Fédération Nationale de l'Automobile
FNA
The Fédération Nationale de l'Automobile (FNA) represents multi-brand automotive craft businesses and SMEs in France.
Lobbying Activity
2 Dec 2025
La Fédération Nationale de lAutomobile (FNA) remercie la Commission européenne doffrir aux acteurs de laprèsvente automobile la possibilité de commenter la proposition de règlement délégué du Règlement 2018/858. Laccumulation de dispositions et de références à une diversité dautres règlements complexifie la lecture et risque de compromettre la sécurité juridique. Audelà de la forme, le fond apparaît dautant plus problématique que la jurisprudence de la Cour de Justice du 5 octobre 2023 plaide pour une réglementation ouverte à la concurrence, où la cybersécurité ne saurait être instrumentalisée pour verrouiller le marché au bénéfice exclusif des constructeurs. Le texte cijoint expose la position de la FNA, prête à porter ses revendications auprès des instances décisionnelles et judiciaires afin de garantir le libre choix de lautomobiliste.
Read full responseMeeting with Pascal Canfin (Member of the European Parliament, Shadow rapporteur)
18 Feb 2025 · End-of-life of vehicles Regulation
French Car Repairers Demand Binding Rules for Vehicle Data
24 Jun 2024
Topic — Evaluation of EU competition rules regarding vertical agreements in the motor vehicle sector.
Message — The organization calls for a binding legal framework to guarantee independent repairers access to vehicle-generated data. They request specific legislation to ensure technical interoperability and prevent manufacturers from using digital locks to exclude competitors.12
Why — This would allow independent businesses to remain competitive during the industry's rapid digital transition.3
French automotive SMEs urge realistic recycling goals and implementation time
4 Dec 2023
Topic — New EU rules for vehicle design, collection, and recycling to improve environmental circularity.
Message — The organization requests a narrower definition of end-of-life vehicles and longer implementation timelines. They also advocate for harmonized recycling targets that are technically achievable for small companies.12
Why — This would protect small recyclers from excessive costs and avoid restrictive manufacturer-imposed requirements.3
Impact — Large vehicle manufacturers would lose control over the independent car repair and recycling networks.4
Response to Revision of the Directive on Driving Licences
28 May 2023
The Fédération Nationale de l'Automobile (FNA) has been the professional organisation representing companies in the automotive, motorcycle and mobility services sector since 1921. It supports entrepreneurs and craftsmen in the automotive and mobility, in particular driving schools represented by the Union des Indépendants de la Conduite (UNIC). This organisation ensures the defence of local businesses interests that are essential to learning about mobility. Active in many French departments, UNIC aims to be the first driving school in France, the first and the only training centre. FNA and UNIC representatives thank the European Commission for this Consultation on Directive 2006/126/EC about a major revision of the Union rules related to driving licences. The present reform is a response to Member States' request to strengthen the EU road safety legal framework to ensure that fewer people die in road accidents. Summary of FNA's response to the European Consultation 1. French market 2. FNA and UNIC Position on the proposal of modified Directive presented by the European Commission 2.1 Choice of strategic option B and the compulsory minimum age to getting the class B driving licence 2.2 Preference for a less strict strategic option B which does not stigmatize seniors 2.3 Choice of strategic option B and the compulsory minimum age to getting the class B driving licence with ACC 2.4 Choice of strategic option B and adaptation to new technologies and societal changes 3. FNAs Position, in particular of the recovery-towing sector on the extension of the B permit to 4.25 t 3.1 Observation of the constant vehicle weight increase 3.2 Consequences for road safety and changing circumstances of economic development 3.2.1 Compulsory training in the control of vehicles that hae become heavier 3.2.2 Proposal for a class "B" driving licence at 4,25 t 3.2.3 Simplification of access to the driving licence for light commercial vehicles 3.2.4 Intructors' training 3.2.5 Learners' training 3.2.6 Practical driving test in real conditions 3.2.7 No lowering of the age to 18 for class "D" licences 3.2.8 Probationary period limited to driving light vehicles (urban cars) 3.3 Furthering knowledge and promoting the mobility contributing to the reduction of pollution emissions 3.3.1 FNA supporting the European Commissions Position 3.3.2 Appreciation for the European Commissions Position in support of FNA's Position on the B licence extended to 4.25 tonnes Please find attached FNAs and UNICs Position further discussed
Read full responseResponse to Improving access to emergency services through the single European emergency number ‘112’
12 Sept 2022
French “Fédération Nationale de l'Automobile” (FNA) has been the professional organization representing craft businesses in the automotive sector and in mobility services since 1921. Their representatives are supporting entrepreneurs and craftsmen whether they are self-employed or affiliated with a network. The organization is directed by volunteer business leaders working for their peers in order to federate, defend and promote the interests of sector businesses. Composed of 60 regional or departmental groups, spread across the entire national territory, the FNA benefits from a solid network of local services for their members. FNA brings together professionals from the automotive trade and repair, breakdown assistance-towing, fuel distribution and technical control, road safety education and associated services.
