OpenLobby.EU
Explore

European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers

EUROMOT

EUROMOT represents manufacturers of internal combustion engines and alternative powertrain technologies for diverse industrial applications.

Lobbying Activity

Response to Persistent organic pollutants: medium-chain chlorinated paraffins.

15 Dec 2025

See feedback attached. EUROMOT, the European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers, represents the key manufacturers of internal combustion engines and alternative powertrains installed in industrial non-road mobile machinery, marine and stationary applications that are operating in Europe and worldwide.
Read full response

Response to EU taxonomy - Review of the environmental delegated act

5 Dec 2025

EUROMOT, the European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers, represents the key manufacturers of internal combustion engines and alternative powertrains installed in industrial non-road mobile machinery, marine and stationary applications that are operating in Europe and worldwide. See attached our position on the Complementary Climate Delegated Act (CCDA), particularly regarding activities related to electricity generation and cogeneration using natural gas. Activities 4.29 and 4.30
Read full response

Response to Digital package – digital omnibus

13 Oct 2025

Please see EUROMOT feedback in the attached document. EUROMOT, the European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers, represents the key manufacturers of internal combustion engines and alternative powertrains installed in industrial non-road mobile machinery, marine and stationary applications that are operating in Europe and worldwide.
Read full response

Response to Review ecodesign electric motors and variable speed drives.

17 Sept 2025

Please see EUROMOT's feedback in the document attached. EUROMOT, the European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers, represents the key manufacturers of internal combustion engines and alternative powertrains installed in industrial non-road mobile machinery, marine and stationary applications that are operating in Europe and worldwide.
Read full response

Response to Sustainable transport investment plan

3 Sept 2025

See feedback attached.
Read full response

Response to Omnibus Directive Aligning product legislation with the digital age

28 Aug 2025

EUROMOT welcomes the consultation on the EC proposal for an Omnibus Directive Aligning product legislation with the digital age and also pleased to have the opportunity to submit our contribution regarding Article 2 of the proposal amending Directive 2011/65/EU (RoHS). We fully support the transition towards digital documentation and procedures. However, we wish to express our concerns regarding the introduction of Article 16a, which proposes the use of common specifications via delegated acts in a regulatory framework that currently relies on a single harmonised standard: EN IEC 63000. See feedback provided in attached document.
Read full response

Response to Revision of the Standardisation Regulation

15 Jul 2025

See feedback in document attached.
Read full response

Response to Technical description of important and critical products with digital elements

14 Apr 2025

EUROMOT, the European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers, represents the key manufacturers of internal combustion engines and alternative powertrains installed in industrial non-road mobile machinery, marine and stationary applications that are operating in Europe and worldwide. See feedback form attached.
Read full response

Response to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies

25 Mar 2025

EUROMOT, the European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers, represents the key manufacturers of internal combustion engines and alternative powertrains installed in industrial non-road mobile machinery, marine and stationary applications that are operating in Europe and worldwide. Regarding Appendix C of Annex IV to Delegated Regulation (EU) 2023/2486, the European Commission has presented two options for simplification in ANNEX X. As EUROMOT we support of OPTION 1 - Deletion of the following paragraph: In addition, the activity does not lead to the manufacture, presence in the final product or output, or placing on the market, of other substances, whether on their own, or in mixtures or in an article, in a concentration above 0,1 % weight by weight (w/w), that meet the criteria of Regulation (EC) No 1272/2008 for one of the hazard classes or hazard categories mentioned in Article 57 of Regulation (EC) No 1907/2006, except if it is assessed and documented by the operators that no other suitable alternative substances or technologies are available on the market, and that they are used under controlled conditions. We believe that this option help achieve the goals of the Omnibus simplification package on sustainability reporting and due diligence by better balancing EU environmental goals with business competitiveness.
Read full response

Response to Delegated act on primarily used components under the Net-Zero Industry Act

19 Feb 2025

EUROMOT, the European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers, represents the key manufacturers of internal combustion engines and alternative powertrains installed in industrial non-road mobile machinery, marine and stationary applications that are operating in Europe and worldwide. Please find our feedback in the attached document.
Read full response

Response to Exemptions under RoHS for lead in glass or ceramic of electrical and electronic components

5 Feb 2025

EUROMOT, the European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers supports the feedback submitted by the Umbrella Project to this consultation.
Read full response

Response to Exemptions under RoHS for lead in high melting temperature type solders

5 Feb 2025

EUROMOT, the European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers supports the feedback submitted by the Umbrella Project to this consultation.
Read full response

Response to Exemptions under RoHS for lead as an alloying element in steel, aluminium and copper

5 Feb 2025

EUROMOT, the European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers supports the feedback submitted by the Umbrella Project to this consultation.
Read full response

