Volvo AB

Volvo Group

The Volvo Group is one of the world's leading manufacturers of trucks, buses, construction equipment, and marine and industrial engines.

Lobbying Activity

Meeting with Kris Van Dijck (Member of the European Parliament)

20 Jan 2026 · E-Mobility

Meeting with Mohammed Chahim (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

10 Dec 2025 · Informal stakeholder roundtable meeting on the automotive package

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

25 Nov 2025 · automotive package

Meeting with Valère Moutarlier (Deputy Director-General Internal Market, Industry, Entrepreneurship and SMEs) and

20 Nov 2025 · Battery Booster

Meeting with Mohammed Chahim (Member of the European Parliament)

20 Nov 2025 · Social Leasing EV's

Meeting with Johan Danielsson (Member of the European Parliament)

19 Nov 2025 · Transport industry

Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra)

19 Nov 2025 · Clean transition in heavy-duty vehicles

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

19 Nov 2025 · HDV package

Meeting with Ana Xavier (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

17 Nov 2025 · Exchange of views on machinery and maritime

Meeting with Liesbet Sommen (Member of the European Parliament)

14 Nov 2025 · Emission reduction in transport sector

Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and Association des Constructeurs Européens d'Automobiles and

5 Nov 2025 · Discussion on EU content requirement for heavy-duty vehicles (HDVs) in view of the upcoming Industrial Accelerator Act

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and Association des Constructeurs Européens d'Automobiles and

5 Nov 2025 · Discussion on EU content requirement for heavy-duty vehicles (HDVs) in view of the upcoming Industrial Accelerator Act

Meeting with Isabella Lövin (Member of the European Parliament) and CEC European Managers - Confédération Européenne des Cadres

15 Oct 2025 · Sustainable leaders summit

Meeting with Andras Inotai (Acting Principal Adviser Research and Innovation)

14 Oct 2025 · EU Startup and Scaleup Strategy

Response to Electrification Action Plan

8 Oct 2025

Volvo Group drives prosperity through transport and infrastructure solutions, offering trucks, buses, construction equipment, and power solutions for marine and industrial applications. We are present in 190 markets across four continents and have approximately 100,000 employees worldwide with headquarters in Sweden. We welcome the call for evidence for the EU Electrification Action Plan and its ambition to address the barriers for electrification. The Electrification Action Plan offers an opportunity to: A. Accelerate the decarbonization of road transport by establishing the necessary enabling conditions to meet the CO2 emission performance standards. This requires investing in, building, and operating approximately 60GW of reliable charging infrastructure for HDVs within the next five years; B. Make Europes grid and electricity markets ready for a decarbonized future. Regulatory reforms are needed to facilitate faster investments, digitalization, and standardization of connection processes, especially for heavy-duty vehicle (HDV) charging. Key measures include integrating HDV power needs into network plans, establishing common capacity maps, and enabling anticipatory grid investments with fair remuneration frameworks for DSOs and CPOs. Additionally, the rollout of fast and en-route charging infrastructure must be accelerated, supported by time-based contracts for night charging. Finally, clear political guidance is essential to prioritize activities facing CO2 reduction targets, classify HDV charging as critical infrastructure, and implement flexible connection agreements that harmonize with logistics sector needs. C. Address the untapped potential of zero-emission construction machinery (non-road mobile machinery). Zero-emission machines are already a reality today, but market uptake is low despite the potential to increase productivity in the sector while reducing emissions of CO2 as well as NOx. Uncertainty on grid capacity is one reason why public procurers hesitate to request zero emission machinery in construction tenders. D. Strictly enforce the principle of carbon pricing without exemptions. Our input for each of the above points is further elaborated in the attached paper.
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Meeting with Jörgen Warborn (Member of the European Parliament)

8 Oct 2025 · US/EU trade relations

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

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

Volvo Group urges deeper industry integration in EU innovation funding

3 Oct 2025
Message — The organization requests that EU innovation funding integrate large industries with startups and academia rather than supporting separate networks. They want the European Innovation Council broadened to include closer links to industry needs and facilitate collaboration with established companies.123
Why — This would give them access to EU innovation funding to support their startup collaboration programs.45
Impact — Universities and research-linked startups lose exclusive access to increased EIC funding.6

