The Automotive Sector’s Influence on EU Biodiversity Policy

The industry’s impact on pollution is first seen in the manufacturing process in the widespread use of PFAS (more commonly known as ‘forever chemicals’.) In particular, fluoropolymers are widely used in the automotive industry. It is for this reason that the industry is particularly focused on proposals by the European Chemicals Agency (ECHA) for a universal restriction of PFAS, with the majority of entities examined in this briefing advocating for specific exemptions for fluoropolymers under the proposal.

The polluting impact of the industry is also seen at the end of the automotive life cycle, with end-of-life vehicle management key to mitigating the potential adverse impacts on biodiversity of vehicle disposal. To this end, circularity requirements imposed by the End of-Life Vehicle Directive (ELVD) (and its proposed replacement, the End-of-Life Vehicle Regulation (ELVR), through its mandatory recycled content and closed loop targets), aim to reduce biodiversity loss stemming from pollution and environmental contamination.

The automotive sector can also be seen to directly impact land-use change, particularly through its demand for leather and natural rubber, which contribute to global deforestation. This is highlighted by the aforementioned Business for Nature report, which makes clear that land use impacts are “clearly attributable to the automotive sector.” The report explains how 20% of all bovine leather—and 40% of all leather produced in Brazil, where “cattle ranching is the number one direct driver of deforestation”—is estimated to “go into cars." Meanwhile, “70% of natural rubber is used to produce tyres,” with the report citing research that, in South-East Asia alone, “more than 4 million ha of forest has been converted for rubber cultivation since 1993.” Consequently, the sector has actively engaged with the proposed EU Deforestation Regulation (EUDR), which aims to reduce the EU’s impact on global deforestation.

The automotive sector further contributes to biodiversity loss by driving GHG emissions that cause climate change. However, this issue is outside the scope of InfluenceMap’s biodiversity assessment, as it is extensively covered by InfluenceMap’s climate policy engagement research.

This briefing finds that, across the industry, automakers generally exhibit negative engagement with biodiversity-related policies, with none of the analyzed entities demonstrating policy engagement aligned with policy pathways to deliver the Global Biodiversity Framework (science-aligned policy engagement).

Toyota, Mercedes-Benz, and Volkswagen Group do exhibit some supportive positions on international treaties and agreements such as the UN Convention on Biological Diversity (CBD), and the Kunming-Montreal GBF’s 30 by 30 target. However, this positive engagement is often outweighed by more negative positions on other regulations intended to address biodiversity loss, such as the revision of the ELVD, and the EUDR.

Furthermore, ACEA consistently takes positions that are more negative than those of its members, with the industry association exhibiting policy engagement that is opposed to science-aligned biodiversity policy. This contributes to the Relationship Scores of automakers, which measure how supportive or opposed the aggregate of a company's industry associations is toward policy, being lower across the board than Organization Scores, which indicates how supportive or opposed an organization is toward biodiversity policy.

Of the seven companies and one industry association examined in this report, five can be considered to exhibit active engagement (above 12%), as per LobbyMap’s Engagement Intensity (EI) metric. The metric, which is independent of both the Organization Score and the Relationship Score, provides a measure of how active a company or industry association is in its direct biodiversity policy engagement activities. For example, Volkswagen’s EI of 18% indicates that it has frequently engaged directly with policymakers on specific biodiversity policies and regularly communicates on biodiversity policy issues through public disclosure channels such as its organisational websites.

In a December 2023 position paper, ACEA stated that the original 25% recycled content target “is not technically achievable”, with “ambitious” targets only being “realistic” if pre-consumer recycled content was included in the calculation. A year later, in a December 2024 press release, ACEA advocated for a “stepwise approach”, with an initial target of 15% recycled content after six years, and a second target of 20% five years later, as well as the inclusion of pre-consumer waste. This same request was echoed by automakers themselves, with a letter to the German Federal Ministry of Transport from Toyota two months later calling for the same targets, and a December 2024 presentation to the German Federal Government from Volkswagen advocating for a flat 15% target and calling for pre-consumer waste to be included in calculations.

More recent engagement, such as BMW’s feedback in November 2025 on the EU’s proposals for a Circular Economy Act, appeared to criticise the Commission’s approach to recycled content quotas in its entirety. Stating that the ELVR proposal creates “obstacles for the circular economy”, BMW argued the proposed legislation hadn’t sufficiently examined whether “the technical implementation of the plastic recycled content quotas is realistic.” It further warned of the possibility of “a disproportionate amount of bureaucratic effort” resulting from such targets.

The eventual agreement, reached at trilogue negotiations in December 2025, has incorporated a number of the alterations sought by the automotive industry, and is significantly weaker than the original ambition for the regulation outlined by the European Commission in July 2023. The new proposals include a weaker overall recycled content target with a stepwise target—15% after six years, and 25% after 10 years—and a reduction of the closed loop target to 20%. This appears to be a victory for the automotive sector, with key concessions in line with industry advocacy.

More recent engagement has focused on associated proposals for the universal restriction of PFAS, more commonly known as ‘forever chemicals’. Many PFAS are considered Persistent Organic Pollutants (POPs) due to the fact that they do not break down naturally in the environment. The proposals aim to restrict the manufacture, placing on the market, and use of around 10,000 of these PFAS substances.

Engagement on REACH revision has been predominantly negative, with ACEA leading efforts to weaken the regulation. ACEA’s opposition was affirmed in an April 2022 consultation response, in which it strongly disagreed with the view that “the most harmful chemical substances” should be prohibited in products used by consumers, and outlined its opposition to the proposed definition of the essential use concept. More recently, advocacy has focused on weakening various existing provisions of REACH in its revision. This has included exemptions for legacy spare parts, and opposition to both the implementation of mixture allocation factors, which aim to address the elevated risks of chemical mixtures, and group restrictions for chemicals. This is seen from ACEA in comments in April 2025 and a September 2025 consultation response, as well as Toyota in feedback to the same consultation.

