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MAHLE International GmbH

MAHLE

MAHLE is a leading international automotive supplier and technology developer focused on e-mobility, thermal management, fuel cells, and clean combustion engines.

Lobbying Activity

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

2 Dec 2025

MAHLE welcomes the Commission´s efforts to draft regulatory amendments on this technically complex matter. MAHLE is significantly affected by this regulation, particularly in the development and distribution of diagnostic tools for automotive workshops. However, the technical circumstances that led to the European court ruling must be prevented from occurring in the future. We emphasize the importance of rigorous enforcement of existing regulatory requirements prior to type-approval to ensure a level playing field for vehicle repairability across Europe. Please find more detailed feedback in the attached document.
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Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis), Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

25 Nov 2025 · Clean corporate vehicles

Meeting with Estelle Goeger (Cabinet of Executive Vice-President Stéphane Séjourné) and Bundesverband der Deutschen Industrie e.V. and

4 Nov 2025 · Overview of the Commission's Single Market Strategy.

Meeting with Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič) and Association des Constructeurs Européens d'Automobiles and

8 Oct 2025 · US and EU Trade Relations concerning tariff rates on the European heavy-duty vehicles sector

Meeting with René Repasi (Member of the European Parliament) and Robert Bosch GmbH and

8 Oct 2025 · Austausch mit Betriebsrät:innen: Klimafreundliche Mobilität und Sicherung der Wettbewerbsfähigkeit der Zulieferindustrie in Deutschland & Europa

Meeting with Jens Gieseke (Member of the European Parliament) and Robert Bosch GmbH and

8 Oct 2025 · Austausch mit den Betriebsräten zu EU-Verkehrspolitik

MAHLE urges simplified CBAM rules and extended default values

25 Sept 2025
Topic — This consultation establishes the methodology for calculating actual embedded emissions for the CBAM.
Message — MAHLE requests clear rules for supplier emissions data and the immediate publication of benchmark values. They also suggest allowing default values for several years and accepting existing carbon footprints.123
Why — This would reduce administrative burdens and eliminate the need for expensive external consultants.45
Impact — Environmental groups lose precise data for carbon tracking when generic default values are permitted.6
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Meeting with Nils Behrndt (Deputy Secretary-General Secretariat-General) and Robert Bosch GmbH and ZF Friedrichshafen AG

25 Sept 2025 · Regulatory framework, climate targets

Meeting with Stéphane Séjourné (Executive Vice-President) and

11 Sept 2025 · - Compétitivité des entreprises - Marché intérieur - Decarbonation - Neutralité carbonne - Voiture électrique

MAHLE urges standardized electronic and assisted driving testing for vehicles

28 Jul 2025
Topic — The consultation reviews EU rules for vehicle inspections and roadworthiness testing.
Message — MAHLE requests standardized criteria for electronic system failures and specific protocols for vehicle diagnostics. They also propose using dedicated tools to verify that assisted driving sensors are properly aligned.12
Why — Standardizing advanced testing methods would boost sales of MAHLE’s existing patented diagnostic equipment.34
Impact — Smaller testing facilities could struggle with the costs of upgrading to complex new hardware.5
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Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné), Estelle Goeger (Cabinet of Executive Vice-President Stéphane Séjourné)

25 Jun 2025 · Automotive

Meeting with Simone Ritzek-Seidl (Cabinet of Commissioner Apostolos Tzitzikostas) and Robert Bosch GmbH

5 Jun 2025 · Follow-up to visit of Commisioner Tzitzikostas in Munich

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and Bayerische Motoren Werke Aktiengesellschaft and Verband der Automobilindustrie

19 Mar 2025 · Future of the automotive sector

Meeting with Daniel Caspary (Member of the European Parliament)

19 Feb 2025 · Austausch

Meeting with Stéphane Séjourné (Executive Vice-President) and

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

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and Robert Bosch GmbH and

12 Feb 2025 · Future of the automotive sector

Meeting with Raúl De La Hoz Quintano (Member of the European Parliament)

4 Feb 2025 · Introduction

Meeting with Borys Budka (Member of the European Parliament, Committee chair)

30 Jan 2025 · Automotive sector

Meeting with Vivien Costanzo (Member of the European Parliament) and Mercedes-Benz Group AG and Robert Bosch GmbH