EUROMOT seeks clarity on CBAM registry and declarant rules

25 Nov 2024
Topic — The initiative establishes the technical and legal framework for the CBAM Registry.
Message — The association requests clarification on 'observations' and argues that thirty days is too short to provide evidence. They also seek to understand the long-term implications of closing a CBAM account.123
Why — Longer appeal periods would help manufacturers avoid five-year bans on importing goods.4
Read full response

Response to Update of minimum requirements for certification programmes for fire protection systems

15 Oct 2024

EUROMOT, the European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers, represents the key manufacturers of internal combustion engines and alternative powertrains installed in industrial non-road mobile machinery, marine and stationary applications that are operating in Europe and worldwide. Please find our feedback in the attached file.
Read full response

Response to Update of minimum requirements for certification programmes for switchgear

15 Oct 2024

EUROMOT, the European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers, represents the key manufacturers of internal combustion engines and alternative powertrains installed in industrial non-road mobile machinery, marine and stationary applications that are operating in Europe and worldwide. Please find our feedback in the attached file.
Read full response

Engine manufacturers seek broader exemptions for UV-328 chemical restrictions

23 Aug 2024
Topic — This consultation concerns adding chemical UV-328 to the list of restricted persistent organic pollutants.
Message — EUROMOT requests broader exemptions for non-road machinery, marine vessels, and rail locomotives. They also seek an 18-month transition period to identify chemicals in complex engine components.12
Why — Broad exemptions prevent the costly redesign and premature disposal of complex machinery.34
Read full response

Engine manufacturers seek broader spare part chemical exemptions

22 Jul 2024
Topic — This consultation concerns adding Dechlorane Plus to the list of restricted persistent pollutants.
Message — EUROMOT proposes expanding exemptions to include all non-road mobile machinery and stationary equipment. They also request an 18-month transition period to identify parts containing the substance.12
Why — This would prevent supply chain disruptions by allowing more time to survey suppliers.3
Read full response

EUROMOT urges higher cut-off for battery carbon footprint methodology

27 May 2024
Topic — The EU is establishing rules for calculating the life-cycle carbon footprint of electric vehicle batteries.
Message — They propose adjusting the cut-off for system components to 3% material and energy flow. This aligns the requirements with the existing Product Environmental Footprint framework.1
Why — This change simplifies compliance by allowing a consistent approach across all company processes.2
Read full response

Response to Evaluation of Standardisation Regulation (EU) No 1025/2012

28 Sept 2023

See feedback in document attached.
Read full response

EUROMOT supports flexible emission factors for marine engines

30 Aug 2023
Topic — The consultation establishes rules for monitoring and reporting greenhouse gas emissions from shipping.
Message — EUROMOT supports allowing companies to diverge from default values for emission factors. Using actual measurement factors helps incentivize reducing methane and nitrous oxide emissions. They advocate for using established international maritime codes for technical engine certification.123
Why — Manufacturers can prove their engines are cleaner than standard industry default values.4
Read full response

EUROMOT Urges Inclusion of Reciprocating Engines in NZIA

14 Jun 2023
Topic — The consultation gathers feedback on the proposed Net Zero Industry Act regulation.
Message — EUROMOT wants sustainable fuel reciprocating engines included in the strategic technology list. They argue these systems are vital for balancing power grids and achieving decarbonization.12
Why — Strategic status would protect manufacturers' market share and strengthen their competitive position.3
Read full response

EUROMOT Urges Recognition of Synthetic Fuels and Flexible Power Plants

8 May 2023
Topic — A revision of the European Union's electricity market design and resilience.
Message — EUROMOT wants clearer rules ensuring power plants using synthetic fuels are not classified as fossil. They propose moving electricity market closure times closer to real-time to reward flexible technologies. The association also opposes mandatory contracts for difference and revenue caps for biogas plants.123
Why — This would protect their members' business models and incentivize investment in flexible engine technologies.4
Impact — Consumers may face higher costs if price caps are removed for certain power generators.5
Read full response

Response to Initiative on EU taxonomy - environmental objective

2 May 2023

EUROMOT, the European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers, represents the key manufacturers of internal combustion engines and alternative powertrains installed in industrial non-road mobile machinery, marine and stationary applications that are operating in Europe and worldwide. Unfortunately, due to the short deadline to provide feedback to the consultation and due to internal proceedings, EUROMOT and its members could not provide a position. About EUROMOT Founded in 1991, we provide an unparalleled heritage and hub of expertise for businesses, authorities, regulators, and public stakeholders worldwide. In partnership with major sector associations and institutions, it is our mission to drive smart regulation and sustainable innovation. Delivering dependable power for society at high energy conversion efficiency with low emissions remains a key objective of EUROMOT member companies. EUROMOT asserts internal combustion engines and alternative powertrains are a key enabler to address the additional societal need for decarbonisation across multiple industry sectors. This can be achieved by continuing to advance the development of highly efficient energy conversion systems capable of operating on low and net-zero Greenhouse Gas (GHG) energy carriers. Headquartered in Brussels, EUROMOT is a European interest group, and our profile is registered in the EU Transparency Register under the identification number 6284937371-73. We have been granted consultative status at the United Nations IMO (International Maritime Organization, London) and United Nations ECE (Economic Commission for Europe - Geneva) and other relevant stakeholders.
Read full response

