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Fédération Internationale de l'Automobile

FIA

The Fédération Internationale de l'Automobile represents the interests of motorists and motor sport worldwide.

Lobbying Activity

Response to Delegated Regulation on effective and secure access to On-Board Diagnostic and Repair and Maintenance Information

2 Dec 2025

FIA accepts adoption of the proposal, but we identified some issues that need to be addressed: 1. Authentication & Authorization complexity Security protocols for accessing in-vehicle data are increasingly complex, especially for time-critical roadside assistance. While authentication options and 24h validity are positive, the need for flawless connectivity for authorization from the vehicle manufacturer (VM) can delay emergency interventions, risking safety for road patrols and vehicle occupants. Security requirements shall be risk-appropriate and technology-neutral. Procedures for certified roadside and rescue services must be further simplified, allowing fast diagnosis and repairs even without continuous internet. Vehicles should autonomously verify access eligibility, not rely solely on manufacturer servers. FIA demands lower access thresholds for routine repairs and clarify authorization levels with a table for easier interpretation. 2. Alternatives to mandatory Vehicle Identification Number collection VIN collection is required for digital access authorization, but permanent connectivity for VIN transmission is not always possible (e.g., tunnels or remote areas). VMs should provide solutions like pre-authorization via diagnostic tools, already used by some VMs, making different options mandatory for all VMs to authenticate a vehicle or owner/driver for independent operators. 3. Implementation for the legacy fleet Different deadlines and solutions for recall of legacy vehicles based on historic approval dates create a patchwork of requirements, increasing costs and restricting competition. Uniform, binding implementation for all newly registered vehicles as of 2020 is needed to avoid fragmented regulations and recalls. 4. Server Availability VMs must provide non-discriminatory server access for OBD, offline data, and Repair and Maintenance Information. However, there is no obligation for VMs to ensure server availability if they go bankrupt or leave the market, risking loss of critical vehicle functions from otherwise roadworthy vehicles. VMs should guarantee server availability for a period after production ends, ensuring consumers receive security updates until the end-of-vehicle-life phase. 5. Integration of legal Re-use or Remanufactured salvage parts The proposal links to the proposal to revise the End-of-Life Directive, aiming to prevent stolen parts but imposing complex requirements on waste operators. Salvage parts from brain-dead donor vehicles (unable to connect to the internet) may become unusable due to new connectivity requirements. Security checks should occur when salvage parts are installed, not removed, to prevent parts theft while keeping the process simple and affordable. This avoids dependency on continuous internet during removal, keeps costs low, and supports the circular economy by making re-use parts viable. affordable and sustainable. In summary - Design security protocols that balance cybersecurity with practical access to in-vehicle data and functions, especially for roadside assistance, rescue services and allowing swift preliminary, emergency diagnosis and repairs. - Lower authorization thresholds for routine repairs and maintenances and reduce online dependency. - Provide technical solutions for VIN collection without mandatory online connectivity. - Incorporate functionality in the car to allow local authentication and authorisation, also in case there is no internet connectivity available or of substandard quality. - Implement uniform requirements for all vehicles to avoid a patchwork of rules. - Simple integration of legal re-use and remanufactured replacement parts or equipment that remain affordable for consumers, maintain resilience against internet connectivity problems, waste treatment operators remaining independent from the judgement of VMs whether or not a salvage part may become a candidate re-use part and preparing the grounds for a circular economy that allows free choice.
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Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and Transport and Environment (European Federation for Transport and Environment) and

21 Oct 2025 · Meeting on small affordable cars initiative and possible Made in Europe requirements

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and Transport and Environment (European Federation for Transport and Environment) and

20 Oct 2025 · Meeting on small affordable cars initiative and possible Made in Europe requirements

Automobile federation warns 90% emissions target risks consumer affordability

16 Sept 2025
Topic — EU proposal to set 2040 climate target of 90% emissions reduction.
Message — The organization requests technological neutrality, allowing combustion engines, sustainable fuels, and hybrids alongside electric vehicles. They emphasize infrastructure investment must precede enforcement and call for incentives over penalties to shift consumer behavior.1234
Why — This would protect their members from forced adoption of expensive electric vehicles.56
Impact — Climate advocates lose faster emissions reductions from delaying electrification transition.78
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Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and European Transport Safety Council

4 Sept 2025 · Approval of Driver Control Assistance Systems (DCAS)

FIA urges flexible and realistic corporate fleet electrification rules

2 Sept 2025
Topic — European Commission consultation on setting zero-emission requirements for corporate vehicle fleet registrations.
Message — The FIA advocates for a technology-neutral framework including plug-in hybrids and sustainable fuels. They emphasize that requirements must be realistic and reflect market conditions and infrastructure readiness. They also demand reliable battery health data to support the second-hand vehicle market.123
Why — Flexible rules prevent financial losses for operators from vehicle depreciation and high compliance costs.45
Impact — Environmental groups lose because extending combustion engine use slows the transport sector's decarbonization.67
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Meeting with Edoardo Turano (Head of Unit Climate Action)

11 Jun 2025 · CO2 fleet targets

FIA urges consumer opt-out rights for vehicle emission data

13 May 2025
Topic — New EU rules for monitoring vehicle emissions and reporting environmental performance data.
Message — FIA advocates for a consumer's right to opt-out of on-board monitoring transmissions. They want drivers to control data flows and include a review clause.12
Why — Consumers gain privacy and the ability to share data with independent repairers.3
Impact — Regulatory authorities lose access to emission data if consumers choose to block transmissions.4
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FIA urges independent laboratory access to vehicle emissions data

13 May 2025
Topic — This consultation concerns emission testing methods and type-approval requirements for light-duty vehicles.
Message — The FIA requests that recognized third-party laboratories receive unrestricted access to essential vehicle data and testing procedures. They advocate for a secure, central data repository providing timely information like coast-down modes without manufacturer interference.12
Why — Access to type-approval databases would help independent labs manage expensive and burdensome testing costs.34
Impact — Vehicle manufacturers lose control over data access and the ability to interfere with manipulation reports.5
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Meeting with Clint Tanti (Cabinet of Commissioner Glenn Micallef)

2 Apr 2025 · Introductory meeting + discussion on FIA's activities including an overview of their structure and work, focusing on past EU funded projects. Minutes attached

Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and FIGIEFA - Fédération Internationale des Grossistes, Importateurs & Exportateurs en Fournitures Automobiles / International Federation of Automotive Distributors and

11 Feb 2025 · Action plan for the automotive sector

Meeting with Piotr Müller (Member of the European Parliament, Shadow rapporteur)

4 Feb 2025 · Circularity requirements for vehicle design and management of end-of-life vehicles

Meeting with Silvia Bartolini (Cabinet of Executive Vice-President Henna Virkkunen), Xavier Coget (Cabinet of Executive Vice-President Henna Virkkunen) and

14 Jan 2025 · The role of the automotive aftermarket in the EU Industrial Action Plan for the automotive sector

Meeting with Helena Hinto (Cabinet of Commissioner Apostolos Tzitzikostas) and Insurance Europe and

10 Jan 2025 · Introductory meeting

Response to Evaluation of the Motor Vehicle Block Exemption Regulation

11 Jun 2024

With approximately 360 million passenger and light commercial vehicles owned by consumers and businesses, the European aftermarket generates annual revenues exceeding 280 billion. The Motor-Vehicles Block Exemption Regulation (MVBER) plays a crucial role in maintaining competitive conditions within the motor-vehicle sector, ensuring consumers have access to a broad range of services and repair choices. European motorists rely on diverse vehicle aftersales services and need the legal certainty that their freedom of choice is preserved. A consumer market survey (1) conducted in 2023 across 11 EU countries revealed that a significant portion of European citizens still prefer independent workshops for their vehicle maintenance, primarily driven by price sensitivity. The FIA European Bureau (FIA EB) urges the European Commission to consider the findings of our latest study on the automotive digital transformation and the economic impacts of limited data access (in attachement). As the industry shifts from hardware to software, vehicle manufacturers are moving away from the traditional on-board diagnostics (OBD2) interface the most common way for independent, direct, real-time, and free access to in-vehicle data. Instead, they are adopting data-based business models, which significantly impact independent service providers and consumers. Our study identifies five common use cases (e.g., vehicle repair) where consumers and independent service providers would need to absorb 95 billion in extra costs due to the absence of a proper framework regulating access to vehicle data, functions, and resources. This is a potential loss that the European economy cannot afford if it aims to stay competitive in the global digitalisation race while guaranteeing competition and innovation. The FIA EB believes that ensuring fair and equal access to vehicle data is paramount for consumers to benefit from new and better digital services, such as improved repair and maintenance. About us: The FIA European Bureau, based in Brussels, is a consumer body comprised of 66 Mobility Clubs representing over 40 million members across Europe. The FIA represents the interests of our members as motorists, riders, pedestrians, and passengers. (1) Survey link: https://www.fiaregion1.com/wp-content/uploads/2023/09/FIA-Region-I-Drivers-Preferences-Survey-FINAL.pdf
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Insurance Europe and

4 Jun 2024 · Discussion on preparation of delegated act on conditions to access data for repair and maintenance activities

Response to Car labelling evaluation

22 Mar 2024

The Fédération Internationale de lAutomobile European Bureau (FIA EB) welcomes the evaluation of the Car Labelling Directive. We would like to share a recent study assessing the clarity, consistency, and transparency of information provided to consumers regarding electric vehicles and chargepoint usage.The findings indicate notable inconsistencies in consumer information across both sectors, highlighting the need for improvements.
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FIA European Bureau urges simplified travel rules and insolvency protection

13 Mar 2024
Topic — The European Commission is reviewing rules to strengthen consumer protection for package travellers.
Message — The organization recommends simplifying travel definitions and limiting advance payments to protect consumers. They urge extending bankruptcy protection to single tickets and providing environmental impact details.12
Why — These changes would reduce financial uncertainty and complexity for their motorist membership.3
Impact — Airlines and service providers would lose access to upfront cash from operators.4
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FIA European Bureau urges stronger protection for single-ticket travellers

