Climate Lobbying Overview: The European Automobile Manufacturers' Association (ACEA) is actively lobbying on EU climate legislation with mixed engagement. In 2021-23, ACEA continues to advocate against numerous key EU climate policies for road transport, including ICE vehicle phase-out and higher CO2 standards for vehicles, while supporting increased electric vehicle infrastructure targets.

Top-line Messaging on Climate Policy: ACEA supports the EU Green Deal and the EU’s goal to become climate neutral by 2050, with former ACEA President, Oliver Zipse, telling EU Climate Commissioner Frans Timmermans that “the association has realized that there must be ambitious goals in order to stop climate change” in March 2021, as well as expressing its support in a February 2022 joint statement. ACEA has also expressed support for the goals of the Paris Agreement in numerous communications, such as a November 2021 EU consultation response.

Engagement with Climate-Related Regulations: On heavy-duty vehicles, ACEA appears to oppose a 100% zero-emission CO2 target for heavy-duty vehicles and any ICE phase-out date in the EU, as indicated by a December 2022 letter to Commission Executive Vice President Frans Timmermans signed by the industry association’s Director General, Sigrid de Vries. ACEA further appeared to oppose a 100% zero-emissions target for heavy-duty vehicles in a February 2023 Politico report, stating “let’s not make this a fight about political symbols, like a 100 percent target”. In a February 2023 press release, ACEA also appeared unsupportive of the EU Commission's proposed short-term 2030 CO2 emission reduction target of 45% for heavy-duty vehicles, and 100% for urban buses.

With regard to light-duty vehicles, in March 2022, former ACEA President, Oliver Zipse, publicly urged policymakers to delay setting the EU's zero-emission 2035 CO2 emissions target until "2040 at the earliest" and called for the decision on a zero-emissions CO2 target to be delayed until later in the 2020s according to a Politico report. Similarly, in May 2022, Politico Pro reported that former ACEA President, Oliver Zipse, had sent a letter to French President Macron, urging him to delay introducing a zero-emissions CO2 target for vehicles from 2035 to 2040 and calling for the final decision to be delayed until 2028. Moreover, a November 2021 EU consultation response from ACEA appeared to similarly oppose a 2035 zero-emissions CO2 target, while stating that a 55% 2030 CO2 target for cars would be "challenging". It also argued that "it seems too early to fix the 2035 CO2 targets now" and proposed that a decision around the 2035 EU zero-emissions target be delayed until 2028.

ACEA has consistently supported extending the EU Emissions Trading Scheme (ETS) to road transport, for example in a March 2021 position paper, a July 2021 press release and a November 2021 EU consultation response. In a June 2021 position paper, ACEA appeared unsupportive of a stringent EU Carbon Border Adjustment Mechanism (CBAM), emphasizing competitiveness concerns while advocating that if applied it should include exemptions for counties with similar climate pricing or regulations, and only applied initially in a 'limited way' in 'certain specific sectors'. Moreover, in February 2022, ACEA signed a joint statement asking the EU Commission to assess the impact of the CBAM on downstream industries, in which it appeared not to fully support the CBAM, suggesting that it may cause carbon leakage if unspecified “necessary steps” are not taken. In the same paper, ACEA appeared to support the Emissions Trading System (EU ETS), but also stressed that unilateral action may cause carbon leakage. A November 2021 EU consultation response from ACEA supported increased EU GHG emissions intensity targets for fuels and electricity, while appearing to support weakening the EU's Renewable Energy Directive (RED) by advocating for the inclusion of low-carbon fuels in RED targets and sub-targets.

Positioning on Energy Transition: ACEA has mixed engagement with policies around a low-carbon transition for the automotive sector. With regard to heavy-duty vehicles, ACEA has opposed a 100% ICE phase-out target, according to a February 2023 Politico report, stating “let’s not make this a fight about political symbols, like a 100 percent target or a phaseout of the internal combustion engine." It further appeared to oppose any ICE phase-out date, and advocated for a technology-neutral approach towards the decarbonization of heavy-duty vehicles in a February 2023 joint letter.

ACEA has also been highly critical of ICE phase-out targets and more stringent policy measures aimed at promoting the electrification of light-duty vehicles. In a February 2022 Automobilewoche article, former ACEA President, Oliver Zipse, was reported to have directly advocated to policymakers to oppose internal combustion engine bans in Germany and Europe at a closed-door meeting inside the German federal parliament. Moreover, in a March 2022 Politico report ACEA's former President, Oliver Zipse, publicly stated opposition to a phase out of ICE vehicles in the EU by 2035, urging the EU to delay the date until "2040 at the earliest". In May 2022, Politico reported that former ACEA President, Oliver Zipse, had sent a letter to French President Macron advocating for the EU phase out of ICE-powered cars and vans to be delayed from 2035 to 2040. Similarly, ACEA appeared to strongly oppose EU measures to phase out ICE vehicles by 2035 in July 2021, with Zipse stating that "we urge all EU institutions to focus on innovation rather than mandating, or effectively banning, a specific technology". Furthermore, in an October 2022 Car Dealer Magazine article, former ACEA President, Oliver Zipse, directly opposed the UK's planned 2030 ICE vehicle phase-out date, warning politicians that suppliers will leave the country if it goes ahead. Additionally, a November 2021 ACEA consultation response to the Energy Taxation Directive appeared unsupportive of higher EU-wide minimum taxes on diesel and natural gas for transport while supporting lower tax rates for biofuels.

However, the industry association has strongly supported policy to enable the roll-out of infrastructure to support the electrification of road transportation. In a December 2022 joint letter, ACEA urged EU member states to set higher targets for the deployment of hydrogen refueling and electricity recharging stations in the Alternative Fuels Infrastructure Regulation (AFIR), following “insufficient ambition” from the EU Council. In July 2021, ACEA advocated for higher binding EU charging point targets in the Fit for 55 package, and in a January 2022 fact sheet, further called for increased stringency and ambition in the AFIR proposal across all EU member states. However, in a November 2021 EU consultation response, ACEA advocated for more CNG and LNG refueling stations for heavy-duty vehicles. Moreover, in a December 2022 joint letter, ACEA called on the EU Parliament's Industry (ITRE) Committee to amend the Energy Performance of Buildings Directive (EPBD) by setting ambitious targets for charging solutions on private property.