Meeting with Elina Bardram (Director Climate Action)

29 Sept 2025 · HDV CO2 standards

Volvo Group Calls for Unified EU Data Sharing Rules

14 Jul 2025
Message — Volvo requests the EU harmonize data regulations and establish a central unit to prevent overlapping rules. They specifically advocate for delaying indirect data access deadlines to align implementation across the industry.123
Why — Streamlined rules would lower administrative costs and provide legal certainty for their global operations.45
Impact — Third-party data users could face delays in accessing information due to postponed regulatory deadlines.6

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

26 Jun 2025 · Automotive

Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné), Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and

23 Jun 2025 · Aspects related to enhancing the competitiveness participants companies

Meeting with Jessika Roswall (Commissioner) and

23 Jun 2025 · Public procurement, the Clean Industrial Deal, Embodied Carbon Product Standards

Meeting with Ursula von der Leyen (President)

26 May 2025 · Exchange of views on investment conditions in AI development and deployment in Europe

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

12 May 2025 · Discussion about Volvo Trucks’s data sharing activities

Meeting with Wopke Hoekstra (Commissioner) and

25 Apr 2025 · Inauguration of Volvo’s EX30 electric vehicle

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and Association des Constructeurs Européens d'Automobiles and

2 Apr 2025 · Automotive

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and

1 Apr 2025 · Plenary Feedback round on previously held GGIA Working Group sessions of 9 different thematical groups regarding Latin America and the Caribbean (LAC).

Meeting with Heléne Fritzon (Member of the European Parliament)

26 Mar 2025 · Besök av Volvo Group, diskussion om fordonsfrågor och den gröna omställningen

Meeting with Beatrice Timgren (Member of the European Parliament)

25 Mar 2025 · New requirements for the circular economy

Response to EU Start-up and Scale-up Strategy

17 Mar 2025

There is a huge potential in Venture Clienting - increased collaboration between large industries and start-ups/scale-ups. The future R&I frameworks should further stimulate this type of collaboration, for ex through better integration between different funding instruments (today Pillar II and Pillar III). To maximize the potential for start-ups to scale together with large industries, these collaborations should be based on industrial applications, needs, challenges and opportunities. Models should be developed that incentivize quick tests/experiments of start-up solutions, often carried out in real industrial environments. This will support the speed that is needed in technology integration, talent attraction and the catalyzation of private investments. In Sweden a publicly funded collaboration framework, Accelerate Start-up Partnerships, focusing on Swedish automotive OEM´s and start-ups/scale-ups is up and running since four years. The model has proven to be very impactful strengthening both the industry competitiveness and the learnings and ability to scale for start-ups and we propose this partnership model as a candidate to scale on EU level.
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Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra) and TotalEnergies SE and

11 Mar 2025 · The role of hydrogen for heavy-duty vehicles

Meeting with Maria Isabel Garcia Catalan (Head of Unit Taxation and Customs Union) and Association des Constructeurs Européens d'Automobiles and

6 Mar 2025 · Hybrid meeting - Discussion on the draft Guidance on CAM under the EU-UK TCA

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

4 Mar 2025 · Future of the HDVs industry

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

20 Feb 2025 · Discussion on Software Defined Vehicle for HDTs

Meeting with Koen Doens (Director-General Directorate-General for International Partnerships) and

6 Feb 2025 · Global Gateway investments

Meeting with Tomas Tobé (Member of the European Parliament)

5 Feb 2025 · Research Policy

Meeting with Jörgen Warborn (Member of the European Parliament)

5 Feb 2025 · Innovation and science

Meeting with Max Lemke (Head of Unit Communications Networks, Content and Technology) and IVECO GROUP N.V. and Daimler Truck AG

24 Jan 2025 · EU Digital Vehicle Ecosystem, software development for commercial vehicles

Meeting with Maria Isabel Garcia Catalan (Head of Unit Taxation and Customs Union) and Association des Constructeurs Européens d'Automobiles and Ford Motor Company

