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Japan Automobile Manufacturers Association, Inc. European Office

JAMA European Office

JAMA monitors EU policy developments to support the Japanese automobile industry.

Lobbying Activity

Meeting with Edoardo Turano (Head of Unit Climate Action)

21 Jan 2026 · Cars and vans CO2 review proposal

Japanese carmakers urge EU to simplify electronic vehicle inspections

28 Jul 2025
Topic — The EU is updating roadworthiness rules to include electronic safety system inspections.
Message — The group requests reducing the number of inspection systems and adopting simpler diagnostic methods. They seek a five-year lead time for new models to implement technical changes.12
Why — Standardized data formats and reduced inspection targets would lower technical and compliance costs.3
Impact — Safety regulators lose the ability to verify that vehicle software has not been tampered with.4
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Meeting with Filip Turek (Member of the European Parliament)

30 Jun 2025 · Technological neutrality ahead of 2050

Japanese Automakers Call for Realistic Euro 7 Approval Rules

13 May 2025
Topic — This initiative establishes technical requirements for the emissions type-approval of motor vehicles.
Message — JAMA requests removing unrealistic requirements regarding manipulation devices. They seek delays for cybersecurity systems and removal of redundant monitoring.123
Why — Manufacturers would avoid heavy investment costs for redundant data systems and complex reporting.45
Impact — Regulators and public interest groups lose measures designed to prevent emission-cheating strategies.6
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Japanese carmakers call for flexible Euro 7 emission monitoring rules

13 May 2025
Topic — Consultation on technical methods and tests for type-approval under Euro 7 standards.
Message — The association requests regulatory clarity for new monitoring systems and flexible data submission timelines. They suggest simplifying in-vehicle displays and using QR codes instead of physical vehicle engravings. Additionally, JAMA seeks to align technical requirements with international standards to ensure global consistency.123
Why — These amendments would lower administrative burdens and reduce the cost of upgrading IT infrastructure.45
Impact — Regulators lose access to complete historical emission data if records are lost during repairs.6
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Response to Determining the technical requirements of on-board fuel and/or energy consumption monitors for heavy-duty vehicles

25 Apr 2025

The Japan Automobile Manufacturers Association, Inc. (JAMA) is a non-profit industry association which represents the interests of Japan's 14 automobile manufacturers including passanger cars, trucks and busses, and motorcycle. Please find JAMA's feedback on the draft regulation in the attached document.
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Response to Updated test procedures for eCall

25 Apr 2025

The Japan Automobile Manufacturers Association, Inc. (JAMA) is a non-profit industry association which represents the interests of Japan's 14 automobile manufacturers including passanger cars, trucks and busses, and motorcycle. Please find JAMA's feedback on the draft regulation in the attached document
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Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

7 Feb 2025 · Common challenges of the EU and Japanese automotive sector

Response to Carbon footprint methodology for electric vehicle batteries

28 May 2024

The Japan Automobile Manufacturers Association, Inc. (JAMA) is a non-profit industry association which represents the interests of Japan's 14 automobile manufacturers. Attached is our comment on the subject.
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Japanese Automakers Seek Delay in EU End-of-Life Rules

1 Dec 2023
Topic — New EU regulation governing the circular design and recycling of end-of-life vehicles.
Message — The organization requests a minimum five-year lead time for new vehicle designs to ensure technical feasibility. They also recommend managing recycled plastics in their entirety rather than tracking specific categories like post-consumer waste. Finally, they argue that producers should not be held financially responsible for the recycling targets of independent waste operators.123
Why — This would preserve the cost-competitiveness of their vehicles and avoid complex, expensive material tracking systems.45
Impact — Waste management operators would lose guaranteed cost compensation and face more direct government oversight for recycling targets.67
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Japanese carmakers urge flexible rules for CO2 eco-innovation

20 Sept 2023
Topic — A procedure for approving innovative technologies to reduce CO2 emissions from vehicles.
Message — JAMA requests exempting air conditioning from standard innovativeness rules and allowing more response time. They argue current formulas for assessing air conditioning performance are not appropriate.12
Why — This ensures manufacturers do not waste resources by being forced to abandon applications.3
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Response to Detailed procedures for the in-service verification of CO2 emissions from light-duty vehicles

10 Aug 2023

Japan Automobile Manufacturers Association (JAMA) welcomes the opportunity to provide feedback to the draft Commission Implementing Regulation on ISV for light-duty vehicles. Please find attached our comments and contribution.
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JAMA Urges EU to Include 5G in New Patent Rules

