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Verband der Automobilindustrie

VDA

The VDA represents over 620 German automotive manufacturers and suppliers globally.

Lobbying Activity

Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra)

20 Jan 2026 · Automotive Package

Meeting with Bernd Biervert (Cabinet of Commissioner Maroš Šefčovič), Jan Hendrik Dopheide (Cabinet of Commissioner Maroš Šefčovič)

14 Jan 2026 · International trade policy

Meeting with Niclas Herbst (Member of the European Parliament, Committee chair)

14 Jan 2026 · Exportorientierte Industrie und globalen Wertschöpfungsketten

German car industry demands research funding and less bureaucracy

13 Jan 2026
Topic — New EU initiative to boost innovation and production capacities for advanced materials.
Message — The VDA requests increased public funding for basic research and faster project approvals. They propose EU-wide material standardization and a significant reduction in reporting burdens.123
Why — Reducing administrative burdens and securing grants would speed up innovation and lower costs.45
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Response to Revision of EU rules on the eInvoicing

17 Dec 2025

Sie finden die Stellungnahme des Verbandes der Automobilindustrie e.V. im Anhang.
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German automotive association calls for unified taxonomy rules

5 Dec 2025
Topic — Review of technical screening criteria within the EU taxonomy’s environmental delegated act.
Message — The VDA requests harmonized taxonomy criteria between vehicle manufacturing and financing. They propose that vehicles deemed green by manufacturers remain green when leased. They also call for consistent treatment of vehicle part and component manufacturers.123
Why — Standardizing these rules would reduce administrative expenses and complex IT investments for automotive banks.4
Impact — Environmental integrity might suffer if banks stop monitoring real-world vehicle performance like tire efficiency.5
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Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall)

3 Dec 2025 · Decarbonisation

Meeting with Gabriele Giudice (Cabinet of Executive Vice-President Raffaele Fitto)

3 Dec 2025 · Automotive policy topics

German Auto Industry Urges Demand-Driven Approach in Chips Act 2.0

26 Nov 2025
Topic — Review of EU Chips Act to strengthen Europe's semiconductor ecosystem and manufacturing.
Message — The organization requests a demand-driven approach focused on power semiconductors and automotive chips, faster approval processes, competitive energy prices, and simplified funding access. They emphasize the need for realistic goals and support for the entire semiconductor ecosystem including design, manufacturing, and recycling.1234
Why — This would secure their supply of specialized chips for electromobility and automated driving while reducing compliance costs.56
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Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

21 Nov 2025 · revision of the CO2 emission standards for cars and vans

Meeting with Jens Gieseke (Member of the European Parliament)

20 Nov 2025 · Austausch zu EU-Verkehrspolitik

Meeting with Tiemo Wölken (Member of the European Parliament)

12 Nov 2025 · Emissions in the Transport Sector

Meeting with Andreas Glück (Member of the European Parliament) and GE HealthCare Technologies Inc

11 Nov 2025 · Environment Policy

German Auto Industry Seeks Flexible Circular Economy Rules

4 Nov 2025
Topic — New EU regulation on circular economy, recycled materials, and product sustainability.
Message — The organization requests careful introduction of recycled content quotas with harmonized measurement methods and impact assessments. They want the 'Repair as Produced' principle enshrined in law, allowing spare parts to remain compliant based on original specifications. They seek exclusion from redundant regulations since automotive is already covered by specific legislation.1234
Why — This would reduce compliance costs and avoid competitive disadvantages from duplicative requirements.567
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs) and

31 Oct 2025 · Exchange of views on automotive topics

Meeting with Christine Singer (Member of the European Parliament)

30 Oct 2025 · Automobilindustrie

German Automotive Industry Urges Digital Regulatory Simplification

14 Oct 2025
Topic — EU initiative to simplify digital regulations affecting automotive data, cybersecurity, and AI.
Message — The organization requests streamlined digital regulations through the Digital Omnibus, including simplified data protection rules, harmonized cybersecurity reporting, and delayed AI Act implementation deadlines. They advocate for risk-based approaches, reduced compliance burdens, and clearer legal definitions across overlapping regulations.123
Why — This would reduce compliance costs and free resources for innovation in connected vehicles.45
Impact — Data protection authorities lose oversight powers and consumers may face weaker privacy protections.67
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Meeting with Michael Bloss (Member of the European Parliament)

14 Oct 2025 · ETS2

Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

14 Oct 2025 · Current situation of the German automotive industry

Meeting with Roxana Mînzatu (Executive Vice-President) and

14 Oct 2025 · Meeting on the transition in the automotive industry

Meeting with Kurt Vandenberghe (Director-General Climate Action)

13 Oct 2025 · The green and digital transformation, the CO2 fleet regulations for cars vans, and HDV, and the ongoing work in the strategic dialogue.

Meeting with Anna Panagopoulou (Cabinet of Commissioner Apostolos Tzitzikostas), Simone Ritzek-Seidl (Cabinet of Commissioner Apostolos Tzitzikostas)

13 Oct 2025 · Automotive industry

Meeting with Daniel Caspary (Member of the European Parliament)

13 Oct 2025 · Austausch

Meeting with Markus Ferber (Member of the European Parliament)

13 Oct 2025 · State of play in the automotive industry

Meeting with Edoardo Turano (Head of Unit Climate Action)

10 Oct 2025 · CO2 emissions from cars and vans

Meeting with Joaquim Nunes De Almeida (Director Internal Market, Industry, Entrepreneurship and SMEs)

9 Oct 2025 · Automotive industry

Meeting with Simone Ritzek-Seidl (Cabinet of Commissioner Apostolos Tzitzikostas)

9 Oct 2025 · VDA Input to Automotive Omnibus

German Auto Industry Urges Voluntary Nature Credits Without New Obligations

30 Sept 2025
Topic — EU roadmap to create market instrument for nature credits to incentivize private biodiversity investment.
Message — The industry requests that nature credits remain strictly voluntary without additional obligations. They seek recognition of credits in existing regulations like the EU Taxonomy and life cycle assessments. They want small plots to be certifiable and clear guidelines on measurement and monitoring.123
Why — This would allow offsetting biodiversity impacts without mandatory compliance costs or competitive disadvantages.45
Impact — Environmental groups lose mandatory protections as voluntary credits could replace stronger regulatory requirements.6
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Meeting with Edoardo Turano (Head of Unit Climate Action)

24 Sept 2025 · CO2 standards Regulation for cars and vans

Meeting with Svenja Hahn (Member of the European Parliament)

24 Sept 2025 · EU-US trade relations, tariffs

Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

23 Sept 2025 · Co2 standards for cars and vans

Meeting with Nils Behrndt (Deputy Secretary-General Secretariat-General)

18 Sept 2025 · Automotive industry

Meeting with Christine Singer (Member of the European Parliament)

12 Sept 2025 · IAA Mobility

Meeting with Stéphane Séjourné (Executive Vice-President) and

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

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

10 Sept 2025 · Exchange of views on automotive issues

VDA Rejects Mandatory Zero-Emission Targets for Corporate Fleets

5 Sept 2025
Topic — The EU is consulting on setting minimum zero-emission vehicle requirements for corporate fleets.
Message — The VDA explicitly rejects binding targets for corporate fleet operators, recommending incentives instead. They argue that new regulations would create unnecessary administrative burdens and economic pressure.12
Why — This would prevent increased administrative burdens and unnecessary economic pressure on manufacturers.34
Impact — Society may lose the benefit of a swifter transition to climate-neutral transport.5
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VDA urges EU to include batteries in state aid list

5 Sept 2025
Topic — Technical updates to rules for compensating high electricity costs under carbon pricing.
Message — VDA wants battery production, precursors, and recycling included in state aid rules. They argue competitive electricity prices are essential for a successful battery ecosystem.12
Why — This would reduce electricity costs and improve the climate for battery investments.3
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Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné)

1 Sept 2025 · Preparation of IAA meeting

Meeting with René Repasi (Member of the European Parliament)

28 Aug 2025 · Stärken, Chancen, Herausforderungen der deutschen Automobilindustrie bei der doppelten Transformation aus Defossilierung und Digitalisierung

German car industry rejects expanding CBAM to downstream products

26 Aug 2025
Topic — Consultation on extending carbon border adjustment taxes to more complex industrial products.
Message — The VDA rejects extending the carbon border tax to downstream products due to high complexity and trade risks. They urge the EU to simplify current regulations and address the non-coverage of export goods.12
Why — Avoiding this expansion would prevent significant new administrative costs and protect their international competitiveness.3
Impact — International trade partners lose market access as the expansion creates new non-tariff trade barriers.45
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German carmakers demand exclusion of vehicles from recycling list

25 Jul 2025
Topic — This consultation identifies products and waste streams with high raw material recovery potential.
Message — The VDA requests that vehicles and batteries be excluded from this regulation. They advocate for efficient shredding technologies instead of mandatory manual dismantling. They also want smaller components removed to avoid disproportionate technical efforts.123
Why — Excluding vehicles avoids regulatory overlap and prevents expensive, labor-intensive manual dismantling requirements.45
Impact — Specialized dismantling businesses lose potential revenue if manual parts removal is not mandated.6
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Meeting with Aurel Ciobanu-Dordea (Director Environment)

23 Jul 2025 · Exchange of views on the general situation of the automotive industry

VDA welcomes proposed delay to battery due diligence rules

22 Jul 2025
Topic — This consultation amends the timeline and requirements for battery supply chain due diligence obligations.
Message — The VDA requests a quick adoption of the two-year postponement and harmonization with existing sustainability reporting frameworks. They also propose a shared responsibility model to manage the complexities of raw material supply chains.123
Why — Streamlining these rules would reduce administrative burdens and avoid the costs of managing conflicting legal requirements.45
Impact — Environmental groups may lose specific protections if product-specific battery requirements are replaced by general corporate rules.6
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Response to Revision of the Standardisation Regulation

21 Jul 2025

VDA Feedback to the Call for Evidence regarding the Revision of EU Regulation 1025/2012 Executive summary Regulation (EU) No 1025/2012 is essential for the European Industry. VDA wel-comes the approach to revise it and would like to contribute to it, by reminding the following aspects, which are crucial for us. Link to international standardization is essential, because the European economy is global and faces international competition that drives our economy. International standards are needed for this, any contradiction with regional or European standard-ization will lead to trade barriers and make products more expensive at the expense of consumers and society. Accelerating the standardization process is crucial to meet the current highly dy-namic development of new technologies. Means to achieve this are the use of user-friendly, digital and collaborative working tools, using English through the entire standardization process and a flexible online based project coordination process. Compliance with the New Legislative Framework (NLF) has huge advantages and should be kept for effective and efficient cooperation between legislators and industry. Presumption of conformity and harmonized European standards (hEN) is sup-porting the European industry. It supports the establishment of hEN throughout Eu-rope, without any national deviations. Its legal nature should be clearly defined as technical rules supplementing regulations and laws. Existing legal uncertainties should be clearly eliminated through the revision process. The current process of Standardization Requests (SReq) to ESOs could be improved by several measures, such as early involvement of them, provisional standardization mandates and clear definition of tasks. "Common Specifications" should only become a recognized alternative in the ex-ceptional case that the ESOs fail to fulfil their task. The creation and systematic ob-servation when in place should follow clear and transparent rules. Plaese find attached our detailed position.
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VDA urges EU to simplify data sharing rules

16 Jul 2025
Topic — The EU is consulting on a strategy to streamline data-sharing laws.
Message — VDA calls for the Commission to streamline legislation and ensure legal instruments interact coherently. They suggest adopting risk-based data rules and an exemption for internal data transfers.1234
Why — This would reduce administrative burdens and provide legal certainty for connected vehicle innovation.56
Impact — Data protection authorities would lose power if their strict legal interpretations are curtailed.7
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VDA demands lower energy prices and faster grid connections

8 Jul 2025
Topic — The proposal aims to accelerate industrial decarbonisation and boost Europe's manufacturing competitiveness.
Message — The association requests faster grid expansion and lower electricity prices for manufacturing. They reject mandatory quotas for green materials and seek harmonised carbon calculations.123
Why — Lowering energy costs and avoiding mandatory quotas would protect their international market share.45
Impact — Producers of green materials lose guaranteed demand if mandatory usage quotas are scrapped.6
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Meeting with Simone Ritzek-Seidl (Cabinet of Commissioner Apostolos Tzitzikostas)

4 Jul 2025 · Automotive Action Plan

Meeting with Henna Virkkunen (Executive Vice-President) and

26 Jun 2025 · Automotive Action Plan (AAP) - pillar “Innovation and Digitalisation”

Meeting with Manfred Weber (Member of the European Parliament)

26 Jun 2025 · Politischer Austausch

Meeting with Michael Hager (Cabinet of Commissioner Valdis Dombrovskis)

25 Jun 2025 · Competitiveness of the automotive sector

Meeting with Ekaterina Zaharieva (Commissioner) and

25 Jun 2025 · Challenges for the EU automotive sector and progressing on the Industrial Action Plan for R&I related aspects

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

23 Jun 2025 · EU Automotive policy

Meeting with Leopoldo Rubinacci (Deputy Director-General Trade)

3 Jun 2025 · VDA webinar series: “America First Trade Policy – Consequences and Options for the EU and Germany”

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné)

26 May 2025 · Automotive

Meeting with Jens Gieseke (Member of the European Parliament) and Lufthansa Group

21 May 2025 · Austausch zu EU Politik

Meeting with Edoardo Turano (Head of Unit Climate Action)

20 May 2025 · CO2 emissions from plug-in hybrid vehicles

German car industry seeks simpler EU deforestation rules

13 May 2025
Topic — The EU is updating rules to prevent products linked to deforestation from being sold.
Message — The VDA requests exempting prototypes based on testing intent and specifically excluding pallets. They also advocate for a risk-based approach and minimum thresholds to reduce complexity.123
Why — These changes would lower administrative costs and simplify reporting for manufacturers and traders.45
Impact — Human rights advocates lose because legal verification would be limited strictly to deforestation risks.6
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German car industry demands clearer Euro 7 emission rules

