ETSC response to the European Commission’s proposal on the Small Affordable Cars initiative

The European Transport Safety Council (ETSC) is deeply concerned by the European Commission’s approach to small car safety timelines and its unprecedented reliance on industry demands in the Small Affordable Cars initiative announced today.

Urban vehicles need the highest safety standards, not delays

We welcome the Commission’s decision to classify the new “Small Electric Vehicle” (M1E) sub-category within the existing passenger car (M1) category. This ensures that these vehicles must comply with all of the existing EU vehicle safety standards.  

However, ETSC is alarmed by the Commission’s explicit intention to use this new definition to “freeze” safety requirements for 10 years for this category.  The proposal justifies this by citing “development costs”, but fails to address the operational reality of these vehicles.

Small electric vehicles are designed primarily for urban environments – the exact locations where interactions with vulnerable road users are most frequent. Technologies such as Automated Emergency Braking (AEB) with pedestrian and cyclist detection are designed precisely to save lives in these settings. If the Commission delays the application of the latest generation of these technologies to the very vehicles most likely to encounter pedestrians and cyclists in city centres, it will be a dereliction of duty. We cannot accept a two-tier safety system where “affordable” urban cars lack the latest protection for the people outside the vehicle.

Antonio Avenoso, Executive Director of the European Transport Safety Council, commented:

“It makes no sense to delay life-saving safety features on the very vehicles that will spend most of their lives on busy city streets surrounded by pedestrians and cyclists. Affordability is important, but it should not be achieved by cutting corners on safety.”

Regulation should be based on public interest, not car industry wishlists

It is an extraordinary development that the Commission’s own explanatory text explicitly cites the list from ACEA (the European automobile manufacturers association) as a primary reference point for this legislative review. The text openly references the industry’s complaints regarding upcoming legislation and details how the Commission reviewed this list to identify amendments.

The role of the European Commission is to assess risk and protect the public interest, not to legislate based on the demands of the entities being regulated. While reducing administrative burden is valid, using an industry wish-list as the baseline for reviewing safety and environmental laws sets a dangerous precedent for EU governance.