Retrofit Mobility Europe

RME

Founded in 2022, Retrofit Mobility Europe is a professional association gathering public actors and European retrofitters which mission is to: • Ensure the large deployment of battery retrofit solutions, as an efficient way to accelerate decarbonization of mobility at lower cost with local employment. • Favor the sharing of legislative, regulatory, economy, fiscal and technical information on retrofit technologies for all type of vehicles on the European continent. • Promote the implementation of harmonized conditions on the European scale, via series type-approval of retrofitted vehicles. The association represents companies from several European countries. These companies convert all types of vehicles, from two-wheelers to trucks, and commercial vehicles.

Lobbying Activity

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

2 Dec 2025

Retrofit Mobility Europe represents the European community of retrofit industry stakeholders whose activities focus on converting diesel and internal combustion engine vehicles to electric powertrains on an industrial scale. In some EU Member States, retrofitters are already recognised as vehicle manufacturers and authorised to perform series conversions. Retrofitting delivers multiple benefits: Circular economy: By reusing vehicles already in circulation, retrofitting significantly reduces the carbon impact of the vehicle fleet, with greenhouse gas emissions reduced by up to: -61% for light commercial vehicles and -87% for heavy goods vehicles, compared to maintaining existing diesel vehicles; and up to -56% for light commercial vehicles and -37% for heavy goods vehicles (16-19 tonnes) compared to scrapping diesel vehicles and replacing them with new electric models (source: ADEME). Innovation and industrial capacity: Retrofitting stimulates the design, integration, and production of advanced electric componentssuch as battery packs, battery management systems (BMS), and electric motorswithin the European industrial ecosystem. Competitiveness and affordability: Retrofitting offers cost-effective decarbonisation solutions for businesses and citizens, complementing the production and sale of new electric vehicles. This activity therefore constitutes a major technological opportunity for strengthening European sovereignty in electric mobility, while supporting a socially fair and economically viable transition. Retrofit Mobility Europe supports the objective of improving the repairability and reducing the repair costs of electric vehicles set out in this initiative and would like to see it as an opportunity to unlock the full potential of vehicle conversion as a key lever for decarbonising transport. To enable this, the revision should explicitly indicate that retrofitters are part of the independent operators defined in Article 3 of Regulation 2018/858, ensuring their access to the information shared by manufacturers. Currently, ambiguity persists: retrofitters do not perform any of the services performed by independent operators as currently defined, since they replace the original powertrain to convert the vehicle to electric propulsion. Consequently, they risk being excluded from access to critical technical and digital information. A dedicated definition of retrofit activitybuilding on existing national frameworks such as those in place in Belgium, France, and Italycould easily clarify what constitutes a retrofit and who is authorised to perform it. Access to technical information is essential for retrofit operations. Indeed, information on components governing key vehicle functions, including braking systems and advanced driver assistance systems, are essential for retrofitters, who must ensure that the original driving qualities remains unchanged after conversion. As with repair operators, retrofitters currently lack access to this information. Extending such access would enhance transparency, allow the retrofit of a wider range of vehicle models, and significantly accelerate the decarbonisation of European transport. This proposal aligns with the position adopted by the European Parliament on the End-of-Life Vehicle (ELV) Regulation and supports the EUs broader objectives for competitiveness, climate neutrality and a just and fair transition.
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Response to Revision of the CO2 emission standards for cars and vans

