DEKRA e.V.
DEKRA
DEKRA is a global provider of testing, inspection and certification services working for safety on the road, at work and at home.
Lobbying Activity
Meeting with Valérie Hayer (Member of the European Parliament) and Amazon Europe Core SARL and
28 Jan 2026 · Politique commerciale de l'UE
1 Dec 2025
DEKRA welcomes the plan to align regulations on access to repair, maintenance, and inspection information with current cybersecurity requirements. The planned amendment of 2018/858/EU will eliminate the legal uncertainty that has prevailed to date regarding the application of security measures for access via the electronic diagnostic vehicle interface (OBD-Port) and remote vehicle interfaces. Access to repair, maintenance, and inspection information is not only of fundamental importance with regards to a level playing field for independent operators in the automotive aftermarket, it is also prerequisite in order to maintain road safety by enabling inspection by authorities and authorized impartial 3rd parties. However, if the current draft of the amendment to Directive 2018/858 in particular Appendix 4 is interpreted strictly, it appears to restrict all access to electronic vehicle systems, even for basic diagnostic services. This could have implications for the maintenance, testing and repair of vehicles over their entire lifecycle. Please find attached our complete feedback.
Read full responseMeeting with Elena Kountoura (Member of the European Parliament, Shadow rapporteur)
6 Nov 2025 · Meeting with DEKRA representative
Meeting with Asger Christensen (Member of the European Parliament, Shadow rapporteur)
15 Oct 2025 · Roadworthiness package
DEKRA calls for standardized battery health labels for EVs
9 Oct 2025
Message — DEKRA requests standardized labeling for all vehicle types. They advocate for independent battery assessments to build trust in the second-hand market.12
Why — This creates new business opportunities for DEKRA in independent battery testing and certification.3
Impact — Car manufacturers lose exclusive control over battery data and proprietary health assessment methods.4
Meeting with Jens Gieseke (Member of the European Parliament, Rapporteur)
30 Sept 2025 · Roadworthiness-Package
Response to Revision of the Roadworthiness Package
18 Jul 2025
With around 48,000 employees in around 60 countries on five continents DEKRA is one of the worlds largest independent and neutral automotive expert organization active in the testing, inspection, and certification ecosystem. Our vehicle and road safety experts have been at the forefront of advances in automotive developments since DEKRA was founded in 1925, as the German Vehicle Inspection Association. As the global partner for a safe, secure, and sustainable world, DEKRA welcomes the EU roadworthiness package proposal, especially the revision of Directive 2014/45/EU on periodic roadworthiness tests for motor vehicles and their trailers. In this regard we want to highlight that we see great potential in the proposal and its amendments to further improve road safety and to reduce the environmental impact of road traffic in Europe. Important amendments were made to ensure future-proof requirements in the light of the rapidly advancing technological development of vehicles. With the feedback document attached, we are submitting specific information and recommendations from the perspective of independent technical inspection organizations for the further legislative process.
Read full responseMeeting with Markus Ferber (Member of the European Parliament)
12 Jun 2025 · EU Roadworthiness Package
Meeting with Alexandra Geese (Member of the European Parliament) and Deutsche Telekom and
29 Apr 2025 · Event: DACH-Tech
Response to Technical description of important and critical products with digital elements
14 Apr 2025
The sheer ubiquity and deep integration of smartphones into modern society further amplify the potential impact of security failures, aligning with the criteria for Class 2 designation which considers the scale and severity of potential adverse effects. A widespread vulnerability affecting a popular smartphone model could have cascading consequences, disrupting communication networks, facilitating large-scale fraud (particularly targeting digital wallets), enabling mass surveillance or identity compromises, or even impacting critical infrastructure indirectly through compromised user accounts or connected IoT devices controlled via phone apps. The societal reliance on these devices for everything from emergency calls and navigation to banking, accessing public services using digital IDs, and making payments means that systemic failures pose a substantial risk of societal and economic disruption, far exceeding the impact expected from lower-risk product categories. Therefore, classifying smartphones as Class 2 under the CRA is crucial for ensuring they are subject to appropriately rigorous security requirements, including mandatory third-party conformity assessments and extended security support lifecycles. Given their complex attack surface, the immense value and sensitivity of the data and credentials they handle (especially digital wallets and identities), their role as controllers for other devices, and the potential for widespread harm should vulnerabilities be exploited at scale, treating them as high-risk products is a necessary step. This classification would mandate a level of security by design, independent verification, and ongoing vigilance from manufacturers that reflects the central and critical role these devices play in the lives of EU citizens and the functioning of the digital economy.
Read full responseMeeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis)
27 Feb 2025 · CSRD simplification
Meeting with Simone Ritzek-Seidl (Cabinet of Commissioner Apostolos Tzitzikostas)
7 Feb 2025 · Exchange of views on automotive sector
Meeting with Delara Burkhardt (Member of the European Parliament, Rapporteur) and TIC Council
14 Jan 2025 · Green Claims
Meeting with Chris Uregian (Cabinet of Vice-President Margaritis Schinas), Despina Spanou (Cabinet of Vice-President Margaritis Schinas)
13 May 2024 · EU Cybersecurity legislation Cybersecurity Skills Academy
Response to Revision of the Toy Safety Directive
31 Oct 2023
DEKRA, a global leader in testing, inspection, and certification, is committed to safety in every domain. Our vision focuses on a safer world, and toys, crucial in a child's formative years, are no exception to our mission of protecting human life. We support the European Commission's initiative to revise the Toy Safety Directive. The evolution into a regulation ensures consistent toy safety standards across Member States. We also endorse the introduction of a Digital Product Passport for toys and enhanced safety measures considering a childs psychological health. However, the proposal's tools might not address all challenges. We're concerned about the rise in unsafe toys in the EU market due to: Reliance on manufacturers self-declaration of conformity. Weak market surveillance mechanisms. Risks of internet-connected toys. While the proposal is a step forward, we suggest: 1.Strengthening Safety Assessment: The Digital Product Passport focuses on compliance documentation but doesn't guarantee the validity of the information and, by extention, a toy's safety. Genuine threats, like harmful chemicals or choke hazards, require comprehensive testing. The DPP should be a transparency tool, providing data on a toy's composition, usability, and recyclability. Only rigorous verification can ensure safety. We recommend mandatory third-party checks for specific high-risk toy categories. Despite these representing a significant share of non-compliances, they're about 20% of the market. For what concerns the cost of certification, estimations conducted by the Commission in its Impact Assessment show no significant price difference between third-party conformity assessment (4500 EUR) and self-assessment (4000 EUR). 2.Addressing Smart Toys' Challenges: Smart toys, with AI and connectivity, introduce both innovation and potential privacy risks. The Commission's proposal references existing or in-progress legislations, but these may have varied risk and compliance perspectives. For instance, the Cyber Resilience Act might not fully align with the Toy Safety Regulation: the conformity assessment procedure for safety aspects under the Toy Safety Directive is more stringent than the procedure for security aspects under the CRA. The upcoming AI Act could leave AI toys in a legislative gray area. An integrated approach is essential, considering both the physical and digital safety of smart toys. 3.Detailed Testing Methodologies: We back the Commission's move to tighten regulations on harmful substances in toys, highlighting a commitment to child safety. However, stricter regulations need robust execution. We urge the Commission to introduce precise methodologies through delegated acts or harmonised standards, ensuring that manufacturers and notified bodies can effectively assess chemical limits and ensuring seamless application of the Regulation.
