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EU Type Approval Explained: How Autonomous Vehicles Get Certified for European Roads · Autonomy Insiders

• Daniel Abreu Marques: Welcome to Autonomy Insiders, the show where global industry leaders in autonomous driving unpack their real-world insights. Today with Dirk Fratzke. TÜV SÜD Dirk Fratzke: our role in the whole process is to give an independent feedback It's really not about you need someone independent because we don't trust you. It's more like bringing more safety inside with someone independent. we have homologation that someone check if you be according to the regulatory framework, you have a safe development, if you have process, if you have a quality management. but mainly it's focused on the development process and then the product by themselves. But if you go on a public road, for example, you're driving here in a countryside where I'm living and you have not 5G everywhere, you have a certified product, but this will not be works in this ODD here. because we have no internet and maybe your vehicle needs it. So you need a two-step process for autonomous driving. You need someone to approve the product and the development process and the company. But if it comes to public road, we have to check if it works there. Daniel Abreu Marques: Welcome to Autonomy Insiders. I'm your host Daniel and today we are tackling a topic that sits at the very core of whether autonomous vehicles can actually make it onto European roads, certification, type approval and homologation. So these are not the sexiest words in the autonomous driving vocabulary, but they're arguably one of the most important ones. And my guest today is Dirk Fratzke. Dirk is a project leader in the autonomous driving and ADAS department at TÜV Süd. And he led TÜV Suits involvement in the Eva Shuttle project in Karlsruhe, which achieved Germany's first SAE level four driving function and public transport. And he has co-authored academic research on how to systematically test autonomous driving functions. And he works at an organization that has become the go-to independent safety assessor for AV companies on three continents, from Waymo in the US to projects across Europe and Asia. So Dirk, so happy to have you on the show today. TÜV SÜD Dirk Fratzke: Yes sir, thanks Daniel for the invitation. I'm very happy to be today in your broadcast. It's one of my first time to broadcast at this but I'm very happy to be here to explain a little bit about what you said. It's not so sexy. Yes, homologation sounds not so super sexy but it's really necessary for European market. But I think inside the call we will see it's not only for European market. It's a topic. It's for all the autonomous driving. Make it useful and safe for the people. will be good. So let's start. I'm very interested in your questions. Daniel Abreu Marques: Perfect. Yeah, Dirk, maybe let's start with you personally. So you're trained as a master automotive technician. You worked in China and you led autonomous driving project at one of the world's most recognized testing organizations. So what was the moment or the project that pulled you into autonomous driving and what keeps you in this field? TÜV SÜD Dirk Fratzke: Yes, mainly I started as you said in a workshop as a car mechanic and studied this and then I changed the automotive industry. So I have a long way of experience starting in an engineering company, then go to OEM and so on. Then finally I worked by a vehicle manufacturer. So you see from the development side, you see the whole process of how product, a car goes up and I was... In China it works for the testing field, make a product safe and in quality also of other systems driver assistance system functionalities. We testing also in China. And this brings me to the point that autonomous driving in 2018 comes more more clear that this will be a technology in the future. But for me the interesting why I changed to a technical company like to suit was one of the first one invest there. and build up a project house, which was me super interesting and that's why I go back from China to Germany to join TIFF Süd and say okay, let's see it from the side, what we talk about today, from homologation, not as a prospect of an engineer, more as a project of an inspector that helps to make the product finally in a good quality and make it safe. Daniel Abreu Marques: Yeah, that's great entry point. maybe let's zoom out from your personal journey to a bigger picture at TÜV Süd. So TÜV Süd formally stood up its autonomous driving and ADAS unit around 2017. So for listeners who may not be familiar with how a 160 year old testing organization decides to jump into autonomous driving. So what was the trigger there? Was there a specific moment where leadership said, okay, now we need a dedicated team for this topic? TÜV SÜD Dirk Fratzke: Yes, of course. So one of the first is TÜVSÜD. Yes, we're looking back around 160 years of history of making technology safe, but one of the genes of TÜVSÜD is that we make future technology for all of us useful and safe, also for people, for nature. And this is one of the genes of TÜVSÜD to not only focus on existing technology, so we're very focused on new technologies and... In the beginning of the project house, was one of my colleague, Benjamin Koller, and the team that says, okay, how to do this? And they set up this project house and TÜV Süd invested this time around about 15 million euros to build up in this project house. The team that's organized, first of all, how we can test this, how is the regulatory framework, how we as TÜV Süd, as a TEEK company, can support this. And this was for me also the entry point. was a sound super interesting. to have a choice to be there at the beginning point. yeah, Most people believe to suit is all company make vehicle technical inspection, no. AI, autonomous driving, future technology is also our daily work and we try to shape it for the future. Daniel Abreu Marques: Yeah, that's super interesting. And maybe let's also