The seven civil society organisations included on the letter are: 

• BEUC - the European Consumer Organisation
• Eurocities  
• European Cyclists’ Federation 
• European Transport Safety Council 
• International Federation of Pedestrians  
• POLIS - Cities and Regions for Transport Innovation  
• Transport & Environment 

You may have noticed the increased growth of the very large 'pick-up' truck behemoths. The vast majority of these vehicles are not manufactured in the EU but are imported, usually from the US. These large vehicles weigh up to 3.5 tonnes, have incredibly poor vision and often lack safety options or devices on board. Examples are the Ford F-150 or Dodge RAM. 

These vehicles are not regulated through the typical type of approval process but go through Individual Vehicle Approval, either at the European or national level. The current safety and emissions requirements for these vehicles are very weak and do not compare to the greatly improved requirements for all other new vehicles across the EU. 

You may remember that in 2019 and 2020, the EU passed legislation that listed a whole raft of safety devices and measures that vehicle manufacturers will have to fit into their vehicles.This means that across the whole single market, new European vehicles will be considerably safer in their interactions with cyclists

Some of the new measures in the GSR include: 

• Intelligent speed assistance 
• Improved impact protection for pedestrians and cyclists 
• Advanced driver distraction warning 
• Advanced emergency braking for detecting pedestrians and cyclists 
• Alcohol interlock installation facilitation 
• Brake assist 
• Driver drowsiness and attention warning 
• Emergency lane keeping 
• Event data recorders 
• Lane departure warning 
• Stability control  

The Individual Vehicle Approval process requires none of these and is a back door for the entry onto European roads of very large, polluting, and unsafe vehicles. While the type of approval for ‘small series’ vehicles (think sports cars manufactured in the EU), which also have a less onerous regulatory system, has a limit capped at 1,500 vehicles, there is no limit on the number of poorly regulated pickup trucks that can enter the EU through this lax regime.  

In the US, where the increase in vehicle weight and size is ahead of Europe, there are some very alarming figures indicating an increase in pedestrian and cyclist fatalities. Pedestrian vehicle crash deaths have increased by around 80% and cyclist deaths by around 50% since 2010, according to the Insurance Institute for Highway Safety, and have now reached their highest levels in 40 years. Another trend is the rise in pickup truck vehicle sales and their impact on those fatality figures. The Ford F-series, Chevrolet Silverado and Chrysler Ram pickup trucks are now the first, second and third most dangerous vehicles for pedestrians and cyclists in the US. 

We know that larger ‘pick-up’ trucks are intrinsically more dangerous in a crash, particularly because of the terrible box-like design of the front of the vehicle, and the extra mass in the crash, as well as the difficulty in manoeuvrability. A Belgian VIAS institute report concluded that “heavier cars increase the probability of death among vulnerable road users: with an increase of about 300 kg in the mass of a passenger car, the probability of death for vulnerable road users increases by 23%.” Unlike smaller cars that tend to have a more mitigating frontal design, large vehicles will throw their victim onto the ground (two serious strikes, one from the car and then a second impact onto the ground) and then run the person over. This poor design also creates blind spots, particularly at the front of the vehicle. This is especially true of the very large ‘pick-up’ trucks, bringing to mind a tweet recently showing popular US pickup trucks having worse frontal direct vision than a Sherman tank!

In the letter, the organisations urge the Commission to apply comparable type approval requirements to those vehicles entering the EU as for those that are mass-produced and manufactured in the EU. In other words, to end the exploitation of regulatory loopholes that allow unsafe products onto European roads.