The European Union has set up a harmonization of an interoperable emergency call service throughout the Union. FNA representatives took part to the development of these regulations at European level through their network of experts called European Automotive Services and Repairers Association (EASRA).
FNA representatives thank the European Commission for gathering stakeholders’ views regarding emergency communications, in particular the delegated act introducing reporting obligations for the Member States to improve the monitoring of the implementation of emergency communications provisions and to help establish best practices.
The following issues are developped in the enclosed document
- Delegated Regulation required
- Qualification of calls by the most appropriate Public Safety Answering Point (PSAP)
- FNA calling on the European Commission to be vigilant for vehicle sales market and vehicle towing market
- Supervision of agreements between the State and private operators in charge of receiving calls
- Surveys highlighting the risks of a steerable mobility
Read full responseResponse to Type approval of motor vehicles regarding access to in-vehicle generated data
17 Jun 2022
French Fédération Nationale de l’Automobile (FNA) has been the professional organization representing craft businesses in the automotive sector and in mobility services since 1921. Their representatives are supporting entrepreneurs and craftsmen whether they are self-employed or affiliated with a network. The organization is directed by volunteer business leaders working for their peers in order to federate, defend and promote the interests of sector businesses. Composed of 60 regional or departmental groups, spread across the entire national territory, the FNA benefits from a solid network of local services for their members.
FNA representatives thank the European Commission for gathering stakeholders' views on the current state of play of access to vehicle data, functions and resources, as well as their feedback on a range of possible measures that could improve the situation, and on the costs, impacts and risks of these measures.
FNA members agree European regulations directly applicable to the French market, taking up their demands that they have been developing for decades. They have long been concerned with rebalancing the aftermarket services, which has been left for too long at the mercy of car manufacturers to the detriment of consumers' freedom of choice and the preservation of their purchasing power.
The comments below are aimed to make effective the access to data, functions and resources, because it is crucial for the development of innovative data-driven mobility services and consumers’ purchasing power.
Comments are enclosed in the attached document (txt doc).
Read full responseFrench auto federation demands fair vehicle data access
12 May 2022
Message — The FNA requests automatic, real-time access to vehicle technical and usage data without complex consent processes. They seek a requirement for manufacturers to provide this information in usable formats at minimal cost.123
Why — This ensures independent repairers can compete fairly and fulfill their legal diagnostic obligations to customers.45
Impact — Car manufacturers lose the ability to capture the aftermarket through digital locking practices.6
Response to Promoting sustainability in consumer after-sales
12 Mar 2022
Many thanks for giving the Federation of Craft Businesses in the Automotive sector and in Mobility Services (FNA) the opportunity to answering the European Commission Consultation on the right to repair.
The proposal for provisions on the right to repair, presented by the European Commission, is a response to the vote of the European Parliament of 25 November 2020 on the Resolution for a more sustainable single market. To this end, FNA's developments recall the MEPs’ support given to independent repairers (I). In accordance with the method adopted by the European Parliament, an impact assessment is described in the enclosed document to consider the negative effects on the automotive after-sales market of a modification that is extremely detrimental to the interests of independent repairers and consumers who benefit from their services, i.e. the extension of warranty period. These following practices misapplying legal provisions on warranty for the sole purpose of circumventing competition rules have been detected in a very long time, since car makers are abusing their market power (II).
I. The right to repair must ensure effective support for independent repairers in order to promote consumer choice and achieve an overall sustainable single market (arguments are developed in the enclosed document).
II.The right to repair must be subject to an impact assessment to consider the possible effects of such potential extensions on independent repair services bacause of car makers misusing warranty extension to foreclose the aftermarket (see the enclosed document).
