We have expanded the list of climate policies we assess company engagement with to incorporate land-use related policy, referring to legislative or regulatory measures to enhance and protect ecosystems and land where carbon is being stored. Assessments under this category are currently underweighted in terms of their contribution to the overall company metrics. This weighting will be progressively increased over the next 6 months.
We adjusted the terminology used to describe the queries running down the left-hand side of our scoring matrix and added additional explanatory text to the info-boxes. This has no impact on the scores and methodology. It has been done following user feedback to improve clarity.
Climate Lobbying Overview: The German Association of the Automotive Industry (VDA) appears to be actively lobbying EU and German climate policy with negative engagement in 2020-22. The VDA has historically criticized long-term EU and German GHG emissions targets, while recently supporting an EU 2050 climate neutrality target. It has consistently opposed more stringent EU CO2 standards for light-duty vehicles and phase-out dates for internal combustion engine (ICE) powered vehicles, including a proposed EU 2035 CO2 zero-emissions target for cars and vans.
Top-line Messaging on Climate Policy: The VDA appears to have mixed top-line messaging on climate policy. Until October 2020, the VDA did not appear to clearly support long-term European climate targets, with VDA President, Hildegard Müller, publicly criticizing EU plans to increase its long-term climate targets, emphasizing cost and carbon leakage concerns in September 2020. However, in October 2020, a press release from the VDA appeared to support a 2050 climate neutrality target for the first time, while taking an unclear position on near-term action to reach such a goal. On its website in March 2022, the VDA also appeared to support a sector-based target for the automotive industry to achieve net-zero emissions by 2050. However, a VDA press release and German consultation response in May 2021 appeared critical of a proposed 2045 German climate neutrality target, emphasizing concerns around economic costs.
The VDA has consistently used its support of carbon pricing at an EU-level to oppose more stringent forms of regulation, including in its 2021 ‘Climate Strategy 2050’ report and a 2020 EU consultation response. On its website in March 2022, the VDA appeared to use support for regional climate neutrality goals to oppose national regulations, arguing that “tougher national targets alone will not help the climate”. Furthermore, in April 2020, the VDA urged the EU to delay additional climate regulations for the automotive sector during the COVID-19 crisis, while in February 2022, VDA President, Hildegard Müller, appeared to support a less ambitious response to climate change, telling a news conference that “we don't need more and more climate goals” and that “the current ones are ambitious".
Engagement with Climate-Related Regulations: The VDA appears to have consistently opposed increasing the EU’s CO2 emissions standard targets for cars and vans in 2020-22. Responses to EU consultations in November 2020 and February 2021, and a May 2021 position paper appeared to oppose an increase to the EU’s 2025 light-duty vehicle CO2 targets, while emphasizing the multiple, extensive qualifying pre-conditions, such as increased recharging infrastructure availability and other regulatory measures under which ambitions for 2030 and post-2035 targets could be increased. A July 2021 VDA press release appeared to strongly oppose the EU’s proposed zero-emissions 2035 CO2 standard for cars and vans. Moreover, a November 2021 EU consultation response from the VDA similarly stated opposition to a 2035 zero-emissions CO2 target and stated that a 55% 2030 target would be "a major challenge". In April 2020, the VDA also appeared to use the COVID-19 crisis to reject increases to CO2 standards for light-duty vehicles in a media comment. A further 2019 press release from the VDA also appeared to oppose ambitious EU heavy-duty vehicle emissions standards, further stating that “the disproportionately high financial penalties, in particular, will threaten the existence even of major commercial vehicle manufacturers”.
The VDA appears to have actively advocated to include road transport in the EU Emissions Trading System (EU ETS) at the expense of other climate regulations in 2020-22, including in two November 2021 EU consultation responses on the revision of the Energy Taxation Directive and the revision of the EU ETS. In a May 2021 position paper, the VDA argued that the “EU ETS should be the lead instrument for ensuring climate-neutral transport”, and in its June 2021 Climate Strategy 2050 report, stated that “the EU ETS 2 should become the new lead instrument and assume an umbrella function, so that the existing regulations only have a complementary effect”.
Regarding 2030 GHG target legislation, a September 2020 media statement from VDA President, Hildegard Müller, appeared unsupportive of a higher 2030 EU GHG emissions target of 55%, while a November 2020 VDA position paper similarly emphasized cost concerns and the need for further impact assessments before increasing the target to 55%. Similarly, a May 2021 German consultation response, and press release appeared to stress concerns around competitiveness and cost regarding a higher German 2030 GHG emissions target, with the press release arguing that further impact assessments were necessary before committing to the target.
Positioning on Energy Transition: The VDA appears to have consistently and actively lobbied against measures to phase out ICE vehicles in the EU and Germany, including in position papers in November 2020 and May 2021, and on its website in 2021. Additionally, a 2020 EU consultation from the VDA directly stated that “we firmly oppose a ban on combustion engines”. A July 2021 VDA press release in response to the EU’s proposed plans for a zero-emissions 2035 CO2 standard for cars and vans appeared to oppose the policy, arguing that it amounted “to a ban on combustion engines.” In 2020, the VDA’s President also criticized California’s decision to phase out ICE vehicle sales by 2035 in a media statement. The VDA has instead consistently advocated that climate policy should support a broad mix of technology that includes ICE-powered vehicles, such as in its 2020 Annual Report and on its website in March 2022.
The VDA also appears to be prioritizing the role of synthetic e-fuels and a long-term role for ICE vehicles over the electrification of transportation in its messaging, including in multiple 2020-21 statements from VDA President, Hildegard Müller, arguing in 2021 that “the engine is not the problem, it is the fuel from fossil sources”. Moreover, the VDA further appears to support an increased role for e-fuels and hydrogen for light-duty vehicles in the EU’s mobility strategy in 2021, according to a press release, its website, and media reports. Statements from the VDA’s President in 2020 and 2021 appear to have strongly opposed stringent EU Euro 7 emissions standards for promoting the phase-out of ICE vehicles, later praising a proposed reduction in stringency from the EU in Euro 7 standards in May 2021 for not phasing out ICE vehicles.
More positively, the VDA has also supported the expansion of charging infrastructure for electric vehicles in the EU and Germany, including higher binding EU targets for member states in a March 2022 position paper and a November 2021 EU consultation response. In July 2021, the VDA supported the EU Commission’s plan to expand electric vehicle charging infrastructure in a press release, arguing for increased funding, while in a February 2022 Euractiv media report, VDA President, Hildegard Müller, called for greater ambition in the EU's Alternative Fuels Infrastructure Regulation. In a May 2021 German consultation response, the VDA also urged the German government to expand EV infrastructure and to fully transition towards 100% renewable electricity in the energy mix, further supporting increased EV infrastructure in another February 2021 German consultation response. The VDA also stated support for taxing kerosene for intra-EU flights and taxing fossil fuels in maritime transport in a 2020 consultation response on the EU Energy Taxation Directive. In 2020, media comments from VDA President, Hildegard Müller, also appeared supportive of the German ‘Umweltbonus’ (environmental bonus) grant for purchasing new EVs. However, other 2020 media comments from VDA’s president appeared to also support expanding German sales incentives to non-EV vehicles. Moreover, in September 2021, the VDA criticized the German government for introducing stricter criteria for plug-in hybrid purchase subsidies to promote the electrification of transport.