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European Council for Motor Trades and Repairs

CECRA

CECRA represents the interests of automotive dealers and repairers across Europe.

Lobbying Activity

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

2 Dec 2025

We recognise the rising cybersecurity risks across connected products, including vehicles, yet we cant support a disproportionately restrictive digital lock on vehicle access points such as the OBD connector. The CJEU judgment of 9 November 2023 in case C-319/22 (para. 39) confirms that manufacturers may not fully restrict or render access to the OBD connector unreasonably difficult. In addition, UNECE Regulation No. 155 on Cyber Security and Cyber Security Management Systems places the responsibility for in-vehicle cybersecurity on manufacturers. We value the Commissions efforts to address these matters and welcome the balanced framework that preserves access to information while introducing defined digital access controls through secure certificates. The amendment package is generally well balanced and reflects the interests of all stakeholders. We particularly support the possibility of reusing existing authentication solutions, which will reduce procedural burdens for independent operators and allow certificates already issued under SERMI to be used efficiently. We also support the adjustments to Appendix 3 of Annex X, notably the removal of the requirement that a Conformity Assessment Body(CAB) must be accredited in the country of the Information Operator. This change should enhance competition among CABs and align with the principles governing the free movement of services. The direct amendments to Annex X are equally positive. They should strengthen competitive conditions and provide a future proof structure. This includes securing availability of Repair and Maintenance Information at the moment a vehicle is placed on the market and ensuring access to all RMI integration points in the vehicle. We also welcome the new obligation for manufacturers to provide information relating to factory installed options and RMI for ADAS or ADS, DCAS and traction batteries. Despite these improvements, we remain concerned about the readability of the proposed text. To improve clarity, we suggest targeted adjustments to the articles and strongly recommend adding a guidance document containing a comprehensive table that visually maps access levels and corresponding requirements for all relevant operators.
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Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and Zentralverband Deutsches Kfz-Gewerbe e.V. and Mobilians

22 Jul 2025 · Automotive aftermarket topics

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'

Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and Fédération Internationale de l'Automobile and

11 Feb 2025 · Action plan for the automotive sector

Meeting with Silvia Bartolini (Cabinet of Executive Vice-President Henna Virkkunen), Xavier Coget (Cabinet of Executive Vice-President Henna Virkkunen) and

14 Jan 2025 · The role of the automotive aftermarket in the EU Industrial Action Plan for the automotive sector

Meeting with Helena Hinto (Cabinet of Commissioner Apostolos Tzitzikostas) and Insurance Europe and

10 Jan 2025 · Introductory meeting

Meeting with Valvanera Ulargui Aparicio (Cabinet of Executive Vice-President Teresa Ribera Rodríguez) and Insurance Europe and

16 Dec 2024 · Exchange with the Independent Service Providers (ISPs) on the upcoming Commission Initiatives that will support the whole sector competitiveness, including the Competitiveness Compass, the Clean Industry Deal and the Automotive Industry Plan

Response to Evaluation of the Motor Vehicle Block Exemption Regulation

24 Jun 2024

CECRA welcomes the opportunity to comment on the Commissions initiative to evaluate the Motor Vehicle Block Exemption Regulation (MVBER) ahead of its expiry on 31 May 2028. The Motor Vehicles Block Exemption Regulation (MVBER) and its Sector-specific Guidelines play a crucial role in maintaining competitive conditions within the automotive vehicles aftersales sector. They provide guidance on how to apply competition rules within the complex automotive sector and thereby give more legal certainty which is essential to support effective competition. Sector-specific rules remain THE optimal solution. Without the MVBER, market participants would be forced to rely on general principles of competition law, which are less suitable, more challenging to interpret, more costly to deal with and burdensome for SMEs, which constitute a vital segment of the independent automotive aftermarket. Letting the MVBER or the Supplementary Guidelines expire would result in legal uncertainty, disrupting established practices and jeopardizing the clarity and consistency that the sector needs. This uncertainty could potentially lead to disputes over compliance with competition rules, increasing the likelihood of litigation and imposing unnecessary costs on businesses, particularly affecting smaller enterprises that may struggle with legal complexities. Moreover, the absence of clear regulatory frameworks could hinder innovation. Therefore, maintaining these guidelines is crucial for providing stability and fostering a competitive environment in the automotive aftermarket. CECRA is pleased to learn that the Commission will use the consultation to evaluate the impact of ongoing digitalization on the ability of independent operators to compete effectively. Indeed, to ensure fair competition and innovation, it is imperative that the MVBER be updated taking into account the future challenges and needs of the automotive vehicles aftersales sector.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Insurance Europe and

