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Stowarzyszenie Dystrybutorów i Producentów Części Motoryzacyjnych

SDCM

Reprezentacja członków Stowarzyszenia w kontaktach z instytucjami administracji państwowej, uczestnictwo w pracach legislacyjnych projektów dotyczących branży motoryzacyjnej, udział w konsultacjach społecznych, etc.

Lobbying Activity

Meeting with Eva Schultz (Cabinet of Executive Vice-President Roxana Mînzatu) and Robert Bosch GmbH and

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

Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič) and Robert Bosch GmbH and

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

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

2 Dec 2025

SDCM (the Polish Association of Automotive Parts Distributors and Producers) representing the interests of aftermarket operators including parts supliers, wholesalers and repair workshops, welcomes the opportunity to provide feedback on the forthcoming amendments to the Type-Approval Regulation. These changes will usher in a new era for the European aftermarket, characterised by a substantial increase in the dependence of independent operators on vehicle manufacturers. This is particularly evident in relation to the provision, maintenance, and operability of multi-brand diagnostic tools. Tool manufacturers will require prompt and comprehensive access to information and technical support from vehicle manufacturers to ensure the proper integration, testing, and validation of cybersecurity requirements. Equally, continuous availability of OEM servers responsible for authentication, parts coding, and software updates is critical; any interruption in these services risks disabling essential repair and maintenance activities performed by independent operators. Given this heightened dependency, it is vital that authorities enforce the new provisions with the highest level of rigour. In cases of non-compliance, rapid and proportionate measures must be applied. The effectiveness of the regulatory frameworkand fair competition in the aftermarketwill depend on robust and uncompromising enforcement across the EU. Providing multi-brand diagnostic tools with the capability to perform parts coding and software updates is a significant and welcome advancement. However, this reform does not address the rapidly expanding number of coded parts that are exclusively available as OEM-branded originals. The absence of alternative or independent aftermarket sources is deeply concerning, as it eliminates competition in parts distribution and increases costs for consumers and workshops. SDCM strongly urges the Commission to introduce complementary legislation to ensure competitive neutrality in the supply of coded components. The situation is equally problematic for re-used parts. In Poland, demand for re-used parts is consistently high due to their affordability and contribution to circular economy objectives. Yet many components cannot be reused because they remain electronically paired to the original vehicle. We call on the Commission to address this obstacle by requiring manufacturers to introduce processes that enable parts to be securely decoupled from the original VIN. This would facilitate re-use, support environmental sustainability, and enhance consumer choice, while maintaining appropriate cybersecurity safeguards. SDCM would also like to highlight a point requiring legal clarification within Annex X, point 6.1.1. The sentence Access to such API may be subject to reasonable fees must remain directly and exclusively linked to the immediately preceding paragraph. It must not be interpreted as applying to the entire point or to all forms of RMI/OBD access, for which no fees may legally be imposed. Any fee may only relate to access to the specific API for transmitting a repair or maintenance record updatenothing beyond this within point 6.1.1. Clear drafting is essential to prevent misinterpretation and to fully preserve the principle of free, non-discriminatory access to RMI and OBD information as established by Regulation (EU) 2018/858. In conclusion, SDCM stresses that the success of this reform will depend not only on the technical measures introduced but also on ensuring equal, non-discriminatory access to vehicle data, practical enforceability of OEM obligations, and a competitive environment for parts supply.
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Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra) and Robert Bosch GmbH and