10 Aug 2023
Topic — New EU rules to create transparency and fairness in standard essential patent licensing.
Message — JAMA requests expanding the regulation to include existing 5G standards and all patent holders regardless of membership. They also want to prevent patent owners from suing while licensing negotiations are actively underway.12
Why — This would reduce legal uncertainty and prevent unfair royalty demands for vehicle manufacturers.3
Impact — Patent assertion entities would lose the ability to exploit loopholes and avoid essentiality checks.4
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Japanese automakers urge more realistic heavy-duty CO2 targets

19 May 2023
Topic — The Commission is reviewing carbon dioxide emission standards for heavy-duty vehicles.
Message — JAMA requests postponing the expanded scope or reviewing specific reduction goals. They argue for including renewable fuels and aligning targets with infrastructure readiness.123
Why — These measures would lower technical hurdles and reduce immediate regulatory compliance costs.45
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Response to Development of Euro 7 emission standards for cars, vans, lorries and buses

9 Feb 2023

Japan Automobile Manufacturers Association (JAMA) welcomes the opportunity to provide feedback to the proposed Euro 7 legislative proposals. Please find attached our comments and contribution.
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JAMA Urges Two-Year Lead Time for Emission Testing Rules

20 Jun 2022
Topic — Amendments to laboratory and real-driving emission testing procedures for light-duty vehicles.
Message — JAMA requests a minimum two-year lead time for technical standards to ensure stable product planning. They also advocate for promoting charging infrastructure rather than just modifying emissions calculation factors for hybrids.123
Why — This would ensure regulatory certainty and protect the industry's ability to meet CO2 compliance targets.4
Impact — Environmental advocates lose if delayed rule changes allow plug-in hybrids to continue emitting more than officially recorded.5
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Japanese automakers urge 24-month delay for EU Data Act

13 May 2022
Topic — New EU rules regulating data access and sharing across the digital economy.
Message — JAMA seeks to extend the implementation period from 12 to 24 months. They request limiting shared data to what is already accessible to manufacturers. They also want business users to provide appropriate compensation for data access.123
Why — A longer timeline and limited data scope would reduce technical costs.4
Impact — Third-party service providers will face longer delays accessing necessary vehicle data.5
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JAMA Urges EU to Reform Standard Essential Patent Licensing

29 Apr 2022
Topic — The European Commission is consulting on creating a sustainable framework for standard essential patents.
Message — JAMA calls for increased transparency through independent essentiality assessments and clear EU guidance on licensing negotiations. They specifically advocate for licensing at the component level rather than the finished vehicle level to address the current power imbalance and prevent unfair injunctions.123
Why — This framework would lower licensing costs by preventing patent holders from overcharging based on the car's total value.4
Impact — Technology patent holders would lose revenue by being unable to target high-value end-products for inflated royalties.5
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Response to Carbon Border Adjustment Mechanism

15 Nov 2021

Please find JAMA feedback comment on the Carbon Border Adjustment Mechanism (CBAM) as attached.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

15 Nov 2021

Please find JAMA feedback comments on a proposal for a amending directive regards the promotion of energy from renewable sources.
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Response to Revision of Alternative Fuels Infrastructure Directive

15 Nov 2021

Please find JAMA feedback comments on a proposal for a regulation on the deployment of alternative fuels infrastructure and a strategic rollout plan to outline a set of supplementary actions to support the rapid deployment of alternative fuels infrastructure.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

Please find JAMA feedback comment on a proposal amending the European Emission Trading System (ETS) as attached.
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Japanese automakers call 2035 combustion engine ban unrealistic

7 Nov 2021
Topic — The European Commission is revising CO2 emission standards for new passenger cars and vans.
Message — JAMA argues that a total ban on internal combustion engines by 2035 is unrealistic and urges the EU to maintain technology neutrality. They suggest that engines powered by renewable fuels should remain a valid climate-neutral option after the deadline.12
Why — This would allow manufacturers to continue utilizing existing engine technologies while waiting for market demand to mature.34
Impact — Automotive workers and regional economies could suffer if the transition does not include employment protection measures.5
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Response to Modernising the EU’s batteries legislation

26 Feb 2021

The Japan Automobile Manufacturers Association (JAMA) is a nonprofit industry association comprising Japan’s fourteen manufacturers of passenger cars, trucks, buses and motorcycles. With climate change and other environmental issues being matters of global urgency, JAMA is committed to addressing relevant challenges in order to contribute to the European Union's policy objective of achieving climate neutrality by 2050. JAMA and its members express our gratitude to the European Commission for giving us the opportunity to provide feedback on its initiative of “modernising EU rules” on batteries.
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Japanese carmakers urge balanced CO2 targets and EV incentives

