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Approval of automated vehicles and of systems intended for such vehicles

Single market

The new General Vehicle Safety Regulation 2019/2144 paves the way to automation in the car sector, since it sets out, for a first time, specific requirements relating to automated and fully automated vehicles. This initiative further provides the technical specifications for the approval of automated vehicles and of the systems intended for such vehicles in order to ensure their safe operation on public roads.

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Public consultation

ID: 12152

Lobbying Activity

18 responses

European Carmakers Seek Higher Production Limits for Automated Vehicles

Association des Constructeurs Européens d'Automobiles, 4 May 2022

ACEA requests increased volumes under the Small Series approval scheme and elimination of production limits for Automated Valet Parking technology. They argue current restrictions threaten economic viability and market introduction of near-ready AVP technology.
This would allow manufacturers to commercialize automated parking technology without volume restrictions that threaten profitability.
Regulators lose oversight controls designed to limit deployment while learning from initial implementations.

German car industry demands parallel national and EU approvals

Verband der Automobilindustrie, 4 May 2022

The VDA wants national approval laws to remain valid alongside the new European framework. This would allow countries to pilot new technologies and approve larger numbers of vehicles locally.
Maintaining national approvals allows German manufacturers to sell more automated cars than EU limits permit.
The European Single Market loses its uniform regulatory environment if national and EU standards coexist.

Automotive suppliers urge higher production limits for automated vehicles

European Association Automotive Suppliers, 5 May 2022

CLEPA requests higher production limits and allowing manufacturers to use their own test sites. They also want to protect trade secrets and remove requirements for external driving status signals.
This would lower manufacturing costs and make self-driving technology more commercially viable.
Law enforcement officers lose the ability to easily identify a vehicle's current driving mode.

Intel urges EU to raise automated vehicle registration limits

Intel Corporation, 14 Apr 2022

Intel proposes increasing registration limits for automated vehicles and allowing countries to set higher caps. They also want a firm deadline for standard approval rules.
Higher caps would allow the company to move beyond experimental trials and achieve commercial scale.

ETSC urges stricter safety tests for automated urban vehicle approval

European Transport Safety Council, 5 May 2022

ETSC requests mandatory testing for vulnerable road users like wheel chair users and e-scooters. They argue regulators, rather than manufacturers, must define acceptable safety levels. They also advocate for independent access to vehicle data for safety research.
Stricter rules ensure automated driving actively reduces road deaths rather than just maintaining status quo.
Manufacturers lose the power to define safety benchmarks and exclusive control over data.

European Cyclists' Federation urges better safety for vulnerable road users.

European Cyclists' Federation, 5 May 2022

ECF requests that automated systems prioritize road user vulnerability and expand safety testing. They advocate for removing the term 'jaywalking' and improving crash data collection.
Cyclists would benefit from automated vehicles better equipped to handle complex urban environments.
Vehicle manufacturers would face more rigorous and costly testing requirements for automated systems.

DEKRA demands independent safety data access for automated vehicles

DEKRA e.V., 4 May 2022

DEKRA advocates for checking software integrity and correct functionality during periodic tests. They also want manufacturers to provide authorities with data for independent safety investigations.
Stricter testing requirements would solidify DEKRA's market position as a leading safety inspector.
Vehicle manufacturers would lose exclusive control over performance data and face higher transparency.

ANEC demands stricter testing and data transparency for automated vehicles

The European Consumer Voice in Standardisation, 5 May 2022

ANEC recommends testing systems with maximum vehicle loads to ensure worse-case scenarios are covered. They urge for clear information on how consumer mobility data is shared and used. The group also calls for harmonizing traffic rules so automated systems can interpret signs accurately.
These measures would increase consumer trust and safety in connected and automated driving.
Manufacturers could face more burdensome testing requirements and higher costs for data compliance.

Consultation response

Waymo, 4 May 2022

Waymo respectfully submits the attached views in response to the European Commission’s public consultation on its ADS Type-Approval Implementing Regulation. Our submission focuses on specific areas where we believe the draft Regulation can be strengthened as well as highlighting general aspects of…

European Blind Union urges automated vehicles to recognize white canes

European Blind Union, 4 May 2022

Automated vehicles should be required to recognize white canes as traffic signs. This requirement must be explicitly included in technical regulations for autonomous cars. All visible signs of visual impairment must be detectable by the vehicle systems.
This ensures the safety and independent mobility of visually impaired people in traffic.
Car manufacturers face higher technical burdens to ensure sensors detect partially obscured objects.

German transport association urges larger scale automated vehicle approvals

Verband Deutscher Verkehrsunternehmen, 5 May 2022

The association requests revising the threshold of the small series scheme to allow at least five-digit vehicle approvals. They also propose an opening clause for the application of national legislation.
This allows public transport operators to deploy large automated fleets under national laws.
Public transport loses if private manufacturers dominate automated services through limited approval quotas.

Consultation response

The International Motor Vehicle Inspection Committee, 5 May 2022

CITA welcomes the draft Implementing Act on ADS. CITA supports the provision that vehicles with ADS perform better than competent and carefully driven manual vehicles (cp. chapter 7 in Annex 2). However, it is not reasonable that the defined acceptance criteria by the manufacturer should be based…

Consultation response

Federation of European Motorcyclists' Associations, 13 Apr 2022

The Federation of European Motorcyclists' Associations (FEMA), representing the European riders of powered two- and three-wheelers (PTTWs) considers it of the upmost importance that vehicles that are equiped with provisions that take away part or even the entire driving task from the driver detect…

Consultation response

Sveriges MotorCyklister, 13 Apr 2022

Sveriges MotorCyklister är positiva till ökad trafiksäkerhet i en vägmiljö där alla fordon beaktas och samexisterar – dagens manuella bilar, motorcyklar, lastbilar, mopeder, bussar och veteranfordon parallellt med framtidens mer eller mindre autonoma fordon. För SMC är det ytterst viktigt att den…

Consultation response

Einride, 5 May 2022

Einride welcomes the European Commission draft Implementing Regulation laying down rules for the application of Regulation (EU) 2019/2144 of the European Parliament and of the Council as regards uniform procedures and technical specifications for the type-approval of fully automated motor vehicles…

Consultation response

Autonomous Vehicle Industry Association, 5 May 2022

Please find attached the Autonomous Vehicle Industry Association's (AVIA) response to the call for feedback.

Consultation response

Argo AI GmbH, 5 May 2022

Argo AI would like to thank the European Commission for the opportunity to provide feedback on the Draft Implementing Regulation laying down rules for the application of Regulation (EU) 2019/2144 (“Draft ADS Regulation”). We welcome the fact that the Draft ADS Regulation as well as the Draft…

Consultation response

MEED Group sarl, 8 Apr 2022

Les spécifications techniques pour les Véhicules automatisés avec ADS, n'ont pas à la conception, un ODD, qui prend en compte les besoins de communications bidirectionnelles sans-fil avec l'infrastructure. Or, C2I par exemple si mentionnée rend les constructeurs (Européen et étrangers) conscients…