13 Mar 2024
Topic — The Commission is reviewing passenger rights to ensure resilience against travel disruptions and carrier insolvency.
Message — The FIA EB calls for harmonized protections between package and single-ticket travellers, especially regarding airline insolvency. They also request standardized environmental impact information and effective limits on travel downpayments.12
Why — This ensures members of motoring clubs are financially protected and reimbursed during airline bankruptcies.34
Impact — Airlines and tour operators would face increased financial pressure from stricter limits on advance payments.5
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Meeting with Daniel Mes (Cabinet of Commissioner Wopke Hoekstra) and Forum for Mobility Society

20 Feb 2024 · Speaker at event Forum for Mobility and Society - 2040 climate target

Meeting with Margaritis Schinas (Vice-President) and

23 Nov 2023 · Cooperation on innovation and ethics in sports - Tackling online hate speech and illegal content - Piracy of sports events

Meeting with René Repasi (Member of the European Parliament, Rapporteur)

6 Oct 2023 · Exchange of Views on the Right to Repair/ Recht auf Reparatur (R2R)

Meeting with Dominique Riquet (Member of the European Parliament, Shadow rapporteur)

5 Jun 2023 · Permis de conduire

Meeting with Karima Delli (Member of the European Parliament, Rapporteur)

3 May 2023 · Driving Licence Directive

FIA calls for realistic air standards and longer review periods

14 Mar 2023
Topic — The European Commission is revising air quality legislation to match WHO health recommendations.
Message — The FIA requests longer review periods for legal certainty and objects to the term zero pollution objective. They argue that monitoring should focus on representative health burdens rather than isolated hotspots. Additionally, they believe current vehicle emission standards are already sufficient to reach target reductions.123
Why — This would reduce regulatory pressure on the transport sector and provide long-term planning stability.45
Impact — Public health groups lose more frequent updates to air safety standards and stricter pollution targets.67
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Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

15 Feb 2023 · In-vehicle data

Response to Development of Euro 7 emission standards for cars, vans, lorries and buses

9 Feb 2023

The FIA European Bureau welcomes the EURO 7 proposal and favours its swift adoption; however, some aspects deserve further attention: We remind the legislators that mobility must remain affordable and accessible for all. The measures proposed seem fine but cost passed on to consumers must not increase after adoption of delegated acts containing detailed requirements. Affordability remains of paramount importance. Fast adoption of the proposal and early application is important since this is most cost-effective and efficient to clean the fleet further. We support technology neutrality, making pollutant limits equally low for all fuels. Compliance up to 240,000 km and 16 years for all powertrain types should be required, as well as a minimum of 70 % residual capacity for propulsion batteries. This would better reflect the usual lifecycle of vehicles across Europe ensuring the environmental performance of second- and third-hand cars. Propulsion battery state-of-health should be continuously made available to consumers. It is important to go beyond the driving and environmental boundary conditions laid down in Euro 6 legislation, in order to also test less frequent but high impact driving leading to high pollutant emissions and fuel/energy consumption. However, the Commission should ensure that unrealistic and extreme driving patterns will invalidate the test results. Those results shall not be considered, to avoid over-engineering and passing on excessive cost to consumers. Guidance can be provided by the boundary conditions tested in the Green NCAP program, which are challenging, realistic, and cost effective The proposal recognizes the importance of connected vehicles for regulatory use-cases like OBFCM, OBD, OBM, geofencing and, partly, ePTI; the FIA EB insists that all these legal use cases require direct-access to in-vehicle data by authorized, independent service providers, while ensuring a state-of-the-art level of security, since they are not mutually exclusive. Automotive sector specific legislation on access to in-vehicle data, functions, and resources, should mandate a fully-fledged Secure On-board Telematics Platform (S-OTP), allowing authorised parties to get remote, direct access to environmental performance control systems on-board of the car, helping consumers keep their cars on the roads, and securing them over the cars lifetime. Euro 7 legislation should be coherent with revision of the roadworthiness package and introduce NOx quotient functionality (see report attached). FIA recommends to further strengthen security of the odometer systems, by introducing a harmonised test procedure. Vehicles should continue being tested in both laboratory (WLTP) - to achieve best possible repeatability - and on the roads (RDE) - to confirm laboratory results and ensure truly low real-world emissions. The proposal does not specify whether all laboratory emissions constituents are also part of RDE testing; this should be clarified. We suggest including the Green NCAP driving range and battery capacity test procedure so that also the impact of cold ambient temperature is considered. Moreover, the introduction of mandatory OBM systems (e.g., NOx or O sensors) is a step forward to assess the environmental performance of a vehicle accurately over its entire lifetime. However, concrete specifications of the OBM requirements (implementation provisions, tolerances/limitations, which pollutants are in the scope, etc) are missing, making it difficult to assess their feasibility and effectiveness. Consumers shall be in full control of the OBM and geofencing data transmitted over the air. Hence, their consent shall be a must, and drivers must be allowed to switch on or off any data flows to and from the vehicle at any moment. FIA and Clubs support the introduction of new test requirements and performance criteria on tyres and brake systems, assessing Particle Mass (PM) and Particle Number (PN) emissions.
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Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean) and FIGIEFA - Fédération Internationale des Grossistes, Importateurs & Exportateurs en Fournitures Automobiles / International Federation of Automotive Distributors and

16 Jan 2023 · Data Act Regulation and Specific legislation on ‘Access to in-vehicle data & functions’

Meeting with Frans Timmermans (Executive Vice-President)

22 Jun 2022 · clean energy transition, the inexorable move towards e-vehicles, and the importance of the car industry to contribute

Meeting with Thierry Breton (Commissioner) and

16 Jun 2022 · Data Act ; in-vehicle data

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Insurance Europe and

10 Jun 2022 · Prep meeting for meeting with Commissioner Breton on 16/6

Response to Revision of the Intelligent Transport Systems Directive

15 Mar 2022

The FIA European Bureau (EB) welcomes the Commission’s proposal for a revised ITS Directive; below some aspects that deserve further attention: ITS for better planning – Today, drivers increasingly rely on digital information to plan their journeys and to receive (real-time) information during their trips. The FIA EB strongly welcomes mandating further datasets to be made available in a digital machine-readable format and covering a wider area, especially regarding vehicle access restrictions. However, further focus should be given to other road users (e.g., electric bicycles) to enable them to embrace ITS and make traffic safer and smoother. An additional definition of “black spot” (location where accidents are frequent), along with a reference to the type of hazard causing it, is needed to make data related to those places available. Further standardisation needs – The potential of co-operative systems lies in the ability to enable as many vehicles, road users, and infrastructure elements as possible to exchange information in real time. To guarantee an effective implementation of the ITS Directive, a single communication technology and the use of a common language must be mandated. The requirement to ensure the accessibility of data on the NAPs is a step forward; however, the data should also be provided through a central point of access in the Single Digital Gateway Regulation. Furthermore, data standards should not be defined by data specialists only, but be subject to a broader consultation, to ensure that it meets the requirements, and hence its usage is not delayed. Lastly, the Directive should further investigate a standardisation with other regions, to make systems inter-operable while decreasing production and implementation costs. Information and awareness raising – The proposal misses the chance to better inform citizens and stakeholders of the benefits of the deployment of ITS technologies in terms of time saving, improved safety, and increased comfort. The proposal should go along with information and awareness raising campaigns, using additional EU programmes funding opportunities. Support Mobility as a Service (MaaS)- MaaS simplifies users’ trips by enabling them to purchase, through one application, tickets from different transport modes and operators. In that vein, the requirements obliging competent public authorities to make multimodal traffic and travel data available, as well as facilitate their electronic exchange with ITS providers, will foster integrated planning and boost the deployment of ITS. However, MaaS operators should have access to public authorities’ data regarding ticketing, timetables, and existing services, and be authorized to resell those services directly to end-users. The upcoming MDMS initiative should tackle those issues. Data protection and security – Consumers will only embrace vehicle connectivity fully if they remain in control of their data and can decide to share this data with the providers of their choice – in line with the principles set out in the Data Act proposal. Encouraging the use of anonymized data is a step ahead; similarly, cybersecurity is crucial to protect the vehicle’s systems and components integrity, as well as personal data, against theft or manipulation. EU legislation should include security-by-design principles and mandate OEMs to ensure state-of-the-art security over the vehicle’s lifetime (cradle to grave). Direct access to in-vehicle data, functions, and resources for ISP, and the highest level of security, are not mutually exclusive, as the FIA study on Secure Onboard Telematics Platform (S-OTP) shows. We call upon the Commission to mandate the S-OTP, in conjunction with the Separation of Duties principle, to avoid perpetuating OEMs’ data gatekeeper role, and guarantee true consumer choice and effective competition.
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FIA urges well-to-wheel emissions approach over combustion engine ban

8 Nov 2021
Topic — EU proposal to strengthen CO2 emission standards for new cars and vans.
Message — The organization requests replacing tailpipe emissions calculations with well-to-wheel analysis by 2030, and opposes the 2035 ban on internal combustion engines. They advocate for technology-neutral policies that keep mobility accessible and affordable while achieving climate goals.123
Why — This would allow continued sales of combustion engine vehicles using alternative fuels beyond 2035.45
Impact — Climate action loses urgency as delaying the combustion engine phase-out slows emission reductions.67
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Automobile Federation calls for tax cuts to offset climate costs

8 Nov 2021
Topic — EU Social Climate Fund to support citizens affected by transport decarbonisation policies.
Message — The organization requests tax reform to progressively lower fuel, vehicle registration and circulation taxes. They want revenues from new energy taxes and emission allowances used to offset increased costs for motorists.12
Why — This would help maintain financial neutrality for transport users despite rising fuel prices.34
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FIA advocates including road transport in EU emissions trading