Read full responseMeeting with Marion Walsmann (Member of the European Parliament, Rapporteur) and European Balloon and Party Council
4 Oct 2023 · Toy Safety Regulation
Response to Revision of the Directive on Driving Licences
30 May 2023
DEKRA is an international testing, inspection and certification company which employs almost 48,000 people in over 60 countries on all six continents. Founded more than 95 years ago as the German Vehicle Inspection Association, Road Safety is at the heart of DEKRA. As one of the worlds leading driver testing and vehicle licensing organizations, we ensure that our customers are fully compliant with all relevant local laws and regulations around driver testing and vehicle licensing. We welcome the European Commissions initiative to revise the Directive on Driving Licenses, as it is necessary to address the new mobility challenges and better reflect on the physical and mental fitness to drive. However, we would like to point out that the current version of the directive still has considerable technical shortcomings, which we have also highlighted in our previous suggestions. Since driving licences law is always about preventing considerable harm to life and limb, the criterion for our assessments is the protection potential for all road users resulting from a regulatory issue. At the same time, we argue from the neutral, independent, and impartial perspective of an expert. In addition to the previous contributions we have shared, please find attached our comments and recommendations regarding the revision of the EU Driving Licences Directive from the perspective of traffic psychology (TP) and traffic medicine (TM), considering our relevant practical experience with drivers committing traffic offences.
Read full responseMeeting with Marcel Kolaja (Member of the European Parliament, Shadow rapporteur for opinion)
4 May 2023 · discussion about the latest developments in the negotiations
Response to Advanced driver distraction warning (ADDW) systems
21 Apr 2023
DEKRA is an international independent testing, inspection and certification company with almost 44,000 employees in 50 countries, which conducts more than 26 million inspections across 22 countries each year. Founded more than 95 years ago as the German Vehicle Inspection Association, Road Safety is at the heart of DEKRA. We welcomed the Draft Delegated Regulation on advanced driver distraction warning (ADDW) systems as part of the General Safety Regulation for motor vehicles, as it was promised to address distracted driving, which is a growing problem on our roads leading to deaths and serious injuries. We however regret the lack of ambition in these technical requirements for ADDW systems to tackle this key road safety issue. We regret that the ADDW system's functionality is limited to warning drivers who look at their lap for an extended period. It does not provide warnings for prolonged gazes away from the front windscreen towards the dashboard, infotainment system, or other devices like smartphones in that area, which are crucial in addressing distracted driving. Moreover, the system does not alert drivers who turn towards the rear of the vehicle. As a result, the system's ability to address various driver distractions is restricted. In addition, we are concern that drivers are permitted to be distracted away from the windscreen for up to 6 seconds while driving at speeds typical of urban areas (vehicles speed between 20 and 50 km/h), which are known for their constantly changing traffic conditions and frequent presence of vulnerable road users. Studies have demonstrated that glances away from the windshield exceeding 2 seconds increase the risk of a crash twofold. Therefore, it is difficult to understand why the system allows drivers to remain distracted for up to 6 seconds in urban areas while it allows a gaze of the driver for a maximum time of 3,5 seconds in the nominal situation when the vehicles speed is of 50 km/h or above. The explanation given, that a longer lead time prior to a warning when driving at speeds between 20 and 50 km/h is necessary to prevent false positive warnings, notably in environments such as roundabouts where drivers would gaze through the side windows to observe the relevant traffic environment, is not valid because the draft rules state that the side windows are part of the area for which no warning has to be given as the driver is expected to be paying attention to the road environment. We urge the European Commission to reconsider the draft requirements with a view of strengthening the provisions so that the technical requirements for ADDW systems match the gravity and urgency of the problem posed by distracted driving. Further relevant aspects and more detailed explanations on the Draft Delegated Regulation, can be found in the Response to the Consultation on the Draft Delegated Regulation on Advanced Driver Distraction Warning (ADDW) systems published by ETSC.
Read full responseMeeting with Nicola Danti (Member of the European Parliament, Rapporteur) and Bureau Européen des Unions de Consommateurs and
27 Feb 2023 · Stakeholder consultation on the Cyber Resilience Act
Meeting with Henna Virkkunen (Member of the European Parliament, Shadow rapporteur)
14 Feb 2023 · EU Cyber Resilience Act
DEKRA Urges Expanded Third-Party Testing for Digital Products
20 Jan 2023
Message — DEKRA argues that third-party certification must be extended considerably to ensure safety. They suggest a stage-based approach to manage capacity while reducing burdens. Self-assessments often lead to vulnerabilities and reward non-compliance with lower costs.123
Why — Mandating third-party assessments would increase demand for DEKRA’s specialized testing and certification services.4
Impact — Manufacturers using self-declaration lose the financial advantage gained from avoiding independent security oversight.5
Meeting with Ismail Ertug (Member of the European Parliament)
14 Nov 2022 · Road Safety Report
DEKRA urges including quality management systems in AI liability rules
8 Nov 2022
Message — DEKRA suggests including Quality Management System requirements from the AI Act in the liability directive. They propose referencing Article 17 to ensure provider obligations following duty of care.12
Why — Expanded compliance requirements for quality systems create more demand for their certification services.34
Impact — AI providers face easier liability claims if they lack robust quality management.5
Response to Type approval of motor vehicles regarding access to in-vehicle generated data
21 Jun 2022
DEKRA is an international testing, inspection, and certification company, which employs almost 48,000 people in over 60 countries on all six continents. One of DEKRA's core activities is performing periodic roadworthiness inspections on behalf of public authorities and by that ensuring that vehicles remain safe and compliant throughout their whole life. Given the importance of this task, DEKRA very much welcomes that the Call for Evidence specifically acknowledges the need of public authorities to have access to vehicle data, functions, and resources.
