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FIGIEFA - Fédération Internationale des Grossistes, Importateurs & Exportateurs en Fournitures Automobiles / International Federation of Automotive Distributors

FIGIEFA

FIGIEFA represents European automotive distributors to ensure fair competition in vehicle repair.

Lobbying Activity

Meeting with Kosma Złotowski (Member of the European Parliament)

15 Jan 2026 · Future of automotive aftermarket

Meeting with Pierfrancesco Maran (Member of the European Parliament, Shadow rapporteur)

11 Dec 2025 · End-of-Life Vehicles Regulation

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

2 Dec 2025

FIGIEFA represents the distributors of automotive spare parts in Europe.Our members and their associated workshops are key actors in the European aftermarket. FIGIEFA endorses the proposed Delegated Act and sees it as striking a good balance between the need to ensure the access rights of independent operators while also allowing vehicle manufacturers to protect the cybersecurity integrity of their vehicles. While we do endorse the proposal, we have some suggestions intended to add clarity for its implementation. Our amendments proposals are provided in the attached file. Implementations of this updated type approval regulation will introduce a new paradigm in the European aftermarket. There will be a significantly increased dependency of independent operators on vehicle manufacturers. This is particularly true for the availability of multi-brand diagnostic tools, on which the independent aftermarket depends. Tools producers will need timely information from vehicle manufacturers for cybersecurity integration, testing and validation. VMs servers also will need to be available for authentication or users will be blocked from providing services. To address server availability, we are proposing an amendment. The new regulation provides important updates for technical progress. As powertrain technology changes and vehicles transition to becoming software defined vehicles repair and maintenance needs change. We therefore applaud the extended definitions of RMI, including the needs for battery repair and ADAS calibration. We also appreciate the provisions on access to machine readable RMI for independent operators. A vital inclusion in this update are related to the use of multi-brand tools for preforming parts coding and software updates. Such operations are becoming increasingly common and until now could only be done using vehicle manufacturers diagnostics tools. Parts Coding is growing practice by vehicle manufacturers. It is the process whereby a part is paired with a vehicle during the installation process. While such activation by multi-brand diagnostic tools is essential for the independent aftermarket, it is only part of the issue. This parts coding process has a direct impact on the ability of parts producers to make interoperable replacement parts, if they do not have access to the coding processes of the vehicle manufacturer. Without regulatory intervention increasing numbers of aftermarket parts will only be available as original vehicle manufacturer branded parts and not be subject to any competitive pressure. Parts prices will inevitably increase and the will ultimately impact on European consumers and businesses, with the cost of repairs increasing significantly. We understand that addressing this issue was not possible in this update, due to time constraints, but we call on the European Commission to bring forward another delegated act to address this issue, without delay. We would also propose to include a short text in Appendix 2 of Annex X outlining the high level requirements to enable this. A related issue concerns the marketing of re-use parts. When a part has been variant coded to a specific vehicle, it is very often not possible to re-use that part on another vehicle without the decoupling of that part from the vehicle of origin. A requirement for vehicle manufacturers to put such a process in place can added to Annex X and we would call on the Commission to do so. It would complement the End-of-Life Vehicle regulation and support the circularity of the automotive sector by making more parts available for re-use. To address this we propose an amendment. We would also propose some amendments to the recitals, including a new one stressing the impact of these new dependencies in the aftermarket and the need for close compliance monitoring and enforcement. We welcome continued dialogue with the Commission and stand ready to contribute constructively to the successful implementation of the revised framework.
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FIGIEFA warns Digital Omnibus must not weaken data access rules

13 Oct 2025
Topic — A European Commission initiative to simplify digital legislation and reduce regulatory burdens for businesses.
Message — FIGIEFA requests that simplification focuses on removing complexity while safeguarding the Data Act’s core principles. They seek clear guidance on the interplay between digital laws and existing automotive regulations. They also call for streamlined incident-reporting to protect sensitive data from competitors.123
Why — Simplifying rules would reduce compliance costs for SMEs and provide the legal certainty needed for investment.45
Impact — Vehicle manufacturers lose their exclusive control over vehicle data and the primary consumer interface.6
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Meeting with Fausto Matos (Cabinet of Executive Vice-President Henna Virkkunen)

8 Oct 2025 · Data

Meeting with Kosma Złotowski (Member of the European Parliament)

25 Sept 2025 · Greening corporate fleets

Meeting with Pascal Canfin (Member of the European Parliament)

8 Sept 2025 · Verdissement des flottes

Automotive distributors urge EU to scrap mandatory fleet quotas

5 Sept 2025
Topic — The European Commission is proposing new rules to decarbonise corporate vehicle fleets.
Message — The federation urges the Commission to avoid mandatory quotas and adopt a market-driven approach. They request a regulatory framework ensuring full repairability and access to vehicle data.12
Why — This would protect distributors from unworkable operational constraints and high capital costs.34
Impact — Forced targets could result in higher transport costs and reduced services for consumers.5
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Meeting with Sergey Lagodinsky (Member of the European Parliament) and ACT | The App Association and EUMANS