8 Nov 2021
Topic — Revising national greenhouse gas reduction targets to meet 2030 climate goals.
Message — The FIA recommends moving road transport into the EU emissions trading system. They also call for lower fuel taxes to keep the reform financially neutral.12
Why — This shift would reduce the high cost of cutting emissions for drivers.3
Impact — Other industries and low-income households would face greater pressure or higher costs.45
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FIA Urges Carbon-Based Fuel Taxes and Consumer Price Protection

8 Nov 2021
Topic — The European Commission is updating energy taxation rules to meet climate goals.
Message — The FIA advocates for taxation based on carbon content rather than energy volume. They request longer transition periods for road transport to keep costs neutral. They also suggest lowering existing fuel taxes if emissions trading is introduced.123
Why — Drivers would avoid sharp price increases and maintain affordable mobility options.45
Impact — National governments would lose revenue if fuel taxes are progressively lowered.6
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FIA urges removing road transport from EU energy efficiency rules

8 Nov 2021
Topic — The European Commission is reviewing energy efficiency rules to meet higher climate targets.
Message — The FIA requests removing road transport from this directive to avoid regulatory overlap with carbon trading. They also advocate for harmonized car labels that include realistic running costs for both new and used vehicles.12
Why — This change would eliminate overlapping regulations and reduce legal complexity for the automotive sector.3
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FIA calls for ambitious fuel targets and open battery data

8 Nov 2021
Topic — The European Commission is revising renewable energy rules to meet 2030 climate goals.
Message — The FIA pushes for higher greenhouse gas reduction targets and increased biofuel sub-targets. They request that vehicle manufacturers provide owners and third parties with free, real-time battery data. They also suggest funding charging infrastructure using revenue from energy taxes.1234
Why — This would lower costs for motorists while giving them control over their vehicle's technical information.567
Impact — Vehicle manufacturers lose proprietary control over battery data, and palm oil producers lose market access.8910
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FIA demands transparent charging prices and rural infrastructure expansion

8 Nov 2021
Topic — Revision of EU rules for expanding electric vehicle recharging and alternative fuel infrastructure.
Message — The FIA demands that charging tariffs be based on electricity consumed rather than time spent. They also insist on payment card availability and better charging coverage in rural regions.123
Why — This would ensure drivers face predictable costs and enjoy consistent accessibility across the EU.4
Impact — Charging operators using time-based billing would lose revenue from inefficient charging sessions.5
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FIA urges EU to cut fuel taxes for transport ETS

8 Nov 2021
Topic — The EU is reviewing its emissions trading system to reach climate goals.
Message — The FIA opposes a standalone carbon market for transport. They advocate for its inclusion in the existing system. They demand lower fuel taxes to prevent high costs for drivers.12
Why — This would lower the financial burden on motorists by equalizing carbon prices across different sectors.34
Impact — Other industrial sectors in the current ETS would face increased pressure to reduce emissions.5
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Response to Revision of the Roadworthiness Package

1 Nov 2021

Founded in 1904, the Fédération Internationale de l’Automobile (FIA) brings together leading national motoring organisations from 146 countries worldwide and is the governing body for world motor sport. The FIA Region I office, based in Brussels, is a consumer body comprising 103 Mobility Clubs that represent over 36 million members from across Europe, the Middle East and Africa. The FIA Region I aims for 5-star drivers in 5-star cars on 5-star roads. FIA welcomes the inception Impact Assessment report drafted by the Commission, the underlying principles, and objectives listed. In particular, the three pillars that were identified: 1) Safety; 2) Green and sustainable mobility requiring environmental performance monitoring and 3) Data handling and Security, ensuring lifetime compliance of vehicles for the three pillars, are all of paramount importance to FIA Mobility Clubs and their members. For detailed feedback of FIA Region I and Mobility Clubs affiliated, please see the attached file 'Have_your_say_Roadworthiness_Package_FIA_Region_I_v3'
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Meeting with Thierry Breton (Commissioner) and

27 Oct 2021 · Data

Response to Package travel – review of EU rules

15 Sept 2021

The FIA European Bureau welcomes the review of the PTD, with a view to increase the level of consumer protection, especially under extraordinary circumstances. These are the aspects that, in our opinion, deserve being reviewed: Raising awareness of travelers’ rights The 2020 Eurobarometer showed that only 32% of respondents are aware of passenger rights in the EU. To be able to exercise them, travelers must be informed about their rights ahead, during, and after their trip. Raising awareness of passengers’ rights should be a priority. FIA members receive massive numbers of complaints because organisers and retailers cannot be reached, correspondence on current questions is impossible, and no sufficient information is provided on their websites. Before the conclusion of the contract, consumers must receive information both on the package travel organizers and their rights. Violations of the pre-contractual information obligations should result in direct consequences for travel providers (e.g., monetary). Distinction of the different instruments It is essential to guarantee consumers’ rights. It is therefore necessary that the definitions in the PTD are understandable. As highlighted in the IIA, the concept of LTA raises uncertainties, and it is often unclear what ‘facilitation’ of the booking means. In some cases, the distinction of package and LTA is difficult to assess and even arbitrary. There should be a clarification of the concepts of package travel, LTA, and flight/accommodation only, as well as better enforcement of the duty to hand the corresponding form, to preserve consumers’ rights. Improving insolvency mechanisms Consumers must have the right, at any time and without costs, to cancel the agreement in case of insolvency or imminent insolvency of the tour operator. The FIA supports measures that increase travelers’ certainty in case of the operator’s insolvency, such as the suggested creation of an EU insolvency back-up fund and a limitation of pre-payments to be made by package travelers. Travel cancellations Although, under the PTD, travellers can terminate the package travel contracts without penalty if unavoidable and extraordinary circumstances are met and significantly affect the performance of the package, COVID-19 showed that the Directive is not crisis-proof. The Directive should clearly state that the traveller can cancel the package without any costs whenever the services cannot be delivered as booked. Also, advance payments of the travel price should only be requested if the tour operator can also ensure that the package travel will be carried out. These rights should not exclusively be linked to a concrete travel advice of national authorities, but to the circumstances in the origin and destination countries. COVID-19 Vouchers The IIA rightfully states that COVID-19 resulted in travellers not having received refunds after a cancellation. Under special circumstances, vouchers may be acceptable, provided that they are offered on a voluntary basis, secured at least against insolvency, and with reasonable validity (for at least 12 months). If by its validity date the voucher has not been fully used, the tour operators/agencies must reimburse the remaining amount to the consumer immediately. Setting rules on voluntary vouchers or on refunds is a positive measure provided that these rules are clearly defined in PTD. Alignment with other rules The FIA insists that problems concerning the insolvency of carriers in the context of ‘ticket only’ travels persist. We would like to see further and firmer action to ensure travelers’ protection, irrespective of the existence of a package or not.
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Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

21 Jun 2021

The FIA European Bureau welcomes the Commission’s plans to address the systemic challenges of data access and use, as well as enhance citizens control over their data by means of a Data Act. Data-driven mobility The IIA recognizes the essential role of data in the digital economy. With the advent of the ‘connected car’, mobility is increasingly becoming software driven. Thus, data availability and access conditions determine the possibility for SMEs to provide high quality and innovative services to consumers. Robust regulatory data-sharing framework The IIA rightfully notes that ‘a data holder with a stronger negotiating power may unilaterally impose unfair terms and conditions to the detriment of a company seeking data access’. Independent Service Providers (ISP) in the mobility sector lack a clear legal framework to access in-vehicle data. The model that Vehicle Manufacturers (VM) propose for third parties to access in-vehicle data (the Extended Vehicle), impedes ISPs’ ability to offer competitive services. Likewise, it gives VM full control over the data flows and the ability to decide for who, when, and how access is granted to the vehicle’s data and functions. A research commissioned by FIA found that the Extended Vehicle model could lead, by 2030, to additional costs of around €65 billion per year for consumers and ISPs. The FIA stresses the need for a robust regulatory regime covering access to data, which ensures: • A technological neutral approach to accessing in-vehicle data. • Fair competition in the aftermarket. • Full respect for the digital and privacy rights of consumers. We urge the Commission to be bold and take the only path leading to a fair, direct, and undistorted access to in-vehicle data, in line with the objectives of the data strategy. Therefore, mandating by law a Secure On-board Telematics Platform (S-OTP), based on the “separation of duties” principle is a viable solution. The S-OTP is the ultimate example of a thorough quest for a solid solution guaranteeing true consumer choice, effective competition, and free entrepreneurship, in a secure and technology-neutral manner. Driver in the pilot seat of data traffic The FIA supports the policy option ‘Contribute to portability of data generated by individuals’. Europeans must be entirely free to choose with whom to share vehicle data and functions in the future, unless otherwise mandated by law. Without a viable technical solution (such as S-OTP) mandated by law, true data portability is not possible. European consumers are ready to embrace connectivity, but not at the expense of data privacy or their freedom to choose among service providers. The FIA MyCarMyData research (https://mycarmydata.eu/) revealed that 95% of European motorists support the need for binding legislation to ensure choice and protection of vehicle generated data. Clearly differentiation personal and non-personal data The FIA stresses that all vehicle-data is personal data, unless anonymized. Consumer’s free, specific, and informed consent needs to be obtained for vehicle data to be processed and shared. Similarly, in accordance with the GDPR, consumers shall have the ability to easily withdraw consent. The IIA contains potential policy options concerning personal and non-personal data. The upcoming Data Act should clearly indicate and differentiate what provisions apply to non-personal and what to personal data. We encourage the Commission to ensure that the level of data protection enshrined in the Data Act is in no way lower than what is recommended in the EDPB Guidelines 1/2020 on processing personal data in the context of connected vehicles and mobility related application/s. Sectoral legislation The FIA also welcomes the approach to leave room to consider specificities in sectoral legislation, making sure that provisions are applied consistently, and bottle necks avoided.
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Response to New EU urban mobility framework