Please find our full feedback attached. In case of further questions, please do note hesitate to contact us at eu.office@dekra.com
Read full responseDEKRA calls for better data access for safety inspections
13 May 2022
Topic — This consultation seeks views on fair access and use of data generated by connected products.
Message — DEKRA calls for the removal of the "exceptional need" requirement for public bodies to access data. They demand that data for sovereign uses like vehicle inspections be unfiltered, unmodified, and shared under fair conditions.123
Why — Guaranteed access to raw vehicle data enables DEKRA to maintain its testing and certification business.45
Impact — Vehicle manufacturers lose their dominant market position and exclusive control over valuable technical data.6
Meeting with Ismail Ertug (Member of the European Parliament)
12 May 2022 · Parlamentarischer Abend: Vorstellung des DEKRA Verkehrssicherheitsreports 2022
DEKRA demands independent safety data access for automated vehicles
4 May 2022
Topic — This initiative provides technical specifications for approving automated vehicles on public roads.
Message — 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.12
Why — Stricter testing requirements would solidify DEKRA's market position as a leading safety inspector.3
Impact — Vehicle manufacturers would lose exclusive control over performance data and face higher transparency.4
Response to Review of Directive 2012/27/EU on energy efficiency
18 Nov 2021
DEKRA welcomes the revision of the Energy Efficiency Directive (EED) and the aim to implement energy saving targets in the public sector, such as through the mandatory annual renovation of 3% of public buildings.
In particular, we would like to express our support for Article 11, which shifts the criterion for energy audits and energy management systems from the type of enterprises to the levels of energy consumption and requires energy management systems for the largest energy using companies. We fully agree that this management system shall be certified by an independent body.
We also believe, that energy audits for these companies shall be carried out in an independent and cost-effective manner by qualified or accredited experts. Here, we would like to emphasize that these audits should be carried out by independent third parties to ensure the impartiality of the energy audits. However, we believe that such an audit should be performed every 3 instead of every 4 years, such as with the ISO 50001 standard on Energy Management, to ensure the constant compliance with the respective energy management system.
Finally, we would encourage the European Commission to also set up requirements with regards to energy management for SMEs than rather just for the largest energy using companies.
Read full responseResponse to Revision of the Toy Safety Directive
2 Nov 2021
DEKRA welcomes the European Commission’s initiative to review the Toy Safety Directive.
We would like to support turning the Toy Safety Directive into a Regulation. We believe, that this will ensure consistent application of the toy safety requirements by all Member States.
We also agree with the points raised in the Impact Assessment on new risks on toys that are connected to the internet or toys operating with AI. We are convinced that they should be addressed by the new Regulation. This would take into account security, privacy and the protection of data, if not covered by other legislation. Additionally, these products should be bound to requirements with regard to the availability of software updates to guarantee the product remains secure during its lifetime. We would like to highlight that security flaws have the potential to jeopardize toy safety.
Furthermore, are we in favor of strengthening the chemical requirements for toys and to also set limits for toys intended for children aged above 36 months, as the risk does not decrease above this age.
With regard to online trade warning signs and other labelling information, we consider that this information should be visible when buying online, similar to when buying toys in a physical shop.
Finally, DEKRA would like to highlight that the Consulting Safety Gate (former RAPEX) reports that many unsafe toys still enter the European single market. This creates an unacceptable risk to the safety, health and privacy of children. Mandatory third-party assessment by independent third parties should be considered for toys with a high-risk potential such as toys intended for the most vulnerable consumers (e.g. children aged 0 – 36 months) and toys connected to the internet.
Read full responseResponse to Revision of the Roadworthiness Package
27 Oct 2021
DEKRA is an international independent testing, inspection and certification company with almost 44,000 employees in 50 countries, which conducts more than 26 million inspections across 22 countries each year. Founded more than 95 years ago as the German Vehicle Inspection Association, vehicle inspection is at the heart of DEKRA.
We welcome the initiative to revise EU’s roadworthiness package to improve road safety and to ensure lifetime compliance of vehicles with emissions and safety standards. As mentioned in the current Directive 2014/45/EU “Roadworthiness testing is […] designed to ensure that vehicles are kept in a safe and environmentally acceptable condition during their use. […] Periodic testing should be the main tool to ensure roadworthiness. ” Therefore it is essential to further develop technical inspections in Europe and to make the legal framework future-proof to contribute to the Sustainable and Smart Mobility Strategy.
The document “COMBINED EVALUATION ROADMAP/INCEPTION IMPACT ASSESSMENT” (Ref. Ares(2021)6015595 - 04/10/2021) already highlights important approaches to improve and to adapt the roadworthiness package. DEKRA also supports to explore the aspects of the 2014/45/EU mentioned in section “B. Objectives and Policy options” in this document. Technical progress in safety-relevant electronic components, the introduction of advanced driving assistance system (ADAS) as well as automated functions must be part of a future-oriented periodic technical inspection. For this, non-discriminatory and free access to vehicle data for inspection organizations is essential.
A combination of visual and mechanical inspection, with calibrated test devices, completed by the analysis of in-vehicle data related to ADAS and safety functions, will provide a future basis for meaningful and relevant periodic technical inspections. The stricter emission requirements necessitate the development of new emissions testing methods and their integration into the legislative framework.
