Investment Rating - The automotive industry supports the upcoming targeted REACH revision, indicating a proactive stance towards regulatory improvements [2]. Core Insights - The automotive industry plays multiple roles under REACH, including importer, distributor, producer of articles, and end user, with a focus on the challenges faced by end users [3][4]. - The complexity of the automotive supply chain and the need for sustained market availability for repairs present significant challenges in executing REACH [5]. - Key recommendations include making the Risk Management Option Analysis (RMOA) mandatory, improving the authorisation and restriction processes, simplifying substance and mixture regulations, and enhancing data quality and exchange [6][7][8][9]. Summary by Sections Key Recommendations - Mandate the RMOA to ensure effective regulatory actions and reduce risks from hazardous substances [6][11]. - Merge the authorisation and restriction processes to create a more efficient system, addressing the backlog of applications and ensuring fair treatment for EU producers [7][12][15]. - Simplify the approach to substances and mixtures by removing unnecessary administrative burdens and focusing on effective risk management [8][25]. - Improve data quality by mandating structured digital Safety Data Sheets and ensuring full disclosure of regulated substances [9][29]. Industry Context - The automotive industry employs 13.6 million people in Europe, accounting for 6.9% of all EU jobs and 8.1% of EU manufacturing jobs [34]. - The sector generates significant tax revenue of €414.7 billion and a trade surplus of €93.9 billion for the EU [34]. - With an annual investment of €84.6 billion in R&D, the automotive industry is the largest private contributor to innovation in Europe, representing 34% of the EU total [34].

二〇二六年二月 欧洲汽车制造商协会 立场文件 提案：数字综合法案 建议 I. 数据采集 1. 拒绝修改《提案》第1条第2款第b项中关于数据主体的定义的提议。 2. 修改《提案》第1(2)(e)条中"机器可读数据"的定义，使其涵盖通过任何设备或远程服务器通信 接口传输的数据。 3. 删除提案第2(4)(b)条中"权限"定义中对"数据用户"的提及。 5. 扩大欧洲数据创新委员会的提议成员资格至 将提案的第1(22)条款中纳入行业和服务的代表。 6. 将《数据法》第4条第（13）款和第（14）款合并为一条单一、全面的条款，以规范对非 个人数据的便捷可用数据的利用。 事前 7. 撤销 通知要求，在《数据法》中规定，以减轻数据持有者和通知机构的管理负担 （第4条（2）、（7）、（8）款；第5条（10）、（11）款；第8条（3）款）。 8. 废止《数据法》对于数据持有人披露信息、说明补偿第三方计算依据的要求（第九条第七项 和第二十条第二项）。 9. 废除《数据法》第32条关于数据向第三国转移的规定；相关GDPR条款应仅适用于国际数据 传输。 第十条：废除《可再生能源指令》（欧盟2023/2413号）第二十条a款第三项。 ...

Investment Rating - The report does not explicitly provide an investment rating for the industry Core Insights - The European automobile industry is undergoing a significant digital transformation driven by connected and autonomous vehicles, necessitating effective vehicle data sharing to maintain competitiveness [4][5] - Vehicle data sharing is crucial for innovation in areas such as autonomous driving and electrification, with manufacturers incentivized to share data to enhance customer engagement and operational efficiency [6][9] - The establishment of a comprehensive regulatory framework, particularly the Data Act, is essential for facilitating data sharing and ensuring fair access for stakeholders [21][17] Summary by Sections Data Sharing and Digital Revolution - The integration of vehicle data sharing into the automotive ecosystem is pivotal for innovation and competitiveness [4][5] - Connected vehicles generate vast amounts of data, which can drive advancements in safety, sustainability, and customer satisfaction [6][7] Recommendations for Data Sharing - Support the implementation of the Data Act and evaluate its market effects before introducing new requirements [3] - Simplify the regulatory framework for vehicle data sharing to align with the Data Act [3] - Create a unified European Data Space to facilitate efficient data sharing [3] Legal Framework and Compliance - The Data Act will apply from September 2025, providing a comprehensive regulation for connected products, including vehicles [21] - The existing legal framework is complex and burdensome, necessitating a streamlined approach to enhance compliance and reduce administrative costs [22][23] Accelerating Innovation and AI - Access to data is critical for driving innovation and developing industry-specific AI models, which can enhance competitiveness against global tech companies [36][37] - A structured forum for regulatory dialogue is recommended to address international data challenges and promote innovation [38] Industry Collaboration and Standards - The report emphasizes the importance of industry-led initiatives to enhance data-sharing practices and promote standardization for interoperability [27][33] - Establishing a decentralized, federated data ecosystem is crucial for efficient data management and innovation [33]