Engine manufacturers urge harmonised EU rules for packaging waste

19 Apr 2023
Topic — The Commission is reviewing design and waste prevention requirements for all packaging.
Message — EUROMOT stresses the need to ensure that Member States shall not further implement individual national measures. They argue that requirements for re-use for transportation packaging must be realistic and proportional for individual industry sectors. Finally, substance requirements should remain under REACH to avoid double regulation.123
Why — Uniform requirements would prevent market fragmentation and reduce administrative burdens for industrial manufacturers.45
Impact — National authorities would lose the power to set stricter local waste targets.6
Read full response

Response to Review of cogeneration reference values

29 Dec 2022

EUROMOT would like to suggest the following changes for consideration of the Commission (see attached file). - Harmonise recital 7 with the text with the Directive 2012/27/EU (EED) Annex II, point f (3). - Need to introduce for the flexible power plant own separate electric efficiency reference values besides the ones for the base load plant in order to reflect the change in the electricity market. - Reference power plant efficiency for Hydrogen plant should be set at 40% (rather than 53%).
Read full response

Response to FuelEU Maritime

8 Nov 2021

EUROMOT welcomes the FuelEU Maritime proposal from the European Commission as a tool to overcome the barriers for the uptake of low and zero carbon fuels in shipping. EUROMOT members are committed to advancing the development of engine technology and propulsion systems capable of operating on such fuels. As the ship’s energy efficiency is not considered in this proposal, it remains important to keep the focus on increasing the energy efficiency of ships by additional efforts. Further, EUROMOT would like to underline that the availability of low and zero carbon fuels is a necessary prerequisite for achieving the intended effect of the proposal. In particular we would like to comment on the following issues, for details see the enclosed position paper: - Well-to-wake approach - Pooling mechanism - Energy from electricity - Tank-to-wake emission factors - Zero emission technologies - Procedures for measurement and certification of tank-to-wake emissions
Read full response

Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

31 May 2021

EUROMOT (the European Association of Internal Combustion Engine Manufacturers) appreciates the opportunity to comment on the EU Commission’s Inception Impact Assessment (IIA) on the REACH revision. EUROMOT supports the Commission’s intention to step up action in the chemicals area in order to protect citizens’ health, as well as to simplify EU legislation on chemicals and make it more effective. We would like to provide our sector’s point of view on four issues of the current REACH Regulation that the EU Commission has highlighted in its IIA. 1. Communication in the supply chain is inefficient and needs to be simplified. When exploring option to simplify communication in the supply chains, the IIA mentions the following: “Options for improving safety data sheets (information for downstream companies and workers on chemical risks and protective measures) will be assessed, including in particular harmonised electronic formats”. We would support such an approach, as safety data sheets are ubiquitous in industry and widely recognized as a means to communicate risk mitigation procedures throughout the supply chain. However, this would be only a partial solution, as much more needs to be done to simplify and increase effectiveness in communication within supply chains. This is especially true for sectors like ours, operating within very diverse global supply chains whose actors are not necessarily familiar with European regulations. 2. The current restriction process is too slow to sufficiently protect consumers and professional users against risks from the most hazardous substances. While we support the efforts to make the restriction process more effective, we in no case support blanket prohibition of hazardous substances, particularly when there is no release of the given material and it provides a significant and measurable benefit to safety, emissions performance or lifespan of professional use equipment. At a minimum, when seeking to speed up the restriction process, sufficient transition periods should be ensured to allow manufacturers to maintain fitness for purpose and risk mitigation. 3. Reforming the authorization process. In this case again, we fully support the Commission’s clarification and simplification efforts. However, we also believe that a complete regulatory management option analysis (RMOA) is important to decide on the most efficient regulatory route and should always be conducted. For example, relating to the Commission’s intention to “improve the interface with other pieces of legislation”, our experience is that the different mechanisms and processes of REACH and RoHS have proven to be effective and adapted to the different nature of these two regulations (which we also underlined in our response to the RoHS evaluation Open Public Consultation). Additional details can be found in our comment on the EU Chemicals Strategy (https://www.euromot.eu/wp-content/uploads/2020/06/EU-Chemicals-strategy_Roadmap_EUROMOT-comments_FINAL_18062020.pdf). At the same time though, we believe it would be crucial to have alignment between different pieces of legislation in terms of timing for new restrictions, to allow manufacturers the continuity of supply. 4. Reinforcing control and enforcement. We fully support the Commission’s efforts in this direction: to this end, we believe that the establishment of minimum requirements for national control and enforcement should be accompanied by common interpretations of EU laws. In this regard, the role of EU Commission guidelines on a common interpretation across Member States to enable uniform enforcement is of key importance. EUROMOT would like to thank the European Commission for the opportunity to raise these concerns in the context of the REACH revision, and reiterates its willingness to contribute to policy and regulatory developments in this area.
Read full response

