Compare organizations

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.

BEUC welcomes the European Commission proposal on the Cyber Resilience Act (CRA). This proposal answers a longstanding need that BEUC and its members have identified and warned about repeatedly. Over the past years, BEUC members have demonstrated that too many connected products sold on the European market lack even the most basic security features. Too many products are putting consumers at risk on a daily basis.

BEUC strongly welcomes the announcement of the European Commission to review the General Product Safety Directive. We agree to the problem definition as outlined in the roadmap which emphasises the challenges posed by new technologies, e-commerce and a fragmented legislative framework for market surveillance.

BEUC strongly supports the draft for a General Product Safety Regulation. We agree on the objectives and welcome: • The underlined value of the safety net function and precautionary principle • Coherent market surveillance rules between harmonised and non-harmonised products as well as the new tools given to Member States • Stronger traceability in the supply chain and a greater responsibility for safety of online…

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.

BEUC welcomes the possibility to give feedback on the European Commission’s Inception Impact Assessment on “Civil liability – adapting liability rules to the digital age and artificial intelligence”. BEUC recommends a comprehensive upgrade of the EU Product Liability Directive, which was adopted 36 years ago and is therefore no longer adapted to cope with the challenges brought by new technologies.

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.

BEUCs preliminary feedback on the PLD proposal: BEUC, the European Consumer Organisation, welcomes the initiative of the European Commission to revise the Product Liability Directive (PLD). However, the European Commission proposal (the proposal) does not sufficiently address fundamental issues like the subsidiary liability of online marketplaces, the burden of proof, the liability exemptions as well as the…

BEUC reaffirms the urgent need for a strong regulatory framework on access to vehicle data, functions and resources. The problems are well identified and have been presented to the Commission on several occasions, notably during a wokrshop on 17 September 2021. We provide a detailed feedback in the document attached.

As Europe’s leading independent location technology specialist, TomTom appreciates the opportunity to provide feedback to this call for evidence for an impact assessment on access to in-vehicle data. TomTom welcomes additional sector-specific legislation regulating access to in-vehicle data, as the Data Act is too general to sufficiently cover the complexity of a product such as a connected car.

BEUC welcomes the foreseen revision of the ITS Directive and joins the Commission in its assessment of the three key problem drivers for the swift deployment of ITS infrastructure. We also fully support the Commission in its intention to make use of a stronger ITS Directive to achieve the European Green Deal objectives.

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.