The Classic Car Retrofit Consortium represents SMEs performing small-series and classic car retrofits, averaging around 10 vehicles per year. The current draft regulation applies OEM-level type-approval logic designed for large-series fleet retrofits, which would eliminate the existing SME sector without materially improving safety. Specific challenges include destructive REESS testing costs of approximately 100,000 EUR per battery pack type, full-vehicle EMC testing costs around 30,000 EUR per car, and cybersecurity requirements unsuitable for classic vehicles. CCRC proposes either clarifying the regulation’s scope to exclude classic car retrofits, or developing a tailored regulatory framework specifically for classic cars produced in small numbers.