24 Jan 2025 · Online meeting - Discussion on the draft Guidance on CAM under the EU-UK TCA

Response to Data types for alternative fuels infrastructure

19 Dec 2024

Regulation (EU) 2023/1804 of the European Parliament and of the Council as regards additional data types on alternative fuels infrastructure: General: -Article 1 (a) (16) Vehicle type-compatibility. N3+O4 access (HD truck with connected trailer) must be the default for HDVs. If any deviation of this; Length, Width and Weight must be described. Any charging / refueling station that is not compatible with N3+O4 should not be considered as a HDV station. Charging: -Article 1 (b) (6) Recharging point maximum power. This need to be complemented with a "predicted actual available energy (kWh/h)" to make the logistics plannable for the transport planner. If max power is load balanced and not available at time of arrival, efficiency of logistics will go down and cost will increase for society. Hydrogen refueling: Comment 1: Added data reporting requirements for hydrogen refuelling stations/points . Type of refueling connector for gaseous hydrogen: Unfortunately, the new standards ISO 17268-1 & -2 are not yet ready. These should be included when ready. Use nomenclature from ISO 17268-1 & -2 . Communication technology and protocol: Refer to the interoperability standard EN 17127:2024. New coming standard ISO 19885-2 for advanced communication should be included when ready. . Protocol should be included in the data : Refer to the interoperability standard EN 17127:2024. New coming standard ISO 19885-3 should be included when ready. Comment 2: Back to back refuelling capacity as kg/h . Add in addition to daily cumulative capacity (c3). Back to back refuelling capacity is an indicator for waiting time at the station. . Max Filling rate per dispenser to be potentially considered
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Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and Association des Constructeurs Européens d'Automobiles and

19 Dec 2024 · HDVs and Buses main priorities

Meeting with Anna-Maja Henriksson (Member of the European Parliament)

2 Oct 2024 · Automotive industry

Meeting with Pascal Arimont (Member of the European Parliament)

1 Oct 2024 · Challenges of the European automotive sector

Meeting with Sofja Ribkina (Cabinet of Executive Vice-President Valdis Dombrovskis), Zaneta Vegnere (Cabinet of Executive Vice-President Valdis Dombrovskis)

24 Sept 2024 · Meeting was held at the request of VOLVO to exchange views on the latest market developments affecting the automotive industry, EU regulatory framework, EV market development trends in the EU, plans of the company.

Meeting with Ruth Reichstein (Cabinet of President Ursula von der Leyen) and Transport and Environment (European Federation for Transport and Environment) and

29 Aug 2024 · transport policy

Meeting with Yvan Verougstraete (Member of the European Parliament)

26 Aug 2024 · Electrification of transport

Meeting with Valdis Dombrovskis (Executive Vice-President)

25 Jun 2024 · Volvo’s electrification strategy, competitiveness of the industry, EU ongoing anti-subsidy investigation into BEVs from China

Meeting with Iliana Ivanova (Commissioner) and

17 Jan 2024 · EU research and innovation policy

Meeting with Pascal Arimont (Member of the European Parliament)

11 Jan 2024 · Standard Essential Patents (SEP)

Response to Count your transport emissions: CountEmissions EU

14 Nov 2023

Please, find attached Volvo Group's comments on 'CountEmissionsEU' (COM (2023) 441).
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Meeting with Kateřina Konečná (Member of the European Parliament, Shadow rapporteur)

13 Nov 2023 · Weights and Dimensions Directive

Meeting with Pär Holmgren (Member of the European Parliament)

28 Sept 2023 · Transport and green transition

Meeting with Christel Schaldemose (Member of the European Parliament, Shadow rapporteur) and Rådet for Grøn Omstilling

22 Jun 2023 · heavy durty vehicles and CO2

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness), Patricia Reilly (Cabinet of Commissioner Mairead Mcguinness)

7 Jun 2023 · Sustainable Finance and EU Sanctions

Meeting with Sylvia Limmer (Member of the European Parliament, Shadow rapporteur)

