Complaint concerning the counterproductive effects of Regulation (EU) 2019/2144 on road safety due to the intrusiveness of ADAS systems

Subject: Complaint concerning the counterproductive effects of Regulation (EU) 2019/2144 on road safety due to the intrusiveness of ADAS systems

I am writing to the European Commission in order to submit a complaint and, at the same time, to draw attention to the practical effects of Regulation (EU) 2019/2144, concerning vehicle type‑approval requirements in relation to general safety, in particular as regards the mandatory nature and functional design of Advanced Driver Assistance Systems (ADAS).

As a regular driver of a recently registered vehicle, fully compliant with the current European regulatory framework, I have been able to verify first‑hand that certain mandatory ADAS systems — especially Intelligent Speed Assistance, Lane Keeping Assistance, and driver attention or distraction detection systems — generate a continuous stream of acoustic, visual and tactile warnings, with repeated activations even in safe and controlled driving situations.

My concern does not relate to the purpose of the Regulation, which I fully share, but rather to its practical outcome. Real‑world driving experience shows that the constant accumulation of warnings, automatic corrections, beeps, on‑screen messages and flashing signals can induce anxiety, cognitive overload and additional distraction for the driver. Paradoxically, the driver is compelled to devote attention not only to the road, but also to the continuous need to deactivate, confirm or counteract the system’s interventions.

Under these conditions, the system ceases to function as assistance and becomes a disruptive factor in driving. The risk involved is not merely subjective: a driver exposed to constant stimuli, many of them irrelevant or repetitive, may suffer a reduction in effective attention to the road, adopt defensive reactions or even perform abrupt manoeuvres triggered by surprise or irritation. From this perspective, it is reasonable to fear that, in certain contexts, these systems may contribute to creating more risk than they prevent, particularly for experienced drivers, on secondary roads, or in situations that require sustained concentration.

According to information provided by the vehicle manufacturer itself, the design of these systems strictly follows the requirements imposed by European legislation, which would preclude both permanent deactivation and any substantial reduction in the frequency or intensity of warnings. This suggests that the issue is not a case of isolated poor implementation, but rather a structural effect of the regulatory framework that has been adopted.

I therefore respectfully request that the Commission:

First. Empirically assess, rather than merely theoretically, the real impact of the intrusiveness of mandatory ADAS systems on driver behaviour and on effective road safety.

In this regard, the following recitals of the Regulation are unconvincing:

“Advanced emergency braking systems, intelligent speed assistance, emergency lane keeping systems, driver drowsiness and attention warning systems, advanced driver distraction warning systems and reversing detection are safety systems that have a high potential to reduce accident casualty figures.”

Has this reduction been empirically evaluated? What is the proportional cost for low‑end vehicles?

(11) “It should be possible to disable the intelligent speed assistance, for example when the driver receives false warnings or inadequate information as a consequence of adverse weather conditions, contradictory temporary road signs in roadworks, or confusing, defective or missing road signage. This deactivation function should be under the control of the driver. It should allow the intelligent speed assistance to be deactivated for as long as necessary and easily reactivated by the driver. When the system is deactivated, information on the speed limit may be provided. The system should always be active when the vehicle is started and the driver should be informed at all times of whether the system is activated or not.”

Second. Consider whether the current regulatory approach, centred on permanent activation and constant warning, adequately complies with the principles of proportionality and effectiveness and, above all, whether it does not produce effects contrary to those intended by irritating the driver and, eventually, distracting the driver from the driving task. In such a case, the European Union would bear responsibility for accidents caused by the implementation of these safety systems.

Third. Explore the possibility of introducing greater regulatory flexibility in the design of the human‑machine interface, allowing for less intrusive configurations without jeopardising safety objectives. In particular, by removing the obligation that the system be “always active from vehicle start‑up”. It would suffice for the vehicle, upon being started, to “ask” whether the driver wishes to activate driver assistance systems. This would be a less intrusive measure and not only equally effective, but also less dangerous for road safety.

Road safety does not depend solely on the presence of technical systems, but also on the driver’s confidence, calmness and concentration. Regulation that systematically degrades the driving experience and generates constant anxiety runs the risk of producing counterproductive effects.

The European Union has earned a reputation for over‑regulation, which often produces effects contrary to those intended and is turning the peoples of Europe into increasingly less free societies.