26 Nov 2020
Topic — The European Commission is revising CO2 emission performance standards for cars.
Message — The organization requests a balanced approach to stricter emission targets that considers the economic impact of the pandemic. They also call for an improved incentive system to accelerate the adoption of low-emission vehicles.123
Why — A more flexible incentive scheme would help manufacturers avoid costly fines while navigating economic recovery.45
Impact — Climate advocacy groups lose if the transition is slowed by prioritizing industry economic stability.6
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Meeting with Gwenole Cozigou (Acting Director-General Internal Market, Industry, Entrepreneurship and SMEs)

19 Feb 2020 · Courtesy meeting and discuss Automotive Industry strategy

Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

18 Feb 2020 · Green Deal

Response to General Safety of Vehicles and Pedestrians

17 Jul 2018

Whereas grateful that some of the comments we submitted to DG GROW have been reflected into COM(2018)286 final (also referred to as the “Draft” in this comment document.) We are pleased to attach a file of our comments on the Draft in response to your feedback invitation. It is hoped that these comments of ours will prove beneficial in your work of regulation drafting. Main Points of JAMA’s Comments (1) International harmonization JAMA acknowledges that reducing traffic accident fatalities and injuries is a high-priority issue of global importance and believes that the specific automotive technical regulations of Japan/EU need to be harmonized with UN Regulations in accordance with the Japan-EU Economic Partnership Agreement in Principle.  Furthermore, when an existing UNR is strengthened in strictness or its scope is expanded over to additional vehicle categories, it is necessary that such changes be in harmony with other UNRs. (2) Lead time While automated driving and other advanced-safety technologies are expected to enhance road safety, the details of respective delegated acts are yet to be established, making impossible for OEMs to start their development activities on a full scale. Consequently, it is imperative that the lead time for the regulations be started not from the implementation dates of COM (2018) 286 final but from the publication dates of the respective delegated acts so as to ensure a sufficient length of lead time.
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Response to Improving the emissions legislation for Light Duty Vehicles

4 Apr 2018

JAMA Comments on the Draft EU-WLTP 2nd ACT (2/2) 3. ISC 3.2 Funding COM Draft: Funding for ISC testing performed by GTAA (granting type approval authorities) shall be provided for by the manufacturer. JAMA Proposal: This clause should be deleted. Justification: It would be difficult to accept such a requirement. 3.3 Type 4 COM Draft: (Article 9) GTAA may perform Type 4 testing in addition to the procedure stipulated in Annex II. JAMA Proposal: The Type 4 ISC testing requirement should be eliminated. Justification: In in-use vehicles, evaporative emissions are impacted by many unpredictable factors arising in normal use. Therefore the ISC requirement should not be included in the revised evaporative emissions testing but instead added to the stringent durability testing in the homologation process. Because the ISC testing requirement for evaporative emissions is not mandatory, adding such a clause to the revised test procedure is not justified. 4. AES/BES COM Draft: AES/BES documentation requirements have been included in Annex I. JAMA Proposal: All these requirements should be deleted, or at a minimum the “best available technology” clause should be revised as follows: Whenever a technology or design that would allow for improved emissions control is widely available on the market at the time of the AES application and when deemed appropriate in view of technological neutrality, it shall be used to the largest extent technically and economically possible (i.e. with no unjustified modulation). Justifications: These requirements were not only not agreed, but not discussed at all in the RDE-LDV WG. As many of the requirements are ambiguous, confusion during the homologation process can be expected. While JAMA agrees with the concept of such requirements, we request more consideration and discussion before establishing specific regulatory requirements. 5. OBFCM COM Draft: OBFCM documentation requirements have been included in Annex XXII. JAMA Proposal: The second paragraph of point 5 should be amended as follows: Notwithstanding the specifications of the standards on reset conditions, once the vehicle has entered into service the values of the lifetime counters shall be preserved. • In case of malfunctioning affecting these values, the counters may be reset simultaneously to ensure that the values remain fully synchronised. • In case of malfunctioning not affecting these values, for vehicles which the ECU memory type is unable to preserve data when battery is disconnected (e.g. static RAM), data needs to be preserved only after January 2022 for new vehicles type-approved and January 2023 for new vehicles registered. Justifications: To develop a new engine control unit, lead time is required. 6. Editing errors 6.1 COM Draft: In Sub-Annex 6b, “Correction of CO2 results against the target speed and distance,” in Paragraph 3.1: Fi : (vi – vi-1)2 should be (vi + vi-1)2 Fmi : (vmi – vmi-1)2 should be (vmi + vmi-1)2 ai : (vi + vi-1) should be (vi – vi-1) ami : (vmi + vmi-1) should be (vmi – vmi-1) 6.2 COM Draft: In Sub-Annex 7, Table A7/1: Output step 2b and Output step 3 should be switched around. • In the current proposal, RCB correction (step 3) comes after the correction of CO2 results against the target speed and distance (step 2b, newly inserted). • Problem: The correction of CO2 results (step 2b) needs to use RCB correction values in its formula, so it is contradictory. • Proposal: RCB correction should come before the correction of CO2 results against the target speed and distance. 6.3 COM Draft: In Sub-Annex 6b, 3.5: • “MCO2,RCB” to be replaced with “M CO2,p,3” or the other way around. • In any case, this value should represent RCB corrected CO2 value without the correction of CO2 results.
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JAMA warns against 'unacceptable' EU CO2 reduction targets