29 Mar 2023 · Euro-7-Verordnung

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

22 Mar 2023 · - Zero-emission vehicles - The recent Commission proposal on Heavy Duty Vehicles - Battery technologies

Meeting with Arba Kokalari (Member of the European Parliament)

14 Feb 2023 · Green and digital transition in the vehicle industry

Meeting with Frans Timmermans (Executive Vice-President) and Association des Constructeurs Européens d'Automobiles and

19 Jan 2023 · visit to see developments in electric mobility

Meeting with Ursula von der Leyen (President) and Vodafone Belgium SA and

18 Jan 2023 · Meeting with Chairman of Volvo, Chairman of Siemens and Maersk, Chairman of Vodaphone, President of IFO Institute (Topic: Competitiveness)

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

24 Nov 2022 · Presentation of a forthcoming public event.

Meeting with Sara Skyttedal (Member of the European Parliament)

28 Jun 2022 · Data act and future sectoral regulation on data

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Association des Constructeurs Européens d'Automobiles

28 Jun 2022 · Data Act, preparation of access to in-vehicle data, Euro 7

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament, Rapporteur)

15 Jun 2022 · Data act

Meeting with Jakop G. Dalunde (Member of the European Parliament)

31 May 2022 · Transport Policy

Volvo Group Demands Extended Timelines and Trade Secret Protections

13 May 2022
Message — Volvo requests extending the implementation period to 36 months and ensuring data holders receive fair compensation for costs. They also demand that the regulation does not compromise trade secrets during disclosure.12
Why — A longer transition period prevents development delays and protects Volvo's valuable proprietary technical information.3
Impact — Third-party service providers would face higher costs to access necessary industrial data.4

Meeting with Jakop G. Dalunde (Member of the European Parliament)

28 Apr 2022 · Study Visit: Volvo Cars

Meeting with Pascal Canfin (Member of the European Parliament)

13 Apr 2022 · Green Deal

Meeting with Ursula von der Leyen (President) and Siemens AG and

18 Mar 2022 · Meeting with Chairman of Volvo, Chairman of Siemens and Maersk, CEO of Air Liquide

Meeting with Ursula von der Leyen (President) and Siemens AG and

20 Jan 2022 · Meeting with Chairman of Volvo, Chairman of Siemens and Maersk, CEO of Air Liquide

Meeting with Caroline Nagtegaal (Member of the European Parliament, Shadow rapporteur) and KIC InnoEnergy SE and

5 Jan 2022 · AFIR

Meeting with Jakop G. Dalunde (Member of the European Parliament)

3 Nov 2021 · E-mobiitet

Meeting with Thierry Breton (Commissioner) and

12 Oct 2021 · CO2 standards, Euro 7, connectivity

Meeting with Ursula von der Leyen (President) and Siemens AG and

25 Aug 2021 · Videoconference with Chairman of Volvo, Chairman of Siemens and Maersk, CEO of Air Liquide

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

21 May 2021 · cars/vans CO2 standards

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

11 May 2021 · HDV in AFID

Meeting with Ursula von der Leyen (President) and Siemens AG and

29 Mar 2021 · Videoconference with Chairman of Volvo, Chairman of Siemens and Maersk, CEO of Air Liquide

Meeting with Ursula von der Leyen (President) and Siemens AG and

19 Feb 2021 · Meeting with Chairman of Volvo, Chairman of Siemens and Maersk, CEO of Air Liquide

Meeting with Adina-Ioana Vălean (Commissioner)

19 Feb 2021 · Meeting President

Meeting with Christiane Canenbley (Cabinet of Executive Vice-President Margrethe Vestager), Michele Piergiovanni (Cabinet of Executive Vice-President Margrethe Vestager) and

25 Jan 2021 · Commission’s priorities for digital and industrial policy in 2021

Meeting with Thierry Breton (Commissioner) and

10 Dec 2020 · industrial, digital and defency policy Green Deal

Meeting with Pascal Canfin (Member of the European Parliament)