4 Sept 2025 · Exchange of Views

FIGIEFA urges EU to mandate repairability for motor vehicles

28 Aug 2025
Topic — The EU is developing a strategy for consumer policy priorities from 2025-2030.
Message — The group suggests revising the Right to Repair Directive to include horizontal repair requirements. They recommend introducing repairability by design requirements for vehicles under the Type-Approval framework. Finally, the Commission should investigate how new production methods like giga-casting impact repairability.123
Why — Mandated repairability ensures continued market demand for independent automotive parts and services.45
Impact — Car manufacturers using integrated production methods would face increased design and assembly costs.6
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Meeting with Mohammed Chahim (Member of the European Parliament)

28 Aug 2025 · Greening Corporate Fleets

Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

27 Aug 2025 · Replacement of traction batteries in electric vehicles

FIGIEFA demands equal data access for independent vehicle repairers

28 Jul 2025
Topic — The EU is revising rules for vehicle roadworthiness inspections and data exchange.
Message — FIGIEFA requests a broad definition of vehicle data including battery health and performance parameters. They want independent workshops to access technical information to the same extent as testing centers. They also seek to exclude minor repairs from mandatory odometer recording obligations.123
Why — This ensures independent shops can compete fairly by accessing necessary repair data.4
Impact — Authorized dealers may lose their current informational advantage over independent repair businesses.5
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Meeting with Stefan Fuehring (Head of Unit Secretariat-General)

23 Jun 2025 · Revision of Vehicle Type-Approval Regulation (EU) 2018/858- Annex X (“Access to vehicle OBD information and vehicle repair and maintenance information”)

FIGIEFA Demands Equal Data Access for Independent Car Repairs

13 May 2025
Topic — Methods for monitoring vehicle emissions and technical requirements for anti-tampering security systems.
Message — Independent repairers want access to emission warnings through the same digital interfaces as vehicle manufacturers. They also need technical info to ensure replacement parts work with anti-tampering systems.12
Why — This would allow independent workshops to compete fairly for vehicle emission repairs.3
Impact — Car manufacturers would lose their unfair advantage in the market for replacement parts.4
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FIGIEFA urges clear definition for Euro 7 pollution control devices

13 May 2025
Topic — This consultation defines technical testing and type-approval requirements for Euro 7 vehicle emissions.
Message — The organization recommends re-introducing Euro 6 wording to clarify which components are regulated. They seek to limit type-approval requirements specifically to catalytic converters and particulate filters.12
Why — A narrow definition helps independent distributors avoid new compliance burdens for replacement parts.34
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Meeting with Jan-Christoph Oetjen (Member of the European Parliament) and European Environmental Bureau and

7 Apr 2025 · End-of-Life Roundtable

Meeting with Stéphane Séjourné (Executive Vice-President) and

19 Feb 2025 · Dialogue on the future of the automotive sector – Suppliers Session

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 Paulius Saudargas (Member of the European Parliament, Rapporteur)

5 Feb 2025 · End-of-life vehicles regulation

Meeting with Piotr Müller (Member of the European Parliament, Shadow rapporteur)

5 Feb 2025 · Circularity requirements for vehicle design and management of end-of-life vehicles

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and European Tyre & Rubber Manufacturers' Association and Leaseurope

4 Feb 2025 · Transformation of the automotive Sector

Meeting with Filip Turek (Member of the European Parliament, Shadow rapporteur)

4 Feb 2025 · Circularity requirements in vehicle design and end-of-life vehicles

Meeting with Paulius Saudargas (Member of the European Parliament, Rapporteur)

31 Jan 2025 · End-of-life vehicles regulation

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

Meeting with Rosa Serrano Sierra (Member of the European Parliament) and European Boating Industry and

11 Dec 2024 · Priorities for European Commission 2024-2029

Automotive aftermarket distributors urge stronger enforcement of competition rules

24 Jun 2024
Topic — Review of EU motor vehicle sector competition rules before 2028 expiry.
Message — FIGIEFA requests the Commission maintain sector-specific competition rules, address persistent barriers to spare parts trade, and expand the review to cover electric vehicles and digitalisation impacts. They urge stronger enforcement mechanisms and better coordination between competition authorities to ensure compliance rather than just ex-post cases.123
Why — This would preserve legal certainty and reduce costs for SME distributors navigating complex aftermarket supply chains.45
Impact — Consumers lose affordable repair choices as independent repairers struggle to access essential spare parts and vehicle data.67
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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 Lucie Rousselle (Cabinet of Commissioner Didier Reynders)

13 Dec 2023 · Discussion on the need for a sector specific legislation on access to in-vehicle data to ensure a better choice of services to consumers, and with increased competition, reduced costs for consumers.

