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Robert Bosch GmbH

Robert Bosch GmbH is a leading global provider of technology and services.

Lobbying Activity

Meeting with Lucia Granelli (Head of Unit Taxation and Customs Union), Maria Isabel Garcia Catalan (Head of Unit Taxation and Customs Union)

15 Jan 2026 · Follow-up meeting on local content

Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

13 Jan 2026 · The Industrial Accelerator Act, the Chips Act and State aid rules

Meeting with Bernd Biervert (Cabinet of Commissioner Maroš Šefčovič), Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič), Dārta Tentere (Cabinet of Commissioner Maroš Šefčovič) and

13 Jan 2026 · Trade agenda and competitiveness of the semiconductor industry in Europe

Meeting with Michael Hager (Cabinet of Commissioner Valdis Dombrovskis)

17 Dec 2025 · Simplification in the Automotive Sector

Meeting with Eva Schultz (Cabinet of Executive Vice-President Roxana Mînzatu) and ZF Friedrichshafen AG and

11 Dec 2025 · Franco-German-Italian-Polish Automotive Suppliers on the Automotive Package

Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič) and ZF Friedrichshafen AG and

9 Dec 2025 · Discussion on EU automotive industry, competitiveness, CO₂ targets, and regulatory frameworks.

Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall)

3 Dec 2025 · Current state of the European bicycle industry and batteries-related topics

Bosch Urges EU to Complete Semiconductor Strategy Beyond Current Pillars

26 Nov 2025
Topic — Strengthening Europe's semiconductor ecosystem and achieving 20% market share goal.
Message — Bosch requests greater industry voting rights in governance, tax incentives for manufacturing investments, and elimination of labeling procedures they view as administrative burden. They advocate for a broader strategy including demand generation, public procurement preferences, and cost compensation to equalize European manufacturing disadvantages.1234
Why — This would reduce their compliance costs and provide operational subsidies to offset higher European manufacturing expenses.567
Impact — Taxpayers fund operational subsidies while transparency mechanisms for crisis supply obligations are weakened.89
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Meeting with Matthias Petschke (Director Taxation and Customs Union)

26 Nov 2025 · Online meeting - Exchange of views on the local content and on the rules for the determination of non-preferential origin in the automotive sector.

Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra) and ZF Friedrichshafen AG and

19 Nov 2025 · CO2 standards for cars and vans and automotive package

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 Matthias Ecke (Member of the European Parliament) and ZF Friedrichshafen AG and Industriegewerkschaft Metall

28 Oct 2025 · Betriebsräte Zulieferer Automobilsektor BW

Meeting with Jens Gieseke (Member of the European Parliament) and ZF Friedrichshafen AG and

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

Meeting with René Repasi (Member of the European Parliament) and ZF Friedrichshafen AG and

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

Meeting with Pauline Weinzierl (Head of Unit Trade) and European Association Automotive Suppliers and

29 Sept 2025 · Exchange on issues related to the current trade context

Bosch Urges Simplification of Burdensome CBAM Emission Rules

25 Sept 2025
Topic — This initiative defines methodology for calculating embedded emissions during the CBAM definitive period.
Message — Bosch requests the unrestricted use of default values for all imports to reduce complexity. They also propose a 100 kg shipment threshold to exempt small quantities from reporting requirements.12
Why — This would significantly reduce the high administrative costs of tracking complex supplier data.34
Impact — Environmental transparency is compromised if companies bypass reporting for individual production facilities.5
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Bosch warns of impossible CBAM timelines, demands streamlined reporting

25 Sept 2025
Topic — Rules for converting foreign carbon prices into EU carbon border certificates.
Message — Bosch requests immediate clarity on reporting rules and the unrestricted use of default values for imports. They also propose a 100 kg exemption threshold to minimize the immense administrative burden.12
Why — These measures would reduce the company's technical compliance costs and simplify data acquisition.34
Impact — Environmental integrity may suffer if default values are used instead of actual emissions data.5
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Meeting with Nils Behrndt (Deputy Secretary-General Secretariat-General) and ZF Friedrichshafen AG and MAHLE International GmbH

25 Sept 2025 · Regulatory framework, climate targets

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné), Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and

23 Sept 2025 · Competitiveness of EU automotive suppliers

Meeting with Stéphane Séjourné (Executive Vice-President) and

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

Bosch Urges Incentives Over Mandatory Corporate Fleet Quotas

8 Sept 2025
Topic — EU consultation on increasing zero-emission vehicle uptake in corporate automotive fleets.
Message — Bosch recommends using fiscal incentives instead of mandatory quotas to decarbonize fleets. They call for a broad technology definition including hydrogen and renewable fuels.12
Why — This would reduce compliance costs and protect Bosch from rising leasing fees.34
Impact — Logistics operators would suffer from high administrative overhead due to complex exemption systems.5
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Meeting with Stéphane Séjourné (Executive Vice-President) and

5 Sept 2025 · - Compétitivité des entreprises - Marché intérieur - Protection de la souveraineté et du pouvoir d’achat - Relation US/EU

Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra) and FuelsEurope and

1 Sept 2025 · Heavy-duty sector and the role of carbon-neutral fuels

Meeting with Kurt Vandenberghe (Director-General Climate Action)

14 Jul 2025 · Upcoming reviews of the CO2 Standards for passenger cars and HDV, the upcoming review of the CBAM as well as ETS2.

Meeting with Valdis Dombrovskis (Commissioner) and

14 Jul 2025 · Omnibus

Meeting with Andrea Wechsler (Member of the European Parliament)

14 Jul 2025 · EU Energy and industry policy

Meeting with Thomas Skordas (Deputy Director-General Communications Networks, Content and Technology) and

11 Jul 2025 · Exchange on enabling scalable AI robotics through end-user leadership in industry.

Bosch urges EU to scrap mandatory audits for unsold goods

10 Jul 2025
Topic — New EU rules requiring companies to disclose information regarding the disposal of unsold products.
Message — Bosch argues against mandatory third-party audits and requests that spare parts be excluded from reporting. They also support a one-year delay to set up internal reporting systems.12
Why — Avoiding external auditing would lower operational expenses and simplify internal reporting processes.3
Impact — Regulatory transparency is reduced as the public loses independent verification of corporate waste data.4
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Meeting with Anna Panagopoulou (Cabinet of Commissioner Apostolos Tzitzikostas), Simone Ritzek-Seidl (Cabinet of Commissioner Apostolos Tzitzikostas) and

10 Jul 2025 · Exchange of views on e-fuels and monitoring methodology.

Bosch urges EU to simplify Innovation Fund application process

4 Jul 2025
Topic — A review evaluating the operational efficiency and effectiveness of the EU Innovation Fund.
Message — Bosch requests streamlining application documents and expanding the technology list to include software and AI. They advocate for user-friendly online tools to manage complex emission and financial calculations.123
Why — Faster application processing and lower administrative costs would improve access to funding.45
Impact — Specialized consultants might lose business if application tools become accessible enough for internal use.6
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Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné), Hanna Anttilainen (Cabinet of Executive Vice-President Stéphane Séjourné) and

3 Jul 2025 · Presentation of ESIA and the semiconductor industry in Europe

Meeting with Joachim Luecking (Head of Unit Mobility and Transport) and Deutsche Bahn AG

24 Jun 2025 · Presentation of Bosch – DB technology development “Perception” for autonomous driving trains and its regulatory challenges

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

17 Jun 2025 · Competitiveness of automotive suppliers in international context

Meeting with Simone Ritzek-Seidl (Cabinet of Commissioner Apostolos Tzitzikostas) and MAHLE International GmbH

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

Response to Cyber Security Requirements for L-category vehicles

2 Jun 2025

Bosch welcomes the proposal of the European Commission to establish the applicability of UNECE R155 to L-category vehicles with the exception of L1e category vehicles designed to pedal (including S-EPACs) within the type approval regulation and to clarify the scope of the CRA accordingly. The proposals are a good compromise between the interests of the motorcycle industry, aiming at treating motorcycles and other two-, three- and four-wheelers in the L-category like cars from a cybersecurity point of view, and the interests of the bicycle industry, ensuring uniform cybersecurity requirements for non-type approved EPACs and type approved S-EPACs. Therefore, Bosch supports the proposals by the Commission, specifically to: exclude L1e category vehicles designed to pedal from the applicability of UNECE R155 via Delegated Regulation (EU) 44/2014 , and leave L1e category vehicles designed to pedal within the scope of the CRA , while excluding other L-category vehicles from the CRA and specifically refer to UNECE R155 in according type approval regulation. Bosch recommends to clarify the wording of the exemption from the CRA for L-category vehicles except L1e category vehicles designed to pedal to include functional parts of the L-category vehicles and to make the exemption explicitly visible in Article 2(2) of the CRA. Please find additional arguments in the attached document. We would like to thank the Commission for considering our position.
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Response to Exclusion of L-category vehicles from scope of the Cyber Resilience Act

