Comité des Constructeurs Français d'Automobiles
CCFA
Le CCFA a pour vocation l'étude et la défense des intérêts économiques et industriels de l'ensemble des constructeurs automobiles français
ID: 76702291980-77
Lobbying Activity
Response to 8th Amendment to Annex II to Directive 2000/53/EC on end-of life vehicles
18 Apr 2017
We CCFA believe that a continued exemption of at least 5 years for lead batteries is vital for future automotive applications, and support the submitted position of ACEA, JAMA, KAMA, EUROBAT and ILA.
Read full response8 Dec 2016
CCFA welcomes the 3rd RDE package as an important step to strengthen the RDE test procedure. However, industry needs a sufficient lead-time to adjust to legislative changes in its R&D activities, as well as for planning the manufacturing processes. This was recognized in RDE package 2 (Sept 2017/ Sept 2019), we urge for the same approach for RDE package 3.
Industry has already accelerated planning and make significant investment on the basis of the already two separate RDE Regulations (March/April 2016) in order to be ready in a very short time to make new models RDE compliant from September 2017.
It is regrettable that European Commission (COM) adopted a process for introducing this complex regulation in multiple steps and thus changing the targets for manufacturers each time. Proper planning by manufacturers to prepare for this new legislation is therefore an almost impossible task.
RDE package 3 introduces in particular PEMS PN measurement (to apply from September 2017 for new models and September 2018 for all new vehicles) that COM aims to have this agreed by the regulatory committee (TCMV) on 20 December. Assuming that scrutiny of the EP passes without problem, this indicates a publication date in April/May 2017. In this regard, COM is proposing major legislation that will give industry a very short lead-time to comply.
Considering all the new measures introduced by RDE Package 3, the COM proposal definitely does not provide sufficient lead-time absolutely needed by industry to address these new challenges.
Industry needs certainty of legislation, time to implement changes which have big implications for manufacturing, and it needs regulatory stability to generate a reasonable return on the major investments it must make.
Another major issue facing industry is the problem created by the WLTP regulation that enters into force from 9/17 (new models) and 9/18 (all new vehicles). It is essential that the WLTP regulation does not interfere with the dates that were agreed for RDE (i.e. 9/17 & 9/19) otherwise there would be major disruptions in the planning and manufacturing process for all manufacturers, as well as their suppliers.
Industry also requests the following points are achieved:
• Decision on RDE package 3 to be decided at TCMV on 20 December so that the legislation is fully complete, fully robust & fully accurate.
• No further tightening or changing of the RDE legislation except those steps already agreed or where the details of the regulation must be improved for robustness.
• Further adjustments on the RDE boundary conditions for LCV’s & other RDE issues to be tackled as mentioned in RDE2 should be addressed in RDE4 without delay.
• PN-PEMS instruments must improve and a suitable error margin greater than 0.5 must apply for PN instruments. All PEMS instruments should be approved & COM should take steps now to introduce a PEMS approval process that should be ready by end-2017.
• The quality of market fuels must be taken into account and improved to help reduce real driving emissions.
We trust we will get support from the legislators to ensure that we have the lead-time that we, and our suppliers, all need to start implementing the new RDE3 requirements on future vehicles.
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