FIGIEFA urges EU to mandate repairability in car design

1 Dec 2023
Topic — This consultation addresses new rules for recycling and circular vehicle design.
Message — FIGIEFA recommends the introduction of a general 'repairability by design' requirement for vehicles. They also seek to ensure fair competition between vehicle manufacturers and independent operators.12
Why — This would preserve the market share of independent distributors and repair shops.34
Impact — Car manufacturers lose control over repair data and part replacement fees.56
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Meeting with René Repasi (Member of the European Parliament, Rapporteur)

27 Sept 2023 · Exchange of Views on the Right to Repair/ Recht auf Reparatur (R2R)

Meeting with Susana Solís Pérez (Member of the European Parliament, Shadow rapporteur) and Bridgestone Europe

20 Jun 2023 · Euro 7 meeting held by parliamentary assistant

Response to Guidelines on exclusionary abuses of dominance

24 Apr 2023

FIGIEFA welcomes the intention to draft new guidelines on exclusionary abuses of dominance. We fully share the Commissions view to ensure that abuse of dominance rules need to be clear, effective and applied vigor-ously to the benefit of European consumers and the economy at large. The motor vehicle sector is a key industry in the EU and affordable automotive mobility is essential for the citi-zens of the European Union. Consumer choice and competitive prices will only be attained where the competi-tion law framework is worded clearly, and enforced regularly. The automotive aftermarket and related mobili-ty services is a major part of the automotive industry, accounting for 4.3 million European jobs and providing essential services ensuring safety & compliance of the 320 million vehicles on European roads. For decades independent operators (IOs), an overwhelming majority of whom are SMEs, were able to put important competitive constraint in the automotive aftermarket on vehicle manufacturers (VMs) and their authorised selective networks. Without effective competition on these brand-specific aftermarkets, consum-ers would face high switching costs as a consequence of the long lifespan of the vehicle, the relatively high purchase price with generally unknown costs for maintenance and repair over its lifetime. Competition from IOs has thus reduced the risks of vendor lock-in and has led to enhanced consumer welfare, based on afforda-ble, innovative, safe and secure mobility. Nowadays digitalisation and IoT give rise to new services and opportunities. However, they also have a disrup-tive impact on the competition on the automotive aftermarket, in particular due to the proprietary closed (digi-tal) design of the vehicle, e.g. through proprietary in-vehicle telematics systems or the increasing use by VMs of parts activation codes. IOs are in direct competition with VMs, but are also fully dependent on the manufac-turers for the provision of access to essential inputs, such as for example technical information, required for developing and offering their independent multi-brand aftermarket services and related spare parts to con-sumers and businesses. Rightly, the amended Supplementary Guidelines to the Motor Vehicle Block Exemption Regulation warn that Article 102 TFEU may be applicable where a supplier unilaterally withholds from independent operators an essential input, such as vehicle-generated data (Commission Notice (2023/C 133 I/01), Article 68a). Key is the acknowledgement that IOs are often extremely dependent on the VMs, and thus reluctant to take action due to the risk of retaliating measures from the VMs, that can be costly and or even fatal to business, especially because IOs are often SMEs. This implies an inequality of (negotiating) positions from the outset, beyond the dominance inherent to 102 TFEU-issues. Experience in the past has demonstrated that even if all this has been overcome, the cases brought forward by SMEs to the competent authorities are often consid-ered too small to be of relevance, thus ignoring that in different jurisdictions other similar (informal) com-plaints might have been filed, resulting in a lack of enforcement. The guidelines might be an opportunity to ad-dress this problem, possibly in ECN-context. Anyway, the upcoming Guidelines on exclusionary abuses should include guidance on enforcement policy in individual cases, both in relation to content and process, to minimise the enforcement problems experienced by SMEs in the automotive sector. In individual cases, Guidelines should create more legal certainty, in particu-lar related to outright refusals and constructive refusals to supply. In order to support the objective of vigorous enforcement, guidance on the (increased) use of interim measures and commitment decisions with the need to involve stakeholders, should be provided.
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Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

15 Feb 2023 · Independent Service Providers meeting on in vehicle data

Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

15 Feb 2023 · In-vehicle data

Response to Review of the Designs Directive

31 Jan 2023

The publication of the European Commissions proposals for a revised Design Directive (COM(2022) 666) and a revised EU Design Regulation (COM(2022) 667) is an important step for competition and consumers. The proposed Design Directive includes an EU-wide Repair Clause for must match visible spare parts (Art. 19), and the proposed EU Design Regulation converts the currently existing transitional Repair Clause into a permanent provision (Art. 20a). If properly defined, the Repair Clause will ensure that vehicle manufacturers will continue to enjoy protection for the design of their vehicles, while enabling fair competition and freedom of consumer choice for visible spare parts used in the context of reparations. However, it is crucial to set the right parameters to the legislation so that the Repair Clause can effectively apply. Our detailed comments and recommendations are available in the attached document.
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Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean) and Fédération Internationale de l'Automobile and

