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European Small Volume Car Manufacturers Alliance

ESCA

ESCA advocates on behalf its members in the European institutions and its member states to ensure their interests are represented alongside the mainstream automotive industry.

Lobbying Activity

Meeting with Leopoldo Rubinacci (Deputy Director-General Trade)

15 May 2025 · Exchange of views on EU-US trade relations

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

ESCA welcomes the opportunity to provide feedback on the draft Implementing Regulation under Regulation (EU) 2024/1257 concerning specific methods, requirements and tests, including compliance thresholds, for OBFCM devices and OBM systems, characteristics and performance of driver warning systems and inducement methods and methods to assess their operation, EVP format and data and methods of communication of EVP data of motor vehicles of categories M1 and N1. However, ESCA would like to raise its request a clarification on the data applicable for environmental data in-vehicle display. Appendix 1 of Annex VI of the draft implementing regulation outlines the environmental parameters that must be displayed inside the vehicle as part of the Euro 7 on-board monitoring framework. While the regulation aims to enhance transparency and driver awareness of environmental performance, its application to manufacturers (U)SVMs remains unclear. Based on the current text, it appears that only one parameterNOx emission limits as listed in Table 3is clearly applicable to (U)SVMs, as all the other parameters are referenced and tracked within OBM and on-board fuel consumption monitoring (OBFCM) from which (U)SVM are exempted. In addition, it remains unclear whether the intention is for this environmental information to be made available exclusively through an in-vehicle display or also via the OBD (On-Board Diagnostics) port, particularly in cases where the vehicle is not equipped with a dedicated digital interface or display unit. ESCA therefore requests that the Commission clearly specify whether access via the OBD port is a compliant alternative to in-vehicle display for (U)SVMs, particularly for vehicles without integrated digital displays. Such clarifications are essential to preserve the viability of small-scale manufacturers while ensuring continued alignment with environmental integrity and transparency goals. We remain at your full disposal for additional questions or further information.
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Response to Emissions type-approval methods, tests, requirements and methodologies for M1 and N1 motor vehicle categories

13 May 2025

ESCA welcomes the opportunity to provide feedback on the draft Implementing Regulation under Regulation (EU) 2024/1257 concerning the methods, tests, requirements, and methodologies for type-approval of motor vehicles under the Euro 7 emissions standard. However, it would like to offer some recommendations to ensure that the Implementing Regulation is effective in achieving the environmental objective of the main Regulation, while also safeguarding the viability and competitiveness of small volume manufacturers within the single market. First, ESCA urges the Commission to provide guidance on how USVMs are required to demonstrate compliance with article 8 Euro 7 Regulation, notably on acceptable laboratory-based test procedures as well as ISC and market surveillance criteria. The absence of precise procedural guidanceespecially concerning applicable test methodologies, boundary conditions, and performance evaluation criteriacreates legal uncertainty and implementation challenges for manufacturers operating at ultra-limited scale. Second, ESCA would like to propose the removal of the compliance requirement with UN Regulation No 155 laid down in Annex XVI of the draft Implementing Regulation or alternatively, add an explicit exemption for USVMs. ESCA is pleased to see that the European Commission has already considered our concerns by including a specific note in the proposed draft confirming the exemption for USVMs from compliance with UN Regulation No 155, however we believe that further clarification is needed. Third, ESCA urges the Commission to incorporate small series scheme I simplifications in Euro 7 context to allow USVM to apply for an emission certificate, notably on-board diagnostic (OBD) systems and gear shift indicator (GSI), in order to ensure legal certainty and regulatory coherence. By incorporating these specific requirements into the Euro 7 framework, USVMs would be able to apply for a Euro 7 certificate under the same conditions they currently benefit from within the existing small series scheme. This would allow USVMs to maintain their competitiveness, access both EU and potentially international markets, and meet the necessary environmental standards without undue regulatory burdens. Finally, we urge the Commission to provide the missing declaration templates for SVMs, notably for gaseous pollutants, particulate matter (PM), particle number (PN), and CO emissions, as well as On-Board Fuel Consumption Monitoring (OBFCM) data, electric energy consumption, and electric range. The absence of such templates not only creates legal uncertainty but also risks delays in type-approval procedures and inconsistent implementation across Member States, as approval authorities may interpret the requirements differently in the absence of harmonised documentation. We remain at your full disposal for additional questions or further information.
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Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and DGA Group Europe SA

10 Feb 2025 · Action plan for automotive industry