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

Response to Clean corporate vehicles

8 Sept 2025

The Association of Automotive Parts Distributors and Producers (SDCM) urges the European Commission to ensure that the forthcoming legislative proposal to decarbonise corporate fleetsdue by the end of 2025takes into account the realities of existing business models and supply chains within the mobility ecosystem. While SDCM and its members fully support the EUs climate neutrality objectives, the accelerated transition to zero-emission vehicles (ZEVs) in corporate fleets poses significant challenges for our sector. The success of this transition depends largely on creating enabling conditions that safeguard the competitiveness of the automotive aftermarket. Key concerns and challenges include: Limited charging infrastructure: Charging points in rural and semi-urban areas are sparse, making EVs impractical for many operationsespecially for sales staff who take vehicles home. Furthermore, some businesses lack the space to install charging infrastructure on their premises. Extended charging times and downtime: Charging durations of 2-3 hours lead to significant inefficiencies, reducing the daily mileage and causing productivity losses for businesses. Inadequate range and payload capacity: Current EVs, particularly electric LCVs, do not meet the operational and payload demands of daily routes. -- Long shifts, sometimes lasting up to 12 hours, require frequent recharging and route adjustments, particularly in rural areas. Financial burden on SMEs: The high upfront costs of EVs and charging infrastructure impose a significant financial strain on SMEs, already grappling with rising logistics costs. The required investment in infrastructure and fleet expansion is highly uncertain in the current economic climate. To support the successful transition to greener corporate fleets, we recommend the following actions: Avoid mandatory ZEV quotas: SDCM opposes mandatory ZEV targets for corporate fleets. Enforcing strict quotas would disrupt businesses. A more flexible, incentive-based approach would better support business continuity and industrial competitiveness. Ensure enabling conditions for voluntary uUptake: Improving access to both public and private ZEV charging infrastructure and enhancing the EU's energy grid readiness are essential. Financial incentives, particularly for SMEs, must be introduced, alongside policy clarity and long-term predictability. Promote EV repairability: Strengthening the legal framework to ensure the affordable and comprehensive repairability of EVs is crucial. This will not only stimulate demand in the primary market but also help develop a second-hand EV market, further driving uptake. Conduct a thorough market study and impact assessment: The European Commission should apply the Better Regulation principle, including checks on SME impact and competitiveness. A detailed analysis is necessary to ensure that the proposed policies are realistic, proportionate, and evidence-based. Adopt a technology-neutral approach: Legislation should remain open to all low- and zero-emission technologies, including hydrogen and sustainable fuels. This would account for varying operational needs and regional infrastructure readiness, as set out in the Commission Presidents Political Guidelines. SDCM is committed to supporting the transition to a more sustainable and circular mobility ecosystem in Europe. However, this transition must not come at the expense of businesses, supply chains, or essential services. A failure to adopt a holistic, flexible approach could ultimately harm the EUs industrial competitiveness, undermining the long-term success of the green transition.
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Meeting with Piotr Müller (Member of the European Parliament, Shadow rapporteur)

28 Mar 2025 · End of life vehicle Regulation

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

26 Mar 2025 · Securing the Competitiveness of the EU automotive industry

Meeting with Piotr Müller (Member of the European Parliament, Shadow rapporteur)

19 Feb 2025 · Circularity requirements for vehicle design and management of end-of-life vehicles

Meeting with Kamila Gasiuk-Pihowicz (Member of the European Parliament)

19 Feb 2025 · Automotive industry

Meeting with Kosma Złotowski (Member of the European Parliament)

19 Feb 2025 · Production of car parts in Europe

Response to Single Market Strategy 2025

30 Jan 2025

On behalf of the members of the Association of Automotive Parts Distributors and Producers (SDCM), a large number of entrepreneurs and companies representing the automotive R&D segment, in order to guarantee the further development of automation-related initiatives and to support the development of research companies producing cutting-edge systems for automated vehicles, we would like to submit for consideration the possibility of changes to the regulations of the common market that would allow for community-based, cross-border test drives of vehicles equipped with thesecutting-edge technologies, which would support the competitiveness of EU R&D projects, especially in the face of restrictions created by national regulations. In the industry's view, such a solution should be combined with appropriate regulations recognising, for example, common test boards across the Union, or allowing for Union-wide recognition of test boards from each country, and combining this with the possibility of Union-wide testing, replacing the need for bilateral agreements in each Union country.
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Response to Evaluation of the Motor Vehicle Block Exemption Regulation