16 Jan 2023 · Data Act Regulation and Specific legislation on ‘Access to in-vehicle data & functions’

Meeting with Elena Lizzi (Member of the European Parliament, Shadow rapporteur) and Alliance for the Freedom of the CAR Repair

12 Oct 2022 · Data Act

Automotive distributors urge stronger rules on spare parts access

30 Sept 2022
Topic — Extension of EU competition rules for motor vehicle distribution and servicing.
Message — The federation requests guaranteed access to technical information, spare parts, real-time vehicle data, and activation codes. They want these provided in unbundled, machine-readable formats at cost-based fees. They seek rules preventing manufacturers from using warranties to exclude independent operators.12345
Why — This would enable independent distributors to compete with manufacturer networks and pursue innovative business models.67
Impact — Vehicle manufacturers lose exclusive control over repair data and aftermarket services revenue.89
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Automotive aftermarket distributors demand full vehicle data access rights

2 Aug 2022
Topic — EU regulation on access to vehicle data for repair, mobility, and insurance services.
Message — The organization demands non-discriminatory access to all in-vehicle data, functions and resources available to manufacturers, including dashboard access and standardized data formats. They argue current Data Act provisions create legal uncertainty and require sector-specific legislation with harmonized rules.123
Why — This would enable independent service providers to compete with manufacturers for digital vehicle services.45
Impact — Vehicle manufacturers lose exclusive control over lucrative digital service markets and customer relationships.67
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Meeting with Ibán García Del Blanco (Member of the European Parliament, Shadow rapporteur for opinion) and Banco Santander, S.A. and

28 Jun 2022 · Joint exchange of views on the Data Act

Response to Sustainable Products Initiative

22 Jun 2022

FIGIEFA (the European federation and political representative in Brussels of the independent wholesalers and retailers of automotive replacement parts and their associated repair chains) welcomes the objectives of the new EU Commission proposal for a Regulation setting ecodesign requirements for sustainable products which will contribute to reduce the negative life-cycle environmental and social impacts of products, improve the functioning of the internal market, achieve longer product lifetimes for example through more durable and reparable products, increase circular material use rate, reduce waste and achieve higher recycling rates. Facilitating product repairability, serviceability, durability, upgradability and accessibility to ensure the longer lifetime of products and replaceable spare parts are essential to enable the transition to a truly circular economy, in which consumers could still choose among a variety of repairers and competitive spare parts be sustainably produced. The high-quality recycling and the product remanufacturing should be ensured to reduce products’ carbon and environmental footprints. Legislation should consider how to best support sustainable production of more sustainable goods, the repairability of these goods, a circular economy, and ensure a level playing field for products sold on the internal market. Rules which enable all market operators to contribute to and benefit from the opportunities for increased sustainability are required at European level for a harmonised approach. Indeed, only a European approach is recommended to avoid emerging national approaches which could further fragment the internal market. Vehicles are consumer goods (actually the second most costly product for consumers), but they are at the same time very complex industrial products. The complexity, the technicality, the price of a vehicle and its entire value chain are all reasons why the automotive sector is already submitted to a wide range of technical, environmental and competitive legislations at EU level. For these reasons, if a horizontal “Regulation establishing a framework for setting ecodesign requirements for sustainable products” would further facilitate product repairability and sustainability in general, the European Commission should not lose sight of the sector-specific legislation and obligations imposed in the last 20 years in the automotive sector. It is indeed crucial to ensure coherence with other regulatory frameworks and sector-specific legislations, such as the EU Motor Vehicle Block Exemption Regulation (461/2010), the Type Approval Regulation (2018/858) for Vehicles and Components, the End-of-Life Vehicles Directive (2000/53), the Regulation concerning batteries and waste batteries (repealing Directive 2006/66/EC and amending Regulation (EU) N°2019/1020), the “3R” Type Approval Directive (2005/64) and the Design Directive (98/71), to name only a few. These sector-specific legislations regulate for example technical safety specifications of a series of parts/components or the relations between the vehicle manufacturers, the various operators of the automotive aftermarket eco-system and the consumers, thereby ensuring a fair level-playing field, more competition, better environmental compliance, high-quality repair and mobility services and freedom of choice. With all these considerations, FIGIEFA invites the European Commission to have a look at these sector-specific legislations and obligations which already exist in the automotive aftermarket and which could serve as examples or as background information when developing further product-specific requirements in future delegated acts, if really needed. Potential overlaps or conflicts with existing legislation should be avoided and excessive burden on businesses should be prevented.
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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 Update of references in Annexes I and II to the General Vehicle Safety Regvulation

