BMW Group

The BMW Group welcomes the European Commissions draft implementing regulation and the opportunity to provide feedback. We support the efforts to establish a harmonised and robust framework for the implementation of Extended Producer Responsibility (EPR) obligations while ensuring effective producer registration and reporting systems under the Packaging and Packaging Waste Regulation (PPWR).

The BMW Group supports the development of the EU's circular economy legislation by presenting a concrete and holistic concept. This paper is intended to present an underlying strategic concept and go beyond individual positions.

For Economic Activity CCM 6.5 of Annex I Pollution Prevention & Control, among others this involves requirements related to rolling resistance and rolling noise. The effort required to prove compliance with tire requirements is disproportionate to the actual benefits, leads to misunderstandings on investor and stakeholder level and creates double regulation with a high level of additional bureaucratic effort.

BMW Group already started in 2010 by implementing due diligence activities with focus on human rights, environmental and social sustainability standards in the supply chain. By setting up a cross-sectoral harmonized sustainability questionnaire in close cooperation with the Drive Sustainability Initiative in 2014 BMW Group took an important step for conducting risk management in its supply chain.

Clean Corporate Vehicles Why Mandates Miss the Mark. Why it matters: The EU Commission is developing a Clean Corporate Vehicles initiative as part of its Clean Industrial Deal and Automotive Sector Action Plan. Corporate fleets which account for around 60% of all new car registrations in the EU play a role in the transition to zero-emission vehicles (ZEVs).

The BMW Group is already the first German car manufacturer to firmly anchor the 1.5 degree path of the Paris Climate Agreement in its business strategy and to become climate neutral by 2050. As part of its holistic sustainability strategy, BMW Group intends to offer cars with the best competitive environmental footprint to its customers.

Filed in German · English published by the European Commission

With “Fit for 55”, the Commission has presented a comprehensive package of 13 pieces of legislation with the objective of reshaping the EU's climate policy on a large scale. BMW Group is convinced that Europe and the European Economy can take a globally leading role in advancing climate change mitigation.

// Full feedback attached as PDF // Summary: An extension of the scope should be postponed until the original regulatory framework for the definitive phase has been fully established. It is almost impossible to evaluate an extension appropriately without a complete regulatory package (methodology, recognition of foreign regulations, standard and benchmark values, distribution cost plan, verification).

With “Fit for 55”, the Commission has presented a comprehensive package of 13 pieces of legislation with the objective of reshaping the EU's climate policy on a large scale. BMW Group is convinced that Europe and the European Economy can take a globally leading role in advancing climate change mitigation.

Dear ladies and gentlemen, we appreciate the European Commission's proposal on the Data Act and support the fundamental principles, already formulated in the European Strategy for Data in 2020, that secure data sharing is - and moreover will be - one important pillar for the European digital economy.

The current proposal by the EU Commission for a 2040 intermediate climate target is aimed exclusively at implementation by EU member states. Other targets that have already been adopted apply to commercially active companies. These different targets pursue the overarching goal, but differ in terms of implementation, requirements, and calculation.

BMW welcomes the opportunity to contribute to the ongoing EU consultations regarding the CBAM: methodology for the definitive period; carbon price paid in a third country; adjustment of obligation to surrender them to take account of free ETS allowances.

The BMW Group is aware that forests provide important resources and ecosystem services for both companies and society. In recognition of this, the BMW Group is committed to support minimizing deforestation and forest degradation. Therefore, we would first like to emphasize that we fully support the goals of the EUDR.

We, the BMW Group, are convinced that Europe and the European Economy can take a globally leading role in advancing climate change mitigation. As a globally acting company the BMW Group promotes for global decarbonisation and the implementation of human rights and sustainability standards in the supply chain.

The BMW Group welcomes the European Commission's proposals for a simplification of administrative burdens in environmental legislation. Sustainability is a key driver for decision making, and our continuous sustainability efforts are a competitive advantage for the BMW Group. Measures that do not demonstrably contribute to overarching or specific environmental objectives should therefore be avoided.

BMW Group welcomes the opportunity to provide feedback on the European Commission's consultation on the future European Chips Act (Chips Act 2.0). Semiconductors are a key enabling technology for Europe's industrial competitiveness, digital transformation, and technological resilience.

The BMW Group is committed to the goals of the Paris Agreement and is leading the way in circularity within the automotive industry. We underpin our commitment with ambitious targets for the use of secondary raw materials as well as with principles including Secondary First, which prioritizes the use of recyclates in development processes, and Design for Circularity, which takes a vehicles recyclability into account…

BMW welcomes the opportunity to contribute to the ongoing EU consultations regarding the CBAM: methodology for the definitive period; carbon price paid in a third country; adjustment of obligation to surrender them to take account of free ETS allowances.

