• "The EU had promised to examine and analyze the realities and, based on that analysis, implement flexibilities and adjustments. This has not happened — Brussels has disappointed with its proposed draft. In times of increasing international competition, in times when European economic strength is crucial, this entire package from Brussels is disastrous.
• The rightly recognized commitment to technological openness must be more than just lip service — unfortunately, this is not the case here. What appears to be greater openness is fraught with so many obstacles that it risks remaining ineffective in practice.
• Given the realities of the European passenger car market and the economic situation of the automotive industry (manufacturers and suppliers) in Europe, it is incomprehensible how the Commission can act in this way at this time. This is no good day for Europe as an automotive location, for the economy, growth, and employment. The reasons for Europe's lack of competitiveness are not even being addressed, nor are the results of the review processes being disclosed. The need for action is thus being deduced in a wrong way.
• Brussels now intends to impose new requirements on the automotive industry — regarding green steel and renewable fuels. These are requirements where the availability of the respective resources is beyond our control. In plain terms, this means that our industry — as was the case with charging infrastructure — is once again dependent on developments it cannot influence. This is the antithesis of planning certainty. We will be penalized if others fail to do their homework or if expectations are not met. This has already been the problem with the development of charging infrastructure and is now being extended to other areas.
• This is a proposal from the Commission. In the further process, the European Parliament and the Member States now have a crucial role to play in significantly amending the Commission's proposal. We are aware that there is a different perspective on the need for action, which was recently reiterated by the German Federal Government and the EPP Group leader. The intended technological opening must also be made practically feasible in the further proceedings.

Furthermore:

Today's proposals from the European Commission for the automotive industry provide the basis for a much-needed debate. However, they offer only limited help in practice and simultaneously create further obstacles. The aim was to make pragmatic adjustments and flexibilities to CO2 fleet regulations based on a fact-based review in order to achieve the targets. In reality, however, today's proposals primarily consisted of new documentation and reporting requirements, postponements, and adaptations that neither reflect reality nor include the urgently needed course corrections.

Also, it remains unanswered how the Commission intends to contribute to a significant increase in the international competitiveness of Europe as an industrial location with its proposals today — a reference to measures already implemented is insufficient. The same applies to the necessary supporting framework for the ramp-up of electromobility, particularly with regard to the expansion of charging and H2 refueling infrastructure, which remains the fundamental prerequisite for achieving the ambitious targets.

Regarding the 2035 target, an adjustment is indeed being discussed. However, this adjustment is tied to conditions that the automotive industry cannot influence: whether sufficient quantities of green steel produced in the EU will be available at competitive prices in 2035 is beyond the automotive industry's control. The same applies to linking the target adjustment to the use of renewable fuels. When targets for an industry are tied to such factors, reliable planning becomes impossible. The ramp-up of charging infrastructure in Europe in recent years has already demonstrated this point.

Instead of allowing technology-neutral solutions based on an adjusted 2035 target, additional hurdles are now being erected that are beyond the control of the automotive industry. Furthermore, the EU Commission has failed to provide an answer as to how the role of plug-in hybrids and their contribution to climate protection can be strengthened. Specifically, what is needed here is, above all, a suspension of the planned tightening of the utility factor and a supplementary perspective beyond 2035. The Commission also appears to be failing to implement Recital 11 regarding the use of CNF vehicles, i.e., vehicles that are demonstrably and exclusively powered by renewable fuels. The clear and logically derived demands — whether from the German Chancellor, the state premiers, or most recently, EPP leader Weber — have unfortunately not been taken into account, or not sufficiently.

At the same time, there are some initial positive steps being taken. These include easing regulations for the light commercial vehicle sector, where demand for electric vehicles is lagging significantly behind expectations. The fact that attention is already being turned to the heavy commercial vehicle segment, specifically the ambitious 2030 target, is also welcome, although not yet sufficient. It is clear that there is an urgent need for action regarding heavy commercial vehicles and their associated fleet-wide CO2 regulations, which is why the corresponding review must be brought forward. Based on this review, the obvious areas for action must be addressed. These include, in particular, the expansion of the charging and H2 refueling infrastructure, as well as a proportionate adjustment of penalties, which are many times higher than those for passenger cars.

The ideas behind the Corporate Fleets Initiative and its allocation to the various member states are completely unrealistic. We strongly reject these proposals, as they fail to address the key challenges of ramping up electromobility, particularly regarding the expansion of charging infrastructure and charging station pricing. Existing initiatives and individual decarbonization commitments provide sufficient guidance and support the electrification of vehicle fleets. A high-performance charging and H2 refueling infrastructure is paramount for the successful electrification of commercial vehicle fleets in particular.

The transition to climate-friendly road transport will not succeed through more regulation, but only by improving framework conditions and creating incentives. Additional measures could be explicitly counterproductive, further complicating the already economically challenging transformation and increasing the administrative burden for companies and fleet operators. Reducing, not increasing, bureaucracy must play a crucial role here as well."