Comment on the Proposal of the EU Commission
In general, the ITS directive primarily represents a work program for the Commission by creating a legal basis for the adoption of delegated acts1. A final evaluation of the directive is therefore only in principle possible once these acts are available. In the future, the EU Commission should involve such stakeholders as the industry even more closely in the development of specifications and the creation of regulations based on the ITS directive. The VDA comments on individual points in the present proposal below. These are mainly questions about the details and further procedure, the timely concretization of which would be helpful for an evaluation of the proposed measures.