Robert Bosch GmbH

Bosch highly welcomes that the EU is taking action to secure the supply of critical raw materials for industry. Copper should not be classified as a SRM. It is a base metal that is widely available from different sources and traded on functioning, transparent international markets. Treating Copper as a SRM would lead to a wrong focus of efforts (e.g., for recycling, supply chain stress tests).

The Bosch Group, a global technology and automotive supplier, operates a large and diverse corporate fleet of 10,000 vehicles in Germany, mostly leased. Committed to carbon neutrality (achieved in Scope 1 and 2 since 2020) and a 30% CO2 reduction in Scope 3 by 2030, Bosch implements internal policies to increase the share of zero-emission vehicles and carbon-neutral fuels in its fleets, including service vehicles.

An effective and cost-efficient path towards de-fossilization must build on a holistic and consistent mix of policy instruments. The planned revision of the EU Emission Trading System should therefore be closely aligned with the EU Effort Sharing Decision, the EU Tax Directive, the EU’s sectoral policies as well as national mitigation policies in order to avoid excessive regulation and an increase of CO2 abatement…

The Data Act and its roadmap a) Access to Data: Concerning B2B data exchanges, there should be sector specific regulations, but no general obligation to grant access to data. Contractual arrangements should be the preferred option. However, in certain industries such as the automotive sector, sector specific regulation is required in order to ensure fair competition between market participants.

(i) Accurately and consistently recognizing third-country CO2 prices remains a key CBAM challenge. To avoid double-counting and uphold environmental integrity, the EU must establish clear, internationally coordinated rules, including formal verification and data-sharing agreements with carbon-pricing third countries, thereby fostering global CO2 pricing alignment.

We fully support the Paris climate agreement to the intermediate REPowerEU and 2030/2050 climate targets as part of the European Green Deal objectives. We also broadly welcome the Commission proposal of a revised F-Gas Regulation.

To achieve genuine technological leadership and supply chain resilience, the Chips Act 2.0 proposal now pivots from a supply-side focus to a proactive, market-driven industrial policy approach. The new proposal introduces a welcomed mix of supply- and demand-side instruments and approaches, which effectiveness will be determined by means of implementation.

(i) The current CBAM emission calculation using primary data is overly complex and burdensome. Supplier data acquisition remains a major hurdle, as data (e.g. on installations, processes, emissions location) is often unavailable or difficult to obtain. Many suppliers may be unable or unwilling to provide this kind of information.

A tightening of the CO2 standards for cars and vans only two years after the last revision of the regulation would significantly increase planning uncertainty and add to the already high transformation pressure of the automotive industry.

Bosch welcomes the opportunity to comment on the draft Implementing Act (IA) laying down the implementation arrangements for the digital product passport registry set up under Regulation (EU) 2024/1781. Given that the Digital Battery Passport (DBP) established under Batteries Regulation (EU) 2023/1542 will likely be the first Digital Product Passport (DPP) to utilise this registry, we offer our comments from the…

- The delegated act is welcomed as further clarity on the role of digital product passport service providers (DPPSP) is needed for legal certainty of affected economic operators. Requirements set out in Art. 10 and Art. 27 of the ESPR must be unambiguously speci-fied through secondary legislation to warrant harmonized implementation in the Internal Market.

Bosch, a steadfast proponent of a resilient, competitive, and transformative European economy, welcomes the European Commission's initiative to outline an ambitious water resilience research and innovation strategy. Building on our vision for a green and sustainable Europe, Bosch would like to highlight following recommendations (see attachment) as means to guide the outlined aims and elements of the initiative.

The EU Machinery Directive is of high importance to the EU Bicycle Industry and therefore also for Bosch eBike Systems, as it legislates the essential health and safety requirements relating to the design and construction of electrically power assisted cycles (EPACs). We have a long standing, good experience with the Machinery Directive to ensure the safety of our products.

