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CLEPA Position Paper on Artificial Intelligence

For a coherent regulatory framework that ensures safety and trust

Automotive suppliers play a central role in the development of connected and automated vehicles. Artificial intelligence (AI) applications are becoming more commonly integrated in vehicles: automated driving is the most well-known example, but a broad range of other applications are also being used, such as many vehicle safety functions, comfort functions, advanced driver-assistance systems, connectivity systems, infotainment systems, and others.

CLEPA believes that an appropriate legislative framework can boost the development and uptake of AI by providing market participants more legal certainty and by bolstering consumer trust. We support a risk-based approach as outlined in the Commission’s White Paper on AI as it is more likely to ensure proportionality. In this respect, the term “high-risk” should be defined clearly. From our perspective, an AI application should be considered high-risk if it can cause personal injury or death.

CLEPA stresses the importance of not hindering innovation unnecessarily. Requirements should always remain proportionate to the risks and leave enough room for testing/prototyping. A balance must be achieved to ensure that the goals of this new initiative do not jeopardise the development of safer vehicles, given the contribution they can make to the EU’s road safety objectives.

CLEPA supports a horizontal AI legislation addressing only high-risk AI applications and ensuring a level-playing field for all actors. These principles can be complemented with technical requirements in sector-specific regulations (either new or by modifying existing legislation), if deemed necessary.

The automotive sector is already subject to strict ex-ante conformity controls, such as the type-approval process. High-risk AI-related technical requirements for automotive products should be implemented into the existing sectoral framework. Certification, testing, and market surveillance should not be duplicated, to avoid additional costs, administrative burdens, or any risk of inconsistencies.

Workstreams should be coordinated to avoid duplication and/or conflicting requirements. Discussions on automated driving are ongoing at the UNECE, where the EU, represented by the Commission, is taking a leading role. The EU itself is also looking into automation regulation, in the Commission’s Motor Vehicle Working Group (MVWG). The EU legislative framework on AI and the UNECE requirements for Automated Driving Systems should be aligned, with future UNECE requirements to be considered valid AI-related requirements, instead of another added regulatory layer.

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