4 Jun 2024 · Discussion on preparation of delegated act on conditions to access data for repair and maintenance activities

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

Response to Transitional measures for smart tachograph 2 regarding its use of OSNMA

7 Mar 2023

JOINT INDUSTRY FEEDBACK - The European Automobile Manufacturers Association (ACEA), European Council for Motor Trades and Repairs (CECRA) and International Association of the Body and Trailer Building Industry (CLCCR) welcomes Mobility Package I. It is essential for ensuring effective implementation and enforcement of road transport legislation, and to provide a balance between the social protection of drivers and the freedom of operators to provide cross-border transport services.
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Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

15 Feb 2023 · In-vehicle data

Response to Creation of the Common European Mobility Data Space

7 Dec 2022

See attached document for CECRA's feedback. CECRA: The European Council for Motor Trades and Repairs (CECRA) is the European federation of professional associations representing the interests of automotive dealers and repairers.
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Response to Type approval of motor vehicles regarding access to in-vehicle generated data

29 Jun 2022

CECRA welcomes the initiative of the European Commission for sectoral legislation on access to vehicle data, functions and resources. With the introduction of the draft Data-Act on February 23rd, 2022 “COM (2022) 68 final; 2022/0047 (COD)” on access to data, the Commission has setup a positive framework to build on the sectoral legislation for the Automotive sector. Clear legislation will help the Automotive ecosystem to develop and foster new initiatives on data driven solutions. Without this legislation the past has already shown that there is no equal access to vehicle data, functions and resources. We welcome and endorse the suggested sectoral legislation to be included into the existing Type Approval Regulation (EU 2018/858).
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Meeting with Thierry Breton (Commissioner) and

16 Jun 2022 · Data Act ; in-vehicle data

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Insurance Europe and

10 Jun 2022 · Prep meeting for meeting with Commissioner Breton on 16/6

Response to Promoting sustainability in consumer after-sales

5 Apr 2022

Vehicles are designed and equipped with very advanced technology in order to last in time for many years (in average 13 years). Vehicles are already reliable and durable products which provide value for money to consumers and prevent the overuse of resources and waste. Furthermore, vehicles are already today – in contrast to disposable products - open to any kind of repair, upgrade, disassemble and – finally – recycling. However, vehicles, composed of a collection of complex components, have each of which its own lifespan and longevity characteristics, depending particularly on the type of components (e.g. brakes) and the kind of use (e.g. kilometers travelled, maintenance, driver behaviour etc.). These external influences are not predictable but have a major impact on the lifetime of components and the vehicle in itself. Keeping all these factors in mind, we consider that the ‘reasonable’ guarantee period, set at 2-year, already offers encompassing all relevant defects and therefore offers a good solution as it ensures high levels of sustainable consumption while keeping the burden for the industry at a reasonable level. Automotive manufactures are accountable for the products they produce and the guarantee – all related costs - they offer for these products. However, in practice, automotive authorised repairers report they are not fully reimbursed by their manufacturers for doing these repairs under the guarantee period. Through the guarantee period offered when buying a car, the automotive sales and repair sector esteems that the automotive industry, as a whole, already offers a sustainable format of repair and maintenance for its products and we do not see any need to introduce additional rules. Nevertheless, CECRA supports the general principle. It therefore supports the voluntary commitments (1st policy option proposed by the Commission), which would encourage businesses to commit voluntarily to repairing goods with a significant negative impact on the environment and promote the purchase of second-hand and refurbished goods which could encourage more sustainable behaviour. Please read the attached document for our full feedback.
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Meeting with Thierry Breton (Commissioner) and

27 Oct 2021 · Data

Response to Requirements concerning data to be made available to the Commission and third parties for automotive market surveillance

5 Jul 2021

CECRA (The European Council for Motor Trades and Repairs) welcomes and appreciate the possibility to review the draft Implementing Act. We have listed our feedback in attachment.
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Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

25 Jun 2021

See attached document: "Feedback CECRA - Data Act - 210625.pdf"
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Response to Modernising the EU’s batteries legislation

