The undersigned stakeholder coalition welcomes the Commission’s acknowledgement of the vehicle manufacturers’ privileged position on ‘access to car data and vehicle resources’ and the issues it raises for fair and undistorted competition, in particular in the form of centralised ‘extended vehicle data platform servers’.
However, our stakeholder coalition has serious concerns because the package fails to set out a clear legislative pathway to guarantee a level playing field for all digital products and services ‘around the car’, which would ensure that consumers can truly decide who they share their car data with and for what specific services.
The Commission’s proposals merely reiterate previous statements found in its GEAR 2030 Report, and falls significantly short of what is required to ensure competitive digital services and products for drivers.
Unless legislation is implemented on an interoperable, standardised, secure and safe digital in-vehicle telematics platform, then there is a serious threat to competition, innovation and consumer choice for mobility services and digital products. The time to act is now, as the volume of connected vehicles is rapidly increasing.
The coalition therefore calls upon the Commission to act upon its recommendation to “monitor the situation on access to in-vehicle data and resources” and deliver – also in line with the Parliament‘s Report on C-ITS – a concrete work programme leading to a legal framework enabling equal competition in digital services.
Moreover, the Commission can prove its commitment now by adopting a definition of Remote Diagnostics Support (currently under discussion as follow-up of the Repair and Maintenance Information provisons of the Vehice Type-Approval Regulation) which should enable a remote, bi-directional and independent communication with the vehicle for service providers to access in-vehicle data.
Furthermore and until a legislative proposal is adopted, all service providers should have the right to non-discriminatory access to vehicle manufacturers’ own systems of access to in-vehicle data and resources or to those in-vehicle data/resources systems offered already today to chosen third parties, which is currently not the case.
* * *
Undersigned Industry, Consumer and SME Associations:
ADPA – the European Independent Data Publishers Association aims to ensure fair access to automotive data and information and to provide competitive framework conditions for independent data publishers. This will allow the publishers to be able to design and provide competitive, innovative and multibrand products and services to operators of the automotive aftermarket. Contact: Laurence Eeckhout – EU Affairs Manager – email@example.com – tel: +32 2 761 95 16.
CECRA – the European Council for Motor Trades and Repairs- is the European Federation representing the interests of the motor trade and repair businesses and European Dealer Councils on behalf of vehicle dealers for specific makes. Its main aim is to maintain a favourable European regulatory framework for the enterprises of motor trade and repair businesses it represents. Contact: Bernard Lycke – Director General – Bernard.firstname.lastname@example.org – tel: +32 2 771 96 56.
CITA is the international association of public and private sector organisations actively practicing compulsory inspection of in-service motor vehicles and their trailers, or with responsibility for authorising and supervising inspection organisations. CITA has defined its vision as enabling its members to play an influential role in the development and implementation of policies for safe and sustainable road usage. This vision will be supported by CITA’s Mission to provide the forums to create, assess and promote best practice, ensuring safe and compliant vehicles throughout their life cycle. Contact: Eduard Fernandez – Executive Director – email@example.com – +32 2 469 06 70.
EGEA – the European Garage and test Equipment Association represents both manufacturers and importers of tools and equipment for the repair, servicing and technical inspection of vehicles, as an integral part of supporting the automotive industrial value chain. Its role is to ensure that its associations’ members can provide the best equipment and service to the automotive aftermarket by striving to keep members up-to-date concerning new vehicle technologies and legislative and standardisation requirements and thus be competitive in the garage and test equipment supply, service and calibration industry. Contact: Eléonore van Haute – Secretary General – Eleonore.firstname.lastname@example.org – tel: +32 2 761 95 15.
ETRMA is the voice of tyre and rubber goods producers to various European institutions. ETRMA activities focus on the following key interdependent areas: representation, co-ordination, communication, promotion and technical liaison. The primary objective of ETRMA is to represent the regulatory and related interests of the European tyre and rubber manufacturers at both European and international levels. ETRMA is the sole interlocutor, specifically designated by the European tyre and rubber producers to carry out this critical task. Contact: Fazilet Cinaralp – Secretary General – email@example.com and Marianna Faino – Coordinator Environment & Transport – firstname.lastname@example.org – tel: +32 2 218 49 40.
FIA Region I is a federation of Motoring and Touring Clubs. FIA Region I represents the interest of these members as motorists, public transport users, pedestrians and tourists in Europe. Its primary goal is to secure a mobility that is safe, affordable, sustainable and efficient. Contact: Chris Carroll – Policy Director – email@example.com – tel: +32 2 282 08 18.
FIGIEFA is the international federation of independent automotive aftermarket distributors. Its members represent retailers and wholesalers of automotive replacement parts and components and their associated repair chains. FIGIEFA’s aim is to maintain free and effective competition in the market for vehicle replacement parts, servicing and repair. Contact: Sylvia Gotzen – CEO – Sylvia.firstname.lastname@example.org – tel: +32 2 761 95 10.
Insurance Europe is the European insurance and reinsurance federation. Through its 35 member bodies — the national insurance associations — Insurance Europe represents all types of insurance and reinsurance undertakings, eg pan-European companies, monoliners, mutuals and SMEs. Insurance Europe, which is based in Brussels, represents undertakings that account for around 95% of total European premium income. Insurance makes a major contribution to Europe’s economic growth and development. European insurers generate premium income of €1 200bn, directly employ over 940 000 people and invest over €10 100bn in the economy. Contact: Thomas Gelin – Policy Advisor – Tel: +32 2 894 30 48 – Gelin@insuranceeurope.eu
Leaseurope – the European Federation of Leasing Company Associations- represents both the leasing and automotive rental industries in Europe. The scope of products covered by Leaseurope members’ ranges from hire purchase and finance leases to operating leases of all asset categories (automotive, equipment and real estate). It also includes the short-term rental of cars, vans and trucks. Contact: Richard Knubben – Director – email@example.com – tel: +32 2 778 05 68.