21 May 2021

The FIA European Bureau is monitoring legislation impacting urban mobility at European level, noting the urban mobility falls outside the competence of the European Union. While a broad cluster of issues can be identified as challenges, each city should be free to address these issues according to local circumstances. The FIA European Bureau believes that there is no silver bullet to address urban mobility challenges. Measures should be tailored to local mobility needs and urban constraints. The FIA European Bureau therefore welcomes the approach of the European Commission to support cities in finding their own solutions, while fully respecting their local competence. The FIA European Bureau believes that the measures of the Urban Mobility Package contained under the four pillars have been relevant given recent developments in urban mobility. The FIA European Bureau suggests adding transport system integration and access to mobility data and transport ticketing to the initiatives taken. The FIA European Bureau stresses the importance of the following policy areas, where the European Commission can bring its support to cities. Lack of transport system integration The FIA European Bureau strongly supports the complementarity of transport modes in cities. Efficient urban planning and infrastructure adaptation support the use of those transport modes that are most adapted to local circumstances. By using adequate traffic information data and consistent multi-modal travel planners, citizens can be prompted to better assess each mode of transport and, ultimately, make the right choice for their mobility needs. Intelligent Transport Systems offer a wealth of opportunities to improve traffic in cities without the detrimental effect of access restrictions. The deployment of these technologies helps to realise their potential to make urban mobility safer, more affordable, more efficient and more sustainable for all. Lack of information to citizens In order to optimise the use of the most appropriate mobility options, users should get all necessary information allowing them to assess the available alternatives in terms of costs, time saving, road safety and comfort. A transparent and competitive market should be developed, based on the following principles: - Data protection: consumers should own all data they generate, get clear information about the data gathered and its potential use and be free to share it with service providers of their choice. - Consumers’ free choice: consumers should have the right to choose from a variety of services and functionalities. - Fair competition: consumers’ right to choose should be safeguarded by allowing simultaneous, non-discriminatory access to travel and traffic data and functionalities to the services providers of choice. - Open public data: all public operators should provide real traffic and travel data and ensure interoperability by using open standards, so that third parties can develop integrated mobility services. With regards to urban vehicle access restrictions, all European users should have access to sufficient, clear and good quality information on to ensure compliance. This information should be made available in multiple formats and languages to ensure that citizens are clear on when and where they can drive. Policy position on urban mobility https://www.fiaregion1.com/policy-position-on-the-urban-mobility/ Policy position on urban vehicle access restrictions https://www.fiaregion1.com/policy-position-on-the-urban-vehicle-access-restrictions/ Policy position on the internalisation of external costs https://www.fiaregion1.com/policy-position-on-the-internalisation-of-external-costs/ A better deal for motorists – survey of road taxation vs. Expenditure https://www.fiaregion1.com/a-better-deal-for-motorists/ Policy position on road pricing https://www.fiaregion1.com/new-policy-position-on-road-pricing/
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Response to Revision of the Directive on Driving Licences

17 May 2021

FIA Region I welcomes the opportunity to provide input on the Inception Impact assessment of the Revision on the Driving Licence Directive. Improved training FIA Region I supports the Commission intention to establish rules on training and to extend the existing graduated access scheme to other vehicle categories. In fact, novice drivers are overrepresented in traffic accidents, many of these crashes are caused by the lack of higher-order skills. A multi-phase schemes, whereby novice drivers must undergo mandatory retraining after having obtained their driver’s licence, to validate it, could significantly support the objective of reducing road accidents. This second phase of training could include more complex driving skills, such as traffic insight and hazard perception. Similarly, further focus should be given to strengthening formal driver training, by requiring mandatory standards for examinations and including minimum training delivered by professional instructors. Crucial factors for safe driving such as training in different traffic and weather conditions should be learnt and confronted. New technologies The IIA notes the importance of supporting lifelong training with new technologies. However, further attention should be given to the new technologies fitted in the vehicles as well as alternative powertrains. This concerns training requirements but also awareness raising. As certain ADAS will be mandatorily installed in vehicles from 2022, it is crucial that drivers understand the capabilities, limitations, and functioning of the systems. The safe and adequate use of these systems needs to be learned during the driver training and, if possible, tested, to decrease the gap between training and real-world driving. Since the number of alternatively fueled vehicles (AFV) is rapidly growing, driver training and tests should include knowledge of the functioning and charging of the different powertrains as well as the safety aspects specific to these vehicles. As a measure to promote the uptake of AFV, the driving licence should be valid both for manual and automatic transmission, regardless of the transmission in which the novice drivers have been trained. Digital Licence Enabling the recognition of digital driving licences among Member States is considered in the IIA. It is essential that this recognition is done in an inclusive manner. Therefore, digital formats should be recognised in addition to the recognition of physical cards. On top of that, the implementation shall include the necessary data protection safeguards and ensure that drivers do not find any hurdles when validating or checking the status of their licences. Diving disqualifications FIA Region I regrets the possibility to establish rules for the application and mutual recognition of driving disqualifications. The existing differences in national legal and enforcement mechanisms make the transposition of penalties extremely difficult for Member States. Following the subsidiarity principle, it should be Member States’ competence to legislate on driving disqualifications. Fitness to drive FIA Region I does not see any substantial safety benefits in mandatory medical certifications based on age. Instead, the Commission should focus, in one hand, on ensuring that Member States have a clear legal framework for assessing fitness to drive and, in the other, on promoting voluntary refreshing courses and assessment drives and encouraging mobility alternatives that enable seniors to remain mobile. Barriers to the free movement FIA Region I welcomes the Commission’s intention to clarify the issues arising from changing normal residence. The definition of normal residence causes problems when an EU citizen lives in one member state and works in another. We also invite the Commission to further look at the problem of driving licence tourism, which is partly caused by an undesired side effect of the (unconditional) mutual recognition.
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Meeting with Adina-Ioana Vălean (Commissioner) and

24 Mar 2021 · Conversation with FIA 1 Euroboard on the SSMS.

Response to Revision of EU Ambient Air Quality legislation

14 Jan 2021

The FIA European Bureau supports the endeavour of the European Commission to revise policies and legislation related to air quality from all sectors in the follow-up to the ambition set in the European Green Deal. Whilst the mobility sector is often singled out, there is a shared responsibility of all sectors to lower their impact on the environment. Whilst revising the implementation of the various initiatives, the European Commission should base the future ambient air quality targets on sound scientific evidence. Moreover, the air pollutant reduction targets in the transport sector, primarily related to the emissions of sulphur dioxide, nitrogen dioxide and nitrogen oxide, and particulate matter (PM10, PM2.5) need to be further evaluated. The transport sector is already heavily regulated. The European Commission significantly improved emission legislation with the full application of Euro 6 Regulation 2017/1151, improving the laboratory test cycle and adopting the Worldwide harmonized Light vehicles Test Procedures. Most instrumental has been the introduction of the Real Driving Environment requirements. Nevertheless, roadworthiness testing and end-of-life requirements should be made complementary. The FIA European Bureau invites the European Commission to: • Carry out in-depth research on pollutant immission levels and the impact of various pollutant sources on ambient air quality, and base future ambient air quality targets on sound scientific evidence. • Invite Member States to base the implementation of the Directive, their measurements and their target setting on scientific evidence. • Clarify the current ambiguities in the legislation when it comes to the sitting of sampling points and the definition of general population exposure. The aim of the legislation should be to measure unbiased and comparable pollution levels, that are representative for the levels the population is facing. • Fully evaluate the potential of stricter post Euro 6 limits to cut air pollutant emissions, that are technologically viable and do not have a significant effect on the cost of motoring. • Make full use of the technology options to tackle emissions at source (very efficient internal combustion engines already exist today, see Green NCAP (https://www.greenncap.com/) and the GVI (https://www.gvi-project.eu/) for additional information), and incentivise innovation to improve citizens’ quality of life in the long term. EU policy should support holistic approaches encompassing command-and-control measures and positive fiscal incentives. Moreover, labour organisation enabling increased flexibility of working hours helps to avoid additional pollution through congestion. Technology, investment and command and control measures are best suited to tackle air pollution and noise (https://www.fiaregion1.com/better-deal-motorists/). • Enhance the market surveillance, as proposed in the revision of the type approval legislation. Provide the legal and technical framework for prosecuting the illegal deactivation of emission reducing devices in vehicles. • Consider the need to a coherent approach between the different existing instruments on air pollution and CO2 emissions, in order to avoid trade off in the transport sector. • Consider the external impact of policy and regulation: tighter definition of acceptable ambient air quality standards should take into consideration the risk of spill-over effects. Action to improve air quality taken in one city or region, such as forcing public transport operators to introduce less polluting buses, does not always lead to old buses to be scrapped. They for instance can be transferred to operators in cities or regions with a less serious pollution problem, where they risk harming ambient air quality. It is further not uncommon for such vehicles to be sold to other countries with less severe problems, with lower air quality standards, or less effective environmental controls (within or outside the EU).
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Response to Revision of Regulation on Union guidelines for the development of the trans-European transport network (TEN-T)

