The EU and the US have issued a joint statement on a framework agreement for mutual, fair and balanced trade – a so-called Mutual Recognition Agreement (MRA). In Section 8 the agreement explicitly addresses the automotive sector. The aim is to mutually accept and recognize each other's standards – but without automatically adopting the respective national regulations.
Maintaining European vehicle safety standards
From the perspective of the TÜV Association, agreements such as the MRA must not lead to the automatic recognition of US vehicle approvals in the EU. This is because the safety and environmental requirements for vehicles in the US and Europe differ considerably in relevant areas – for example, in terms of pedestrian protection, crash scenarios and the infrastructural design of mobility.
European type approval – regulated by EU Regulation 2018/858 in conjunction with the General Safety Regulation – ensures a high and established level of safety. This must not be watered down or circumvented by a trade agreement.
The TÜV Association's recommendations on the Mutual Trade Agreement
- No automatic recognition of US vehicle approvals in the EU – the MRA must not lead to European safety standards being circumvented.
- Adherence to the proven European type approval system and the third-party testing approach – especially for safety- and environment-related vehicle functions.
- Clear legal demarcation – a trade agreement cannot override existing EU secondary legislation.
- Strengthening transatlantic standardisation – close cooperation in the development of common standards is expressly welcomed.
