As ACEA we believe that vehicle producers, policymakers and consumers alike need a robust process to ensure that motor vehicles meet relevant standards before they are brought on the market. That’s why the automobile industry supports the core objectives of the European Commission’s proposal for a new type approval framework. This proposal seeks to strengthen market surveillance, improve the current system and harmonise it further.
For those of you who are not familiar with the type approval process, let me briefly explain it. Before a car can be registered in Europe, it is tested by a national technical service in accordance with EU legislation. When all relevant safety and environmental requirements are met, the national authority delivers an EU vehicle type approval certificate to the manufacturer, authorising the sale of the car type in the European Union.
Last month, the European Parliament's Committee on the Internal Market and Consumer Protection (IMCO) adopted its report on revising the system. While ACEA welcomes many of the report’s recommendations, the industry has serious concerns about some of its suggestions. The three most controversial issues relate to repair and maintenance information (RMI), access to in-vehicle data and the shortage of testing facilities.
Our industry has worked closely with the Commission and other stakeholders to ensure that robust RMI requirements are in place that allow third-parties to access relevant data. The Commission’s proposal suggests to transfer the existing RMI provisions from EU emissions legislation to the type approval framework. This makes sense, because the right for independent operators to access repair and maintenance information on a non-discriminatory basis does not only apply to emissions-related information.
The recent IMCO report, however, proposes to make substantive changes to the content of the legislation as part of this transfer. Clearly, it is not appropriate to make substantive changes to existing legislation without carrying out a proper impact assessment. The Commission is still in the process of investigating the effectiveness of the current rules on RMI access. Hence, only amendments that confirm or clarify existing law are appropriate at this stage.
But our concerns do not only relate to the legislative process. Auto manufacturers also have major doubts about the content of the RMI proposals that surfaced in February. For example, the suggestion to disclose all vehicle identification numbers of all vehicles together with the exact specifications of each vehicle would constitute a fundamental breach of data protection legislation.
A second proposal seeks to provide direct access to in-vehicle data by means of a wireless connection. This would enable third parties to introduce or re-write software that might affect the vehicle’s integrity. Providing uncontrolled remote access to vehicle data poses much greater risks to security, safety and liability than giving RMI access when the vehicle is physically brought to a workshop by the consumer. Likewise, it would make it impossible for manufacturers to fulfil their liability obligations – especially in the case of connected and automated driving.
Together with automotive suppliers and other stakeholders, we’re currently in the process of finding a solution for providing secure and safe access to vehicle data to interested parties. Various technical solutions are currently being explored. So we believe that it would be premature to include some of the ideas proposed in the report in the revision of the type approval legislation.
Coming back to the way vehicles are tested, ACEA welcomes the proposed audit of how national authorities operate, as well as further improving market surveillance and compliance testing provisions. However, the IMCO report also suggests that member states should be obliged to take 20% of new car models off the road and have them tested in labs to ensure compliance. This would place a massive burden on national authorities, with some countries having to test tens of thousands of vehicles for conformity. The industry has grave concerns as to how this would work in practice.
Already now a car has to undergo almost 100 tests before it can hit the road. And later this year WLTP, the new emissions test for cars, will be introduced as well. The switch to the new test is expected to increase the burden on testing facilities by 6-8 times the current levels. Given the existing shortage of testing facilities, manufacturers already undertake roughly 40% of type approval tests at their own facilities, or in third party laboratories, strictly monitored by representatives of national type approval authorities.
Even if the proposal to check 20% of all new cars would be dropped, permanent high demand will continue to require in-house testing capacity. Under proper accreditation and supervision, both in-house and third party testing facilities should remain part of the new ecosystem.
As an industry, we fully support the update of the type approval framework in order to restore trust and the credibility of the system. But before the new legislation comes into place, we need to identify the measures that can further strengthen the internal market in the most cost-effective manner, while safeguarding the environmental and safety performance of motor vehicles. We should ensure that the new system remains practicable and implementable for our industry.
Secretary General of ACEA