Robert Bosch GmbH

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.

(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.

(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.

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.

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 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.

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.

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.