define TÜVSÜT's role for our listeners who may not be that familiar with European automotive regulation. So when we say TÜVSÜT is a technical service, so what does that actually mean in practice? So what do you do that manufacturers cannot do themselves? TÜV SÜD Dirk Fratzke: Yeah, that's also good question. Yeah, TÜVSÜD is an independent company. our role in the whole process is to give an independent feedback and to look back to that, I think we jump a little bit deeper in that. But what we provide is an independent feedback. So we have regulatory, we have standards and we have the authorities. They will see that the manufacturer also on the OEM markets for OEM ACE, they will have a look on that, that the manufacturer fulfill everything. So we are the independent between the manufacturer and the authorities to give a feedback that what they developed is producted according to the regulatory or the standards. Daniel Abreu Marques: Today your team works also with AB companies from the US, from China, from across Europe. And you have an assessed safety system for companies like Aurora Gettyc, MotionL and others. So how big is the autonomous driving team at Tufts-Süd now and how has the demand for your service also changed over the past maybe two or three years? TÜV SÜD Dirk Fratzke: So to count the team in numbers, right now it's not longer possible. if I started to get to Germany, it was around 10 to 15, and then it increased from 2017 to 2020. I think finally it was in project house with around 60 to 80 peoples. They broke on this topic, so it means we have specialized for cybersecurity, for functional safety, for vehicle safety. for regulatory things, all that comes up around it, also already there we talk about AI and try to figure out how we can also integrate AI in the homologation process. So in the beginning 40 to 60 people, right now it's different. Right now we've been already changed in the whole business unit, we'd be part of the normal homologation process because autonomous driving come real, we have the regulatory, we have the standards and the topic we touched. Like for example, cybersecurity, is already regulatory framework in Europe for the UNICEF. They their own team. They only make cybersecurity. But they be also part of autonomous driving. So I would say maybe in Germany, we have 20 to 25 experts only for autonomous driving. But if you look around, sure, you take hundreds of people. They can take care of topics part-wide of autonomous driving. And to give you a number by teams. Projects are running right now in a complex field of formalization of autonomous driving. A team is between three and ten auditors and experts to handle one customer. Daniel Abreu Marques: OK, this makes sense. And now before we go deeper into the process and the challenges, I think it's also important that we define a few key terms. Maybe our listeners come from different backgrounds, and I want to make sure everyone is on the same page. So maybe let's start with the basics. So what is a home and location? What is a type approval? And how also do these differ from the kind of self-certification that we see in the United States? TÜV SÜD Dirk Fratzke: So yeah, simple the word homologation cover the things, the process to getting a vehicle approved by an authority for an recognized market. And in the homologation process is what I says at the beginning. Homologation means you be according to regulatory framework. So, and in the homologation process, we checking the relevant things like the vehicle, the safety, the security. And this we do in an independent part, what is part of the ONA regulatory framework that it says for homologation you need an independent one. And in the US market, the companies are self-assessed. Or mainly, but we will come later also to this topic, they do not have an independent one. The company shows by themselves that they will be according to regulatory standards. But homologation means there is someone, you're starting, you have a product, you will bring it on the market. And for that you need someone independent that double check if you be according to the regulatory framework. Finally, you have reports and documents from your technical company. And with that you can apply in your market like Germany or Austria or Netherlands or Japan that you be a control regulatory with your product and then you can go to public. Daniel Abreu Marques: And the type approval is then the result of the homologation process TÜV SÜD Dirk Fratzke: Yes, exactly. Daniel Abreu Marques: And everyone in the industry is also now talking about the different SAE levels, so like three, four, and five. But from a regulatory perspective, the distinction matters enormously. And maybe can you also walk us through what level three means for type approval versus level four? Because I think Europe has two completely separate regulatory tracks for those differences, correct? TÜV SÜD Dirk Fratzke: It's a very good question, thanks for that. It's not totally different if you talk about level two, level three. There is a difference between level two and level three, but if you go level three, level four, I always explain to our clients that from the base, we're starting from the same, because what we have is that the system take care of a part of the driving function, and they take the responsibility. That's a big difference. By level three, For example, we have a line keeping system system. There is a new AU regulatory. It's L157. So in this description, the vehicle can drive by himself and just take the responsibility. But if this comes to a point where the system cannot handle it, it can take back to the driver. So there is a recognized time, but the driver then had to be over. For example, highway pilots, the vehicle takes care of the driving function. You can read the newspaper. But finally, the vehicle knows now it cannot drive longer because it comes to situation where it cannot handle. Then they warning you and you have a certain time to take over. Otherwise, the vehicle make a minimum