The extension of the availability of spare parts is an absolute necessity because of the aging vehicle fleet and the reduced purchasing power of consumers. This availability priority is to be distinguished from warranty extension given by car makers.
Read full responseResponse to Requirements for Artificial Intelligence
6 Aug 2021
Federation of Craft Businesses in the automotive sector and in mobility services (FNA) would like to thank the authors of the Proposal of European Regulation laying down harmonized rules on Artificial Intelligence (AI) to inform citizens and stakeholders about the Commission's work in order to allow them to provide feedback on the intended initiative and to participate effectively in future consultation activities. FNA representatives also express their thanks for being given the opportunity of once again making submissions on the Consultation. They make the following comments.
Summary
Undue hardship on advanced technologies
New European Regulation laying down rules on AI should be in line with technical progress on the Automotive aftermarket.
FNA representatives welcome option 3 in particular stating mandatory requirements, Articles 64, 71, 84 and Annexes, also Commission Staff Working Document on the Impact Assessment of April 21,2021, in particular Problem 2 - Use of AI poses an increased risk of citizens' fundamental rights and Union values violations as use of AI may, indeed, lead to discriminatory outcomes keeping out independent repairers of the maintenance and repair services.
Therefore FNA representatives call on the European Commission to make effective the following fundamental rights
-Unrestricted access to vehicle repair and maintenance data
-Competition in the market for Automotive data services and AI information
-Actual consumer’s choice being analysed regularly to make it effective on the Automotive services
-More financial and human resources for national authorities
Detailed comments are attached
Read full responseResponse to Revision of the Directive on Driving Licences
20 May 2021
FNA Contribution
1. FNA welcomes the EU Commission new initiative, whose aim is to tackle key problems that have been identified in the study on the implementation of the Directive 2006/126/EC in particular those related to update the current rules and procedures on drivers’ testing and training for what concern the following questions:
-Experience and risk-awareness
-Insufficient skills, knowledge and/or medical fitness
-Environmental performance, i.e. Insufficient skills and knowledge in relation to new vehicle technologies (alternative fueled vehicles, autonomous driving) and mobility concepts (e.g. eco-driving or car-sharing) may limit the impact of current and future drivers on the reduction of the direct and indirect gas emissions.
2. FNA supports the EU Commission policy option aimed at improving the current Directive as follows:
Whatever the technological evolutions of vehicles and the emergence of new forms of mobility, road safety must guide the public authorities in the definition of new regulations which would reform the use of traffic lanes. A balance should be found between strengthening training and the price of a driving licence. The FNA recommends the following points to consider.
Objective 1. To increase safety on Union roads by reducing dangerous behaviour.
Public policies often reduce the scope of “dangerous behaviour” to a speeding violation combated by the generalization of speed cameras. This approach is very reductive. To be effective, it would be advisable to legally define the dangerous behaviour that led to the accident, such as motorists driving in the middle of the road, not respecting safety distances, running red lights… The rules exist but they are not respected. This amounts to analysing more objectively motorists’ behaviour who contributed directly or indirectly to the accident and to sanction them more severely in terms of loss of points.
Objective 2. To increase safety on Union roads by improving driving skills and increasing risk awareness and knowledge about road safety.
Accompanied driving (AAC)
France has implemented this training for many years and it is a success. In 2019, early learning to drive resulted in the issuance of 213,898 B licences (i.e. + 8.5% compared to the previous year).The proportion of permits issued in AAC represents 24.8% of all B permits issued. The pass rate for the B permit for these candidates is 74.24% (17 points higher than the overall pass rate and 21 points higher than the pass rate excluding AAC). The FNA is therefore very favorable to it. With this experience, the French regulatory framework can be a model to follow. On the other hand, we are opposed to starting training at the age of 15. Only 2 out of 10 students are on average sufficiently ready for this training. We recommend raising the start of training to 16 years old.
Progressiveness between driving licence categories
Young drivers aged 18 to 24 account in 2017 18% of road deaths, and are involved in 32% of accidents. The FNA proposes that during the three-year probationary period (reduced to two if the motorist does a post-licence internship or 1 year and a half when AAC), we limit the type of vehicles driven by a power / weight ratio to city cars for example.