2 Jun 2025

Bosch welcomes the proposal of the European Commission to establish the applicability of UNECE R155 to L-category vehicles with the exception of L1e category vehicles designed to pedal (including S-EPACs) within the type approval regulation and to clarify the scope of the CRA accordingly. The proposals are a good compromise between the interests of the motorcycle industry, aiming at treating motorcycles and other two-, three- and four-wheelers in the L-category like cars from a cybersecurity point of view, and the interests of the bicycle industry, ensuring uniform cybersecurity requirements for non-type approved EPACs and type approved S-EPACs. Therefore, Bosch supports the proposals by the Commission, specifically to: exclude L1e category vehicles designed to pedal from the applicability of UNECE R155 via Delegated Regulation (EU) 44/2014 , and leave L1e category vehicles designed to pedal within the scope of the CRA , while excluding other L-category vehicles from the CRA and specifically refer to UNECE R155 in according type approval regulation. Bosch recommends to clarify the wording of the exemption from the CRA for L-category vehicles except L1e category vehicles designed to pedal to include functional parts of the L-category vehicles and to make the exemption explicitly visible in Article 2(2) of the CRA. Please find additional arguments in the attached document. We would like to thank the Commission for considering our position.
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Response to Quantum Strategy of the EU

2 Jun 2025

Bosch strongly endorses the Recommendations from the European Quantum Industry Consortium (QuIC) for the EU Quantum Strategy. Beyond these critical recommendations, we wish to emphasize the following points, crucial for ensuring Europe's leadership in the quantum technology field: 1. Quantum computing: algorithms and software 1.1. European industries possess significant potential for applications of quantum computing. These applications could substantially advance their businesses. Fostering Europe's QC applications, algorithms, and software industry is important. It has the potential to become a significant competitive advantage for Europe. 1.2. While investments in QC hardware are important for reducing critical dependencies on non-European regions, Europe must ensure that sufficient attention is given to our QC applications, algorithms, and software industry. 1.3. Europe needs a complete and competitive QC software stack. However, it may not be necessary to invest in components that are not essential for competition and are available as Open Source Software. Resources should be allocated strategically, avoiding the duplication of existing efforts. 2. Quantum sensing 2.1. Europe must support the industrialization of the current mid- to high-TRL quantum sensors. Industrialization typically requires more capital than R&D. Bringing beneficial products to the market as soon as possible could demonstrate the potential of quantum technologies and contribute to the advancement of the field. 2.2 While fostering the industrialization of mid- to high-TRL quantum sensors, it is also necessary to ensure the technology pipeline for future quantum sensors is filled. This can be achieved by investing in new quantum sensing technologies, which are still in the research domain. 2.3. Europe must drive the industrialisation and market uptake of quantum sensors by establishing an EU-wide strategy for research, commercialisation, and deployment of quantum sensors in key sectors, including healthcare, mobility, manufacturing, aerospace, climate monitoring, space and others. 3. Critical components 3.1. Strengthening Europes quantum supply chain is essential to reduce dependence on non-EU suppliers. We must assess critical components and make sure these are available in quality and quantity necessary for commercialization for European QT companies.
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Meeting with Eszter Lakos (Member of the European Parliament)

15 May 2025 · Automotive industry

Meeting with Tiemo Wölken (Member of the European Parliament)

28 Apr 2025 · CBAM Implementation (Staff level)

Meeting with Pierre Chastanet (Head of Unit Communications Networks, Content and Technology) and Infineon Technologies AG and

15 Apr 2025 · Implementation of the Automotive Industrial Action Plan with : - NXP - Infineon - STMicroelectronics - Bosch - Axelera AI

Meeting with René Repasi (Member of the European Parliament)

10 Apr 2025 · Bosch Insights Automotive Action Plan

Meeting with Stéphane Séjourné (Executive Vice-President) and

10 Apr 2025 · Impact of US tariffs

Meeting with Henna Virkkunen (Executive Vice-President) and

3 Apr 2025 · The European semiconductor industry and the review of the Chips Act

Meeting with Denis Redonnet (Deputy Director-General Trade) and Infineon Technologies AG and

3 Apr 2025 · Exchange on the implications of recent US trade measures and the broader geopolitical environment on the European semiconductor industry

Meeting with Bernd Biervert (Cabinet of Commissioner Maroš Šefčovič), Dārta Tentere (Cabinet of Commissioner Maroš Šefčovič) and

3 Apr 2025 · Trade relations and economic security

Meeting with Pierre Chastanet (Head of Unit Communications Networks, Content and Technology) and Infineon Technologies AG and

24 Mar 2025 · Automotive Industrial Action Plan with : - NXP - Infineon - STMicroelectronics - Bosch

Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

Bosch welcomes the Net Zero Industry Act (NZIA) that supports EU competitiveness in clean technologies, which is urgently needed. A comprehensive supply chain approach will be an important step towards enhancing the EUs domestic manufacturing of key technologies. The NZIA is based on a strict, predetermined set of technologies already excluding certain technologies from the start and establishes specific criteria for the eligible components. The proposed list of components is being overly restrictive in its scope, as it only incorporates specific components that can solely be used for a net-zero technology, whereas components that are part of not only net-zero technologies but also of several other ones do not qualify. While it is true that other specific components may fall within the scope of the NZIA if project promoters can prove that the components not listed are primarily used for the production of net-zero technologies such a method creates legal uncertainty and can entail a high administrative burden for project promoters. Both the exclusion of certain technologies and in particular the strict criteria defining specific components may lead to suboptimal outcomes, preventing the manufacturing of technologies that provide a significant contribution to Europes net-zero economy. Any possible extension of the list of net-zero technologies in accordance with the evaluation foreseen in 2028 may come too late to take into account important technological developments. Instead, an approach open to all current and future technologies that contribute to decarbonisation and increase competitiveness of the EUs industry would be much more sensible, avoiding the exclusion of future or emerging key technologies. Additionally, it is crucial that the annex explicitly addresses the essential granular components required for the up-take of net-zero technologies. The NZIA should take into account the complex industrial ecosystem of key technologies. In the current version of the delegated act, however, the NZIA does not do justice to this fact. The stronger consideration of such an entire ecosystem would also allow for a more dynamic response to future supply chain crises and be beneficial for Europes technological sovereignty. For this reason, it is crucial that the annex goes beyond its current classifying approach, and incorporates components deemed essential, even if they are not primarily used exclusively for the deployment of net-zero technologies. These components are vital for the functionality and efficiency of net zero technologies, but, more importantly, they are pivotal for establishing a well-structured European net-zero ecosystem. Below you will find some examples of key technologies and components that are essential for net-zero technologies and must be included in the final list. A more comprehensive list is provided in the attachment. 1) Acknowledge the role of the hydrogen combustion engine: The hydrogen engine is an important net-zero technology, especially for heavy-duty vehicles (HDVs), where alternatives are limited. Its role is confirmed by the current legislation on CO2 standards for HDVs, which recognises the hydrogen engine as zero-emission technology alongside the battery-electric and fuel cell powertrains. Europe's expertise in combustion engine technology enables a cost-effective transition by repurposing current facilities and leveraging skilled workforces, thereby reducing disruption. 2) Semiconductors are key components of net-zero technologies: Semiconductors are fundamental to the deployment of net-zero technologies. The increasing demand for e.g. wind and solar plants, electric vehicles is heavily reliant on semiconductors. These components are not just enablers but are indispensable for key transformative solutions. A strict classification approach risks overlooking semiconductors cross-sectoral importance, despite their essential role in multiple net-zero applications.
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Meeting with Stéphane Séjourné (Executive Vice-President) and

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

Meeting with Svenja Hahn (Member of the European Parliament) and Microsoft Corporation and

14 Feb 2025 · Exchange on upcoming digital EU legislation

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and ZF Friedrichshafen AG and

12 Feb 2025 · Future of the automotive sector

Meeting with Aurel Ciobanu-Dordea (Director Environment)

28 Jan 2025 · Exchange on Circular Economy Act

Meeting with Hildegard Bentele (Member of the European Parliament)

23 Jan 2025 · Industry Policy

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) and Mercedes-Benz Group AG and MAHLE International GmbH

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

Response to Standards for wireless recharging, electric road system and vehicle-to grid-communication of recharging infrastructure

