Volkswagen Aktiengesellschaft

Feedback Volkswagen Group on Digital Package – Digital Omnibus Date: 14.10.2025 Feedback Volkswagen Group on Digital Package – Digital Omnibus 1 Introduction Europe’s competitiveness is under significant pressure, as highlighted in recent reports by Draghi and Letta. The EU is lagging behind the United States and China in terms of economic growth, productivity, and innovation.

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

Volkswagen Group Position on the Industrial Accelerator Act (IAA) The Volkswagen Group (“Group”) is committed to Europe, the Groups home and home market. As such the Group wants to ensure that Europe remains the global powerhouse in the automotive industry. A level playing field is the foundation for this.

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

Comments for Public Consultation From: Volkswagen AG To: EU Commission Dear Sir or Madam With this message Volkswagen AG would like to give a feedback on the public consultation regarding the European Critical Raw Materials Act (ECRMA). https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13597-European-CriticalRaw-Materials-Act_en.

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

Volkswagen AG very much welcomes the AI Act and its risk-based approach, and understands and supports the unique opportunity that the European Commission has in advancing the safe and trustworthy use of AI. We believe that this approach will give Europe a competitive advantage on the long-term development and deployment of AI systems.

We welcome the proposed amendments to the EU Taxonomy Delegated Acts. The adaptations provide more clarity and strengthen the practicality of the requirements. We would like to suggest two DNSH criteria. Water and marine resources We welcome the clarifications provided by the European Commission.

Filed in German · English published by the European Commission

Volkswagen Group welcomes the efforts of the European Commission to establish a flourishing data economy within the EU. The Data Act constitutes a main pillar of the European Data Strategy and is an essential milestone to achieve the single market for data.

VW Group Position on the Environmental Omnibus Volkswagen welcomes the Environmental Omnibus to reduce administrative burden and complexity. Our input is dived in two parts: A) On the EU Battery Regulation (2023/1542) B) On the EU Industrial Emissions Directive (2010/75/EU) Part A) On the EU Battery Regulation (2023/1542) A1) General Support for ACEA Position and ACEA Proposed Amendments Volkswagen Group fully…

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

The Volkswagen Group anticipates that the rules for calculation, verification and reporting of data on chemically-recycled plastic content in single-use plastic beverage bottles could serve as a blue print for future rules in other sectors. We are therefore participating in this consultation to ensure that automotive-specific considerations are appropriately reflected.

The Volkswagen Group fully supports advancing the European Union into a modern, resource-efficient and competitive economy. Therefore, we welcome the Commissions proposal to define criteria for when plastic waste ceases to be waste on the basis of the already existing regulation for steel scrap ((EU) 333/201199).

With the attached position we welcome the Commissions efforts to clarify and streamline labelling requirements and welcome several improvements in the current draft. At the same time, we would like to highlight several points where further adjustments are necessary to ensure the regulation remains practical, proportionate, and aligned with industry realities.

As a manufacturer of cars and batteries, we believe that sector-specific regulations such as the Batteries Regulation and the proposed End-of-Life Vehicles (ELV) Regulation should remain the primary legal instruments driving circularity in our industries. Any circularity measures targeting batteries or motor vehicles, including those related to critical raw materials, must be anchored in these two regulations.

The Volkswagen Group welcomes the plan of the EU Commission to review the ITS Directive in regard to its effectiveness and its goals in order to harmonize and coordinate the deployment of respective technologies in Europe and appreciates the opportunity to provide input on the policy options spelled out in the Inception Impact Assessment.