Associazione Nazionale Filiera Industria Automobilistica
ANFIA
Anfia, Associazione nazionale filiera industria automobilistica, svolge da più di 100 anni la funzione di Trade Association come portavoce delle aziende italiane che operano ai massimi livelli nei settori della costruzione, trasformazione ed equipaggiamento degli autoveicoli per il trasporto individuale e collettivo di persone e di merci.
ID: 825545524163-39
Lobbying Activity
Response to Transitional measures for smart tachograph 2 regarding its use of OSNMA
7 Mar 2023
ANFIA (Italian Association of Automotive Industry) is the one of Italy's most important industrial sectors represent the Italian automotive industry (car designers, component manufacturers, light and heavy vehicle manufacturers, trailer manufacturers and bodybuilders). ANFIA would like to thank the European Commission for the possibility to express our views on the upcoming transitional measures regarding the introduction of new version of Smart Tachograph (G2V2). ANFIA is seriously concerned about the risks that: body builders and vehicle manufacturers will run due to excessive retrofitting costs and lack of certain delivery times, which could cause problems of quality and reliability of the products placed on the market. In particular, ANFIA does not understand why the manufacturers and body builders have to pay the consequences of problems beyond their control and predictable and correctable without financially burdening any of the parties involved. For this reason ANFIA, in collaboration with its associates, has carried out a cost analysis which it will find in the attachment and which highlights the critical points exposed. ANFIA is confident that the Commission will be able to objectively evaluate its requests and await the solutions that the Commission will find to economically and commercially protect all the parties involved.
Read full responseResponse to Development of Euro 7 emission standards for cars, vans, lorries and buses
9 Feb 2023
Please find ANFIA's feedback in the attached file.
Read full response19 Apr 2022
ANFIA would like to thank DG GROW for the Draft Commission Delegated Regulation amending Reg. (EU) 2018/858, in particular as regards the technical requirements for vehicles produced in small series.
Representing, among other automotive business companies, a few renowned Small Volume Manufacturers based in Italy, we would like to stress our comments on the Draft, especially with regards to Annex II where the relevant criteria to be eligible to apply for “Small series scheme I” (please refer to the explanatory notes to point (2), table 1) have been given.
ANFIA strongly believes that the overly simplified criteria (with respect e.g. to those specified, and having been applied for several years now, in the emissions legislation for Light Duty Vehicles, please refer to the details given in the footnote) do not respond to the needs of independent Small Volume Manufacturers whose operations are based in the EU.
The actual threshold (now set at 1,500 vehicles) risks to be counterproductive for the European industry.
ANFIA therefore supports alignment with the EU emissions legislation and calls on the Commission and on Member States to increase the threshold for “Small series scheme I” to a value of 10,000 vehicle registrations per year.
Footnote
Reg. (EU) 2017/1151 currently defines Small Volume Manufacturers (SVMs) as follows:
'Small volume manufacturers' means a manufacturer whose worldwide annual production is less than 10,000 units for the year prior to the one for which the type approval is granted and:
a) Is not part of a group of connected manufacturers; or
b) Is part of a group of connected manufacturers whose worldwide annual production is less than 10,000 units for the year prior to the one for which the type approval is granted; or
c) Is part of a group of connected manufacturers but operates its own production facilities and own design centre.
Read full response7 Dec 2016
The actual development of the RDE Legislation (RDE3) concerns two very critical issues for the automotive industry:
- PEMS-PN - The new requirements for fine particle number measurement into the regulations on real driving emissions.
- Cold-engine start - Inclusion of cold-engine start emissions in an RDE trip analysis for compliance.
These elements are additional with respect to the two RDE packages early adopted on which the Automotive Industry is already intensively working to adapt the vehicles. Therefore it is important to plan a correct timing of the two above-mentioned issues in order not to jeopardize the activities done so far for the first RDE packages; otherwise the Automotive Industry will be obliged to start again the development in order to take into account the new additional prescriptions on PEMS-PN and cold-engine start.
The impacts of these provisions on the vehicles design are very relevant.
PEMS-PN provisions will affect mainly the gasoline direct injection (GDI) vehicles. The addition of a particulate filter for GDI vehicles is not a simple addition. It requires to re-design the layout of the exhaust gas system and to develop a new engine calibration. The significant engineering and certification burden associated with these new necessities requires sufficient lead-time: first, the particle filter technology for direct injection gasoline engines still needs development; moreover, the level of maturity of the portable measuring instruments used for homologation is not yet adequate.
Cold-engine start provisions will be added on top of the already approved RDE regulation and without any change of the conformity factors. This new requirement introduces a new challenge both for diesel and gasoline engines. The technical solutions envisaged to meet RDE requirements with cold-engine start may impose modifications to the hardware of the emissions system with the introduction of additional devices and the development of new engines calibration strategy.
On the basis of the timetable proposed by the European Commission, these new provisions would apply from September 2017 for new vehicle types and from September 2018 for all new vehicles (one year more for heavier LCVs, due to the specific characteristics and configurations of these vehicles). Assuming the publication of RDE3 on May/June 2017, this timing would leave the Industry only 2/3 months for the new types and 14/15 months for all new vehicles.
ANFIA urges to consider the impacts of these requirements since we believe it is not possible to set them as mandatory on the proposed dates. Both requirements should apply in a longer timeframe and only for new vehicle registrations. In particular the cold-engine start provision, that impacts on all vehicle models and implies unbearable re-design effort, should have further extended application time, consistent with the concerned development and validation activities.
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