Verband der Automobilindustrie e.V.

The German Association of the Automotive Industry (VDA) welcomes the European Commissions initiative to simplify the digital legal framework through the Digital Omnibus. Consolidating existing regulations is an important step toward strengthening European industrys competitiveness and enhancing legal clarity for companies.

Please find attached the feedback of the VDA which outlines the German Automotive Industrys recommendations to ensure that the Digital Omnibus delivers on its promise: to provide a future-proof, innovation-oriented regulatory environment that supports Europes industry in mastering the twin challenges of digitalization and decarbonization.

The German Association of the Automotive Industry (VDA) consolidates around 620 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. As VDA we fully support the advancing of the European Union into a modern, resource-efficient and competitive economy.

Position Paper Industrial Accelerator Act German Association of the Automotive Industry (VDA) June 2026 VDA | INDUSTRIAL ACCELERATOR ACT | JUNE 2026 Disclaimer The VDA recommendations are recommendations that anyone is free to apply. Those who apply them are responsible for their correct application in specific cases. They reflect the state of the art.

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

Please find our input and recommendations on the IDAA in the document attached. The German Association of the Automotive Industry (VDA) consolidates around 620 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.

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.

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 German Association of the Automotive Industry (VDA) consolidates about 650 manufac-turers 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 of-fers. We represent the interests of the automotive industry and stand for modern, future-oriented multimodal mobility on the way to climate neutrality.

Please find the feedback of the German Association of the Automotive Industry (VDA) in the document attached. The German Association of the Automotive Industry (Verband der Automobilindustrie / VDA) represents the interests of the German automotive sector at a national, European, and international level.

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 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.

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.

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…

In principle, the VDA welcomes the fact that the proposal for a “Directive on Corporate Sustainability Due Diligence" has laid the foundations for a uniform implementation of sustainability requirements in the member states of the EU.

Comment on the EU Clean Corporate Vehicles Initiative Introduction The German automotive industry is in the midst of the biggest transformation in its history. It is of great importance for prosperity and employment in Germany. Therefore, a successful transformation towards climate-neutral transport is of interest to society as a whole.

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.

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.

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 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.

Stellungnahme zur EU-Verordnung Cybersecurity Act II Mai 2026 EU Verordnung Cybersecurity Act II 1. Executive Summary Der Verband der Automobilindustrie (VDA) unterstützt die Zielsetzung des Cybersecurity Act II, die europäische Cybersicherheitsarchitektur an eine verschärfte Bedrohungslage und an geopolitische Risiken anzupassen.

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

Please find attached the position of the German Association of the Automotive Industry (VDA). For the time being, the German automotive industry clearly rejects an extension of the CO2 border adjustment mechanism to downstream product groups due to the ques-tionable climate policy benefit, the risk of additional trade barriers, and the high com-plexity.

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.

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 a revision of the EU energy taxation directive (ETD). I.

The Verband der Automobilindustrie e.V. (VDA) represents the interests of the German automotive industry at national, European and international level. As a representative of the key sector of the German economy, the VDA assumes its responsibility for around 620 member companies.

Filed in German · English published by the European Commission

Dear Sir or Madam, please find enclosed the opinion of the Automobile Industries Association (VDA) on the draft Data Act. Yours sincerely, Dr [name removed], LL.M. Head of Legal and Compliance Department Association of Automotive Industries (VDA) Behrenstr.

Filed in German · English published by the European Commission

The German automotive industry welcomes the European Commission's proposal on amending Annex I of the EUDR. However, with regard to prototype components and test parts, the focus should be on the intention to use prototype parts exclusively for testing purposes instead of having to prove that these components are entirely used up or destroyed.

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.

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…

The increasing density of reporting requirements and bureaucratic obligations has posed signif-icant challenges for companies in the automotive industry and many other sectors for years. In particular, European environmental legislation, which aims at driving the sustainable transfor-mation of the economy and society, has led to a noticeably growing administrative burden in recent years.

Beitrag des Verbands der Automobilindustrie zum von der EUKommission vorgeschlagenen „Fahrplan für Naturgutschriften“ Datum 30.09.2025 Die Europäische Kommission hat am 7. Juli 2025 eine Roadmap zum Thema Naturgutschriften veröffentlicht, um Anreize für private Investitionen in den Schutz und die Erhaltung der Natur zu schaffen.

Filed in German · English published by the European Commission

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

In recent years, the German automotive industry has experienced one of the most severe supply crises in its history. The pandemic and global supply bottlenecks have highlighted the dependency on international value chains. Against this backdrop, the European Chips Act was an important step toward securing semiconductor supply and strengthening Europes technological sovereignty.

The German automotive industry is fully committed to the Paris climate targets. The strategy of the German automotive industry to reduce the carbon footprint goes far beyond the use phase of a vehicle and covers the whole life cycle, from raw materials and production, repair, reuse and remanufacturing to recycling.

Filed in German · English published by the European Commission

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.

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.

For the automotive industry the regulation of fleet emissions is an important instrument that has been tightened again. The German automotive industry is committed to the goal of making EU road transport climate-neutral by 2050 at the latest.