20 Nov 2020 · Green Deal

Response to Revision of the Intelligent Transport Systems Directive

19 Nov 2020

Fulfillment of European wide interoperability as the main prerequisite for a successful deployment of different solutions, in the context of subsidiarity, should be considered as a major criteria. Volvo Group notes however that the evaluation of the ITS Directive has not considered such criteria . The need for a homogeneous and interoperable implementation of the various ITS platforms at national level requires the provision of EU funding to finance the implementation of the ITS Action plan. To ensure crucial input from relevant stakeholders, Volvo Group would like to see a more active call from DG MOVE onto the ITS Advisory Group which we believe has not been actively consulted up to now in this process as well as in the process of the C-ITS draft delegated act and the update of the ITS Action plan of 2008. Data protection and privacy: Compliance with GDPR is a major and critical issue. Vehicle manufacturers takes this seriously. It is currently unclear how compliance with the General Data Protection Regulation and ePrivacy legislation can be ensured for data processing in the context of C-ITS. The Commission should act upon this suggestion and provide the clarity that is required in this field. The current ITS spectrum is not sufficient to achieve higher levels of safety and serve advanced levels of automated driving and advanced ITS use cases, such as Day 2 and Day 3 applications. See Car2Car Communications Consortium, White Paper on Road Safety and Spectrum Needs in the 5.9GHz for C-ITS and Automation Applications, 20 February 2017 and 5GAA Study of spectrum needs for safety related intelligent transportation systems – day 1 and advanced use cases, 25 June 2020. Securing the availability of current spectrum and a plan for the extension in the near future is highly recommended. The guiding principle regarding communication technologies should be technology neutrality, provided a well-functioning and appropriate solution is guaranteed. The choice of appropriate technology should be left to the market as long as interoperability, scalability and harmonization for ITS related services is ensured.
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Meeting with Ursula von der Leyen (President) and Siemens AG and

6 Nov 2020 · Videoconference with Chairman of Volvo, Chairman of Siemens and Maersk, CEO of Air Liquide

Meeting with Ursula von der Leyen (President) and Siemens AG and

9 Oct 2020 · Videoconference with Chairman of Volvo, Chairman of Siemens and Maersk, CEO of Air Liquide

Meeting with Timo Pesonen (Director-General Defence Industry and Space)

6 Oct 2020 · Videoconference to discuss content and areas of European defence research.

Meeting with Ursula von der Leyen (President) and Siemens AG and

22 Jul 2020 · Videoconference with Chairman of Volvo, Chairman of Siemens and Maersk, CEO of Air Liquide (Topic: European Economic Recovery)

Meeting with Marius Vascega (Cabinet of Commissioner Virginijus Sinkevičius)

10 Jul 2020 · Green Deal in the area of heavy-duty vehicles, transport sector and environmental footprint

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

9 Jul 2020 · Truck automotive industry

Meeting with Wioletta Dunin-Majewska (Cabinet of Commissioner Elisa Ferreira)

9 Jul 2020 · Decarbonisation of transports

Meeting with Mariya Gabriel (Commissioner) and

9 Jul 2020 · EU Green Deal, Research & Innovation and Horizon Europe

Meeting with Ursula von der Leyen (President) and Siemens AG and

19 May 2020 · Videoconference with Chairman of Volvo, Chairman of Siemens and Maersk, CEO of Air Liquide (Topic: European Economic Recovery)