24 Jun 2024

Association of Automotive Parts Distributors and Producers - SDCM welcomes the opportunity to give feed-back on the Commissions evaluation exercise on the Motor Vehicle Block Exemption Regulation (MVBER) ahead of its expiry on 31 May 2028. We would like to highlight the importance of the MVBER regime and its Sector Specific Guidelines (SGL) for the maintenance of the free and effective competition on the automotive aftermarket, as well as stress that the maintenance of this regime is imperative to guarantee the balance on the said market. Sector-specific and tailored rules are still the best solution for this key industry. Without the MVBER, market participants would need to rely on general principles of competition law, which would be less appropriate, more difficult to interpret and more costly to deal with especially for SMEs, which form an essential part of the independent automotive aftermarket. Letting the MVBER provisions and SGL expire would lead to legal uncertainty, both for the business and for the consumers. With the average age of the EUs car park of over 12 years now and the tendency of consumers to keep their vehicles longer, there will still be the need to physically repair and service the cars in the workshops, as this vehicle park will still require hardware parts, often involving parts coding and software updates, needless to mention the remote diagnostic functionalities that will also be employed. What should be stressed is the need to maintain freedom of trade in spare parts, so that independent operators may offer their services and consumers enjoy the freedom of choice due to the aftermarket presence. It should be also borne in mind that an obstacle on one stage of the repair and servicing procedure may impede further procedures. The issues to overcome are in particular the availability of spare parts, the captive parts issue or the warranties which are other a tool used to restrict competition. The ongoing technological advancement and development of new digital solutions shall also bring us to the point of the ability of independent operators to compete effectively. This entails unrestricted access to essen-tial inputs which shall be provided in format and modus allowing effective processing and thus offering competitive services and products. Also, the requirements for parts activation, the maintenance of vehicle software and the impact of cybersecurity create new potential barriers to independent operators abilities to provide effective competition in the supply or spare parts or in the risk of the abuse of such measures to impose unwarranted fees or restrictions on Ios. Safeguarding measures to address such issues should be considered. We believe that the emerging trends such as digitalisation and electrification (the availability of replacement batteries and foreclosure of independent repairability) constitute potential new risks of excluding independent operators from the automotive aftermarket and tying the consumers. They should be addressed by competition law with a focus on the repairability of electric vehicles (EVs) and thus the scope of the evaluation should be enlarged further to the hindrances in vertical relations in respect of Electric Vehicles. We would therefore suggest that this Evaluation exercise considered also aspects of effectiveness, efficiency and EU added value, while revising the enforcement of the MVBER-regime with less focus on the number of cases/evidence brought up as a measure of well-functioning markets. Instead, the focus should be on building a more robust MVBER enforcement system on which market operators can rely to seek compliance and justice.
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Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean)

30 Mar 2023 · Meeting on access to in vehicle data and Roadworthiness Package

Meeting with Beata Mazurek (Member of the European Parliament)

29 Mar 2023 · Exchange of views on type-approval of motor vehicles and engines and of systems, components and separate technical units intended for such vehicles, with respect to their emissions and battery durability

Response to Review of the Designs Directive

26 Jan 2023

The Association of Automotive Parts Distributors and Producers (SDCM) welcomed the proposal of the European Commission on the revision of the Design Directive (COM(2022) 667) and the EU Design Regulation (COM(2022) 666) announced on 28 November 2022. One of the main points is the introduction of an EU-wide Repair Clause in the Directive and the confirmation of a permanent Repair Clause in the Regulation. The Repair Clause is an indispensable precondition to the achievement of the liberalisation of the spare parts market, the completion of the EU internal market for spare parts and circular economy. The Repair Clause allows consumers to purchase visible spare parts (such as car bumpers, windscreens and automotive lighting) from the producer of their choice, irrespective of the brand of their vehicles. It stimulates purchasing power for the owners of more than 300 million of vehicles in the EU, as well as innovation and employment for more than 500.000 independent aftermarket operators (many of them being SMEs or entrepreneurs), legal certainty and growth, hence making the right to repair more tangible, accessible and affordable. SDCM provides the following comments on the European Commissions proposal: 1) We welcome the introduction of an EU-wide Repair Clause in the Design Directive (Art. 19(1)), which is indeed the right choice from a legal and economic perspective. 2) However, we regret the newly introduced restriction of the Repair Clause to form-dependent component parts of complex products only, both in the Design Directive (Art. 19(1)) and in the Regulation (Art. 20a(1)). In our view, this restriction is not justified under any intellectual property principle, it contradicts the original intention of the EU legislator, and it would weaken the position of consumers. 3) We also regret the introduction of unclear and redundant information requirements for consumers on product design (Art. 19(2) of the Directive and Art. 20a(2) of the Regulation), which will neither improve consumer information nor fit with the realities of the spare parts market. It is crucial to have accurate information requirements for all market participants; such requirements are already better addressed in existing consumer protection laws. 4) The Repair Clause will not fully benefit the millions of motorist consumers as long as it does not apply to new and existing designs. Thus, we recommend a far shorter and more flexible transition period, leaving the choice to Member States whether they want to apply the Repair Clause to existing designs from day 1, and at most until 3 years from the entry into force of the new Directive (Art. 19(3)). A more detailed explanation of our comments is provided in the attachment.
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