Proposal to clarify the treatment of extensions of existing approvals under the new transitional provision guidelines (“Until 31 December 2019, Supplement 5 to the original version of this Regulation may not apply to extensions of approvals that were originally granted prior to the entry into force of Supplement 5”.)

Proposal to redefine “key” to include “physical device or electronic solution”. At the same time, the proposal excludes “hardware (e.g. smartphone) provided by other than car manufacturer” from this definition.