, develop, engineer and test vehicles and parts. They set up a complex logistics and distribution system for their products and make spare parts available until ten years after the end of production of the vehicle. Copiers take a free ride on these investments: they simply reverse engineer and sell the most profitable parts for as long as they are in demand. This is unfair competition. - Threaten European competitiveness and jobs The parts affected by these rights (bonnets, bumpers, radiator grilles, wings, doors, lights) are almost exclusively produced by vehicle manufacturers in Europe today. If copying were permitted, an estimated 50,000 jobs would be lost to large copiers in Asia. This would undermine the competitiveness of the European automobile industry. - Contradict the EU's own IPR policy Abolishing design rights that currently exist in a majority of Member States conflicts with the EU's efforts to combat counterfeiting and piracy, both in Europe and elsewhere. The EU is neither credible nor consistent when it tells the Chinese not to copy European products but permits the copying of parts within Europe. - Undermine vehicle safety Before they can be put on the market, vehicles and their component parts must meet an impressive series of technical requirements. Safety tests are an important part of this. However, the EU has absolutely no safety requirements in place for after-market parts. Clearly, a repaired vehicle must be as safe as one that is new. - Bring no consumer benefits The abolition of design rights for spare parts will not lead to lower consumer prices. Authoritative studies have shown that on average, parts prices are actually higher in Member States without design protection than in Member States with design protection. Any profits or cost savings that could result from the use of potentially cheaper copy parts are likely to end up in the pockets of parts traders, repairers or insurance companies. There is no consumer benefit when money is simply being shifted from one industry sector to another.
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Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

19 Jul 2018 · Mobility proposals

Response to REFIT review of the Motor Insurance Directive

13 Jul 2018

The European automobile manufacturers are highly concerned about the proposed definition of “use of a vehicle” in article 1. We see a risk that this definition could lead to a situation whereby vehicles that are still under the ownership and control of the vehicle manufacturer, importer or distributor and that have not yet been sold to a final customer would have to be insured against third-party liability. We feel this is both unreasonable and unnecessary. It is unreasonable because it could potentially oblige the companies concerned to take out insurance for millions of individual vehicles that are under their control between the time of production and the time of sale. The administrative burden would be tremendous. It is unnecessary because these companies today have commercial insurance that can cover any damage caused by a vehicle to a private person. It would also complicate the sales process in that the seller would have to cancel his insurance contract at the same time when the buyer would need to sign a new insurance contract to be able to register and drive the car. In our view, the scope of the motor insurance Directive should not be extended to cover such cases. Insurance against third-party liability should remain limited to vehicles that have been registered for use on public roads.
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Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

26 Jun 2018 · US Section 232 / EU Safeguard investigation

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and

26 Jun 2018 · steel safeguard

Meeting with Miguel Arias Cañete (Commissioner)

5 Jun 2018 · Mobility Package in Europe

Meeting with Cecilia Malmström (Commissioner)

5 Jun 2018 · current trade issues

Meeting with Carlos Moedas (Commissioner) and

5 Jun 2018 · Horizon Europe and Mobility

Auto industry opposes one-size-fits-all EU circular economy product rules

3 Jun 2018
Topic — EU framework for product policy contributing to the circular economy.
Message — ACEA demands a sector-specific approach for vehicles, arguing they should be regulated as complete products within dedicated frameworks rather than as collections of parts. They oppose design-for-recycling requirements as obsolete given modern sorting technologies.12
Why — This would preserve their existing regulatory framework and avoid new design requirements.34
Impact — Environmental advocates lose stronger circular economy standards across product categories.5
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Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

22 May 2018 · Low-carbon mobility

Meeting with Jean-Luc Demarty (Director-General Trade)

22 May 2018 · Automotive: Japan, Mercosur and Mexico

European Automakers Seek Brexit Type-Approval Grace Period

9 May 2018
Topic — EU regulation addressing vehicle type-approval validity after UK withdrawal from the EU.
Message — ACEA requests that vehicles with UK-issued certificates remain valid after Brexit and that the regulation stay in force until end of 2020. They want exemptions for parts in stock and continued use of UK technical services.123
Why — This avoids costly re-homologation and protects their ability to sell existing vehicle stock.45
Impact — UK manufacturers lose automatic EU market access without reciprocal recognition arrangements.6
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Meeting with Manuel Nobre Goncalves (Cabinet of Commissioner Carlos Moedas)

