ACEA

ACEA welcomes the Commissions proposal for a Digital Omnibus Package as a crucial step toward a more coherent and business-friendly regulatory environment and put forward proposals on key areas which we believe can foster innovation, strengthen competitiveness, and help ensure that Europe remains a global leader in automotive technology and digital transformation.

ACEA represents Europes 16 major car, van, truck, and bus manufacturers. Modern vehicles are central to the digital economy, serving as platforms for advanced technologies, connectivity, and innovative business models, making the automotive sector a key driver of Europes digital solutions.

ACEA is the voice of the European auto industry representing 17 major car, truck, van and bus makers. ACEA welcomes the Commissions aim to use public procurement to accelerate decarbonisation and strengthen industrial resilience. Our submission addresses the potential use of made in the EU requirements for the heavy duty vehicle segment.

The European Automobile Manufacturers Association (ACEA) shares its initial views and broad assessment on the IAA as a whole. This text does not include all detailed industry positions or proposals on each relevant IAA provision. Further details will be shared in an ACEA position paper at a later stage.

The European Automobile Manufacturers' Association (ACEA) welcomes the opportunity to provide input to the Commission via this public consultation. Please see attached file in which we share our feedback and main concerns, focussed at the issue of creation of local content requirements at European level.

The European Automobile Manufacturers Association (ACEA) welcomes the proposal to revise the Renewable Energy Use Directive (RED) and the Fuel Quality Directive (FQD). RED is one of the key cornerstones of an effective policy framework which supports and enables the transition to carbon-neutrality. ACEA’s position paper on RED-FQD is attached.

The European Automobile Manufacturers' Association (ACEA) welcomes the opportunity to provide feedback on the inception impact assessment towards a revision of Directive (EU) 2018/2001 on the promotion of energy from renewable sources (RED). Please find attached our contribution.

ACEA represents Europe's 17 major car, van, truck and bus manufacturers. As vehicles become ever more integrated into the broader digital ecosystem, the regulatory framework governing electronic communications infrastructure and services increasingly impacts the sectors ability to compete and innovate.

The European Automobile Manufacturers' Association (ACEA) appreciated the Commission's initiative to review the Climate and Environment Delegated Acts of EU Taxonomy. We have identified a few key areas where improvement is not only possible, but needed. Please see attached our position:

Please find attached detailed comments for the CRMA as well as associated NZIA. In general the industry welcomes the activities to facilitate and simplify procedures, but is aware of the subsidiarity and lack of EU competencies in that area - member states will be key to deliver. Streamlined and enhanced financial instruments are missing as well, especially for NZIA.

Internal Ref. Ares(2022)8160516 - 25/11/2022 25 November 2022 ACEA views on the Critical Raw Materials Act initiative Internal ACEA VIEWS ON THE CRITICAL RAW MATERIALS ACT GENERAL REMARKS ACEA welcomes the announced initiative of the European Commission for a European Critical Raw Materials Act (CRMA).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Automobile Manufacturers Association appreciates the Commissions efforts to achieve simplification in the area of sustainability reporting standards and this proposal. However, further clarifications and simplifications will be key to achieve meaningful results for companies. Please see attached our comments.

Paving the way to carbon-neutral transport 10-point plan to implement the European Green Deal January 2020 CONTEXT The transport sector is responsible for 22.3% of total EU greenhouse gas (GHG) emissions, with road transport representing 21.1% of total emissions.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ACEA is thankful for the opportunity provided by the Commission to comment on the proposed AI Act, adopted on 21 April 2021. The present ACEA response, attached hereunder, builds on ACEA’s previous contributions to the Commission’s White Paper (12 June 2020, document No.

ACEA welcomes LCA analyses as they are important procedures that can help to reduce a motor vehicle’s impact on the environment and believes that the studies made should be scientifically sound and compare equivalent systems. LCA can be a useful tool to address environmental issues and is applied as internal environmental system for systematically managing environmental improvements in the automotive industry.