risk maneuver. Go, for example, to the side and stay there until you take over. By L4, it's... Also driving autonomally, maybe in a different field. What this means the ODD, the description of the operation area is different. But the vehicle first of all, is drive by himself also like L3. But then there is no human that can take over because it's maybe a passenger, it's a robot taxi. So the vehicle have to handle all situations in his ODD by himself. There is no opportunity to hand it over. So what it means by different regulatory framework. how you developed your system, that you have a management system for safety, for cybersecurity, for quality. I always think from the point of view like our customer right now, there's not so much difference because you need explaining way how you argue with safety. The only thing is that it may be on the engineering side. You can put it a level lower because it says, okay, I cannot handle it. I can't give it someone back, a woman driver, they take care of it. And in L4, you have to develop more scenarios, more deeper because you have to handle more complex scenarios. But the way how you develop, it's mainly the same. Daniel Abreu Marques: Okay, understood. the regulatory body behind a lot of this, you already mentioned like UN ECE, the United Nations Economic Commission for Europe. For listeners who hear UN regulation and think of something like really abstract and really far away, how does UN ECE regulation actually become then a binding law that affects what cars can do on the German Autobahn, for example? TÜV SÜD Dirk Fratzke: Yes, so first of all, it's good to know when SAA regulations is not that they're sitting a court and design some regulatory frameworks. The sitting companies, vehicle manufacturers, supplier company, engineers, experts for different topics, and the main idea behind it to have a common standard, have a common understanding how to bring a product and I would wait for the scripted that it's safe. on the way so this starting in a working group there's a special working group exactly for autonomous driving in the moment and they will publish also soon the next regulatory step they work together that's really full of export they have a high expertise what they're and they make an UNACA output is then you have a UNACA regulatory what is in this moment not enforced what has happened next is that the AU for example or Japan country that works with UNICEF regulatory they take it over and make from that they make a regulatory so as you know if the AU makes a regulatory and publish it there's two ways it can be immediately in all countries enforced or it comes by the country can vote for that and it comes in force so this is the way how it's going but the base it comes from engineers it comes from companies they develop products And what it helps us to have an UNACE standard is if you will buy a product and you look to that and says, this is according to a standard, you can be sure someone checked this and it's developed on a framework and a very good framework to have an certified product on the end. And this is very useful. And not only. the EU countries use the UNACA. There's a lot of other countries that look to that and says, that's cool. Let's take this in our country too. China have other regulatory framework, but the base is always, if you see this, it's not so far from our UNACA framework. Maybe they combined to this country, but the framework help us to, yeah, developed on a safe way. And finally also have an fair way that everybody will checked on the same level. Daniel Abreu Marques: Yeah, makes sense. And it's also interesting to hear that it's expert group doing this and not like someone who is mainly focused only on regulatory and then write something like really technical, but it's like a real expert group who is handling such things. So thanks for the explanation, Dirk. maybe now that we have all the definitions in place, let's talk also a bit about like how this looks like in a real world. So I think there's no better example than a project you led personally. So The Eva shuttle project in Kaosu is described as the first SAE-level driving function in German public transport. So there were three autonomous shuttles named Elavera and Anna and they are carrying real passengers. So what was to suit specific Roland's project and what did you have to build from scratch because it had never been done before? TÜV SÜD Dirk Fratzke: So I have to correct you a little bit. The very, very first one of autonomous buses was made also from our team in Bad Bönnbach. This was the year before we have EFA. But this was really the first, first one. It's maybe not so public in the press right now because EFA was more shuttles, nice names, as you say. But the first, first one was Bad Bönnbach. And there the first idea was that there was no regulatory framework how to approve this, how to talk to the local authorities and say, hey, let them drive, let them test drive without steering wheel, without breakings, with anything, but still we have a safety concept. then comes AFA, what was the follow up and our role inside that was not to develop something in a safe way because we've been not a developing company, we've been a company to make it certified, but what we need is also to Developed our way how to approve If it's safe and we focus in this project first of all on the test on the test field so how to Do test driving on a safe way how you set up a safe system? With the unsafe autonomous driving system because you are known as driving buses. It was not fully developed But we will transport people with driving door by door with the three buses pick up passengers also in Kobe time We use it was from this case was quite good because it was a small shuttle only two to three persons inside with space for six but we only use it for two to be also in in the the COVID time on the safe side. But mainly we as Tiff Süd was focused to develop the process how to approve prototypes for autonomous testing long before we have in Germany