Nyheder Our Feedback to EC 27 April 2022

Have your say - Automated cars

You can also get involved in forming EU laws. The European Commission would like to hear your views on laws and policies currently in development. They offer a platform "Have your say" with the list of all new EU initiatives open for public consultation. You need to register to write your feedback.


There are always 5 stages of each EU initiative, each stage is open for public consultation for a specific time frame:

  1. In preparation

  2. Call for evidence

  3. Public consultation

  4. Draft act

  5. Commission adoption

Automated cars – technical specifications

About this initiative: From mid-2022, new EU rules will apply (Regulation 2019/2144) governing  modern technologies used in vehicles, to improve road safety and reduce pollution. This initiative introduces specific requirements for automated and fully automated (‘driverless’) vehicles and the systems they employ, to ensure that they are safe to use.

Feedback period: for stage 4 it was 07 April 2022 - 05 May 2022

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12152-Automated-cars-technical-specifications_en

Feedback from Europeans for Safe Connections

We "Europeans for Safe Connections" are very concerned with this initiative.

There are several problems that need attention:

- In general, civil rights and privacy is at stake with the information flow as proposed.
- Passengers data and travel data should legally not be available for other purposes than travel related issues.
- A compartmented approach is proposed for the processing of data.
- Data minimisation must be applied as prevention of stealing

We suggest that among technical specifications the following is described:

- personal data of passengers are always maintained locally only
- platform for passengers authorisation and platform for travel data are strictly separated
- platform for passengers authorisation should not be connected to the network
- finished route coordinates is deleted from the system by default. User can choose to save it.
- all Sensor Data are deleted when the navigation is finished. This is default preset. However, user can choose to save it. This is called "opt-in" system for sensor data saving.
- all sources of radiofrequency electromagnetic fields are exactly specified. By default they must be turned off. A user can turn them on one-by-one.
- devices used for communicating with other cars must not irradiate the interrior of the car and must not irradiate the interrior of cars around
- guiding by satellites whose owner is outside the EU will be forbidden

We suggest that before introduction of automated driving system (ADS) of fully automated vehicles, these preparations are be made:

- launch an impact assessment on personal data protection and evaluate compliance against current data protection laws.

- ensure public transport offers Wi-Fi and radiation free options. This means, we must keep traditional transport means in parallel to automated trams, busses, metros, trains. If not, sensitive people would be discriminated against.

- In each car encorporate broadband meter of RF EMF. Actual peak intensity (not average) must be visible on a car display. Also ensure that passengers are informed about this radiation with labelling. Hazardous areas (including cars and public transport) must be properly and visibly marked at entrance with warning signs "Caution non-ionizing radiation" for the protection of the population and a warning sign for citizens with pacemakers and other implants.

- organize public debates whether or to what extent to authorise digital innovations. It is clear that the ADS will include a large number of radio frequency (RF EMF) emitting devices, plus more and more small cells will be installed along the roads. Vehicles using electric motors also generate higher values of magnetic fields. All this should be taken into consideration, when introduce digital innovations.

Best regards
Petra Bertova Polovkova
on behalf of Europeans for Safe Connections


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