In addition to the aspects named in the document of the public consultation (Ref. Ares(2021)6015595 - 04/10/2021), we would like to highlight the importance of the impartiality of inspection organizations and their inspectors avoiding conflicts with manufacturing, leasing, trade and maintenance of vehicles and their parts. Regardless of the inspection methods used and further developments in this field, the independence of the inspectors and their organizations should always be a key requirement for conducting inspections. This guarantees an objective inspection as well as the necessary confidence of vehicle owners in correct vehicle inspections. Therefore, we propose to include this aspect in the exploration and evaluation as part of the revision.
Further relevant aspects and more detailed explanations on the revision of the entire roadworthiness package, which are supported by DEKRA, can be found in the position paper "STRENGENING THE ENVIRONMENTAL AND ROAD SAFETY ASPECTS OF THE EU ROADWORTHINESS PACKAGE" published by CITA.
Read full responseResponse to Review of the general product safety directive
30 Sept 2021
DEKRA welcomes the European Commission’s proposal to revise the General Product Safety Directive.
We believe, that many important points to improve consumer safety have been addressed in the proposal.
We support the following:
• The Commission proposing to turn the Directive into a Regulation
• The proposal to integrate the traceability requirements for products and the obligations for economic operators by proposing a separate delegated to establish a new system for traceability
• To create a market surveillance system for harmonized and non-harmonized products
• The further development of the Safety Gate
• Stricter rules for online marketplaces and the requirement to register with the Safety Gate. Online marketplaces should carry similar responsibilities in terms of product safety as physical shops and inform the consumer of possible dangers of the respective product
However, the current proposal does not take into account the need to increase product testing by independent third parties to improve product safety on the EU’s internal market.
Article 7, addressing the aspects for assessing the safety of products, states that when assessing whether a product is safe, European and international standards as well as voluntary certification schemes or similar third-party conformity assessment frameworks, when available, shall be taken into account.
However, this is not reaching far enough. Mandatory third-party assessment by independent third parties on a risk-based approach or in the absence of harmonized standards would make products placed on the EU’s internal market safer and reduce the number of non-compliant products on the market. This would also contribute to a better functioning market surveillance system and should therefore be considered in the next steps of the legislative process with regards to the proposed Regulation.
We strongly believe, that third-party conformity assessment performed by a Notified Body (NB) should be established in the Regulation to ensure compliance with essential safety requirements as an alternative to the general self-assessment procedure.
In particular, as standards for new products entering the market often do not exist or are not harmonized yet, the approval by a Notified Body (NB) can ensure compliance with essential requirements for products. The Radio Equipment Directive (2014/53/EU) could serve as a blue print here.
Furthermore, Notified Bodies may be instructed by economic operators to test products falling under the new Regulation on a voluntarily basis. However, a mandatory inclusion of NBs is recommended for novel products and products which pose a serious risk as defined in the Regulation (EU) 2019/1020 on Market Surveillance.
As highlighted in the text, the Regulation should aim at protecting consumers and put this aim as the highest priority when revising the General Product Safety Directive. It rightly points out that dangerous products can have very negative consequences on consumers and citizens. All consumers, including the most vulnerable, such as children, have the right to safe products. This is best ensured by reliable and independent testing, inspection and certification by third parties. Here we would like to add, that while clear safety requirements apply to toys, non-harmonized childcare products do not necessarily address all safety issues if used inappropriately.
Finally, we would like to raise the regulations of online trade, considering the visibility of the CE mark and labelling information on products. If products are bought on-site, the CE mark and labelling information are visible to consumers before the purchase. In case of online trade, consumers can only consult the CE mark and labelling information after delivery. Article 18 covers the obligations of economic operators in case of distance sales. We propose to include the obligation for the visibility of any kind of labelling in this article.
Read full responseResponse to Revision of Alternative Fuels Infrastructure Directive
14 Sept 2021
DEKRA is an international independent testing, inspection and certification company with almost 44,000 employees in 50 countries and offers a broad portfolio of services. DEKRA is also specialized in various services connected to charging stations for electrical vehicles (EV). This entails technical advisory when defining the project specifications, the electrical measurements to establish the available power before the installation, the certification of conformity of the electrical installation, the initial inspection, the technical quality control of the charging station installation as well as the functional testing of EV charging stations (AC charger), periodical inspections, non-periodical inspections and IR Thermography.
We welcome the European Commission’s Proposal for a Regulation on the deployment of alternative fuels infrastructure.
Currently each country follows its own approach and goals with regards to the regulation of inspections of electrical vehicle charging stations. By proposing to turn the Directive into a Regulation, the Commission aims to ensure a rapid and coherent development towards a widely-spread network of fully interoperable recharging infrastructure in all Member States. To reach this goal, we believe a more harmonized approach with regards to the initial and periodic inspections of charging stations should be followed as well. As pointed out in the proposal, the shortcomings of the current policy framework are clearly visible and the Member State’s level of ambition varies greatly. Only a common European legislative framework that includes inspections of charging stations can reach these objectives.
As a positive example, which could be a base for a common approach, we would like to highlight the French decree No. 2017-26. It concerns the recharging infrastructure for electric vehicles and containing various measures for the transposition of Directive 2014/94/EU. It lays down, that charging facilities open to the public, shall be checked at least once a year.
We are convinced, that a regular periodic inspection which entails functional tests, an evaluation of the general condition and thus an assessment of the proper functioning of the charging station is crucial to ensure the safety, availability and usability of a dense, widespread network of alternative fuels infrastructure throughout the EU. This would also facilitate a predictive maintenance approach.
The proper functioning of charging stations will be a key issue in the future. However, it is equally important to define who would be able to carry out this inspection. As independent third parties hold the competence and capacity to reliably carry out this inspection, we are convinced that third-party inspection is the best way to guarantee the safety and availability of charging stations and hence the safety and satisfaction of users of these charging stations.
As stated in Article 19 of the proposal, the Commission plans to adopt delegated acts to supplement the proposal with common technical specifications, to enable full technical interoperability of the recharging and refueling infrastructure in terms of physical connections and communication exchange. When mentioning the technical interoperability of the recharging infrastructure in the Commission’s proposal, we believe it is essential to include the inspection of the charging stations as well. The aforementioned harmonization of rules to inspect the charging infrastructure could be included here.