13 May 2025
Topic — Consultation on technical requirements for monitoring vehicle emissions and type-approval procedures.
Message — The industry requires a legally secure framework with predictable conditions for development. VDA warns that current drafts are flawed and need significant technical corrections for type approval. They specifically demand precise criteria for on-board monitoring and fuel consumption systems.123
Why — Technical clarity would lower compliance costs and protect the competitiveness of future vehicle technologies.4
Impact — Public health may suffer if broader exemptions for auxiliary emission strategies weaken real-world monitoring.5
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German car industry demands changes to flawed Euro 7 rules

13 May 2025
Topic — Defining testing and approval methodologies for light-duty vehicle emission standards under Euro 7.
Message — The VDA requests clear limit values for low-temperature tests and transitional provisions for fuel consumption monitoring. They demand concrete definitions for manipulation devices to create a legally secure framework for manufacturers.12
Why — Industry members gain lower costs and more predictable development timelines through a simplified regulatory environment.3
Impact — Market surveillance authorities lose the ability to effectively enforce standards due to ambiguous testing requirements.4
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Meeting with Peter Liese (Member of the European Parliament)

30 Apr 2025 · Austausch

Meeting with Alexandra Mehnert (Member of the European Parliament, Rapporteur for opinion)

30 Apr 2025 · ELVR

Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra)

25 Apr 2025 · Automotive Action Plan and CO2 standards

Meeting with Alexandra Hild (Cabinet of Commissioner Ekaterina Zaharieva)

10 Apr 2025 · Exchange about the situation in the German and European automotive industry

Meeting with Paolo Garzotti (Acting Director Trade)

10 Apr 2025 · Exchange on the EU-Mercosur Agreement and its value for the sector

Meeting with Andreas Schwarz (Cabinet of Commissioner Ekaterina Zaharieva)

10 Apr 2025 · Exchange about the situation in the German and European automotive industry

Meeting with Sergio Oliete Josa (Head of Unit Directorate-General for International Partnerships)

9 Apr 2025 · Follow-up meeting between INTPA and VDA

Meeting with Lucie Šestáková (Cabinet of Commissioner Jozef Síkela)

27 Mar 2025 · The Position of the Automotive Industry within the Current EU Paradigm

VDA urges relief from "burdensome" green taxonomy reporting

26 Mar 2025
Topic — The consultation seeks to simplify EU sustainability reporting for companies.
Message — The association recommends making taxonomy reporting voluntary and exempting minor activities from detailed assessments. They advocate for deleting complex chemical safety rules that are extremely difficult to implement. Additionally, they request simpler reporting templates to avoid repeating data.123
Why — These proposals would significantly lower administrative costs and simplify global supply chain oversight.45
Impact — Environmental regulators would lose detailed oversight of hazardous substances used in vehicle manufacturing.6
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Meeting with Max Lemke (Head of Unit Communications Networks, Content and Technology) and Bayerische Motoren Werke Aktiengesellschaft and Mercedes-Benz Group AG

25 Mar 2025 · Automotive Action Plan

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and Bayerische Motoren Werke Aktiengesellschaft and MAHLE International GmbH

19 Mar 2025 · Future of the automotive sector

Meeting with Andreas Glück (Member of the European Parliament)

18 Mar 2025 · Climate and Environment Policy

Meeting with Norbert Lins (Member of the European Parliament)

18 Mar 2025 · Strategischen Dialog zur Zukunft der europäischen Automobilindustrie

Meeting with Max Lemke (Head of Unit Communications Networks, Content and Technology)

17 Mar 2025 · EU Digital Vehicle ecosystem

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

27 Feb 2025 · automotive

Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall)

27 Feb 2025 · Exchange of views on environment priorities

Meeting with Elisa Roller (Director Secretariat-General)

27 Feb 2025 · Automotive industry

Meeting with Eva Schultz (Cabinet of Executive Vice-President Roxana Mînzatu)

26 Feb 2025 · EVP invitation to IAA MOBILITY 9-12/09/2025 and automotive industry

Meeting with Gabriele Giudice (Cabinet of Executive Vice-President Raffaele Fitto), Vincenzo Matano (Cabinet of Executive Vice-President Raffaele Fitto)

25 Feb 2025 · Evolution of the Automotive Industry in view of the Automotive Action Plan

Meeting with Magda Kopczynska (Director-General Mobility and Transport)

21 Feb 2025 · VDA statement on the strategic dialogue on the future of the European automotive industry.

Meeting with Stéphane Séjourné (Executive Vice-President) and

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

Meeting with Bjoern Juretzki (Head of Unit Communications Networks, Content and Technology)

13 Feb 2025 · Discussion on data initiatives related to making the European car industry more competitive.

VDA urges EU to harmonize standards and vehicle approvals

31 Jan 2025
Topic — The initiative aims to deepen the single market for services and goods.
Message — VDA requests prioritizing industry-led standards over specifications created by the European Commission. They seek mutual recognition of approvals for automated vehicles to enable cross-border deployment. The association also pushes for simplified, harmonized corporate tax systems across member states.123
Why — These measures would reduce administrative burdens and streamline international vehicle production.45
Impact — National governments would lose individual control over their specific corporate tax frameworks.6
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Meeting with Svenja Hahn (Member of the European Parliament) and Deutsche Industrie- und Handelskammer and

24 Jan 2025 · Exchange on Green Claims

Meeting with Svenja Hahn (Member of the European Parliament)

23 Jan 2025 · Exchange on trade related issues

Meeting with Sergio Oliete Josa (Head of Unit Directorate-General for International Partnerships)

22 Jan 2025 · Introduction meeting between INTPA and VDA and VDA interest on the Global Gateway

Meeting with Max Lemke (Head of Unit Communications Networks, Content and Technology)

21 Jan 2025 · EU digital Vehicle Ecosystem; Global SDV development trends

Meeting with Anna Panagopoulou (Cabinet of Commissioner Apostolos Tzitzikostas)

15 Jan 2025 · Dinner discussion

Meeting with Svenja Hahn (Member of the European Parliament)

15 Jan 2025 · Exchange on current digital topics, reducing bureaucracy and legislative obstacles for SMEs

Meeting with Jens Geier (Member of the European Parliament)

14 Jan 2025 · Task and challenges for the automotive value chain

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

14 Jan 2025 · Challenges of mid-cap automotive suppliers

Meeting with Bjoern Juretzki (Head of Unit Communications Networks, Content and Technology)

14 Jan 2025 · Competitiveness of the European car industry and how digital/data initiatives can help make the European car industry more competitive.

Meeting with Max Lemke (Head of Unit Communications Networks, Content and Technology) and Volkswagen Aktiengesellschaft and

10 Jan 2025 · EU Digital Vehicle ecosystem

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and PFA - Filière Automobile Mobilités

19 Dec 2024 · Automotive sector : Euro 5

Meeting with Sophia Kircher (Member of the European Parliament) and Wirtschaftskammer Österreich and

20 Nov 2024 · Vehicle Emission Targets

Meeting with Valdis Dombrovskis (Commissioner) and Association des Constructeurs Européens d'Automobiles and

20 Nov 2024 · High Level European Car Summit, organised by EPP and ACEA. EVP Dombrovskis was invited to give a speech.

Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

20 Nov 2024 · general exchange on the current challenges in the automotive sector

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

20 Nov 2024 · Beziehungen der EU zu China und den USA, Mercosur, Rahmenbedingungen für die Transformation bis zu bürokratischen Belastungen.

VDA warns against bureaucratic double auditing of truck emissions

10 Oct 2024
Topic — The Commission is establishing procedures to verify real-world CO2 emissions from heavy-duty vehicles.
Message — End double auditing of variables already certified and introduce an introductory phase. Inform manufacturers before tests to account for customer modifications that alter vehicle performance.123
Why — This would lower compliance costs and shield manufacturers from liability for customer-led changes.45
Impact — Regulators lose the power to conduct unannounced spot checks to verify real-world performance.6
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Meeting with Erik Marquardt (Member of the European Parliament)

2 Oct 2024 · General exchange on competitiveness, transformation, new commission

Meeting with Andreas Glück (Member of the European Parliament)

1 Oct 2024 · Climate and Environment Policy

Meeting with Sabine Weyand (Director-General Trade)

1 Oct 2024 · Digital and green transformation, European competitiveness, transatlantic relations and EU-China relations.

Meeting with Marie-Agnes Strack-Zimmermann (Member of the European Parliament)

1 Oct 2024 · Exchange on EU industrial policy

Meeting with Svenja Hahn (Member of the European Parliament)

1 Oct 2024 · Implementation of regulation, competitiveness, tariffs

Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

1 Oct 2024 · General exchange on current transitional challenges

Meeting with Matthias Ecke (Member of the European Parliament)

1 Oct 2024 · Aktuelle Lage Automoblindustrie

Meeting with Andrea Wechsler (Member of the European Parliament)

30 Sept 2024 · EU Energy and Industry Policy

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

30 Sept 2024 · Exchange on European competitiveness

Meeting with Jens Gieseke (Member of the European Parliament)

30 Sept 2024 · Austausch zur Europapolitk

Meeting with Michael Bloss (Member of the European Parliament)

25 Sept 2024 · Austausch Industriepolitik

Meeting with Stine Bosse (Member of the European Parliament)

24 Sept 2024 · European industrial policy related to the automotive industry

Meeting with Angelika Niebler (Member of the European Parliament)

12 Sept 2024 · European competitiveness

Meeting with Jens Gieseke (Member of the European Parliament) and Verband Deutscher Maschinen- und Anlagenbau e.V.

16 Jul 2024 · Austausch zu Umwelt- und Verkehrspolitik

Meeting with Jens Gieseke (Member of the European Parliament) and Airbus

11 Jul 2024 · Austausch zu Verkehrspolitik

Meeting with Markus Ferber (Member of the European Parliament)

27 Jun 2024 · Transport policy in the new term

Meeting with Markus Schulte (Cabinet of Commissioner Iliana Ivanova)

19 Jun 2024 · European Research & Innovation policy and Industrial Competitiveness

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

19 Jun 2024 · current situation of the automotive industry

German Auto Body VDA Demands Delay for Heavy Vehicle Reporting

10 Jun 2024
Topic — EU consultation on extending CO2 monitoring and reporting to trailers, buses, and coaches.
Message — The VDA requests postponing the reporting start date to January 2025. They argue manufacturers need twelve months to establish reliable databases and technical processes. Existing software inconsistencies and missing data make current 2024 deadlines unrealistic.12
Why — A delay would reduce administrative burden and provide necessary lead time for implementation.34
Impact — Regulators lose access to reliable CO2 data needed to establish a policy baseline.5
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German car industry demands flexible battery carbon footprint rules

28 May 2024
Topic — This consultation defines the methodology for calculating electric vehicle battery carbon footprints.
Message — The VDA requests the acceptance of renewable energy certificates and regional electricity mixes. They demand shared data responsibilities between manufacturers and suppliers to protect confidential information.12
Why — This would protect proprietary data while allowing manufacturers to lower their reported emissions.3
Impact — Countries with clean energy grids lose their competitive advantage to coal-intensive manufacturing regions.4
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Meeting with Michael Kauch (Member of the European Parliament)

27 Apr 2024 · General exchange

Response to Options for support for R&D of dual-use technologies

26 Apr 2024

Im Rahmen der Konsultation zum Weißbuch der Europäischen Kommission für eine verstärkte Unterstützung von Forschung und Entwicklung zu Technologien mit potenziell doppeltem Verwendungszweck betont der Verband der Automobilindustrie e.V. die Berücksichtigung der folgenden Aspekte: Die deutsche Automobilindustrie begrüßt die bisherige erfolgreiche und effiziente Trennung von ziviler und militärischer Forschung im Rahmen von Horizon Europe und dem European Defense Fund. Die Definition des Automobils als nicht-militärisches Gut sollte unbedingt beibehalten werden. Wenn eine Förderung der Forschung von Technologien mit Dual-Use Potential angedacht ist, ist dazu zwingend eine Klärung der Definition sowie der erforderlichen rechtlichen und administrativen Rahmenbedingungen und Prozesse erforderlich. Auf den ersten Blick erscheint eine solche Klarstellung am einfachsten mit Option 3, der Einführung eines dezidierten Dual-Use-Funds, realisierbar allerdings sind auch hierbei Definition, Prozesse und Rahmenbedingungen zu klären. Wesentlich ist ebenfalls eine klare Allokation der Budgets für zivile, militärische und Dual-Use-Forschung.
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Response to Evaluation and revision of the Weights and Dimensions Directive

15 Apr 2024

Please find attached feedback from the German Association of the Automotive Industry (VDA).
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Meeting with Henrike Hahn (Member of the European Parliament, Shadow rapporteur) and Bundesverband deutscher Banken e.V. and

21 Mar 2024 · Critical Raw Materials

Meeting with Daniel Freund (Member of the European Parliament) and Bundesverband der Deutschen Industrie e.V. and

5 Mar 2024 · Exchange with economic associations

Meeting with Rasmus Andresen (Member of the European Parliament) and Bundesverband der Deutschen Industrie e.V. and

5 Mar 2024 · socio economic situation

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

23 Feb 2024 · Aktuelle Themen in der Europapolitik und Sachsen

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

22 Feb 2024 · Umweltpolitik

Meeting with Michael Kauch (Member of the European Parliament)

13 Feb 2024 · General exchange

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

13 Feb 2024 · Umweltpolitik

Meeting with Angelika Niebler (Member of the European Parliament) and Volkswagen Aktiengesellschaft and

30 Jan 2024 · Standard essential patents

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur)

24 Jan 2024 · Corporate Sustainability Due Diligence

Meeting with Christian Ehler (Member of the European Parliament)

24 Jan 2024 · Industrial policy

Meeting with Daniel Caspary (Member of the European Parliament)

24 Jan 2024 · Austausch

Meeting with Angelika Niebler (Member of the European Parliament)

24 Jan 2024 · EU automotive policy

Meeting with Magda Kopczynska (Director-General Mobility and Transport)

24 Jan 2024 · - State of the automotive industry - European competitiveness and industry location - Charging infrastructure – next steps AFIR - Access to vehicle data, functions and resources

Meeting with Peter Liese (Member of the European Parliament)

24 Jan 2024 · Austausch

Meeting with Sabine Weyand (Director-General Trade)