Further comments are attached
Read full response4 Feb 2021
Independent repairer access to security-related repair & maintenance information (RMI) is consumer’s freedom of access to aftermarket service suppliers of his choice and best price
1. A crucial issue for more than 14 years -→Notwithstanding, the Commission’s proposal is deferring the date of application from two years after publication of the modified Delegated Regulation! This deferral confers a significant benefit upon car manufacturers as it improves their market power on the automotive aftermarket where their services are more expensive than those of independent repairers.
2. Disproportionate provisions of the new proposal of Annex
Already in 2013, Mr. Philippe Jean when he was Head of Unit ‘‘Automotive industry’’ in Directorate General Enterprise and Industry of the European Commission supported that independent repairers’ access to repair and maintenance information (RMI) be “an overreaching horizontal principle” to be vigorously applied across policy areas.
►But the Conformity Assessment Body (CAB) simply receives car manufacturers’ Certificate on RMI where they indicate their website address & access conditions to RMI. Only if independent repairers or their association file a complaint to the CAB, this approval authority proceeds to an audit to verify compliance by manufacturers with their obligations. ►In contrast, independent repairers must undergo an inspection procedure where they have to demonstrate that they pursue a legitimate business activity. Such a procedure may seem burdensome. It is a reflection of car manufacturers’ longstanding practices causing considerable harm in terms of a significant reduction in choice and higher prices for repair services. →The efficiency of the control can be reached without encumbering independent operators with an excessive supervisory burden or restricting competition. FNA representatives call upon the European Commission for a total redesign of the authorization procedure (Appendix 3): ●Independent operators are chosen by their customers and already approved by the Chamber of Trades or the Chamber of Commerce, both obliging them to complete criminal records check. ●Therefore, an efficient and quicker solution to verify that the independent operator is carrying out a legitimate business activity is setting up a direct online criminal record check service between the CAB and the French Ministry of Justice Teleservice. ●Regarding employees, there is in France a strong cultural and legal barrier which prohibits the employer from checking criminal record information. Even in a few rare activities regulated by French legislator for activities listed by Decree only the authority “Préfet” is able to investigate in the “Système de traitement des infractions constatées – STIC” database. These exceptions are consistent with a trust-based co-operation between employers. French case law tends to consider that there are efficient means to control the integrity of an employee by asking references to previous employers. Another ground to this solution is the functional approach which best characterizes the employee’s relationship with his manager. Consequently, the assessment of the legitimate business activity must be carried out for the employer solely, i.e. for the independent operator.
Further comments are enclosed.
Read full responseResponse to A New Consumer Agenda
10 Aug 2020
Federation of Craft Businesses in the automotive sector and in mobility services (FNA) would like to thank the authors of the Roadmap on a New Consumer Agenda.
This information will make a substantial contribution towards an improved understanding and enforcement of the European provisions relating to the effective protection of consumer rights particularly in a complex and constantly evolving online environment.
Finally, FNA representatives express their thanks for being given the opportunity of once again presenting the following comments in the attached document.
Read full response10 Aug 2020
Federation of Craft Businesses in the automotive sector and in mobility services (FNA) would like to thank the European Commission for the draft regulation related to the online data exchange and the notification of EU type-approvals under Regulation (EU) 2018/858 of the European Parliament and of the Council.
This information will make a substantial contribution towards an improved understanding and enforcement of the European provisions to make accessible to the public as from 1 September 2022 a list of the EU type-approvals for vehicles, systems, components and separate technical units that have been granted, amended, refused or withdrawn.
Finally, FNA representatives express their thanks for being given the opportunity of once again sending their comments in the attached document.
Read full responseResponse to Revision of the NIS Directive
10 Aug 2020
Federation of Craft Businesses in the automotive sector and in mobility services (FNA) would like to thank the authors of the Evaluation Roadmap on Directive (EU) 2016/1148 concerning measures for a high common level of security of network and information systems across the Union (the NIS Directive). This information will make a substantial contribution towards an improved understanding and enforcement of the European provisions relating to key cybersecurity issues. Finally, FNA representatives express their thanks for being given the opportunity of once again making the following comments in the attached document.
Read full responseResponse to Administrative procedures and technical specifications for approval of vehicles as regard their safety
10 Aug 2020
Federation of Craft Businesses in the automotive sector and in mobility services (FNA) would like to thank the European Commission for the draft regulation. This information will make a substantial contribution towards an improved understanding of the European provisions relating to the key competition issues arising on the automotive market from businesses, consumers and European competition law enforcers. Finally, FNA representatives express their thanks for being given the opportunity of once again making the following comments in the attached document.