Read full responseResponse to Standardisation Strategy
20 Jul 2021
As one of the world’s leading testing, inspection and certification (TIC) company, DEKRA welcomes the publication of the Roadmap for a revision of the standardization strategy and to address the challenges for the European Standardization Strategy (ESS).
We would like to raise two challenges that are currently being faced by the ESS and where we see room for improvement.
Firstly, the publication and subsequent citation in the OJ as harmonized standards of many standards developed by a European Standardization Organization (ESO) under an EU mandate to support EU legislation, are recently being heavily delayed. As a consequence, harmonized standards do not exist for a significant group of products and those that exist, do not reflect the state of the art.
Another consequence of these developments is that EU standards are lagging more and more behind compared to international standards. Therefore, the content of EU and international standards start to diverge. In particular, since international standards are being developed at a high pace.
Secondly, we would like to highlight the issue of access to standardization and opportunity that arises from digitalization. We strongly believe that the further digitalization of the standardization process could increase accessibility of stakeholders and thus participation in standardization. This in turn could lead to a broader stakeholder group involvement, result in a broader acceptance and an increased quality of the standardization deliverables. For instance, the provision of tools to allow remote participation in more meetings would make it less time consuming, cheaper and more convenient for stakeholders to participate.
Read full responseResponse to Revision of the Machinery Directive
15 Jul 2021
As one of the market-leading Notified Bodies (NBs), DEKRA welcomes the European Commission’s proposal for a Regulation on machinery products.
We fully support that the proposal enhances the role of independent third parties as providers of testing, certification and inspection (TIC) services for machinery products and proposes to extend their competencies to ensure the safety of machinery products and in the following also the safety of consumers and workers.
The fact that TIC services performed by third parties, hence Notified Bodies and independent laboratories, increase the safety of machinery products when placed on the European market, the European Commission confirmed already when presenting the legislative proposal in a IMCO Committee hearing in the European Parliament.
We recognize that the legislative framework on machinery products received an update with regards to new risks, in particular on the digitalization of machinery. Here, we would like to highlight the importance of incorporating Artificial Intelligence (AI) in the proposal.
It has been rightly stated that half of the amount of produced high-risk machines, which include AI applications, which are not covered by Annex VI, are already voluntarily being tested by third parties. Many SMEs use this opportunity for reputational reasons as well as due to their lack of expertise on the procedure of performing these services themselves. Therefore, the inclusion of third parties can be highly beneficial for manufacturers while paying an adequate and fair contribution, which is compared to the manufacturing costs comparatively low.
However, we would like to call for more clarification on this matter. We support the incentive to make AI applications incorporated in machinery products as safe as possible and by doing this through the conformity assessment of high-risk AI products by third parties. Nevertheless, we would like to point out, that the proposed text foresees no distinction between the size of the machinery and the potential risk that could stem from it. The different levels of safety risks should be considered here and defined more clearly.
In addition, the risk connected to the mobility of machinery products should be taken into consideration. Due to the fact that a machine, which is not mobile and with low impact of energy and force or used under specific conditions only (e.g. mechanized inspection in not accessible areas) poses a smaller risk to the consumers and workers than a mobile machine, that could for example interfere with traffic, needs to be addressed.
To provide more precise information to the industry on which machinery needs to be tested and certified by a third party, we believe that a clearer distinction should be included in the text. We believe that not all machinery that has an AI element provides the same risk factor than others and should be treated the same way when it comes to conformity assessment procedures.
Such a clarification could be included in the Machinery Guide, which will for detailed clarification and example accompany the Regulation, but preferably in the Regulation itself. However, for Notified Bodies and independent testing laboratories a planning horizon is key. To provide the necessary personnel and resources to prepare performance of services and extend the accreditation scope or reach out for accreditation of specialized labs, a notification of at least nine month in advance to the application of the new legislation is required.
Finally, we would like to draw your attention to the position paper of our association, the TIC Council, which brings together the most important discussion points of our industry on the new Regulation on machinery products. Please find the document attached.
Read full responseResponse to Requirements for Artificial Intelligence
8 Jul 2021
As an independent Testing, Inspection and Certification (TIC) company, we welcome the European Commission’s proposal for a Regulation laying down harmonized rules on Artificial Intelligence to ensure the safety and security of European consumers in the area of Artificial Intelligence.
Third-party conformity assessments conducted by independent TIC companies guarantee not only the impartial and thorough testing, inspection and certification of any product entering the European market, but also of AI systems. The assessments offer the providers’ expertise and ensure that products meet the requirements of the relevant applicable legislation and high consumer protection. Through this, a level playing field is being created on which ground innovation can flourish.
It is necessary to build a legislative framework suitable for the future and meeting, among others, highest standards in terms of consumer protection. Not including the highest standards as regards scrutiny and quality assurance of new products in the form of third-party assessments, due to the fear that notified bodies might not yet have the capacity to perform the conformity assessments of AI systems, seems counterproductive to the aforementioned goal. TIC companies have already shown their capacity to successfully innovate or adapt their services offering to the evolution of technology, as is currently the case in the area of cybersecurity.
In particular, with regards to stand-alone AI systems with risk of adverse impact on fundamental rights, which are explicitly listed in Annex III, we do believe that internal control checks by the industry (with the exception of remote biometric identification systems that would be subject to third-party conformity assessment) are not sufficient and might even be impractical for significant parts of the AI innovation ecosystem.
We are convinced, that there is a need to have qualified and independent resources to conduct conformity assessment on AI systems. This also includes providing the necessary infrastructure, such as tooling. Furthermore specialized experts need to be able to perform the required assessments with high certainty, very mature processes and organizational structures within the assessing organization to assure reliability and replicability of the assessments.
With this proposal, there will be no additional financial burden on small-scale providers, as the European Commission considered this and suggested offering adequate fees for small-scale providers when turning to notified bodies.
As also highlighted by Commission officials, many manufacturers/providers would turn to notified bodies even if they are not obliged to do so. This is for reputational reasons and due to their lack of expertise to perform conformity assessments of their own.