23 Jan 2024 · The automotive industry, global competitiveness and trade relations.

Meeting with Aleksandra Baranska (Cabinet of Vice-President Maroš Šefčovič)

16 Jan 2024 · Mobility

Meeting with Angelika Niebler (Member of the European Parliament)

5 Dec 2023 · Standard essential patents

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

29 Nov 2023 · Standard Essential Patents

German car association VDA urges sweeping EU reporting cuts

28 Nov 2023
Topic — EU initiative to reduce company administrative reporting requirements by 25 percent.
Message — The VDA calls for standardized databases and a Once-Only reporting principle. They demand simplified approval procedures and thresholds to exclude small shipments from reporting.123
Why — Streamlining these rules would reduce high costs and significant personnel requirements for companies.45
Impact — Public authorities and environmental groups lose detailed data on emissions and chemical safety.67
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Response to Update of standards for the 112-based eCall in-vehicle systems

24 Nov 2023

VDA greatly welcomes the urgently needed initiative of the Commission to update the references to technical standards relevant for the transmission of automotive eCall. The move from circuit-switched to packet-switched telecommunication networks is ongoing and must be reflected in the eCall regulatory framework. VDA appreciates that this is addressed in the draft Delegated Regulation and supports most of the provisions therein. On a more detailed level, there are three points where VDA sees the need for modifications, these are explained in the annex.
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German Car Industry Urges Open Circular Economy Standards

23 Nov 2023
Topic — The European Commission is revising legislative rules on vehicle design and recycling.
Message — VDA demands an open circular economy allowing chemical recycling and post-industrial waste. They advocate for harmonized international standards instead of unique European regulations. Redundant reporting requirements for circular strategies should be eliminated to reduce bureaucracy.123
Why — Using global standards would protect competitiveness and reduce unnecessary bureaucratic costs for manufacturers.45
Impact — National regulators lose the ability to control recycling market prices through state intervention.6
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Response to Revision of the Union Customs Code

6 Nov 2023

Der Verband der Automobilindustrie (VDA) bedankt sich für die Möglichkeit, den Vorschlag der Europäischen Kommission zur Überarbeitung des Zollkodex der Union kommentieren zu können. Unsere Anmerkungen finden Sie in der beigefügten Stellungnahme.
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Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

11 Oct 2023 · State of the automotive industry and competitiveness.

Meeting with Thomas Rudner (Member of the European Parliament)

8 Sept 2023 · Allgemeiner Austausch mit verschiedenen Ausstellern zu unterschiedlichen Themenbereichen der Mobilität

VDA urges quick adoption of EU patent licensing regulation

3 Aug 2023
Topic — Proposed EU regulation on the licensing of standard-essential patents across sectors.
Message — The VDA supports mandatory out-of-court settlements and the publication of global royalty rates. They call for deleting exemptions for specific standards to ensure regulatory consistency for all. They also demand easier access to expert opinions by removing restrictive participation thresholds.123
Why — This provides manufacturers with reliable cost calculations and protection from immediate patent lawsuits.45
Impact — Patent holders lose their leverage to force agreements through the threat of immediate injunctions.6
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VDA Urges Simpler CBAM Reporting to Avoid Industry Overload

11 Jul 2023
Topic — Consultation on reporting rules for the EU's new carbon border tax.
Message — The VDA requests a significant reduction in mandatory data fields and broader permission to use default carbon values. They argue the current timeline is unrealistic due to missing IT infrastructure and supplier readiness.123
Why — Automotive companies would avoid massive administrative costs and the risk of legal non-compliance.45
Impact — Environmental regulators lose the precise, installation-level data needed for accurate climate tracking.6
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German Automotive Industry Urges Flexibility in Sustainability Reporting Rules

7 Jul 2023
Topic — New standards for corporate sustainability reporting that companies must use for their environmental disclosures.
Message — The VDA requests equal treatment for net and gross emission targets. They seek exemptions for special purpose vehicles and more implementation time for subsidiaries. The group also calls for broader eligibility for carbon offsetting projects.123
Why — These changes would protect the industry's ability to refinance vehicle sales through financial instruments.45
Impact — Strict reporting requirements could collapse the public market for automotive debt securities.6
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Response to CO2 emission class of heavy-duty vehicles with trailers

30 Jun 2023

The German Association of Automotive Industry (VDA) welcomes the opportunity to comment on the proposal. Please find attached our feedback.
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German car industry urges realistic 2040 climate target paths

23 Jun 2023
Topic — The European Commission is establishing a target for 2040 greenhouse gas reductions.
Message — The VDA supports 2050 goals but demands realistic intermediate targets for 2035 and 2040. They advocate for technology neutrality and using emissions trading as the primary policy tool.123
Why — A lead emissions trading system would simplify regulations and improve the investment climate for carmakers.4
Impact — Industrial workers and the economy risk harm if targets exceed capacity or cause job losses.56
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Response to European Critical Raw Materials Act

16 Jun 2023

The German Association of the Automotive Industry (VDA) consolidates about 650 manufacturers and suppliers under one roof. The members develop and produce cars and trucks, software, trailers, superstructures, buses, parts and accessories as well as new mobility offers. We represent the interests of the automotive industry and stand for modern, future-oriented multimodal mobility on the way to climate neutrality. The VDA represents the interests of its members in politics, the media, and social groups. We work for electric mobility, climate-neutral drives, the implementation of climate targets, securing raw materials, digitization and networking as well as German engineering. We are committed to a competitive business and innovation location. Our industry ensures prosperity in Germany: More than 780,000 people are directly employed in the German automotive industry. E-mobility is the cornerstone of the automotive industry's decarbonization strategy. To achieve the ambitious goals of ramping up e-mobility, a critical amount of battery raw materials, such as lithium, nickel sulphate, graphite, manganese and cobalt, but also rare earths, such as neodymium, praseodymium, dysprosium and terbium for the permanent magnets in the traction motors are needed. In this context, the automotive industry is heavily dependent on imports from non-EU countries. To achieve better diversification and long-term stable supply of CRMs needed for the decarbonization of the transport sector, a reorientation of the European raw materials strategy is indispensable. Other major world regions are actively onshoring respective value chains to support their industries. Europe is at risk of being left behind. Therefore, the German Automotive Industry is fully committed to the goals and intentions of the European CRMA. However, we also see several shortcomings in the current proposal, which could be fixed during the following consultations. The attached paper highlights these issues and provides concrete advice and suggestions for solutions.
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Meeting with Tiemo Wölken (Member of the European Parliament)

26 May 2023 · CO2 Reduktion bei Trailer

VDA urges linking truck CO2 targets to infrastructure progress

19 May 2023
Topic — The Commission is reviewing CO2 emission standards for heavy-duty vehicles to support climate neutrality.
Message — The VDA proposes a mandatory indicator to track charging infrastructure and calls for an earlier regulatory review. They also request lower, more realistic CO2 reduction targets for trailers and new vehicle subgroups.123
Why — This prevents manufacturers from paying massive fines for infrastructure failures beyond their direct control.45
Impact — Environmental groups lose if targets are lowered to match slow infrastructure deployment across Europe.6
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VDA demands equal taxonomy treatment for automotive suppliers

3 May 2023
Topic — This initiative creates a classification system for sustainable economic activities to direct financial investment.
Message — The VDA advocates for including automotive suppliers in the taxonomy to ensure a level playing field. They argue that complex components are essential for performance and should be recognized as sustainable.12
Why — Suppliers would gain equal access to sustainable capital and avoid being structurally disadvantaged.3
Impact — Environmental groups lose if hybrid vehicle components are classified as sustainable until 2026.4
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German car industry urges flexibility in EU packaging rules

21 Apr 2023
Topic — The EU is reviewing design and recycling requirements to reduce packaging waste.
Message — The VDA requests exemptions for legacy spare parts packaging to avoid damaging sensitive components. They also urge a reconsideration of ambitious plastic recycling targets and transport re-use mandates.1234
Why — Exemptions would prevent unnecessary costs and material waste from repacking stored automotive components.5
Impact — Small packaging manufacturers may face disadvantages when competing for scarce and expensive recycled plastics.6
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Meeting with Jens Gieseke (Member of the European Parliament, Shadow rapporteur)

14 Apr 2023 · Austausch zur EU-Verkehrspolitik

Response to VAT in the Digital Age

4 Apr 2023

Sehr geehrte Damen und Herren, wir bedanken uns für die Möglichkeit zur Stellungnahme und übermitteln Ihnen anbei die Anmerkungen des Verbands der Automobilindustrie (VDA) zu dem Richtlinienvorschlag der EU-Kommission "VAT in the Digital Age".
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Meeting with Hildegard Bentele (Member of the European Parliament, Shadow rapporteur)

30 Mar 2023 · Critical Raw Materials Act

Meeting with Tiemo Wölken (Member of the European Parliament)

21 Mar 2023 · EURO VII Emission Regulation

Response to Enhancing the convergence of insolvency laws

17 Mar 2023

Dear Sir or Madam, Thank you for the opportunity to participate in the consultation. Please find the explanations in the attached document. Sincerely Ricarda Leffler
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Response to Transitional measures for smart tachograph 2 regarding its use of OSNMA

7 Mar 2023

The German Association of Automotive Industry (VDA) is representing about 650 companies in the automotive sector (vehicle manufacturers, body builders and suppliers). We are waiting for new generation of tachographs as this innovation will improve control capabilities and improve the industry as a whole. The ongoing activities to implement the new tachograph version is supported by our members, but we have fundamental concerns regarding the proposed timeline and the main objective as proposed in this draft implementing regulation. Please see our detailed comments in the attachment.
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Meeting with Viola Von Cramon-Taubadel (Member of the European Parliament)

7 Mar 2023 · Exchange between the President and a group of MEPs

Meeting with Sergey Lagodinsky (Member of the European Parliament)

7 Mar 2023 · Exchange of Views

Meeting with Kurt Vandenberghe (Director-General Climate Action)

7 Mar 2023 · introductory meeting and discussion on current automotive topics

Meeting with Andreas Glück (Member of the European Parliament)

15 Feb 2023 · Climate and Transport

German Auto Industry Urges Delay and Easing of Euro 7 Standards

9 Feb 2023
Topic — New EU regulation setting stricter emission standards for all combustion-engine vehicles.
Message — The organization requests delayed introduction dates (July 2026-2027 instead of 2025), eased limit values aligned with international standards, and completion of brake dust testing methods before implementation. They argue current requirements are technologically unfeasible and risk relocating production outside Europe.1234
Why — This would give them more development time and reduce compliance costs for new exhaust systems.567
Impact — Citizens lose faster air quality improvements from reduced vehicle emissions.8
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Response to Evaluation of the Technology Transfer Block Exemption Regulation and Guidelines

22 Dec 2022

Dear Ladies and Gentlemen, enclosed we submit our position paper on the EU-BER Technology Transfer. Regards, Dr. Ralf Scheibach, LL.M. Head of Department | Department Law and Compliance German Association of the Automotive Industry e. V. (VDA) Behrenstr. 35 | 10117 Berlin Phone: +49 30 897842 260 | +49 170 859 5672 I Mail: ralf.scheibach@vda.de VDA | www.vda.de | LinkedIn | Twitter | YouTube IAA | www.iaa.de | Facebook | LinkedIn | Twitter | YouTube
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Response to European Critical Raw Materials Act

25 Nov 2022

The German Automotive Industry fully supports the goals of the European Critical Raw Materials Act. However, the identified challenges and proposed fields of action of the European Critical Raw Material Act need to be adapted. The following challenges must be overcome: - High energy costs cause problems for refining industry - The list of Critical Raw Materials should be shortened to strategic critical raw materials - Raw material procurement should also include raw material refining and recycling - Centralized storage of strategic raw materials is the wrong strategy - Local content requirements lead to a further narrowing of the market - Changing the global commodity market requires large-scale stimulus from political institutions - Raw material procurement is not only promoted by an ECRM Act - Closing material loops is not a lifeline - Promoting existing ESG-standards for mining and refining Strengthening the three pillars of sustainable raw material In order to master the challenges, the German automotive industry recommends the following instruments: 1. Expand existing raw material partnerships with raw materialrich third countries 2. Accelerate negotiation and ratification of free trade agreements 3. Establish a European agency for strategic mining projects and a Eu-ropean raw material fund 4. Improve the location conditions for the refining industry in Europe 5. Intensify the support for the circular economy in the transformation towards recycling of electric vehicles 6. Continue and expand the support for research and development 7. Counter illegal disposal of end-of-life vehicles and strengthen certi-fied recycling companies 8. Ensure environmentally compatible export of vehicles 9. Collect raw CO2 data on secondary raw materials and materials In the Document attached you will find further information on what the challanges are and how the instrument should be implemented to have an impact.
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

8 Nov 2022 · Venue of President to Brussels- discuss state of play of Data, Euro 7, energy crisis, supply shortages

VDA calls for flexible greenhouse gas rules for synthetic fuels

17 Jun 2022
Topic — The consultation concerns methodology for calculating greenhouse gas savings from renewable transport fuels.
Message — VDA requests including industrial CO2 sources from outside the EU ETS. They want carbon capture at unavoidable sources permitted after 2036. The association suggests using energy content to allocate greenhouse gas emissions.123
Why — This would lower administrative burdens and expand the availability of industrial carbon sources.45
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Meeting with Johannes Hahn (Commissioner)

16 Jun 2022 · Green transition, strategic autonomy, supply chain disruptions, ETS

Meeting with Thierry Breton (Commissioner) and

16 Jun 2022 · Green and digital transition of the automotive industry; raw materials availability

Meeting with Dārta Tentere (Cabinet of Commissioner Mairead Mcguinness), Peter Power (Cabinet of Commissioner Mairead Mcguinness)

16 Jun 2022 · Sanctions

Meeting with Henrik Hololei (Director-General Mobility and Transport)

15 Jun 2022 · Situation of automotive industry; Fit for 55

Meeting with Jens Gieseke (Member of the European Parliament)

15 Jun 2022 · Austausch zur Verkehrspolitik

German auto industry urges limits on corporate sustainability liability

23 May 2022
Topic — EU proposal requiring companies to identify and mitigate environmental and human rights risks.
Message — The VDA demands higher employee thresholds to exempt smaller firms from regulation. They also argue against extending due diligence to the entire value chain and opposing civil liability.123
Why — These changes would reduce administrative costs and shield companies from potential legal disputes.45
Impact — Human rights victims and environmental groups would lose legal avenues for corporate compensation.6
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German car industry warns Data Act could stifle innovation

