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The European Automobile Manufacturers' Association (ACEA) supports the Commission’s objective of enhancing and ensuring a high level of cybersecurity for digital products and related services and of setting up a level playing field for vendors. This will help increase resilience against a continuously evolving and more complex cyber threat landscape.

TomTom wishes to provide feedback regarding the public consultation for the proposal for a regulation on horizontal cybersecurity requirements for products with digital elements (amending Regulation (EU) 2019/1020) published on the 15th of September 2022, the Cyber Resilience Act.

The European Automobile Manufacturers’ Association (ACEA) believes that the GPSD is still broadly fit for purpose and does not require a major overhaul. At the most, it could be revised in a targeted manner to update some of the definitions with a view to clarifying their applicability.

TomTom welcomes the fact that Type-approval for motor vehicles and the General Safety Regulation (GSR) are both listed as “Union harmonization legislation” covering the automotive sector. Obligations on economic operators and their placing on the market of products defined in the GPSD proposal only apply when obligations are not yet covered by Union harmonisation legislation.

Dear Sir, Ma'am, Please find below ACEA Position and feedback to the consultation. Logically, vehicles can clearly be identified by the individual VIN-Number and it is in the interest of vehicle manufacturers that our customer's are aware of the product manufacturer or recall actions triggers for used goods.

ACEA welcomes the opportunity to provide feedback on the European Commission’s Inception Impact Assessment on adapting liability rules to the digital age and circular economy. We provide detailed observations on this initiative in the document attached.

TomTom wishes to submit feedback on the Product Liability Directive together with fellow location technology provider HERE Technologies. Our position paper gives feedback on both the Product Liability Directive and the AI Liability Directive. Please refer to our position paper for full details.

ACEA welcomes the opportunity to provide feedback to the Commission (EC) on this Inception Impact Assessment on the revision of the ITS Directive. Please refer to our detailed response attached to this summary. We agree with the EC that attention should be given to the lack of interoperability and cross-border continuity of applications, systems and services.

HERE and TomTom wish to provide feedback to the proposal of the European Commission to amend Directive 2010/40/EU on the framework for the deployment of Intelligent Transport Systems in the field of road transport and for interfaces with other modes of transport. We acknowledge the Commission’s endeavor to increase the deployment and operational use of ITS services across the EU.