ACEA POLICY PAPER ON GREENING CORPORATE FLEETS FOR LIGHT DUTY VEHICLES BRUSSELS, 5 SEPTEMBER 2025 www.acea.auto 1 CON EXECUTIVE SUMMARY The corporate fleet market for passenger cars and vans is highly complex. An artificial acceleration of market demand completely ignores the still absent regulatory frameworks necessary to achieve such high electrification rates in the EU.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Automobile Manufacturers Association (ACEA) welcomes the proposal to establish an emissions trading system for road transport. It is one of the key cornerstones of an effective policy framework which supports and enables the transition to carbon-neutrality. - Achieving the necessary emission reductions by 2030 and on the way towards climate neutrality requires unprecedented efforts by all stakeholders.

ACEA welcomes the opportunity to comment on the Inception Impact Assessment “Amendment of the EU Emissions Trading System” and would like to provide the following comments. We welcome the recent communications by the Commission which open up the possibility for an expanded ETS which could be developed as an upstream trading system regulating at the point of fuel distributors or tax warehouses.

August 2025 ACEA COMMENTS CALL FOR EVIDENCE FOR AN IMPACT ASSESSMENT: CBAM DOWNSTREAM EXTENSION AND RULES FOR THE ELECTRICITY SECTOR CBAM will assist ACEA (European Automobile Manufacturers Association) members in reaching climate neutrality commitments and is a necessary complimentary instrument to allow for increased ambition in the ETS.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Automotive Submission on the Revision of EU legislation on hazard classification, labelling and packaging of chemicals The Automotive Industry welcomes the opportunity to provide feedback on the inception impact assessment. Making the economy and society more sustainable.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Automobile Manufacturers Association (ACEA) welcomes the Commission’s proposal to the Council on the restructuring of the Union framework for the taxation of energy products and electricity. Within the fit for 55 package, the ETD is one of the key measures for an effective policy framework that supports and enables the transition to carbon-neutrality. ACEA’s position paper on ETD is attached.

The European Automobile Manufacturers’ Association (ACEA) appreciates the opportunity to give feedback on this proposal for a Data Act. ACEA supports the Commission’s ambition to put consumers at the centre of the data-sharing process and to achieve fair, reasonable, and non-discriminatory access to data across all sectors of the data economy.

The European Automobile Manufacturers Association, ACEA, unites Europes 16 major car, truck, van and bus makers. ACEA members are users and importers of CBAM goods that they use in the building of motor vehicles in Europe. Please find our comments regarding the current consultation in the attached file.

The European Automobile Manufacturers’ Association (ACEA) is committed to reducing industrial emissions and therefore supports the planned revision of the IED. We as ACEA believe that the revision should be practical for companies as well as for authorities, and should start at the value-added processes where the greatest relevance for the reduction of industrial emissions can be achieved.

ACEA welcomes the opportunity to provide comments to the Inception Impact Assessment for the revision of the Industrial Emission Directive (IED). As general comment ACEA would like to underline that, while the European Commission intends to modify the Directive, the IED has been just implemented and a lot of BREFs are not yet updated and did not entered into force yet.

The European Automobile Manufacturers' Association (ACEA) in general welcomes the EU Commission's efforts to provide further guidance and clarity on the implementation of the EU Deforestation Regulation (EUDR). However, key issues remain, adding additional/unnecessary burdens and leading to legal uncertainties for our industry.

ACEA would like to provide its initial assessment on the Commission proposal on a new Battery Regulation. ACEA supports that batteries placed on the EU market should become sustainable, high-performing, and safe all along their entire life cycle and keep a level playing field.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ACEA believes that any collection target would be inefficient to recycle more batteries. Therefore no changes are necessary to the actual legislation.Efficient and well-working collection and recycling processes, not only for automotive batteries and traction batteries, but for vehicles as such, are already implemented in many Member States.

ACEA, the European Automobile Manufacturers Association, strongly welcomes the Review of the Weights & Dimensions Directive published on 11 July 2023 as part of the Greening Freight Package. The Review of the Directive is one important element of the regulatory framework to facilitate the market uptake of zero-emission vehicles (ZEVs), namely battery-electric and hydrogen-powered trucks and buses.

The European Commission has invited stakeholders to provide views on a range of questions on the revision of current rules on weights and dimensions for heavy-duty vehicles. ACEA welcomes the initiative and is herewith providing comments. The last fundamental revision of the Weights & Dimensions Directive was only adopted 5 years ago ((EU) 2015/719), with additional amendments introduced in 2019 ((EU) 1242/2019).