30 Dec 2024

We appreciate the opportunity to provide feedback on the draft delegated regulation supporting the Regulation (EU) 2023/1804 (AFIR), specifically regarding its application to L- category vehicles. Legislators appear to have treated L-category vehicles as a homogeneous group when including them in the AFIR. We would like to emphasize that this category actually comprises a very diverse range of vehicles, from assisted cycles to motorcycles and heavy quadri-mobiles. It is crucial to acknowledge and address the distinct charging needs of these different L-vehicle categories when developing charging infrastructure regulations and standards. The L1 category, specifically the L1e-B subcategory also include pedal-assisted cycles, so called Speed EPACs. Speed EPACs share more similarities with electrically power assisted cycles (EPACs), which are exempt from L-category type approval, than they do with motorcycles, which are within the L-category. The requirements for recharging points for L-category electric vehicles in 1.3.3 should not apply to recharging points primarily intended for electrically power assisted cycles, including S-EPACs (L1e-B category). Applying these requirements would create unnecessarily overbuilt structures and hamper the roll-out of (S-)EPAC specific charging infrastructure. If new, more specific technical specifications for charging sockets are considered for L-category vehicles with a power output of less than or equal to 3.7 kW, it is important to understand these changes could significantly affect the vehicles' electrical systems. A detailed impact assessment is needed beforehand to ensure that any new charging specifications are both safe and compatible. Motorcycles require significantly high power charging solutions due to their larger battery capacities and longer ranges. These vehicles may benefit from dedicated charging stations with higher power outputs, similar to those used for electric cars, to enable faster charging and support their longer-distance travel requirements. For more specific comments see the document attached.
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Response to Digital Product Passport (DPP) service providers

10 Dec 2024

- The delegated act is welcomed as further clarity on the role of digital product passport service providers (DPPSP) is needed for legal certainty of affected economic operators. Requirements set out in Art. 10 and Art. 27 of the ESPR must be unambiguously speci-fied through secondary legislation to warrant harmonized implementation in the Internal Market. - Particularly, the obligation for manufacturers, in accordance with Art. 27 (1) point c to include a back-up copy of the most up-to-date version of the DPP stored by a DPPSP must be further elaborated. As established in the ESPR, the DPP, for intellec-tual property and data safety reasons, banks on a decentral operation in which econom-ic operators are fully responsible for sharing (potentially sensitive) corporate or product-specific data. Accordingly, data management and access control must be controlled solely by the economic operator itself. The delegated act should therefore clarify that ex-ternal DPPSP may only manage and control DPP data in case of absence of an eco-nomic operator (e.g., if a company is no longer operational or active in the market while its products still are). In this case, the back-up provider should be required to provide the last status of the DPP before the economic operator ceases to exist. It must be prevent-ed that external providers receive full access to internal data management systems. - Since there is no reference case in product regulation, details on the provision of a back-up copy and most up-to-date version of the DPP (Art. 10 (4), Art. 27 (1) point c) are crucial to prevent any potential misinterpretation that a second, identical DPP must be operated by a DPPSP simultaneously in addition to the DPP already established by the economic operator placing the product on the market. The delegated act should help to clearly outline the intersection and distinction between the economic operator respon-sible for the DPP and the DPPSP. In the same context, Art. 2 (32) ESPR, defines an DPPSP as an independent third-party authorised by the economic operator which plac-es the product on the market. A common understanding of independent third-party is needed. In line with the ESPR, DPPs should be based on a decentralised data system and be set up and managed by economic operators. (Recital 41). This fundamental principle must not be counteracted by ambiguous rules on DPPSP. - There are no product-specific information requirements (i.e. data to be incorporated in the DPP) established yet. These requirements will be determined through corresponding delegated acts tailored to the product groups regulated under the ESPR in the future. It should be noted that any potential dynamic information will increase the burden of im-plementation for economic operators if this data must be continuously backed up and updated in any form outside the actual DPP. Again here, data security and intellectual property concerns must be thoroughly considered. - It must furthermore be ensured that industry involvement is guaranteed and respective technical expertise is considered in developing further DPP requirements, both with re-gard to horizontal DPP requirements (e.g. on the DPP registry, data carriers) and prod-uct-specific delegated acts.
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

20 Nov 2024 · Exchange on mobility operations

Meeting with Christine Singer (Member of the European Parliament) and EEW Energy from Waste GmbH

19 Nov 2024 · Austausch neue Legislaturperiode

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

19 Nov 2024 · Discussion on energy during Electrolysers Summit

Meeting with Peter Liese (Member of the European Parliament) and ZF Friedrichshafen AG and EW GROUP GmbH

13 Nov 2024 · Austausch

Bosch calls for flexible rules to boost low-carbon hydrogen

24 Oct 2024
Topic — Establishing a greenhouse gas emissions savings methodology for certifying low-carbon fuels.
Message — Bosch requests practicable criteria for production, including a review to ease additionality rules. They seek the possibility to claim specific electricity values and better supplier data verification.123
Why — These changes would accelerate hydrogen production while protecting the company from greenwashing risks.45
Impact — Environmental integrity may suffer if strict methane default values are removed to boost availability.6
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Meeting with Jens Geier (Member of the European Parliament)

24 Sept 2024 · EU Industrial Policy and competitiveness

Meeting with Markus Ferber (Member of the European Parliament)

11 Sept 2024 · Implementation of the Green Deal

Meeting with Andrea Wechsler (Member of the European Parliament) and Bundesverband der Deutschen Industrie e.V. and MARKENVERBAND

11 Sept 2024 · EU Energy and Industry Policy

Meeting with Christian Ehler (Member of the European Parliament)

6 Aug 2024 · European research policy

Bosch calls for four-year transition to phase out flame retardant

23 Jul 2024
Topic — This consultation concerns restricting dechlorane plus under the EU’s persistent organic pollutants regulation.
Message — Bosch requests that the EU change the proposed transition period to a minimum of four years. They urge regulators to allow the industry to choose feasible alternative solutions.12
Why — A longer transition period helps Bosch avoid supply chain disruptions and product certification delays.3
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Bosch Urges EU to Maintain Motor Vehicle Competition Rules

24 Jun 2024
Topic — Evaluation of competition rules governing agreements in the motor vehicle sector.
Message — Bosch insists motor vehicle competition rules must be upheld. The regulation should be updated for electrification and cybersecurity.12
Why — A stable legal framework allows Bosch to sell its full product range.3
Impact — Car manufacturers lose the power to lock out independent repair businesses.4
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Meeting with Kurt Vandenberghe (Director-General Climate Action) and ZF Friedrichshafen AG and MAHLE International GmbH

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

Bosch demands tailored carbon footprint methodology for hybrid batteries

28 May 2024
Topic — The Commission is defining how to calculate the lifecycle carbon footprint of batteries.
Message — Bosch requests specific criteria for hybrid batteries and a market-based method for energy. They also propose tighter review intervals and a list of high-impact materials.123
Why — Market-based accounting would let Bosch benefit from its investments in renewable energy contracts.45
Impact — Suppliers of precious metals lose the ability to hide high emissions under mass-based limits.67
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Meeting with Jens Gieseke (Member of the European Parliament, Shadow rapporteur)

21 Feb 2024 · Umweltpolitik

Meeting with Marion Walsmann (Member of the European Parliament, Rapporteur) and Volkswagen Aktiengesellschaft and

29 Nov 2023 · Standard Essential Patents

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

24 Oct 2023 · Verkehrs- Umwelt und Wirtschaftspolitik

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

18 Oct 2023 · Automotive industry: CO2 regulation for HDV and the interaction with AFIR, Euro 7 and possible regulation of access to vehicle data

Meeting with Michael Bloss (Member of the European Parliament)

18 Sept 2023 · Industrietransformation

Meeting with Ditte Juul-Joergensen (Director-General Energy) and BASF SE and

29 Aug 2023 · Energy transition and security

Bosch calls for delay in EU carbon border adjustment reporting

10 Jul 2023
Topic — EU regulation implementing carbon border adjustment mechanism reporting requirements during transitional period.
Message — The company requests postponing the October 2023 deadline and reducing over 100 mandatory data fields. They argue the requirements create immense administrative burden and crucial specifications are missing. They recommend allowing default values without restrictions and providing operational IT systems urgently.123456
Why — This would reduce compliance costs and give suppliers more time to provide standardized data.789
Impact — Environmental advocates lose detailed emissions tracking that ensures accurate carbon border pricing.1011
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Meeting with Jens Gieseke (Member of the European Parliament, Shadow rapporteur)

