Briefing on risks to the EU vehicle market and road safety of recognising US-market vehicles as ‘equivalent’

March 19, 2025

Context

The US government under President Trump is pursuing an aggressive trade policy towards the European Union, threatening tariffs of 25% on cars and other goods.

ETSC understands that the US has expressed a desire for US and EU vehicles to be considered as ‘equivalent’, enabling US-market vehicles to be sold in the European Union without meeting the EU’s own standards.

This would be a catastrophic mistake, and the consequences would be measured in the deaths of men, women and children on EU roads.

The EU and US have developed their separate vehicle safety standards over several decades, based on local traffic conditions, their particular fleet makeup and the regulatory environment. These all have a role in the overall level of safety.

ETSC believes that the top priority with regard to vehicle safety is that the highest standards are maintained and there is no opportunity now or in the future to weaken them, or delay tighter standards.

Road safety trends in the US and EU

Since 2013, road deaths in the EU have decreased by 16%.[1] Higher vehicle safety standards are a key driver of this improvement.

In the US, over the same period road deaths have increased by 25%.[2] While there are likely to be multiple causes for this increase, the transition to larger, heavier SUVs and light trucks, as well as weaker vehicle safety requirements has played a key role.

Are EU and US standards equivalent?

ETSC was a stakeholder consulted on vehicle safety issues during negotiations for TTIP during the Obama administration. Our analysis at that time concluded that EU and US standards are not equivalent. [3]

A study commissioned by the car industry found that EU models were, on average, 33% safer in terms of risk of a serious injury in common front-side crashes. [4]

There are no pedestrian protection requirements in the United States

A fundamental difference in policy approach between the two markets is that EU vehicle safety policy takes account of all road users, not just those protected inside motor vehicles.

The EU has had pedestrian protection requirements affecting vehicle front end design for cars and vans since the mid-2000s, which have been upgraded in the years since. [5] The United States has no such requirements.

How have EU and US standards diverged since the TTIP negotiations ?

Since March 2018, all cars and vans in the EU are required to be fitted with an automated emergency calling system known as e-call, which can operate in the event of a crash in the case where the driver may be unable to call for help. [6] The US does not require mandatory fitting of an emergency calling system.

Since September 2019, the EU has required that all new cars be fitted with seatbelt reminder systems in all front and rear seating positions. [7] The US does not currently require reminders apart from on the driver’s seat – though could introduce such a requirement in 2026-7 if the new administration maintains a new Biden-era rule. [8]

Since July 2022, new vehicles sold in the EU have been subject to a newer and significantly safer standard defined in the updated General Safety Regulation [9]. The entry into force of the various standards depends on the vehicle type and applies first to new types, with longer lead times for new vehicles already on the market. [10]

New safety features required in all new vehicles in the EU from July 2024:

Intelligent speed assistance
Reversing detection with camera or sensors
Attention warning in case of driver drowsiness
Emergency stop signal
Cybersecurity measures

Additional features required for new cars and vans:

Lane keeping assistance
Advanced emergency braking detecting obstacles and moving vehicles ahead
Event data recorders

Additional features required for new buses and trucks:

Detection and warnings to prevent collisions with pedestrians or cyclists
Tyre pressure monitoring systems (already required for cars and vans)

Further measures to be progressively introduced for all new vehicles in the EU between July 2024 and July 2029

Advanced driver distraction warning
Safe and longer-lasting tyre performance

Additional features required for new cars and vans:

Safety glass
Advanced Emergency Braking systems that can detect pedestrians and cyclists

Additional features required for new buses and trucks:

Improved direct vision
Event data recorders

The new safety measures will help to better protect passengers, pedestrians and cyclists across the EU, and are expected to save over 25,000 lives and avoid at least 140,000 serious injuries by 2038.[11] The vast majority of these new requirements are not required by US legislation. Backup cameras have been a requirement on new US cars since 2018. The US had planned to require Automated Emergency Braking as of 2029 – but that rulemaking has been suspended by the Trump administration. [12]

Vehicle automation

The US and EU have very different approaches to vehicle automation. Tesla’s “Full Self Driving” driver assistance system has been allowed to operate legally on American roads, but is subject to mandatory incident reporting and is currently under investigation by US federal authorities.[13] Tesla’s FSD system is not permitted on EU roads. In the EU such systems are regulated by EU and UNECE regulations, and are subject to vehicle type approval testing. If the EU were to consider US vehicles as ‘equivalent’ to complying with EU standards, would that extend to automation functions? If so, how would such systems be regulated as the EU has no central regulatory authority for vehicle safety or crash investigation ?

For further information on the status of EU rules on Level 2 driver assistance systems see: https://etsc.eu/un-working-party-cautious-on-driving-features-that-blur-the-lines-between-human-and-automated-driving/

The Individual Vehicle Approval loophole

Thousands of American-market pickup trucks, such as the RAM and Ford F-150 are currently being sold in Europe through a loophole known as Individual Vehicle Approval. [14] These vehicles are not type-approved for the EU market, and are given approval by national authorities based on a much more limited set of requirements designed originally for vehicles modified for disabled drivers, for search and rescue operations or other special purposes.

Close to 5,000 RAM US-market pick-up trucks were imported into the EU in 2023 and approved under the IVA scheme, up from 1,800 in 2019.

For a pedestrian or cyclist hit by a pick-up, the risk of serious injury increases by 90% and the risk of fatal injury by almost 200%. [15] It is essential that we close this loophole, not open the floodgates (via ‘equivalence’) to an invasion of thousands more of these vehicles as well as large, heavy and tall US SUVs built on truck platforms.

After the 20% increase in RAM imports recorded between 2022 and 2023, the Commission said that it “is committed to addressing the [IVA] issue as soon as possible,” including “making sure that the IVA rules are only used for the customized vehicles and individual imports for which they were designed, as opposed to large numbers of mass market vehicles” (Politico, 7 July 2024).

Following in the path of RAM, other US-market vehicles are increasingly being imported using IVA, as shown by the examples in the table below (2024 data not yet available).

Sharp increases in other mass market vehicles imported using IVA

	2022	2023	Year on year rise
Chevrolet Silverado	47	288	513%
Chevrolet Tahoe	13	72	454%
Ford Bronco	101	238	136%
Cadillac Escalade	59	124	110%

Source: EEA data, analysis by Transport & Environment

The rate of rise is of most concern – with the clear potential to follow the RAM pattern (in a do-nothing scenario). Equally concerning: in Jan 2025 Ford started selling IVA vehicles from its own showrooms, e.g. F150s from Ford dealerships in Belgium. [16]

The issues highlighted here are referred to in the Commission’s recently-published Automotive Action Plan which states that “the enforcement of the regulatory framework for motor vehicles is important to ensure a level playing field and avoid circumvention of the applicable EU rules across the board. This is primarily a responsibility for national type-approval authorities, but the Commission will work with Member States to address potential gaps in the regulatory framework, e.g. in individual vehicle approval schemes”. [17]

If the US proceeds with the threatened tarifs on EU vehicles, the EU could consider a rebalancing measure on US pick-ups – this would provide a clear and immediate road safety benefit in advance of modifications to the Individual Vehicle Approval scheme.

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