FEM Position Paper on AI

FEM Position Paper on AI

The FEM has carefully analysed the proposal for a Regulation on “A European Approach to Artificial Intelligence” presented by the European Commission in April 2021 and presents its position on it:

While not in favour of any specific piece of legislation on AI systems in the industrial field, FEM agrees with the need to have a harmonisation piece of legislation preventing Member States from enacting diverging pieces of legislation that would threaten the fee circulation of our products in the EU Internal Market.

The risk-based approach proposed by the European Commission should be much better fine-tuned by providing a better definition of AI, and of the notion of AI system affecting a safety function, considering the current legislation in place and the industrial environment. Most industrial AI application use cases have entirely different ethical implications compared to consumer-oriented AI solutions for end-consumers. Therefore, in most of the cases industrial AI should not be considered as a high-risk AI. The possibility given to the Commission to extend the list of high-risk AI systems should be counterbalanced by a proper consultation of stakeholders

Most requirements of the future Regulation should be revised to make them proportionate, enforceable, and respectful of companies’ IPRs, notably with regards to data and data governance, technical documentation, record-keeping of events, transparency, and provision of information to users, appropriate human oversight measures to minimise risk and high-level of robustness, accuracy, and security

A balance has to be found whereby the companies’ right to protect their know-how shall only be infringed in cases where such sharing of information has a substantial and indisputably necessary effect on safety or on the personal right to protect personal data.

The respective roles and responsibilities of providers and users have to be clarified

Standardisation and harmonised standards and not “common specifications” must remain the tool of choice to develop technical specifications offering compliance with essential requirements

A single Declaration of Conformity (DoCs) for the final product, even composed of several DoCs, should be established

Cybersecurity aspects should be dealt with in a dedicated horizontal legal act.

The European AI Board should be supported by an advisory group of industry experts

For more information, see FEM position

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