the ABGBB paragraph 16 what we have right now. Now it's a very clear. process how to get a prototype but in this way there was not. And we find a way together with the authorities to make it safe. Daniel Abreu Marques: And what surprised you the most about what it takes to test such a vehicle without a steering wheel? TÜV SÜD Dirk Fratzke: First of all, I was surprised about our team how to get find arguments to says Hey, there is no steering wheel. We have no regulatory framework, but it's going and To explain maybe a little bit on a funny ways that one of our team says hey if we go back to To this vehicle that was with with horses They have also no steering wheel, but it was also mainly on the regulatory framework and the framework forces is still there so let's name it like it's a In Germany it Kutsche and says, okay, let's use it like that. There's also no steering wheel. So we find the augmentation. This was the first thing what surprised me really that you have engineers in our team to be not like engineers says, this is the framework we cannot look left and right. So we understand our role also right now like enabling the technology. Find the augmentation together with the development that is safe and it's can be according to the regulatory framework. And we did. This was the first thing that surprised me. The other thing is, of course, this was for me the first time to do a deep dive in functional safety, cyber security, and learn what else has to be done to make it safe. And what else we on technical inspection company need to do to have a simply named checklist. We cannot name it only checklist, but it's finally something like that. You have to check. If this everything is in your mind if you develop them this was surprised me also Daniel Abreu Marques: Yeah, so this Eva shuttle gave you a really concrete case study and to learn a lot. So maybe now let's generalize a bit. And I want to walk through the type approval process for our listeners now, step by step. So level four, there's the EU implementing a regulation 2022-1426. It's graded in two-stage process. So we have first an EU type approval for the product and then also a national operating area. approval in each member state. So that sounds a bit bureaucratic, I would say. So can you explain to how does it work in practice? TÜV SÜD Dirk Fratzke: Yeah, first of all, it's not in works in practice right now because there's no one drive at the moment in L4 and don't running the whole process. the idea behind, and I think this is very good idea is on one hand we have that homologation what I explaining first that someone check if you be according to the regulatory framework, you have a safe development, if you have process, if you have a quality management. And if the product, is the AU part, is the UNACE or the AU 1426, they describe the product, you describe the ODD, but mainly it's focused on the development process and then the product by themselves. But if you go on a public road, for example, you're driving here in a countryside where I'm living and you have not 5G everywhere, you have a certified product, but this will not be works in this ODD here. because we have no internet and maybe your vehicle needs it. So you need a two-step process for autonomous driving. You need someone to approve the product and the development process and the company. But if it comes to public road, we have to check if it works there. And this is the idea behind that first of all, the product is certified and then it comes to really to their authorities to be take care of this. For example, you go in a highway in Germany, have Autobahn GmbH. So the second step you're not doing with KBA, German authorities for vehicle, you do it with Autobahn Gesellschaft, because they have to give you also green light that it's matching what you described in your ODD that you can drive on this highway or you go to Munich and drive in Munich, then for sure you will talk to the authority of Munich And this is this two-step approval system. that on one hand we have the product and the manufacturer and on the other hand we have the approval for the area where we drive. That's the idea behind. Daniel Abreu Marques: Yeah. And the approval for the area is then always from the city you're driving in or for example, if you talk about like the countryside, a small town where you live in and then you want to have an autonomous shuttle there, would the small town, need to approve that or is it more like a higher level approval TÜV SÜD Dirk Fratzke: I would say it's organized like the owner of the road, name it simple in this call here. It's the owner of the road. Germany is also a good example because we have a highway, it's Autobahn GmbH. We have Bundesstraßen, what is then the government of Germany. And if you have a countryside road in a village, Landstraße, we name it in German, the country road, this is owned by the country, so you have to talk to them. But the process will be not that you have to talk to each one separately. It's mainly you maybe go to Munich and it says Munich in the whole area, then you hand it over your approval package to them and they will take care and get the agreement from all of them. So this is at the moment they're running test processes and test projects. There is a community with... some countries in Germany and also with KBA and with technical inspection companies and they're running test drives how this process will be broken and honestly the process is written down the regulatory framework is there but from my prospect no one running at the moment and we have a couple of customers we do this at the moment we started this process but I think it will still need a while to have a clear picture of how it works and be Daniel Abreu Marques: Yeah, so maybe to stay on that theme. as of today, May 2026, there are zero level four vehicles that have received the EU type approval, as you already mentioned. The regulation exists. The technical services like to suit already. So what is actually blocking it? What are the concrete