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Conc. Art. 59: We are pleased that independent operators will be granted access to the battery management system for industrial rechargeable batteries and electric vehicle storage batteries with a capacity of more than 2 kWh so that they can assess and determine its condition as well as the remaining lifetime.

The TÜV-Association welcomes the EU Commissions initiative to modernise EU legislation on batteries. Batteries are becoming more and more essential for key sectors of our economy and society such as mobility, energy and communications. In order to fully tap the potential of batteries for environmental and climate protection, their own ecological and social footprint must be as low as possible.

As a TÜV association, we welcome a product policy that ambitiously promotes the transition from a linear economy to a circular economy. This includes the issue of the repair (ability) of products with the aim of significantly prolonging their useful life. The Sustainable Products (SPI) initiative should establish a right to reparability. The TÜV Association supports Option 3 taking into account all sub-options.

Filed in German · English published by the European Commission

Vehicles are designed and equipped with very advanced technology in order to last in time for many years (in average 13 years). Vehicles are already reliable and durable products which provide value for money to consumers and prevent the overuse of resources and waste.

The TÜV Association welcomes the EU Commissions proposal on common rules promoting the repair of goods. The Right to Repair will make it easier and more cost-effective for consumers to repair goods rather than have them replaced. In addition, increased demand will boost the repair sector while creating incentives for manufacturers and sellers to develop more sustainable business models.

In the document downloadable via the link below, we have studied the three options of the proposal: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12313-Development-of-Euro-7-emission-standards-for-cars-vans-lorries-and-buses We have chosen the most virtuous of the 3 but not in its current form. We support option 3 but with some amendments : see CECRA's position in attachment.

VdTÜV (Association of Technical Inspection Agencies) advocates technical safety and trust in products, plants and services by independent testing in the European Union. Its international members are the TÜV organizations as well as industrial companies which are affiliated with the objectives and tasks of the association.

TÜV Verband e.V. in line with CITA aisbl welcomes the initiative of the European Commission to tackle the issues of accessing vehicle data, functions and resources. Due to significant impacts of the Data Act on the mobility ecosystem, we support the intention of the EU Commission, in line with recital 3 of the Data Act, to adopt specific provisions within the EU type-approval regulations for the automotive sector.

CECRA welcomes the initiative of the European Commission for sectoral legislation on access to vehicle data, functions and resources. With the introduction of the draft Data-Act on February 23rd, 2022 “COM (2022) 68 final; 2022/0047 (COD)” on access to data, the Commission has setup a positive framework to build on the sectoral legislation for the Automotive sector.