Robert Bosch answer to the European Commission Inception Impact Assessment on the Revision of the Machinery Directive 2006/42/EC. Bosch does not favour Options 0, 1 and 3. The Machinery Directive has to be adapted at least to the New Legislative Framework, especially with the provisions of Decision 768/2008, and need adjustments for clarification in the scope, definitions and content with respect to legal clarity.

Public consultation NC RfG (August 2026) Paragraph Amendment Proposal Reasoning Relation to other provisions Article 52 - Common provisions on equipment certificates 3 Problem: Conflict with Annex III article 2.1, 2.2, 2.3, Annex III article 2.1, 2.2, 2.3 The Annex III / 2 is defining scope of applicability of the family for V2G EV Proposal 1: Modify Text: "The scope of applicability of the PGU family and component…

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

Bosch supports stringent CO2 reduction targets for Heavy Duty Vehicles (HDV) to contribute to the objective of the EU to reduce its overall CO2 emissions by 55% by 2030 and to become climate neutral by 2050. By setting targets for HDV, potentials of cost-efficient CO2 reductions, technology availability and lead times as well as freight transport specific requirements to ensure reliable logistic chains over long…

Bosch welcomes the publication of the draft delegated act establishing the methodology for the calculation and verification of the carbon footprint of electric vehicle batteries. We believe the methodology should be as robust and as harmonised with existing standards as possible.

The comments of the Robert Bosch GmbH are not exhaustive. They give an overview with regard to some matters that are of particular interest to our company. 1. On the matter of mental health The context and the added value of the WHO definition of ‘health’ for the GPSR is unclear.

Bosch welcomes the COM initiative to provide a uniform framework for quantifying GHG emissions in the transport sector. The goal to promote new business models and to initiate a strong dynamic in the reduction of CO2 emissions in the transport sector is also supported form our part.

Bosch supports Euro 7/VII as the last regulatory step for exhaust emissions. Euro 7/VII standards can further reduce the impact of new vehicles (and beyond 2035 for vehicles in use) on air quality. Given the rapidly growing share of electric vehicles, it is reasonable to also set limit values for particle emissions from brakes and tyres. Nevertheless, a monitoring period is advisable to test new measurement methods.

Bosch welcomes the opportunity to contribute to the development of new emission standards. The impact of road traffic on air quality needs to decrease further. Since the internal combustion engine will remain an important part of the future powertrain mix beyond 2030, new emission standards need to reflect technological progress while ensuring competitiveness of the European automotive industry.

A. Product Liability Directive – Should the EU product liability regime be revised as a consequence of AI related technological developments The liability of the producer of a product As Bosch, we urge to consider carefully, whether the Product Liability Directive (PLD) needs revision as a consequence of technological developments such as AI.

Please find attached the expert opinion of Robert Bosch GmbH on the draft Implementing Act on Articles 7 and 13 of the Batteries Regulation. The Bosch group manufactures batteries falling within various of the battery categories of the Batteries Regulation and also produces battery-operated electrical and electronic equipment. Therefore, the Bosch group is directly affected by the draft Implementing Act.

Bosch strongly supports the transition to a circular economy and particularly welcomes the European Commissions decision to adopt a flexible, credit-based mass balance system on an operational level for recycled content. Discarding impractical physical segregation models is a crucial step to safeguard the operational viability of continuous industrial manufacturing.

Bosch welcomes the EU Chips Act and its ambitious target of increasing Europe’s share of global chips manufacturing to 20% by 2030 as well as its contribution to the success of the twin transition of the European industry, which relies on an innovative and resilient supply of mature and advanced chips for future growth.

Robert Bosch GmbH highly appreciates the preparation of a new European R&I partnership for Safe and Automated Road Transport by the European Commission - in close collaboration with the Member states - as a priority in the strategic planning for Horizon Europe.

The Bosch Group, a supplier of a comprehensive portfolio of braking components to the independent aftermarket, supports the objective of establishing a harmonized framework for measuring and mitigating brake particle emissions. To ensure a smooth transition to Euro 7 standards by 29 November 2026, establishing a workable regulatory framework specific to the aftermarket is vital.