28 Jun 2023 · Verkehrspolitik

Response to European Critical Raw Materials Act

26 Jun 2023

Bosch highly welcomes that the EU is taking action to secure the supply of critical raw materials for industry. Copper should not be classified as a SRM. It is a base metal that is widely available from different sources and traded on functioning, transparent international markets. Treating Copper as a SRM would lead to a wrong focus of efforts (e.g., for recycling, supply chain stress tests). Company Supply Chain Audit Making supply chains more resilient is a high priority for companies. Introducing an additional mandatory external SRM supply chain audit would not contribute to mitigating these risks but cause additional administrative burdens and costs for companies. This is especially relevant if audits would be mandatory also for exchange traded materials like Copper. Imposing the requirement for a SRM supply chain analysis on companies producing certain strategic technologies is not meaningful. When only large companies manufacturing strategic products are required to investigate their supply chains, but their suppliers are not, the investigation will not be successful. Analysis and stress test requirements should focus on importers of SRM since only they can create the necessary transparency with meaningful effort (similar to the Conflict Minerals Regulation). All information on dependencies and stress test results must not be disclosed to third parties since it could reveal weaknesses and put companies in a disadvantageous position for purchasing SRMs. Permanent Magnet Recycling Establishing large-scale recycling of permanent magnets in the EU is the right approach and much needed to secure the supply in the long term. The requirements for products containing permanent magnets should strike the right balance between effectively advancing this important goal and not creating unnecessary administrative burdens for companies. Low-grade ferrite magnets that include less than 0.5% Cobalt should be excluded from the recyclability requirements since they are widely available and their recycling is often not economically meaningful. A labelling of products should only be required when products contain magnets, and not in cases where they do not. Such negative labelling would create an additional burden for companies but not offer meaningful benefits in the recycling process. Detailed information on the location of magnets in the product, their composition, and dismantling instructions should only be accessible for recyclers (favorably via the digital product passport) and not for consumers or other companies since it might allow conclusions on confidential product design. Product manufacturers should not be required to provide detailed information on dismantling processes and tools. Dismantlers have the specific know-how and often their own techniques, tools, and processes so that describing one way of how to dismantle a product might not even be useful to them, while creating immense efforts for manufacturers. Harmonization with other upcoming regulations that introduce circularity requirements such as the Ecodesign for Sustainable Products Regulation (ESPR) and the End-of-Life Vehicles Regulation (ELV) needs to be ensured. ESPR and ELV provisions should take precedent over the CRMA. The definition of recycled content should include post-consumer waste and manufacturing waste, i.e. the materials rejected during the manufacturing process, which cannot be re-used as an integral part in the same process and need to be recycled. This will accelerate the development of the necessary recycling infrastructure and a functioning EU circular economy for permanent magnets. When introducing minimum shares of recycled content of REE in permanent magnets implementation periods that take the length of production cycles into account (at least 5 years) are crucial. Implementing changes in running series production is a huge effort (requires changing supply contracts, redo testing, new customer approval).
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Meeting with Anna Deparnay-Grunenberg (Member of the European Parliament)

21 Jun 2023 · Fahrradindustrie

Meeting with Nicola Beer (Member of the European Parliament, Rapporteur)

31 May 2023 · Critical Raw Materials Act (Meeting held by parliamentary assistant)

Meeting with Kathleen Van Brempt (Member of the European Parliament, Shadow rapporteur)

4 May 2023 · Euro 7

Bosch Welcomes Recognition of Sustainable Automotive Component Manufacturing

3 May 2023
Topic — This consultation establishes a classification for environmentally sustainable investments in mobility sectors.
Message — Bosch requests the inclusion of heavy-duty vehicles and removal of end-use tracking requirements. They also suggest aligning chemical regulations to prevent double regulation.123
Why — This recognition improves taxonomy usability and secures investments in their green technologies.45
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Meeting with Margrethe Vestager (Executive Vice-President) and

25 Apr 2023 · Chips Act, State Aid

Meeting with Ditte Juul-Joergensen (Director-General Energy)

17 Apr 2023 · Energy market

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

8 Mar 2023 · Austausch zur Europapolitik

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

8 Mar 2023 · Dr Heyn wanted to present their priorities on Euro 7.

Bosch warns Euro 7 timeline unmanageable, urges implementation delay

9 Feb 2023
Topic — This consultation develops stricter Euro 7 emission standards for combustion-engine cars, vans, and heavy-duty vehicles.
Message — Bosch requests delaying new pollutant limits until mid-2026 for cars and mid-2027 for light commercial vehicles. They urge the Commission to clarify technical details and driving test conditions to ensure feasibility.123
Why — A delayed timeline avoids significant vehicle supply shortages and prevents excessive development costs for manufacturers.45
Impact — Citizens and environmental groups lose immediate air quality benefits because of the requested implementation delays.6
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Meeting with René Repasi (Member of the European Parliament, Rapporteur for opinion)

2 Feb 2023 · EU-Lieferkettengesetz/ Corporate Sustainability Due Diligence Directive (CSDDD) - Staff Level

Meeting with Karen Melchior (Member of the European Parliament)

2 Feb 2023 · Discussion and exchange of experience with German legislation, regarding compliance multipli-tier challenges in huge companies in the CSDDD

Meeting with Florika Fink-Hooijer (Director-General Environment)

6 Dec 2022 · Revision of the F-gas regulation

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

11 Nov 2022 · Taxonomy

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

14 Oct 2022 · ETS

Meeting with Christiane Canenbley (Cabinet of Executive Vice-President Margrethe Vestager), Pierre-Arnaud Proux (Cabinet of Executive Vice-President Margrethe Vestager), Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

12 Oct 2022 · EU digital policy

Meeting with René Repasi (Member of the European Parliament)

12 Oct 2022 · Diskussionsrunde und Mittagessen; Ökologische und digitale Tranformation

Meeting with Bernd Lange (Member of the European Parliament, Committee chair)

12 Oct 2022 · General exchange of views

Meeting with Jens Geier (Member of the European Parliament)

12 Oct 2022 · Fit For 55

Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur) and RENAULT and

11 Oct 2022 · Data Act

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

29 Sept 2022

Bosch welcomes the Commission’s proposal to extend the MVBER until 2028 and agrees with the importance of access to in-vehicle generated data. Please see our more detailed feedback in attachment.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

12 Jul 2022 · Stratégie industrielle, REPowerEU

Bosch: Strict gas rules could stall heat pump rollout

28 Jun 2022
Topic — The EU is reviewing regulations to further reduce emissions from fluorinated greenhouse gases.
Message — Bosch requests targeted exemptions for larger units and a slower transition to natural refrigerants. They advocate maintaining current phase-down timelines to reflect market realities.12
Why — This avoids costly system redesigns and protects existing investments in current heat pump technologies.3
Impact — Environmental groups lose because high-warming greenhouse gases would remain in circulation for longer.4
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Response to European chips act package – Regulation

6 May 2022

Bosch welcomes the EU Chips Act and its ambitious target of increasing Europe’s share of global chips manufacturing to 20% by 2030 as well as its contribution to the success of the twin transition of the European industry, which relies on an innovative and resilient supply of mature and advanced chips for future growth. In the following we would like to provide some recommendations on the current draft: Pillar I: Chips for Europe Initiative • Ensure that EU funding matches the ambitious targets: Industry estimates that the 20% increase in production target requires a total investment of €200 to €600 bn, together with an increase of European chips manufacturing output by a factor of 5 (IHS Markit; VDA Project team). Sustainable growth in market share will naturally also require a commensurate growth in R&D efforts. Thus, additional funding sources need to be identified, in line with the principle that newly created legislative initiatives must come with additional financial resources rather than reallocating funding from other important R&I programs. • Virtual design platform and pilot lines should match industry needs: Industry has to be closely involved in shaping the definition, functioning and access to virtual design platforms and pilot lines to ensure that they align well with industry needs. Pillar II: Security of Supply • First-of-a-kind Facilities should be defined broadly to target all state-of-the-art semiconductors: The focus on 2 nm advanced chips needs to be adjusted in order to guarantee a sufficient level of innovation within the EU chip manufacturing industry. The EU’s semiconductor industry will benefit more from mature chips that, for example, constitute around 95% of future demand within the automotive sector (IHS Markit ; VDA Project team ) . There is a high innovation level centered around mature chips and this is also where most of the manufacturing capacity expansion targeted by the Chips Act will originate from. Focusing on more mature chips the Chips Act’s ambitions would better match the actual chips market demands and dynamics. • Reduce uncertainty around First-of-a-kind Facilities: The funding gap will have to be closed by private sector investments. Any uncertainty with regard to classifications, eligibility criteria, procedures and timelines surrounding First-of-a-kind Facilities will hamper private sector investments. Also, funding rules and the framework conditions in which funding is possible need to be clear and consistent. To achieve the market share target of 20% it will not be sufficient to build “first” facilities, but the massive replication of capacity will be necessary. Pillar III: Monitoring and Crisis Response • Engage stakeholders in a collaborative way: The proposed mechanisms are far-reaching and have the potential to affect the business integrity of semiconductor manufacturers and other actors in the European value chain. Therefore, a collaborative mechanism which respects the needs of industry has to be created. Governance • Involve industry in the Semiconductor Board: The governing board will play a crucial role in defining guidelines for the semiconductor landscape. Thus, industry should be closely involved in both governing body and subgroups. • Any unnecessary complexity in governance structures should be avoided: The governance structure of the Chips Act should create a clear and productive environment. Confidentiality • Industry data confidentiality needs to be a key element and rigorously ensured: We consider it a crucial matter that the Commission guarantees protection of highly sensitive company information.
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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.