The data ecosystem holds true potential in the data economy where our sector contributes to the objective of the Commission to foster the availability of data by both increasing trust and by strengthening data-sharing mechanisms across the EU.

We believe that the following preliminary perspectives are needed before creating any ex-ante rules on data spaces. 1. CONTEXTUALISATION OF INDUSTRY LED INITIATIVES: Ex-ante regulatory intervention for B2B/B2G data sharing should not be a primary goal given the competitiveness of our sector, its high investment level into R&D and data sharing initiatives and is therefore deemed premature and disproportionate.

ACEA welcomes the Commissions Environmental Omnibus package as a necessary and timely simplification initiative aimed at reducing administrative burden while preserving high levels of environmental protection. The automotive sector strongly supports targeted, proportionate amendments that enhance regulatory coherence, legal certainty and practical workability across the Batteries Regulation, the Industrial Emissions…

The European Automobile Manufacturers' Association (ACEA) is firmly committed to advancing the EU towards a modern, resource-efficient, and competitive economy. We welcome the European Commission's Proposal for a Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles (ELVs), which envisages a transformation towards enhanced sustainability, circularity, and innovation.

The ELV Directive, which came into force 20 years ago largely delivered on its initial objectives due to the significant efforts made by the automotive and the recycling industry. The European Automobile Manufacturers’ Association (ACEA) fully supports the European Commission’s initiative to ensure a better consistency with the objectives of the European Green Deal, including the Circular Economy Action Plan and the…

The European Automobile Manufacturers' Association (ACEA) supports the Commission’s objective of enhancing and ensuring a high level of cybersecurity for digital products and related services and of setting up a level playing field for vendors. This will help increase resilience against a continuously evolving and more complex cyber threat landscape.

ACEA takes note of the publication of the draft Implementing Act on the DPP registry. While the draft provides an initial framework for the future functioning of the registry and its interaction with the Battery Passport under Regulation (EU) 2023/1542, a substantial number of legal, technical and operational aspects remain insufficiently clarified at this stage.

Internal Ref. Ares(2023)7547637 - 07/11/2023 November 2023 Comments UCC Review ACEA COMMENTS ON THE EUROPEAN COMMISSION’S PROPSOAL FOR A REVIEW OF THE UNION CUSTOMS CODE INTRODUCTION The European Automobile Manufacturers Association (ACEA) has taken note of the proposal of the European Commission for a review of the Union Customs Code.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

In line with the overall contribution to the Green Deal implementation published by ACEA on 22 January (https://www.acea.be/publications/article/paving-the-way-to-carbon-neutral-transport-10-point-plan-to-help-imple), automobile industry considers investment into alternative fuels infrastructure absolutely essential and the proposal on the AFID review should be presented by the Commission even sooner than foreseen…

ACEA welcomes the initiative of the European Commission to gather evidence in view of drafting the rules applicable to DPP service providers, and would like to share some concerns and questions which we hope will be addressed in the delegated act - please see attachment.

SUSTAINABLE CONSUMPTION OF GOODS – PROMOTING REPAIR AND REUSE - ACEA COMMENTS The European Automobile Manufacturers’ Association (ACEA) welcomes the Commission’s initiative to promote sustainable consumption through the increased repair and reuse of goods. We believe motor vehicles are a good example of goods that are consumed in a sustainable manner.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ACEA welcomes the opportunity to provide comments to the European Commission Inception Impact Assessment on Waste shipments – revision of EU rules. ACEA believes that the Waste Shipment Regulation (WSR) does not effectively support the transition to a circular economy: the transboundary shipment of waste batteries aimed for recycling between EU Member States is currently subject to significant administrative…

ACEA represents Europe's 16 major car, van, truck, and bus manufacturers. ACEA welcomes the Commissions Digital Fitness Check as an opportunity to improve regulatory coherence and create a more business-friendly framework that supports innovation, competitiveness, and Europes leadership in automotive technology and digital transformation.

ACEA and CLEPA welcome the opportunity to provide feedback on the Commission’s proposal for a Directive on high common level of cybersecurity across the Union (NIS 2 Directive). The proposal is timely and an important initiative to address the emerging threats to the European Digital Single Market.

Europes water sector is entering a period of unprecedented pressure. Climate change, increasing drought frequency, ageing infrastructure, growing demand, stricter environmental standards and rising expectations regarding resilience are exposing the limits of traditional approaches to water management. Against this backdrop, digitalisation is no longer an optional technological upgrade.