22 Mar 2018
Topic — New EU rules setting CO2 emission standards for passenger cars and light commercial vehicles.
Message — JAMA proposes a 20% CO2 reduction by 2030 and removing the 2025 interim target. They also request target phase-ins and continued exemptions for small-volume manufacturers.123
Why — Lowering targets and extending deadlines reduces the technical and financial burden on manufacturers.45
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Response to Vehicle's On-Board Fuel Consumption Measurement device

9 Jan 2018

In principle, JAMA supports the Commission’s intention of ensuring the validity of WLTP by setting new requirements on the continuous storage of fuel consumption(FC) data on-board. Moreover, we appreciate the COM’s response to industry’s concerns by leaving BEVs from the OBFCM requirements in the 1st step and excluding distance measurement from the accuracy requirement. The data on fuel consumption stored in on-board systems in the ECU and the values measured during the TA and CoP are calculated or measured in different ways. On one hand, the FC values stored in the vehicle’s on-board system are the results of estimation based on the combination of fixed/assumed amount of fuels, injection pulse width/time for each fuel injection. The degree of accuracy of stored data depends on car manufacturers, and it is an area of competition. On the other hand, the actual FC can vary according to several factors, which subsequently impact the OEM’s compliance with the 4% accuracy requirement. In respect of the EU and Japan Competition Law, we provide generalized statements regarding the accuracy of each factor as follows (it would be too sensitive to share more detailed information): 1. Measurement methods: the actual FC data can be obtained through a number of methods, such as carbon balance method and the direct volumetric measurement method of fuel flow. A consistent deviation of approximately 3% is statistically proved between these two methods by a study conducted by the US EPA. 2. CVS uncertainty: CVS uses the carbon balance method, measuring the carbon atoms in the vehicle exhaust and subsequently calculating the quantity of fuel consumed. 3% uncertainty of CVS lab measurements has been reported by a recent JRC study. 3. Fuel injection variances: the actual consumption of fuels are constantly controlled and adjusted according to driving/vehicle conditions. For example, actual amount of fuel injection is reduced when evaporated fuel is purged into the engine while the fixed value is used for fuel consumption on ECM. There are also variances in air flow meters for capturing the amount of air flow and characteristics of air, which would be reflected in accuracy deviation. In addition, the most up-to date engines are equipped with high fuel pressure system susceptible to time, which makes them more prone to variances in fuel injection pulse width. Particularly fuel injection systems for diesel engines work in high pressure, which results in the largest variances. Considering these factors, JAMA estimates that a total 7.5% deviation for diesel and 6.5% for petrol can occur due to these factors. 4. The reference fuel divergence: this factor provides an additional uncertainty. The density of reference fuels differs up to 0.9% for petrol and 0.2% for diesel even within the testing fuels . The share of ethanol in testing fuels additionally impacts the actual amount of fuel injection as it is controlled to respond to ethanol by feeding more fuel than usual in case the share of ethanol in fuels is relatively high. When we process these deviation factors with the mathematical method of square-root of sum of squares, the accuracy of FC data will deviate up to 7.8% for petrol. and 8.6% for diesel at TA and CoP. Therefore, 4% accuracy requirement is too ambitious. For these reasons, JAMA requests a more cautious approach on accuracy requirement. JAMA is particularly concerned on the potentially high risk that the 4% accuracy requirement may hamper the TA process and impede the launch of new vehicles of the future with lower CO2 emissions. It is therefore recommended for the 1st step that manufacturers are required to equip their vehicles with OBFCM without accuracy requirements. The accuracy requirement should be set as a 2nd step after a detailed and more thorough feasibility/impact assessment than the recent JRC’s test, which was based only on 2 vehicles and is far from fully representing the market reality.
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Response to Real-Driving Emissions in the EURO 6 regulation on emissions from light passenger and commercial vehicles (RDE3)