Bosch Urges Technology Neutrality and Realistic Truck Emission Timelines

14 Mar 2022
Topic — The Commission is reviewing CO2 emission performance standards for new heavy-duty vehicles.
Message — Bosch requests that the 2025 target remains unchanged and advocates for a technology-neutral approach. They emphasize that hydrogen engines and renewable fuels must be recognized alongside electrification.12
Why — Bosch would protect its broad investments by ensuring the regulation supports multiple technology options.3
Impact — Existing automotive employees face redundancy risks due to the rapid industry transformation.4
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Meeting with Axel Voss (Member of the European Parliament)

1 Mar 2022 · Artificial Intelligence

Meeting with Karen Melchior (Member of the European Parliament, Shadow rapporteur) and Adobe Systems Benelux bvba

23 Feb 2022 · AI Act

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology) and Infineon Technologies AG and

10 Jan 2022 · Semiconductors

Meeting with Thierry Breton (Commissioner) and

10 Jan 2022 · CEO Round Table on Semiconductors

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

16 Dec 2021 · Semiconductors

Response to Count your transport emissions: CountEmissions EU

10 Dec 2021

Bosch welcomes the COM initiative to provide a uniform framework for quantifying GHG emissions in the transport sector. The goal to promote new business models and to initiate a strong dynamic in the reduction of CO2 emissions in the transport sector is also supported form our part. The objective of enabling new business models requires calculation methods that quantify GHG emissions precisely, verifiably and comparably across competitors in the market. This requires a quality of the framework that cannot be guaranteed by any standard to date. It is imperative that the binding nature of the framework will be defined internationally so as not to neglect significant parts of the transportation sector. Quantification must be continued to be exercised in a technology open way and in line with the market. In concrete terms, this means that biofuels and alternative fuels are options available in the medium term with existing technology to reduce CO2-emissions. In heavy goods/passenger transport, switching to gas drives (CNG/LNG) for CO2-reduction is an obvious measure that must not be excluded. The framework must therefore include an effective certification system for CO2-reducing fuels. To ensure widespread application in the transportation sector, a low entry threshold for small companies is mandatory. Many years of experience of sustainability experts must not be the entry requirement for the large number of small transport service providers. Finally, if the framework only enables to shift CO2 emissions within the transport sector - or even beyond – but not effectively avoid emissions and increase the shares of renewable energy overall, it would do climate protection a disservice.
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Meeting with Yizhou Ren (Cabinet of Executive Vice-President Margrethe Vestager)

17 Nov 2021 · Digital Decade

Meeting with Thierry Breton (Commissioner) and

12 Nov 2021 · Visit of major semiconductor research and production sites in preparation of EU Chips Act

Meeting with Markus Pieper (Member of the European Parliament, Rapporteur) and Climate Action Network Europe and

9 Nov 2021 · RED III

Meeting with Thierry Breton (Commissioner) and

5 Nov 2021 · Chips Act

Meeting with Yizhou Ren (Cabinet of Executive Vice-President Margrethe Vestager)

22 Oct 2021 · Digital decade

Meeting with Thierry Breton (Commissioner) and

23 Sept 2021 · Semiconductors

Response to Revision of the Machinery Directive

14 Aug 2021

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

29 Jun 2021 · Discussion on Industry expectation for Fit-for-55 Package

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

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

Meeting with Axel Voss (Member of the European Parliament) and OVH Groupe

18 Jun 2021 · --Workshop-- AI Industry showcase

Meeting with Thierry Breton (Commissioner) and

3 Jun 2021 · Clean Hydrogen Alliance; regulatory framework

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

The Bosch Group is committed to the Paris Agreement and the objective of the European Union to become climate neutral by 2050. In recognition of its own responsibility for environmental protection and resource-saving, Bosch has been climate-neutral worldwide since 2020 (Scope 1 / Scope 2). Furthermore, Bosch has set an ambitious target for its Scope 3 emissions, which is recognized by the Science Based Targets Initiative to support the 1.5°C Paris Climate Goals. The company has been added to the “A” list by the Carbon Disclosure Project (CDP) for its performance and transparency with regards to climate protection. Bosch supports the objective of the Sustainable Finance Regulatory Framework to promote sustainable economic activities in Europe and considers the European Taxonomy for Sustainable Finance as a pertinent instrument to define and foster sustainable investments and enhance transparency in the market. In this regard, Bosch supports the introduction of disclosure obligations also for non-financial undertakings. It is important that disclosure obligations remain practical and proportionate for companies without risking competitive interests of the European industry. Article 9 and Annex I of the Delegated Regulation requiring the disclosure for a non-financial undertaking by NACE code or economic activity represents an unprecedented granularity of company disclosure. For a company like Bosch, this presents two major challenges: - The obligation could lead to the compulsory publication of sensitive information such as strategic investment (CapEx). This could result in a competitive disadvantage of European undertakings on the global market. - Current reporting processes are not designed to report on this level of granularity. This would lead to high implementation costs and a disproportionate implementation workload. It is questionable if the disclosure of sustainable investments is necessary on such granular level for the purpose of the Regulation (EU) 2020/852. As a technology and service provider, Bosch for example, operates in 16 different business units resulting in a multitude of different product categories in various sectors. A more aggregated reporting rather than by individual activity could serve the purpose equally to demonstrate to which degree the turnover and capital and operational expenditure of non-financial companies are directed to sustainable economic activities in the sense of the Taxonomy Regulation.
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Meeting with Thierry Breton (Commissioner) and

7 May 2021 · Alliance in microelectronics

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

13 Apr 2021 · Decarbonizing road transport sector

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

8 Apr 2021 · IPCEI Microelectronics (virtual meeting)

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.

Meeting with Valdis Dombrovskis (Executive Vice-President)

25 Feb 2021 · - Green and digital transition - Decarbonisation path for automotive industry - Trade Policy Review

Meeting with Christiane Canenbley (Cabinet of Executive Vice-President Margrethe Vestager)

23 Feb 2021 · Data economy

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis) and Siemens AG and Bitkom e.V.

6 Jan 2021 · RRF, industry strategy, digital strategy

Response to Revision of the Communication on important projects of common European interest

21 Dec 2020

Bosch sees Important Projects of Common European Interest (IPCEI) as an important tool to enable Europe to respond to challenges related to the green and digital transition and at the same time to strengthen its competitiveness in a global context. IPCEIs play a key role to allow European companies to continue to invest in Europe and expand global market shares of European based manufacturing. The green and digital transition requires substantial investments in innovative technologies and systems and a high degree of coordination in entire sectors as well as cross-sectoral. Hydrogen and fuel cell technology for stationary and mobile applications, microelectronics and automated driving technologies have been identified, among others, as strategic value chains. They can become important facilitators for the transformation of industry as well as of the energy and mobility sector to reduce global warming in line with the Paris Agreement objectives. To support the required substantial investments and to address the considerable technical and financial risks involved Bosch regards high-scale public funding for the identified strategic value chains essential. Europe has to act fast to stay competitive as there is very well funded international competition. Also, the EU must respond to increasing government incentives for particular industries outside Europe, e.g. state aid in China and the US in the double to triple-digit billions (EUR) range. The first IPCEI projects have proven IPCEI to be a suitable tool to support first industrialisation and scale-up of innovative technologies. Bosch participated in the IPCEI Microelectronics 1 launched in 2017. The experience gained in the first phase of IPCEIs can help to further optimise the instrument. Please find Bosch's recommendations for the revision of the IPCEI guidelines attached.
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Meeting with Thierry Breton (Commissioner) and