Finally, as mentioned in the White Paper on AI published by the European Commission last year, “the carrying out of conformity assessments could be entrusted to notified bodies designated by Member States. (..) Independent assessment will increase trust and ensures objectivity. It could also facilitate the work of relevant competent authorities. The EU enjoys excellent testing and assessment centres and should develop its capacity also in the area of AI”
We further support,
• the development of a risk-classification of AI systems
• mandatory conformity assessments according to the relevant sectoral legislation when the AI system is a safety and/or security component of a product
• new ex ante re-assessments of conformity in case of substantial modifications to the AI systems
• that Annex III will need to get constantly updated to take new technology developments into account
• the non-discriminatory access to data for the validation of high-risk systems also for notified bodies through European Common Data Spaces, to be able to perform our duties. We call on the Commission to also grant this access for lower-risk systems, to allow notified bodies to perform their services
Read full responseResponse to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)
21 Jun 2021
For DEKRA, an independent TIC company, safety, security, and sustainability are our vision and mission. In the field of vehicle inspection, DEKRA represents a leader, whose objective is to ensure that vehicles are safe during their whole life cycle. To guarantee that future automated vehicles (AVs) also perform safely, access to in-vehicle data will be necessary. Therefore, we welcome the EC’s initiative for the Data Act (DA).
AVs will operate without a driver as a backup if the technology fails. Thanks to connectivity, AVs will receive safety relevant updates constantly during their life cycle. As a result, the AVs’ safety-relevant functionality will change, based on software updates performed over-the-air. Insufficient maintenance, bad repairs, and lacking calibration of sensors will also have an impact on the performance of the AVs. To ensure that a vehicle with an updated software still performs safely, it is necessary to monitor it continuously and periodically, but for this, an actual status of hardware/software will need to be known to the inspection organisation. Such information is currently only available to the vehicle manufacturers (VM) who store the data on their data clouds, via ExVe (Extended Vehicle). Third parties can receive the data from the VM against a payment. This model does neither guarantee that the VM share all data they store, nor that the offered data was not modified. Yet, for institutions performing state-mandated tasks, including roadworthiness tests or investigating traffic offences, it is crucial to have access to the unfalsified and non-preselected data. Thus, they cannot work under this data access regime. As mentioned, it is welcome that the EC plans to address the difficulties of access to and use of data in the horizontal DA. Moreover, it is a positive development that the EC acknowledges that in the B2G data sharing, there is a lack of rules governing reliable data sharing functions and transparent production of information from privately held data. The impact assessment also states that the DA may be complemented by sector-specific initiatives, such as access to vehicle data. The latter is already in the works of DG GROW, whose proposal is supposed to address the B2B situation. Consequently, it is necessary to clarify, whether stakeholders, such as police, prosecution, or vehicle inspection companies will have to rely on the horizontal DA for access to vehicle data. Should this not be the case, the EC should clarify whether it plans to propose an additional sector-specific legislation on access to vehicle data for these stakeholders. The solution which we propose for access to vehicle data for inspection companies, prosecution, i.e., tasks carried out on behalf of the state, is introduction of an impartial and independent Trust Center (TC). The TC would be governed by a state authority in each country. The TC would not require any changes to the architecture of a vehicle or processes already introduced by the VM. In fact, it would not require an establishment of any additional data cloud, as it would function as a digital twin of an existing VM-data cloud. The only requirement for the establishment of the TC, is a “layer of legislation,” allowing to copy the digital infrastructure established by the VM, from a vehicle to the cloud, via a mobile network operator. The biggest advantage of the TC would be that it would allow authorised bodies to access the data in un-modified manner. Moreover, it would provide information on the whole life cycle of the vehicle, as it would contain the historical information from the vehicle. The TC model could also serve the needs of the automotive aftermarket (independent service providers). The bi-directional communication with the driver via Google Auto or Apple Car Play would enable most of their business cases by retrieving the necessary data directly out of the TC rather than waiting for an additional interface (secure onboard telematics platform).
Read full responseMeeting with Henrik Hololei (Director-General Mobility and Transport)
7 Jun 2021 · A solution for non-discriminatory and independent access to in-vehicle data
Response to New EU urban mobility framework
25 May 2021
DEKRA e.V. welcomes the initiative for the new urban mobility framework. Please find our feedback attached as a PDF.
Read full response4 Feb 2021
DEKRA welcomes the initiative of the European Commission to provide standardised access to vehicle on-board diagnostics information and repair and maintenance information, and the requirements and procedures for access to vehicle security information.
DEKRA is the world leader in vehicle inspections, with 27 million of vehicle inspections carried out per year.
Our comments pertain mainly to the new Appendix 3 and are the following:
2.1. Definitions
- Lacks the definition of an “IO” (Independent Operator) as well as “CAB” (Conformity Assessment Body)
Consequently, a question arises, which institutions are expected to fulfil the role of the CAB for garages and inspection companies. Inspection companies are already certified/accredited according to ISO standards by CABs (such as KBA or BASt in Germany, Cofrac in France, etc.) however, for garages, this needs to be further clarified.
Moreover, even though Appendix 3 contains a definition of the Trust centre, it must be further clarified which institution should fulfil this role.
3. Accreditation of CABs, approval of IOs and authorisation of IO employees
This section states that IO employees who are to handle security-related RMI shall obtain an authorisation inspection certificate from a CAB accredited by the NAB of the Member State where the IO employee resides.
Whereas this seems like a practical solution for workshops and garages with few employees, it is not workable for huge vehicle inspection (PTI) companies with a few thousand inspectors. In Europe, there are approximately 70,000 inspectors active in PTI. Should every single one of them be required to receive an authorisation, the management of these authorizations PTI becomes very time demanding and costly. This will have a negative impact on the final cost of the inspection paid by the customer. Therefore, only the PTI organisations should be required to get an authorization as an IO. The management of authorization by PTI companies could be then integrated in the scope of accreditation/certification. This means that the certification bodies would audit and assess this procedure.