ACEA supports the development of clear, robust and harmonised End-of-Waste (EoW) criteria to ensure that recycled plastics re-enter the economy safely and in full compliance with EU legislation on substances of concern, including legacy substances present in certain waste streams.

ACEA, the European Automobile Manufacturers' Association, welcomes the opportunity to contribute to the initial roadmap consultation regarding the consumer policy and how strengthening the role of consumers in the green transition. In particular ACEA welcome policy option 2: a new stand-alone consumer protection instrument.

Public consultation NC RfG (August 2026) Paragraph Whereas 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 TITLE I - General provisions Article 1 - Subject matter Article 1 Article 2 - Definitions 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 17 18 70 16 17 18 65 70 71 72 73 74 Amendment Proposal Mandate EN50549-1 and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

In 2019, the European Union set CO2 reduction standards for heavy-duty vehicles. These standards require manufacturers to reduce the average fleet emissions of new vehicles in certain regulated vehicle groups by 15% (by 2025) and 30% (by 2030), compared to a 2019/2020 baseline.

Comments to the public consultation on the Commission proposal for ambient air quality standards March 2023 Key Points: • Future air quality limits must be assessed on the basis of a full risk assessment and risk management process. • Any new sector-specific measures need time to deliver their intended benefits before new air quality limits values could apply.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Automobile Manufacturers Association (ACEA) welcomes the Commissions proposal on digitalisation and is fully aligned with the Commissions goal of reducing paperwork for businesses, cutting unnecessary administrative burdens, and encouraging the use of digital tools, such as digital product passports.

The automotive industry takes note of the recently published delegated act establishing the methodology for the calculation of the carbon footprint of electric vehicle batteries, as mandated by Article 7 of the Batteries Regulation.

The European Automobile Manufacturers' Association (ACEA) represents Europes 16 major Car, Van, Truck and Bus manufacturers. Technical defects on vehicles are related to less than 1% of fatalities, as a study from fka (RWTH Technical University Aachen) shows: https://www.acea.auto/news/less-than-1-of-accidents-caused-by-technical-defects-confirms-new-study/ Each potential measure should be evaluated with a…

Dear Sir, Ma'am, Please find below ACEA Position and feedback to the consultation. Logically, vehicles can clearly be identified by the individual VIN-Number and it is in the interest of vehicle manufacturers that our customer's are aware of the product manufacturer or recall actions triggers for used goods.

The European Automobile Manufacturers’ Association (ACEA) believes that the GPSD is still broadly fit for purpose and does not require a major overhaul. At the most, it could be revised in a targeted manner to update some of the definitions with a view to clarifying their applicability.

ACEA supports the move towards a harmonized emissions calculation framework in the EU. We believe that this will enhance the accuracy and comparability of emissions data and support companies in their sustainability efforts. However, it is essential that these new rules are carefully designed to align with existing regulations and avoid unnecessary duplication.

ACEA the European Automobile Manufacturers Association thanks the European Commission for the opportunity to provide comments on the European Chemicals Agency proposal for a basic regulation. We wish to express our support for the proposed regulatory amendments that strengthen the functioning and capacity of ECHAs scientific committees.

The European manufacturers of cars, vans and heavy-duty vehicles (trucks, buses and coaches), represented by ACEA, are fully committed to providing the right vehicles to swiftly move Europes mobility and transport sector to climate neutrality and to minimise the impact of our sector on air pollution. ACEAs members support the aim to improve air quality in Europe.

The European Automobile Manufacturers' Association (ACEA) represents the 16 major Europe-based car, van, truck and bus makers. The activities of ACEA members sustain 13.8 million jobs for Europeans in the auto industry (directly and indirectly), accounting for 6.1% of all EU jobs.

ACEA welcomes the opportunity to provide feedback on the European Commission’s Inception Impact Assessment on adapting liability rules to the digital age and circular economy. We provide detailed observations on this initiative in the document attached.