13 May 2022
Topic — New EU regulation aimed at facilitating data access across the digital economy.
Message — The VDA requests a narrower definition of data that excludes internal vehicle functions. They demand strong protections for trade secrets and a longer implementation timeline for manufacturers.123
Why — This would protect their technical investments and avoid excessive data processing costs.4
Impact — Independent service providers would lose access to essential internal vehicle sensor data.5
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German car industry demands parallel national and EU approvals

4 May 2022
Topic — New technical rules for the type-approval of fully automated vehicles and driving systems.
Message — The VDA wants national approval laws to remain valid alongside the new European framework. This would allow countries to pilot new technologies and approve larger numbers of vehicles locally.12
Why — Maintaining national approvals allows German manufacturers to sell more automated cars than EU limits permit.34
Impact — The European Single Market loses its uniform regulatory environment if national and EU standards coexist.5
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Response to Technical requirements for unlimited series, small series, special purpose vehicles and fully automated vehicles

19 Apr 2022

The German automobile industry welcomes the development of a European Framework for the approval of fully automated vehicles, as it is an important step towards making the benefits of automated mobility available to European Citizens and strengthening the EU’s attractiveness as a center of commerce and innovation. However the VDA would like to address the following concern: 1. National approvals (with effect for national territories) have to remain possible Germany already has developed national legislation for the national approval of fully automated vehicles limited to German territory. Other Member States are working on similar legislation or might be interested to do so in the future. Should the EU adopt the amendments in their current form, the EU law might be interpreted to block any national legislation addressing the approval of such vehicles, since the EU law in general takes primacy over national law. From the point of view of VDA this is very problematic as it would thwart the goals of both the EU as well as the national legislation to promote the deployment of fully automated vehicles and strengthen the EU as a center of commerce and innovation: • The EU draft is limited to a small series deployment. For many use cases, these numbers are insufficient. From the point of view of VDA there is no reason to hinder Member States from approving of use cases that might require larger amounts of vehicles as long as it is ensured that the ADS only operates on their territories. • The EU draft is limited to specific use cases. However in the future additional use cases might be developed. As new technology emerges, Member States need the possibility to “pilot” new functionalities on their territories. The experiences gained on a national level could then serve as a basis for developing an EU harmonized framework. It is therefore submitted to clarify that the drafts are without prejudice to national solutions with effect limited to national territories, so that a harmonized frame for EU Small Series Type Approval and national solutions could exist in parallel. 2. Unclarities in Recital 7 As the safety of operation is primarily addressed by the technical requirements in the delegated act, Recital 7 in its current form could be misunderstood as to allow for Member States to place additional (technical) requirements on fully automated vehicles that are EU type approved, even for topics already addressed by the delegated act. This has to be avoided, as it would counteract the goal of harmonization. On the other hand, the approval of national operational areas can take appropriately only place on the national level (and it is the assumption of the VDA that this is what Recital 7 aims to address). The VDA therefore suggests to modify Recital 7 accordingly. 3. Limited legal effect It is further noted that addressing the possibility of national legislation in Recital 7 might be insufficient, as Recitals are rather explanatory and do not take full legal effect. The modifications mentioned in Sections 1. and 2. should therefore be moved to the legally binding sections of the regulation.
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Response to Commission Regulation on the influence of heavy-duty trailers on the CO2 emissions of towing trucks

14 Apr 2022

VDA – the German Association of the Automotive Industry e.V. – represents more than 600 companies along the automotive value chains, manufactures of cars, trucks, and busses, suppliers, and manufactures of bodies, and trailers. About 800,000 employees are working in the automotive industry in Germany. VDA recognizes the importance of further steps for CO2 reduction by considering potentials to optimize trailers and we would like to give the following comments (please see attached document).
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Response to Revision of the Intelligent Transport Systems Directive

17 Mar 2022

Please find attached VDA's feedback to the public consultation.
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Response to Review of the CO2 emission standards for heavy-duty vehicles

14 Mar 2022

The forecast predicts a growing haulage capacity in Europe with the need for fossil-free transportation modes. In Europe about three third of goods are transported on roads by light and heavy duty vehicles. Stringent CO2 reduction targets for Heavy Duty Vehicles (HDV) will contribute to the objective to reduce overall CO2 emissions by 55% by 2030 and to reach climate neutrality until 2050. The industry is focusing on providing reliable, efficient, and affordable zero emission vehicles. However, ICE-based vehicles in the heavy duty segment are still dominating the market and are needed for certain segments. Therefore, ambitious goals have to be defined to support the transition in the road transport sector. In this context the VDA sees a strong need to strengthen the activities for a set-up of charging and H2-refilling infrastructure for HDV and buses all over Europe. The timeframe 2025-2030 is sensitive as the ZEV market development depends on growing infrastructure. Especially the targets for 2030 and beyond must correlate with the existing charging- and H2-infrastructure. We support ambitious, but technically and economically feasible targets. Freight-/passenger transport must remain functional, affordable and continue to cover all necessary use cases. Industry needs a stable framework to manage the transition. CO2-targets should account for TCO, lead times and sector readiness as well as technology availabilities. New technologies become available in the market mainly in the 2nd half of the 2020s. Targets must distinguish between vehicle classes due to different use cases and technology options. Revised CO2-targets should be structured to avoid unintended market shifts between vehicle classes. The development of the freight and passenger transport sector, the range of BEV, grid development and electricity supply should be monitored, and long-term targets have to be re-assessed by the end of the 2020s. Higher incentives are necessary to support the market uptake of ZLEV and ZEV and compensate the missing market pull, which is especially important for the deployment of long-haul vehicles. The ZEV benchmark (2% in 2025, cap 5%) was set to stimulate the ZEV deployment. Higher CO2 reduction target requires a higher ZEV share, beyond the current benchmark. H2-ICE should be considered as ZEV and part of an incentive system as well as trailer technologies. The CO2 regulation shall remain open for a variety of ZLEV technology options and shall respect necessary boundary conditions (mandatory EU-wide alternative infrastructure deployment, availability of renewable electricity/Green-Hydrogen, CO2 pricing for fuels, Eurovignette and other consumer incentives). Any funds should be invested in charging/refueling infrastructure and market incentives. In addition, revenues should be used as purchase incentives to reduce the higher costs of ZLEV and encourage their market uptake, as well as to support research & development and the transformation within industry; e.g. for requalification measures.
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Response to Evaluation and revision of the Weights and Dimensions Directive

18 Feb 2022

The VDA represents the interests of the entire German automotive industry: manufacturers of passenger cars, trucks and buses, as well as suppliers and the manufacturers of trailers and bodies. In the Sustainable and Smart Mobility Strategy (SSMS) published by the Commission on December 9, 2020, the Commission committed to beginning preparatory work on a possible legislative proposal to revise the Weights and Dimensions Directive/Regulation. The German Association of the Automotive Industry welcomes the initiative now launched to evaluate Directive 96/53/EC, which sets the standards for maximum permissible weights and dimensions in cross-border transport. We would like to participate in this process and contribute concrete proposals that have been developed with various trailer, body and truck manufacturers in order to support the achievement of the Smart Mobility Strategy's climate goals. We would like to take up the points listed in the initiative and comment on them (please see details in attached pdf-file)
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Meeting with Walter Goetz (Cabinet of Commissioner Adina Vălean)

3 Feb 2022 · Automotive industry

Response to Maximum dimensions and weights in national and international traffic for certain road vehicles circulating within Union

28 Jan 2022

The German Association of the Automotive Industry welcomes the proposal to codify the Masses and Dimensions Directive in order to create clarity and transparency. In its Sustainable and Smart Mobility Strategy (SSMS) published on 9 Dec 2020, the Commission indicated to start preparatory work for a possible legislative proposal for the revision of the Weights & Dimensions Directive. For the planned revision of this directive, the VDA would like submit concrete proposals amending the Weights & Dimensions Directive to achieve the climate targets of the Smart Mobility Strategy. In our view, it is important to update the guidelines regularly in order to allow the use of new technologies and to consider further design developments. Since 1996 many vehicle configurations came into operation, that should be standardized for EU. Examples are four axle busses systems, or twin and triple axles systems in combination of steering and drive axles. It is essential that any revision take into account the diverse perspectives of the industries affected by any change. It is also important to consider an economic impact assessment. We would like to support this initiative to develop a long-term stable legal framework for all vehicle manufacturers and suppliers. Furthermore, we see a need for more concrete amendments on the planned revision of the masses and dimensions directive, e.g.: Increasing the maximum permissible weight in cross-border traffic to 44 tons is an important contribution to climate protection and to reducing the traffic load. In this context, we would also like to recommend analyzing the differences between EU vehicle weight requirements and national maximum axle weight regulations. We consider it will be necessary to advance a uniform regulation for the use of the European Modular System (EMS) in order to facilitate approval throughout Europe and to adapt the dimensional criteria for EMS transports (e.g. maneuverability and overall length), taking into account the special features of the individual countries. It would also be important to define exemptions in vehicle length and vehicle width for all fuel-saving and CO2-reducing measures. The use of vehicle technologies that can help to improve the CO2 balance should also not result in the vehicle's payload being negatively affected due to the additional weight of these technologies.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

With “Fit for 55,” the European Commission has presented a comprehensive package aimed at reshaping the European Union’s climate policy. The German automotive industry supports the goal of making road traffic climate-neutral by 2050 at the latest and welcomes the revision of the Renewable Energy Directive (RED) – especially the introduction of GHG-mitigation quota. However, the proposal lacks ambition: - The GHG-mitigation quota should be raised to 40% for 2030 - A 30% quota for renewable fuels should be introduced for 2030 - The sub-quota for RBNBO should become effective earlier as a stepstone to a much higher quota in 2030 A detailed position regarding the proposed legislation can be drawn from the attached document.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

With the "Fit for 55" package, the Commission has presented a comprehensive legal package aimed at reshaping the EU's climate policy. The German automotive industry supports the goal of making road transport climate-neutral by 2050 at the latest. However, the individual instruments proposed by the Commission are not sufficiently coordinated and the targets are more ambitious than the willingness to provide the necessary framework conditions. German carmakers and suppliers support above all the principle of more overarching, market-based incentive systems in climate policy. We therefore welcome the proposal to introduce a separate emissions trading system for transport and buildings in the EU. We welcome as well the Commission’s proposal to revise the EU Energy Tax Directive (ETD), which has remained unchanged since 2003. However, the following recommendations should be considered in the further legislative process: Art. 1 paragraph 2 - Taxation based on energy content: The new systematic approach of basing taxation on energy content and environmental impact is a viable way of achieving the targets of the revised ETD. Art. 3 – Uses outside the scope: We welcome the exclusion of certain uses from the scope of the Directive. However, in particular electricity for electrolysis should be granted mandatory tax exemptions, as this is of utmost importance for the production of green hydrogen. Art. 5 paragraph 1 – Implementation of the minimum tax rate ranking into national law: According to the Commission’s proposal the Member States shall ensure that the minimum tax rate ranking set out in Annex I is implemented into the national tax codes according to product and intended use. This could lead to significant increases in the tax rate for diesel fuels in Germany. As a consequence, the relationship between the prices of gasoline and diesel would be reversed from 2023. Art. 5 paragraph 1 – Optional special taxation of e-mobility: Member States may set a specific tax rate for electricity used for charging electric vehicles. In order not to jeopardize the market ramp-up of e-mobility and the achievement of climate targets it should be ensured that only a separate taxation of e-mobility with a relieving effect is permissible. Art. 5 paragraph 2 – Indexation of minimum tax rates: As of 1/1/2024, the draft provides for an automated annual adjustment of the minimum tax rates to the development of consumer prices. However, this would lead to automatic tax increases every year and significantly increase the administrative burden for companies (e.g. in regard to applications for tax exemptions and reductions). An annual adjustment of the minimum tax rates is therefore not expedient. Art. 16 d) – Tax incentives for sustainable fuels: According to the draft, Member States may exempt or grant tax incentives for renewable hydrogen, sustainable biofuels, e-fuels and e-gas, among others. To ensure that the climate protection targets can also be achieved for existing vehicles with internal combustion engines, tax concessions for sustainable fuels should be made mandatory for the member states. Art. 22 paragraph 4 – Exemption for electricity storage equipment and transformers: We welcome the new exemption for electricity storage facilities and transformers that are considered redistributors when supplying electricity. Furthermore, double taxation should also be avoided in the case of electric vehicles (mobile electricity storage). Avoiding double burdens and increasing legal certainty: The Impact Assessment does not examine the effects of the interaction between new regulations in the ETD and other instruments at national and European level (e.g. SESTA – German Fuel Emissions Trading Act, EU ETS, CO2-based Eurovignette). However, these interactions should be carefully analyzed in the further legislative process in order to avoid double burdens. Furthermore, more attention should be paid to legal certainty and to reducing tax complexity.
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Meeting with Adina-Ioana Vălean (Commissioner)