hurdles that still need to be cleared? TÜV SÜD Dirk Fratzke: I will not say blocking it. From my point of view right now, and I have, as you named at beginning, a couple of named customers, also there's a couple of unnamed customers, but I have to say there's no blocking. All of them use this framework, we explained at the beginning, and they're quite happy because now they have a framework. They know they have to bring something for security. They have to bring something for safety. They have to bring something for the supervision. And they work on that on one hand and what need time and this is really one of the main point is they need time to bring all the evidence on that. Of course we see a lot of good function at the moment right now. If you're looking for way more in the United States, it's amazing what you're seeing, what a vehicle can handle right now. But you have to see if they come to Europe and then they be requested here by the authorities, ah you have a technical inspection company in the background, so where's the report and... a technical inspection company for companies like that, have to show up. have a cyber security management, they have a functional safety management, they have a quality management. And after they have that, they have to show their development in this process. And at the moment, a lot of startups that they've developed autonomous driving function in a very high way, and then they do the world back and now they describe how they do this and how they develop it. And it's a time because... then maybe they script it in a way that is not according to that what is standard and then you have to find a way and this is what needing time at the moment so I will not say this is blocking it's more like in some of our autonomous driving customers they develop first that's now they have to set up the management system and this means it's need a while but after this while I'm very sure we see that is coming Daniel Abreu Marques: maybe a follow-up question on that. In the autonomous driving industry, there are different kinds of models. So you have a more vertical integrated approach like Waymo where you have the driver and the vehicle from one party more or less. then you have others, they are more like partnerships. So we have an OEM and then you have an external virtual driver company. And in this partnership model, so. Who comes to you? Is it the virtual driver company? Is it the OEM? Is it both at the same time to homologate the whole product? So how is that dynamic working? TÜV SÜD Dirk Fratzke: This is a really dynamic field and a very good question. think many people are interested in should go to the technical inspection company and who should apply for that. And I have to say honestly, all of them have there. We have companies that have been service providers. They have no vehicle, they have no product. They believe, okay, we have to talk to the suit because we will buy a vehicle and we will buy a V-Stack and we will combine this and then we will have approval. This is one of them that coming to us. The other one is already named... Companies they have to hold product by himself. This has we make the car we make the V stack We make everything with our main customer in the in past is companies to build up a product But what is coming or more is also companies like you says we have a vehicle manufacturer and they have a partnership with some named EV stake providers and Yes, of course. There's a good question who is coming. Sometimes it's a V stake provider that comes to says I will running the vehicle I will do this what I should do first of all if you come to UNACA regulatory framework and approve for more than one vehicle you have to become a manufacturer and we don't care if you be the vehicle manufacturer or the V-Stack provider finally the company they apply to get the approval have to talk to us latest day because they need the approval report so it can be happened In a multi-stage approval you have a base vehicle. For example, you take an ID bus from Volkswagen. They will sell it as an autonomous vehicle ready. So you can buy it, but there's no EV stick on it. Then the base vehicle is approved by Volkswagen, for example. you have a partnership with Volkswagen, come to a technical inspection company like TÜV Süd. And then you make the second stage. The stage is approved and then you build the next stage on it. So finally you'll be the vehicle manufacturer. have to be initial assessed that you'll be a manufacturer. It's not so big deal. But after that you have to fulfill all requests what is needed on the changes of the vehicle, also the impact of the vehicle and the system you're adding. So this is the way. But it's very open who talk to us. At the moment everybody is coming and I can say Everybody is on a good way if you come by time. If you have a business idea but not clear how you come to approval, feel free to talk to us. Mainly we're starting mostly with a smaller workshop to explaining the framework, exactly what we're doing here in this call, a little bit more deeper. And this helps these companies to figure out what is the best way who should finally approve. Daniel Abreu Marques: Yeah, makes sense. maybe a follow up question on that. So how long should a manufacturer then realistically expect this to take? So when he wants to start right now. TÜV SÜD Dirk Fratzke: Also, this is not a question that I can answer in days or months or years. I will say, at the moment that you have your concept, if you are very clear who will apply for approval, this is the latest thing you should talk to us because we do something like preloading. It's not that you come at the latest day before you will approve to a technical inspection company and say, okay, I'm ready with my product. It's what I explained before. The base for our approval is your management system. The AO1426 requests that you have, for example, a safety management system and a quality management system. And of course, also some others like cyber security and software. But