Insurance Europe welcomes the opportunity to comment in writing on Discussion Paper VII, forming the basis of discussions during the seventh meeting of the expert group on European insurance contract law (EICL) (held on 12-13 November 2013), and the relevant section of the final report that will represent the work-output of the expert group by the end of 2013.

Insurance Europe notes that motor insurance is highly important for European consumers. As rightly cited in the discussion paper, the European motor insurance market represents the largest in the world and is one of the largest non-life insurance business lines in Europe as well. It is also an extremely competitive market with very tight margins.