16 Nov 2021 · Meeting CEO

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

16 Nov 2021 · Discuss Euro 7 and access to in-vehicle data.

Response to Carbon Border Adjustment Mechanism

15 Nov 2021

The EU can and should play a leading role in climate policy. Until a global emissions trading system is established, however, exceptionally ambitious EU climate targets could lead to competitive disadvantages for European industry in global trade. Against this background, the introduction of a carbon border adjustment mechanism (CBAM) such as that proposed by the European Commission is an obvious way of compensating for different levels of climate policy ambition and the associated competitive disadvantages. The priorities from the point of view of the automotive industry In view of the importance of fair competition, we generally welcome political instruments that lead to a global level playing field. Properly designed, the CBAM can help to reduce the risk of carbon leakage and the transfer of companies, production sites and emissions abroad. Furthermore, the CBAM can contribute to the future introduction of a global emissions trading scheme. While this represents a major challenge, it must nevertheless be the overriding goal of European climate policy. In the best-case scenario, the introduction of the CBAM will go hand in hand with an agreement on minimum carbon-pricing at the G20 level. When it comes to the concrete design of the CBAM, the CBAM will contribute to achieving the goals of the Paris Climate Agreement if it is WTO-compliant and accepted by all relevant trading partners. Trade policy considerations must therefore be sufficiently taken into account, though without compromising its effectiveness. To avoid any kind of distortion in international trade such as a protectionist pushback, the CBAM should therefore be introduced, if possible, in close consultation with trading partners. If these conditions are met CBAM can become a suitable instrument for ensuring fair competition in times of different levels of climate policy ambition. In this respect, the Commission’s proposal is going in the right direction, but needs further clarification: - The planned phased introduction of the CBAM, its limited initial application to a few carbon-intensive commodities such as steel and aluminum and the envisaged test phase without any payment obligations duly reflect the complexity of the instrument. The envisaged transition period for gradually phasing out the free allocation of certificates may be too long. - Although it is planned that the carbon prices paid in the country of origin will be taken into account when determining the border adjustment, it remains unclear whether and to what extent other climate policy instruments, energy taxes or regulatory requirements will also be properly considered. This issue requires further clarification, as does the method for calculating the carbon content, so that no border adjustment needs to be levied for imported goods from countries of origin with different framework conditions but comparable levels of climate policy ambition. - In view of criticism from important trading partners, the compatibility of the CBAM with WTO rules and existing EU free trade agreements needs to be better addressed, for example as regards the gradual phasing-out of the free allocation of certificates or the use of the expected revenues. When it comes to the further development of the CBAM via delegated legal acts, transparent decision-making processes are required. - Determining the carbon emission intensity of import products based on the efficiency of the lowest-performing EU plants may in some cases be inappropriate; the determination of the default values should therefore be subject to further examination. - To accurately assess the impact on industry, including potential price increases and mounting bureaucratic requirements, the final proposals should be subject to an impact assessment. - In addition to the long-term transition to a global emissions trading scheme, carbon contracts for difference should be increasingly used to stimulate investment in climate-friendly production technolies.
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Response to Revision of Alternative Fuels Infrastructure Directive

15 Nov 2021

In order to achieve the more stringent fleet targets and the necessary scaling-up of e-mobility, a binding, rapid and comprehensive expansion of the charging infrastructure (CI) across Europe is essential. We welcome the fact that the COM plans to use the legal instrument of a regulation to provide a firm legal basis for the accelerated expansion of the CI for EVs in the member states. However, the COM´s targets of 1 million charging points (CP) by 2025 and 3.5 million CPs by 2030 across the EU are far too modest. In view of the uneven distribution of the CI, far greater efforts and clear targets are needed for the period up to 2035. Following changes are required More ambitious targets for the charging and refueling infrastructure are needed Increase charging capacity per BEV/PHEV We support the allocation of dedicated charging capacities per registered BEV/PHEV. However, the capacity of 1 kW per BEV and 0.66 kW per PHEV is clearly too low. Based on realistic assumptions about the energy consumption of EVs and the share of public charging operations, the charging capacity should be 3 kW per BEV and 2 kW per PHEV. Strengthen CI along the TEN-T network To ensure that sufficient charging options will become available in the future, the maximum distance between charging stations (CS) for cars and vans should be reduced to 40 km. In view of increasing requirements for fast charging, the capacity of CS should be doubled, and they should also include at least one 350 kW CP. The large-scale expansion of the CI for HDV and coaches is also of particular importance for ensuring both the trade of goods and the transport of passengers in Europe (appendix). Ensure a basic level of service In order to meet the demand for a comprehensive public CI, especially in urban areas, it is not sufficient to provide CPs based solely on the number of vehicles and to focus only on the TEN-T networks. For this reason, a minimum level of service should be established at country level, both as a whole and for metropolitan areas (for example, based on the number of inhabitants or the total number of vehicles), alongside the right for users to have access to a CP in the vicinity of their place of residence (in km or minutes). Set up user-oriented CI To make charging at third-party charging stations as easy as possible, roaming should be made mandatory. In addition, all CS should be built in accordance with the ISO 15118 standard, not least so that automated payment is possible across Europe using the payment data stored in the vehicle. Strengthen hydrogen infrastructure along the TEN-T network Setting up an infrastructure for the provision of hydrogen also requires improvements. From the start, the respective refueling stations should be designed in such a way that they can be used by all vehicle categories. The planned targets (a minimum capacity of 2 t/day with at least 700 bar by 2030) should be brought forward to 2027 across the entire TEN-T network. Furthermore, it would also make sense to specify a maximum distance of 100 km instead of 150 kilometers and to give sufficient consideration to the supply of liquid hydrogen. Additional requirements In order to set up a comprehensive, pan-European network of standard and fast CS as quickly as possible, AFIR must be supplemented by funding programs, especially in countries that have so far built hardly any CI. This must also include programs for promoting private and commercial charging solutions, for example for charging at home or at the workplace. These programs must be coordinated at EU level and implemented in all member states. In this regard, the revision of the EPBD can make an important contribution by cutting red tape and setting ambitious targets. This should also include a “right to plug,” as is already the case in Germany. Last but not least, member states must ensure that cheap, 100 % green electricity is available in sufficient quantities for charging EVs in the future.
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Response to Revision of the specifications for EU-wide real-time traffic information services (Delegated Regulation 2015/962)

9 Nov 2021

Please find attached the response of the Verband der Automobilindustrie (VDA) to the public consultation on the proposed revised Delegated Regulation on Real Time Traffic Information.
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German Auto Industry Warns Against 2035 Combustion Engine Ban

5 Nov 2021
Topic — EU regulation strengthening CO2 emission standards for new cars and vans.
Message — The industry supports the 2030 targets but demands rapid, binding expansion of charging infrastructure and coordinated EU-wide support programs for electric vehicles. They reject the proposed 2035 zero-emission target as a technology ban and want the post-2030 targets delayed until 2028 based on infrastructure progress.123
Why — This would give manufacturers more time to adapt while avoiding mandatory phase-out of profitable combustion engine models.45
Impact — Climate advocates lose faster emissions reductions and face continued fossil fuel vehicle sales.6
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Response to Updating the EU Emissions Trading System

5 Nov 2021

With “Fit for 55,” the European Commission has presented a comprehensive package aimed at reshaping the European Union’s climate policy. Among other things, the Commission’s proposal envisages the introduction of a separate emissions trading system (ETS) for road transport and buildings (ETS-2) from 2026, alongside the existing EU ETS for the energy and industry sectors. The aim is also to include fuel distributors in ETS-2. The Commission has proposed reduction targets of around 5 percent per year, without setting any minimum price. In the future, it is planned to merge the new scheme with the EU ETS to form a single emissions trading system. ETS-2: a key element in reducing the GHG emissions of road transport The main features of the Commission’s proposal correspond to the VDA’s recommendations and are thus to be welcomed. An effective carbon price based on reliable quantitative limits can provide clear investment signals and thus help steer the entire road transport sector toward greater sustainability. By means of a uniform price signal, all actors in the supply chain – from raw materials to fuel and recycling – will be equally involved in achieving the EU’s climate targets. At the same time, this will also provide a clear price signal for consumers. As a result, the ETS acts as an instrument to accelerate decarbonization throughout the value chain and can serve as a market-based driver of climate neutrality in the road transport sector. The planned launch of ETS-2 supports efforts to scale up electromobility by creating incentives for the purchase of electric vehicles. At the same time, it ensures that production capacities for renewable fuels (advanced biofuels and eFuels) will be created. These fuels are important because they also enable existing vehicles with internal combustion engines to make a significant contribution to reducing the CO2 emissions of the road transport sector. One issue that still needs to be resolved is the extent to which the road transport sector will be included in the Effort Sharing Regulation (ESR). Set a binding deadline for the merger with the existing ETS In the long term, merging the two ETS emissions trading systems has the advantage that CO2 emissions can be reduced wherever it is most cost-effective to do so. A binding deadline should be set for the transition to a uniform EU emissions trading system in order to prepare markets for a timely and predictable merger. A price corridor that needs to be gradually reduced should make it easier for both systems to be merged at a later date. Unfortunately, the Commission proposal lacks a specific timetable for such a merger with the existing ETS. The target date for merging the two systems should be the start of the fifth trading period, beginning in 2030. Use revenues from ETS-2 in a targeted manner for transformation and social mitigation measures The introduction of emissions trading for road transport and buildings will generate substantial revenues. How these funds will be used will play a crucial role in the success of the transformation of the automotive industry. It is therefore important that the revenues are earmarked for measures that accelerate the transformation. Where necessary, and provided that this is compatible with the desired incentive effect, they should also be used for social impact mitigation. In the interest of social acceptance, we therefore welcome the Commission’s plan to set up a social climate fund for the period from 2025, which would receive 25 percent of the revenues expected from the auctioning of certificates by the individual member states. It will also be crucial for the success of ETS-2 that the member states use the remaining revenues to drive the transformation of the automotive industry, the roll-out of alternative drive systems and renewable fuels, and, above all, the expansion of the charging infrastructure.
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Meeting with Barbara Glowacka (Cabinet of Commissioner Kadri Simson), Laure Chapuis (Cabinet of Commissioner Kadri Simson)

27 Sept 2021 · VDA Position Paper "Fit for 55" and info study regarding the effects of electromobility on employment in Germany.

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

23 Jun 2021 · VDA would like to discuss the level of ambition of the CO2 proposal and interplay with Euro 7

Response to Technical requirements and test procedure for approval of intelligent speed assistance (ISA)

28 Apr 2021

General VDA supports road traffic safety to reduce deaths and injuries. Different systems, which inform the driver about the given speed limit, are already established in the market. Regulation should allow competition of different technical solutions to ensure further innovation. The Intelligent Speed Assistance (ISA), which will be mandatory for vehicle categories M1, N1, M2, N2, M3 and N3 by 6th of July 2022 for new types and 7th of July 2024 for all types in Europe, supports to avoid speeding above the given speed limit. Inappropriate speeding below the given speed limit will not be detected by ISA. We kindly ask for a fair investigation, which potentials are covered by ISA. Assistance systems should support drivers and should not distract them from various traffic situations. Regarding the current traffic situation, drivers are responsible to choose the appropriate speed at or under the given speed limit. Concerns Manufacturers create HMI-concepts to inform and assist drivers without distracting them. This is a major development goal and important for road traffic safety. Visual warning is state-of-art, accepted by the customers and a dedicated, appropriate and effective feedback. This was shown in several consultations and is based on scientific investigations. The required warning in the current draft will result in a high switch-of-rate by the customers. Possibility to reduce speeding above the given speed limit is thrown away. Requirements of new article 4 are not clear. Instead of article 4, an evaluation together with needed stakeholders could be done to improve this regulation in future. The sign catalogue is not complete and not logical. Cost benefit calculation of ISA based on camera-only-systems. Even latest camera-only-technology will not fulfill the requirements in the current draft. As consequence this regulation is in addition with other cost-intensive requirements very expensive. As other stakeholders, we would suggest reducing the mandatory 14 years life cycle performance to 6 years. A validation of this regulation in a real-world-test was never done. Every regulation must prove that intended goals will be achieved. Road traffic safety is a system approach, we as VDA and our members are willing to support and take over our responsibility. Other involved stakeholders of the whole system should be also involved to enhance road traffic safety. Thank you very much!
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Response to Technical specifications for the construction and type-approval of the second version of the smart tachograph

23 Mar 2021

The German Association of Automotive Industry (VDA) would like to thank the European Commission for the possibility to express our views on the upcoming legislation for the new smart tachograph generation (version 2). We are very much aware of the intensive work EU COM and other stakeholders have put in to reach this milestone. The German Association of Automotive Industry (VDA) would like to draw the European legislator’s attention to some specific issues for the bodybuilding industry, around the intended application date of this proposal and the impact it has on the bodybuilders who construct vehicles as a second (or subsequent) stage of vehicle type approval. Unfortunately, bodybuilding industry and truck manufacturers have already faced a very difficult situation during the introduction of the smart tachographs (version 1) in 2019, when the very short lead time, combined with a delay in finalizing the technical requirements, led to substantial hurdles and extra costs for industry for the in-vehicle validation tests and timely roll-out of the final device. In Germany, numerous vehicles had to be retrofitted with the new smart tachograph in 2019 because they were not registered in time before the deadline. In addition, body builders were sometimes forced to pre-register unfinished vehicles. In some cases, German authorities had to grant exemptions for the installation of the new smart tachograph. The German Association of Automotive Industry (VDA) would like to express its support to CLCCR’s recommendation towards the European legislators to introduce a split into the proposed entry into force date and/or the date of application for vehicles built through the ‘multi-stage’ process. Furthermore, a dedicated lead time of 12 months from the time of type approval of tachographs until their mandatory presence in newly registered vehicles would consider the current pandemic situation and the lessons learned from 2019. In addition, the German Association of Automotive Industry (VDA) is requesting some clarification for the recording activities of the tachograph in buses/coaches. As defined in the regulation (EU) 165/2014 the position of the vehicle shall be recorded automatically every time the vehicle performs loading or unloading activities. The smart tachograph shall also record whether the vehicle has been employed for the carriage of goods or passengers, as required by Regulation (EC) No 561/2006. Are loading/unloading activities in coaches/buses equatable with the embarking/disembarking of passengers? Does the tachograph in buses/coaches has to register the vehicle position where passengers enter or leave the bus/coach for a break or permanently?
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Response to Modernising the EU’s batteries legislation

