VDA Statement
VDA Statement on NPRM "Connected Vehicles"
VDA Managing Director Dr. Marcus Bollig:
"The Notice of Proposed Rulemaking (NPRM) 'Connected Vehicles' introduces extensive new requirements for manufacturers of connected vehicles and vehicle connectivity systems.
The hardware and software variants of the vehicles resulting from the regulation will generate additional development costs. This will ultimately lead to a reduction in the synergies of a globally uniform technology and to increased costs for customers.
One thing is certain: Ensuring maximum security is in the best interests of the German automotive industry. The VDA is therefore pursuing a proactive approach to preventing cyber attacks and protecting connected vehicles. In principle, we welcome measures that contribute to the safety of vehicles. However, the requirements of the regulations must always be reconciled with technical feasibility and economic efficiency.
Therefore a blanket ban on certain vehicle components, as provided for in the NPRM 'Connected Vehicles', would not be reasonable. Thus, components that are not part of communication systems should not be covered by the regulation - for example, functions such as auxiliary heaters. The same applies to systems at levels 1 to 2+: levels of automated driving in which the driver is supported but always retains control and responsibility for the vehicle. These functions, which are not part of autonomous driving, would be covered by the current regulation, only because the wording is not clear. Many of these inaccuracies could be eliminated by a clear definition.
In addition, the proposed timeline for introducing the law is simply unrealistic. Most vehicles exported from the European Union to the United States contain software and/or hardware that falls under the NPRM. Completely converting supply chains in such a short period of time is extremely difficult and poses major challenges. We therefore recommend that the US side postpone the deadline for hardware and software until at least the 2030 model year - which would still be highly ambitious. The financial and time expenditure required for shorter deadlines would be disproportionate to the added value in terms of safety provided.
Last but not least, multiple regulations should be avoided at all costs: manufacturers already devote a lot of resources to complying with cybersecurity, as required, for example, in UNECE R 155.
The German automotive industry is clearly committed to the US-German trade partnership. Both sides benefit from the close trade relations: The German automotive industry employs 138,000 people in the United States of America. Of these, 48,000 work for automobile manufacturers and a further 90,000 for German suppliers. Production by German original equipment manufacturers (OEMs) in the USA will reach a record high of 908,000 cars in 2023. Around one in eleven light vehicles produced in the USA bears the logo of a German brand. Production by German OEMs grew by 10% in 2023, more than overall production, which increased by 5%."