Revision of the Vehicle Type-Approval Regulation : Analysis and Recommendations

On 29 March 2022, shortly after the publication of the proposal for a Data Act, the European Commission published the initiative “Access to vehicle data, functions and resources”. The background of this initiative is the long-standing conflict between vehicle manufacturers and a broad range of service providers in the automotive aftermarket and other complementary markets within the ecosystem of connected driving. Because the proposed Data Act alone, due to its horizontal approach, may not be able to solve this conflict, this initiative suggests additional sector-specific measures. The key question is which additional measures are necessary to ensure fair and secure access to vehicle data, functions and resources. This paper has been submitted as a neutral input to the initiative’s public consultation. We analyze, from the perspective of competition and innovation, the potential impact of the Data Act on this debate, and how the different policy options proposed in the initiative “Access to vehicle data, functions and resources”, in conjunction with the Data Act, intend to solve this problem. From this analyzes we derive policy recommendations for this sector-specific regulation as well as new questions with respect to the relationship between the initiative and the Data Act