9 Oct 2025

Retrofit Mobility Europe brings together retrofit stakeholders in Europe whose activity aims to convert diesel or internal combustion engine vehicles to electric motors on an industrial scale. It should be noted that in some European Union countries, retrofitters carrying out series conversions have the legal status of manufacturers. The retrofitting activity has many advantages in terms of: 1/ Circular economy, through the reuse of vehicles already in circulation and with a very low carbon impact (up to 56% reduction in GHG emissions compared to scrapping diesel vehicles/replacing with new electric vehicles for the light commercial vehicle category - Source: ADEME); 2/ Innovation and industrial production, through the design (battery pack, BMS, electric motor, etc.) and integration of electric powertrains and their production on the European continent; 3/ Competitiveness, through the placing on the market of cost-competitive transport decarbonisation solutions for European businesses and citizens. The retrofitting activity, which complements the production and sale of new electric vehicles, represents a major technological advance that will strengthen European sovereignty in the field of electric powertrains, as part of an economically viable and socially equitable transition. As part of this public consultation, RME wishes to raise certain issues currently posed by the CO2 regulation: 1/ The regulation only considers vehicles that are registered in the Union for the first time and which have not previously been registered outside the Union. Thereby, retrofitted vehicles, which by their nature have already been registered, cannot be included in the CO2 Regulation, both for passenger cars and light commercial vehicles. The scope of the regulation would therefore need to be amended to allow the inclusion of vehicles that have already been registered AND converted to electric power. 2/ The regulation excludes manufacturers and retrofitters 'which, together with all of its connected undertakings, is responsible for fewer than 1 000 new passenger cars or for fewer than 1 000 new light commercial vehicles registered in the Union in the previous calendar year, unless that manufacturer applies for and is granted a derogation in accordance with Article 10.' Retrofitting represents a significant potential market for decarbonisation across many vehicle segments. It would be beneficial that retrofitters be covered by the CO2 regulation without any minimum production obligation, at least for a defined period. 3/ For the calculation of carbon emissions, particularly for manufacturers, the regulation refers to the type approval of vehicles. For retrofitters, conversion to electric motorisation should count as zero emissions without reference to the type approval of the vehicle (NEDC). 4/ The regulation opens up the possibility of creating groups of connected manufacturers. Retrofitters should be able to join groups of connected manufacturers, given that these electrified vehicles, which are zero-emission vehicles, are being placed on the European market. It should be noted that Article 10 of the Regulation excludes manufacturers producing fewer than 1 000 new passenger cars or fewer than 1 000 new light commercial vehicles from manufacturer groups. This point, specifically for retrofitters, would also need to be adapted. 5/ The regulation does not provide for any bonus linked to retrofitting. RME proposes the introduction of a multiplier coefficient of 1.5 to account for the significant reduction in carbon emissions over the entire life cycle of retrofitted vehicles. Retrofit Mobility Europe is therefore calling for electric retrofitting to be fully integrated into the future CO regulation, both as a business activity and in terms of the conversions they carry out.
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Meeting with Helena Hinto (Cabinet of Commissioner Apostolos Tzitzikostas), Simone Ritzek-Seidl (Cabinet of Commissioner Apostolos Tzitzikostas)

5 Feb 2025 · Exchange of views on automotive sector

Response to Single Market Strategy 2025

31 Jan 2025

Retrofit Mobility Europe (RME), the professional association gathering public actors and European retrofitters, welcomes the Commissions consultation on the Single Market Strategy 2025. Retrofitting vehicles (namely converting an internal combustion engine/vehicle into a zero-emission one) would allow the European union to reach several of its key objectives, such as reindustrialisation, decarbonation and competitive circular economy. Yet, as of today, the European market uptake of retrofitted vehicles is hampered by the lack of harmonised technical and administrative rules for their approval. There are two main obstacles: Lack of, or diverging, national regulatory frameworks, which are based on isolated type-approval, except in Italy and France. Questions regarding subsidiarity and legal basis: European type-approval only applies to new vehicles. The EU regulatory framework is therefore ill-suited for retrofitting. It prevents the development of a mass market and companies to scale up. To enable retrofitting at industrial scale, RME argues it is crucial to harmonise the type-approval rules for vehicles with internal combustion engine converted to battery/fuel cell electric drive, in order to allow for series approval. The Single Market Strategy is a formidable opportunity to address this issue and support more uniform rules. You will find attached a detailed Position paper.
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