16 Jan 2025 · Exchange of views on the future of the European Automotive Industry at the Automotive Summit

Meeting with Stéphane Séjourné (Executive Vice-President) and

16 Jan 2025 · Future of the automotive sector

Meeting with Vivien Costanzo (Member of the European Parliament)

16 Oct 2024 · Exchange of views on the future of the automotive policy

Meeting with Andreas Glück (Member of the European Parliament)

4 Sept 2024 · Climate and Transport Policy

Meeting with Andrea Wechsler (Member of the European Parliament) and European Association Automotive Suppliers and

3 Sept 2024 · EU Energy and Industry Policy

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs), Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

2 Jul 2024 · Discussion on competitiveness and Green Deal

MAHLE Urges Extension and Digital Updates to Vehicle Competition Rules

24 Jun 2024
Topic — This consultation evaluates competition rules for the motor vehicle repair and parts sector.
Message — MAHLE supports extending current competition rules and adding updates for new digital technologies. They want regulations to ensure that independent repair shops can verify and install spare parts digitally.12
Why — This would provide legal certainty and maintain market access for their spare parts business.3
Impact — Vehicle manufacturers could lose their ability to restrict repairs to their authorized networks.4
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Meeting with Kurt Vandenberghe (Director-General Climate Action) and Robert Bosch GmbH and ZF Friedrichshafen AG

24 Jun 2024 · Effective technology pathways for transport decarbonization towards 2040

Meeting with Michael Bloss (Member of the European Parliament)

14 May 2024 · Austasch Industriepolitik und Dekarbonisierung

Meeting with Daniel Caspary (Member of the European Parliament)

18 Mar 2024 · Austausch

Meeting with Anna Cavazzini (Member of the European Parliament, Committee chair) and Apple Inc. and

23 Feb 2024 · Aktuelle Themen in der Europapolitik und Sachsen

Meeting with Pascal Arimont (Member of the European Parliament)

7 Nov 2023 · CO2 emission standards for Heavy-Duty Vehicles

Meeting with Tiemo Wölken (Member of the European Parliament)

7 Nov 2023 · HDV CO2 Targets

Meeting with Matthias Ecke (Member of the European Parliament)

7 Nov 2023 · Industriepolitik

Meeting with Jens Geier (Member of the European Parliament)

24 Oct 2023 · Exchange on CO2 emission performance standards for new Heavy Duty Vehicles Regulation

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

19 Oct 2023 · In-vehicle data, transformation automotive industry

Meeting with Kurt Vandenberghe (Director-General Climate Action)

18 Oct 2023 · Current transformation challenges and insights from other regions like Asia and the US.

Meeting with Martina Michels (Member of the European Parliament, Shadow rapporteur)

15 Jun 2023 · Transformation in the automotive sector (staff level)

Meeting with Matthias Ecke (Member of the European Parliament, Shadow rapporteur)

15 Jun 2023 · Automobilregionen im Wandel

Meeting with Jens Gieseke (Member of the European Parliament, Shadow rapporteur)

30 Mar 2023 · Austausch zur EU-Verkehrspolitik

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean), Walter Goetz (Cabinet of Commissioner Adina Vălean)

16 Nov 2022 · Energy, supply chain and strategy for sustainable mobility.

Meeting with Jens Gieseke (Member of the European Parliament)

4 May 2022 · Austausch zur Vekehrspolitik

Meeting with René Repasi (Member of the European Parliament) and Bayerische Motoren Werke Aktiengesellschaft and ZF Friedrichshafen AG

20 Apr 2022 · Breakfast with works council chairpersons on "How can the green transformation in the automotive industry succeed?"

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

22 Mar 2022 · Meeting MAHLE/ZF/BOSCH to discuss Taxonomy, Access to in vehicle data and Euro VII developments

Meeting with Adina-Ioana Vălean (Commissioner)

22 Mar 2022 · Meeting with CEO

Meeting with Nicolas Schmit (Commissioner) and

22 Mar 2022 · Fair transitions, Skills Agenda, reskilling and upskilling of the workforce and the impact of the war in Ukraine on business and value chains.