Response to Revision of EU rules on Gas

8 Mar 2021

EUROMOT very much supports the EU ambition for a rapid reduction of greenhouse gas emissions and of the unabated use of fossil fuels, and for a progressive increase in the market penetration of low-carbon gases. As underlined in our recent paper on Taxonomy (https://tinyurl.com/erbucxz4), our new engines are more and more ready to run on hydrogen (having a target of 20% vol Hydrogen today and 100% vol in 2030) and/or other low-carbon/decarbonised gases, depending on EU technical specifications on gas quality (see below) and on the availability of such gases. We also agree that a direct electrification of the heating of buildings and processes with by nature very effective heat pumps can save a considerable amount of primary energy and consequently reduce the connected emissions. Large-scale electrification will make the society and economy increasingly depending on an uninterrupted electric power supply. With a substantial fraction of electricity coming from solar panels and wind turbines, it is of crucial importance that the power grid stays stable with a maximum reliability. Batteries alone cannot provide the task of enabling by-nature fluctuating power sources. There is evidence that distributed generation, often in combination with cogeneration and district heating, is excellently capable of performing this renewable-enabling task. EUROMOT has highlighted such a key function of gas-fired engines in a number of papers: for example, when commenting on the EU Taxonomy (see link above) and on the EU Energy System Integration Strategy (https://tinyurl.com/62xf34yw). Although EUROMOT members can design and tune their products for running on any kind of gas, be it renewable, fossil or low-carbon, a good engine performance requires a suitable and close to constant gas quality. Indeed, as mentioned in our paper on the Energy System Integration Strategy, abrupt and deep changes in fuel composition will jeopardize engines’ performance, thus undermining key EU policy objectives such as safety, exhaust emissions reduction and energy efficiency: a concept which applies not only to renewable-enabling and grid-stabilising power plants as described above, but to all engine sectors and applications. More particularly, in the same paper we make our proposals concerning the values of some key quality parameters of the gas delivered to consumers (namely: the Wobbe Index, its rate of change, the Methane Number and the Sulphur content of gas). Such a close to constant gas quality over an extended time is economically and technically possible without jeopardising the security of gas supply. Therefore, adequate legislation to this end can and should be harmonized and put in place at the EU level. For the same reasons, we recommend aiming for a separate hydrogen grid to ensure an optimum and adequate use of such a costly and valuable energy carrier: because of the considerably deviating properties of hydrogen compared to methane, blending (high) fractions of hydrogen in gas will result in a poor gas quality, especially when the hydrogen fraction does vary. To sum up: 1. Reciprocating engine-based electricity generators have a proven capability to enable a fast large-scale integration of renewable electricity. 2. For an adequate performance, these engines need a close to constant good and stable gas quality over an extended time. 3. It is technically and economically possible to ensure a narrow gas quality range without jeopardising the security of supply (e.g. US FERC Interim Guidelines) while facilitating cross-border transfers of gas. 4. The EU should develop legislation aiming at an optimum gas quality, taking into considerations technical expertise and concerns of all actors of the gas value chain.
Read full response

EUROMOT Urges Realistic Taxonomy Criteria for Gas-Fired Power

17 Dec 2020
Topic — The consultation defines environmentally sustainable economic activities within the EU taxonomy for investment purposes.
Message — The association requests higher emission thresholds and the inclusion of renewable fuels. They argue criteria should account for the role of gas-fired plants.12
Why — These changes would ensure their engine technologies remain eligible for sustainable financing.3
Impact — Environmental goals could be compromised by weaker emission standards and prolonged gas reliance.4
Read full response

Response to Review of Directive 2012/27/EU on energy efficiency

18 Sept 2020

EUROMOT, the European Association of Internal Combustion Engine Manufacturers, welcomes the Commission's initiative to consult stakeholders on the review process of the Energy Efficiency Directive EED 2012/27. An efficient use of energy is crucial in order to fulfil the EU climate objectives. After an analysis of the EED and of the Commission’s Inception Impact Assessment (IIA) on its review, we noted in particular that aspects related to the new electricity market development are to a large extent neglected. The general and main principle we would like to highlight is that the role of thermal fired plants facilitating grid stabilization and step-by step integration of intermittent renewables into the electricity grid is not duly acknowledged in the EED, nor – for the sake of legislative coherence and better regulation principle – in other ongoing EU regulatory processes, such as the EU Taxonomy on Sustainable Finance. We develop this point in the attached paper, based on the various sections of the IIA and on a number of sources referenced in the text.
Read full response