26 Feb 2021

Conc. Art. 59: We are pleased that independent operators will be granted access to the battery management system for industrial rechargeable batteries and electric vehicle storage batteries with a capacity of more than 2 kWh so that they can assess and determine its condition as well as the remaining lifetime. Idem for access to information relevant to handling and testing of rechargeable industrial batteries and electric vehicle batteries. This access must be granted to any operator, independent or not. Conc. Annex XIII: it seems fundamental that part 2. of the information system referred to in Annex XIII of the proposed Regulation should be accessible to all operators (independent or not) provided they have the required competences and certificates legally required to work safely on such batteries. The terms “accredited economic operators” used in the proposal should be replaced and adapted accordingly. The information contained in this point 2. (listed below) is essential for workshops to assess the performance of the batteries and possible options of reusing them (before disposing of them). a. Detailed composition, including materials used in the cathode, anode and electrolyte; b. Part numbers for components and contact details of sources for replacement spares; c. Dismantling information, including at least: • Exploded diagrams of the battery system/pack showing the location of battery cells, • Disassembly sequences, • Type and number of fastening techniques to be unlocked, • Tools required for disassembly, • Warnings if risk of damaging parts exist, • Amount of cells used and layout; d. Safety measures With regard to c) it is important to add a diagram of the electrical topology and fitted safety components. If not, it is difficult to repair/remanufacture the battery. In absence, this will have an impact on safety (e.g., way in which packs & modules are electrically connected with an indication of the opening and closing relays or the location of these in the electrical circuits of the "service disconnect"). Definition of « remanufacturing » - repairing activities on battery packs currently carried out in workshops contribute to the extension of the battery life. They take place at a moment when batteries are not yet considered “waste”. It is essential to define "remanufacturing" activities and to distinguish between these activities that can be carried out both on batteries in the "product" status/phase and on batteries in the "waste" status/phase, each of these operations ultimately aiming at repairing them for their original application. “Repurposing” activities are carried out to ensure a second life of an application other than the original one. Definition of « Status » or « change of Status » of the battery - it is important to clarify Art. 59 on the requirements related to repurposing and remanufacturing of industrial batteries and electric vehicle batteries according to the different phases of the life cycle of the batteries covered by the operations included in these various provisions. And this by clearly defining the notions of "status" and "change of status" of the battery. View: p. 4, §2&5 of this Art. only concern "waste" phase of batteries whereas the previous provisions (p. 2to4, §1) mix activities carried out before and after the "disused batteries" phase. Conc. Art. 65, p. 5: needs to be made clear that the replacement in workshops of one or more modules in a battery pack or the repairing activities already in progress on battery packs do not as such have any impact (change) on the "status" of the battery as specified. Conc. Art. 65, p. 6: needs to be made clear that "change of status due to repairing activities", refers only to repairing activities on a "disused" battery (which has lost its original purpose) carried out by the person who intends to carry out a repurposing activity.
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Response to Standardised access to vehicle information for on-board diagnostics, repair and maintenance and security features

4 Feb 2021

CECRA, the European Council for Motor Trades and Repairs and member of AFCAR, the Alliance for the Freedom of Car Repair in Europe, attaches herewith its combined feedback on standardised access to vehicle information for on-board diagnostics, repair and maintenance and safety features.
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Response to Light Duty Vehicles (LDV) monitoring - amendment of Annexes I, II and III