I will say that if you talk with your technical inspection company like TIFFSYT on your starting point, we first of all, already before you have your product, we assess your management system then you can go ahead and work one year to develop your product but you know be on the right way because you will be already on the way with your safety argumentation and your safety management. So I will say as soon as the company is coming, it's better. And if you're knocking the door at the technical inspection companies and you already have certified management systems like cyber security, safety and quality, I expect you can run the approval process very fast because then we're talking about your product and your safety augmentation and not longer about how to. So I cannot name it in years and for sure sooner or later you will ask me when the first car is coming but it's related exactly on a question like that. Daniel Abreu Marques: OK, makes sense. And maybe let's stay on the EU 1426. So one specific issue that always comes up is also like the small serious limitation. So there's a cap at 1,500 units per vehicle, type per like across the entire EU, with no more than 250 per member state or something like that. And for a company that's trying to build like a real commercial robotaxi fleet, Maybe that sounds like a non-starter, so is this regulation designed for pilot project or is there a path to unlimited serious... TÜV SÜD Dirk Fratzke: It's it's opposite. It's really opposite. First of all, it's less. It's not 1500. It's only 1400. But cut only out because it's so small series means you have less requirements. If you put that the series, you have to do crash and other things for the approval. So it's a benefit that is a small series. The level what you have to jump from, it's low. The request what is for small series. It's lower than for high series. So it's really a benefit. And I would say it was a very good idea to starting with that to put the level not so high. If they put it as you can only product series, it means you have to product in full-fledged with everything what we have for the series production of big numbers like more than five, six, seven thousands. So by small series, the level is much lower for the rest of the vehicle. And I says it's not the different if you put that. one autonomous vehicle or five or 500 because the framework what I always explaining is the same and I would be happy if the first 10 be there I don't think this is a showstopper to say so you can only product 1400 because I tell you if I look a little bit in real projects of homologation what I was doing to change the type of vehicle is not a big thing other wheels A little bit other design and you have a new type and if you're rolling this you can product much more than 1400 each year. So but my main message will be if you see the first 100 I'm very happy and then I'm very sure if you have the first 500 there will be a way that they realized we have to give them more space but first we need the first 10 if we have that then I think it's coming in rolling and then This will be not a showstopper. Daniel Abreu Marques: And maybe this brings us also to another fascinating part of this conversation. So the common narrative is also that Europe is lagging behind the US and China in autonomous driving and Waymo operates commercially in multiple US cities. Baidu also has old robotaxis on the roads in China and Europe has, as we just discussed, zero level four vehicles approved yet. But yet you are also telling a different story. So you are saying that the US and the Chinese companies are also now coming to TIFF suit because they want to adhere to this European standards. Can you explain us why? TÜV SÜD Dirk Fratzke: So yeah, there's not only the coming they already long time here some of them starting with us Already when we start the project house some of them really going a very long way with us Why they do this why some new ones coming now some longer partners being already with us on the way is It's don't care if you be self-certificated or you be independent Certificated important is that you have someone to bring the for a principle and they give you some framework to assess something because what all of them need and that's why I always say it's not a challenge between Asia and Europe and China but China is very close to Europe I have to say as I said at the beginning China is almost also regulatory with the independent one and they have frameworks and also our customer from the US comes to Germany or to Europe not to enter in the market immediately, maybe also this later, but the first step is we have a framework, we have standards, have regulatory, and they ask, hey, how is this in this country? How you develop according to this process? And this helps them to have argumentations why the system is safe. That's the main thing why I says they come to Europe, they talk to us and talk to our partners and to our competitors, exactly of that. Daniel Abreu Marques: Okay, because and for example, if you take them, for example, Waymo in the US, and they have no mandatory third party certification, they have the self certification, but they still want someone like a 4S principle to look after and say, how can we do that, according to the TÜV SÜD Dirk Fratzke: Exactly and I give you one example more I would say some of us always says wow autonomous driving. is something like flying Because it's complex. It's it's not the easy system controlled by human So if you if you look so aviation also in the United States, this is not a self-certificated market in the United States It's also so parts as the issue by Boeing was the people complain a little bit how this in OS works But there is so that they also buy the aviation they have a 4i principle you need someone independent They hand it over to the companies they have inside the companies independent department, but also there they do something like that, so That's why I always says why not take care autonomous driving what we all believe is complex