18 Dec 2020

The proper functioning of the EU’s transport system is essential to its competitiveness and the quality of life of its citizens. Citizens should benefit from a transport system designed and managed to their needs, considering social, economic and environmental aspects in a balanced way. EU Regulation 1315/2013 has played an important role in promoting an EU network of efficient infrastructure through providing a legislative framework and through encouraging Member States to upgrade their transport networks. Good transport infrastructure is a condition for sustainable mobility in ensuring smooth traffic flow and giving a high level of traffic safety. While almost nine out of ten transport journeys are done on the road, policy needs to appropriately support infrastructure maintenance and development for different modes in an integrated manner. Studies underline the strong positive relationship between investment into transport infrastructure and GDP growth. An important field of action in European transport policy is the financial support given to priority transport infrastructure axes, completing the TEN-T. Given the key role played by the road in Europe’s transport system, a respective share of the financial investment should be allocated to it. Maintaining and completing the TEN-T will reduce the amount of traffic congestion and so bring a contribution to less pollution and lower energy consumption as well as improve road safety by resolving some of the road network’s black spots. This investment will contribute to make mobility more sustainable. The revision of TEN-T guidelines should in particular focus on increasing safety and supporting the cross-border deployment of Intelligent Transport Systems. With regard to safety, the European Union should condition TEN-T funding to the delivery of safe infrastructure and to the provision of road related risk information according to the concept of the "freedom of information act". Each European Council should in this regard set road safety on its agenda and monitor progress very closely. To be safest, roads must be “functional” (matching design and use), “self-explaining” (reducing the likelihood of an accident occurring), “forgiving” (providing protection when an accident occurs) and resilient in case of severe weather conditions. The refurbishment of existing roads should focus on state-of-the-art safety considerations at every conception stage. The TEN-T guidelines should further be revised to support the cross-border deployment of Intelligent Transport Systems. Their implementation will help to efficiently use limited infrastructure, reduce congestion and improve safety. Applications now need to be deployed, while making sure that user needs are considered, the proper functioning is confirmed and that liability issues are addressed. The supplementary infrastructure measures will greatly contribute to the objectives of a future-oriented transport system: - by 2030, the safety level of the TEN-T roads and 25% of the extra TEN-T roads (100% by 2050) should be brought up to the state of the art - road operators should be responsible for the safety standard of road infrastructure - regional funds should be used to promote EU-wide safe road infrastructure programme making safe road design a priority, with special attention to more dangerous roads - research and monitoring should be supported to establish the economic costs and benefits that can be achieved with safe road infrastructure programmes - national educational programmes on safe road design for all stakeholders of a safe road system - public, road professionals, safety professionals and policy makers should be supported - appropriate infrastructure should encourage to shifting freight transport from road to rail and water - further digitalisation should allow the transport sector to strengthen the cohesion within the EU - the consequences of the Brexit should be alleviated to avoid create new gaps in existing TEN-T corridors
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Response to Green Paper on Ageing

11 Dec 2020

The ageing population impacts a wide range of policy areas. Transport and mobility is in crucial need of attention. The elderly remain increasingly mobile at high age, both in their daily life and travel for tourism purposes. Mobility is an important contributor to their well-being and quality of life. The phenomenon of the young old will further develop in future. Their leisure behaviour differs substantially different from earlier generations. The elderly get further involved in various activities and active travel. Mobility behaviour is increasingly shifting towards motorised individual mobility that best corresponds to their needs. The ageing of the European population will therefore likely lead to a shift from public to private transport means. The decrease in the number of users of public transport will likely lead to a decline in the service offer. Improved health resulting from medical advances allows people to drive for longer and, as families are more geographically dispersed, and communities less tied together, individuals are increasingly relying on their own personal transport to meet their mobility needs, in particular for those who live alone. By enabling them to remain mobile, transport allows the elderly to participate and contribute to social life, to the benefit of themselves and to society at large. In this perspective, the elderly should benefit from a transport system designed and managed to embrace their needs. Research on well-being of the elderly after they stopped driving found that their health worsened in various ways, including higher risks of depressive symptoms and diminished cognitive and physical abilities. Covid-19 is currently and perhaps for some time to come influencing significant numbers of older citizens (especially those with age-related comorbidities) to choose leisure and holiday travel options which are naturally socially-distanced. That means more self-driving travel within Member States, and between within the European Union as restrictions ease, instead of flight-based or cruise ship journeys. Adapted infrastructure is an important enabler for the elderly, in particular for people with disabilities. In this regard, the EU should further develop the European reciprocity scheme for holders of the standardised EU model parking card. Safe and well-maintained road infrastructure as well as an appropriate public transport offer are important to enabling the elderly to remain mobile. The EU should condition road development funding to the delivery of safe infrastructure and to the provision of road related risk information. To fit the needs of the elderly, public transport needs to become a lot more efficient and better integrated with park/bike-and-ride, sharing and pooling, integrated mobility management, moving towards MaaS. To further develop an integrated offer, access to data and its user and usage rights are unbearable to enable market players to offer services in a competitive market. As public transport is at the heart of MaaS platforms, it is vital that there is open access to timetables and that there is a wholesale market for public transport, for MaaS providers to offer new tailor-made services to the elderly users. Connectivity allows for promising applications to support the daily mobility and travel of the elderly. Advanced driver assistance systems have proven their contribution to safer mobility. As elderly drivers are strongly benefiting, awareness about their benefits need to be raised. Providing education and training for the elderly is a good way to keep them independently mobile for as long as they are willing and able. To ensure that drivers maintain, upgrade and further develop their driving skills throughout their life, the EU should adopt multi-phase schemes and life-long training, as some Member States have already successfully implemented it. Such training must be part of a lifelong educational framework and must not affect the validity of the driving licence
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FIA Urges Consumer Neutrality if Road Transport Enters ETS

26 Nov 2020
Topic — Updating the EU Emissions Trading System to include road transport and other sectors.
Message — The FIA recommends that if road transport is included in the EU ETS, existing energy taxation must be adapted to ensure no extra financial burden falls on consumers. They argue that efficiency standards and technology-driven measures are more effective than charging environmental costs to reduce emissions.12
Why — These proposals aim to prevent increased mobility costs for motorists and maintain the affordability of private car use.34
Impact — State budgets could lose revenue if national road taxes are reduced to offset new carbon pricing costs.5
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Response to Revision of EU legislation on end-of-life vehicles

19 Nov 2020

The FIA European Bureau welcomes the European Commission’s ambition to adapting the end-of-life vehicles (ELVs) rules to the objectives set out in the European Green Deal, as well as to considering the technological advances. FIA European Bureau invites the European Commission to further consider the following: Life Cycle Assessment Since the overarching goal of the Green Deal is to make the EU's sustainable and, therefore, ensure clean air, water and soil, all the stages of the production, use and end of life of various mobility options should be taken into account. The FIA European Bureau firmly believes that the environmental effects of transportation systems can only be analysed and compared based on Life Cycle Assessment (LCA), including the production, operation, and the end of life treatment. Although FIA European Bureau acknowledges that LCA can only be used for information purposes for now, we trust that the scientific progress will make larger leaps to make LCA also useable for absolute use in due course. To make more accurate information available to the consumers, and informed purchasing decisions, the FIA European Bureau advocates making it obligatory for the OEM to provide the Bill of Energy of sourcing materials and producing vehicles, and consider all logistics energy at the beginning of the vehicle’s life, as well as at its end of life, when the vehicle will be dismantled, scrapped, or exported to other parts of the world where environmental legislation is less developed or enforced. These Bills of Energy shall be made available at type approval, and the OEM shall be obliged to make this information available to third party auditors like Green NCAP, allowing for an accurate LCA.
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Response to Revision of the Intelligent Transport Systems Directive

19 Nov 2020

ITS for better planning - A number of tools can help public authorities in reaching their objectives towards sustainable mobility, for example, integrated planning, including optimal use of ITS technology that can support a safer, more affordable, more sustainable and more efficient transport and mobility, fostering inter-modal complementarity in mobility planning taking local specificities into account and improving air quality, and encouraging the deployment of ITS to reduce congestion, increasing safety and bring more efficiency to mobility. Information and awareness raising on benefits -Information to decision makers and various direct and indirect user groups as well as awareness raising directed to multiple stakeholders will effectively support and accelerate the deployment and use of ITS technology. Informing citizens of the concrete benefits of ITS, in terms of time saving, improved safety, increased comfort and promoting open access to real-time traffic and travel data to improve the quality of information provided to users should become a top priority of the revision of the ITS Directive. Further standardisation needs -The safety potential of co-operative systems reside in the capability to enable as many vehicles, road users and infrastructure elements as possible to exchange information in real time. This requires the use of a common language and the same communication technology. In this context, technology neutrality may prove counter-productive since different manufacturers would work at the introduction and promotion of competing and incompatible standards. Consequently, consumers and infrastructure operators may hold back purchase decisions and investments, lead to high costs and delay in implementation. To guarantee an effective implantation of the ITS Directive, a single communication technology needs to be mandated to guarantee the overall functioning of the deployed ITS. Navigation data -Today drivers and vehicle operators increasingly rely on digital information delivered through on-board navigation systems and mobile devices to plan their journey and to receive information during the trip, including real-time traffic information, tolling information, height-restriction in tunnels, weight restrictions on bridges, pedestrian areas. The scope of data covered by the ITS needs to be revised and complemented for several data categories, including on vehicle access restrictions. Nowadays, there is no requirement for authorities in charge of defining vehicle access restrictions to provide the respective detailed, exact and reliable data in the necessary standardised digital format. The data should be provided through a central point of access in the Single Digital Gateway Regulation, which has recently been adopted, so mandating the provision of such information to via the Single Digital Gateway portal YourEurope and the National Access Points. The data should furthermore not only be defined by data specialists such as the DATEX2 experts, but also foresee a consultation of practitioners during the definition progress as well as a broader consultation of the draft standard to ensure it meets the requirements, and hence the process of using it is not delayed. Access to data for MaaS -The ITS Directive should support measures to advance ‘Mobility as a Service’ initiatives. For the user, MaaS offers added value through the use of a single application to provide access to mobility, with a single payment channel instead of multiple ticketing and payment operations. One of the key challenges for MaaS operators is being able to access public transport ticketing and scheduling information. The EU should take measures to unlock the potential here and allow for a more competitive marketplace, where MaaS operators can sell public transport tickets directly to end users. Moreover, MaaS can alleviate some pressure from public transport by making use of existing services and better connecting public transport with their users.
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Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean)

22 Oct 2020 · FIA event presentation

FIA demands road infrastructure support and vehicle data control

27 Jul 2020
Topic — EU strategy to reduce transport emissions by ninety percent and modernize mobility infrastructure.
Message — The FIA requests continued road infrastructure support and fair access to vehicle data. They oppose charging for external costs, favoring cleaner technology and consumer data control.123
Why — This prevents new costs for drivers and helps independent mechanics compete with manufacturers.45
Impact — Climate advocates and city planners lose EU-wide backing for road charging and traffic bans.67
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FIA Advocates for 90 Percent Battery Recycling Efficiency Targets

