BRP (Bombardier Recreational Products)

BRP

BRP Inc.

Lobbying Activity

Response to Revision of the Directive on Driving Licences

18 May 2021

BRP (Bombardier Recreational Products) produces motor tricycles with a power exceeding 15 kW (L5e) sold in the EU. We welcome the Commission’s revision of the current Directive on Driving Licences (3DLD), with the objective to improve the freedom of movement and road safety. We believe further actions are required to ensure the objectives of the Directive on Driving Licences are met. We have highlighted below two main issues to the freedom of movement riders of motor tricycles (L5e) face and we will respond in more details to the public consultation, which will open in the fourth quarter of 2021. 1. The Driving Licence Directive (art. 6 §3) allows Member States to grant the equivalence for motor tricycles to be driven under a category B licence but only on the national territory. This restriction limits the freedom of movement in the EU. Citizens of a State which has granted the equivalence and who obtained their B licence after 19 January 2013 are only allowed to drive in their country and cannot cross borders to other EU countries which have approved the same equivalence. Allowing mutual recognition of the equivalence among Member States which have granted it will improve the freedom of movement in the EU. 2. There is some confusion related to the codes indicating the driving entitlements on licences for motor tricycles, as not all holders of a B licence have an indication on their driving licence proving their ability to drive tricycles. The recognition of the entitlement could be problematic, and drivers can face issues in their country, when crossing borders or driving in other EU countries. The restriction to the national territory of the Member State which has granted the equivalence and the absence of indication on the driving licence that a holder is entitled to drive motor tricycles generate uncertainty, a form of inequity among European citizens and create major obstacles to the exercise of the freedom of movement within EU. The above points should be addressed in this initiative.
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