Investment Rating - The report does not explicitly provide an investment rating for the automotive industry in Europe Core Insights - The report highlights the significant gap between the sales of battery-electric vehicles (BEVs) and their actual representation on European roads, with BEVs accounting for 13.6% of new car registrations but only 1.8% of passenger cars on the roads [8][9] - The average age of vehicles on European roads is increasing, with the average age of passenger cars reaching 12.5 years in 2023, indicating a need for modernization towards cleaner technologies [10][12] - The report emphasizes the importance of accelerating the adoption of zero-emission vehicles across all segments, particularly vans, trucks, and buses, to meet decarbonization targets [11][13] Summary by Sections Key Figures - In 2023, the EU passenger car fleet grew by 1.4% to nearly 249 million cars, with Croatia showing the highest growth at +4.3% [18] - The number of vans in circulation reached 30.1 million, with a concentration in France, Italy, and Spain [18] - The EU truck fleet saw a 0.8% increase, totaling 6 million medium and heavy commercial vehicles [18] - Buses in operation numbered 679,802, with Italy, France, Germany, and Poland accounting for over half [18] By Age - The average age of cars is 12.5 years, with Greece having the oldest fleet at 17.5 years [18] - Vans average 12.7 years, with Italy having the oldest van fleet at 14.8 years [18] - Trucks average 14.1 years, with Greece again having the oldest fleet at 22.6 years [18] - Buses average 12.2 years, with Greece having the oldest bus fleet at 17.6 years [18] By Power Source - In 2023, only 3.9% of the total EU car fleet consisted of electrically chargeable vehicles [18] - Diesel remains dominant in light commercial vehicles, with 90.5% of the fleet running on diesel [18] - For trucks, 96.4% are diesel-powered, with only 0.1% having a zero-emission powertrain [18] - Diesel buses account for 89.2% of the fleet, with only 2.5% being battery electric [18] Per 1,000 Inhabitants - The EU has 563 passenger cars and 83 commercial vehicles and buses per 1,000 inhabitants [18] - Italy has the highest car density at 694 per 1,000 people, while Latvia has the lowest at 381 [18] Vehicle Ownership - The report indicates that a significant portion of European households still own at least one car, with Denmark having nearly 40% of households without a car [18] - The average annual distance traveled in the countries covered is 12,346 kilometers [18]

Industry Investment Rating - The report does not explicitly mention an investment rating for the industry [1][2][3] Core Viewpoints - The European automotive industry is making steady progress in developing automated vehicles, with significant investments yielding results [3] - Automation in mobility is expected to bring tangible benefits to European society, including lower transport costs, reduced environmental impact, improved working conditions, and better-served transport needs [3] - Supporting R&D in automation will enable European firms to remain competitive in the future of transport and encourage high-quality connectivity [3] - The roadmap aims to help European policymakers and stakeholders navigate the transition to automated mobility [3] Levels of Automated Driving - Assisted driving includes basic systems that recommend actions to drivers or provide additional sensory perception (e g blind spot detection) [3] - Advanced active safety systems intervene automatically, faster, and more reliably than humans (e g automated emergency braking systems) [3] - Automated driving technology can perform all dynamic driving tasks in specific scenarios (e g autopilot function for motorways) [3] - Autonomous driving aims to enable the vehicle to handle the full driving experience without human input [3] Uses of Automated Driving Technology - Highly automated heavy trucks can carry freight over medium and long distances, optimizing routing and scheduling for efficiency [5] - Commercial vehicles in confined areas (e g harbours, airports) allow for earlier adoption of self-driving technology due to controlled environments [5] - Automated last-mile delivery can alleviate strain on road networks and businesses caused by increased online shopping demand [5] - Automated passenger services can provide crucial mobility services, especially for people with disabilities and the elderly [5] - Automated valet parking systems save time, enhance safety, reduce energy consumption, and optimize parking space usage [6] - Private vehicles on highways are evolving from assisted driving to full automation, with each development stage lasting around a decade [6] - Hub-to-hub freight transport can operate on request around the clock, reducing wasteful trips and improving traffic flow [7] Benefits of Automated Mobility - Innovation capabilities: Cutting-edge research and engineering create and retain know-how in Europe, attracting a highly skilled workforce [10] - Competitiveness: Automated mobility allows Europe to leverage public-private cooperation and balance intelligent infrastructure with intelligent vehicles [11] - Workforce and skills: Automation can address the shortage of commercial vehicle drivers and improve working conditions [12] - Sustainability: Optimal vehicle usage leads to less congestion, lower speeds, and more efficient transport operations [13] - Road safety and comfort: Automated systems reduce human error, react faster, and remain vigilant, enhancing safety and comfort [14] - Accessibility and inclusion: Automation provides new mobility solutions for those with reduced mobility, improving access to healthcare and work [15] Recommendations for Deploying Automated Vehicles - Foster R&D in automated driving technologies and standards [17] - Simplify national and cross-border pre-deployment testing of automated systems on open roads across the EU [17] - Upgrade, adapt, and harmonise digital infrastructure for automated driving [18] - Establish European minimum standards for high-quality physical road infrastructure [18] - Update and harmonise road traffic rules to allow for high-level automation [18] - Cooperate with the industry on guidelines for remote vehicle supervision [18] - Grant access to public traffic data [18] - Update Europe's type-approval scheme to remove restrictions on automated vehicle registrations [19] - Expand the number of automated vehicle applications allowed in Europe [19] - Support the adoption and harmonisation of national operation, licensing, and traffic regulation [19] - Foster harmonisation of legislation on a global scale [19] - Create a European funding scheme for automated passenger and freight services [19] - Inform and establish a dialogue with the general public and future drivers and passengers of automated vehicles [20] - Adapt labour regulations for commercial vehicle drivers and operators [20] Roadmap - Commercial operation for each use case will start within the indicated time range (2022-2030) [21][22]