This section also stipulates that vehicle manufactures may demand a fee for the registration of IO employees on RMI websites and for access to security-related RMI. Such fee shall be proportionate to the cost for such registration and provision of access. It must be defined in a transparent manner what constitutes a proportionate price. Otherwise, we risk that the increased price for access to the RMI information will be passed on the customers, who will eventually need to pay more for the service.
Furthermore, point 3 says that all digital data transfers between IOs, TCs and CABs shall be carried out via business to business (B2B) transactions using secure protocols and in a timely manner. The timely manner must be precisely defined. A delayed data transfer could cause a delay in PTI, and eventually a worsened service to the customer.
Lastly, rather than having every garage and every PTI company requesting data from each vehicle manufacturer, it should be considered to have an independent vendor collecting all the data and customizing them for PTI or RM purposes. Garage equipment suppliers already work with such tools.
4.3.4. Criteria for IO employee authorisation by the CAB
Rather than having CAB verifying whether an IO employee meets all the requirements for authorisation, CAB should only verify whether the IO (PTI organisation in this case) and the management of authorization by the PTI company, meet the requirements.
4.5.1. Responsibilities and requirements of IO employees
Instead of each employee requesting an authorisation from CAB, the authorisation for the IO should apply directly to all IO employees, after the CAB assesses the management of authorization by the PTI company.
Read full responseResponse to EU Strategic Framework on Health and Safety at Work [2021-2027]
26 Nov 2020
DEKRA strongly welcomes the aim of the European Commission to define a new strategic framework for workplace health and safety.
From the experience of DEKRA, there is no universal protection of employees from work-related hazards. Whilst some companies implement measures conform to and even exceeding the scope of respective regulations, others address the protection of their employees against work-related hazards insufficiently.
Fostered by regulations on product safety, technical safety of machinery and equipment is getting increasingly effective. Furthermore, health and safety management systems as well as well-established safety standards in the industry sector lead to increasing protection of EU citizens.
All national legislators throughout the EU have issued regulations that clearly oblige employers to identify and assess risks as well as to implement measures for health and safety at work. The necessary technical safety expertise, technologies and methods can also be viewed as available to employers and are of good quality in all EU Member States.
In recent years, many companies have successfully reduced the number of accidents and work-related illnesses by implementing appropriate safety measures. In addition to the implementation of risk assessments and the definition of measures, this also includes the provision of the necessary resources and the implementation by the respective managers / leadership and decision-makers. These companies obey to national and EU regulations proactively. The commitment of these companies is both recognisable and exemplary. They have been the drivers of reduced accident rates and work-related illnesses in recent years.
Yet, in other cases, employees are not protected proactively. From our experience, many of the work-related accidents and illnesses are not caused by technical failure, employers' lack of regulatory awareness or a lack of expertise on how to control exposure and reduce risks. Illnesses and accidents occur repeatedly since some employers or management personnel fail to implement the necessary measures adequately. In these cases, health and safety measures are implemented partially or superficially only. It seems to have been accepted or even encouraged that priorities and resources are allocated to other topics leading to at-risk situations and exposure for employees. Hence, in case of accidents and illnesses, there exists the risk to wrongly claim employees' behaviours as causes for incidents in order to avoid any liability or responsibility.
In conclusion, while requirements of occupational health and safety are of high-quality, we perceive a failure in their implementation and commitment in some cases. Thus, from our experience, their insufficient or even deliberately neglected implementation accounts for the figures on work-related accidents and illness in the EU.
From this, we deduce that a revised Strategic Framework on Health and Safety at Work should concentrate more on the effective implementation of established protective measures. Responsibility for occupational safety therefore needs to be extended to responsibility for organizational culture, decision-making, the implementation of measures related to health and safety as well as to their evaluation in terms of effectiveness.
Management and all executive and leadership levels must be committed more to the true effectiveness of their leadership and implementation of measures in relation to occupational health and safety. As the issue of commitment throughout all leadership levels has not been specifically addressed in the current legislation, this should be changed in the future.
Read full responseResponse to Sustainable corporate governance
8 Oct 2020
The DEKRA Group welcomes the aim of the European Commission for the Sustainable Corporate Governance initiative to further embed sustainability into the corporate governance framework.
Following the positive example and impact of legal framework for other important content areas that have been implemented successfully in the past, such as workplace health, occupational safety, or environmental protection, also sustainability is a fundamental matter for the society, environment, and organizations and therefore should be addressed equally. We recognize the task is substantial given the breadth of aspects covered by sustainability and the differing impacts between industrial sectors. Thus, DEKRA supports a framework, which avoids national patch-work legal framework or cross-border contradictions as well as allows businesses across the EU to define individual strategies on how to achieve the EU sustainable development goals.
The framework should therefore address general sustainability targets and main methodological requirements. Application of consistent assessment and verification methodologies, and a full life-cycle analysis with respect to products and services would support the overall aims. Having clear and industry-specific guidance based on best practice that an organization can use, would encourage a faster implementation of such strategies and hence quicker benefits from improved performance with respect to sustainability. Similarly, having clear metrics and reporting requirements (including verification) would underpin a requirement for continuous improvement. Yet, businesses should be provided with the necessary freedom and flexibility to choose and implement the individually best fitting measures. Especially with regards to the large majority of Small and Medium Size Enterprises in the EU, the legal framework must allow the integration or utilization of qualified third-party consultancy expert organizations. We also would recommend a role for independent third-party audit and assessment to ensure accuracy in reporting.
Read full responseMeeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean)
2 Oct 2020 · Meeting to discuss road safety.
Response to Revision of the NIS Directive
3 Aug 2020
ELEMENTS TO BE INCORPORATED IN A REVISED NIS DIRECTIVE
DEKRA recommends incorporating three major elements when revising the NIS Directive. Please find them outlined in the following:
1. UNIFICATION OF EVALUATION METHODOLOGIES, LIMITATION OF GRANULARITY
Under the flexibility of the current NIS Directive, each country has identified various operators of essential services (OES) by use of different criteria. A revised NIS Directive should therefore align the criteria for identifying the OES. This is especially important for companies operating in different countries, as diverging criteria could be applied to the same OES. Complementary actions in this regard could be the following:
• The Cooperation Group could provide clarifying documents on how to apply the revised NIS directive, similar to the clarification document provided by other working groups. Examples and cases could be used to help harmonizing criteria on the identification of OES. Annex II should be updated with a list of OES covered by the Directive.
