Berlin, 7. March 2025 - The European Commission's Industrial Action Plan for the European automotive sector (COM(2025) 95) sets important priorities for the European automotive industry, particularly in the areas of electrification, digitalisation and supply chain resilience. Although the plan provides a good basis for the future development of the sector, it does not take into account key aspects that are essential for a safe and sustainable transformation of the industry. For the TÜV Association, the future of the automotive industry depends heavily on a balanced regulatory framework that promotes safety and innovation in equal measure while protecting public interests. In particular, the action plan lacks clear measures on road safety in automated driving, the strengthening of independent third-party assessment and a standardised procedure for testing the condition of batteries in the used car market.
In principle, it should be noted that the announced evaluation of the Regulation on the authorisation and market surveillance of motor vehicles (2018/858) in 2026 with the aim of regulatory simplification must not lead to a weakening of the necessary level of vehicle and road safety in Europe. Through their services, independent third parties help to ensure that new technologies fulfil regulatory requirements efficiently without placing unnecessary burdens on companies.
Road Safety and Automated Driving
The EU Commission does address the potential of autonomous and connected driving to strengthen Europe's global competitiveness in its action plan. However, the topic of road safety, as the basis for trust and acceptance of the technology among the population, is neglected in the overall presentation. It is still unclear how the high safety performance of vehicles demanded by the EU is to be measured or proven in a concrete and comprehensible manner - especially when algorithms and AI-based systems (e.g. for SAE level 4 applications) take over crucial driving functions.
As part of its action plan, the EU should not only promote a technological approach to automated driving, but also a responsible safety approach. This includes standardised EU-wide safety and testing procedures in which all relevant risks are made transparent, including interaction with conventionally driven vehicles. Safety-relevant AI systems should continue to be trained with verified real-world data and not directly updated with environmental data obtained from moving traffic.
Independent vehicle inspection remains vital
While the action plan incentivises investment in innovation, it remains unclear who will oversee technical safety in the long term. The plan relies heavily on national authorities, but does not mention the role of independent assessment authorities. Furthermore, the plan ignores how, for example, safety-critical software updates should be integrated into the Periodic Technical Inspection (PTI). The EU Commission's current plans for access to vehicle-generated data do not go far enough. A mere extension of the Data Act is not enough to address the specific challenges of the automotive industry.
What remains necessary is sector-specific legislation that ensures that independent players in vehicle inspection have direct access to relevant test data in order to assess (over-the-air) software updates, safety functions and freedom from manipulation. The establishment of an EU-wide compatible register for vehicle data and history must also be further promoted, especially in order to achieve mutual recognition of registration documents in the EU. The systematic involvement of independent assessment organisations in approval and monitoring procedures remains necessary in order to ensure transparency and safety throughout the entire vehicle life cycle
Battery State of Health (SoH) – Transparency in the second-hand car market
Sector-specific regulation remains necessary to ensure that independent vehicle inspection stakeholders have direct access to relevant testing data in order to monitor (over-the-air) software updates, safety functions and freedom from manipulation. The establishment of an EU-wide compatible register for vehicle data and history must also be further promoted, especially in order to achieve mutual recognition of registration documents in the EU. The systematic involvement of independent Technical Services in approval and monitoring procedures remains necessary in order to ensure transparency and safety throughout the entire vehicle life cycle.
In its action plan, the EU Commission also emphasises that retrofitting conventional commercial vehicles - especially buses - with an electric drivetrain can make a cost-effective contribution to the decarbonisation of vehicle fleets. Recommendations for the assessment of corresponding conversion measures are already available at a national level. The TÜV Association has published a technical leaflet on the individual approval of electric vehicles, which can be downloaded from its website: Electric vehicles in the individual approval procedure (MB-FZMO-764).
Central questions of safety are neglected
Although the EU action plan for the automotive industry creates a good basis, it falls short in addressing key issues of safety and trust in new technologies. In order to make the transformation of the industry safe, sustainable and consumer-friendly, the EU Commission should, among other things:
- Regulate the safety of AI driving functions with clarity and establish EU-wide harmonised testing and approval procedures, taking into account existing national regulations in the EU member states.
- Involve independent assessment organisations more closely to ensure continuous safety checks and transparent certifications.
- Establish reliable criteria for a standardised SoH assessment procedure for batteries in order to strengthen the used car market and prevent tampering
Only by taking these aspects into account can the transformation of the automotive industry be successful and future-proof. It is important that all players in the sector are involved in further shaping the industry so that a strong European single market for clean, future-proof and digital mobility can develop. The TÜV Association therefore welcomes the continuation of the strategic dialogue on the future of the automotive industry in Europe. CITA should be closely involved in this dialogue as a central international player in independent technical vehicle inspection. From the TÜV Association's point of view, one thing is certain: only with joint and consistent efforts - at both European and national level - can the goals set for a future-proof automotive industry be achieved that is climate-neutral, digital and therefore also competitive.