1 Sept 2020

Answer from CECRA, the European Council for Motors Trades and Repairs From 1 January 2021, the CO2 emission standards are to be based on CO2 emissions data determined in accordance with the Worldwide Harmonised Light Vehicle Test Procedure (WLTP) as set out in Commission Regulation (EU) 2017/11512. CECRA welcomes the introduction of an independent and regular check of the difference between laboratory values and real-world CO2 emissions and energy-consumption values. This is the only way to prevent a further increase in the discrepancy between these measurements and to ensure transparency to obtain even more realistic consumption information for the consumer. CECRA also welcomes the opportunity to evaluate, by 2027, how representative the Worldwide Harmonised Light Vehicle Test Procedure (WLTP) is of real-world traffic conditions as a basis for developing measures to modify regulations. It is therefore necessary to amend regulations (i.e. Annex I to Regulation (EU) 2019/631) in order to adjust the parameters to be monitored and reported and to remove references to data determined on the basis of the New European Driving Cycle (NEDC). The main objective of the delegated regulation is to ensure the appropriate monitoring and reporting of data relating to new passenger cars and light commercial vehicles since these are essential for the functioning of the CO2 emission standards set out in Regulation (EU) 2019/631. In order to simplify the monitoring and reporting, the data parameters monitored and reported by Member States for passenger cars and light commercial vehicles should also be harmonised to the extent possible. Checking actual CO2 emissions based on the actual fuel or energy consumption can be implemented during PTI by using the electronic vehicle interface (OBD). According to Regulation (EU) 2018/1832 Annex XXII, the OBFCM device must guarantee standardised and unrestricted access to the data. In UNECE regulation Nr. 83 is defined that this standardized access must fulfil ISO 15031-5. The “OBD interface” enables standardised communication between vehicles and external test equipment during type approval, periodic technical inspections (PTIs) and repair and maintenance. Since every vehicle with an OBFCM is also required to be fitted with such an interface, it is already possible today to read out the data in all vehicles. Furthermore, the interpretation of the read-out data is standardised in "SAE J1979". Consequently, all relevant information can be retrieved from the vehicle using any commercially available external test equipment. This wired solution prevents any manipulation of the data during transmission. Data protection and data security are also optimally ensured, as only authorised persons have access to the OBD interface installed in the vehicle. Therefore, CECRA recommends the solution of reading out the data via the standardised electronic vehicle interface. To ensure the direct transmission of a representative quantity of data to the Commission for all vehicle models, CECRA believe that the following points are necessary: • Development of an EN standard under the Vienna Agreement, which provides a definition of direct transmission with end-to-end encryption • Mandatory introduction of this interface in the type-approval regulations • Full transparency for the vehicle owner and clarification of the costs for the data transmission with regard to the consumer • During the life of the vehicle once put on the road, a full access (in wired and/or OTA form) to vehicle data (i.e. the parameters monitored and reported) for repairers so that they can proceed, if necessary, to bring the vehicle back into emission conformity. • The delegated regulation must remain aimed at the vehicle manufacturers, the Member States and the repairers (selected by the driver or the owner of the vehicle) and not be used to monitor individual vehicles or drivers.
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Response to Development of Euro 7 emission standards for cars, vans, lorries and buses

25 May 2020

In the document downloadable via the link below, we have studied the three options of the proposal: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12313-Development-of-Euro-7-emission-standards-for-cars-vans-lorries-and-buses We have chosen the most virtuous of the 3 but not in its current form. We support option 3 but with some amendments : see CECRA's position in attachment.
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Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and

17 May 2019 · 'Access to in-vehicle data' and EC recommendation on '5G, cybersecurity and data governance'

Response to Evaluation of the Motor Vehicle Block Exemption Regulation

18 Mar 2019

As the European umbrella association of the motor trade and repair sector – representing the interests of both franchised vehicle dealers and independent repairers – CECRA welcomes this European Commission’s initiative. Our members have experienced some unbalances which were already existing during the previous framework and, as anticipated by CECRA in 2010 have been accentuated under the new regime due to the disappearance of those rules providing due protection to vehicle dealers against vehicle manufacturers’ initiatives aimed at punishing some dealer’s pro-competitive activities. Even some of the few remaining protective clauses mentioned in the guidelines - such as the possibility for authorised dealers to keep acting as an authorised repairer when, for a reason whatsoever, he has lost his status of franchised dealer – have been difficult to activate before some national courts. This is a point we believe should be better expressed in future guidelines. Manufacturers and importers are today competitors to the dealers in some customer segments. They have kept the right to sell cars directly to some customer segments and at the same time they demand (based on dealer agreements) business critical data (customer data, data from pricing and profitability etc) from dealers. It is clear that due to this operation manufacturers/importers have a lot of larger data banks that a single dealer will ever have. That distorts competition largely. In the light of the above, the overall judgement expressed by the European vehicle dealers and repairers upon the Motor Vehicle Block Exemption Regulation n° 461/2010 is the following: • The current rules - although they need to be modernised in order to better fit to the nowadays market, shaped by the latest trends and technologies which allow the OEMs to have an increasing grip on the customer and position themselves as a separate ‘privileged’ player compared to both the independent repairers and also the franchised ones (i.e. resetting of fault codes, which happen over the air, and are, due to technical barriers, sometimes impossible for traditional repairers, being them independent or authorised) - give to each player of the complex and varied automotive value chain room to play his role in servicing the consumers’ needs. • On the one hand, authorised dealers/repairers enjoy the faculty to be the exclusive recipients and act as the sole distributor of the so-called “captive parts” (on which the vehicle manufacturer holds a valid industrial property right). This gives vehicle manufacturers, as mentioned in the guidelines, the right incentive to keep investing in the development of their products, and a proper compensation to franchised dealers/repairers who have to maintain (and face the related costs of) a higher standard in their facilities as opposed to the one of regular independent repairers. • Independent repairers, in turn, would not be able to properly compete in the vehicle repair and maintenance market if vehicle manufacturers were not obliged to provide them with access to technical repair and maintenance information, or without the clause, explicitly forbidding vehicle manufacturers to prevent their original equipment suppliers from supplying their spare parts to independent repairers. Against this background, we urge the European Commission to properly assess the new technically advanced possibilities for OEMs to prevent, restrict and distort competition. Both the automotive industry and the personal mobility is being deeply re-shaped by some major trends such as Mobility as a Service, Connected Cars, Electromobility, Automated Driving, etc. We need the new Motor Vehicle Block Exemption Regulation to capture these changes. Therefore, we look forward to further engage and share our knowledge with the European Commission in the future steps of this evaluation process, hoping that such an important issue will be granted the necessary time and attention.
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Response to Evaluation of the Vertical Block Exemption Regulation