7 Jul 2020
Topic — The European Commission is modernising legislation for the entire battery life cycle.
Message — FIA urges raising battery recycling efficiency targets to over 90 percent. They want a separate legal category and framework for second-life battery use. Manufacturers must ensure transparency and provide standard access to battery data.123
Why — This strategy would help lower battery prices and emissions for automobile owners.4
Impact — Manufacturers would bear new costs for sustainable design and managing battery disposal.56
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Meeting with Adina-Ioana Vălean (Commissioner) and

11 Jun 2020 · Meeting to discuss the Automotive sector.

Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean)

29 May 2020 · Meeting to discuss the impact of COVID 19 in the sector

Response to Report on the application of the General Data Protection Regulation

28 Apr 2020

FIA Region I welcomes the opportunity to provide input on the Roadmap on the Report on the application of the General Data Protection Regulation. We have outlined three points that could be considered in the process of identifying possible issues in the application of the legislation: The representation of mobility end-users is the utmost priority of FIA Region I. Our 104 Mobility clubs represent over 36 million members from across Europe, the Middle East and Africa. Our members provide roadside assistance, legal advice, insurance and many other products to their members. In 2017, FIA Region I developed a campaign called My Car My Data highlighting the importance of informed consent on access to car data. The campaign was backed up by a survey which polled 12 000 motorists from 12 European countries. Its findings pointed out the importance of consumers being fully informed about what data is being transmitted and for what purposes. For instance, 86% of European motorists showed serious concerns about unauthorised commercial use of their data. More recently in March 2020, FIA Region I contributed to the consultation of the European Data Protection Board on the ‘Guidelines on processing personal data in the context of connected vehicles and mobility-related applications’. In our feedback (see attachment), we addressed motorists’ concerns over the security of personal data for repair and maintenance services. Besides, FIA Region I suggested the Guidelines included of a case study looking into the particularities of data processing and security of personal data for vehicle diagnostics, repair and maintenance services. When assessing the potential issues with the application of the GDPR, the report should investigate areas where the application of the legislation has prevented individuals from exercising data protection as a fundamental right in its fullest extent. Therefore, the report should not abstain from addressing the challenges experienced in different sectors, such as transport. As highlighted, the processing of car data is a particular case which poses several challenges deriving from the sensitive relationship between the consumer and the connected vehicle. For instance, when it comes to dashcam recordings, it becomes extremely challenging to put Articles 12 and 13, GDPR into practice. Although the recordings might offer key evidence in civil proceedings settlements, it inherently prohibits the fulfilment of information obligations under the GPDR and, therefore, violates the fundamental right to the protection of personal data. We appreciate the chance to contribute with the perspective of Mobility Clubs and road users to the roadmap of the report on the application of the GDPR.
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FIA Region I Urges Technology Neutrality in Climate Target Plan

15 Apr 2020
Topic — The EU proposes increasing the 2030 greenhouse gas emission reduction target to at least 55 percent.
Message — FIA Region I requests a re-evaluation of CO2 emission limits using life cycle assessments instead of just tailpipe emissions. They advocate for a technology neutral approach including low carbon liquid fuels while maintaining cost neutrality for consumers.123
Why — This would protect motorists from rising costs while ensuring traditionally powered vehicles remain viable for longer.4
Impact — Electric vehicle manufacturers would lose their competitive advantage if life cycle emissions are factored into targets.5
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Meeting with Penelope Papandropoulos (Cabinet of Executive Vice-President Margrethe Vestager)

12 Feb 2020 · Meeting with FIA Region I on digitalisation of the transport sector

Meeting with Violeta Bulc (Commissioner) and

2 Oct 2019 · European Young Women Closing Conference

Response to Driving licence legislation ex-post evaluation

10 Sept 2019

FIA Region I welcomes the opportunity to provide input on the Evaluation Roadmap on the Third Driving Licence Directive. We have outlined five points that could be considered in the evaluation process: Verifying the performance level of the driving licence legislation is paramount for FIA Region I and its member automobile clubs. This opportunity allows the legislator to revise the adequacy with road safety objectives and to support the progress towards lifelong learning for road users. When assessing the performance of the current legislation, the Commission should assess how to strengthen formal driver training. For instance, requiring professional examiners and instructors to conduct tests based on harmonised mandatory standards could significantly support the objective of reducing road accidents, with the inclusion knowledge of modern driving assistant systems and hazard perception training. On the back of the recommendations of the 2017 Implementation Report, the evaluation should consider including knowledge of advanced driver assistance systems (ADAS) in the examination procedure. With such systems soon becoming standard in all EU-manufactured vehicles, the driving tasks will also require the modernisation of drivers’ skillset. Therefore, learning how to safely use these systems during the basic training and, ideally, retraining systems, is essential to make sure that the new technologies do not become a distraction for the drivers. The evaluation of the Directive should consider the feasibility of mandating a EU-wide multi-phase retraining system. Asking novice drivers to undertake compulsory retraining after obtaining the driver’s licence could significantly reduce traffic accidents. This second phase of training could be, then, a requisite for validating the license and include more complex and higher driving skills, such as traffic insight, self-assessment, risk awareness and hazard perception. Additionally, the Driving License ex-post evaluation should look into the benefits of removing from the legislation any obstacles to the deployment of alternative powered vehicles and advanced driving systems. This also applies to driver training, which should include topics such as electromobility and alternative fuels. We appreciate the chance to contribute with the perspective of Mobility Clubs and road users to the evaluation of the EU driving licence legislation.
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Response to Evaluation of rights of passengers in bus and coach transport in the EU

3 Sept 2019

FIA Region I welcomes the opportunity to provide input on the Evaluation Roadmap that concerns the Regulation of rights of passengers in bus and coach transport. Below are five points we would like to be taken into account in the evaluation: Passenger rights and obligations should be the same throughout the EU. The evaluation should, therefore, assess to what extent passengers can benefit from a minimum EU-wide protection framework when travelling by bus or coach that allows for high-quality transport standards and seamless travel. Passengers should receive information on their rights when travelling and how to exercise them. The evaluation should look into how to better harmonise the level of information provided to passengers. Currently, this is highly dependent on the transport carrier, resulting in many passengers not receiving orientation after cancellations, delays, as well as assistance and right of compensation. The collection of complaints and detailed reporting to National Enforcement Bodies could significantly improve the understanding of how passengers exercise their rights and the biggest issues when travelling by bus and coach. In fact, FIA Region I mobility Clubs often report significant differences in how transport companies handle consumer complaints. Therefore, an evaluation of the implementation of the regulation should look into the reporting of complaints and the penalisation for non-compliant carriers. Passengers with disabilities or reduced mobility should receive better assistance when travelling in all Member States. This includes assistance when there are traffic disruptions, for accessing terminals and boarding vehicles. The evaluation should, therefore, consider the added value of new accessibility requirements for vehicles and infrastructure. Besides, a compliance check with current accessibility requirements should be carried as part of the assessment, with special attention to densely populated areas. Finally, the evaluation should include both legislative and non-legislative tools to increase the level of protection and assistance to passengers. Apart from improved compliance and enforcement, the evaluation should consider the adoption of soft tools such as promoting passenger rights awareness campaigns and access to alternative dispute mechanisms.
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Response to European Partnership for Safe and Automated Road Transport

26 Aug 2019

FIA Region I believes that a series of challenges for safe automated road transport can better be addressed by a co-programmed European partnership of coordinated actions from public authorities and industries (option 1). The Partnership should help defining a long-term framework for the strategic planning of research and pre-deployment programmes. From a consumer perspective, we wish the Partnership to focus on the following aspects. Recommendation 1 the Partnership should help to focus on user requirements and outreach Research and innovation programmes have put a lot of focus on technical maturity, with lesser focus on implementation and market deployment. Citizens will however only reap the benefits, if further efforts are made to reaching out to users, analysing their needs with the aim to overcoming market deployment barriers. The Partnership should support the efforts to deploy technology with citizens’ full buy-in. Recommendation 2 the Partnership should help to foster further integration of flexible mobility options As urbanisation is likely to further increase, innovative approaches are needed to tackle the pressure of mobility demands in limited space. The Partnership should bring the necessary public and private stakeholders together to realise an integrated approach to transportation, facilitated by increasing connectivity. This would offer a variety of flexible mobility options: private, on demand, shared ownership, public and semi-public transport, while fostering social inclusion. The Partnership should help to shape a competitive single market, ease deployment for investors and operators, guarantee minimum rights for users, and create a framework for technical and commercial solutions. Recommendation 3 the Partnership should help to develop a data management framework Increasing data gives valuable information about individual and collective behaviours, about the performance of infrastructures and vehicles, travel patterns and traffic flows, disruptions. It also enables an increasingly flexible mobility that consumers demand. As much of this data records personal mobility behaviour, data protection, full informed consent and free sharing should be guaranteed for citizens. The Partnership should help to ensure that open data policies and open platforms, fair access to data, data access costs, user acceptance, data security, data integrity, data confidentiality and data privacy become an integral part of safe and automated road transport. Recommendation 4 the Partnership should help to master the transition towards highly automated driving Automation holds the potential to vastly change road transport. Increased safety, reduced costs, reduced fuel consumption and emissions, improved mobility and traffic flow count amongst the expected benefits. This progressive evolution will require an adaptation of user behaviours and encounter challenges in terms of user acceptance. By involving a wide range of stakeholders, the Partnership should help to ensure a safe transition from current levels of automation to a situation where drivers can engage in other tasks, while managing their responsibilities for vehicle safety. Findings from other highly automated transport domains may be instrumental in shaping the transition. Recommendation 5 the Partnership should help to safeguard the reliability of automotive product quality One of the important gaps to close from a consumer perspective is the deteriorated automotive product quality, which has significantly suffered over the past years. Reasons for this deterioration may have different reasons, including increasing complexity and commercial pressure on product development times. The consequence of this evolution is that consumers get products that are less reliable or functional. The Partnership should aim to revert this trend and help closing this increasing gap in product quality, enabling the high technical reliability required by higher levels of automation.
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Response to Obligations of European Electronic Toll Service providers