19 Apr 2022

FIGIEFA (the European federation and political representative in Brussels of the independent wholesalers and retailers of automotive replacement parts and their associated repair chains) welcomes the updates of EU rules on vehicle safety, and in particular the amended reference in Annex I to the UN R155 providing uniform provisions concerning the approval of vehicles with regards to cybersecurity and cybersecurity management system. Until now, EU legislation for vehicle/components homologation has always set clear performance criteria (and/or test procedures) to be fulfilled. As such, there were clear benchmarks for vehicle manufacturers and parts producers for the production of their vehicles/components, transparent for everybody for first equipment and aftermarket purposes. However, the new UN R155, is very holistic and broad, and leaves the implementation of cybersecurity up to each vehicle manufacturer. This is an important shift of paradigm from the established principles under EU type-approval. Vehicle manufacturers are now allowed to set their own benchmark through a detailed technical implementation of their own proprietary cybersecurity measures. This entails legal uncertainty for the entire aftermarket sector in terms of security implementation, with no equal means to develop product and services compatible with the security architecture of the vehicle. The implementation of this regulation within EU has an impact on all actors of the aftermarket ecosystem value chain including generic parts manufacturers, independent parts distributors, diagnostic tool manufacturers, and workshop operators installing parts and using multi-brand diagnostic tools. This ecosystem employs over 4.5 European citizens, in 500.000 companies, who are predominantly SMEs (cf. Eurostat figures). These actors should have the continued possibility to develop/install/activate automotive replacement parts in a manner, which is cybersecurity-compatible with the vehicle’s security architecture. For that, a range of compatibility and interoperability information needs to be defined to enable automotive Aftermarket operators to remain responsible actors in the security chain. In addition, legislation should ensure that supporting provisions for aftermarket operators are included into the European legislation to cover the entire security lifecycle of the mobility chain from developing secure replacement parts, validating them with the vehicles security architecture and installing/ activating these parts securely during the repair process. To enable this provision for aftermarket operators, it should be possible for them to become trusted partners with the vehicle manufacturers, using an EU wide harmonised accreditation scheme. This could be modelled on the existing SERMI scheme (SERMI – is the EU wide harmonised accreditation and authorisation scheme for independent operators to access Security-related Repair and Maintenance Information (RMI)), the scope of which could be extended to address these new requirements. An unregulated environment, which does not address the need for an inclusive cybersecurity management process, enabling the manufacturing/activation/installation/coding of cybersecurity-relevant generic replacement parts (comparable to the processes which vehicle manufacturers have with their Tier1 suppliers, mirroring ISO 21434 processes) will foreclose the automotive Aftermarket for competitive customer choice and result in monopolistic structures with installation of OE vehicle replacement parts only selected by each individual vehicle manufacturer. FIGIEFA is therefore calling upon the Commission to accompany the transposition of such UN R155 into EU law together with respective amendments to Annex X of Reg.2018/858, for ensuing that multi-brand diagnostic test equipment and spare parts either from first equipment or generic suppliers can be provided, installed and used by independent operators.
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Response to Technical requirements for unlimited series, small series, special purpose vehicles and fully automated vehicles

19 Apr 2022

FIGIEFA (the European federation and political representative in Brussels of the independent wholesalers and retailers of automotive replacement parts and their associated repair chains) welcomes the amendment of Annex II to Regulation (EU) 2018/858 on the approval and market surveillance of motor vehicles and their trailers to update the references to the General Safety Regulation, and to include specific provisions on software updates in the conformity of production procedure in Annex IV to that Regulation by transposing the UN Regulation N°156 into EU law. With digitalisation paving the way for more and better connected and automated technologies, it is of imperative importance to have legislation supporting these digital changes, and legislative provisions for conducting software updates are a welcome development in that direction. Such transposition will affect the actors in the aftermarket ecosystem value chain including generic parts manufacturers, independent parts distributors, diagnostic tool manufacturers, and workshop operators installing parts and using multi-brand diagnostic tools. This ecosystem employs over 4.5 European citizens, in 500.000 companies, who are predominantly SMEs (cf. Eurostat figures). FIGIEFA would like to point out that the current provisions for conducting software updates does not consider the provisions for all operators in the industry, in particular the independent operators including independent repair shops and multi-brand diagnostic tool manufacturers. The impact for independent operators comes as a result of the current provisions in UN regulation R156 and its supporting interpretation document, which cross references the ISO 24089 standard for implementation requirements related to setting up a Software Update Management System (SUMS) and conducting software updates. These existing provisions do not include all the necessary supporting provisions for independent aftermarket operators, who are involved in the mobility and repair value chain. In order to ensure equal capabilities for independent operators to conduct software updates, legislation should ensure that equal rights are provided for them. In addition to equal rights, legislation should also explicitly prescribe the requirements/ provisions that need to be made to conduct these software updates. These requirements cover the entire lifecycle of the software update operation, from requirements/preconditions for performing the software updates, authenticating the entity conducting the software update and confirmation of the successful completion of the software update. The roles/ rights of independent operators to perform these actions are not clearly defined in any of the existing legislation, and the adoption of the R156 into European legislation should take these elements into consideration. FIGIEFA would like to therefore recommend to further revise the current/existing provisions (Annex IV and Annex X of Regulation 2018/858) to include provisions for all relevant operators in the mobility value chain, particularly for independent repairers and multi brand diagnostic tool manufacturers, regarding rights and technical capabilities for conducting software updates. An extension of the existing SERMI scheme (SERMI – is the EU wide harmonised accreditation, approval and authorisation scheme for independent operators to access Security-related Repair and Maintenance Information (RMI) which was set-up by DG GROW and stakeholders), to include harmonised authorisation for the performance of software updates should also be foreseen. Moreover, following the initial suggestion from the Commission to set up a dedicated ad-hoc working group for implementation of UN R156 into European law, FIGIEFA would like to support this initiative and invite the Commission to launch the working group at the earliest.
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Response to Promoting sustainability in consumer after-sales