Meeting with Ursula von der Leyen (President) and Siemens AG and

30 Apr 2020 · Videoconference with Chairman of Volvo, Chairman of Siemens and Maersk, CEO of Air Liquide

Meeting with Ursula von der Leyen (President) and Siemens AG and

17 Apr 2020 · Videoconference with Chairman of Volvo, Chairman of Siemens and Maersk, CEO of Air Liquide

Meeting with Margrethe Vestager (Executive Vice-President) and

6 Feb 2020 · Digital policy

Meeting with Adina-Ioana Vălean (Commissioner) and

6 Feb 2020 · Discuss the automotive industry

Response to European Partnership for Safe and Automated Road Transport

22 Aug 2019

The Volvo Group welcomes the progress made towards an agreement for the next framework programme Horizon Europe. For the key challenges of Connected Automated Mobility (CAM or CCAM) and self-driving vehicles, the Volvo Group calls for a co-programmed partnership (option 1) across industry sectors and value chains: • The co-programmed partnership will enable quick and timely research actions; the institutionalised partnership (based on Article 187 TFEU) inherently will take longer time. Europe cannot afford to lose the global innovation race. We must accelerate R&I programmes, especially when it comes to digitalisation of road transport. With shorter innovation cycles and increasingly fast-acting competition from countries like the United States and China, Europe needs to accelerate both research and the time-to-market. • Increased agility and flexibility of programme and projects. Due to the increased demands on the industry’s constantly evolving business environment, it is crucial to improve the agility and flexibility of R&I programme implementation in order to deliver results in time and with the available resources and funding. The rigid structure of an institutionalised partnership will not fulfil this requirement. • Reduce administrative burdens for the setting up and executing the R&I programme as much as possible. Lower administration efforts are clearly favouring a co-programmed partnership for R&I in Connected Automated Mobility. Digitalisation and automation are both innovation drivers for the automotive industry and decisive factors for the future mobility of citizens in Europe. The Volvo Group is committed to achieve safer, cleaner, smarter and more efficient transport solutions by further emphasising collaborative research in Connected and Automated Mobility (CAM): • CAM technologies will support the Vision Zero targets set for 2050 by decreasing the number of road fatalities and accidents. • CAM contributes to reducing transport emissions and congestion, while ensuring inclusive mobility for persons and goods. • CAM will provide individual mobility to all users; in particular elderly and people with disabilities. • CAM will have a remarkable economic impact ensuring long-term European growth and jobs. • CAM will enable new mobility concepts shifting design & development from a driver-centred to mobility-user-centred approach. The Volvo Group’s ambition for R&I in CAM is to accelerate the implementation of Connected Automated Vehicles significantly; advance the technological competitiveness of the automotive industry; and maintain its position as a significant employer in Europe
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Response to Specifications for the provision of cooperative intelligent transport systems (C-ITS)

8 Feb 2019

The Volvo Group is one of the world’s leading manufacturers of trucks, buses, construction equipment, marine and industrial engines, appreciate and support the published delegated act on C-ITS. As a global transport solution provider, the Volvo Group is driving the technical development and solutions aiming increased traffic safety, environmental care and prosperity in the world. We believe that C-ITS is an important technology towards our common long-standing goal to reduce the number of fatal accidents, improve traffic efficiency and introduce new mobility services. We as Volvo Group fully support these efforts of the European Commission and its Member States for making C-ITS a success in Europe. Having followed the regulatory debate on the Delegated Regulation, we would like to express our strong support for the only exiting technology which has extensively been tested and is ready for large deployment i.e. ITS-G5 (IEEE 802.11p). In order to ensure a coordinated deployment of C-ITS technologies, a Delegated Regulation necessarily has to reference standards of available and proven technologies. Moreover, the Delegated Act is sufficiently open for embracing new emerging technologies in the future, e.g. 5G technology. Without a regulatory guidance the rollout of C-ITS functionalities to EU roads would be delayed by several years and existing investments in vehicles and road infrastructure across Europe could become obsolete, without a guarantee of interoperability, backward compatibility and continuity of services in the future. However, the industry needs appropriate lead time between adoption and entry into force in order to ensure compliance with the requirements. We want to emphasize the importance of industry involvement, both now and in the future, to address and find solutions to remaining open items that need a clear understanding. We would like to re-state and emphasize comments also provided by Car2Car Communication Consortium (not included here).
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Response to Commission Implementing Act on on-board weighing equipment