27 Apr 2018 · Auto

Meeting with Manuel Nobre Goncalves (Cabinet of Commissioner Carlos Moedas)

27 Apr 2018 · CO2 emission standards for heavy-duty vehicles

Response to NEDC/WLTP correlation procedures - VANS

11 Apr 2018

ACEA and its members welcome the present publication and would like to address, in the attached document, the issues we have noticed. We believe the proposed changes are solving all those issues, and we are eager to engage with the Commission for further explanations if needed. All our comments being valid for both cars and vans regulations the same document is uploaded to both replies to the public consultation.
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Response to NEDC/WLTP correlation procedures - CARS

11 Apr 2018

ACEA and its members welcome the present publication and would like to address, in the attached document, the issues we have noticed. We believe the proposed changes are solving all those issues, and we are eager to engage with the Commission for further explanations if needed. All our comments being valid for both cars and vans regulations the same document is uploaded to both replies to the public consultation.
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Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker) and MAN Truck Bus SE

11 Apr 2018 · Climate Change and Clean Mobility

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström)

10 Apr 2018 · Steel tariffs

Response to Improving the emissions legislation for Light Duty Vehicles

5 Apr 2018

Part 2/3 In completion to feedback part 1/3, the attached document deals with comments to the proposed elements for the fourth RDE package.
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Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

14 Mar 2018 · Cooperation of car producers and cities on access restrictions

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska)

14 Mar 2018 · Urban Access Restrictions (meeting organized by CAB VP Katainen)

Meeting with Miguel Arias Cañete (Commissioner) and Mercedes-Benz Group AG and

19 Feb 2018 · Cars, CO2 standards

Meeting with Elżbieta Bieńkowska (Commissioner) and

19 Feb 2018 · Upcoming discussion for CO2 targets on heavy duty vehicles

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

30 Jan 2018 · 3rd Mobility Package

Auto industry urges relaxation of fuel monitoring rules

5 Jan 2018
Topic — New EU requirements for on-board fuel and energy consumption monitoring devices.
Message — ACEA requests removing the 4% accuracy requirement, which they say is unachievable, and excluding accuracy checks from production testing. They want terminology changed from 'measuring' to 'estimating' fuel consumption since vehicles don't actually measure it. They seek clarity on definitions and reduced administrative burden.123
Why — This would avoid costly production halts and vehicle recalls for failing accuracy tests.45
Impact — Consumers and policymakers lose accurate real-world fuel consumption data for monitoring purposes.
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Meeting with Alina-Stefania Ujupan (Cabinet of Commissioner Mariya Gabriel)

27 Nov 2017 · Smart Mobility

Meeting with William Neale (Cabinet of Vice-President Karmenu Vella) and RENAULT and Peugeot S.A.

23 Oct 2017 · Automobile post-2021 CO2 regulation

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič), Ivo Schmidt (Cabinet of Vice-President Maroš Šefčovič)

13 Oct 2017 · Mobility package

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

12 Oct 2017 · data economy (access to vehicle data) ; cyber security; EECC (telecoms framework);ePrivacy ; global roadmap CCAM (incl. Funding approach)

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

21 Sept 2017 · Industrial policy

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska)

21 Sept 2017 · European automotive industry

Meeting with Günther Oettinger (Commissioner)

6 Sept 2017 · connected and automated driving

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

6 Sept 2017 · Preperation for IAA visit VP Sefcovic

Meeting with William Neale (Cabinet of Vice-President Karmenu Vella)

20 Jul 2017 · Urban emissions

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

20 Jul 2017 · Car urban emissions

Meeting with Christian Linder (Cabinet of Vice-President Maroš Šefčovič)

20 Jul 2017 · Urban emissions

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

12 Jul 2017 · IAA Fra, CO2 regulation, GEAR

Meeting with Miguel Arias Cañete (Commissioner)

6 Jul 2017 · on the post-2020 CO2 Regulations for cars and vans.

Meeting with Jyrki Katainen (Vice-President) and

6 Jul 2017 · Decarbonisation of transport

Meeting with Günther Oettinger (Commissioner)