5 Apr 2022

FIGIEFA welcomes the objectives of the new ‘Right to Repair’ Initiative of the EU Commission, which will contribute to promote more accessible, green and affordable repair services to the benefit of all European consumers. Facilitating product repairability, serviceability and accessibility to ensure the longer lifetime of products and replaceable spare parts are essential to enable the transition to a truly circular economy, in which consumers could still choose among a variety of repairers and competitive spare parts. Legislation should consider how to best support the repairability of consumer goods and a circular economy. Rules which enable all market operators to contribute to and benefit from the opportunities for increased sustainability are required. Vehicles are high purchase value and are long-standing goods that live for more than 20 years. They require regular servicing and maintenance (and are not systematically replaced as other goods); when encountering a damage or problem, repair is the guiding method. The very essence of the automotive aftermarket (franchised and independent) is to offer safe, efficient and priceworthy repair services ensuring a long lifetime of vehicles from both, consumers and corporate customers. However, it is important to keep in mind that vehicles are safety-related products. It is the duty of the aftermarket to ensure safety on the roads for road users (from drivers to pedestrians). To this end, repairability is submitted to legal and technical safety requirements. Most of vehicle parts/components are safety-related and either cannot be repaired (e.g. worn out brake linings), or alternatives still need to be developed/deployed at larger scale (e.g. the use of alternative materials in the production of parts, where possible, or alternative repair methods such as remanufactured/refurbished components). Vehicles are consumer goods (actually the second most costly product for consumers), but they are at the same time very complex industrial products. The complexity, the technicality, the price of a vehicle and its entire value chain are all reasons why the automotive sector is already submitted to a wide range of technical and competitive legislations at EU level. For these reasons, if a horizontal “Right to Repair Act” would be beneficial for consumers and would further facilitate product repairability in general, the European Commission should not lose sight of the sector-specific repair rights achieved and obligations imposed in the last 20 years in the automotive sector. It is indeed crucial to ensure coherence with other regulatory frameworks and sector-specific legislations, such as the EU Motor Vehicle Block Exemption Regulation (461/2010), the Type Approval Regulation (2018/858) for Vehicles and Components, the End-of-Life Vehicles Directive (2000/53), the “3R” Type Approval Directive (2005/64) and the Design Directive (98/71), to name only a few. FIGIEFA believes that vehicles should be considered with a specific focus and with a dedicated sector-specific legislation. Also, it is of utmost importance to ensure first that there are more repairable products/parts at all, which ultimately need to be developed and produced by companies from the automotive sector before they can be offered/used (often through more complex supply chain processes). Only on this basis, when such a choice exists, we believe it would be sound to start considering a possible extension of the legal guarantee period for new goods only. Should vehicles be included in the scope of application of the future ‘Right to Repair’ initiative, despite their high complexities and technicalities, FIGIEFA strongly suggest following Policy Option n° 1 outlined in the Commission’s “Call for Evidence for an Impact Assessment” with a low intervention and more voluntary commitments.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

4 Apr 2022 · Data Act, access to in-vehicle

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

24 Jan 2022 · Mobility: green and digital transition

Meeting with Thierry Breton (Commissioner) and

27 Oct 2021 · Data

FIGIEFA demands full vehicle data access for independent repairers

4 Feb 2021
Topic — New technical rules for accessing vehicle repair, maintenance, and security information.
Message — The group requests clarification that manufacturers must provide machine-readable data datasets alongside website access. They demand that the complete vehicle diagnostics data stream remains accessible via the physical connector for all repair purposes. Finally, they urge that security access rules focus specifically on anti-theft features rather than general vehicle integrity.123
Why — Guaranteed access to comprehensive vehicle data ensures independent garages can remain competitive.4
Impact — Vehicle manufacturers would lose the ability to restrict data to proprietary systems.5
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Response to Intellectual Property Action Plan

