Agoria reaction on the EU Automotive Package "for a clean and competitive automotive sector"

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Published on 18/12/25 by Jean-Marc Timmermans
Agoria has taken note of the Automotive Package presented by the European Commission on 16 December. We welcome the fact that the Commission is explicitly placing the competitiveness, resilience and job protection of the European automotive industry at the heart of its approach.

For Agoria, four points are crucial:

1) Clarity and investment certainty on the path to net-zero mobility

European companies and consumers need clarity and predictability regarding the pathway towards net-zero drivetrain technologies, so that long-term investments can be facilitated and scaled up.

We note that the relaxation (90% instead of 100% by 2035) is, however, accompanied by new compensatory measures. Swift clarity is therefore needed on this new 2035 set-up (compensating the remaining 10% through EU-made low-carbon steel and e-fuels/biofuels), so that feasibility and investment certainty are not undermined. This also requires a simple, transparent and verifiable methodology for implementation and verification (monitoring, reporting & verification), so that the offsetting rules are robust and remain workable for companies. We explicitly call for a single EU-wide MRV methodology and uniform control requirements for these “offsets”, so that they do not lead to 27 different interpretations and additional administrative burden for cross-border value chains.

While the Commission presents this revision as a step towards technology neutrality, the practical flexibility will depend entirely on the implementing rules. Agoria therefore urges the EU to ensure that the package delivers a genuinely technology-open pathway to net-zero mobility—without disproportionate complexity and cost increase for suppliers and consumers.

Further assessment is needed towards the implications of the offset components (including the underlying eligibility criteria, certification and availability of low-carbon inputs) once the detailed implementing framework is clearer. What matters at this stage is that the offset mechanism remains robust, yet workable, transparent and cost-effective for the full value chain.

Belgian automotive companies are strongly represented in net-zero drivetrain technologies. At the same time, they are facing the consequences of slow market development and intense competition from outside Europe. European industrial policy must therefore strengthen value creation in Europe and further safeguard jobs in the automotive industry. This is in line with the Automotive Industrial Action Plan, which focuses on competitiveness, resilience and strengthening strategic value chains. A concrete example of high value creation is the battery value chain, including innovative materials and recycling.

2) Enabling conditions: grids, charging infrastructure, demand stimulation and system integration (V2G)

The transition can only succeed if Europe accelerates the enabling conditions—above all grid reinforcement and the further roll-out of charging infrastructure. These are no-regret investments that are also essential for the broader energy transition. They also align with the recent European Grids Package (10 December 2025), which focuses on faster permitting, better planning and appropriate financing for grid expansion and modernisation.

At the same time, stimulating demand remains important: a stable, market-supporting policy framework that supports the uptake of net-zero vehicles is needed to anchor investments across the broader European automotive value chain. A positive business case and a competitive total cost of ownership (TCO) for net-zero vehicles, including light commercial vehicles and heavy-duty vehicles, are also key prerequisites for healthy market uptake. Fiscal measures such as a tax shift should help improve the business case for these net-zero vehicles compared with fossil-fuel alternatives.

We are cautiously positive about the additional focus on affordable, smaller models. Through the Automotive Omnibus, the Commission aims to ease administrative burdens and cut costs, while introducing a new vehicle category of “small affordable cars” (≤ 4.2 m) to help this market segment grow faster and to anchor volumes in Europe.

We welcome the Omnibus on regulatory simplification and more predictable, staggered implementation of future requirements—provided this reduces administrative burden.

Europe should also unlock the potential of vehicle-to-grid (V2G) through workable market rules, standards and incentives, so that vehicles can become a lever for grid stability and flexibility. This aligns with Europe’s electricity market rules, including the EU Internal Electricity Market Directive (Directive (EU) 2019/944), which supports demand response and aggregation as building blocks for flexibility.

On greening corporate fleets, Agoria recognises the intent to stimulate demand and build a stronger second-hand market. However, we are concerned that rigid, mandatory targets—especially given the role of leasing and rental—could create disproportionate impacts for parts of the market and risk delaying renewal if costs and infrastructure are not aligned. 

Finally, we note the announced revision of car labelling rules, which can help ensure that consumers have clear, comparable information on vehicles’ emissions and can make more informed choices.

3) Level playing field: externally and across EU Member States

External level playing field. Europe must protect its industry against unfair competition with robust, proportionate measures (where needed, trade instruments and measures addressing distortive foreign subsidies), while continuing to invest in its own innovation. Europe must once again become an innovation engine.

Internal level playing field (between Member States). EU funding and EU instruments should be deployed in a way that strengthens the single market and avoids fragmentation or a subsidy race between Member States. At the same time, we see that the current revision and relaxation of the 2035 framework again contains elements that will largely be implemented through national approaches. Without clear, harmonised European rules and a uniform methodology for implementation and control, Europe risks once again becoming a patchwork of differing and fragmented measures—creating additional uncertainty, administrative burdens and costs for companies that are, de facto, active across borders. This risk increases further when demand measures (such as corporate fleets) set EU objectives, while instruments, definitions and reporting are largely left to national implementation. 

In a package that already adds new layers of detailed obligations, Europe must avoid creating complexity; otherwise, the measures will not safeguard production and jobs at scale.

The Battery Booster and other EU instruments should contribute to a level playing field and strategic autonomy, including aligning foreign investments with Europe’s strategic interests. In that context, we welcome the Battery Booster strategy with €1.8 billion for an EU-made battery value chain, and we stress that EU financing should be accessible to the entire value chain (materials, components, recycling and innovative SMEs), not only to large-scale cell manufacturing—so that European value creation and jobs are strengthened across the whole supply chain.

We take note that parts of the package introduce “Made in EU” conditionalities (e.g., linked to certain flexibilities and/or forms of public support). While strengthening European value creation is legitimate, these provisions must be designed in a workable, WTO-compatible way and should avoid unintended disruption of global supply chains and strategic partnerships.

FDI screening. We support a stronger EU and national framework for FDI screening to protect critical technologies and strategic value chains from high-risk acquisitions, while keeping Europe open to value-creating investment.
Mandatory cooperation with the local ecosystem. Where public support is granted (EU funding, incentives or public procurement), access should be conditional on a demonstrable European footprint and structured cooperation with the local ecosystem—through partnerships with European suppliers, joint R&D, skills and training programmes, and local anchoring of knowledge and know-how. This is in line with the Automotive Industrial Action Plan.

4) Skills transition as an accompanying measure

The transformation requires a strong skills and labour-market transition: targeted upskilling and reskilling, support for job mobility, and partnerships between companies, training actors and public authorities are essential to retain talent and to manage potential restructuring in a socially and economically responsible way.

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