ACEA welcomes the Commissions proposal to increase the choice and level of support measures for combined transport organizers, but challenges the statements on modal shift, raises concerns on how the Commission will ensure sufficiently precise comparison of operations overtime and how the Commission intends to ensure consistency and complementarity of the common harmonised calculation methodology for externalities…

The underlying principle in combining two or more modes of transport is efficiency. To stay competitive with respect to costs, all modes have to improve their efficiency. The achievement of a true internal market for rail, short sea and inland waterways transport services and the improvement of their full potential in terms of productivity is essential for a true intermodal or multimodal transport based on…

The underlying principle in combining two or more modes of transport is efficiency. To stay competitive with respect to costs, all modes have to improve their efficiency. The achievement of a true internal market for rail, short sea and inland waterways transport services and the improvement of their full potential in terms of productivity is essential for a true intermodal or multimodal transport based on…

ACEA acknowledges the updated draft Implementing Regulation on battery labelling and welcomes the direction taken by the European Commission towards greater flexibility and digitalisation of battery labelling requirements.

March 2026 Simplification of energyefficient products legislation ACEA input to call for evidence ACEA RESPONSE TO THE EUROPEAN COMMISSION CALL FOR EVIDENCE ON ENERGY-EFFICIENT PRODUCT LEGISLATION ACEA welcomes the initiative and is happy to contribute to the tyre related part. There are indeed some improvements concerning the tyre label possible.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ACEA welcomes the objectives of the Critical Raw Materials Act (CRMA) to reinforce the resilience and sustainability of European supply chains. To ensure regulatory efficiency and avoid unnecessary complexity, the CRMA must be closely aligned with existing sectoral legislation, most notably the Batteries Regulation and the proposed End-of-Life Vehicles (ELV) Regulation.

Preliminary comments to the European Commission Inception Impact Assessment related to the update of concentration limit values of persistent organic pollutants in waste as per the Annex IV and V of the EU Regulation 2019/1021 on POPs. Over the last few years, ACEA members have significantly reduced the volume and number of substances classified as persistent organic pollutants in new vehicles.

The European automobile industry is concerned about the Commission's suggestion to abolish design rights for automotive spare parts. We believe this would: - Deprive an innovative industry of fair returns on investment Vehicle manufacturers design, develop, engineer and test vehicles and parts.

ACEA welcomes the opportunity to provide feedback to the Commission (EC) on this Inception Impact Assessment on the revision of the ITS Directive. Please refer to our detailed response attached to this summary. We agree with the EC that attention should be given to the lack of interoperability and cross-border continuity of applications, systems and services.

The European Automobile Manufacturers' Association (ACEA) recognises the European Commissions proposal to postpone the due diligence obligations under the EU Batteries Regulation (EUBR). We understand that this delay is a pragmatic and necessary measure to ensure that manufacturers and relevant authorities can meet the Regulations objectives effectively.

ACEA, the European Automobile Manufacturers' Association welcomes the opportunity to comment on the Commission Roadmap “Towards an EU Product Policy Framework contributing to the Circular Economy”. Particularly, ACEA members would like to reflect on the problem this initiative aims to tackle. Please find ACEA feedback enclosed.

The automotive industry is a major downstream user of chemicals and a manufacturer of articles supporting for many years the objectives of the Stockholm Convention. ACEA however would like to express its concern and share its comments regarding the published amending Regulation 2019/1021 of the European Parliament and of the Council as regards medium chain chlorinated paraffins.

The automotive industry is a major downstream user of chemicals and a manufacturer of articles supporting for many years the objectives of the Stockholm Convention. ACEA however would like to express its concern and share its comments regarding the published amending Regulation 2019/1021 of the European Parliament and of the Council as regards to long-chain perfluorocarboxylic acids, their salts and related…

ACEA acknowledges the Commission’s efforts to establish an innovative and competitive European battery value chain and to foster safe and efficient development and use, together with high sustainability requirements for batteries placed on the EU market.

ACEA welcomes Commissions better regulation efforts to enhance competitiveness of European companies. Hence it is positive that Eco-design for Sustainable Products Regulation (ESPR) explicitly does not apply to vehicles, since they are already covered under existing EU sector-specific regulations, including the End-of-Life Vehicle Regulation (ELVR).

ACEA welcomes the opportunity to provide feedback on the draft Commission Implementing Regulation laying down rules, procedures, testing methodologies and administrative requirements for the application of Regulation (EU) 2024/1257 (Euro 7) with regard to brake particle emissions of M1 and N1 vehicles. The incorporation of internationally developed methodologies, including those based on UN Regulation No.