14 Aug 2020

FIGIEFA is the European federation and political representative in Brussels of the independent wholesalers and retailers of automotive replacement parts and their associated repair chains. FIGIEFA is part of a wider eco-system, Europe’s automotive aftermarket value chain, accounting for over 4,5 million jobs in the wider ‘automobile use’ being employed in over 500.000 – pre-dominantly – SME companies. This sector plays a vital role in enabling personal mobility, the distribution of goods or servicing public transport operators. It contributes to safer, cleaner, and more affordable mobility for private, corporate, or public users of the more than 308 million vehicles on EU roads. FIGIEFA supports the initiative of the European Commission for an Intellectual property action plan and the corresponding Roadmap. We believe however that the Action Plan should be extended to better protect competition and the innovative strength of European small and medium-sized enterprises in secondary markets and to support even further the goals of a greener and digital European economy. The reparability of products is one of the core elements in the green transition. The EU’s policies should therefore take account of the competitiveness of SMEs in aftermarkets where digitalisation and reparability of complex industrial products is key. In line with the European Commission’s intention to identify current shortcomings and propose practical measures to improve the quality and consistency of the IP framework, FIGIEFA advocates the introduction of a fair-use principle that transcends property rights as a further objective in the sense of "well-calibrated and modern IP policies" to protect competition and the innovative strength of European small and medium enterprises in secondary markets. For further details, please see attachment.
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Response to Revision of the NIS Directive

10 Aug 2020

FIGIEFA, the European Federation of Automotive Aftermarket Distributors, is part of Europe’s substantial automotive aftermarket and mobility value chain, accounting for over 4,5 million jobs in the wider ‘automobile use’, most of them being employed in over 500.000 SMEs. This sector plays a vital role in enabling personal mobility, distribution of goods, servicing public transport operators as well as ensuring essential services such as medical services and law enforcement can continue to operate. It contributes to safer, cleaner, and more affordable mobility for - and at the regional proximity of – the private, corporate, or public users of the more than 308 million vehicles on EU roads. This value chain is particularly affected by the introduction of recent developments in the automotive sector Cybersecurity, mainly the UNECE Regulation on Cybersecurity and the ISO/SAE 21434 standard on Cybersecurity engineering. Not only vehicle manufacturers (VMs) and their supplier chain will have to address Cybersecurity, but also the entire aftermarket will also need to address (cyber-)secure integration of their products and services. This threatens business continuity and distorts competition due to the system administrator and gatekeeper roles of the VMs – who are now competitors in the automotive aftermarket. FIGIEFA welcomes the Commission’s initiative to review the NIS Directive to increase levels of cybersecurity across Europe. However due to its legal nature as “Directive”, this Directive is being implemented and interpreted differently at national/sectoral levels. This is why, FIGIEFA requests the European Commission to have better harmonised requirements for cybersecurity across the European Union and its Member States. This will help to foster competition and avoid fragmentation of the single market. Without a harmonized approach, particularly SMEs in the Aftermarket value chain could not handle these fragmented cybersecurity requirements, from either the technical or commercial aspects and would be effectively blocked from the market. For that, FIGIEFA confirms its support to the European Commission and therefore proposes the adoption of a robust legislative framework (in line with policy option number 4) to ensure the harmonisation of rules within the EU and extending the scope of this Directive to others sectors/services not covered by this Directive and introducing new policy measures specific to the sectors or services such as the automotive aftermarket sector. This could be addressed as part of an amended SERMI scheme ((EC) No. 715/2007) where SME’s are approved and authorised and could use a single point of access (e.g. a trust centre) for certificates. FIGIEFA supports the positive impact of cybersecurity preparedness, but there is a high risk that the potential efficiency gains and cost reductions which should benefit SMEs will, in practice, be invalidated due to the dependency of SMEs on dominant market players (i.e. the VMs who cite liability reasons) and restrict access to the relevant sources of data, functions and information that are needed to ensure undistorted competition. Therefore, FIGIEFA proposes that sector-specific rules are adopted, with relevant arbitration mechanisms or bodies to ensure equal abilities for all service providers to ensure business continuity and the ability to innovate – especially for SMEs.
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Automotive distributors urge specific EU rules for vehicle data