27 Nov 2020 · Roundtable on Processors

Response to Updating the EU Emissions Trading System

26 Nov 2020

An effective and cost-efficient path towards de-fossilization must build on a holistic and consistent mix of policy instruments. The planned revision of the EU Emission Trading System should therefore be closely aligned with the EU Effort Sharing Decision, the EU Tax Directive, the EU’s sectoral policies as well as national mitigation policies in order to avoid excessive regulation and an increase of CO2 abatement costs. Bosch calls for an ambitious CO2 price that sets strong incentives to reduce CO2 emissions from cradle-to-grave across all sectors. In other words, a CO2 price must be sufficiently high to redirect business investments and finance from fossil fuels to less fossil carbon-intensive technologies and to incentivize consumer choices in favour of low-carbon alternatives. Ideally, a carbon pricing system should take the form of an EU-wide CO2 tax levied on the carbon content rather than the energy intensity of energy carriers. In so doing, the use of renewable fuels, including green hydrogen and eFuels, would be fiscally advantageous compared with fossil-based fuels, meaning that technologies could compete fairly against each other based on the fossil CO2 footprint of the fuels they rely on. Yet, since the revision of the EU Energy Taxation Directive is expected to be a lengthy process with uncertain outcome – due to unanimity in the Council – the introduction of a sectoral CO2 price would be a good alternative. With a view to the EU Commission’s considerations to broaden the scope of the ETS, Bosch suggests to regulate emissions from transport in a separate cap-and-trade system. This way, such a system could be designed in a way that it conforms to the sector’s individual abatement costs and price elasticities. Further, Bosch beliefs that a cap-and-trade system should be complemented by crisis response mechanisms such as a carbon floor price to make sure that the price of allowances neither exceeds nor falls below a certain level. Revenues arising from a CO2 price system should flow back into the targeted sectors and be earmarked for research, support programs and refunds supporting businesses and households on their path towards de-fossilization. In the transport sector, for instance, this could mean that parts of the revenues are used to incentivize the market ramp up of renewable fuels, including hydrogen and eFuels. Such support measures should complement and not replace existing funding mechanisms. Carbon pricing, if implemented wisely, is a highly cost-efficient mitigation tool. In the long run, a full integration of all industrial sectors and energy installations into one ETS would be the logical consequence. However, the full potential of carbon trading can only be unlocked if the European system is going to be extended to a worldwide level. In order to promote international carbon markets, the Commission should carefully reassess its opposition against international carbon credits. Carbon credits facilitate and deepen global climate mitigation efforts and have positive net effects on the global climate as long as they are properly monitored and verified.
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Bosch advocates for renewable fuel credits in vehicle CO2 standards

26 Nov 2020
Topic — Revision of CO2 emission standards to ensure a pathway towards zero-emission mobility.
Message — Bosch calls for a well-to-wheel approach and a voluntary crediting system for carbon-neutral fuels. They advocate for technological neutrality instead of banning the internal combustion engine.123
Why — The company would gain flexibility to meet targets while avoiding costly regulatory penalties.4
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

3 Nov 2020 · European Green Deal

Meeting with Thierry Breton (Commissioner) and

27 Oct 2020 · Data, AI, hydrogen, processors

Meeting with Margrethe Vestager (Executive Vice-President) and

27 Oct 2020 · Artificial intelligence, green deal, industrial policy

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

30 Sept 2020 · Discuss with the CEO for Automotive of Bosch to exchange views on the access to vehicle data, artificial intelligence, hydrogen and emission standards for vehicles.

Meeting with Adina-Ioana Vălean (Commissioner)

30 Sept 2020 · Transport

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

12 Jun 2020 · Future of mobility

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

Bosch advocates for technological neutrality and planning certainty

21 Apr 2020
Topic — This initiative develops stricter emission standards for all combustion-engine cars and lorries.
Message — Bosch recommends using air quality modeling to assess current standards before new rules. They advocate for technology-neutral standards and establishing technical parameters three years before enforcement.12
Why — Adopting a volume-based phase-in would provide Bosch with necessary planning flexibilities.3
Impact — Environmental advocates may face slower air quality improvements due to phase-ins.4
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Meeting with Thierry Breton (Commissioner) and

7 Apr 2020 · Discussion of COVID-19

Meeting with Christine Schneider (Member of the European Parliament)

4 Feb 2020 · Klimaneutralität und Unternehmensverantwortung

Meeting with Margrethe Vestager (Executive Vice-President)

4 Dec 2019 · Meeting with CEO of Bosch

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

4 Dec 2019 · AI - data economy

Meeting with Mariya Gabriel (Commissioner)

4 Dec 2019 · Research and Innovation

Response to European Partnership for Key Digital Technologies

27 Aug 2019

Robert Bosch GmbH highly appreciates the preparation of a new European partnership for Key Digital Technologies (KDT) by the European Commission - in close collaboration with the Member states (MS) - as a priority in the strategic planning for Horizon Europe. Bosch has been an active participant in a number of European partnerships and in particular also in ECSEL, which is the predecessor of the proposed KDT partnership. The new partnership could not only strengthen European leadership in KDT, but applications of KDT could also be instrumental in addressing global challenges such as transport and smart mobility, health and wellbeing, energy, digital industry and digital life, as well as driving the digital transformation of Europe’s economy and society in general. The KDT partnership has the potential to continue the achievements of ECSEL by supporting a vibrant ecosystem involving large firms, SMEs, universities and institutes, fostering fruitful collaborations between otherwise fragmented industry sectors and along the entire value chains up to and until industrialisation, covering not only KDT technologies, but also their applications beyond the KDT industry. In addition, it could help to strengthen the global competitiveness of the European KDT industry as well as ensuring Europe’s sovereignty and autonomy by providing Europe’s other industries and markets with independent and unrestricted access to KDT. However, certain aspects of ECSEL made it a less favourable instrument when compared with other partnerships in Horizon 2020 - for Bosch as well as for many other stakeholders. The established tripartite organization of ECSEL, for example, resulted in two more or less separate sources of funding, EC and MS, significantly increasing the complexity for collaboration and the administrative burden for applicants due to, among other issues, double-reporting and country-specific requirements. Often, especially recently, projects had too many partners to work efficiently as well. As regards to the proposed partnership, the apparently stronger focus on new and additional topics for the KDT partnership that were not topics of major interest in ECSEL, e.g. photonics and software, could without an increase in the overall budget result in less funding for the typical focus areas of ECSEL, i.e. R&D on microelectronics and semiconductors, which should be avoided. We would also prefer a more consequently followed two-stage proposal process in which a strict(er) pre-selection is performed during the first evaluation stage to reduce overall effort for applicants during the application phase. Also, the overall funding rate is in ECSEL considerably lower than in typical H2020 projects making participation less attractive, especially as many occurring overhead costs are not eligible for funding. To summarize, the new Key digital technologies partnership model should be designed in a way that the MS funding does not negatively influence the future projects definition, chances for funding, geographical balance and administrative requirements. The main challenge is to simplify the co-funding mechanism, with more alignment of funding rates, procedures, timing and requirements between participating MS, as well as multi-annual financial commitments, a higher degree of central financial management, a single funding source for each beneficiary (instead of funding from both the JU and national/regional authorities), and single (instead of double or triple) reporting on activities and costs. This would not only result in a more efficient organisation but also in a widening of the participation. The Bosch Group is a leading global supplier of technology and services. It employs roughly 410,000 associates worldwide (as of December 31, 2018). The basis for the company’s future growth is its innovative strength. At nearly 130 locations across the globe, Bosch employs some 68,700 associates in research and development.
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Response to European Partnership for Safe and Automated Road Transport

27 Aug 2019

Robert Bosch GmbH highly appreciates the preparation of a new European R&I partnership for Safe and Automated Road Transport by the European Commission - in close collaboration with the Member states - as a priority in the strategic planning for Horizon Europe. Collaborative research in the field of Connected, Cooperative and Automated Mobility (CCAM) will help Europe to achieve safer, cleaner, smarter, more accessible and efficient mobility solutions. Research and innovation activities conducted within the partnership can play a crucial role for maintaining and even increasing the innovativeness and thus competitiveness of the European automotive industry given the fierce international competition from, for instance, the US, China, and Japan. We recommend a partnership under the format of a Co-programmed partnership (Option 1) that can provide the necessary long-term framework for a strategic planning of research and pre-deployment activities for CCAM. Bosch prefers Option 1 over Option 2 mainly for the added speed, flexibility, openness, and smaller administrative burdens associated with Co-programmed partnerships. The introduction of a Co-programmed partnership will allow for a quick and timely start of the partnership, since no new structures or organizations need to be introduced. Starting the partnership as soon as possible is critical, considering the global race of the European industry in developing new solutions in a context of shorter innovation cycles and fast-acting international competition. In addition, Co-programmed partnerships, formerly contractual Public Private Partnerships, have proven to be agile and flexible instruments. These features are especially attractive for research, testing and pre-deployment in the CCAM field, which is highly dynamic and includes many uncertainties. Participation in the partnership must remain open to any stakeholder at any time of the partnership lifetime to accommodate for the many new actors in the automated mobility field. The scope implies collaboration between several sectors: automotive, telecom, data, infrastructure, services providers, and the involvement of public authorities on national and local levels. The Co-programmed Partnership is the easiest instrument to ensure this openness, introducing a European wide harmonized funding framework facilitating also the straightforward involvement of smaller actors, such as SMEs and start-ups. Reducing the administrative burden for the partners should also be an objective, enabling an efficient organisation and a wide participation. The Co-programmed Partnership offers the right frame: supporting the public private collaboration and the research agenda setting, but without creating additional participation constraints. Close coordination between the different European technology and research initiatives in the road transport area is required, such as the planned partnership towards zero emission mobility. Also the coordination of additional partnerships that provide enabling technologies for CCAM is necessary, e.g. electronics and smart systems (ECSEL/KDT), 5G, Cyber Security, AI. Research and innovation activities within the partnership should ideally address the entire innovation chain. This includes basic research, technology development, demonstration, pre-deployment, and the formulation and implementation of strategies for standardization, regulation and market introduction. The Bosch Group is a leading global supplier of technology and services. It employs roughly 410,000 associates worldwide (as of December 31, 2018). The basis for the company’s future growth is its innovative strength. At nearly 130 locations across the globe, Bosch employs some 68,700 associates in research and development.
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Response to European Partnership for Clean Hydrogen

