INDUSTRIES, AUTOMOTIVE | The ECJ on disclosure of vehicle identification numbers by car manufacturers

Newsletter n. 90 – November 2023

INDUSTRIES

AUTOMOTIVE

The ECJ on disclosure of vehicle identification numbers by car manufacturers

On 9 November 2023, the EU Court of Justice (ECJ) issued its judgment in Case C-319/22, on the scope of the obligation imposed, under EU law, on car manufacturers to provide independent operators – including repairers, spare parts distributors and publishers of technical information – with the information necessary for the repair and maintenance of the vehicles they manufacture. Specifically, the ECJ first reiterated that car manufacturers are required to provide access to all vehicle repair and maintenance information, in particular by setting up a database where such information can be searched based on vehicle identification numbers and/or other criteria, such as the vehicle’s engine output or trim level. In this respect, the Court was also asked about the possible privacy consequences that such an obligation might cause, clarifying that – where vehicle identification numbers are associated with individuals, thus constituting personal data – their disclosure under EU law is nevertheless compliant with the General Data Protection Regulation.