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LKQ Europe

LKQ Europe, a subsidiary of LKQ Corporation, with its head office in Zug, Switzerland, is the leading distributor of automotive aftermarket parts for cars, commercial vans and industrial vehicles in Europe.

Lobbying Activity

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

1 Dec 2025

The Carglass/ATU vs FCA case stands as a regrettable example of the lengthy legal proceedings required for the independent aftermarket to have its fundamental rights respected. The judgment merely reaffirms obligations that vehicle manufacturers should have already fulfilled under the existing type approval regulation. As the Delegated Act moves forward, it is essential that it guarantees fair and equal access for the independent aftermarket, matching that of vehicle manufacturers and their authorised networks. Effective policing of these new requirements is crucial, and the EU must respond swiftly and decisively to any non-compliance, ensuring independent operators are not forced into further protracted and costly litigation. Our comments in attachment include proposed amendments to further improve the proposed Delegated Act.
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Response to Circular Economy Act

6 Nov 2025

We welcome the European Commissions initiative to develop a Circular Economy Act and wish to express our strong support for the key priorities outlined by APRA Europe. We believe the considerations listed in the attached LKQ document are essential for the Acts success and for achieving the EUs environmental and sustainability goals.
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Response to Clean corporate vehicles

29 Aug 2025

Please find attached our feedback to the consultation on clean corporate vehicles in which we explain how we are greening our fleet of 8700 vehicles. We also highlight the challenges as well as the economic and operational realities. We urge the Commission to avoid the introduction of ZEV mandates. We believe that any future legislative proposal should be grounded in the operational realities of existing business models. The introduction of mandatory targets, without adequate supporting infrastructure or financial measures, could threaten to disrupt the continuity and competitiveness of our parts wholesale business and sector.
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Response to Revision of the Roadworthiness Package

30 Jun 2025

The attached LKQ Europe position paper highlights the critical importance of adapting regulatory frameworks to address the evolving challenges brought about by advanced vehicle technologies, particularly electric and automated vehicles. Innovative inspection protocols and unrestricted access to vital resourcessuch as testing tools, training, and manufacturers on-board systemsare indispensable for maintaining road safety and achieving environmental sustainability goals. From a safety perspective, updated testing standards are necessary to identify defects in complex systems like ADAS, regenerative braking, and high-voltage drivetrains, ensuring all vehicles continue to perform optimally. Environmentally, rigorous inspections can help monitor emissions performance and battery health, contributing to broader climate and air quality objectives. We urge policymakers to prioritise the frequency of periodic technical inspections, especially in light of the ageing vehicle fleet across Europe. Older vehicles often present higher risks due to wear and tear on critical components, necessitating more frequent testing to ensure compliance with safety and environmental standards. Adapting inspection schedules to reflect vehicle age can significantly enhance road safety and prolong the operational lifecycle of these vehicles. Additionally, for modern vehicles such as EVs, the periodicity of inspections should account for specific characteristics, such as accelerated tyre wear caused by higher torque and the potential masking of traditional brake issues due to regenerative braking systems. This tailored approach supports long-term safety and environmental benefits while preparing Europe for a sustainable automotive future.
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Meeting with Eva Schultz (Cabinet of Executive Vice-President Roxana Mînzatu)

7 Mar 2025 · Meeting with LKQ – Strategic Dialogue on the Future of the European Automotive Industry – thematic session on skills and social considerations

Meeting with Barbara Bonte (Member of the European Parliament)

25 Sept 2024 · Auto-industrie

Response to Evaluation of the Motor Vehicle Block Exemption Regulation

21 Jun 2024

Please find below the view of LKQ Europe on the MVBER evaluation.
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Response to Revision of EU legislation on end-of-life vehicles

30 Nov 2023

Please find enclosed LKQ Europe's response to the consultation.
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Meeting with Catharina Rinzema (Member of the European Parliament, Shadow rapporteur) and Koninklijke Nederlandse Toeristenbond ANWB

12 Jul 2023 · Right to Repair

Meeting with Catharina Rinzema (Member of the European Parliament, Rapporteur)

14 Jun 2023 · Right to Repair

Meeting with René Repasi (Member of the European Parliament, Rapporteur)

2 Jun 2023 · Exchange of Views on the Right to Repair Directive/ Recht auf Reparatur Richtlinie (R2R) - Staff Level

Response to Promoting sustainability in consumer after-sales

22 May 2023

Please find attached our response to the consultation. LKQ Europe, a subsidiary of LKQ Corporation is the leading distributor of automotive aftermarket parts for cars, commercial vans and industrial vehicles in Europe. It currently employs approximately 26,000 people with a network of more than 1,000 branches and approximately $5.7 billion in revenue in 2022. The organisation supplies around 100,000 independent workshops in over 20 European countries.
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Response to Review of the Designs Directive

27 Jan 2023

Please find attached LKQ Europe response to the consultation on intellectual property - review of EU rules on industrial design (Design Directive).
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Response to Adapting liability rules to the digital age, the circular economy and global value chains - the new Product Liability Directive

30 Nov 2022

The proposed amendments of the product liability directive and the introduction of the new AI liability directive cut across the operations of LKQ Europe. In the attached response we focus on four issues: Distributor liability: the importer can be held liable in case of import from outside the EU and the proposed time for the distributor to identify an economic operator Circular economy and remanufacturing: the interpretation of the term substantial modification Proportionality: of the disclosure of information. Data loss: the measures necessary to preserve the confidentiality of trade secrets across jurisdictions and the presumption of a causal link between the fault of the defendant and the output produced by the AI system.
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Meeting with Antonius Manders (Member of the European Parliament)