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

18 Sept 2020

EUROMOT, the European Association of Internal Combustion Engine Manufacturers, welcomes the Commission's initiative to consult stakeholders on the review process of the Renewable Energy Directive (“RED”) 2018/2001/EU. Together with the Energy System Integration and Hydrogen Strategies, this constitutes the key legislative tool to decarbonize the EU energy mix and fulfil the EU climate objectives. The Commission’s Inception Impact Assessment on the “RED” review explicitly states that such a review will “consider elements emanating from the Energy System Integration and Hydrogen strategies, where appropriate”. Most notably, the review will consider the following aspects, already identified as priorities in the two abovementioned strategies: • “Increase the deployment of renewables in the power, heating and cooling, and transport sectors", and • “Promote further development and use of renewable and other low-carbon fuels including advanced biofuels, synthetic liquid and gaseous fuels and hydrogen, in hard-to-decarbonise sectors such as industry and heavy duty transport, aviation and shipping”. In this respect, we would like to remind a series of concerns for our sector that we already expressed in our feedback (“June 2020”) to the Commission’s roadmap on the Energy System Integration Strategy (https://www.euromot.eu/wp-content/uploads/2020/06/EUROMOT-final-comments-on-EU-Smart-Sector-Integration-Strategy-Roadmap-2020-06-05.pdf). In particular, the potential of synthetic fuels (“Power-to-X”) for the power generation sector should be fully taken into account in the “RED”. For details and sources, please see the attached document.
Read full response

Response to Chemicals strategy for sustainability

18 Jun 2020

EUROMOT (the European Association of Internal Combustion Engine Manufacturers) welcomes the Commission’s initiative to consult stakeholders on the upcoming EU Chemicals Strategy for Sustainability. Our feedback to the Commission's roadmap focuses on two main points: 1) We understand the Commission’s view that the current COVID-19 crisis has even increased the focus of EU action in this area, to promote the EU’s strategic autonomy for those chemicals essential to society and health (e.g. for the production of pharmaceuticals or disinfectants). On the other hand, the timing of actions on chemicals beyond those sectors identified as essential to society and health should be carefully assessed: some of such ongoing policy activities are going to have a tremendous impact on industrial sectors like ours, particularly where supply chain disruptions due to COVID-19 have considerably reduced industry’s ability to monitor and contribute to regulatory developments. Most importantly, we request a postponement of the 5th January 2021 deadline for companies to upload data to the SCIP Database. SCIP requirements were already very challenging under normal circumstances due to the complexity of our sector’s supply chains, as well as to the fact that the database is still under development by ECHA. The current pandemic has made the situation even more challenging for manufacturers. 2) EUROMOT strongly agrees with the principle of regulatory simplification, which can only be beneficial for business and for citizens. However, when it comes specifically to the regulatory framework on chemicals, we would like to underline that simplification should not lead to any sort of “merging” of (part of) pieces of EU legislation on chemicals. In particular and most importantly, as we expressed already in our response to the Open Public Consultation on the RoHS Directive review (December 2019), we believe that the RoHS Directive and the REACH Regulation should remain separated. Please see the attached documents for a more detailed explanation of the two above-mentioned points. EUROMOT would like to thank the European Commission for the opportunity to raise these concerns in the context of the Chemicals strategy Roadmap, and reiterates its willingness to contribute to policy and regulatory developments in this area.
Read full response

Response to A EU hydrogen strategy

8 Jun 2020

EUROMOT (the European Association of Internal Combustion Engine Manufacturers) supports the development of an EU Hydrogen strategy. We would like to raise the following points: 1. Internal Combustion Engines (ICEs) are capable of operating on a wide range of bio-, hydrogen and synthetic fuels, such as hydrogen-derived liquid/gaseous fuels, for use in power generation systems, non-road mobile machinery, rail or marine applications. 2. The upscaled deployment of renewable hydrogen, at reasonable cost, but with a transition and distribution methodology that ensures the end-user always receives a fuel with sufficiently predictable and stable properties, is key. 3. Hydrogen will be important not only as a gaseous fuel, but also as an intermediate step in the production of ‘Power-to-X’ fuels. For example, in the power generation sector, synthetic ‘Power-to-X’ fuel production is an efficient mean to avoid curtailment of intermittent renewable energy and to enable, on the long term, full greening of the sector and energy storage for grid balancing ICE plants. Please see the attached EUROMOT submission on the Smart sector integration strategy roadmap for more information and references on the abovementioned points
Read full response