6 Dec 2018

Dear Sir, Dear Madame, Please find attached CECRA's contribution to the evaluation of the EU competition rules on vertical agreements. CECRA is the European umbrella association of the motor trade and repair sector representing the interests of both, franchised vehicle and truck dealers and independent repairers. If you have doubts or questions, please, send us an email at the following address: bernard.lycke@cecra.eu
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Response to Cooperative, Connected and Automated Mobility (CCAM)

16 Nov 2018

Please, notice that this is the most important part of the document for us: "Data governance framework: models on access to in-vehicle data are still emerging and to date there is still no model that is widely accepted across stakeholders. For instance, the 2017 Commission study on 'Access to In-vehicle Data and Resources' indicates that centralisation of in-vehicle data as currently implemented by some market players, might in itself not be sufficient to ensure fair and undistorted competition between service providers. As models for data access are still emerging, the Commission will make recommendations in light of the principles proposed in the Communication 'On the road to automated mobility: An EU strategy for mobility of the future' of 17 May 2018" Please, find attached CECRA position paper on Connectivity and access to in-vehicle data
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Response to Technical information necessary for roadworthiness testing, and the recommended test methods

19 Oct 2018

After checking the proposal, we suggest the following changes to the implementing act: a) Directive instead of Regulation: The EC proposed a Regulation for this implementing act. The source legal act (2014/45/EU) is a directive and the member states transposed this directive in their national law. Some of them has also foreseen the implementing act. Therefore, it is necessary that this implementing act have the flexibility for national trnasposition. b) Article 5/2: „the technical information shall be made available not later than 6 months after the registration or entry into service of the vehicle“ should be replaced with “the technical information shall be made available at the registration or entry into service of the vehicle.” OEM have to deliver a lot of data at the time of registration or entry into service of a vehicle. If they deliver different data on different times, this will be a source of errors, which should be avoided. Otherwise this Art 5/4 of Directive 2014/45/EU would open up to the possibility to do a PTI after an accident affecting the main safety-related components of the vehicle, such as wheels, suspension, deformation zones, airbag systems, steering or brakes, without the possibility to get access to the necessary data. Therefore, it is necessary that these data have to be available immediately after registration. c) Article 6: the proposal is not defining a standard. The international RMI Standards ISO 18451 and ISO 18542 have to be implemented. Due to Regulation 715/2007 and Regulation 692/2008 an international standard for the structures of data were defined. RMI-data and PTI-data have the same basis. Therefore, it seems efficient to use these same standards in the implementing act.
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Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and

9 Mar 2018 · Connected Car

Meeting with Martin Übelhör (Digital Economy)

13 Dec 2016 · ePrivacy

Meeting with Jocelyn Fajardo (Cabinet of Commissioner Violeta Bulc)

19 Mar 2015 · Meeting with CECRA

Meeting with Aura Salla (Cabinet of Vice-President Jyrki Katainen)

12 Dec 2014 · Automotive & Repair Industry