Read full responseResponse to Legislative framework for the governance of common European data spaces
28 Jul 2020
Federation of Craft Businesses in the automotive sector and in mobility services (FNA) would like to thank the authors of the Inception Impact Assessment on the legislative framework for the governance of common European data spaces.
This information will make a substantial contribution towards an improved understanding and enforcement of the European provisions relating to the European Strategy for Data.
Finally, FNA representatives express their thanks for being given the opportunity of once again making submissions and present the following comments in the attached document so as to improve the evaluation purpose and scope.
Read full responseResponse to Sustainable and Smart Mobility Strategy
28 Jul 2020
Federation of Craft Businesses in the automotive sector and in mobility services (FNA) would like to thank the authors of the Roadmap on Sustainable and Smart Mobility Strategy. This information will make a substantial contribution towards an improved understanding and enforcement of the European provisions relating to key environmental issues and their side effects on economic efficiency. Finally, FNA representatives express their thanks for being given the opportunity of once again making submissions and present the following comments so as to improve the evaluation purpose and scope.
FNA position is explained in the attached document.
Read full response30 Jun 2020
Platforms leading to imbalances
1. FNA supports the European Commission analysis, i.e. “traditional businesses are increasingly dependent on a limited number of large online platforms. This leads to imbalances in the bargaining power between large online platforms on the one hand and their users and rivals on the other, a trend which is expected to increase in the future.”
2. There are 139,602 enterprises on French automotive services market that employ almost 40% of the 399,500 employees of this sector. They have a major role to play to make new mobility sustainable, democratic and non-discriminatory as they provide a local networking which consistently deliver efficient closeness service and adapted solutions for 43 million vehicles.National and European authorities should therefore intervene both in the interest of consumers and SMEs.
Taking advantage of data gathered from one area of their activity to develop new services and “steer” consumers to them
3. Advanced technologies win the automotive industry: on the one hand, the electric car revolutionizes maintenance methods; on the other hand, the increasing connectivity of new "smart" vehicles tends to channel diagnostic, maintenance and repair services through the manufacturer's network. Difficulties in access to the maintenance and repair market, which have already been identified for the combustion engine, are focused now on the electrical system. While the new technique is designed to reduce the cost of maintenance and repair, vehicle manufacturers tend to reserve the operation to their network, at the expense of consumers’ choice.
4. The exclusive and permanent connection of manufacturers with motorists entails the risk of favoring their network. Moreover, this risk has been highlighted by the European Commission, after the study carried out by the Cooperative Intelligent Transport Systems (C-ITS) group.
5. Another crucial automotive market, which is that of collision repair service is also fully distorted through insurer’s platform that the policyholder is required to call as soon as he is victim of a vehicle accident. This platform connects the insured with repairers and appraisers chosen by insurers “exerting too much systematic pressure on the insured and often making derogatory comments about his usual repairer in order to direct him towards the insurer’s one”, as noted by French Commission for Reviewing Commercial Practices (CEPC) and by Directorate for Competition and Fraud Prevention .
6. In addition, the power of the insurer’s platform is reinforced by general conditions of the automotive insurance contract, i.e. a “standard form agreement," whose full scope is not thoroughly understood by the insured. This platform is an efficient tool used by insurers to weaken and squeeze out of the market 8,000 vehicle body repairers from the existing 14,000 ones.
7. The principle of free choice is of public interest. It is based on transparency. It must become a tangible reality in the automotive market. This justifies strengthening and clarifying the framework so that “to establish clear obligations and prohibited practices for online platforms with economic power, application of which may provide European consumers and business users more choice and access to innovative solutions. This also includes an objective of making online platform ecosystems and online activities more open, fair, predictable and accessible, increasing the social gain from innovation, and/or levelling the playing field between the platforms, on the one hand, as well as actual and/or potential competitors, on the other.”
8. FNA representatives welcome the European Commission option of “an ex ante regulatory tool” establishing both clear obligations to be complied by platforms and prohibited or restricted unfair trading practices (“blacklist practices) and also “the ability to impose, where considered necessary and justified tailor-made remedies such as interoperability requirements".
Read full responseResponse to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services
30 Jun 2020
Platforms used as a significant tool for information asymmetries
1. FNA supports the European Commission analysis, i.e. “there is currently a lack of oversight over digital services in the current legal framework, with significant information asymmetries between the services and their users (citizens and businesses).”
