20.09.2013
Key Positions

Road Traffic Safety and Mobility

On European and national level, several measures are currently being prepared whose impacts on markets and consumers have to be carefully assessed.

As from 2015 all new vehicles registered in the EU will have to be equipped with an eCall-system that sends after a serious accident an alarm signal – automatically or manually – with information on the location and condition of the vehicle to an emergency response center. Every new car will be factory-equipped with the respective communication technology. In the realm of the “connected cars”, this provides the car manufacturer also in case of a breakdown or a minor accident with the access a large quantity of data and the direct possibility of communication into the vehicle. The car manufacturer is thus in the position to procure privileged contact with customers at the expense of other market players (e.g. independent workshops, automobile clubs and insurance companies). The insurance industry supports the EU’s eCall Initiative, provided the customers retain control over their data and the means of communication and are in the position to freely choose their service providers. To this aim, other market players must not be cut off from access to their customers.

The European Commission is currently preparing rules to simplify the purchase and transfer of private vehicles and vehicle fleets within the European Single Market. In the end, however, the proposals will not improve the situation of consumers or lead to more safety on European roads: If, for instance, a buyer wants to transfer a used car purchased and de-registered in an EU member state on its own wheels to Germany, he needs an (interim) registration for the trip to the German border in accordance with the law of the country of purchase and has to negotiate this with the foreign authority while encountering the respective language barriers. Moreover, the rules foreseen for commercial vehicle users will allow commercially used vehicles to be moved to other member states under reduced inspection and registration requirements. Under these circumstances, the free movement within the Single Market will be “purchased” at the expense of reduced control of the roadworthiness of these vehicles, whereas the roadworthiness of vehicles is a key prerequisite for their insurability.

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The recording and deletion of points for traffic offences in the Flensburg Central Register of Traffic Offenders is for the driver difficult to understand. Though drivers have the right to information about their points status, they cannot rely on the information given by the Federal Motor Transport Authority. Currently, a driver’s points account is only reset to zero when the period for the last entry has expired. If new points are added after the deletion of the old points, however, the old account is reanimated if the day of the new offence was within the period of the old points. The insurance industry supports all reform efforts in favor of a more transparent rule, above all with the aim of increasing road traffic safety. Therefore, only offenses related to road traffic safety should be assigned with points and the attendance at psychological driver awareness programs be made mandatory. It is all the more regrettable that the proposal of the German Traffic Court Day (Deutscher Verkehrsgerichtstag) was rejected.

Our Positions
Connected car: Ensure free access to digital interfaces
Every vehicle owner disposes the control of the data generated by his or her vehicle. This is the only way for the owner to retain the freedom to decide whether and to whom these data should be provided—no matter whether as driver or keeper of the vehicle, being involved in an accident or as an insurance customer. For this purpose, non-discriminatory access to these data in the form of an “open digital interface” in the vehicle is indispensible, enabling free and fair competition for all market participants. Vehicle owners should be free to decide themselves to whom and for what purpose they want to provide their vehicle’s data. Access to telematic services and information from and into vehicles may not be monopolised.
Design the Vehicle Registration Regulation in a consumer friendly way
Simplifications in cross-border road traffic are desirable. However, they may not undermine national rules on road safety control and the enforcement of the insurance obligation.
It should be easy for consumers to purchase a vehicle from another member state. For this purpose, a European-wide recognized temporary license plate, linked to insurance cover, should be created , which the buyer can bring from his member state to the country of purchase and attach to the purchased vehicle for the trip home.
Reform the Central Traffic Register
The overdue reform of the Central Register of Traffic Offenders should not fail just because it does not completely satisfy all interested parties. However, the insurance industry considers the maintaining of the “extended” data storage period to be inevitable. Moreover, the insurance industry assumes that the foreseen focus on road traffic safety related offenses and the new concept for the obligatory psychological driver awareness program upon reaching a certain limit of points are the right moves. The German insurance industry expects the adoption of the reform by the legislator within the current legislative period.
Simplify alcohol limits
The rules governing driving under the influence of alcohol are incomprehensible for non-lawyers. The law sets various limits (between 0.3 and 1.6 per mill) and provides different degrees of sanctions depending on the anomalies of the driving behavior and the means of transport (see below for driving a car under the influence of alcohol). The insurance industry advocates the Traffic Court Day and the legislator to tackle these rules and to shape them more simply, transparently and effectively.
Keep the deadlines for main vehicle inspections
The shortened inspection periods proposed by the European Commission for older cars cannot be justified scientifically. The periods applicable in Germany have proven themselves and should be preserved. At most, a reduction to a one-year period could be considered for vehicles older than twelve years.