26 Feb 2021

The German Association of the Automotive Industry (VDA) represents more than 600 companies in the automotive industry - manufacturers of motor vehicles and their engines, set-ups, installations, containers and vehicle parts and equipment - which produce in Germany. The automotive industry is the highest-turnover branch and generated a revenue of more than 435 billion euros in 2019. Approximately 833,000 employees manufactured about 4.7 million cars in Germany - from 16 million cars worldwide. This does not include commercial vehicles (trucks and buses) produced by our member companies. Together we research and produce for a clean, safe, and sustainable mobility of the future. The German automotive industry is fully aware of its responsibility throughout the entire cycle of a car’s production and use. Therefore, the VDA supports the goal of the European Commission to reduce waste and foster the reuse of resources. All political initiatives should be directly linked to the primary goal of the European Union to achieve climate neutrality until 2050. However, the European Green Deal and the European Directive on Waste must be considered in a differentiated way. The VDA recommends that electric vehicle batteries must be treated completely independently of other battery categories in a separate chapter. Existing legislation should be taken into account which is already being planned or revised, e.g. the End-of-Life Vehicles Directive. There is a need for a separate chapter on electric vehicle batteries: The vehicle is placed on the market as a holistic product by car manufacturers and can therefore only be treated as a holistic product due to the manufacturer responsibility. The new chapter on electric vehicle batteries must regulate the transition from a second life electric vehicle battery to a stationary, industrial battery. Guiding principles for the revision of future regulations in context of electric mobility: - Promoting markets and innovation - Preferring European and international standardization over implementing acts - Protecting intellectual property - Regulation must promote the achievement of climate objectives - Consider functional unit of electric vehicle and electric vehicle battery - Considering the complexity and dynamic development of batteries Attached is the VDA comment on the draft regulation.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

The VDA and its members aim at a substantial and holistic reduction of GHG-emissions on the pathway towards a climate neutral economy in 2050. The European Green Deal proposes several significant changes in climate protection policy. Increasing the speed in the transition towards a climate neutral world requires a shift in the regulatory logic and appropriate measures – it cannot be achieved with a continuation of current instruments. In the transport sector, the current approach of regulation, is neither effective in terms of reaching the climate goal, nor efficient in terms of least cost avoidance. The desired mitigation cannot be reached solely by CO2 reduction of new cars, and avoidance cost is completely out of scope, compared to other sectors. A clear pathway towards an extensive and market-based emission trading system covering all sectors would solve this problem. In the interest of a reliable achievement of the climate goals, the VDA welcomes the recent communications by the Commission which opens for the idea of an expanded emission trading system and would like to encourage the installation of a powerful and comprehensive emissions trading system (ETS) for a 2030 ambition level setting and a prospective policy design towards 2050. Principles of an emission trading system: 1. CO2 pricing should become a crucial basis and core element of defossilisation in Europe to support the transformation towards carbon neutrality by differentiating between fossil and renewable energy carriers. 2. A clear pathway towards an extensive and market-based emission trading system (ETS) covering all sectors should be established. A consequent introduction of an ETS is the only approach, which guarantees both effectiveness as well as efficiency. Further, due to the extension of ETS more participants will pay for allowances. That means all sectors participate in the financing the defossilisation. 3. An emission trading system should set a pathway towards 2050. The number of GHG allowances (“CAP”) should be aligned towards this goal stepwise for the upcoming years, there should be a free market for allowances (“TRADE”). 4. Climate protection costs money and requires effort in terms of investment and innovation, but it is money well spent. The function of an ETS is to minimize these costs to a necessary amount (“least cost avoidance”). 5. A clear commitment towards a substantial price signal can ensure long-term planning certainty and can thus spur investment in green technology. 6. In order to reduce these costs, a future ETS should include as many emissions (sectors) as possible and should be designed towards a gradual spatial (worldwide) expansion. 7. The ETS should consider (only) the fossil carbon content of all energy carriers. Renewable energy must be exempt from the allowance requirement due to its irrelevance for climate change. 8. A convergence between ETS and energy tax systems should be aimed for. However, in a long-term perspective, only one overarching system for the whole European Union should set a price for CO2 emissions and that should be the ETS. 9. The administrational overhead should be minimized as far as possible. Therefore, an upstream-approach is favoured. 10. Transitional elements (a “bridge” between today and the future) with ambitious targets are required, which take existing national schemes into account and lead to a harmonised CO2-price and planning security for industry and customers. At the end of the transition period an alignment to the EU ETS ambition level must be achieved. This includes appropriate measures to prevent carbon-leakage. 11. The long-term goal must be to replace sector specific climate goals and regulations across EU Member States with one overarching EU ETS target for all sectors.
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German automotive industry demands technology-neutral framework and infrastructure investment

26 Nov 2020
Topic — Revision of the CO2 emission standards for cars and vans to achieve climate neutrality.
Message — The organization calls for a technology-neutral regulatory framework that includes investments in charging infrastructure and the use of alternative fuels. They request a thorough impact assessment that considers social and economic consequences before tightening any emission targets.123
Why — These measures would protect existing jobs and help the industry maintain its market position during the transition.45
Impact — Automotive workers and medium-sized suppliers face significant risks from rapid regulatory shifts without support.67
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Response to Revision of EU legislation on end-of-life vehicles

18 Nov 2020

The Association of the Automotive Industry (VDA) represents more than 600 companies in the automotive industry -manufacturers of motor vehicles and their engines, set-ups, installations, containers and vehicle parts and equipment -which produce in Germany. The automotive industry is the highest-turnover branch and generated a revenue of more than 435 billion euros in 2019. Approximately 833,000 employees manufactured about 4.7 million cars in Germany -from 16 million cars worldwide. This does not include commercial vehicles (trucks and buses) produced by our member companies. Together we research and produce for a clean, safe, and sustainable mobility of the future. The German automotive industry is fully aware of its responsibility throughout the entire cycle of a car’s production and use. Therefore, the VDA supports the goal of the European Commission to reduce waste and foster the reuse of resources. All political initiatives should be directly linked to the primary goal of the European Union to achieve climate neutrality until 2050. Overall, the current ELV Directive is a success story. Only slight improvement is needed to sustain the Directive for future requirements. The VDA will support this process. The automotive industry is pioneer for circular economy Due to the ELV Directive a high-quality, certified take-back and recycling network for ELVs has been established in Europe by car manufactures and its business partners. In this network takeback is free of charge for the last holder and an environment friendly treatment of ELVs is guaranteed. The products of car manufacturers and suppliers are pioneer for circular economy and are benchmark for other industries due to ▪ high amounts of recycled steel and NF metals in new vehicles, ▪ established remanufacturing processes with high volumes, ▪ very good reparability, ▪ longevity of their products and ▪ significant reduction of hazardous materials. Guiding principle for the ELV-revision The revision of the ELV Directive should reinforce its existing strengths, should foster innovations, and should trust in existing market mechanism. 1. Passenger cars are no ordinary consumer products 2. The ELV Directive should focus on passenger cars 3. The ELV Directive should cover the different requirements by the member states 4. The traction battery is crucial for a self-sustaining business model in future 5. A future-proof recycling system by digitizing deregistration and certificate of destruction 6. The ELV Directive should not contradict the climate protection goals by the European Union 7. Complex technologies need flexible use of advanced materials
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Sept 2020

The German Association of the Automotive Industry (VDA), representing 630 German based, mostly fully in the EU-internal market integrated and globally acting members across the whole automotive value chain, welcomes the opportunity to provide feedback on the inception impact assessment for the revision of the Renewable Energy Directive (RED). The automotive industry is committed to establish a greenhouse-gas-neutral transportation system by the middle of the century. All stakeholders agree that these ambitious climate targets can only be attained if, in addition to electric mobility using green electricity, sustainable, renewable fuels are comprehensively deployed in the transport sector. Here the revision of the REDII is the key regulation. I: The current design and ambition level of the REDII is insufficient The existing REDII regulation – finalized end of 2018 – doesn't consider the development of other regulations and the latest climate targets of the EU. The 14% ambition quota of is easily achievable by the quadruple counting of charging power for electric vehicles. For example, in Germany the automotive industry aims to sell at least 7 million electric vehicles in 2030 at least due to the challenging targets of the CO2 standards, which have been finalized last year. With an obligatory share of renewable electricity of 65% a REDII ambition level of 10% is automatically achieved. Adding the existing 5% biofuels no investment of renewable fuels – and therefore further CO2 reduction – is trigged on. Multipliers and low ambition levels are leading to a weak RED regulation. Since 2006 we see no increase of renewable energy in the German transport market. In addition, security of investment is further prevented by outstanding delegated acts. The whole hydrogen and power-to-x economy is waiting on the definition of appropriate power supply concepts. Also the implementation of the European hydrogen strategy is slowed down by the late deadline of the 31th of December 2021. The industry wants to invest and has developed several pragmatic approaches (e.g. the ptx alliance or the global powerfuel alliance) of how to guarantee a sustainable power supply concept. II: What do we need? In a comprehensive study on behalf of the German industry association an amount of 23% renewable fuels in 2030 is determined to comply with the EU climate targets. In this case all other climate measures are also considered. We assume an amount of up to 7% of conventional biofuels, which is rightly limited at this point, 11% of advanced biofuels as an European expert group has investigated and at least 5% of hydrogen or E-Fuels (synthetic fuels). The following regulatory changes are necessary in the revision of the REDII to kick-start an European sustainable fuel market: - Implementation of more ambitious targets: at least 23 percent renewable fuels in 2030 without multipliers under RED II - a minimum quota of 5% green hydrogen and E-Fuels in the revision of the REDII - Preparation of proposals for the delegated acts “Definition of obtaining electricity from a grid” (Article 27) and the “CO2 performance of E-Fuels” (Article 28) in the second half of 2020 - Consideration of liquified biomethane in the REDII
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Response to Sustainable and Smart Mobility Strategy

20 Jul 2020

VDA welcomes the Commission’s intention to present a strategy for sustainable and smart mobility. As stated in the roadmap, the transport sector faces enormous challenges ahead given its green and its digital transformation already under way. These challenges can only be met by a joint effort of all stakeholders including the EU and its member states. The roadmap emphasizes the importance of transport for the single market and industrial leadership. Transport is key for Europe’s competitiveness and secures jobs and growth. Mobility is also essential for society as a whole and for social cohesion. This is particularly true for road transport with its flexibility and decentralized network. Any EU strategy on mobility should bear in mind the important role transport plays. As already stated in the 2011 White Paper on transport, curbing mobility is not an option. Therefore, the mobility strategy should follow a balanced approach which does not focus only on the ecological aspects of transport but takes into consideration its economic and social importance, too. Affordability of transport and the needs of transport users are crucial issues which should also be addressed. According to the roadmap, a key objective of the strategy on mobility is to deliver a 90% reduction in transport-related greenhouse gas emissions by 2050. The German automotive industry supports the aim to turn Europa into a climate neutral continent by the middle of the century. Of course, this is a very challenging task especially for the transport sector. The German automotive industry alone will invest in the next few years about 50 billion Euro in alternative propulsion systems. However, the market uptake of these new technologies needs political support on both EU and national level. One crucial issue is the creation of a charging infrastructure for electrical vehicles and of a hydrogen infrastructure. This area of action should be a key element of the strategy. The AFID review will be an important step in this regard. Another key area is to create incentives to invest in clean vehicles. One example for trucks is the CO2 variation of tolls as proposed in the revision of the Eurovignette directive. The mobility strategy should also take into account the important role of alternative energy carriers. The EU should set incentives (e.g. in the RED and by exempting these fuels from energy taxation) for investing in the production of synthetic fuels as they provide a means of addressing the CO2 emissions of the existing vehicle fleet. The transition towards climate-neutral transport requires enormous investments by all stakeholders. Therefore, it is of utmost importance to follow the principle of least cost avoidance along the value chain. As indicated by the roadmap the Commission intends to promote modal-shift as one of the pillars of its strategy. However, any efforts in this regard have not been particularly successful in the past. Therefore, the Commission will be better advised to take up again the approach of co-modality with the aim of improving efficiency and sustainability of all modes both on their own and in combination. Whereas it is of the utmost importance to promote rail transport e. g. by modernizing its infrastructure, possibilities for improving other modes - especially road transport - should not be neglected. The Commission’s strategy should clearly aim at further improving the efficiency of road infrastructure use, the review of masses and dimensions being one possible area of action. The 2011 white paper on transport already underlined the importance of innovation. Fostering innovation should again be at the core of the mobility strategy. Digitalisation and automation can support the transport sector in reducing emissions, improving its efficiency, promoting multimodality and becoming even more safe and secure. The roadmap promises to take full advantage of these opportunities. It is important that the strategy will deliver on this promise
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Response to A EU hydrogen strategy

8 Jun 2020

The German Association of the Automotive Industry (VDA), representing 630 German based, mostly fully in the EU-internal market integrated and globally acting members across the whole automotive value chain, welcomes the opportunity to provide feedback on the inception impact assessment for an European hydrogen strategy. The automotive industry is committed to establish a greenhouse-gas-neutral transportation system by the middle of the century. All stakeholders agree that these ambitious climate targets can only be attained if, in addition to electric mobility using green electricity, sustainable, renewable fuels are comprehensively deployed in the transport sector. I: A coherent hydrogen strategy needs to activate target markets We therefore advocate in favour of taking greater account of the climate impact of energy carriers. The European Green Deal offers the unique opportunity to create the framework necessary for a fast ramp-up of alternative fuels. The VDA therefore recommends developing a coherent sector integration strategy, which should address all necessary political changes, making the European hydrogen strategy as ambitious as possible, bringing ecological components into the energy taxation and revising the Renewable Energy Directive (RED II) swiftly and ambitiously – so that sustainable, renewable fuels will be ramped-up extensively and starting off quickly. The current discussion about European hydrogen as well as sector integration strategies is an important first step towards the support needed for a fast technology ramp-up. However, it is right that the governments should support research projects, but the best project support will not bring any benefit if there is no demand for the products on the market. The current considerations and national drafts neither prioritize the measures nor contains proposals for immediately accessible target markets – in the light of the very ambitious climate targets, road traffic should become a driver of sector integration and, therefore, a hydrogen economy. II: Carbon pricing in road traffic as a key driver of a hydrogen demand It is often argued that hydrogen and further processed synthetic products (so called E-Fuels) should be deployed primarily in the energy-intensive industry, aviation and shipping sectors and should not be used in road traffic. This argument seems manifest since the named applications have no other option to “defossilize”. However, it disregards the fact that high CO2 avoidance costs in road traffic represent by far the best driver to increase the demand for these fuels and thereby cut down the price. Currently, road transport is the only sector, in which willingness to pay can spark the uptake of hydrogen technologies. A massive price crash is needed, so that other sectors can afford the introduction of climate neutral fuels. Road transport has a sound potential to roll-out significant production capacity: Every long-distance truck running on hydrogen will need approx. 10 tons of hydrogen per year. Furthermore, the European CO2 Regulation puts considerable pressure on vehicle manufacturers to sell considerable numbers of carbon-neutral vehicles. The following regulatory measures can kick-start economic opportunities for an European hydrogen market: - a targeted European PtX market introduction program for all sectors with 2 x 40 GW of installed capacity by 2030 - a full exemption of the energy taxation for renewable energy carriers in the revision of the European Energy Taxation Directive - a minimum quota of 5% green hydrogen and E-Fuels in the revision of the REDII - Allowance to the member state to reduce power taxes and surcharges for hydrogen production according to the sustainability criteria defined in the delegated acts, - Preparation of proposals for the delegated acts “Definition of obtaining electricity from a grid” (Article 27) and the “CO2 performance of recycled carbon fuels” (Article 25) in the second half of 2020
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German Auto Industry Urges Pragmatic Euro 7 Standards