18 Jan 2019

Whereas (5) says ”The current state of the technology does not make possible the implementation of neither CEN DSRC nor C-ITS communication standards in on-board weighing equipment by 27 May 2021“. Does this mean that neither CEN DSRC nor C-ITS will be required for 27 May, 2021? “Enforcement” could be understood that drivers are fined immediately, which is not the case for this regulation. If direct fining refers to Stage 2 in this regulation, then what have we done for 2 years with DG MOVE? Are Member states which opt for on-board weighing obliged to adopt stage 2 OBW by 2024? It should be clearly stated that they are not. It should also be clearly stated what Stage 2 is supposed to solve, if it is enhanced requirements for pre-selection it should say so, or is the objective to get a certified system for OBW to be used for direct fining? Systems used for fining should be further detailed than what is written in this regulation. Current Stage 2 is not certified and thus cannot in its current state be used for fining the drivers. Such criteria should not be up to each member state to define. The security that is requested is not suitable for pre-selection purposes, nor is it proportionate to the purpose of a pre-selection system. The security justification (whereas (3)) refers to other vehicle systems such as the tachograph and emission control. However, no security is required for emission control, nor is it is enforced roadside or for pre-selection purposes. The digital tachograph is not a vehicle system and its security is not designed or implemented by vehicle manufacturers, thus have its own criteria. No other vehicle regulation has as high security requirements as stipulated in this regulation. Article 1 only allows member state (“may”) to exempt vehicles not designed or suitable for exceeding maximum authorized weight from on-board weighing, it does not require member states to exempt them. Anything else than EU harmonized exemptions would require vehicle manufacturers to develop solutions for all vehicles. This will be very costly and add cost for all vehicles. The exemptions in Article 1 are unspecific and there is a clear risk that it will be implemented differently in respective member state that opt for on-board weighing. For vehicle and trailer manufacturers this is base for high risk as they need to prepare vehicles that are not suited/designed for weight sensing and transmitting equipment as a precaution since such fitments takes time to develop and vehicles can be sold and delivered several months prior to registration. This uncertainty will carry over costly solutions on vehicles that may never be required to have on-board weighing. There is a conflict in Annex I between 1.3 and 2, where the former has axle weight on the motor vehicle as an option and the latter makes axle weight processing mandatory if there is a TU, how shall vehicle manufacturers know what trailers that will have a TU? This implies axle weight becomes mandatory as a precaution for motor vehicles. Stage 2 accuracy requirement also implies axle weight because of the technical limitations of dynamic systems. If the trailers don’t have a TU the vehicle combination will be impossible if the dynamic system cannot measure weight with 5% accuracy (Stage 2), according to this regulation. The only possible way to ensure compliance with this regulation is then to use axle weight, but mandating OBW-opted member states to request axle weight exceeds the purpose and the mandate from 96/53. With current text, axle weight is no longer optional for Stage 2. Annex II Figure 4 has a picture with a box called "OBW message". It should be called "OBW-VU message" for consistency with text and definitions in paragraphs. Inspections will take a long time to load/unload and loadings needs to be in various formats to fit for all types of vehicles. Inspection will require thorough planning as both vehicles and trailers need their own reports respectively.
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Meeting with Violeta Bulc (Commissioner) and

5 Jul 2018 · Meeting on tachographs

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

22 Sept 2017 · Connected Cars

Meeting with Manuel Nobre Goncalves (Cabinet of Commissioner Carlos Moedas) and Association des Constructeurs Européens d'Automobiles

10 Mar 2017 · Annual EUCAR Reception

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

7 Feb 2017 · Innovation in trucks and busses

Meeting with Violeta Bulc (Commissioner) and

18 Jan 2017 · Meeting with Mr. Håkan Agnevall, Member of the Volvo Group Executive Management

Meeting with Manuel Nobre Goncalves (Cabinet of Commissioner Carlos Moedas)

7 Dec 2016 · Preparation for the Innovation Summit 2017

Meeting with Günther Oettinger (Commissioner) and Orgalim – Europe's Technology Industries and

15 Sept 2016 · digitising european industry

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

7 Oct 2015 · CO2 emissions

Meeting with Joao Aguiar Machado (Director-General Mobility and Transport)

14 Apr 2015 · Safety and environmental performance, Urban mobility

Meeting with Miguel Arias Cañete (Commissioner) and

9 Apr 2015 · Decabornisation of Road Transport