A supportive regulatory framework that fosters growth, jobs and investment is key to the global competitiveness of the industry and the continued strength of the European economy. The industry is fully committed to facing the challenges of sustainable mobility. Nevertheless, policy makers need to strike a careful balance between an ambitious climate and energy policy on the one hand, and future competitiveness and prosperity on the other.
Policy makers should ensure that the regulatory framework is not unnecessarily complex. New regulations are often introduced before existing regulations are correctly implemented and enforced in member states. Action should be taken to alleviate this regulatory burden and the cost of doing business in Europe.
- The EU institutions should apply the principles of ‘Smart Regulation’ set out in the CARS21 final report and re-iterated in the CARS 2020 Action Plan.
- Robust impact assessments, cumulative impact studies and thorough ‘competitiveness proofing’ should be carried out systematically whenever proposals are drafted, significantly amended by the European Parliament and/or Council, or legislation is reviewed. Lead-times for proposals affecting industry should be realistic, reflecting the complexity of the implementation required and the possible impact on the supply chain.
- There should be sufficient transition periods between the implementation dates of new regulations to allow for amortisation and depreciation.
- Incentives and interventions that support the renewal of the fleet in EU member states should be consistent.
- New regulations should have a global potential and therefore should not restrict sales opportunities to the EU only.
- Apply thorough competitiveness proofing to future proposals regarding safety (Regulation 661/2009), the World Light-Duty Test Procedure (WLTP) and Real Driving Emissions (RDE) and CO2.
- Ensure the continuity of a flexible and predictable type approval system when reviewing current legislation.
- Apply an ‘integrated approach’ in all relevant policy areas, including the environment and safety.
- Re-evaluate today’s legislative framework to take into account innovative new drivetrain technologies, eg in the field of climate policy.