UEAPME is the employers’ organisation representing the interests of European crafts, trades and SMEs at EU level. UEAPME is a recognised European Social Partner. It is a non-profit seeking and non-partisan organisation. As the European SME umbrella organisation, UEAPME incorporates 67 member organisations from 34 countries consisting of national cross-sectorial SME federations, European branch federations and other associate members, which support the SME family. UEAPME represents about 12 million enterprises, which employ around 55 million people across Europe. Contact: Dieter Grohmann – Director Communication and Media – firstname.lastname@example.org – +32 2 285 07 05 and Véronique Willems – Secretary General – email@example.com – +32 2 285 07 22.
UEIL (the Union of the European Lubricants Industry) represents the interests of the lubricants industry in Europe, with a special focus on SMEs and independent companies that produce lubricants and metal processing fluids essential for the automotive and industrial sectors. Contact: Jos Jong – Past President UEIL – firstname.lastname@example.org; UEIL: tel.: +32 2 504 90 03.
NEWS FROM BRUSSELS – After a two-year period following the emissions scandal, Members of the European Parliament have today, the 19th of April 2018, backed proposals to reform the type approval process for new cars, which it is claimed will guarantee that new models on Europe’s roads are ‘clean and safe’.
This new regulation introduces a new testing regime to ensure cars remain within emission limits throughout their lifetime and clarifies the responsibilities of national type approval authorities, testing centres and market surveillance bodies, in order to make them more independent and prevent conflicts of interest. This legislation also requires now every EU country to conduct a minimum number of checks on cars each year (i.e. at least one for every 40 000 new motor vehicles registered in that member state in the preceding year). At least 20 % of these tests will have to be emissions-related. For countries with a low number of car registrations, there will be a minimum of five tests to be conducted. The EU Commission will also be able to carry out tests and inspections of vehicles to verify compliance, to trigger EU-wide recalls and to impose administrative fines on carmakers of up to €30 000 per non-compliant vehicle.
This new legislation will also improve considerably the system of access to Repair and Maintenance Information (RMI), for example:
- the continued possibility to communicate with the vehicle’s technical information/data via the standardised on-board diagnostic connector, which is now better clarified and which makes clear that third party service providers should not be barred from accessing vitally important vehicle data when the vehicle is in motion (for read-only functions). This is a good first-step towards the adaptation of our sector with the digital economy and the connected vehicle.
- the information needed for preparation of vehicles for roadworthiness testing has been included into the RMI definition, as many consumers bring their vehicles to a workshop for preparation before undergoing the periodic inspection, and this information was unfortunately not available for test equipment manufacturers via the Roadworthiness Directive 2014/45/EU;
- an adaptation of the format of the RMI to the state-of-the-art, which means the technical repair information can also be obtained in an electronically processable form;
Next steps: The Regulation, approved by 547 votes to 83, with 16 abstentions, still needs to be formally adopted by the other co-legislator, the Council of the EU. The new rules will be applicable from 1 September 2020.
NEWS FROM BRUSSELS – On the 13th of March 2018, the European Parliament Plenary has approved the Transport and Tourism (TRAN) Committee Report on the Commission Communication “A European Strategy on Cooperative Intelligent Transport Systems” and voted in favour of amendments which among others, call upon the Commission to come forward with a regulatory proposal on access to in-vehicle data and resources by no later than the end of this year.
In its amendment n°20, the Parliament report states clearly that:
- Recommends that the Commission rapidly establish an adequate legal framework to achieve EU-wide cross-border interoperability, as well as a framework laying down rules on liability for the use of the various forms of connected transport; calls on the Commission to publish a legislative proposal on access to in-vehicle data and resources by the end of the year; recommends that this proposal should allow the entire automotive value chain and end users to benefit from digitalisation and guarantee a level playing field and maximum security with regard to access and storage of in-vehicle data for all third parties, which should be fair, timely and unrestricted in order to protect consumer rights, promote innovation and ensure fair, non-discriminatory competition on this market in respect of the principle of technological neutrality; stresses the need to contribute to the modernisation of all urban and rural infrastructures also linked to public transport services; calls on the Commission to guarantee that it will, in all cases, ensure full compliance with the GDPR, reporting to Parliament on its monitoring on an annual basis;
From our side, EGEA is very pleased to see that the European Parliament is taking actions and is calling upon the European Commission to come forward with a legislative proposal on access to in-vehicle data and resources that ensures fair competition, consumer choice, data privacy, cybersecurity and a vibrant high-quality automotive after-market sector, and this by the end of the year!
Indeed, innovation and service providers’ competitiveness in digital products will directly depend on their ability to have equal and undistorted access conditions to the vehicle, its data and resources compared to the vehicle manufacturers in terms of data content, quality, latency and the ability to present their services directly via the in-vehicle display to the automobile consumer.
On the 20th of July 2017, the Edition 2.1 (update of the 2nd Edition) of the Guide to application of the Machinery Directive 2006/42/EC has been publically made available on the Europa website for machinery sector and is available here: Edition 2.1 of the MD Guide_FINAL – July 2017. Please note that this Guide is available […]
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