6 Aug 2019

FIA Region I wishes to emphasise that the data protection rules of the European Union must be respected, including: the purpose binding obligation, the maximum storage duration and the right to information. The purpose of the data collection is and should remain the settlement toll claims. The proposed exchange of information with regard to the EETS under Article 2 paragraph 4 includes the collection and processing of personal data, such as the name and address of the vehicle owner and user, and the vehicle registration number. These are sensitive data that are directly related to mobility and travel profiles. The FIA Region I therefore also calls upon the European Commission that provisions should be made that Member States shall take the necessary measures to ensure that the exchange of information takes place with interoperable electronic means without exchanging data with other databases. This should be in line with the principle of purpose and data minimisation.
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Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and

17 May 2019 · 'Access to in-vehicle data' and EC recommendation on '5G, cybersecurity and data governance'

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

11 Apr 2019 · Vehicles/potential access to data models

Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)

11 Apr 2019 · Access to vehicle data

Meeting with Ivo Schmidt (Cabinet of Vice-President Maroš Šefčovič)

11 Apr 2019 · FIA study on digitalisation

Response to Cross-border enforcement of road traffic rules

10 Apr 2019

FIA Region I welcomes the European Commission’s Inception Impact Assessment and the opportunity to give feedback on the initiative. Representing 36 million European motorists, FIA Region I and its member Mobility Clubs offer its expertise to support the Commission’s evaluation with any additional information necessary. The Cross-Border Enforcement (CBE) Directive is viewed as an important step to improve road safety while streamlining and facilitating the procedure between Member States when enforcing the rules on road traffic offenses. Below are some general points that we would like to raise: Scope of the Directive As detailed in the study evaluating the application of Directive (Grimaldi, 2016), the offences covered by the Directive cover most of the offences that are the major contributing factors to road fatalities on EU roads. Applying the legislation has been challenging for Member States for many reasons including the level of administrative burden and because of the differences in procedures with regard to Member States' administrative and/or judicial decisions. One challenge faced by motorists is the latency in procedures for the notification of fines, often caused by different deadlines or difficulties in obtaining vehicle registration information. The focus of the Commission should therefore be on ensuring the effective application of the existing requirements of the Directive. Informing citizens of their rights in their own language Article 5 of the Directive outlines how any offence is to be communicated with the owner of the vehicle. The Article includes a non-binding requirement for the correspondence letter to be in the language of the vehicle registration. This voluntary element means that in some cases letters are not sent to recipients in their own language. This can mean for recipients that it is difficult to understand the information shared with them and potentially they would have to bear the costs of translation. Furthermore, it is also the case that correspondence letters, even in the native language of recipients can also be incoherent or badly translated. The impact assessment should better review this issue in order to ensure that such letters of correspondence are always delivered in the language of the vehicle owner. An assessment of the options available (e.g. provision of EU funds for translation purposes) to improve the operations of Member State authorities should also be further explored. Moreover, it would be desirable that Article 5 is also applicable for all traffic offences related to road safety and not just for the traffic offences that fall under the scope of the Directive. Data protection Vehicle registration details should be carefully recorded, stored, corrected and deleted. The processing of drivers’ personal data must be restricted to purposes defined in the scope of Directive, therefore, avoiding any exploitation of the drivers’ movement profiles. A full assessment of the Directive should be carried to ensure that the transfer of vehicle registration details among Member States, or any third-parties, abide by the principles of the new GDPR, ePrivacy Directive, as well as the Directive (EU) 2016/680 on the processing of personal data by public authorities in criminal offenses. Therefore, a comprehensive set of safeguards should be put in place against the misuse of personal data. Enforcement One of the key findings of the Grimaldi (2016) study showed that not all Member States can legally enforce financial penalties for road traffic offences that have been committed in other Member States. A detailed analysis should be carried out in order to address and clarify such issues. In this context, it is desirable to research further how Member States enforce financial penalties. Specifically, the issues with passing on collected fines and excessive costs built in the financial penalties by private debt collecting agencies.
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Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

4 Apr 2019 · Connectivity in the automotive sector.

Response to Evaluation of the Alternative Fuels Infrastructure Directive

19 Mar 2019

With the expected increased deployment of alternatively powered vehicles over the coming years it is essential that the EU takes necessary steps to prepare for such change. The evaluation of Directive 2014/94 should assess the added value of the legislation and where it can be improved in order to better manage the shift towards alternatively powered vehicles. Below, we highlight key issues to be focused on during the evaluation: Amounts of charging infrastructure – It is essential that adequate levels of charging infrastructure for different power trains are in place across the European Union. With the EU’s agreed light duty vehicle CO2 reductions targets for 2021, 2025 and 2030, it is expected that a significant number of ultralow carbon vehicles including electric cars will be brought to market. It is therefore essential to evaluate the extent, to which the Directive is having an effect on increasing the amounts of charging infrastructure for the entire range of alternatively powered vehicles. Information on locations of charging points – Owners of electric vehicles should be fully informed about the locations and types of charging infrastructure. The evaluation should therefore assess the extent to which the Directive has ensured that adequate information is being delivered to motorists about such issues. Fuel labelling – The evaluation should include a review of how the fuel labels standard EN 16942 has been implemented across Europe and in particular the extent to which the labels appear across Europe. As the fuel labelling developed in the standard only applies to fuelling stations and to new vehicles, measures should also be taken to inform the owners of older vehicles, who are at the same time more likely to be confronted with fuel incompatibilities. This issue is most pressing for citizens travelling cross-border in Europe. It is essential that drivers have better information on the suitability of fuels for their vehicles wherever they travel in the European Union in order to help them avoid misfuelling. Transparency on pricing – It is essential that the consumer can easily understand the cost of using charging infrastructure and the differentiation in prices between different fuel types. The evaluation should include an assessment of the extent to which it has ensured that charging facilities offer clear and reliable information about the cost of charging vehicles, especially as time based tariffs make solid comparisons nearly impossible. Furthermore, it should review to what extent Member States have implemented the May 2018 Implementing Regulation on Fuel Price Comparison. Vehicle access restrictions - Public authorities should give citizens longer term horizons, when implementing traffic bans for certain fuel types or vehicles fulfilling certain pollution norms. Within the alternatives offered to citizens in the framework of traffic bans, public authorities should promote alternative fuels, while reinforcing the offer of refuelling infrastructure and the information about their location. Public awareness campaigns may also guide citizens to envisaging a move towards alternative fuels. Interoperability – In order to foster a consumer friendly approach to charging for electric vehicles, users must be capable of seamlessly accessing charging infrastructure, including receiving transparent information for payment services. Interoperability is therefore a critical feature and the evaluation should in turn review the extent to which the Directive has and will affect interoperability across the EU. Vehicle labelling – Although not directly covered by the Alternative Fuels Infrastructure Directive, it is essential that the European Commission also reforms labelling rules for new cars on their fuel consumption and emissions performance. Prospective car buyers should be provided with a basic level of clear, relevant and reliable information about the fuel consumption and environmental performance of new vehicles.
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Response to Evaluation of the Motor Vehicle Block Exemption Regulation

19 Mar 2019

Motoring consumers’ need for a motor-specific Block Exemption Regulation: Compared to the sale of new vehicles, the brand-specific nature of repair and maintenance services and the distribution of spare parts markets impose different competitive conditions on traders. The peculiarities of the motor-vehicles sector often impose restrictive obligations in spare parts distribution after-sales service agreements, as well as threaten the competitive independence of independent aftermarket players. Warranty agreements influence consumer’s preferences in repair and maintenance services, with the majority of drivers choosing brand-affiliated repairers in the first 3-4 years of after-sales. Consequently, the MVBER plays a key role in guaranteeing the competitive conditions of the motor-vehicle sector agreements, and thus, avoid that consumers are subject to higher prices for spare parts and limited services and repair choices. European motorists rely on a range of aftersales services and need the legal certainty that their freedom of choice is preserved. It is therefore key that the MVBER is maintained in order to safeguard the competitive independence of dealers and service providers to ensure consumers’ freedom of choice. Ensuring affordability of repair and maintenance of vehicles: The costs related to repair and maintenance represent a considerably high proportion of what consumers spend on cars. Guaranteeing competition in the motor vehicle aftermarket ensures that motorists have access to affordable repair and maintenance services, as well as spare parts. Allowing for choice and availability of in-vehicle data: By 2030, all cars will be connected, with high demand for digital services. Consumers could benefit from connectivity in many ways, from remote diagnostics and repair to in-vehicle entertainment. However, the existing European regulatory framework does not adequately account for advances in the automotive sector with regards to connectivity, both from the perspective of the consumer nor the independent aftermarket. As part of this framework, the MVBER should be modernised to ensure that players from the motor vehicle aftermarket have fair access to vehicle information to provide diagnostics, repair and maintenance, among other services. The TRL Report ‘Access to In-vehicle Data and Resources’ (2016), commissioned by the European Commission, highlighted that competition law has a key role to ensure that the aftermarket is protected against anticompetitive behaviour. The report goes further and states that certain models of access to in-vehicle data, such as the Extended Vehicle, pose a serious risk to the distortion of the market to the detriment of consumers. Additionally, the JRC Study ‘Access to digital car data and competition in aftersales services markets’ (2018) highlighted that the car manufacturer’s preferred model, called Extended Vehicle, would allow for a monopoly on access to data. The study concluded that this model would significantly reduce welfare for drivers and aftersales service providers. The preliminary results of the study commissioned by FIA Region I in 2019 highlight the harm consumers face from the absence of rules ensuring direct access to vehicle information. Although consumers favour independent operators due to cost savings, there are a series of challenges to provide repair and maintenance in connected vehicles, such as access restrictions, extra costs, delays in receiving the data and the risks of being monitored. FIA Region I will provide DG COMP with the full report once it is published. To prevent disruption and to allow for the protection of consumers interests, a sector-specific competition framework to ensure fair and non-discriminatory access to in-vehicle data is necessary. Thus, it is essential that the evaluation of the implementation and future revision of the MVBER fully takes the aspects of vehicle connectivity into account while taking consumers’ welfare as a priority.
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Response to Specifications for the provision of cooperative intelligent transport systems (C-ITS)