27 Aug 2019

Robert Bosch GmbH highly appreciates the identification and preparation of a new, revised European partnership for Clean Hydrogen as a priority in the strategic planning for Horizon Europe by the European Commission - in close collaboration with the Member states. Based on the previous two Fuel Cells & Hydrogen Joint Undertakings (FCH JU) that have significantly contributed to developing hydrogen and fuel cell technologies within the EU and strengthened the European value chain, we would prefer the continuation of the current institutionalised European Partnership based on Article 187 TFEU (option 2). In recent years, the FCH JU has contributed to developing a number of key technologies and a first generation of products. However, it is crucial to now build on this success with a new partnership tackling the whole European value chain from basic research up to market ready solutions in order to develop the next generation of technologies and a functioning Hydrogen ecosystem. We therefore welcome the objective to involve additional stakeholders along the hydrogen value chain. Hydrogen as an energy carrier has the potential to also make an important contribution towards well-to-wheel and life cycle CO2 neutral on-road transport solutions and off-highway applications. Bosch follows a technology neutral approach for possible hydrogen powertrains. Therefore, complementary to fuel cell powertrains, the hydrogen internal combustion engine (H2 ICE) powertrain should also be included as one additional potential solution. The partnership enables European OEMs and suppliers (many of which are SME) to perform an evolutionary transition towards CO2 neutral powertrains while using already existing strong competencies, manufacturing technologies, value chains and products at favourable costs. Since existing ICE powertrain technologies and vehicle architectures already form a robust basis for the conversion towards H2 ICE powertrains, the additional investments and associated risks are limited. Generally, the inclusion of both FC and H2 ICE as hydrogen powertrain solutions will generate a more robust demand for hydrogen and for the build-up of a European hydrogen infrastructure. Also, both FC and H2 ICE powertrains can use the same on-board H2 tank system components and H2 refuelling station network. Additional feedback to the proposed partnership is provided in the commented Inception Impact assessment proposal text attached to this feedback. The Bosch Group is a leading global supplier of technology and services. It employs roughly 410,000 associates worldwide (as of December 31, 2018). The company generated sales of 78.5 billion euros in 2018. Its operations are divided into four business sectors: Mobility Solutions, Industrial Technology, Consumer Goods, and Energy and Building Technology. The basis for the company’s future growth is its innovative strength. At nearly 130 locations across the globe, Bosch employs some 68,700 associates in research and development.
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

22 Jun 2019 · Visit of Bosch R&D Centre with focus on road safety

Response to Revision of the Machinery Directive

11 Feb 2019

Robert Bosch answer to the European Commission Inception Impact Assessment on the Revision of the Machinery Directive 2006/42/EC. Bosch does not favour Options 0, 1 and 3. The Machinery Directive has to be adapted at least to the New Legislative Framework, especially with the provisions of Decision 768/2008, and need adjustments for clarification in the scope, definitions and content with respect to legal clarity. Therefore, Bosch welcomes Option 2, which would align the Machinery Directive with the New Legislative Framework and bring the chance for adjustments in the scope, definitions and content in relation with emerging digital technologies in a limited extent. • Clearer differentiation/separation of the scope of several relevant directives, e.g. between the Machinery Directive, Low Voltage Directive and the Radio Equipment Directive. • Certain categories of products in the scope of Machinery Directive are not clearly defined, which leads to (mis-)interpretation between the industrial players and member states and subsequently to increased costs. Examples are “safety components” and “partly completed machinery”. • We favour horizontal regulation of cyber security rather than requirements in each directive. Fallback option could be the seamless integration of cyber security within the different Directives. • Further discussions are necessary on the regulation of innovative technologies, e.g. collaborative technologies, AI, IoT. Focus on high level requirements, because the play field is too dynamic and still in development. Details should be defined by public standards. • Bosch favours allowing manufacturers to provide their documentation under a digital format (e.g. declaration of conformity and incorporation, manuals). By preventing high logistic effort and saving environmental resources, this ensures competitiveness as well it does reflect the digitalization. We recommend to evaluate whether these deficiencies can be clarified in the guide of interpretation to the Machinery Directive without any modification to the legislation. At least, additional unnecessary expenses and time for the formal correction of related regulations and public standards could be prevented. Bosch welcomes option 4 of turning the Machinery Directive into a Regulation as this exercise would allow a harmonised interpretation of the legal act in all Member States, avoid transposition problems in the Member States and ultimately, contribute to the completion of the internal market of goods. In general we agree to the described impacts.
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Response to Specifications for the provision of cooperative intelligent transport systems (C-ITS)

5 Feb 2019

Bosch supports the initiative of the European Commission to have a European legislation that would enforce the ITS Directive (2010/40/EU) through a Delegated Act. Bosch welcomes the opportunity to comment through an open and transparent consultation process. Bosch, as a leading global automotive supplier, has a particular interest in C-ITS because it can significantly reduce the number of fatalities on the road, improve traffic efficiency and has a positive effect on the environment. Bosch supports technology neutrality in a sense that we do not favour one particular technology. We respond to the demand of our customers when these technologies are or will be available. Bosch supports the deployment of ITS without any delay. Bosch supports the draft Delegated Act as it represents a step forward towards enabling mobility. It is an opportunity for Europe to be at the forefront of C-ITS developments. The draft Delegated Act provides legal certainty that the European industry has been waiting for. For Bosch, it is paramount that this legal framework ensures interoperability, compatibility and continuity of services. Bosch supports the draft Delegated Act regarding technology development as it allows a prompt deployment today while it leaves the door open for further innovation in Europe. We would invite the European Commission to consider our comments on the draft Delegated Act. We would propose to amend the current draft Delegated Act with our suggestions in Annex 1 of the attached document.
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Meeting with Manuel Mateo Goyet (Cabinet of Commissioner Mariya Gabriel)

17 Oct 2018 · Copyright

Response to REFIT review of the Motor Insurance Directive

23 Jul 2018

Electrical Power Assisted Cycles (EPAC) should be excluded from the scope of the MID at EU level. Firstly, EPAC´s driving performance is very similar to a conventional bicycle: the average speed varies just by approximately 2-3 km/h. The auxiliary electric motor, with which EPAC is equipped, has a maximum continuous rated power equal or lower than 250W. Its electric motor´s output is designed to interrupt when the cyclist stops to pedal or to progressively reduces the power, until its full shutdown, before the EPAC´s speed reaches 25km/h. The limits for the maximum continuous rated power and the maximum vehicle speed with assistance is defined in a way that they correspond to a bicycle. Relevant speed difference is achieved in uphill situation, where higher speed is advantageous for bike´s stability. EPAC users apply the support of the auxiliary motor primarily to realise the same behaviour of a bicycle driver but with less effort. Therefore, the main difference is increased comfort. As an example, the last revision of the StVZO implemented in 2017 in Germany, explicitly states in §63a that an EPAC is considered a bicycle. Secondly, regarding the occurrence of accidents, there is no higher frequency of serious injuries. When looking at the number of injuries it should be considered that the mileage of EPAC is significantly higher compared to the conventional bicycle´s one (2.000 km/year versus 270 km/year). Therefore, the share of EPAC accidents is similar to bicycle´s one. In this regard, there are many studies which compare both types of vehicle on common scenarios of accident. For example, the study ‘Compact accident research – Traffic safety of electric bicycles’ of the German Insurance Association (11/2014), comes to the conclusion that EPAC users do not face critical situations more often than bicycle drivers. Hence, as the number and type of conflicts is comparable, EPAC drivers are not subject to increased or different safety risks. Hence, it would be incomprehensible for the general public to use and consider bicycles and EPACs equally, except for the compulsory insurance. In case of a compulsory third party insurance for EPACs, the direct effect would be a considerable restriction of its usage, leading to a marked decline of EPACs. In this respect, it is already visible today that the usage of Speed-EPACs (up to 45 km/h reached and considered as L1e-B motor vehicle), which requires higher bureaucratic effort, is insignificant if compared to the market diffusion of EPACs. The decline of EPAC usage would have a counter-productive effect on the current goals to ease traffic flow. There are already good signs that short distance commuters switch to EPACs instead of using other means of transport. A study from German Insurance Association emphasizes that EPACs are considered an alternative to cars and, in turn, that in the case of not having any more availability to EPACs, users would directly switch back to cars. This scenario would also have a negative impact on the uptake of the electro-mobility and it would hinder the achievement of global goals, such as the Paris Agreement. In fact, EPACs´ usage contributes not only to reduce traffic congestions but also CO2 concentration as well as particulate emissions, which represent one of the main problems faced by European cities. The use of EPAC is healthy, environmental friendly, traffic-load-reducing and cost saving. Thus, it is important to keep the same handling of bicycles and EPACs, in order not to prejudice the success of current EPAC usage as a type of electro-mobility and, as a consequence, to encourage the diversification of modes of transport and the achievement of the goals set under the Paris Agreement. EPAC´s exception from the current status of the Directive 2009/103/EC, its technical definition and features, and the beneficial effects of its usage shall be taken into account during the revision of the MID.
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Response to General Safety of Vehicles and Pedestrians

