Volvo Car Corporation

The European Union (EU) has established itself as a global leader in promoting circular economy (CE) principles, setting benchmarks in resource efficiency and industrial sustainability. However, other global economic powers, such as the United States and China, are also advancing towards circularity, emphasizing the need for Europe to maintain and enhance its competitive edge.

Volvo Cars welcomes the overall objective of the Industrial Accelerator Act (IAA) to strengthen Europes industrial base and support the development of a strong value chain in strategic sectors. In its current form, however, the proposal risks falling short of this objective, as it introduces significant complexity both for manufacturing and investments, overlapping requirements, and unclear incentives.

Volvo Cars welcomes the Commissions initiative to accelerate the decarbonization of corporate fleets and appreciates the opportunity to share its position. Reducing emissions in the transport sector is not only an environmental imperative but also a strategic driver of Europe's competitiveness.

Volvo Cars Corporation believes connected safety (via the exchange of information with other vehicles and road users) will improve overall safety on the roads. Our connected safety technology was introduced in 2016, uses Volvo Cars cloud, based on real-time data. It allows all Volvo cars to communicate with each other and alert drivers of nearby slippery road conditions and hazards.

Volvo Cars supports the objectives and overall design of the Carbon Border Adjustment Mechanism (CBAM) as a key instrument to prevent carbon leakage and to incentivise the development of robust carbon pricing systems globally. Aligning carbon costs across jurisdictions is essential to ensuring a level playing field and accelerating global decarbonisation.

Volvo Cars welcomes the European Commissions initiative to develop a roadmap for nature credits and particularly values the recognition of the need for public seed funding and the linkage with the Nature Restoration Regulation, which together provide a strong foundation for fostering collaboration between public and private actors.

Volvo Cars welcomes the Chips Act 2.0. The ambition to reduce strategic dependencies, build world-class manufacturing capacity on European soil, and develop robust crisis preparedness tools is sound policy and essential. Volvo Cars shares these goals fully.

Overall, Volvo Cars welcomes the Commissions proposal to revise the End-of-life Directive and Directive on the type-approval of motor vehicles regarding their reusability, recyclability and recoverability, published on 13 July 2023. The proposal aims at increasing the sustainability and circularity of motor vehicles from cradle to grave, an objective we fully support.

Volvo Cars welcomes the opportunity to provide feedback on the Euro 7 proposal presented on 10 November 2022, which as published will have a major impact on the automotive sector. While we support the Commissions overarching aim of the initiative, i.e.

Volvo Cars welcomes the opportunity offered to review the proposed methodology for the calculation and verification of recycled content in batteries. We support the proposed approach to apply an (up to) yearly average of recycled content in a specific plant, with the possibility to allocate a specific share, if there are contractual agreements of the set-up with recycled content loops in place.

Volvo Cars welcomes the progress made towards an agreement for the next framework programme Horizon Europe. For the key challenges of Connected Automated Mobility (CAM or CCAM) and self-driving vehicles, Volvo Cars calls for a co-programmed partnership (option 1) across industry sectors and value chains: • The co-programmed partnership will enable quick and timely research actions; the institutionalised partnership…

The non preferential origin rules as they are written in the union customs code (UCC) are clear. The criteria are clear, the conditions are clear as are the restrictions and exceptions for both articles falling within the annexes as well as guidelines and the precedence set by the European Court of Justice in the past years.