Meeting with Sara Cerdas (Member of the European Parliament, Shadow rapporteur)

12 Jan 2022 · Revision of the Regulation on CO2 standards for cars and vans in the context of the Fit for 55 package

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Robert Bosch GmbH and ZF Friedrichshafen AG

21 Jun 2021 · CO2 standards for cars and vans; Euro 7

Meeting with Mauro Raffaele Petriccione (Director-General Climate Action) and Robert Bosch GmbH and ZF Friedrichshafen AG

13 Apr 2021 · Decarbonizing road transport sector

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans) and TotalEnergies SE and

3 Mar 2021 · Roundtable with transport value chain alliance - Transformation of the automotive value chain in the context of green recovery

Meeting with Anouk Faber (Cabinet of Commissioner Nicolas Schmit), Christoph Nerlich (Cabinet of Commissioner Nicolas Schmit) and

3 Mar 2021 · Roundtable with transport value chain alliance - Transformation of the automotive value chain in the context of green recovery.

Response to Revision of the CO2 emission standards for cars and vans

26 Nov 2020

The MAHLE Group is a leading international supplier to the automotive industry as well as a pioneer for the mobility of the future. We are committed to making transportation more efficient and more environmentally friendly and support the EU’s objective of becoming carbon-neutral by 2050. To achieve these goals, we need a reliable, long-term regulatory framework that is based on a comprehensive socio-economic impact assessment, reflecting the impact of the COVID-19 pandemic and resulting effects on mobility needs. The planned revision of the CO2 standards comes only one year after their adoption. Increasing the reduction target would create unnecessary uncertainty in the market and greatly increase the cost for compliance at a time when scarce resources are needed to counter the COVID-19 crisis. Instead of revising the targets, we would like to point out that the parallel revision of EU energy and climate legislation under the Green Deal provides a unique opportunity to better integrate and align the strictly sectoral regulations in order to increase their effectiveness and efficiency, by: • Maintaining technology-neutral regulation: Mobility needs are diverse, and every technology has a specific set of strengths and weaknesses tailored to the individual mobility use cases. Regulation with the intention to phase-out specific technologies is therefore counterproductive (older, more polluting vehicles being used longer) and could have unintended consequences (e.g. experience from first-generation biofuels). Instead, a clear pathway for phasing-out fossil fuels is needed. • Using market-based principles: Setting emission targets should move away from sector-specific ones towards a market-driven cap-and-trade instrument like the EU Emission Trading System to enable GHG-savings where they are most cost-efficient. • Holistic approach for guiding GHG reduction efforts: Current CO2 vehicle emission standards are based on tailpipe measurements considering only tank-to-wheel emissions. Emissions when producing, fuelling or recycling a vehicle are considered in isolation. To ensure a truly carbon-neutral economy, policymakers need to have a complete overview of all emissions along the product life cycle and how reductions in one stage impact emissions in another. Future legislation should therefore be based on a life cycle analysis or well-to-wheel analysis as a first step. This would ensure emission reductions in one stage are not offset by increases in others and reduce the environmental footprint by all market operators. • Realise potential of clean hydrogen: Hydrogen use in fuel cells as well as direct combustion in Internal Combustion Engines offers a complementary decarbonisation pathway to batteries. The EU can support it by developing infrastructure for the production and distribution of hydrogen with refuelling standards based on gaseous hydrogen. • Introduce a method for crediting highly efficient HVAC systems as eco-innovation for passenger cars and light commercial vehicles by 2021. Heating and cooling are responsible for an increasing share of energy consumption in vehicles but currently not considered by vehicle efficiency standards. • Leveraging potential of carbon-neutral fuels: The average car age in the EU is 11 years. Even when assuming 80% of all new cars sold in 2030 will be fully electric, it would still take decades to fully decarbonize the fleet. Using renewable fuels (biofuels, hydrogen and electricity-based liquid and gaseous fuels) could realise much greater CO2 savings through the existing vehicle fleet in parallel to those from electrification by: o Increasing the RED-II target for renewable fuels in 2030 to a minimum of 20% without multipliers and introducing a minimum sub-quota of 5% for e-fuels. o Full reduction of the tax for renewable fuels under the Energy Tax Directive. o Crediting schemes for renewable fuels in the CO2 fleet regulations. Switzerland has already implemented such a system.
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Response to A EU hydrogen strategy