Response to Strategy for smart sector integration

5 Jun 2020

EUROMOT (the European Association of Internal Combustion Engine Manufacturers) supports the Commission’s initiative to develop an EU Smart Sector Integration Strategy. Please find attached the EUROMOT’s comprehensive response to the Commission’s roadmap. In such a paper, we focus on the following aspects: 1. The role of Internal Combustion Engines (ICEs) in achieving the EU climate targets: ICEs have fully demonstrated over time a high degree of operational flexibility and adaptability both to different fuels and technological changes, regardless of their type, size, or whether they are used in power generation systems, non-road mobile machinery, rail or marine applications. 2. At the same time, a sufficient level of stability and predictability in fuel composition is a key factor: abrupt and deep changes in fuel composition will jeopardize ICEs’ performance, thus undermining key EU policy objectives such as safety and energy efficiency. 3. Concerning ICEs installed into hard-to-decarbonize applications (such as marine transport and non-road mobile machinery), it is critical that the EU energy policy has the prospect of creating wide availability of low or net-zero carbon fuels in sufficient scale, and at an acceptable total cost of ownership to the end-user. In this regard, each fuel having different technical properties, sector-specific impact assessments should be conducted. 4. Concerning the power generation sector, we most importantly underline that gas-fired grid balancing engine plants make possible the step-by-step integration of intermittent renewables in the electricity grid. Unfortunately, recent EU regulatory developments around the EU Taxonomy on sustainable finance may establish barriers to such a process. Finally, we would like to stress the importance of European harmonized gas composition standards, in a context of progressive market penetration of decarbonized gases. Please see the attached document for additional details and references on the abovementioned points.
Read full response

Response to FuelEU Maritime

23 Apr 2020

EUROMOT, the European Association of Internal Combustion Engine Manufacturers, would like to submit its comments on the consultation on the European Commission’s Inception Impact Assessment on “FuelEU Maritime – Green European Maritime Space”. In particular, we would like to raise the following issues in the attached position paper: 1. Technical requirements on marine propulsion systems and marine power units 2. Interaction of technology development of engines and making available of low/zero carbon fuels 3. Well-to-wake approach for low/zero carbon fuels 4. Market barriers 4.1. Safety issues 4.2. Regulatory uncertainties 5. Cost implications and the need for drivers 6. Benefits of LNG 7. Benefits of shore-side electricity
Read full response

Response to Climate Law

21 Apr 2020

EUROMOT (the European Association of Internal Combustion Engine Manufacturers) welcomes the Commission’s initiative to consult stakeholders on the Proposed Climate Law. We would like to comment in particular on one aspects indirectly related to the Commission's proposal: the Taxonomy on sustainable finance. Taxonomy is mentioned in art. 7 of the proposed Climate Law. In turn, article 7 refers to articles 5 and 6 where the trajectory towards carbon neutrality is mentioned (see text below). E.g. the Taxonomy Regulation is one of the criteria used when assessing climate-neutrality achievement progress and measures expressed in the trajectory, which will be periodically reviewed starting from year 2023. In Article 3 trajectory considerations such as cost-effectiveness and economic efficiency, best available technology, etc. are listed. Therefore it is of the utmost importance that the Taxonomy has a robust basis. Analyses made by EUROMOT revealed unfortunately that this is not the case so far: EUROMOT has already questioned the criteria that the Technical Expert Group has proposed to define “sustainable” investments. We refer to our published paper here for additional details: https://www.euromot.eu/wp-content/uploads/2020/04/Taxonomy-Delegated-Act-Inception-Impact-Assessment_EUROMOT-comments_FINAL_17Apr2020.pdf . Thus proposed Taxonomy threshold criteria need a careful assessment before being enshrined in EU law. Regulatory references in the proposed Climate Law: Article 7 “Common provisions on Commission assessment” 1. In addition to .. referred in Article 6(1), the Commission shall base its assessment referred to in Articles 5 and 6 on at least the following: 1 e) “any supplementary information on environmentally sustainable investment, by the Union and Member States, including, when available, investment consistent with Regulation (EU) 2020/… [Taxonomy Regulation]." It is stated that by 30 September 2023 and every 5 years thereafter the Commission shall assess measures at EU and national level to reach carbon neutrality (art. 5 and 6). More specifically: - In Article 5 “Assessment of Union progress and measures” a) the collective progress made by all Member States towards achievement of the climate-neutrality objective .. as expressed by the trajectory referred to .. b) the collective progress made by all Member states on adoption .. - In Article 6 “Assessment of national measures” a) the consistency of national measures identified … as relevant for the achievement of climate-neutrality objective .. as expressed by the trajectory referred to .. b) the adequacy of relevant national measures to ensure progress on adaptation ..
Read full response