20 May 2020
Topic — EU consultation on stricter Euro 7 emission standards for all combustion-engine vehicles.
Message — The VDA requests impact assessments based on current vehicle technology and air quality targets. They want streamlined regulations that avoid high engineering costs and maintain affordable mobility.12
Why — Preventing "near zero" targets helps manufacturers avoid expensive overengineering and protect product margins.3
Impact — Environmental groups and citizens lose more aggressive pollution cuts that could faster improve health.4
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

18 May 2020 · The meeting was a courtesy meeting to touch base after the appointment of Ms. Jorna as Director General of DG GROW and discuss future recovery in pandemic

Response to Climate Law

30 Apr 2020

VDA represents 630 German based, mostly fully integrated in the EU-internal market and globally acting members across the whole automotive value chain. The "European Climate Law" aims to enable the EU to become climate neutral by 2050. However, there is currently no generally accepted understanding of how exactly climate neutrality is to be defined. We would expect such a definition to be a major pillar of the “Climate Law”. VDA welcomes the Green Deal Initiative of the EU-Commission as an opportunity to rearrange the EU–framework towards a climate neutral economy more holistically and coherently. We are committed to the Paris agreement and are ready to contribute to a reliable and ambitious regulatory framework to achieve these objectives. We strongly believe that the main focus of the Green Deal should be to define the framework, to incentivize innovations and activate investment in best suited GHG-reduction technologies. In addition, it is important to implement EU financing tools/mechanisms to support the transition of the automotive industry in the years to come. The current crisis we are facing through the COVID-19 pandemic hits the global economy in a unprecedented manner. This new and unforeseen situation calls for a reassessment of plans laid out in the European Green Deal. Economic recovery and environmental goals have to be brought into a proper balance. Especially ambition levels for the next decade need to be analyzed in the context and based on consequences of the COVID-19 Crisis. Therefore the timeline laid out in the EU Climate Law should be adjusted to the overall disruption in early 2020. We are facing a groundbreaking transformation of mobility systems as well as value chains in the EU. Therefore a one-sided approach should be avoided. Europe's future welfare does not depend solely on the ecological goals of the Green Deal. The transformation will only succeed if it is based on all three pillars of sustainability: environmental, economic and social. To achieve the extremely ambitious targets set out a highly and globally competitive European manufacturing industry is key. In the same time individual mobility must remain affordable for all Europeans. We strongly believe without a global competitive automotive industry the EU cannot be leading the world towards sustainable mobility systems. We would like to emphasize that ecology and economy are not antagonists – if the political framework is set out in the right way, they spark each other to more overall success on both levels. Currently, the EU climate policy as well as national policies are composed of a variety of instruments which are regulating energy use and emissions differently in specific sectors. We observe that this fragmentation creates inefficiencies. With regards to transport sector different measures are needed to decarbonize road transport sustainably and effectively. This includes especially the use of electricity and electrified cars. In addition, alternative fuels for PHEV and modern and efficient ICEs and in specific areas fuel cell technology will be applied. Furthermore, new mobility and digital solutions have the potential to support GHG reduction goals. They need to be harmonized across the EU Member States. Investments into a sufficient, customer friendly EU-wide electrical charging infrastructure, is crucial. It is not only about technical goals for new cars, vans and trucks. Fundamental contributions can be made by decarbonising the automobile production along its supply chain and decarbonizing the existing vehicle stock of over 240 Mio ICE cars in the EU by adding renewable fuels to the market fuel. VDA calls therefore to start building regulatory bridges and supports the EU Commission to incorporate an improved emission trading scheme in order to put CO2-pricing in the center of EU Climate regulation . The EU ETS should become the central element of the European Green.
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Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

20 Apr 2020 · Green deal and the automotive sector

Meeting with Michele Piergiovanni (Cabinet of Executive Vice-President Margrethe Vestager)

17 Apr 2020 · To discuss with you the consequences of COVID-19 on the automotive industry

Response to Carbon Border Adjustment Mechanism

1 Apr 2020

The VDA represents the interests of over 600 international companies with 800,000 employees in Germany . With an added value of approximately 130 billion euros per year and a 4.7 percent share of the gross domestic product, the automotive branch is one of the most important industrial sectors in Germany. Our association unites manufacturers of passenger cars, light and heavy commercial vehicles, suppliers as well as manufacturers of trailers and bodies. The EU can and should play a leading international role in achieving the Paris climate targets. The German Automotive Industry supports the announcement to readjust and align all relevant directives and regulation towards a more holistic wide approach to achieve more sustainability in the European Union. VDA supports the EU Commissions approach to incorporate an improved emission trading scheme and CO2-pricing on EU Level into the European Green Deal. Achievement of ambitious climate targets requires to avoid any carbon leakage due to different national or regional climate regulations. In order to preserve international competitiveness, international cooperation and existing trading-regimes, any new established mechanism, e. g. a Carbon Border Adjustment Mechanism, should be carefully considered. Necessary discussions to define such a system should be based on a holistic and carefully performed impact assessment. A complete package must focus on these main criteria: • The VDA supports a multilateral, rule-based framework for international trade and investment. All potential measures being adapted to avoid carbon and investment leakage have to ensure compliance with WTO rules and EU's international trade agreements. • Potential effects on the international trading system must be considered. This includes, for example, negative counter-reactions by affected states, regardless of whether the EU has de jure found a WTO-compliant measure. Any form of discrimination or unilateral preference must be prevented. • Furthermore, it has to be considered that according to the concept of the European Commission exports from the EU would not be unburdened from higher costs due to EU-climate policies. This has a negative impact on competitiveness of European industries. • A convincing concept of how a new mechanism - for instance a Carbon Border Adjustment Mechanism - could be implemented in practice is not finally developed yet. Even the recording and verification of the CO2 content of a product ("Product Carbon Footprints") is yet difficult to calculate for many products. • To what extent a concept would be effectively replacing national compensation measures, such as free certificates under the European Emissions Trading System (ETS) or the electricity price compensation under the German EEG is open. • Finally, a Carbon Border Adjustment Mechanism should not be established without assessing alternatives, such as common international Emission Trading systems. Furthermore it should be coordinated internationally to avoid possible counter-reactions by trading partners. In this regard, communication with trading partners is a prerequisite to achieve international acceptance of potential actions taken by the EU. • Last but not least all negative consequences of the COVID19 Pandemic have to be taken into account. We call on the EU Commission to carry out a comprehensive impact assessment in order to examine the effects in detail. The VDA is happy to participate constructively in this process. At this state of the discussions a final assessment is not yet possible.
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Response to Climate Law

6 Feb 2020

VDAs feedback on the roadmap of the European Commission for the “Climate Law” enshrining in law the ambition to reach carbon neutrality by 2050 The German Association of the Automotive Industry (VDA), representing 630 German based, mostly fully integrated in the EU-internal market and globally acting members across the whole automotive value chain, welcomes the opportunity to provide feedback on the roadmap for an EU Climate Law. The "European Green Deal" aims at a fundamental transformation of the economy and society and should enable the EU to become climate neutral by 2050. However, there is currently no generally accepted understanding of how exactly climate neutrality is to be defined. We would expect such a definition to be a major pillar of the “Climate Law”. VDA welcomes the Green Deal Initiative of the EU-Commission as an opportunity to rearrange the EU – framework towards a climate neutral economy more holistically and coherently. German automobile manufacturers and suppliers are a driving force behind the transformation to a sustainable, smart and safe mobility. We are committed to the Paris agreement and are ready to contribute to a reliable and ambitious regulatory framework to achieve these objectives. We strongly believe that the main focus of the European Green Deal should be to define the framework, to incentivize innovations and activate investment in best suited GHG-reduction technologies. In addition, it is important to implement EU financing tools/mechanisms to support the transition of the automotive industry in the years to come. We are facing a groundbreaking transformation of mobility systems as well as value chains in the EU. We are on the way to provide the innovations and solutions needed for this transformation. However, a one-sided approach must not be taken. Europe's future welfare does not depend solely on the ecological goals of the Green Deal. The transformation will only succeed if it is based on all three pillars of sustainability: environmental, economic and social. To achieve the extremely ambitious targets set out in the European Green Deal a highly competitive European manufacturing industry is key. In addition, decision makers in the EU always need to take into account the global competitiveness of the industry. In the same time must individual mobility remain affordable for all Europeans. We strongly believe without a global competitive automotive industry in Europe the EU cannot be leading the world towards sustainable mobility systems. The necessary technology for climate protection can only be developed and put into the market on a large scale by a healthy industry sector. We would like to emphasize that ecology and economy are not antagonists – if the political framework is set out in the right way, they spark each other to more overall success on both levels. A European Climate Law has to create entrepreneurial planning and investment security. Currently, the EU climate policy is composed of a variety of instruments regulation energy use and emissions differently in specific sectors. We observe that this fragmentation creates inefficiencies. With regards to transport a level playing field for different drive train technologies is needed, because all available technologies and innovations will be required to decarbonize road transport sustainably and effectively. This includes the use of electricity, hydrogen, fuel cell and alternative fuels. Furthermore, new mobility and digital solutions have the potential to support GHG reduction goals. They should be harmonized in the EU Member States. Investments into a European infrastructure for alternative power trains are crucial. It is not only about technical goals for new cars, but also about decarbonizing the existing fleet of over 240mio cars in the EU with renewable fuels. VDA calls for therefore to start building regulatory bridges and to include fuels into the EU-ETS as soon as possible.
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Meeting with Frans Timmermans (Executive Vice-President)

16 Jan 2020 · The European Green Deal: challenges and opportunities for the automotive industry

Meeting with Johannes Haenicke (Cabinet of Vice-President Günther Oettinger)

9 Jul 2019 · EU transport and climate change policy

Meeting with Günther Oettinger (Commissioner)

29 May 2019 · European elections

Response to Rear aerodynamic devices according to the amended directive 96/53/EC on maximum weights and dimensions

18 Mar 2019

The German Association of Automotive Industry (VDA) represents more than 620 companies (car, bus and truck manufacturers, trailer manufacturer as well as suppliers) involved in production for the automotive industry in Germany. We thank DG MOVE for the opportunity to comment the draft implementing regulation regarding the use of rear aerodynamic devices pursuant to Directive 96/53/EC. We would make the comments: “Article 3, Operational conditions, 1.a These requirements lead to serious risks when the driver must leave the vehicle before maneuvers at loading points, parking lots or roads to fold the system. These provisions shall be deleted, or these conditions shall not apply to devices not exceeding 500 mm in length in the in-use position. Article 3, Operational conditions, 1.b What is meant with the term “stationary”? Does this mean that the system has to be folded at each red traffic light? Why should the vehicle not be able to be parked with the unfolded system? The vehicle and the system have the correct lighting and can therefore be recognized like any other vehicle. The requirements for stiffness/robustness are defined in the type approval requirements as proposed by DG GROW. The provisions in article 3, 1.b shall be deleted, or these conditions shall not apply to devices not exceeding 500 mm in length in the in-use position. Article 3, Operational conditions, 1.c When loading vehicles from the side, it is not necessary to fold. When loading from the rear, a folding cannot be avoided. Why do we need provisions for loading/unloading processes where the drivers normally know their business? It is not necessary to describe such things in a regulation. These provisions shall be deleted, or these conditions shall not apply to devices not exceeding 500 mm in length in the in-use position. Article 3, Operational conditions, 2. In many rural regions in Europe are very small areas with a localized speed limit. Here, this system constantly folds in and out, what makes no sense. We suppose that the driver will only fold out the system at the beginning. These provisions shall not apply to devices not exceeding 500 mm in length in the in-use position. Article 3, Operational conditions, 3.a These provisions should be rewritten in a way that vehicles designed for intermodal transport and equipped with rear aerodynamic devices should provide the relevant clearance and durability of these devices to avoid any interference during intermodal transport operations. Article 3, Operational conditions, 3.b There is an error regarding 250 mm: “…vehicles fitted with devices shall not be wider than 2600 mm, thus protruding by maximum 25 mm on each side of standard vehicles in accordance with point 1.2 (a) of Annex I to Directive 96/53/EC…”. Article 3, Operational conditions, 4. Defects might also affect the unfolding/folding functions. The provisions that a driver must be able to dismantle/remove a system is questionable with respect to the dimensions and the fixation of such system on the rear end of the vehicle. Defect systems might be repaired by a workshop and not by the driver.” We kindly ask to consider these comments and proposals in order to secure a robust and practical implementation.
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Response to Type-approval requirements for elongated cabs and rear flaps for trucks/trailers