8 Jun 2020

MAHLE welcomes the creation of an EU hydrogen strategy. Investments into clean hydrogen support the economic recovery and help secure technology leadership of EU industry while offering a no regret option to decarbonise the economy. In response to the roadmap, we would like to highlight the following: Clear need for hydrogen in road transport In order to be able to achieve the ambitious 2030 EU energy and climate targets, road transport needs additional clean energy carriers that are complementary to renewable electricity. This is because every powertrain technology has a specific set of strengths and weaknesses tailored to the individual mobility use cases. Hydrogen is most promising due to its versatility and ability to enable long-term, large-scale energy storage as well as rapid refuelling of vehicles both in gaseous as well as liquid forms through e-fuels. Fuel cell powertrains show their strength on long-haul and medium to short-haul journeys with high loads due to being locally emission-free and not requiring large batteries. For very long distances and high loads, the internal combustion engine remains highly competitive, due to its mature technology, affordability and the higher energy density related to the fuel and the resulting higher payload. By using hydrogen directly in internal combustion engines or hydrogen-based e-fuels through “drop-in” (rising percentages of decarbonised e- fuels in fossil fuels) we are able to de-fossilise also the existing fleet of vehicles on the road today and realise much greater CO2 savings in parallel to those from electrification (our well-to-wheel analysis shows vehicle emissions using 100% fossil fuel at 336 g CO2/kWhth compared to 75 g CO2/kWhth using 100% synthetic fuel). Promoting market-uptake It is important to also implement demand-side measures. Using clean hydrogen in road transport would provide the stable demand that is needed for industry to invest into large-scale production capacity. It could be incentivised through a robust certification scheme for clean production combined with: • Increasing the Renewable Energy Directive target for renewable fuels in 2030 to a minimum of 20%; • Full reduction of the energy tax for renewable fuels according to Article 19 EU Energy Tax Directive; • Or a crediting scheme for renewable fuels in the CO2 fleet regulations. The revision of the alternative fuels infrastructure directive should introduce more ambitious and binding national targets for hydrogen infrastructure. Promoting fuelling infrastructure along main EU road transport corridors could speed up the market take-up of hydrogen powertrains significantly. Another effective instrument could be CO2- based road charging. The EU should also champion standardisation efforts on relevant global standards such as fuel tanks and fuelling infrastructure to capitalise on its industry know-how. Efficient allocation needs holistic regulatory approach To ensure efficient allocation of clean hydrogen where it contributes the most to a carbon-neutral economy, policymakers need to have a complete overview of all emissions along the life cycle of the different hydrogen use cases and how reductions in one case impact emissions in another. Future regulation should therefore be based on a life cycle analysis to ensure emission reductions in one use case are not offset by increases in others and allow different energy carriers to compete based on their overall CO2 emissions. About MAHLE MAHLE is a leading international development partner and supplier to the automotive industry as well as a pioneer for the mobility of the future. The group’s product portfolio addresses all the crucial issues relating to the powertrain and air conditioning technology—both for drives with combustion engines and for e-mobility. In 2019, the group generated sales of approximately EUR 12 billion with more than 77,000 employees and is represented in more than 30 countries with 160 production locations.
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans) and Bayerische Motoren Werke Aktiengesellschaft and

2 Jun 2020 · Recovery and green transition in the automotive supply chain

Meeting with Günther Oettinger (Commissioner)

5 Jun 2018 · sustainable mobility + transformation of car industry

Meeting with Alina-Stefania Ujupan (Cabinet of Commissioner Mariya Gabriel)

4 Apr 2018 · Connected vehicles

Response to Post 2020 light vehicle CO2 Regulation(s)