to have someone independent to take care about the 4I principle. And that is not a question of trust of the manufacturer. It's more like if you know by yourself at home, if you say to someone, can you take an eye on it? And maybe they have another point of view and they see something what you do not see because you're focused on your development, on your project and you're sticking every day in your work. But you take someone else, they're in the same topic, he's also professional, he has also ideas. But they have other point of view and maybe they see some gaps. And this is the role what we're doing. It's really not about you need someone independent because we don't trust you. It's more like bringing more safety inside with someone independent. And I can tell you also in the development process, our German customers, they not apply for something, they use it for his own tests inside the company. Sometimes they come to us to only request for something independent, to have other point of view. This I think is the background idea of that to have really other point of view. Daniel Abreu Marques: Makes a lot of sense, And we're seeing also now, for example, Pony AI launching in Zagreb. We have Rewrite operating in four European countries. have Momenta planning tests in Germany. the Chinese AV companies appear to be also flooding into Europe. From your perspective, I'd like see how... Serious RDS market entries actually. So RDS genuine like communication projects under the EU 1426. So RDS more like companies leveraging national exam chance or pilot frameworks to get really on the road quickly. TÜV SÜD Dirk Fratzke: Yeah, it's first of all, yes, it's true. There's a coming one more Asian companies to Europe also as companies coming more and more but if you ask me about the Asian and Chinese name Pony from one example I think it's two things what they're doing here. One thing is of course is other field of testing and They have here also different kind of road different kind of traffic different kind of human behavior And it's interesting to test this to adapt to them, to bring also if you use AI, give them more learning experience. This is one point. But of course, some of them already realize this is a market. Because also here we have leaking out of public transport. If you see, we have less numbers of bus driver at the moment, and it's coming more and more to a problem. And they realized also this can be a future. Robot taxis, robot buses. It's a market and None of them will be the last in Europe. This is really the challenge Is one of the challenges also to be here to test here? But if they're going a door open you have to be ready. So that's why I think they coming to be prepared and Some of them you have also to see They not only product and for the auto product as we and all three Chinese company getting more more suppliers for European OEMs. if you look in European Product Vehicle and you look what kind of driver system system, highway pilot, traffic control, other things they have. Also this is the reason why they come to Europe. And as I said in the beginning, L3 and L4 by development process is not so far away. So if they come to Europe and maybe they product L4, They used the know-how also to product his real product for elsewhere. Daniel Abreu Marques: and maybe another question that just came into my mind, which is a bit more technical. we have like in the autonomous driving industry also two different approaches, so to speak. You have like this standard normal approach or AV 1.0 where you have like this modular based system and then you have like AV 2.0 where you have this end-to-end AI system. And oftentimes people say, with an end-to-end AI system, cannot drive in Europe because you have to save the argumentation like you need it. So what is your take on that? Is that true? TÜV SÜD Dirk Fratzke: It's true. base of all is as I repeat once again and maybe someone says so very okay homologation is really boring. The process and the safety argumentation and you need this. So I don't care about who coming with which system and says, okay, there is a I inside and that's why I cannot explaining the safety is will be not works in. in the field of EU or UNICEF because you have to explain the whole way how it works in things like how is your development process, how is your development, how is the system works like, how is this minimum risk maneuver designed to, how it comes to that and almost the people are struggling sometimes to have argumentation why you believe you cover all and this is also by systems like that the main issue for them is to explain how they can improve that they cover the most or 90 % of the scenarios. Daniel Abreu Marques: It's really interesting. Because you see more and more companies also going into this NTI approach. So basically what you're saying is that with their current approach, they could not enter European markets more or less. TÜV SÜD Dirk Fratzke: I think it's not the black and white, you cannot enter or not at the moment because as you know also we as SSS at beginning we already also checking how we integrate AI and there is race to have also their argumentation and shows up and this is what we works all together and this is also to your question how long it needs also by that they only work on that how to have a common understanding to says okay we can describe what is running inside there and I believe also the part of artifact intelligent what they use it's not magic it's magic from our point of view outside but if you talk longer to them and you go step by step with them you have an understanding how it's come to and this is important. So that's why I will say it's not totally showstopper but you cannot put something on road and say oh sorry it's end to end I don't know how it works. This is not the way how it works like. But I'm very very sure they find a way of argumentation. Daniel Abreu Marques: listed. Yeah, absolutely. It's also evolving over time like the approaches. So they will find a way to explain the decisions. Maybe