Response to EU rules on industrial emissions - revision

20 Apr 2020

EUROMOT welcomes the Commission’s initiative to consult stakeholders on the IED revision process. We have been active in past LCP BREF 2017 and IED consultation processes. In the paragraphs below we provide our response to some specific sections of the Commission’s inception impact assessment on the IED review. 1. Section A Quote “The European Green Deal commits the Commission to review ... from large industrial installations … fully constituent with climate … policies. …“. The Green Deal strategy refers to the “Taxonomy” for sustainable economic activities as a tool to foster sustainable investment. The Final Taxonomy Report Technical Annex contains e.g. criteria thresholds for an activity to be identified as “substantially contributing to climate change mitigation”. Unfortunately, many of the established criteria thresholds do not reflect the state of play in the current technology development nor the realistically foreseeable development in coming years. The Annex is for many activities based on assumptions on technologies that are not mature enough, and will probably not be for many years to come – most notably, the CCS technology. The Platform on Sustainable Finance (expected to be operational in Autumn 2020) should thus carefully assess the set criteria thresholds: the objective should be to encourage – not hinder – the use of available, viable cost-efficient low carbon alternatives (see also paragraph 2 below). 2. Section B We make a list of proposals to enhance the performance of the IED, focusing on a few aspects mentioned in the inception impact assessment. “Interaction with decarbonisation of industry”: The LCP BREF contains BAT-AEELs for efficiency (proxy for CO2) and for some prime mover BAT-AEL CH4-limits. From this data, BAT GHG limits can be worked out and included in the IED process (as suggested by EUROMOT in the past). This would allow a cost-effective and environmentally sound decarbonisation of the EU electricity grid and a deep penetration of intermittent renewable energy into the grid. “Implementation issues”: IED Art 15(3) requires that emissions under normal operating conditions do not to exceed the BAT limits in LCP BREF. E.g. variations in gas quality and composition (sulphur content etc.) within the EU and in operational conditions put stress on oxidation catalysts needed for abatement of unburned emissions (CO, formaldehyde): in these cases, the highest possible flexibility would be needed in the IED framework. IED Art.15(4) allows emission derogations for e.g. remote areas but Annex V limits must not be exceeded anyway. Annex V limits are similar to the max. LCP BREF limits for e.g. gas engines: this means, in practice, no flexibility. EUROMOT has proposed that the approved split views of LCP BREF could be a basis to develop a real flexibility option for installations affected by Art. 15(4). “BREF Process”: In order to increase effectiveness & efficiency: the ECM BREF 2006 (cost aspects) needs a higher rank in decision making. As to relevance: approved dissenting views should be used for e.g. remote areas. “Commission Implementation Decisions” should also be strengthened in order to secure a balance in the TWG discussions. 3. Section C Quote: “Industry is likely to need to make significant investments .. to support .. climate neutrality. Industry may also be able to contribute to reducing resource use and promoting a more circular economy...” In paragraph 2 we have proposed a cost-effective way which will help the EU achieve its climate ambitions. We would also like to provide a proposal to strengthen the circular economy dimension: fuels based on Absolute Non-Hazardous (ANH) waste should be classified as non-hazardous and plant using those fuels should be allowed to apply Chapter III and Annex V emission limits. By following this approach virgin fuel consumption would decrease and waste would be utilized more efficiently. (please note: in attached file additional links and text)
Read full response

EUROMOT Urges Inclusion of Gas Engines in Sustainable Taxonomy

17 Apr 2020
Topic — This consultation defines technical criteria for identifying environmentally sustainable economic activities for investment purposes.
Message — The association requests revised threshold criteria to include flexible gas engines and viable technologies. They propose technique-specific emission limits reflecting current industrial capabilities and cost-efficiency.12
Why — These changes would protect the market competitiveness of European internal combustion engine manufacturers.3
Read full response

