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Explanation of the type approval of FSD Supervised

On Tuesday 16 June, the Minister of Infrastructure and Water Management provided an explanation in the House of Representatives (Tweede Kamer) of the Netherlands regarding the type approval of Tesla’s FSD Supervised. In follow-up to that discussion, the RDW provides below an explanation of the process that was followed.

The RDW carefully assessed and tested this driver assistance system before approval was granted. As part of this process, we analysed and evaluated data from vehicles that had been driven in Europe. We also collected and assessed our own data and continue to monitor the performance of this system on the road.

Assessment of the data

The RDW verified how Tesla collected and analysed the data. In doing so, we assessed whether the data was complete, verifiable and accurate. In addition, RDW data experts independently reviewed Tesla’s statistical analysis. 
For the assessment, data was used from the most recent Tesla models without FSD Supervised that comply with European safety regulations. This data was compared with data from test vehicles equipped with FSD Supervised that had been driven in Europe.

RDW’s own tests

The RDW did not rely solely on Tesla’s data; we also carried out extensive testing ourselves using our own test equipment. Over a period of more than 3,000 hours, testing took place both on test tracks and on public roads, under a wide range of conditions, including complex and busy urban traffic, a broad variety of road types, and different — including extreme — weather conditions. This included the use of data from 1.8 million kilometres driven in Europe with FSD Supervised.
The RDW’s own tests — comprising more than 1,000 test runs — were conducted in accordance with European regulations. The Tesla data used by the RDW also complied with those rules. The RDW independently assessed and validated the process used to collect the data.
Through these tests, the RDW gathered objective information and verified the manufacturer’s data. The RDW does not base its assessment solely on information provided by the manufacturer. We carried out extensive independent investigation. On the basis of this overall process, the RDW concluded that the system meets the applicable requirements. As a result, a European type approval valid for use in the Netherlands was granted.

Safety comes first

Safety is the RDW’s foremost priority. This Tesla driver assistance system supports the driver to a greater extent than other systems because, when activated, it takes over multiple driving tasks. The proper use of driver assistance systems makes a positive contribution to road safety by supporting the driver in performing driving tasks; it is intended as an aid to the driver. Owing to the continuous and strict monitoring of the driver in the vehicle, this driver assistance system is at least as safe as other driver assistance systems. We have thoroughly assessed and tested this system over a period of more than 18 months.

In-use supervision 

The RDW also monitors vehicles equipped with FSD Supervised after the type approval has been granted. In doing so, the RDW follows European legislation, but has for the time being increased the mandatory reporting frequency from annually to monthly. Data on the operation and safety of the system is continuously collected and analysed. On the basis of these findings, the RDW may carry out further investigation or impose appropriate measures on the manufacturer. In this way, we continue to safeguard the safety of vehicles on the road. 
At present, nearly 40,000 Teslas equipped with FSD Supervised have driven approximately 24 million kilometres in the Netherlands since the type approval was granted, without any relevant incidents.

Provision of information on type approval
Each year, the RDW issues approximately 50,000 type approvals for complete vehicles or vehicle components. Driver assistance systems are also vehicle components that we assess. 
Further information can be found in our file on Type Approval (in Dutch). 
As part of the type approval process, manufacturers share commercially sensitive information with the RDW. For that reason, we are not in all cases able to provide substantive information. The RDW understands the interest in this application and aims to be as transparent as possible within the legal framework governing type approval.