The German automotive industry is meeting the challenge of climate change and will contribute to tackling it through innovation and technology. Our vision is climate-neutral mobility by 2050 at the latest. It is important that the regulatory framework is open to technology and stable in the long term.

Filed in German · English published by the European Commission

The German automotive industry supports the establishment of Digital Product Passports (DPPs) and promotes their benefits for industry and other stakeholders. VDA also welcomes the implementing regulation on the DPP registry. The published draft already reflects the main points and provides industry with guidance. However, we still see a few aspects that require clarification.

VDA-Anmerkungen zur Überarbeitung des Zollkodex der Union Wir bedanken uns für die Möglichkeit, den Vorschlag der Europäischen Kommission1 zur Reform des EU-Zollkodex kommentieren zu können. Wir unterstützen die vom Bundesverband der Deutschen Industrie (BDI) eingereichte Stellungnahme, an deren Erstellung der VDA mitgewirkt hat.

Filed in German · English published by the European Commission

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

The Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste (PPWR) represents a significant step toward promoting sustainability and the circular economy in Europe. The aim is to reduce packaging waste and promote reuse and recycling.

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.

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 EU revision of the Alternative Fuels Infrastructure Directive (AFID).

The Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste (PPWR) represents a significant step toward promoting sustainability and the circular economy in Europe. The aim is to reduce packaging waste and promote reuse and recycling.

We would like to thank you for the opportunity to comment. The initiative Streamlining the European Commission’s reporting obligations aims to identify reporting obligations in EU legislation that can be abolished or streamlined without jeopardising policy objectives.

Filed in German · English published by the European Commission

The German Association of the Automotive Industry (VDA) welcomes the European Commissions decision to conduct a comprehensive Digital Fitness Check of the Unions digital regulatory framework. The automotive industry, as one of Europes largest industrial sectors and a central driver of research and innovation, is particularly dependent on a coherent, innovation friendly and neutral regulatory environment.

The Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste (PPWR) represents a significant step toward promoting sustainability and the circular economy in Europe. The aim is to reduce packaging waste and promote reuse and recycling.

VDA-Position on the Revision of Network Codes on Requirements for Generators (RfG 2.0) The Association of the German Automotive Industry (VDA) welcomes the revision of the Network Codes on Requirements for Generators (RfG) as an important step towards supporting the integration of electrified transport and distributed energy resources into the European electricity system.

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

In the context of the consultation on the European Commission’s White Paper on Enhanced R & D support on potentially dual-use technologies, the Automobile Industries Association stresses the need to consider the following aspects: The German automotive industry welcomes the successful and efficient separation of civil and military research under Horizon Europe and the European Defense Fund so far.

Filed in German · English published by the European Commission

VDA welcomes the opportunity to contribute comments on the proposed revision of Regulation (EU) 2019/1242 for CO2 standards of HDV. German heavy-duty vehicle manufacturers and suppliers are strongly committed to rapidly reducing CO2 emissions in the public passenger and road freight transport sector and to making newly registered commercial vehicles fossil-free by 2040.

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 European raw materials policy is at an industrial crossroads. Critical raw material supply chains are no longer just a matter of security of supply. They decide on industrial value crea-tion, defence capability, technological sovereignty and the competitiveness of the European Union.

The German Association of the Automotive Industry (VDA) unites more than 650 manufacturers and suppliers under one roof. Its members develop and produce cars and trucks, software, trailers, bodies, buses, parts and accessories, and ever new mobility offerings. We represent the interests of the automotive industry and stand for modern, future-oriented multimodal mobility on the way to climate neutrality.

Feedback VDA (German Automotive Industry Association) Recent results indicate that the Euro 6d-temp and Euro VId emission legislation is effective. The air quality is continually improving as the market penetration of clean Euro 6d/VId vehicles increases.

DEAR Ladies and Gentlemen, enclosed we submit our position paper on the draft Regulation on SEP-licensing. Regarding, Dr Ralf Scheibach, LL.M. Head of Department | Department Law and Compliance German Association of the Automotive Industry e.V. (VDA) Behrenstr.

Filed in German · English published by the European Commission

We appreciate the Commissions effort with the implementing regulation under Regulation (EU) 2023/1542 to harmonize battery labelling in order to enhance transparency, sustainability, and consumer information. We welcome the use of QR codes as digitalization is key to manage multilingual and multi-market requirements. However, we would like to highlight several points that need further adjustments.

The VDA 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 regulatory framework must avoid duplication of rules that already apply to the automotive sector.

Filed in German · English published by the European Commission

Please find our feedback in the attached document. The German Association of the Automotive Industry (VDA) consolidates around 620 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.

Please find attached the feedback from the German Association of the Automotive Industry e.V. The German Association of the Automotive Industry (VDA) consolidates around 620 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.

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.

The German Association of the Automotive Industry (VDA) welcomes the objective of the European Commission to establish, through the present Implementing Regulation, a uniform procedural framework for measures pursuant to Regulation (EU) 2024/1689 (AI Act).

Filed in German · English published by the European Commission