2. There are 139,602 enterprises on French automotive services market that employ almost 40% of the 399,500 employees of this sector. They have a major role to play to make new mobility sustainable, democratic and non-discriminatory as they provide a local networking which consistently deliver efficient closeness service and adapted solutions for 43 million vehicles.National and European authorities should therefore intervene both in the interest of consumers and SMEs.
3. Advanced technologies win the automotive industry: on the one hand, the electric car revolutionizes maintenance methods; on the other hand, the increasing connectivity of new "smart" vehicles tends to channel diagnostic, maintenance and repair services through the manufacturer's network.
4. Difficulties in access to the maintenance and repair market, which have already been identified for the combustion engine, are focused now on the electrical system. While the new technique is designed to reduce the cost of maintenance and repair, vehicle manufacturers tend to reserve the operation to their network, at the expense of consumers’ choice.
5. The exclusive and permanent connection of manufacturers with motorists entails the risk of favoring their network as consumers experience a tension between making their voice heard and understanding the true scope of the obligations imposed on them under the pretext of implementing the advanced technology.
6. Moreover, this risk has been highlighted by the European Commission, after the study carried out by the Cooperative Intelligent Transport Systems (C-ITS) group.
7. Another crucial automotive market, which is that of collision repair service is also fully distorted through insurer’s platform that the policyholder is required to call as soon as he is victim of a vehicle accident. This platform connects the insured with repairers and appraisers chosen by insurers “exerting too much systematic pressure on the insured and often making derogatory comments about his usual repairer in order to direct him towards the insurer’s one”, as noted by French Commission for Reviewing Commercial Practices (CEPC) and by Directorate for Competition and Fraud Prevention .
8. In addition, the power of the insurer’s platform is reinforced by general conditions of the automotive insurance contract, i.e. a “standard form agreement," whose full scope is not thoroughly understood by the insured. This platform is an efficient tool used by insurers to weaken and squeeze out of the market 8,000 vehicle body repairers from the existing 14,000 ones.
Answering the Consultation
9. The principle of free choice is of public interest. It is based on transparency. It must become a tangible reality in the automotive market. This justifies strengthening and clarifying the framework in the sense of “a more comprehensive legal intervention, updating and modernising the rules of the e-Commerce Directive”. Also “an effective system of regulatory oversight, enforcement and cooperation across Member States, supported at EU level” should be created “providing for an effective EU-wide governance of digital services through a sufficient level of harmonisation of rules and procedures”. FNA representatives welcome that “public authorities’ capabilities for supervising digital services would be strengthened including through appropriate powers for effective and dissuasive sanctions for systemic failure of services established in their jurisdiction to comply with the relevant obligations, potentially supported at EU level.”
Federation of Craft Businesses in the automotive sector and in mobility services (FNA)
Read full responseResponse to New competition tool
29 Jun 2020
Summary
Platforms used as significant obstacle to access to automotive data and customers
Undue hardship on advanced technologies
Need of European regulations in line with technical progress
-Unrestricted access to vehicle repair and maintenance data
-Free choice of repairer in collision repair services
-Actual consumer’s choice being analysed regularly
Answering the EU Consultation
-“to identify competition problems and intervene before a dominant company successfully forecloses competitors”
-“to identify and remedy structural competition problems that cannot be addressed (at all or as effectively) under the EU competition rules even when companies are not dominant
Federation of Craft Businesses in the automotive sector and in mobility services (FNA) would like to thank the authors of the Inception Impact Assessment to inform citizens and stakeholders about the Commission's work in order to allow them to provide feedback on the intended initiative and to participate effectively in future consultation activities. FNA representatives also express their thanks for being given the opportunity of once again making submissions on the Consultation on New Competition Tool and they enclose the following comments.