14 Mar 2018

The CO2-regulation is a success story that should be continued to realize further CO2 reduction potential via efficiency measures, alternative powertrains and synthetic fuels. CO2 targets drive efficiency of the internal combustion engine (ICE) and innovations in the area of alternative powertrains. MAHLE believes the Commission’s proposal sets ambitious targets for further reducing CO2 emissions of light vehicles. To achieve significant CO2 reductions in the transport sector, we need both highly efficient ICEs, ideally running on synthetic fuels, and electrified powertrains. MAHLE thus calls for a wide and effective technology-neutrality to open all paths to decarbonization. 1. Include low-emission Air-Conditioning into the eco-innovations scheme already from 2022 MAHLE appreciates the eco-innovation scheme as a tool to include efficient auxiliaries into the CO2 regulation for light vehicle and welcomes that Air-Conditioning (A/C) can be recognized as an eco-innovation. However, A/C is included only from 2025 onwards. As A/C is a significant contributor to the real world CO2 emissions of vehicles, this timeframe ignores the already existing large potential for reducing their CO2-emissions of ICEs as well as the enormous impact on the range of electric vehicles. Therefore, the CO2 regulation should include A/C as an eco-innovation earlier than 2025 as this would incentivize a rapid introduction of the latest technologies of A/C into the new car fleet and lead to significant real-world CO2 savings. In addition, a simplification of the application process should be considered, also a lowering of the minimum CO2 reduction threshold from 1g/km to 0,5g/km as well as the deletion of the eco-innovation cap of 7g so as to allow additional applications. 2. Increase weighting of plug-in hybrids in the zero- and low-emission vehicles benchmark MAHLE welcomes the Commission’s zero- and low-emission vehicles (ZLEV) incentive scheme instead of mandatory quotas. The latter would have been a serious violation of the principle of technology-neutrality. However, by low-weighting plug-in hybrids (PHEV) in the ZLEV benchmark, the Commission sets a one-sided incentive for pure electrification: Zero- and low-emission vehicles are not counted equally. Instead, the linear weighting of the ZLEV-factor (based on tailpipe CO2) counts only cars with zero-tailpipe emissions fully as “one” ZLEV car, while cars with 50g/km are not counted at all. In this logic, a 25g/km vehicle counts as a 0.5 ZLEV car. As a result, the maximization of the ZLEV-factor drives car manufacturers to pure electrification, instead of hybridization. This neglects the social, industrial and environmental advantages of PHEVs: they offer the “best of both worlds” and not only eliminate crucial problems of electric vehicles such as range anxiety, but help to reduce overall CO2 emissions by keeping batteries small. In addition, PHEVs can help turning the danger of a technological disruption of the automotive industry into an industrially and socially manageable transition by stabilizing employment rates and strengthening the competiveness of the European automotive industry. Therefore, MAHLE asks to reconsider the ZLEV weighting scheme with a view to setting appropriate incentives for PHEVs. 3. Open path of synthetic fuels for decarbonization As the Commission’s proposal remains a tailpipe regulation, MAHLE misses the regulatory recognition of synthetic fuels as a viable and important path to lowering CO2 emissions. Synthetic fuels can make a crucial contribution to lowering CO2 emissions as they pave the way to a climate-neutral combustion engine. Unfortunately, no incentive is given in the CO2 proposal to push or to invest into the deployment of synthetic fuels. However, crediting synthetic fuels and extending the regulatory perspective beyond tail-pipe emissions would unleash investments into synthetic fuels, thus offering new opportunities in climate protection.
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Response to Vehicle's On-Board Fuel Consumption Measurement device

8 Jan 2018

MAHLE welcomes the opportunity to comment on the draft regulation put forward by the European Commission. 1. Technology neutrality Fuel and energy consumption measurement is currently foreseen for vehicles powered by internal combustion engines and liquid fuels only (including plug-in hybrid vehicles). MAHLE would like to encourage the Commission to go for a truly technology-neutral approach, which would also include an on-board energy measurement in the case of electric vehicles (battery electric and fuel cell electric). Real-world consumption and real-world efficiency should be among the key parameters to be assessed across the wide range of powertrain options. 2. Utility factor of plug-in hybrid vehicles With regard to on-board fuel and energy consumption measurement in the case of plug-in hybrid vehicles, MAHLE would like to stress that the utility factor (currently determined at type approval) is not only dependent on the vehicle and the technologies installed. When measuring real-world consumption it will become obvious that the real-world utility factor is also dependent on the individual driver behaviour, i.e. both on the possibility and readiness to charge the battery regularly. In addition, a high charging frequency (with renewable electricity) is also a climate policy concern. All this should not lead to scepticism towards the potentials of plug-in hybrid vehicles (especially as they are a viable alternative to the CO₂ footprint of large batteries in purely electric vehicles), but to a constructive debate on how vehicle efficiency and boundary conditions (e.g. incentives for easy-to-use inductive charging, driver incentivation for frequent charging, etc.) can go hand in hand.
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Meeting with Christian Linder (Cabinet of Vice-President Maroš Šefčovič) and Shell Companies and

14 Jul 2017 · Presentation and discusson about decarbonisation of transport as well as Europe on the Move and Clean Energy for All Europeans - packages

Meeting with Violeta Bulc (Commissioner) and

11 Jul 2017 · Meeting and visit with MAHLE-Lektrika

Meeting with Jos Delbeke (Director-General Climate Action)

30 May 2017 · Sustainable mobility

Meeting with Günther Oettinger (Commissioner)

30 May 2017 · future of automotive industry

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

24 Apr 2017 · CO2 + increasing electrification