The BMW Group welcomes the European Commission's proposal to promote an agile and future-oriented approach to the introduction of legislation and to reduce bureaucratic requirements for companies. This paradigm shift is essential to ensure that the regulatory framework can effectively address both current and new challenges.

The Digital Product Passport (DPP) registry draft implementing act represents a crucial step in defining the core architecture for the trusted digital infrastructure needed to support efficient product markets in the EU.

The BMW Group welcomes the European Commissions Call for Evidence on the calculation, verification and reporting of recycled content under Article 7(8), (9) and (10) of the Packaging and Packaging Waste Regulation (PPWR) and appreciates the opportunity to provide feedback.

The BMW Group welcomes the European Commissions Call for Evidence on the calculation, verification and reporting of recycled content under Article 7(8), (9) and (10) of the Packaging and Packaging Waste Regulation (PPWR) and appreciates the opportunity to provide feedback.

The EUs CO2 regulation remains one of the most ambitious climate initiatives worldwide, designed to accelerate the transition toward zero-emission mobility by 2035. It has triggered unprecedented investments into electrification, infrastructure and new technologies. Yet, five years into implementation, a significant gap has emerged between regulatory expectations and market developments.

We welcome the opportunity to contribute to the European Commissions Digital Fitness Check and to share our views on the cumulative impact of EU digital legislation. As a company active across multiple digital and data driven value chains, we strongly support the objective of ensuring a coherent, proportionate and innovation friendly regulatory framework that strengthens Europes competitiveness while safeguarding…

The EBW introduces a harmonised, interoperable and legally recognised infrastructure for identification, authentication and the exchange of standardised digital proofs across the EU. If implemented well, it can reduce document based friction and support more automated, verifiable and scalable compliance workflows.

The BMW Group welcomes the European Commissions Call for Evidence on the calculation, verification and reporting of recycled content under Article 7(8), (9) and (10) of the Packaging and Packaging Waste Regulation (PPWR) and appreciates the opportunity to provide feedback.

BMW welcomes the opportunity to contribute to the ongoing EU consultations regarding the CBAM: methodology for the definitive period; carbon price paid in a third country; adjustment of obligation to surrender them to take account of free ETS allowances.

The BMW Group welcomes the Delegated Act on the Methodology for the Calculation and Verification of the Carbon Footprint of Electric Vehicle Batteries, although we have certain concerns with the current state of the draft. In the proposed delegated act for EU battery regulation, the EU no longer plans to accept renewable energy certificates.

The European Commissions tax simplification agenda and the forthcoming Omnibus on Taxation should identify priority measures that reduce compliance burdens, eliminate redundancies, and enhance EU competitiveness. For BMW Group the two most important items would be The elimination of (German) CFC rules (example: would avoid monitoring substance in holding companies of BMW Group).

The BMW Group welcomes the European Commission's public consultation on labelling under the EU Battery Regulation. In principle, minor adjustments should be made to the labelling requirements to ensure clarity on labels. This requires greater flexibility in labelling methods and formats. The BMW Group has listed its feedback with the most important points. Please find this overview in the document attached.

The BMW Group welcomes the initiative to simplify administrative burdens regarding energy-efficient products legislation. Such initiatives offer critical relief for industry and strengthen the global competitiveness of European companies.

The BMW Group supports the objective of making iron and steel products more sustainable. Well-designed ecodesign requirements can improve transparency for customers and provide industry with the legal certainty and long-term predictability needed to invest in the transition. At the same time, the framework must avoid duplicating rules that already apply to the automotive sector.

BMW Group supports implementing rules that enable efficient and proportionate operation of the CBAM certificate system. Key priorities are group-level certificate management, standardized API connectivity, quarterly repurchase opportunities, timely processing of repurchase requests, and transparent certificate allocation and pricing rules.

The BMW Group welcomes the European Commissions Draft Delegated Act for the recycled content calculation and verification rules in the context of the EU Battery Regulation (EU 2023/1542). Strengthening the circular economy and therefore reducing environmental impacts through involving recycled content is an essential part of BMW Groups sustainability strategy.

The BMW Group welcomes the proposed postponement of the battery due diligence requirements and asks for a quick adoption. The postponement of the Battery Regulation due diligence obligations by two years is a necessary measure to give authorities enough time to appoint the required notified bodies and to finalize the urgently needed implementation guidelines in due time.

We understand that the rationale behind the introduction of an anti-coercion instrument (ACI) is to deter third countries from influencing the EU and its member states via economic coercion. We also understand that the use of this instrument is intended as a last resort and that ideally its use would never be necessary.

We welcome the digitalization of the VISA procedure, which ensures a convenient facilitation of the process. By digitising the following aspects should be considered: • All accompanying documents in the application process should be displayed in English and German • In addition the digital application process should enable to upload the application form including all accompanying documents in English and German •…