In two initiatives, namely a Delegated Act amending Annex II to Regulation 2018/858 and an Implementing Act for Regulation 2019/2144, the European Commission is currently updating type-approval requirements and introducing technical specifications for fully automated vehicles. The initiatives restrict type-approval for automated vehicles to small series.
Overall, Bitkom welcomes the EU’s initiative to set out clear requirements for the type-approval of automated vehicles. However, the limitation to small series threatens to hamper innovation and the acquisition of valuable experience.
Therefore, Bitkom proposes the following:
Insert an opening clause to ensure national flexibility.
Increase the quantity limits of the small series regulation.
Set out a timeline to move from small series to unlimited series type approval.