European Small Volume Car Manufacturers Alliance
ESCA
ESCA – the European Small Volume Car Manufacturers Alliance – is a pan-European association comprising independent small volume car manufacturers (SVMs) based in the EU.
ID: 246272027879-90
Lobbying Activity
Meeting with Jens Gieseke (Member of the European Parliament, Shadow rapporteur) and E-GAP S.r.l. Società Benefit
7 Dec 2022 · Austausch zur Verkehrspolitik
15 Apr 2022
ESCA welcomes the proposed Delegated Regulation from the Commission and would like to express its position, with regards to the content of the proposed Delegated Regulation and the Annexes.
Below we provide an overview of the aspects of the proposed documents that should be reviewed before the publication of the final text, to ensure an optimal environment for the car manufactures operating within the ‘small series’ regime.
1. Scope: threshold of 10,000 M1 and 22,000 N1 vehicle registrations in EU
ESCA welcomes the increased threshold of 1,500 vehicle registrations, however, the proposed inclusion of all vehicle types per manufacturer as part of the ‘Small series scheme I’, runs the risk of making the increase of the volume threshold too restrictive on the growth potential of Europe’s small volume manufacturers.
Threshold must be viewed as a ceiling, not a disruptor for small manufacturers. ESCA believes that thresholds should not only legitimately restrict access to flexibilities but they should also allow for growth of the smallest manufacturers, in the view to deploy unlimited series fast. All SVMs have identical business models with limited to no access to vehicle safety technologies because orders are not prioritized due to low volumes. There is a risk of non-compliance for all ESCA members if threshold is put too low.
In addition a separate N1 threshold is required as the N1 vehicles market is significantly different from the M1 market, with much lower margin profits per vehicle and hence larger production volumes per manufacturer. However, and similarly as to the M1 market, N1 small volume manufacturers face similar issues in accessing safety technologies, with close to no prioritization of their orders, making compliance with GSR2 requirements extremely difficult if not impossible.
We support alignment with the EU emissions legislation and call on Commission and Member States to support a 10,000 M1 and 22,000 N1 threshold of EU vehicle registrations per year for the ‘Small Series Scheme 1’.
2. Scope: regulatory certainty on definitions used
We understand the rationale for the Commission restricting the access to the Small Series Scheme 1 to a limited selection of manufacturers by conditioning the vehicle type to not be based on or derived from vehicles produced in large series. However, a uniform and harmonized understanding of these concepts is critical to ensure regulatory certainty in order to avoid different interpretations across national type approval authorities and technical services.
ESCA believes clarity on the definitions and wordings used is necessary to support national type approval authorities, technical services and manufacturers in their assessment of which manufacturer and vehicle type can qualify for the Small Series Scheme 1.
3. Timing
ESCA supports the Commission’s proposal for the transitional period of 2 years for the application of the requirements for new vehicle types (7 July 2024) and additional 2 years for all new vehicles produced in small series (7 July 2026). With the expected text’s publication date in July 2022, this provides sufficient time to adapt the planning and production lines of the vehicles and to meet the new requirements of GSR2.
ESCA supports 24 months lead time for new types and an additional 24 months for all vehicle registrations for M1 vehicles and date of application 7 July 2028 for all types of N1 vehicles.
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