International Federation of Automotive Aftermarket Distributors Boulevard de la Woluwe 42 Box 5 BE-1200 Brussels
Tel.: +32 2 761 95 10 Fax: +32 2 762 12 55 E-mail: firstname.lastname@example.org Web: www.figiefa.eu
Bank: 310-1494130-28 IBAN: BE37310149413028 BIC: BBRUBEBB V.A.T.: BE-472205007
Brussels, 26th September 2014
Trilogue discussions on eCall Regulation
Type-approval requirements for the deployment of the eCall in-vehicle system
FIGIEFA Position paper
FIGIEFA welcomes the EU’s eCall initiative and fully supports the Europe-wide mandatory introduction of eCall in all new type-approved cars and light commercial vehicles. This represents an important initiative to reduce fatalities and the severity of injuries on Europe’s roads.
However, eCall cannot be treated in an isolated manner: eCall will bring the underlying telematics technology into every new car. An in-vehicle eCall system provides telematics functions and often shares the same basic hardware and software components that can also be used for other telematics system functionalities. This technology can thus be used to transmit any live data from the vehicle to the manufacturer. Therefore the major threat is that - without any EU legislation which provides for the sharing of the information - only vehicle manufacturers are able to obtain this data wirelessly and thus exclusively. This gives vehicle manufacturers a game-changing advantage and will undermine the ability of all aftermarket operators to offer competitive spare parts, repair or maintenance services and to contribute positively to the EU economy, in line with the EU Single Market principles.
The only way to ensure fair competition, true choice for the EU’s 260 million motoring consumers and to maintain the independence of more than 400.000 aftermarket companies is online access to vehicles, via a ‘standardised, interoperable, secure and open platform’.
The European Parliament in its Positon adopted on the 26th of February 2014 on the Commission Proposal addresses this issue in Article 10a para.3.
FIGIEFA very much welcomes this new Article and the mandate given to the Commission to start working on an open-access platform in view of issuing a separate legislative proposal, following a broad stakeholder consultation and an impact assessment.
With this mandate, the introduction of eCall will neither be
affected nor delayed, but at the same time the Parliament ensures that the Commission will start tackling the ‘open platform’ separately within a short term period and without delay.
However, FIGIEFA regrettably noticed that the Council did not include a similar reference to the ‘interoperable platform’ in its ‘General Approach’ on the Commission’s text as adopted at the Competitiveness Council on the 26th of May 2014. In fact, the Council only provided in Art. 5, par. 6 that the eCall system shall be accessible for repair and maintenance purposes “in accordance with the Euro 5/6 Regulation”. However, this reference is not sufficiently robust to ensure a true level playing: the “nondiscrimination principle” in the Euro 5/6 Regulation refers only to the authorised network and is neutered in the digital era, as telematics live data are directly channelled to the vehicle manufacturer.
Therefore, FIGIEFA calls upon Member States’ represented in the Council to support in the course of the trilogue discussions the ‘interoperable, standardised and secure open platform’ as provided for in the proposed Art. 10a, par. 3 of the EP. This would ensure a level-playing field for all market operators, to the benefit of Europe’s consumers, businesses and economy.