4 Feb 2019

FIA Region I would like to give the following feedback on the Commission’s proposed Delegated Regulation: Efforts to better ensure interoperability in C-ITS should bring with it considerable benefits, not least in improving vehicle safety. It is essential that with any measure taken to improve the communication between vehicles and other agents that data protection and privacy are ensured and that motorists have the right to easily give their consent to the use or sharing of any data generated by their vehicle. Annex 2 specifies that passengers should be able to switch off the C-ITS terminal at any time. A default-off setting would be useful as long as the data exchange within C-ITS is not required by law. It is important that the Commission’s proposed delegated regulation is regularly reviewed in order to better understand the impacts of the legislation and to potentially adapt the regulations for technological progress. It is disappointing that the Commission deems a regulatory approach appropriate for so called ‘first day’ data access needs but refrains from proposing legislation with regard to other data access needs, for instance those related to remote diagnostic support.
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Response to Cooperative, Connected and Automated Mobility (CCAM)

16 Nov 2018

Data governance The existing European regulatory framework does not adequately account for advances in the automotive sector with regard to connectivity, both from the perspective of the consumer nor the independent aftermarket. In a survey of 12,000 motorists across Europe in 2015, 95% of them called for dedicated legislation in this area. Both the Roadmap and the May 2018 Communication on Connected and Automated Mobility infer that access-to-data models currently being implemented in the market do not abide by the principles of fair and undistorted competition. The recent report of the JRC on access-to-data strongly argues that current models being implemented by OEMs such as the Extended Vehicle concept reduce welfare for drivers and aftersales service providers. Conversely, the Roadmap deems it unnecessary to carry out an Impact Assessment as the ‘economic, environmental and social impacts arising from this initiative are considered to be small’. FIA Region I (FIA RI) is disappointed that an Impact Assessment has not been conducted and believes it is entirely necessary in order to better understand the potential effect of a Recommendation, on the understanding that it would not require binding legislation, and therefore would not prevent against unfair competition due to existing market developments. FIA RI insists that the only way to ensure fair competition is for the EU to bring forward binding legislation. Binding legislation should in turn ensure the following principles are met: • Direct real-time access to time-critical in-vehicle generated data for all service providers; • Bi-directional communication with the vehicle and its functions for all service providers; • The ability for service providers to safely and securely interact with the driver (via the dashboard or voice commands) to fulfil their service offers; • The prohibition of business monitoring between any service provider and OEMs. • The assurance that consumers can give their informed consent for the sending and processing of their data and the ability to easily withdraw consent in accordance with the GDPR. Cybersecurity Ensuring that vehicles and the transfer of data is secure is essential. Cybersecurity will be an ongoing issue for both OEMs and regulators, whatever data-access model that is applied. Motorists are also concerned about cybersecurity - 85% of respondents to an FIA Region I survey said they were concerned about hacking. It is clear therefore that the European Commission should take necessary precautions to ensure that vehicles are cybersecure and this will most likely require measures to be taken at the UN and EU level with standards being developed to ensure that vehicles are secure when type approved but also throughout their lifetime. However, it is important to note that cybersecurity should not be used to curtail the fundamental requirements of ensuring fair and undistorted competition. It is important to recognise that the 2016 TRL study highlighted in the Roadmap on access to data also indicates allowing for direct access to vehicle data does not provide a greater security risk beyond those associated with a server based model. Furthermore, the 2018 JRC study on access to data also highlighted how security risks will exist with each and every data access model, be it server-based or one that allows for direct access. Regulators, OEMs and aftermarket service providers must all remain vigilant in this area. Connectivity FIA RI supports a market approach to connectivity and rejects a mandated introduction of C-ITS technology. More real-life data is needed in order to evaluate the benefits with regards to traffic safety and transport efficiency. With regards to an EU approach to connectivity, it is essential that further research and development is supported in order to better understand the opportunities and barriers to improving connectivity between vehicles and other infrastructure/users.
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Response to REFIT review of the Motor Insurance Directive

17 Jul 2018

The FIA welcomes this opportunity to give feedback on the European Commission’s proposal to revise the MID. Below is our input based on our preliminary analysis of the issues concerning mobility and motor sports: - Insolvency of an insurer: The FIA welcomes the revision of the MID establishing that Member States must set up compensation bodies or schemes, so victims can be compensated in their Member State of residence, irrespective of where the accident took place. - Limitation periods and efficiency in the processing of claims: The proposal does not stipulate a time period during which an insurer should compensate victims. This is important so as to avoid long time periods before compensation is granted. The FIA strongly argues for the implementation of a 3-month deadline for the insurers to admit claims and a 2-month deadline after that to settle. Additionally, the proposal did not address the issues of divergence in limitation periods, which may place obstacles for citizens to get redress in cross-border accidents. The FIA therefore proposes to add a general minimum limitation period of 4 years, which would start from the date of the injury, or the date of the victims’ acknowledgement of the injury. - Claims history statements: The proposal addresses the issue of portability of claims limited to five years. However, FIA favours an obligatory mutual recognition of at least seven years with no damages to fully ensure that insurers will treat claims history statements issued by an insurer in a different Member State equally to those issued domestically. - Enforcement against uninsured driving and personal data: The targeted revision of the MID added a new concern about the handling of personal data from drivers, which will be used by authorities to increase the control for uninsured driving. Although Article 4 of the proposal mentions the checks on insurance must be conducted in full compliance with Regulation 2016/679, there needs to be further clarity. Here, the Proposal needs to be clearer on determining how personal data will be handled by authorities or any third parties, in order to ensure that safeguards are in place against the misuse of personal data. - Reimbursement of legal fees, access to documents – The proposal does not tackle the issues faced by victims when seeking compensation against an insurer in court. The injured parties, if successful, should have the right to be reimbursed for the costs of any lawyer, judicial expert or expert if their involvement is required, and if the costs are reasonable. Additionally, such reasonability of the costs should be assessed considering (a) the actual services rendered; (b) any actual disbursements by the lawyer or expert; (c) the likely time spent (d) complexity; (e) any potential risk to the lawyer’s liability; and (f) rules and standards. - Codification of the scope: The unique characteristics of motor sport have not been taken into account. The impact assessment failed to make a proper analysis of the economic impact of the proposed modifications. This proposal could lead to motor sport events becoming unaffordable, although there are currently systems in place, which allow them to be covered at reasonable prices. Setting insurances prices is the sole responsibility of the insurance companies and the enhancement of the scope will lead to an exponential increase of premium insurance policies. This in turn, would have a high social impact, affecting the grassroots practice level of thousands of motor sport fans and the organisation of motor sport events across the EU. In addition, the proposal fails to tackle practical issues, specific to motor sport, such as the implementation of the driver-to-driver liability insurance during sport competitions.
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Meeting with Tibor Navracsics (Commissioner)

26 Jun 2018 · Agreement FIA and Pledge to implement Good governance in sport

Meeting with Violeta Bulc (Commissioner)

19 May 2018 · Meeting with Mr Jean Todt, President of FIA on Road Safety and E-Mobility; E-Formula race

Meeting with Violeta Bulc (Commissioner) and Allgemeiner Deutscher Automobil-Club e.V.

18 May 2018 · Dinner with the President and Vice-President of Fia as well as President of ADAC

Meeting with Alisa Tiganj (Cabinet of Commissioner Violeta Bulc)

14 May 2018 · Meeting with CEO

Meeting with Szabolcs Horvath (Cabinet of Commissioner Tibor Navracsics)

27 Mar 2018 · Motor Insurance Directive

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and

9 Mar 2018 · Connected Car

Meeting with Alisa Tiganj (Cabinet of Commissioner Violeta Bulc)

26 Feb 2018 · 3rd Mobility package

Response to Vehicle's On-Board Fuel Consumption Measurement device

9 Jan 2018

• FIA Region I welcomes the European Commission’s proposal to require car manufacturers to introduce on-board fuel metering devices. This is an important step in the right direction in order to keep a better check on the validity of type approval test results and to build future legislation on real-world statistics and evidence. • FIA Region I also calls on the Commission to introduce CO2 emission and fuel or energy consumption measurements under real-world driving conditions in RDE by 2020. The test procedure should be amended to allow measuring CO2 emissions and fuel consumption in the shortest delays possible to ensure planning security for authorities, test houses, the industry and NGOs.
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Meeting with Violeta Bulc (Commissioner) and

8 Nov 2017 · Meeting with Mr Todt

Meeting with Alina-Stefania Ujupan (Cabinet of Commissioner Mariya Gabriel), Carl-Christian Buhr (Cabinet of Commissioner Mariya Gabriel)

26 Oct 2017 · Access to vehicle data

Meeting with Jocelyn Fajardo (Cabinet of Commissioner Violeta Bulc)

6 Feb 2017 · Transport issues

Meeting with Henrik Hololei (Director-General Mobility and Transport)

12 Apr 2016 · My Car My Data connectivity

Meeting with Carlos Moedas (Commissioner) and Automóvel Club de Portugal

21 Mar 2016 · Mobility as a Service (maaS) - Changing personal transportation

Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)

16 Oct 2015 · connectivity

Meeting with Eric Mamer (Digital Economy)

15 Oct 2015 · DSM

Meeting with Violeta Bulc (Commissioner) and

12 Oct 2015 · Meeting Jean Todt as UN special envoy for Road Safety

Meeting with Eduard Hulicius (Cabinet of Commissioner Věra Jourová)

23 Sept 2015 · Data related issues and automobile sector

Meeting with Violeta Bulc (Commissioner)

12 Mar 2015 · Meeting with FIA

Meeting with Justyna Morek (Cabinet of Commissioner Elżbieta Bieńkowska), Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska)

12 Feb 2015 · Connectivity