Compare organizations

Bitkom appreciates the opportunity to provide feedback on the Commissions proposal for a Cyber Resilience Act. Please find our position paper attached. We welcome the proposal to create a more efficient legal framework to improve cybersecurity in Europe. Nevertheless, some important aspects should be optimized and clarified during the legislative process.

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.

For Bitkom and its members, the safety of the products placed on the market is the top priority. Therefore the General Product Safety Directive (GPSD) has a high priority for us and we appreciate the opportunity to provide feedback on the roadmap for its revision. Since its enforcement the GPSD has made a significant contribution to the safety of consumer products.

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.

Bitkom welcomes the opportunity to provide feedback on the European Commission’s Inception Impact Assessment on adapting liability rules to the digital age and artificial intelligence. Please find our detailed position 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.

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.

Bitkom welcomes the EU Commission's initiative with the aim to facilitate the use of data for a smarter, safer, and sustainable mobility ecosystem. However, we would like to also underline that relying on market principles will be key to fostering the enormous potential of data-driven solutions in the field of mobility.

Considering the parallel cross-sectorial legislative proposal on liability (the revision of the product liability directive from 1985) and the potential overlap between these two pieces of legislation, TomTom would like to submit detailed comments on both files simultaneously during the PLD consultation (closing on 9th December 2022).

In principle, Bitkom welcomes the fact that the draft AI Liability Directive aims to regulate the first fundamental questions of liability in the event of damage arising from the use of AI. However, we believe that additional liability rules in this form would not have been necessary. Rather, they could have a negative impact on the application and further development of AI technologies.

Filed in German · English published by the European Commission