also let's go to another topic that you already touched upon a bit. It's like the UN ECE GRVA adopted a draft global regulation for the automated driving systems designed for this level 4 and above. TÜV SÜD Dirk Fratzke: Hmm? Daniel Abreu Marques: The formal award is expected, I think, in June 2026, so we're really close. So if adopted, this could become the first globally harmonized framework for fully autonomous vehicles. So how significant is this in your opinion, and what does it change for your work? TÜV SÜD Dirk Fratzke: It's significant, I think. I really honor all the work of this working group and it's really necessary that we have this working group because as we have at the first step, have Germany ABGBB. We were super proud, I think, in Germany that really globally, Germany was the first country to have a regulatory framework for autonomous driving. So this is for me always important to name this first because Many people, you talk about no miscribing, your friends, my friends would say, no miscribing, Germany, we've been the last in this whole group. We have nothing. And this is not true. We have good companies already here that do something, also in Germany they develop something. We was the first to have the framework, but this is exactly why we need the global group is this was for Germany and is matched only for Germany. And there was some gaps to win ACE and almost to AU. And then... Later comes the EU regulatory framework, the 1426. And if you look in that, there's still there, there's a gap to the regulatory framework because if you do approval by that, for example, I always choke a little bit, there's an alcohol interlock, what is required by 2018. the UNHCA framework for homologation. For the new overheat, you need the alcohol interlock. Now I ask you. make it sense that I have alcohol interlock in the L4 vehicle where I have no driver seat? Makes no sense. So this is one example where we always jokingly say, okay, how to handle that? Officially, if we go into the framework right now, they have to, and there's other gaps, but it's not clear by the regulatory. So I'm very happy if we have hopefully crossed the finger. the UNACE for autonomous driving because it's closed some gaps. Maybe not all, still there are some gaps because all of us push this forward. We will have this regulatory framework and still you will figure out that there will be popped up questions what is not matching to our framework, but it's okay. We will find a way. But really think about the alcohol interlock and then you understand why it's necessary to make some updates. Daniel Abreu Marques: Yeah, absolutely. Absolutely. And maybe now let's come to the question that you already anticipated. when will a passenger in Europe be able to hail a fully autonomous vehicle with no safety operator as a regular commercial service? So what do you think? Are we talking like 2027, 2030, later? TÜV SÜD Dirk Fratzke: I know that you will raise this question. This was for me sure because if I tell someone where I work it's the beginning question. I'm very thankful that you asked me at least and not really at the early beginning, but it's the most tricky question if you ask me. Because if I look in the field of my customer, I see so many very cool technologies. When we going to see some test drive or we talk to our customer and it shows up in the... We are already ready, we can do everything and they can handle really lot of good things. But if I then turn inside the companies and we talk about processes and things like that, you see it's need a while. And I'm always happy, for example, last week one of my customers, Mobileye, announced that they fulfilled now is functional safety management assessment by Tuftsuit. What is very cool that they have that, what this means, they developed. function safety according to the EU regulatory framework for autonomous driving. So if you ask me in this way, okay, they have this big milestone. Now they have only to follow this system and then they can finish. How long they need to do this, you have to ask our customers. I will not give you any number, but I am in a very good mode that if we have some more customers, they fulfill sooner or later in the next days, the part of Systems then they can engineer very good products and they already have it on very good way Maybe we see it very soon. Maybe in one year maybe two so this is my prospect but It's not relying on the regulatory framework. It's not on the tick company like to suit and our partners It's really hanging on that that someone have to follow this framework and to script down what they already finished develop Daniel Abreu Marques: And maybe one last question before we end. So if you could change one thing about the European regulatory landscape for autonomous driving tomorrow, one policy, one regulation, one process, what would that be? TÜV SÜD Dirk Fratzke: That's really good questions. But if I I look back to that what we talked the last minutes, I will say only make the updates faster. This is what I believe it's necessary. Close our gaps. I think the way how it was developed was good. I'm not mainly a regulatory writer. But if you ask me what is needed, I will say let's close the gap that we have less discussion and speeding on on the things we're talking first about. the second stage roadside approval. Make it happen. Make the process finish that if our first customer coming says the vehicle is ready, we homologate it, maybe here how we get the roadside approval, then everybody should be ready. Ready with every formula, every request that we can then really run it very smooth, very smooth. That is what is my wish. All other things, am in a very good mode that we've been very good. Daniel Abreu Marques: Perfect. So thank you, for this insightful conversation. I think we covered a lot of ground today, and we also shed some light on the topics of homologation, type approval, certification. So it was really great to have you on, Dirk. And yeah, thank you so much. TÜV SÜD Dirk Fratzke: See you.