Read full responseResponse to Development of Euro 7 emission standards for cars, vans, lorries and buses
29 May 2020
FNA’s Contribution on the Development of post-Euro 6/VI emission standards for cars, vans, lorries and buses
Summary
Regular repair and maintenance to take up the environmental challenge
●Old vehicle fleet and 2, 8 used vehicles are sold for 1 new one
●High value added services in vehicle pollution control at the lowest prices
Proposals for roadworthiness testing and eco-performance
●Real-time emission monitoring through on board diagnostic system
●Early diagnosis of the most common dysfunctions of vehicles
Accurate and independent measurement of emissions
●Real-world emission monitoring over the entire lifetime of a vehicle
●Plug and Play device ensuring independence from manufacturers
Federation of Craft Businesses in the automotive sector and in mobility services (FNA) would like to thank the authors of the Evaluation Roadmap to inform citizens and stakeholders about the Commission's work in order to allow them to provide feedback on the intended initiative and to participate effectively in future consultation activities. FNA representatives also express their thanks for being given the opportunity of once again making submissions on the Evaluation Roadmap and make the following comments.
Complete feedback here enclosed
Read full responseResponse to Evaluation of the Commission Notice on market definition in EU competition law
15 May 2020
Federation of Craft Businesses in the automotive sector and in mobility services (FNA) would like to thank the authors of the Evaluation Roadmap to gather evidence on the functioning of the Commission Notice on the relevant market definition. This information will make a substantial contribution towards an improved understanding of the European provisions relating to the key competition issues arising on the automotive market from businesses, consumers and European competition law enforcers. Finally, FNA representatives express their thanks for being given the opportunity of once again making submissions on the Evaluation Roadmap and make the following comments.
Summary
Reviewing the Evaluation Roadmap
Automotive aftermarket
●High degree of market power of car manufacturers and their practices, in particular by channeling data transmission on the connected vehicle operating condition
●Significant pressure applied by car insurers taking advantage of their digital platforms to steer motorists to repairers on whom they impose unprofitable conditions
Making the European Green Deal visible and effective
When defining markets, the European Commission should answer the question “Can motorists turn to local repairers or are they steered to remote businesses just because they benefit car manufacturers or insurers?”
Accurate guidance and legal certainty of the market definition
Complete feedback here enclosed
Read full responseResponse to Action Plan on fight against tax fraud
30 Mar 2020
Federation of Craft Businesses in the automotive sector and in mobility services (FNA)
→Focusing on citizens’ experience, small and medium sized businesses’ losses and the European Parliament willingness to remediate tax frauds and significant distortions of competition
→Sharing FNA’s input in fighting against “carousel” fraud. Brief report of the meeting with Commissioner Pierre MOSCOVICI, in the enclosed annex in page 6 of 2018 Review and page 3 of the online 2017 Review https://madmagz.com/fr/magazine/1216632#/page/1
→Agreeing reasons and method to transition to qualified majority voting (QMV) decision-making at EU level
Read full responseResponse to Evaluation of the Motor Vehicle Block Exemption Regulation
19 Mar 2019
Federation of Craft Businesses in the automotive sector and in mobility services (FNA) would like to thank the authors of the Evaluation Roadmap to gather evidence on the functioning of the Motor Vehicle Block Exemption Regulation (MVBER), including the supplementary guidelines and Frequently Asked Questions (FAQs). This information will make a substantial contribution towards an improved understanding of the European provisions relating to the key competition issues arising on the automotive market from businesses, consumers and European competition law enforcers.
Finally, FNA representatives express their thanks for being given the opportunity of once again making submissions on the Evaluation Roadmap and make the following comments.
Highlights of feedback are enclosed.
Read full responseResponse to More efficient law-making in taxation: a move to QMV
17 Jan 2019
Federation of Craft Businesses in the Automotive sector and in Mobility Services (FNA) would like to thank the authors of the Evaluation Roadmap to trigger a debate and explore possibilities for moving to qualified majority voting (QMV) in taxation. FNA representatives express their thanks for being given the opportunity of once again making submissions on the Evaluation Roadmap and make the following comments so as to improve the evaluation purpose and scope.
To this end they propose to focus on citizens’ experience, small and medium sized businesses (SMEs)’ losses and the European Parliament willingness to be more empowered, in order to remediate the weaknesses brought to light through the frauds, scandals and significant distortions of competition.
The complete feedback is enclosed.
Read full responseResponse to Evaluation of the Vertical Block Exemption Regulation
5 Dec 2018
-Federation of Craft Businesses in the Automotive sector and in Mobility Services (FNA) would like to thank the authors of the Evaluation Roadmap to gather evidence on the functioning of the Vertical Block Exemption Regulation (VBER) and the relevant Guidelines.
-This information will make a substantial contribution towards an improved understanding of the European provisions relating to the key competition issues arising in vertical relationships from businesses, consumers and European Competition law enforcers.
