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

Certification, type approval, homologation. Not the sexiest words in autonomous driving, but arguably the most decisive ones for whether AVs ever reach European roads at scale.

The EU's Level 4 regulation (2022/1426) has existed for four years. As of today, not a single vehicle holds EU type approval under it. The common narrative blames slow regulation. My guest tells a different story: the framework is ready, the technical services are ready, and the real bottleneck sits inside the companies themselves.

Dirk Fratzke is Project Leader in the Autonomous Driving & ADAS department at TÜV SÜD, the independent testing organization that assesses AV companies across three continents, from Waymo and Aurora in the US to projects across Europe and Asia. He led TÜV SÜD's involvement in the EVA shuttle project in Karlsruhe, one of Germany's first SAE Level 4 deployments in public transport, and has co-authored academic research on systematically testing autonomous driving functions.

In this episode, we cover:

• What homologation and type approval actually mean, and how Europe's independent assessment model differs from US self-certification
  
• The two-step approval process for Level 4: EU type approval for the product, then operating area approval from the "owner of the road"
  
• Why the 1,400-unit small series cap is a benefit for AV companies, not a showstopper
  
• What is really delaying Europe's first Level 4 approval, and why Dirk says "maybe one year, maybe two"
  
• Why Mobileye's completed functional safety management assessment matters as a milestone
  
• Whether end-to-end AI systems can pass European certification at all
  
• Why Pony.ai, WeRide, and Momenta are entering Europe
  
• How TÜV SÜD approved shuttles without steering wheels by arguing from the regulatory framework for horse-drawn coaches
  
• The newly adopted UN global regulation for driverless vehicles, and the alcohol interlock absurdity that shows why updates were overdue
  

Whether you build, operate, insure, or invest in autonomous vehicles, this episode explains the process that decides who gets to deploy in Europe and when.

Timestamps:

00:00 – Cold open: why AVs need an independent set of eyes
01:18 – Intro: certification, type approval, homologation
03:07 – Dirk's path: from car mechanic to TÜV SÜD
04:48 – Why a 160-year-old testing org jumped into autonomous driving
06:19 – What a "technical service" actually does
07:22 – Team size and how demand has shifted
09:24 – Homologation vs type approval vs US self-certification
11:10 – Level 3 vs Level 4: two separate regulatory tracks
14:00 – How UNECE regulation becomes binding law
17:05 – The EVA shuttle project in Karlsruhe (and Bad Birnbach first) 19:05 – Approving a vehicle with no steering wheel
21:09 – The two-step EU approval process (2022/1426)
23:30 – Operating area approval: the "owner of the road"
25:11 – Zero Level 4 approvals: what's really blocking it
27:32 – Vertical integration vs partnership: who applies?
30:21 – How long approval realistically takes
32:43 – The 1,400-unit small series cap, and why it's a benefit
35:12 – Why US and Chinese companies come to TÜV SÜD
36:46 – Waymo, self-certification, and the four-eye principle
39:15 – Chinese AV companies entering Europe: the Level 3 play
41:42 – Can end-to-end AI pass European certification?
44:16 – The new UN global regulation for driverless vehicles
47:00 – When can a passenger hail a driverless AV in Europe?
49:00 – The one thing Dirk would change tomorrow