13 Jul 2018

The EU has defined a target aiming at halving the number of road fatalities from approximately 31,000 to 15,000 within the decade 2010-2020 . However, since 2013 the number of victims and injured on Europe´s roads show not only a significant slowdown but several Member States are reporting even a slight increase1. As illustrated in EU road safety statistics, in 2016 more than 25,000 people died on the road and 135,000 were severely injured . This causes an estimated cost of €100 billion1. On average, the majority of the accidents occurs in urban areas, involving vulnerable road users (VRU), such as pedestrian and cyclists, bearing the highest risk. Being aware that additional action is needed to improve vehicle safety, Bosch welcomes the proposal by the European Commission for a review of the General Safety Regulation (EC) No 661/2009 (GSR) and the Pedestrian Safety Regulation (EC) No 78/2009 (PSR). It is particularly positive that the Commission proposal includes the full set of safety measures, opting for the maximum reduction of road fatalities and severe injuries which will firmly contribute to saving lives across the EU. Therefore, Bosch calls for a swift conclusion of the co-decision procedure within the current legislative period in order to avoid any further delays. It should also be considered to shorten the application timeline of some of the technologies so as to benefit from their contribution to road safety as soon as possible. Namely, Bosch identified AEB as a promising technology since: • It has a proven record that collisions are avoided or significantly mitigated and therefore the number of fatalities and injuries could be reduced • Traffic flow could be improved due to decreased congestion caused by accidents • Key technologies for automated driving will be implemented
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Meeting with Ivo Schmidt (Cabinet of Vice-President Maroš Šefčovič)

2 Jul 2018 · LOW EMISSION MOBILITY

Meeting with Carl-Christian Buhr (Cabinet of Commissioner Mariya Gabriel)

24 Jan 2018 · Cybersecurity, Internet of Things

Meeting with Günther Oettinger (Commissioner)

21 Nov 2017 · CO2 émission regulation

Meeting with Günther Oettinger (Commissioner)

22 Mar 2017 · Connected and Automated Driving

Response to Real-Driving Emissions in the EURO 6 regulation on emissions from light passenger and commercial vehicles (RDE3)

30 Nov 2016

Bosch has supported the Real-Driving Emissions (RDE) test in the course of its development and in particular during the preparations of regulatory packages 1 and 2. Credibility with regard to real-driving emissions is of utmost importance for the long-term political and societal acceptance of the internal combustion engine, gasoline as well as diesel. Regarding the ongoing regulatory discussion of RDE package 3 (see details below) and the future package 4 (main focus in-service conformity), Bosch upholds its proactive approach towards RDE testing. Emissions during cold start are a relevant contribution to overall emissions from gasoline and diesel engines and should be covered by the RDE test. The technical input provided by different stakeholders to the EU RDE LDV (light-duty vehicles) working group has unfortunately shown that only a very limited number of cold start emission measurement results generated under the RDE boundary conditions is currently available. Under this precondition and keeping in mind a regulation starting with RDE step 1 (9/2017), Bosch believes that a straightforward and robust cold start inclusion should be pursued. Political preference should be given to a simple regulatory approach as represented by option 0. The Bosch experiences show that measurement results in the first 5 minutes are hardly robust and very sensitive to boundary conditions of the trip. Therefore, a regulatory approach based on a separate assessment of the first 5 minutes plus a weighting with RDE urban (option 2a) would have to be complemented by both an adequate reference distance (data situation remains non-conclusive following European Commission assessment) and a consideration of the physical effect of low system (engine and exhaust gas aftertreatment) temperatures on emissions, e.g. via a cold start correction factor (divisor) for low system temperatures. The planned real-driving emissions regulation for the particle number (PN) limit affects in particular gasoline direct injection (GDI) vehicles, as all diesel vehicles in the European market are equipped with a closed diesel particle filter since the Euro 5 introduction (9/2009 new types and 1/2011 all new vehicles). Bosch believes that the planned introduction deadlines for RDE-PN (9/2017 new types and 9/2018 all new vehicles) seem short. As hardware changes are expected, for which a lead-time of approximately three years is usually a minimum, Bosch calls upon RDE decision-makers to study the potential market impacts carefully. The agreed introduction of WLTP in the EU regulations for CO₂ and emissions is a key measure for bringing test-cycle results much closer to real world, ensuring higher transparency for consumers and restoring trust in the automotive industry as well as in the governing regulations. Bosch is therefore supporting the WLTP introduction. It is also acknowledged that the WLTP decision of the EU Technical Committee Motor Vehicles (TCMV) states the political intention that “the timetable and the transitional provisions for introducing the real driving emissions test procedure remain unchanged with respect to those lined out previously in Regulations (EC) 2016/427 and 2016/646”. However, concerns do remain that the WLTP introduction (9/2017 new types and 9/2018 all new vehicles) would require all new vehicles to already comply with RDE step 1 (9/2018 instead of 9/2019). This would lead to a de facto shortening of the lead-time for all new vehicles by one year. The same concern also exists for the future regulation of evaporative emissions (EVAP), where an introduction in 9/2019 (all new vehicles) was expected at the TCMV on 12th May 2016. Given the short remaining lead-time for the introduction of these new regulatory requirements and the necessary preparations throughout the automotive industry value chain, Bosch is convinced that the confirmation of the original introduction scenarios for RDE and EVAP is urgently required.
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

19 Oct 2016 · European Strategy for Low-emission Mobility

Meeting with Dominique Ristori (Director-General Energy)

15 Sept 2016 · Energy policy

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

15 Sept 2016 · Energy Efficiency

Meeting with Bodo Lehmann (Digital Economy)

11 Jul 2016 · decarbonisation of transport

Meeting with Günther Oettinger (Commissioner)

8 Jul 2016 · connected & automated driving and decarbonisation of transport

Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc) and Fleishman-Hillard and

5 Jul 2016 · decarbonisation of transport

Meeting with Bodo Lehmann (Digital Economy)

23 Jun 2016 · decarbonisation of transport

Meeting with Antonio Lowndes Marques De Araujo Vicente (Cabinet of Commissioner Carlos Moedas)

8 Jun 2016 · EIC

Meeting with Günther Oettinger (Commissioner)

19 May 2016 · company/site visit

Meeting with Jos Delbeke (Director-General Climate Action)

19 Apr 2016 · CO2 / cars

Meeting with Rodrigo Ballester (Cabinet of Commissioner Tibor Navracsics)

12 Apr 2016 · Skills agenda, radicalisation

Meeting with Violeta Bulc (Commissioner) and

14 Feb 2016 · Roundtable with European Businesses in Singapore

Meeting with Günther Oettinger (Commissioner)

9 Nov 2015 · Automated driving

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

23 Oct 2015 · RDE

Meeting with Eric Mamer (Digital Economy)

6 Jul 2015 · connected mobility

Meeting with Günther Oettinger (Commissioner)

28 May 2015 · Industry 4.0, DSM

Meeting with Eric Mamer (Digital Economy)

29 Apr 2015 · DSM

Meeting with Justyna Morek (Cabinet of Commissioner Elżbieta Bieńkowska)

20 Apr 2015 · CO2/cars post-2020 & General Safety Regulation

Meeting with Pierre Schellekens (Cabinet of Vice-President Miguel Arias Cañete)

26 Feb 2015 · Energy Union and Climate Action

Meeting with Günther Oettinger (Commissioner)

20 Feb 2015 · Industry 4.0

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker)

5 Feb 2015 · Energy Union

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

26 Jan 2015 · ENERGY EFFICIENCY IN PRODUCTS, TRANSPORT, BUILDINGS