-Finally, FNA representatives express their thanks for being given the opportunity of once again making submissions on the Evaluation Roadmap and make the following comments so as to improve the evaluation purpose and scope.
-To this end they propose to focus on the present automotive market characterised by diminishing margins combined with increasing investment requirements. Indeed, recent years have seen car manufacturers and insurers shifting investments onto dealers, sub-dealers and bodywork repairers, while they were tightening the profit margins of these contracting parties of agreements which are referred to as vertical agreements because each operate at different levels of the production or distribution chain.
-In order to preserve competition for the benefit of consumers, appropriate safeguards are to be considered when deciding on the scope of a block exemption in order to prevent possible risks of foreclosure from arising, as well as to preserve dealers', sub-dealers’ and bodywork repairers’ margins to enable them to profitably remain on the market.
-Commercial dependence on car manufacturers and insurers is an important issue for many dealers, sub-dealers and bodywork repairers. In the context of vertical agreements, the dependence of one contractual partner on the other is not viewed as a competition problem in itself. Nonetheless, such a situation may create a problem for competition if it makes it easier for the stronger party to pressurise the weaker party (in this instance, the dealer, the sub-dealer and the bodywork repairer) to implement anti-competitive practices.
-The European Commission therefore has to be careful to preserve Article 101's deterrent effect by ensuring that the scope of any VBER is not so large as to enable suppliers to realise anti-competitive aims through indirect means. Otherwise, the European objective of protection of competition on the market might not be achieved.
-This fundamental principle implies that VBER is not an instrument aimed at ensuring fairness in bilateral commercial relations between parties with unequal bargaining power, or at preventing abuses of economic dependence.
-The protection of the legitimate interests of weaker contracting parties falls instead within the remit of national laws and remains within the competence of the Member States.
-It is therefore important to improve the evaluation purpose and scope of the VBER by recalling the problem to be addressed, (i.e. the “Why”), the objectives (i.e. the “What”) and the present policy options (i.e. the “How”).
-Accordingly, the methodology and approach should focus more on the effective implementation of the VBER in order to increase awareness of public authorities of the existence and significance of the gap which remains between European VBER provisions and dealers’, sub-dealers’, bodywork repairers’ day-to-day reality.
-Any policy choice on the VBER therefore needs to be based on a genuine partnership. All dealers, sub-dealers and bodywork repairers, but especially the smaller ones, would benefit from a competition regime in which car manufacturers and insurers would not be forced to shift on them significant investments costs to protect their corporate identity against possible opportunistic behaviour of competitors.
-FNA representatives are looking forward to the discussions when the Consultation process continues and are confident that consensus can be achieved.
Read full responseResponse to Cooperative, Connected and Automated Mobility (CCAM)
14 Nov 2018
Federation of Craft Businesses in the Automotive sector and in Mobility services - FNA,
welcomes the EU Commission Recommendation on Connected Vehicles, in particular on Access to Automotive Data, which is essential for craft businesses on the after-market to continue and develop their growth in the interests of motorists and environment, because they are local SMEs
Read full responseResponse to Legislation on end-of-life vehicles - evaluation
31 Oct 2018
Federation of Craft Businesses in the automotive sector and in mobility services - FNA - Fédération de l'Artisanat Automobile, entrepreneurs artisans de l'automobile et de la mobilité welcomes the EU Roadmap on the evaluation of the EU End-of-Life Vehicles (ELVs) Directive and remains at the disposal of the European Commission to exchange views and comment on the enclosed contribution in the light of the current experience of our operators involved in recovery, recycling and transformation of ELVs.
Key feedback highlighted relate to measures to be taken in order to improve consumer confidence in recycled ELVs:
- Focusing on the entire vehicle and not only on glass and plastic fractions,
- Setting up a Fund to stimulate and support recycled ELVs on the market,
- Supporting recovery channels in tires, used oils, glass, LPG and electric vehicles and the treatment of components of the new eCall system,
- Monitoring the implementation of provisions on traceability of ELVs and recycled spare parts and taking measures to make easier the administrative end of life of ELVs in national registers and fighting against illegal ELV Centres,
- Co-operating with the technical inspection centres to ensure road safety of recycled ELVs.
Read full responseMeeting with Pierre Moscovici (Commissioner) and
22 Feb 2017 · Fraude à la TVA