Response to 2030 Climate Target Plan

14 Apr 2020

EUROMOT welcomes this initiative to consult stakeholders in the process of preparing a proposal for an increased climate target for 2030. Such an adaptation of the current EU 2030 climate target is needed in order to face the climate emergency existing already now, and more and more in the future. At the same time though, a right balance between the objectives of environmental protection of safeguarding the competitiveness of the EU economy needs to be found, now more than ever: Europe will have to face a heavy economic downturn due to the current Covid-19 pandemic for the months – probably years – to come. For this reason, it will be crucial to design a regulatory framework that enables the use of already fully viable technologies leading to a fast cost-effective decarbonization coupled with access to a secure, affordable and sustainable energy system. We believe that the abovementioned principles should be at the basis of any EU decarbonization policy. In the following lines we provide our response to some specific sections of the Commission’s inception impact assessment, while making reference to some other EU initiatives – most importantly the “EU Taxonomy” – currently ongoing in parallel with the review of the 2030 target. 1. Section A The subparagraph “Problem the initiative aims to tackle” states the following: “The initiative needs to assess how to increase the ambition in a manner that best contributes to sustainable and inclusive growth, .. ”. The Final Taxonomy Report Technical Annex published in March 2020 is a key document in defining sustainability policies. Most notably, the Annex defines threshold criteria for an economic activity to be identified as “substantially contributing to climate change mitigation” and “not significant harm” environmental objectives. Unfortunately, the Technical Expert Group (TEG) that drafted the report was almost entirely composed by representatives of financial institutions, whereas the industry sectors to which the Taxonomy would be applied were not represented. Moreover, feedback provided to the Draft report by said industry sectors was, to a large extent, overlooked in the final report. More specifically, the thresholds that were set for many activities such as “Electricity production from gas” do not reflect the state of play in the current technology development, nor the realistically foreseeable development in the coming years. On the contrary, as highlighted by EUROMOT, the report is based on assumptions on technologies that are not mature enough, and will probably not be for years to come – most notably, the CCS technology. Therefore, we believe that the EU Commission, when preparing the Delegated Acts establishing “Climate Change Mitigation”, etc. criteria in the upcoming months, should carefully assess (together with the “Platform on Sustainable Finance”, expected to be operational in Autumn 2020) the thresholds criteria set by the TEG: as described above, the overall objective should be to encourage – and not to hinder – the use of already available and viable cost-efficient low carbon alternatives needed for the Green transition. In particular, EUROMOT has underlined the importance of gas-fired (reciprocating) engines to enable, thanks to their flexibility and their multifuel capability, the step-by-step integration of renewables in the electricity grid. 2. Section D We believe that the Renewable Energy Directive in particular should include Power-to-X fuel options in order to foster the production of renewable fuels such as synthetic biomethane. Synthetic P2X fuel production is an efficient mean to avoid curtailment of intermittent renewable energy production, while enabling a further expansion of renewable energy. 3. Subsection: Evidence base and data collection The list of economic models does not include the PLEXOS modelling tool, which enables deep analysis of different system options. Please see the article "Path to 100% Renewables for California".
Read full response

EUROMOT demands more efficient and predictable RoHS exemption procedures

12 Oct 2018
Topic — The evaluation assesses rules restricting hazardous substances in electrical and electronic equipment.
Message — EUROMOT urges a review of the exemption process to make it more transparent and efficient. They recommend defined deadlines or transitional solutions to resolve long evaluation delays.12
Why — Streamlined procedures would provide legal certainty and ensure engine manufacturers do not lose orders.3
Impact — Consumers and industrial users lose access to essential products due to slow approvals.4
Read full response

Response to Regulation complementing EU type-approval legislation with regard to the UK withdrawal from the EU (Brexit preparedness)

20 Jul 2018

EUROMOT, representing the manufacturers of engines type-approved for use in non-road mobile machinery, including construction, agricultural and industrial equipment, railway locomotives and inland waterway vessels, welcomes the new proposal for a regulation to provide a way forward for manufacturers holding UK-issued EU type-approvals when the UK leaves the Union. These approvals are not just used by UK companies but are relied upon by various manufacturers across the EU-28 and the rest of the world as the basis for placing products on the Union market. Given the thousands of UK-issued approvals to be converted to Union approvals and the deadline of 30 March 2019 for that conversion it is essential to finalise this regulation so that it can enter force no later than six months prior to that date. Engine emission regulation in the non-road sector is unique in setting regulation based on a combination of production and placing on market dates, which, by intent of the co-legislators, may be separated by a period of months or even years. This recognises the global nature of the production and supply chain where the engines may originate from, and be shipped to, any part of the EU-28 or rest of the world, before finally the finished excavator, tractor or locomotive is placed on the Union market. Furthermore, as designed by co-legislators, there are a number of transition provisions and exemptions that do not require an existing valid type-approval for placing on the market but instead rely upon an ‘old’ invalidated EU type-approval as evidence of conformity to a prior emission level. Key areas where amendments should be made to the proposed regulation are as follows (see our position paper for detailed proposed wording): 1. Clear identification of when conversion to Union type-approval is required 2. Recognition of markings of engines already in the supply chain 3. Avoiding unnecessary re-testing of engines Whilst seeking a speedy conclusion and publication of the regulation, EUROMOT urges that members of the European Parliament and the Council propose, or support others in their proposal of, the above amendments to improve this draft regulation. EUROMOT welcomes any questions and remains open to provide further supporting information on the above points.
Read full response

Response to Regulation complementing EU type-approval legislation with regard to the UK withdrawal from the EU (Brexit preparedness)

9 May 2018

Please find here attached our response to the European Commission's Brexit roadmap for NRMM & Ag Tractors. Best regards, Michelle Petrequin
Read full response