8 Dec 2016

While JAMA fully recognizes the objective of the RDE Regulation and its 3rd Package, we would like to state our views on the concerned topics below. 1.Implementation dates Enforcement dates should be the same as the dates for RDE 2nd step (i.e. 1 Jan. 2020 for new types and 1 Jan. 2021 for all vehicles). Rationale: Lead time for the auto industry is insufficient for the following reasons. a. EC plans a TCMV vote on 20 Dec. 2016 which will lead to publication in the OJ in June 2017 at the earliest. Lead time to the stipulated enforcement date of 1 September 2017 for new vehicles is thus extremely short. b. The NOx Conformity Factor (CF) adopted at TCMV in Oct. 2015 was based on the stakeholder information requested by EC to determine achievable emission levels by Euro 6 systems without modifying after-treatment devices. However, those emission levels were established based on hot-start conditions because no cold-start emission calculation procedure existed at that time. Since cold-start impact is not reflected in the CF, additional lead time of at least 3 years is necessary. c. Although EC proposal requires particulate number (PN) for all vehicles by 1 Sept. 2018 based on footnote(3) (in (EU) 459/2012, Annex I, Table 2), lead time has not been discussed, so the stipulated enforcement date should be postponed. It must be noted that footnote(3) was abruptly included without any consultations with stakeholders and that this inclusion did not subsequently give rise to discussions on this matter because a lead time of around 3 years was a common assumption by the auto industry at that time. While there has been considerable delay in the publication of the RDE regulations, citing a footnote insertion dating back to 2012 as justification for the enforcement date is completely irrational. 2.Fuel specifications Fuel specs for RDE testing should be in line with Type 1 testing using the reference fuel. Rationale: Fuel specs have a significant impact on emission results, and especially on PN emission results. PN emissions from RDE testing vary widely, even in identical models, depending on the market fuels used due to the wide variety of fuel specs, which is why we request the use of reference fuels to minimize data variations. If market fuels are used for RDE testing, JAMA strongly suggests that the simplified PN-index concept we proposed within the RDE-LDV discussions should be applied, compensating the test results when necessary using the index. But since discussions on the use of such a correction method are needed, in the meantime, pending the outcome of those discussions, the 3rd-package regulations should at least include an additional provision formulated on the basis of the E150 distillation parameter enabling an optimal impact on PN emissions, in order to address issues concerning very heavy fuels used in RDE testing. 3.Validity of CF value (1.5) for PN The validity of the stipulated CF value(1.5) requires further investigation. Rationale: There has been insufficient investigation of the testing accuracy of PN-PEMS and the data accumulated so far do not provide sufficient basis for establishing appropriate CF values. The validity of the 1.5 value should be further investigated only after the accuracy and reliability of the testing procedure has been confirmed, and should be revised if necessary on the basis of those investigations. 4. Extended documentation package Auxiliary emission strategies requirements should be regulated only after thorough discussion among the relevant stakeholders. Rationale: While JAMA fully understands that the objective in including such requirements is to ensure the transparency of type approvals, we cannot support their abrupt inclusion in the RDE regulations without any discussion whatsoever with relevant stakeholders on their content. Adoption of these requirements in the regulations should be carried out only after a thorough examination/assessment of their specific content.
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Meeting with Jyrki Katainen (Vice-President) and

29 Jun 2016 · EU-Japan economic relations

Meeting with Elżbieta Bieńkowska (Commissioner) and

27 Jun 2016 · Economic Partnership Agreement EPA

Meeting with Jon Nyman (Cabinet of Vice-President Cecilia Malmström), Maria Asenius (Cabinet of Vice-President Cecilia Malmström)

3 Mar 2015 · EU - Japan negotiations

Meeting with Justyna Morek (Cabinet of Commissioner Elżbieta Bieńkowska), Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska)

3 Mar 2015 · Automotive sector in Europe