• The identification of the OES should be carried out by an independent third party, which would apply the current and future criteria defined by the Cooperation Group. Consequently, divergences and delays currently existing in the identification of the OES due to each country’s self-assessment would be avoided.
• In the case of cross-border operators, the criteria on the identification of OES of the most restrictive country should apply.
2. A NEW VERSION OF THE LIST OF OES INCLUDED IN ANNEX II
According to the "Report assessing the consistency of the approaches in the identification of operators of essential services" and as outlined above, each state has identified different OES. A new list considering the lessons learnt so far is desirable. Possible options to undertake are the following:
• The Cooperation Group should update Annex II. Certain sectors and sub-sectors of the OES previously not included in Annex II should equally qualify as OES.
• The procedure of OES identification should periodically be reviewed by the Cooperation Group.
3. IMPROVEMENT OF THRESHOLDS/UNIFICATION OF CRITERIA
A unified list of qualitative and quantitative criteria to define the thresholds of identifying OES should be established. Quantitative criteria might, for instance, include the number of users depending on the service, the number of connected autonomous systems and the market share. To homogenize these figures, the numbers should refer to the number of users per 1,000,000 habitants to avoid divergences between countries of different size. Additionally, risk analyses of the critical infrastructures should be carried out to classify them according to their level of risk/criticality. This would be beneficial for the implementation of cyber-resilient measures at a later stage. Please find possible actions to pursue below:
• An existing methodology for risk assessment could be adopted by the Cooperation Group.
• Based on the chosen methodology, risk assessment might be carried out by an independent third party.
• Based on the risk assessment, working groups could be created per sector/group of sector within the Cooperation Group. They would define specific measures in cybersecurity furthering cross-country harmonization.
POLICY OPTIONS TO CONSIDER
Based on the reasoning above, DEKRA supports the third and fourth policy option indicated in the Combined Evaluation Roadmap/Inception Impact Assessment.
• OPTION 3. Since this option is to “introduce more harmonized elements in the process of identification of operators of essential services (OES)”, DEKRA appreciates it, as explained previously.
• OPTION 4. DEKRA supports this option due to its implementation of a “higher level of harmonization and consistency by means of more detailed and precise rules.” The fragmentation of the internal market would be reduced significantly. Introducing new policy measures to meet better the needs for increased cybersecurity is equally favourable.
Read full responseResponse to Modernising the EU’s batteries legislation
9 Jul 2020
One of DEKRA’s main activities is carrying out vehicle periodic technical inspections (PTI). From this perspective, it would be helpful to establish a battery-identification-system. Importantly, such an identification system should be transparent and accessible in a standardised way.
When assessing the condition of a used fully-battery-electric vehicle or a hybrid vehicle, it must be taken into consideration that different battery systems might behave differently when ageing. Moreover, there might even be different battery types in the same type of vehicles. Therefore, there should be a public datasheet with key figures (e.g. proposed lifetime - How long will I be able to use electric vehicle?; proposed end-of-life-behaviour – How will my electric vehicle behave at end-of-life? What will be its driving range?; proposed efficiency – for new and end-of-life vehicles; performance indicator like internal resistance – for new and end-of-life vehicles) available which would answer consumer expectations and improve consumer protection.
The public datasheet would be useful for identification of a battery during PTI and would enable the testing stations to define an “end-of-life” vehicle for PTI purposes. Moreover, an identification of batteries could:
- increase safety in emergency situations, e.g. for fire brigade personnel - some batteries might get more dangerous than others. This would be important for all battery accumulators (e.g. in stores or in vehicles).
- an identification option, including type and age, could increase the attractiveness of aged vehicles, in case of a refurbishment.
- an electronic verification of the labelling could help to increase safety and lifetime of vehicles in case the batteries could be exchanged. The labelling information should be provided by an independent organization.
Battery passports could also be an option how to realise the public datasheet. It would be a centrally saved battery information which could help the producer to estimate the battery-usage. The passport should, however, not be established by a battery producer due to conflict of interests. There should by a neutral organization providing this information. In addition, the battery passport could lead to simplification and reduction of administrative burden, especially for SMEs.
Lastly, labelling of second life usage batteries should be addressed, including a mandatory testing procedure, which shows the usability of cells for second life usage. Moreover, it should define the state when the cells need to be recycled (safety, efficiency, …).
Read full responseMeeting with Henrik Hololei (Director-General Mobility and Transport)
2 Jun 2020 · Trust Center Initiative
Response to A new Circular Economy Action Plan
17 Jan 2020
We welcome the initiative of publishing a roadmap for a circular economy action plan. However, we urge the European Commission to strive for a more ambitious attempt.
We would like to emphasize that many of the standards requested by M/543 will terminate in early 2020. Unfortunately, the roadmap doesn´t refer to the period after this point.
Furthermore, including a sustainable product policy in the circular economy action plan is crucial. However, in our opinion the details of the implementation are too vague.
In addition, so far no progress has been made on the staff working document published at the beginning of 2019. We would appreciate further developments in this area.
Read full responseMeeting with Julian Siegl (Cabinet of Commissioner Julian King)
14 May 2019 · cyber security
Meeting with Mariya Gabriel (Commissioner)
15 Oct 2018 · Cybersecurity
Meeting with Bodo Lehmann (Digital Economy)
11 Jul 2016 · connected cars
Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)
19 Feb 2016 · Type approval
Meeting with Michael Hager (Digital Economy)
10 Nov 2015 · DEKRA Arbeitsmarktreport 2015
Meeting with Eric Mamer (Digital Economy)
5 Nov 2015 · automotive/DSM
Meeting with Joao Aguiar Machado (Director-General Mobility and Transport)
24 Feb 2015 · Road Safety
Meeting with Jocelyn Fajardo (Cabinet of Commissioner Violeta Bulc)
24 Feb 2015 · Future of the CPC Directive (2003/59), on the Road Safety Strategy of the Commission and its future mid-term review, and on the implementation of the roadworthiness package.