Opposition to the universal restriction on PFAS is more widespread across the industry, with both ACEA and automakers themselves consistently advocating for various exemptions and derogations. Indeed, even before the proposals were submitted to the ECHA in January 2023, ACEA raised its concerns—a December 2022 presentation given to the FluoroProducts and PFAS for Europe (FPP4EU) Collaboration Platform Workshop summarizes that, despite a lack of knowledge of the details of the proposals, “the PFAS restriction is a major threat to our European business.”

Upon the publication of the proposed restriction, ACEA was more forthright in its opposition, as evidenced by its submissions to the Annex XV Dossier of the Universal PFAS Restriction Proposal. Both its May 2023 comments, as well as its submission in September 2023, sought to reduce the proposal’s scope, advocating for exemptions for fluoropolymers and fluoroelastomers, a position it reaffirmed in an October 2023 joint statement. This culminated in a December 2023 presentation to the aforementioned FPP4EU Workshop, in which ACEA warned that the “current PFAS restriction proposal is not manageable for the automotive industry.”

Direct automaker engagement on the proposal has advocated for similar exemptions for fluoropolymers. For example, Volkswagen’s September 2023 statement on the proposals advocated for their “exclusion from the restriction,” as did Ford in a position statement to the German Bundestag in June 2024. In a June 2024 meeting with the European Commission, BMW similarly sought to distinguish fluoropolymers, while also associating itself with the aforementioned comments to the Annex XV restriction dossier of ACEA. Meanwhile, Volvo Group’s September 2023 submission on the Annex XV Dossier notes the importance of fluoropolymers, while Nissan’s consultation response to the ECHA in June 2023 cites a “recent review” that concluded that "fluoropolymers are irreplaceable in many applications,” thus advocating for their exemption.

In August 2025, the ECHA announced an update to its draft PFAS restriction proposal. Amongst the amendments contained in its Background Document, it proposed a 13.5 year derogation for fluoropolymers used in “vehicle systems, components or separate technical units,” as well as for fluoropolymers that are “strictly necessary for (the) safety or environmental performance of those vehicles until 13.5 years after” the regulation’s Entry Into Force (EIF). Whilst this falls short of the blanket exclusion advocated for by the automotive industry, it suggests that its advocacy has been somewhat successful thus far. Further concessions may be advocated for in the upcoming ECHA consultation period.

After this initial postponement, BMW took the opportunity to push for further revision and simplification of the EUDR. A February 2025 position paper sent to the German Bundestag argued that existing due diligence policy was sufficient and need not be replicated in the EUDR, with it also concluding the need for a “thorough review of the regulation’s overall simplicity.” This was followed by a March 2025 presentation to the European Commission’s Expert Group on Protecting and Restoring the World’s Forests, in which BMW advocated for the introduction of minimum threshold exemptions in order to “improve (the) feasibility” of the EUDR.

A month later, the European Commission announced simplifications to the EUDR’s implementation and launched a public consultation to clarify the Regulation’s scope. This paved the way for the most extensive period of engagement from the automotive industry thus far, with responses recorded from ACEA, BMW, and Mercedes-Benz. While both automakers stated support for the goals of the EUDR, they were unified in their advocacy for specific exemptions, with both position papers calling for exemptions for prototype parts used for testing purposes, and BMW supporting the EU’s proposals to exclude packaging material from the EUDR’s scope. ACEA advocated for a wide range of measures that would weaken the EUDR, supporting the introduction of minimum threshold exemptions, opposed intra-EU tracing, and advocated for a risk-based approach.

In their respective September 2025 consultation responses regarding the simplification of administrative burdens in environmental legislation, ACEA, Toyota, and BMW all advocated for the same range of measures outlined in ACEA’s aforementioned consultation response. ACEA additionally called on the Commission to delay the EUDR’s implementation by one year, a position it reaffirmed in a November 2025 press release that argued that attempts by the European Commission to simplify the EUDR “fall short of achieving a significant simplification”, “raising significant concerns for automotive OEMs and suppliers”. In December 2025, the European Council, in a further victory for the automotive sector, officially announced the postponement of the application of the EUDR for a second time. The announcement also obliges the European Commission to produce a “simplification review” by 30 April 2026, which will “evaluate the impact and administrative burden of the EUDR."

Of all entities covered by this briefing, only one (Nissan) has been evaluated as being partially transparent on its positions and engagement activities on specific biodiversity-related policies. Four entities (ACEA, Mercedes-Benz, BMW, and Volvo Group) exhibit mixed transparency, having published partial accounts of their positions and engagement activities, but excluding more than three cases of material evidence of direct biodiversity policy engagement identified by InfluenceMap’s database.

The remaining three entities (Toyota, Volkswagen, and Ford) have been evaluated as less transparent, with the respective disclosures of their positions and engagement activities being limited to top-line biodiversity statements without reference to specific biodiversity-related policies.

Of the seven companies analyzed in this briefing, only four—Volvo Group, Ford, Mercedes-Benz, and BMW—have disclosed a full list of their industry association memberships. However, neither they, nor the other three companies covered by this research, have provided an account of these industry associations' positions and engagement activities with biodiversity policy. Given the wide range of such engagement undertaken by industry associations in the sector—as evidenced by this briefing—this represents a likely governance oversight, and falls significantly short of investor expectations on corporate lobbying.