18 Oct 2022 · Data Act

Meeting with Jeroen Lenaers (Member of the European Parliament)

12 Oct 2022 · European Data Act

Response to Review of the EU rules on Motor Vehicle Block Exemption

27 Sept 2022

LKQ Europe welcomes the Commission evaluation and conclusion that Regulation (EU) 461/2010 (the MVBER) is and remains important for competition in the motor vehicle sector. LKQ Europe also supports the Commission proposal to extend and update the current regime at least until May 31, 2028 and perform additional evaluations in due time. To achieve a fit for purpose MVBER, LKQ Europe believes this can be achieved by: • introducing better definitions and examples both in the MVBER and SGL, thereby reducing the difficulties of interpretation; • including new technologies, data and access to the vehicle and its systems for data processing and use, entertainment, refueling and captive parts in the definition of essential inputs; • improving the enforcement of the MVBER on the EU and member state levels The attached document sets out in detail the current issues and challenges resulting amongst others from a survey ran during Summer 2022 with independent workshops. It also proposes amendments to further improve the Supplementary Guidelines.
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Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur) and UNIFE and REWE ZENTRALFINANZ eG

13 Sept 2022 · Data Act

Response to Sustainable Products Initiative

21 Jun 2022

LKQ Europe, a subsidiary of LKQ Corporation, with its head office in Zug, Switzerland, is the leading distributor of automotive aftermarket parts for cars, commercial vans and industrial vehicles in Europe. It currently employs approximately 26,000 people with a network of more than 1,000 branches and approximately $6.1 billion in revenue in 2021. The organization supplies around 100,000 independent workshops in over 20 European countries. The group includes Euro Car Parts, LKQ Fource, RHIAG Group, Elit, Auto Kelly, and STAHLGRUBER Group, as well as recycling specialist, Atracco. LKQ also holds a minority interest in Mekonomen Group. LKQ Europe supports the general approach taken by the Commission in setting ecodesign requirements for sustainable products. LKQ Europe views these requirements in conjunction with the future proposal on right-to-repair as instrumental in defining how products need to be designed, maintained and repaired in a sustainable way. In article 5 of the proposed Regulation it is stipulated that ecodesign requirements shall be established for specific product groups. When considering automotive, the Commission Staff Working document correctly notes the need to take care about the coherence with ongoing initiatives on the revision of ELV requirements and the upcoming Battery requirements. LKQ Europe supports the analysis in the Commission Staff Working document: the ELV and Battery regulations should be the main tools for vehicle requirements to be covered under the ecodesign proposed regulation.
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Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

9 May 2022

LKQ Europe, a subsidiary of LKQ Corporation, with its head office in Zug, Switzerland, is the leading distributor of automotive aftermarket parts for cars, commercial vans and industrial vehicles in Europe. It currently employs approximately 26,000 people with a network of more than 1,000 branches and approximately $6.1 billion in revenue in 2021. The organization supplies around 100,000 independent workshops in over 20 European countries. The group includes Euro Car Parts, LKQ Fource, RHIAG Group, Elit, Auto Kelly, and STAHLGRUBER Group, as well as recycling specialist, Atracco. LKQ also holds a minority interest in Mekonomen Group. LKQ Europe supports the general principles as laid down in the proposal. Specifically we support: - The manufacturer’s obligation to make the data by default easily and securely accessible, including continuously, directly and in real-time. - Clarity on ownership of data by the consumer to enable accessibility & mobility to service providers without restriction. This mobility of data is already frequently addressed in metering and mobile phone industries. - The prohibition on monitoring by the manufacturer of the activities of users/third parties. - Costs only relate to making the data available (and not for the data itself) and based on FRAND principles. Some provisions LKQ Europe would like to see clarified: - There is no ‘Ab initio’ right of access to the information 3rd parties require to develop their services/products as alternative choice for users. Such ‘Ab initio’ rights are required to give effect to the right of access to data for the product user, as without a means of access, access rights in themselves serve no purpose when no alternative could be created. Users will be locked-in due to lack of choice. - The data holder obtains an institutionalised right to use the data the machine generates for its own business purposes. No distinction is made between the role of the data holder to make the data (technically) available and the role of the data holder to use the machine generated data for its own business purposes. Thus, under the Data Act, the data holder is granted an important competitive advantage. - Some information or data produced by IP protected algorithms may be excluded: In the preamble, there is a provision stating that ‘The data represent the digitalisation of user actions and events and should accordingly be accessible to the user, while information derived or inferred from the data, where lawfully held, should not be considered within scope of this Regulation’. This provision could exclude access to certain data, such as predictive maintenance information generated by an application running in the vehicle. Given the complexity of automotive data and its importance to consumers. LKQ Europe welcomes a sector specific legislative measure to regulate access, ownership, sharing and security of in-vehicle generated data. This should include any software required to access or use such data. Without easy access to data then consumers access to repair, re-fuelling/-charging, servicing and other automotive and mobility services would be restricted. OEM’s will have a monopoly and there is a risk of bundling or restricted access, unless sector specific requirements are put in place. LKQ Europe would favour the industry specific legislation to include an annex with a ‘model agreement for licensing’. LKQ Europe will respond in further detail in the separate In-Vehicle Generated Data Consultation.
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