26 Feb 2019

The German Association of the Automotive Industry (VDA) welcomes the initiative of the EU Commission to revise the (EC) 1230/2012 and sees this as an important step towards improving the energy efficiency of commercial vehicles and trailers through design measures in line with the requirements as defined in 96/53/EC and (EC) 2015/719. The proposed amendment of (EC) 1230/2012 gives the manufacturers the opportunity to install so-called aerodynamic devices on the rear of the vehicle and to change the geometry of the cab. Both measures are seen as a module for future technical development in the commercial vehicle sector. Nevertheless, we see room for improvement in the current draft, especially with regard to the technical requirements for the aerodynamic equipment and the definition of the max. width for tarpaulins: 1. A simultaneous amendment of the UN R58 is urgently needed. Otherwise, there will be no complete vehicle type approval. It must be ensured that the conditions in Appendix 4 are transferred to UN R58 in the same manner. 2. In the respective paragraphs 1.3.1.1.1. and 1.3.1.2.1. in Annex I Part B and C and paragraphs 1.4.1.1.1. and 1.4.1.2.1. in Part D it is described that the aerodynamic device must be type-approved as a separate component. The VDA would also request the possibility of a type-approval for the aerodynamic device as part of the overall vehicle. This possibility is explicitly described in the test procedure in appendix 4. The appropriate sentences should be amended as follows: “The separate devices and equipment or the devices installed on a vehicle shall be type-approved in accordance with this Regulation.” 3. In paragraphs 1.3.1.3., 1.3.1.4. and 1.4.1.3. it is requested that the technical service should demonstrate to the type-approval authorities, inter alia, that the ventilation of the cab and cargo area is not adversely affected by the aerodynamic devices. The required verification is not described and will lead to unnecessary discussion during the type approval process. We would recommend to delete this phrase without replacement, as long as no uniform test conditions are described. 4. In paragraph 3.2. in Annex I Part D the semi-trailer with aerodynamic facilities is explicitly excluded from the calculation. The VDA would like to point out here that this is not supported and does not reflect the current state of technical development. We would appreciate that the evaluation of the manoeuvrability of vehicles may be done in any case by a calculation. 5. The proposed change in Table II item no 13. is in contrast to today's valid regulation. It is proposed here to limit the permissible width for tarpaulin and their protection over the entire vehicle height to 25 mm on the right and left. So far, 20 mm were defined here up to a height of 2 m and 50 mm above 2 m. This new measure over the entire vehicle height cannot be fulfilled with current devices for securing loads in e.g. tippers, since here either tarpaulins are rolled up on the side or rolled up on the front side and guided on the longitudinal sides. Both variants clearly exceed 25 mm and would therefore not be compliant with the new regulation. We would strongly prefer to define under item no. 13 max. 50 mm over the entire vehicle height as proposed in the original draft document of the European Commission from Oct. 2018. We kindly ask to consider these comments and proposals in order to secure a robust and practical implementation.
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Response to Specifications for the provision of cooperative intelligent transport systems (C-ITS)

8 Feb 2019

Efficiency, safety and environmental performance of road transport are a common task for policymakers and the industry. The automotive industry utilizes a large part of its innovative power for continuously improving safety, as well as further reducing emissions and the consumption of our valuable resources. A necessary framework need to be created. The proposed Delegated Act / Specifications for the provision of cooperative intelligent transport systems (C-ITS) builds a baseline for the future. The automotive industry sees the need for a comprehensive evaluation to ensure proper further development of the legal framework. With their technical expertise the automotive industry supports the European Commission in such an evaluation. C-ITS improves road safety and traffic efficiency. The German Association of the Automotive Industry (VDA) is supporting the interests of the whole German automobile industry in all areas of the automobile economy, as e.g. economic, traffic and environmental policy, the technical legislation, standardization and quality assurance. More than 600 companies are members of the VDA.
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Meeting with Jean-Luc Demarty (Director-General Trade)

22 Jan 2019 · Trade and customs in the automotive sector

Meeting with Christian Burgsmueller (Cabinet of Vice-President Cecilia Malmström)

22 Jan 2019 · 232 Cars

Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

22 Jan 2019 · Exchange on the most recent issues regarding climate change policy in the sector

Response to Commission Implementing Act on on-board weighing equipment

18 Jan 2019

The Intention in (EC) 2015/719 was the protection of the infrastructure from overloaded vehicles. The use of On-Board Weighing Devices (OBWD) in several vehicle classes was limited to a pre-selection and the focus on the overall weight of the vehicle/vehicle connbination. It was also defined that the weight information shall be transmitted via a wireless interface as defined in CEN DSRC and requested by (EC) 165/2014 and (EU) 2016/799. Therefore the scope should be the same as defined in (EC) 561/2006. Furthermore we see no reason to require OBWD on vehicles of N2, M2, M3 and 03 below 12 tonnes, as those vehicles have a gross vehicle weight below maxinnum legal weights of (EC) 2015/719. These vehicles shall be exennpted from the scope of the regulation. Vehicles of category 01 (up to 0.75 tonnes) and 02 (up to 3.5 tonnes) shall be also exempted, as these vehicle categories to no have an innpact on road destruction by overloading. Stage 2 requests much higher requirements (higher accuracy of 5%), not only on motor vehicle or trailer manufacturers but also for operators and inspection authorities. The manufacturers, workshops and authorities are confronted with very high security requirements für encryption of signals and high requirements für the accuracy of the System which are not justified by the (EC) 2015/719. This level is not proportionate für a pre-selection System.
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Meeting with Christian Burgsmueller (Cabinet of Vice-President Cecilia Malmström)

28 Nov 2018 · EU-US trade relations

Meeting with Günther Oettinger (Commissioner)

5 Sept 2018 · future of automobile industry, electromobility

Meeting with Jean-Luc Demarty (Director-General Trade)

5 Sept 2018 · EU-US relations

Response to REFIT review of the Motor Insurance Directive

23 Jul 2018

Sehr geehrte Damen und Herren, anliegend erhalten Sie unsere Stellungnahme zum Entwurf einer Änderungsrichtlinie zur Kraftfahrzeughaftpflichtrichtlinie. Mit freundlichen Grüßen, Dr. Ralf Scheibach Leiter Abteilung Recht und Finanzdienstleistungen Verband der Automobilindustrie e.V. Behrenstrasse 35 10117 Berlin Deutschland
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Meeting with Günther Oettinger (Commissioner)

19 Apr 2018 · farewell speech, automotive industry

Meeting with Jean-Luc Demarty (Director-General Trade)

21 Mar 2018 · US measures on steel an aluminium and ongoing trade negotiations

Meeting with Günther Oettinger (Commissioner)

20 Mar 2018 · mobility package

Meeting with Silke Obst (Cabinet of Commissioner Violeta Bulc)

8 Mar 2018 · Automobile topics

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis), Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis)

7 Mar 2018 · Sustainable Finance, Fintech, Green Finance, Securitization

Meeting with Günther Oettinger (Commissioner)

18 Feb 2018 · carbon dioxide emissions

Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)

24 Oct 2017 · standardisation, SEPs

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

19 Oct 2017 · CO2 proposal

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

17 Oct 2017 · Energy Union

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

29 Jun 2017 · CO2 regulation, IAA

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

29 Jun 2017 · Connected automated cars

Meeting with Michel Barnier (Head of Task Force Task Force for Relations with the United Kingdom)

1 Jun 2017 · Meeting with the Task Force for the Preparation and Conduct of the Negotiations with the United Kingdom under Article 50 TEU

Meeting with Günther Oettinger (Commissioner)

31 May 2017 · future of automotive industry

Meeting with Günther Oettinger (Commissioner)

22 Mar 2017 · future of Europe

Meeting with Maroš Šefčovič (Vice-President) and

21 Feb 2017 · CO2 emission targets, GEAR 2030, batteries, electrical vehicles

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

10 Feb 2017 · upcoming mobility package

Meeting with Christian Linder (Cabinet of Vice-President Maroš Šefčovič)

1 Feb 2017 · Situation of the car industry

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

8 Dec 2016

The German Automotive Industry generally supports the introduction of RDE with the dates and the conformity factors set out in the 2nd RDE-package. The 3rd RDE package now addresses additional requirements such as cold start, regeneration and urban-only testing. Vehicles complying with this RDE legislation will show ultra low emissions on the road and will contribute to comply with the air quality targets set by the EU. Calculations by AVISO (https://www.scienpress.com/journal_focus.asp?main_id=59&Sub_id=IV&Issue=1932) have shown, that the air quality limits will be achieved in Europe with the ongoing market penetration of Euro6-vehicles. We have however serious remarks regarding leadtime. This concerns several technical and organisational issues. Sufficient leadtime is essential to cover the new cold start requirements, to make changes of the internet platform for publication of RDE-results to comply with the new requirements regarding PN-PEMS. The 3rd RDE package definitely does not provide this required lead time. PN-PEMS-systems are available on the market since beginning of the year 2016. Cars could start to be developed and verified since this time. Considering a publication of the 3rd package in April this leaves only 5 months until the mandatory introduction of PN-PEMS. We believe that the planned mandatory introduction date for RDE-PN (9/2018) is far too short. We ask to respect the CARS21 principles granting sufficient leadtime for major hardware changes. PN-PEMS requires the broad introduction of gasoline particle filters. The engines have to be developed and adapted to these new aftertreatment devices. The development and verification takes time – at least 2 years for development and summer- and winter-testing. We therefore strongly recommend to link the requirements for PN to Euro 6d as foreseen in the 2nd RDE package.
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Response to Commission Regulation amending Annex III to Directive 2008/98/EC

16 Aug 2016

The Association of the German Automotive Industry is much concerned that the proposed Commission Regulation amending Annex III to Directive 2008/98/EC as regards the hazardous property HP 14 (ʻEcotoxic’), based on the outcome of “Study to assess the impacts of different classification approaches for hazard property "HP 14" preferring the calculation method 1 for classification purposes, will adversely impact recycling. An approach relying on chemical analysis, as it is the case with method 1, is technically unfit for characterisation of complex solid waste streams, such as fluff-light fraction and dust from shredding of metal containing waste (19 10 03*/19 10 04). The chemical analysis is suited for assessing homogeneous substances and well-defined mixtures commonly found in virgin materials but absolutely not adapted to the characterisation of solid waste which by nature is heterogeneous and complex. Sampling solid waste coupled a chemical lixiviation of the sample to obtain a homogeneous liquid and exhibit its chemical properties would provide only a very poor indication of the hazardous properties of the waste sample analysed: It would neither be representative of complex materials found in solid waste nor would it be indicative of the bioavailability of hazardous substances in water as only a very small fraction of what is recycled in scrap can be soluble in water. However, we welcome the introduction of generic cut-off values, being in line with the position of Dutch authorities, even if it does not address the limits of relying on a method using a chemical analysis. The Study, used as a basis for the draft Commission Regulation, is based on an extremely limited dataset not allowing to draw conclusions relying on solid scientific evidence. The Study explicitly acknowledges “the lack of availability of characterisation data from chemical analysis” in general (p.91, sec. 5.4.1, 1.par) and the lack of data for fluff and dust from metal shredding (p.15, above the table and p.126, sec. 6.4.5, last par). Moreover, the study acknowledges that the method 1 is associated to a potential overestimation of waste classification (p.13, Results). Neither the suggested approach nor the far-reaching detrimental impacts expected for the recycling industry, stemming from the application of method 1, are in support of the transition to a circular economy. Socio-economic impacts resulting from a probable reclassification of fluff-light fraction and dust from metal shredding from currently non-hazardous to hazardous, on the basis of an unfit method, would seriously disrupt if not render impossible recycling of streams reaching high recycling targets and force facilities to temporary or definitively cease operation for no environmental benefits. Applying the method 1 for classification of fluff-light fraction and dust would from a scientific viewpoint be irrational. Given the limitations of the chemical analysis approach, it would be justified to develop a harmonised method which is scientifically fit for purpose of assessing the ecotoxicity of complex solid waste streams instead of relying on a preferred method 1 which is inadequate for assessing HP 14 for complex streams. As long as such a method is not developed, complex solid waste streams such as fluff-light fractions and dust must be exempted from any method based on chemical analysis for assessing HP 14 and regulatory changes to incorporate such a method in the legislation. We urge the European Commission and the Technical Adaptation Committee to refrain from approving any proposal relying on chemical analysis for the assessment of the ecotoxic property of waste HP 14 applicable to fluff-light fraction and dust until a proper harmonized method fit for the purpose of characterising complex solid waste streams is set up. This response has been prepared under a very short period of time given the period and short time left to stakeholders to respond to this consultation
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Meeting with Miguel Arias Cañete (Commissioner)

13 Jul 2016 · Contribution of the automotive industry to the decarbonisation of the economy

Meeting with Günther Oettinger (Commissioner)

10 Mar 2016 · connected cars

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

17 Feb 2016 · decarbonisation and digitalisation of transport

Meeting with Günther Oettinger (Commissioner)

17 Feb 2016 · electro mobility, digitisation

Meeting with Elżbieta Bieńkowska (Commissioner) and

16 Feb 2016 · Situation German Automotive Industry

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

16 Oct 2015 · RDE/DIESEL

Meeting with Christian Linder (Cabinet of Vice-President Maroš Šefčovič) and Bundesverband der Deutschen Industrie e.V. and

11 Sept 2015 · Energy Union Strategy with a forward-looking climate policy

Meeting with Eric Mamer (Digital Economy)

7 Jul 2015 · decarbonisation of transport

Meeting with Eric Mamer (Digital Economy)

7 Jul 2015 · connected mobility

Meeting with Christian Linder (Cabinet of Vice-President Maroš Šefčovič)

4 Jun 2015 · Transport, Mobility in the Energy Union/Situation of car industry

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

26 Feb 2015 · Current EU Policy Issues

Meeting with Violeta Bulc (Commissioner)

26 Feb 2015 · Meeting with VDA

Meeting with Karl-Friedrich Falkenberg (Director-General Environment)

25 Feb 2015 · Meeting with VDA präsident, Mr Matthias Wissmann on Air quality policy

Meeting with Daniel Calleja Crespo (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

25 Feb 2015 · E-Mobility, Connected Cars and competitiveness of the automotive sector and relaunch of Cars 2020

Meeting with Jean-Luc Demarty (Director-General Trade)

25 Feb 2015 · Ongoing Trade negotiations

Meeting with Günther Oettinger (Commissioner)

28 Jan 2015 · DSM, automated driving

Meeting with Renate Nikolay (Cabinet of Commissioner Věra Jourová)

22 Jan 2015 · Digital Single Market

Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)

21 Jan 2015 · Energy Union priorities for the automotive sector

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

20 Jan 2015 · Digitalisation of Transport, electrification of transport

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

20 Jan 2015 · Investing in EU

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

20 Jan 2015 · Industrial Policy

Meeting with Justyna Morek (Cabinet of Commissioner Elżbieta Bieńkowska)

20 Jan 2015 · EXCHANGE OF VIEWS ON CURRENT TOPICS

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

10 Dec 2014 · Investing in Europe and Energy Union