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.
TOM
TomTom
Company · Netherlands · EU Transparency Register 068100722742-39
7
positions filed
in the 583 files tracked
7
legislative files
of 583 tracked
3
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1048 companies & groups on this site, they rank #157 by legislative files engaged — a count of participation, not a measure of influence.
1.8
declared lobbying FTE
self-declared
€300K+
declared costs / yr (floor)
0
EP accreditations
as declared to the register
2016
in the register since
Declares membership of
- Active members in TISA (www.TISA.org)
- Active member in CLEPA (www.clepa.eu)
- Active member in ERTICO ITS Europe (www.ertico.com)
Self-declared to the EU Transparency Register (snapshot 2 Sept 2026).
- Register category
- Companies & groups
- Registered as
- TomTom International bv (TomTom)
- Head office
- Amsterdam, Netherlands
Self-declared to the EU Transparency Register (snapshot 2 Sept 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
Track TomTom in PolicySpeak: request access →
Work at TomTom? so we know who speaks for it.
Their record over time
TomTom filed 7 positions between 27 Aug 2019 and 23 Jan 2023, across 7 of the 583 legislative files tracked here, attaching a full position paper 3 times.
2019 · 1 filed2021 · 1 filed2022 · 4 filed2023 · 1 filed
What they argued
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.
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.
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.
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).
TomTom welcomes the prospect of a new European Partnership for safe and automated road transport via the Horizon Europe programme. It is essential that the development of the Partnership's work programme is conducted in a fair and transparent manner giving industry the possibility to shape research topics along with governmental bodies. The new EU CCAM Platform should be a key instrument to drive this activity.
Looking for an argument rather than an organization? Search every submission for a phrase and see everyone who used it.
Put TomTom next to another organization. Same files, same register facts, side by side. Compare →
Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers — not evidence of coordination, and we do not suggest any.
Showing 5 of 57.
Is this your organization?
Everything on this page comes from TomTom’s own submissions to the European Commission — we have added nothing and interpreted nothing. If something is wrong or out of date, email info@policyspeak.com and we will correct it. If you are an individual named in a record, our privacy policy sets out your rights to correction, objection and removal.
Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.