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SMEunited welcomes the initiative for harmonised rules regarding cyber resilience. Manufacturers and developers must be liable to ensure cybersecurity, not sellers. The Cyber Resilience Act must be precise regarding when cybersecurity must be ensured: assessments during the whole lifetime of a product would be costly. We recommend a mixed approach, combining both soft and hard rules.

We welcome the proposal on horizontal cybersecurity requirements as it includes several of SMEuniteds preliminary requests. Indeed, a patchwork of rules would hamper the ability of manufacturers of digital products, especially of small and medium size, to operate and scale up across European markets. To ensure legal certainty, we insist that the requirements must be defined precisely.

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.

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.

Key messages According to SMEunited the proposal contains several provisions and approaches which are very positive, such as: - the need for uniform market surveillance in the EU, - the general approach to AI, - the formal recognition of the imbalance between the rules for physical stores and those for digital platforms.

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.

SMEunited welcomes the proposal as updated liability rules are necessary to account for the necessities of a digitalised world and a circular economy. Below our main take aways: - The proposal must take into account that an increased liability comes together with higher prices for European products. - Entrepreneurs require clear rules in order to make their business decisions.

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).

SMEunited welcomes the aim to provide more clarity and legal security for businesses engaging with AI in EU Member States and especially for businesses trading across borders. Bringing minimum levels of protection is appropriate but must take into account the size and resources of the different economic actors.