26 Jun 2017 · connected and automated driving

Meeting with Jos Delbeke (Director-General Climate Action)

24 May 2017 · Mobility package

Meeting with Henrik Hololei (Director-General Mobility and Transport)

24 May 2017 · Alternative fuels, clean vehicles, connected and automated driving

Meeting with Jocelyn Fajardo (Cabinet of Commissioner Violeta Bulc)

22 May 2017 · Mobility package

Meeting with Lowri Evans (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

22 May 2017 · The meeting addressed a range of current issues in the field of the automotive and mobility industries.

Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc)

8 May 2017 · Meeting with Erik Jonnaert

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

4 May 2017 · Decarbonisation of Transport

European Auto Industry Backs Lead Battery Exemptions

13 Apr 2017
Topic — Amendment to End-of-Life Vehicles Directive regarding heavy metal restrictions.
Message — The associations support the draft amendment and request extended review periods for lead exemptions. They propose changing review timelines to four years for most entries and seven years for aluminum alloys, measured from publication rather than entry into force. They also seek terminology corrections to avoid confusion.123
Why — This gives them more time for R&D on alternatives while maintaining current production systems.456
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Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

6 Apr 2017 · Heavy Duty Vehicles

Meeting with Manuel Nobre Goncalves (Cabinet of Commissioner Carlos Moedas) and Volvo AB

10 Mar 2017 · Annual EUCAR Reception

Meeting with Jos Delbeke (Director-General Climate Action)

13 Feb 2017 · Low-carbon mobility

Meeting with Elżbieta Bieńkowska (Commissioner) and

8 Feb 2017 · GEAR, CO2 Standards, Future of Diesel, RDE, Automation/Connectivity, GSR

Meeting with Maroš Šefčovič (Vice-President) and

8 Feb 2017 · Annual reception 2017

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

6 Feb 2017 · Decarbonisation of Transport

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič), Christian Linder (Cabinet of Vice-President Maroš Šefčovič)

3 Feb 2017 · Preperation of ACEA Annual Reception 2017

Meeting with Martin Übelhör (Digital Economy)

14 Dec 2016 · connected and automated driving

Meeting with Jon Nyman (Cabinet of Vice-President Cecilia Malmström), Maria Asenius (Cabinet of Vice-President Cecilia Malmström)

14 Dec 2016 · Japan negotiations

Response to Real-Driving Emissions in the EURO 6 regulation on emissions from light passenger and commercial vehicles (RDE3)

8 Dec 2016

#4. Detailed technical comments to the RDE3 proposal (Annexes) can be accessed at the following link: http://acea.be/uploads/publications/20161208_ACEA_technical_comments_to_RDE3.pdf
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Meeting with Violeta Bulc (Commissioner) and

6 Oct 2016 · Meeting with ACEA board members on the role of the car in the transport system of the future

Meeting with Violeta Bulc (Commissioner) and

6 Oct 2016 · Meeting with ACEA Board members

Meeting with Jos Delbeke (Director-General Climate Action)

6 Oct 2016 · Decarbonisation of road transport

Meeting with Miguel Arias Cañete (Commissioner)

6 Oct 2016 · Decarbonisation of road transport

Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)

16 Sept 2016 · data, standardisation, events

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

13 Jul 2016 · Prep meeting for High Level Mtg

Meeting with Inge Bernaerts (Cabinet of Commissioner Marianne Thyssen)

7 Jul 2016 · Occupational health and safety

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

6 Jul 2016 · follow up Acea meeting 30 June

Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc)

6 Jul 2016 · Introductory meeting with EUCAR Director

Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc)

4 Jul 2016 · Connected vehicles

Meeting with Günther Oettinger (Commissioner)

30 Jun 2016 · connected driving

Meeting with Elżbieta Bieńkowska (Commissioner) and

30 Jun 2016 · Future of the car industry, NOX emissions

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

27 Jun 2016 · Decarbonisation

Meeting with Henrik Hololei (Director-General Mobility and Transport)

27 May 2016 · Decarbonisation & Connected and Automated Driving

Meeting with Bodo Lehmann (Digital Economy)

