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 2021-23. 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. It also appears unsupportive of the EU’s proposed CO2 reduction targets for heavy-duty vehicles.

Top-line Messaging on Climate Policy: VDA appears to have mixed messaging on climate policy. It has consistently expressed support for the EU's Green Deal and 2050 targets, for example in a September 2022 position paper. Similarly, on its website in March 2022, VDA appeared to support a sector-based target for the automotive industry to achieve net-zero emissions in the EU 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. On its website in March 2022, the VDA also appeared to use support for regional climate neutrality goals to oppose national regulations, arguing that “tougher national targets alone will not help the climate”. In February 2022, VDA President, Hildegard Müller, further appeared unsupportive of an 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". The VDA has repeatedly stated support for the goals of the Paris Agreement, for example in a February 2023 press release.

Engagement with Climate-Related Regulations: VDA has consistently opposed the EU’s proposed CO2 emissions standards for cars and vans, which includes a 2035 100% CO2 reduction target. In a February 2023 press release, VDA President, Hildegard Müller, appeared to support the attempted last-minute weakening of the EU's 2035 zero-emissions target for light-duty vehicles, calling on the German government to push for amendments to weaken the regulation in its final stages. Similarly, a February 2021 EU consultation response 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 November 2021 EU consultation response from VDA stated opposition to a 2035 zero-emissions CO2 target and stated that a 55% 2030 target would be "a major challenge". In a September 2022 position paper, VDA further appeared unsupportive of the EU's proposed 2035 zero-emission CO2 target.

With regard to heavy-duty vehicles, in March 2022 comments submitted to the EU Commission, VDA emphasized extensive qualifying conditions needed to increase ambition for CO2 targets, including the expansion of charging and re-fueling infrastructure across Europe, and in a September 2022 position paper, advocated for some compliance flexibilities, such as extending the credit and debt system. Furthermore, in a February 2023 Berliner Morgenpost interview, VDA President, Hildegard Müller, appeared unsupportive of higher HDV CO2 targets, arguing that electric trucks are too heavy for German bridges compared with their combustion engine counterparts. Müller also appeared to oppose the introduction of a German speed limit in the same interview.

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, 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 819480 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”.

Positioning on Energy Transition: VDA appears to have actively lobbied against measures to phase out ICE vehicles in the EU and Germany. The industry association has consistently opposed the EU’s proposed 2035 ICE phase-out date for light-duty vehicles, most recently in a February 2023 Berliner Morgenpost interview. In a February 2023 press release, VDA President, Hildegard Müller, appeared to support the attempted last-minute weakening of the EU's 2035 proposed ICE phase-out, calling on the German government to push for an e-fuels exemption in the EU Commission's proposal. In June 2022, Müller opposed both the European Parliament’s and Council's vote in support of a 2035 ICE phase-out. VDA has continuously advocated for climate policy to support a broad mix of technology that includes ICE-powered vehicles and has historically promoted a long-term role for synthetic e-fuels over the electrification of transportation, including in multiple statements from VDA President, Hildegard Müller, who in a November 2022 news report argued that without e-fuels we will not achieve climate targets. Other arguments used by the VDA to opposed the EU CO2 standards include negative economic and social costs, and insufficient EV charging infrastructure.

With regard to heavy-duty vehicles, VDA appears to have conditioned support for a 100% HDV future ICE phase-out date in the EU on enabling conditions such as charging infrastructure expansion, as indicated by a September 2022 position paper. It has also advocated for a long-term role for the internal combustion engine powered by carbon-neutral fuels over the rapid decarbonization of heavy-duty vehicles, as well as appearing to oppose a ZEV mandate. However, the VDA has also called for measures promoting a transition towards zero-emission HDVs in the EU, such as the expansion of charging and hydrogen infrastructure, incentive systems such as subsidies, toll exemptions and tax breaks.

More positively, the VDA has supported the expansion of charging infrastructure for electric vehicles in the EU and Germany, including higher binding targets for EU member states in a September 2022 position paper. Furthermore, in a February 2022 Euractiv media report, VDA President, Hildegard Müller, called for greater ambition in the EU's Alternative Fuels Infrastructure Regulation (AFIR). In an October 2022 press release, Müller also expressed support for the Charging Infrastructure Master Plan II in Germany, and in an August 2022 Zeit Online article, called on individual municipalities to do more to promote implementation.