31 Jul 2020
Topic — The initiative proposes a legislative framework for the governance of common European data spaces.
Message — FIGIEFA calls for sector-specific automotive legislation to ensure independent service providers can access in-vehicle data. They support creating a European coordination body to establish non-discriminatory technical standards and interoperability. This prevents vehicle manufacturers from acting as gatekeepers and distorting the market.1234
Why — This would allow independent distributors to compete fairly with manufacturers by accessing vehicle data.56
Impact — Vehicle manufacturers lose their exclusive control over vehicle data and their role as market gatekeepers.78
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Meeting with Marius Vascega (Cabinet of Commissioner Virginijus Sinkevičius)

16 Jul 2020 · Cleaner environment and reducing emissions

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'

FIGIEFA demands modernized rules for fair automotive competition

19 Mar 2019
Topic — Evaluation of competition rules for vehicle maintenance and spare parts distribution.
Message — FIGIEFA requests modernizing the regulation to address technical barriers like software coding. They advocate for independent access to manufacturer-controlled spare parts and data.123
Why — These changes would safeguard the market competitiveness of independent small businesses.4
Impact — Vehicle manufacturers would lose their exclusive control over vehicle-generated data.5
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FIGIEFA demands equal vehicle data access to ensure competition

16 Nov 2018
Topic — EU consultation on policy for cooperative, connected, and automated vehicle mobility.
Message — FIGIEFA calls for laws establishing an open digital platform for vehicles. They demand direct, real-time access to car data and in-vehicle displays.12
Why — This would allow independent distributors to maintain their market position against car manufacturers.3
Impact — Car manufacturers would lose their exclusive control over lucrative vehicle data and services.4
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Response to Evaluation of EU legislation on design protection

27 Jul 2018

FIGIEFA is the European federation and political representative in Brussels of the independent wholesalers and retailers of automotive replacement parts and their associated repair chains. Together with its 20 national European members it represents the interests of more than 30.000 companies trading with vehicle parts, components and accessories. With a European supply network of more than 50.000 outlets and their 355.000 employees, FIGIEFA’s members provide an efficient regional delivery of replacement parts to ensure that the consumer can get rapidly back on the road. The market for vehicle replacement parts, servicing and repair fosters job creation, supports a healthy environment and promotes free consumer choice in auto care. As a member of the ECAR alliance, one of FIGIEFA’s objectives is the establishment of a harmonised, free and genuinely competitive European Internal Market for automotive visible replacement parts (also called “must match” visible replacement parts). The thousands of independent aftermarket SMEs, which are at the heart of the EU local economic base are currently suffering from the absence of a real EU Internal Market for visible automotive replacement parts. Currently at stake is the integrity of the Euro 15 Billion after-sales market of visible “must match” replacement parts for the millions of vehicle owners and for the spare parts suppliers. Extending design protection to visible spare parts would grant a de facto product monopoly to the vehicle manufacturers and thereby eliminate consumer choice and stifle free and fair competition. A Repairs Clause, to the contrary, rightly and equitably gives vehicle manufacturers full protection over the design of their new cars while ensuring that this protection is not extended to the corresponding visible spare parts. It thus leaves vehicle owning consumers free to repair their vehicles as they wish, and avoids creating deleterious spare parts monopolies. National repairs clauses already exist in 11 Member states: Belgium, Greece, Hungary, Ireland, Italy, Latvia, Luxemburg, the Netherlands, Poland, Spain and the United Kingdom. In the rest of the EU, visible replacement parts can only be supplied by vehicle manufacturers under monopolistic conditions. The recent “Partneo scandal” revealed by Mediapart in June 2018, where PSA and Renault secretly and artificially inflated the prices of certain spare parts thanks to the use of a very sophisticated software, is yet another attempt by many vehicle manufacturers to use all the opportunities of their monopolistic situation to still and always make more money at the expense and to the detriment of motorist consumers. This scandal has been widely facilitated by the French design legislation where design protection is extended to the visible spare parts market. FIGIEFA therefore urges the Commission to tackle these distortions of the Internal Market and consumer rip-offs without delay. FIGIEFA strongly welcomes the Commission Evaluation Roadmap as a next step in the Overall Evaluation procedure of the design protection legislation and system in the EU. FIGIEFA especially welcomes the planned assessment of the consequences of the fact that the rules applicable to spare parts have not been harmonised at EU level and looks forward to see the conclusions of both the Economic Review and the Legal review on the Repairs Clause again fully endorsed by the Commission in its future Evaluation Report. More concretely, FIGIEFA believes that the targeted consultation should be open to organisations of automotive aftermarket companies involved both in the distribution (parts wholesalers) and in the repair or replacement of these components.
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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 Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

17 Feb 2017 · vehicle homologation and maintenance

Meeting with Günther Oettinger (Commissioner)

18 Feb 2016 · IOT, digitisation of the automotive industry

Meeting with Justyna Morek (Cabinet of Commissioner Elżbieta Bieńkowska) and CECIMO and European Council for Motor Trades and Repairs

26 Mar 2015 · Motor Trades & Repairs