8 Apr 2016 · connected and automated driving

Meeting with Tânia Frazão Nunes (Cabinet of Commissioner Carlos Moedas)

9 Mar 2016 · Discussion on research and innovation in the automotive sector with ACEA's R&D branch EUCAR (European Council for Automotive R&D)

Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc)

8 Feb 2016 · decarbonisation and dgitalisation of road transport

Meeting with Miguel Arias Cañete (Commissioner) and Honda Motor Europe

21 Jan 2016 · Decarbonisation of transport

Meeting with Jos Delbeke (Director-General Climate Action)

21 Jan 2016 · Decarbonisation of transport

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska), Tomasz Husak (Cabinet of Commissioner Elżbieta Bieńkowska)

12 Jan 2016 · Emissions and how to build the future for mobility connecting decarbonisation with digitalisation of transport solutions

Meeting with Eric Mamer (Digital Economy)

15 Dec 2015 · connected automated driving

Meeting with Henrik Hololei (Director-General Mobility and Transport)

5 Nov 2015 · ITS

Meeting with Lowri Evans (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

3 Nov 2015 · RDE, revision of type approval framework, gear 2030, CECRA, TTIP

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

30 Oct 2015 · Preparation for the meeting with the Board of ACEA

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

20 Oct 2015 · Decarbonisation of Transport, presentation of ACEA position on Commission's forthcoming paper on RDE, CoP21

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

19 Oct 2015 · Situation of car manufacturing industry

Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans)

9 Oct 2015 · Better Regulation agenda

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska)

8 Oct 2015 · Real Driving Emissions and Automated Driving

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

5 Oct 2015 · anti-dumping case on aluminium wheels

Meeting with Justyna Morek (Cabinet of Commissioner Elżbieta Bieńkowska), Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

29 Sept 2015 · Real Driving Emissions

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

16 Sept 2015 · Decarbonisation

Meeting with Eric Mamer (Digital Economy)

7 Jul 2015 · connected mobility

Meeting with Karl-Friedrich Falkenberg (Director-General Environment)

3 Jul 2015 · Air pollution

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

15 Jun 2015 · Competitiveness

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

15 Jun 2015 · Competitiveness

Meeting with Robert Madelin (Director-General Communications Networks, Content and Technology) and American Chamber of Commerce to the European Union and

3 Jun 2015 · New College and Better Regulation

Meeting with Karl-Friedrich Falkenberg (Director-General Environment)

28 Apr 2015 · RDE (Real Driving Emissions)

Meeting with Joao Aguiar Machado (Director-General Mobility and Transport)

13 Apr 2015 · White paper on Transport Policy, ITS & Connected Vehicles, Weights & Dimensions

Meeting with Miguel Arias Cañete (Commissioner) and

9 Apr 2015 · Decabornisation of Road Transport

Meeting with Daniel Calleja Crespo (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

7 Apr 2015 · AUTOMOTIVE INDUSTRY

Meeting with Jos Delbeke (Director-General Climate Action)

20 Mar 2015 · Transport conference and 2030

Meeting with Pierre Schellekens (Cabinet of Vice-President Miguel Arias Cañete)

19 Feb 2015 · Energy Union and Climate action

Meeting with Maria Da Graca Carvalho (Cabinet of Commissioner Carlos Moedas)

10 Feb 2015 · EUCAR (European Council for Automotive R&D) - New issues on simplification

Meeting with Jyrki Katainen (Vice-President)

4 Feb 2015 · Regulatory framework for automotive

Meeting with Günther Oettinger (Commissioner)

4 Feb 2015 · DSM

Meeting with Violeta Bulc (Commissioner)

4 Feb 2015 · Meeting with ACEA

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

21 Jan 2015 · Decarbonization

Meeting with Eric Mamer (Digital Economy)

14 Jan 2015 · Digital Single Market

Meeting with Daniel Calleja Crespo (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

4 Dec 2014 · Cars / RDE /WLTP / Framework Directive 2007/46/EC

Meeting with Carlos Moedas (Commissioner) and RENAULT

4 Dec 2014 · New technologies in the field of automotive, electric and connected vehicles in globalisation, EUCAR challenges.

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

1 Dec 2014 · Circular economy