Argo AI GmbH
Argo AI is a self-driving technology platform company.
ID: 120651441741-14
Lobbying Activity
Response to Approval of automated vehicles and of systems intended for such vehicles
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 Delegated Regulation amending Annexes I, II, IV and V to Regulation (EU) 2018/858 (“Draft Delegated Regulation”) aim to harmonize the regulatory and technical requirements for autonomous vehicles in the EU.
However, we are concerned that this regulatory proposal limits the type-approval of fully automated vehicles to a small-series, which leads to a limitation of 250 units of one type of vehicle per year and member state, and an overall maximum of 1500 units of one type of vehicle per year across the EU, to be type-approved. The limitation at EU level will in particular severely restrict the planning security of companies wishing to enter the market with commercial offerings in the coming years. The highly technical and cost-intensive development of autonomous vehicles requires a secure planning horizon, and the aforementioned limitation may represent a significant market entry and development hurdle.
Moreover, individual member states have already enacted national regulations with the goal to play a leading role in autonomous driving, e.g. Germany with its Autonomous Driving Act of 2021 and the associated Autonomous Vehicle Approval and Operation Ordinance (AFGBV). We would like to point out that the currently envisaged limitation at EU level represents a considerable step backwards compared to these national regulations and objectives which already allow for an unlimited approval and operation of autonomous vehicles.
We would therefore like to suggest the following regulatory alternatives:
- Insert an opening clause in the relevant EU regulations to the effect that these do not conflict with national type approvals (without quantity limits) in the area of automated/autonomous vehicles and allow for parallel applicability of the EU and national regulatory frameworks.
- Increase the quantity limits of the small series type approval legislation for automated/autonomous vehicles through delegated act as foreseen by the Regulation.
- Establish a reliable and short-term timeframe for the transition of the EU small-series regulation into an unrestricted regulation for series approval.
This approach would allow uniform regulation of technical and regulatory requirements throughout the EU without imposing restrictions at the national level. At the same time, planning security for companies would be increased and incentives for technological development would be maintained.
Please find attached a supporting document where we propose changes to the Draft ADS Regulation in regard to the volume limitation as well as in regard to other technical specifications.
Read full response19 Apr 2022
Please find attached Argo AI's feedback to the draft delegated regulation.
Read full response