Petition to Relevant European Union Regulatory Authorities

Subject: Petition for Comprehensive Pre-Market Regulatory Review of Xiaomi Corporation Prior to Its Planned 2027 EU Automobile Market Entry

Addressed to:
European Commission Directorate-General for Competition (DG COMP)
European Commission Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs (DG GROW)
European Data Protection Board (EDPB)
European Consumer Centres Network (ECC Net)
Federal Motor Transport Authority of Germany (Kraftfahrt-Bundesamt, KBA)
 
1. Background of the Petition

Xiaomi Corporation is a leading Chinese consumer electronics and smart hardware enterprise, with three core business segments: smartphones, consumer-grade IoT ecosystems, and smart electric vehicles. It has operated in the EU market for many years with smartphone and smart home product lines.
In July 2026, Lei Jun, founder of Xiaomi Corporation, officially confirmed via official channels that Xiaomi Automobile will enter the EU market in the second half of 2027, with Germany as its first launch market and plans to roll out models including the SU7 and YU7. Preparatory work including whole vehicle certification, channel establishment and local team building is already underway.
As a long-term Xiaomi consumer and a firsthand party to an after-sales dispute, the petitioner hereby formally submits this petition, drawing on Xiaomi’s past compliance record in the EU, systemic quality control and after-sales problems exposed in the Chinese market, and the special regulatory requirements for intelligent vehicles. We respectfully urge EU regulatory authorities to launch a comprehensive pre-market review, and to suspend the EU market access process for Xiaomi’s automotive products until full compliance with all EU laws and regulations is confirmed.

2. Relevant Facts and Current Status

2.1 Prior records of violations of consumer rights and data compliance in the EU market

Penalties for violations of consumer protection rules 

In July 2022, the Italian Competition Authority (Autorità Garante della Concorrenza e del Mercato, AGCM) imposed a fine of €3.2 million on Xiaomi Technology Italy S.r.l. for refusing to fulfil maintenance obligations within the warranty period for minor non-functional defects. The regulator confirmed that Xiaomi used excuses such as minor appearance scratches to evade statutory warranty services for products under warranty, which seriously infringed on consumers’ statutory rights. This penalty directly verifies that Xiaomi’s after-sales system has a systemic tendency to deliberately evade statutory warranty obligations, rather than isolated incidents at individual stores.

Violations of data privacy compliance 

The Spanish Data Protection Agency (Agencia Española de Protección de Datos, AEPD) has previously issued administrative penalties against two official Xiaomi retail stores in Madrid for illegally storing and exposing consumers’ personal data and employee privacy information on display devices, in violation of the core requirements of the General Data Protection Regulation (Regulation (EU) 2016/679, GDPR). In 2025, NOYB (None Of Your Business), a European digital privacy advocacy group, listed Xiaomi as one of the key Chinese enterprises under complaint, launching collective proceedings over the compliance of its cross-border data transmission and user information processing practices, confirming clear potential risks in its data security governance capabilities.

2.2 Systemic quality control and after-sales system defects recently exposed in the Chinese market

In July 2026, 1818 Golden Eye, a well-known consumer rights and livelihood news program in Zhejiang Province, China, reported a consumer rights dispute that highlighted loopholes in Xiaomi’s after-sales rules and quality control failures: a long-term user with nearly 200 devices across Xiaomi’s full ecosystem sent a smartphone for repair due to natural degradation of the rear camera sealing gasket (a manufacturing defect unrelated to user damage). The official service centre damaged the phone screen during disassembly and inspection, but subsequently attributed the screen damage to user-inflicted damage, refused to fulfil warranty obligations or provide a replacement, and declined all liability for the secondary damage caused during the inspection process.

This incident is not an isolated case. During the same period, media also exposed multiple related disputes: quality failures of the Xiaomi SU7 electric vehicle including millimetre-wave radar failure and advanced driver-assistance system (ADAS) malfunctions within 5 hours of delivery; and disputes over extended warranty services where the valid period did not match official promises, constituting suspected false service term commitments. These incidents jointly point to two core problems:

Xiaomi’s product quality control system has stability defects, with non-man-made factory quality issues occurring across both consumer electronics and automotive products.

Xiaomi’s after-sales system has systemic rules designed to evade obligations and shift liability: it transfers responsibility for secondary damage generated during inspection and repair to consumers, and deliberately lowers warranty performance standards, which is seriously inconsistent with the service commitments promoted by the brand.

2.3 Multiple potential compliance risks of Xiaomi Automobile’s EU market entry

Intelligent vehicles are a special product category with high safety requirements and high data sensitivity. Xiaomi’s current quality control and after-sales capabilities cannot meet the regulatory standards of the EU automotive market:

Vehicle safety and quality control risks: Xiaomi’s automotive business has been in operation for less than 3 years. Multiple complaints about factory defects of new vehicles and ADAS abnormalities have already emerged in the Chinese market, and the maturity of its mass production stability and complete vehicle safety verification has not been fully validated.

Insufficient after-sales delivery capacity: Xiaomi’s existing after-sales system in the EU only supports mobile phones and small smart hardware, and completely lacks local service capabilities for new energy vehicle fault repair, defect recall, and three-electric system (battery, motor, power electronics) maintenance. A hasty market entry would leave consumers with no basic protection of their rights.

Data security risks: Intelligent vehicles collect large amounts of sensitive data including user location trajectories, driving behaviour and in-cabin biometric information. Xiaomi has a prior record of data compliance violations in the EU, and there are major pending issues to be verified regarding whether its connected vehicle system and smart cockpit data processing procedures fully comply with GDPR requirements.

3. Specific Petition Requests

Launch a cross-business line review of consumer rights compliance 

Led jointly by DG COMP and the ECC Net, conduct a comprehensive review of Xiaomi’s warranty policies, after-sales processes and dispute resolution mechanisms for all business lines (smartphones, IoT products and automobiles) in the EU market. Verify compliance with the Consumer Rights Directive (Directive 2011/83/EU), with a focus on investigating whether Xiaomi artificially sets warranty barriers and refuses to fulfil statutory maintenance obligations.

Conduct a comprehensive pre-market compliance verification of Xiaomi Automobile 

Around the time Xiaomi submits its application for EU Whole Vehicle Type Approval (WVTA), the KBA, in cooperation with relevant EU authorities, shall carry out a full-dimensional verification of models planned for EU launch including the SU7 and YU7, covering:
Technical compliance of passive safety, active safety and three-electric systems of the complete vehicle;
Compliance of full-lifecycle battery management with the EU Battery and Waste Batteries Regulation (Regulation (EU) 2023/1542);
Functional safety of ADAS and authenticity of promotional content, to eliminate false or misleading advertising;
Data collection, storage and cross-border transmission processes of connected vehicle systems and smart cockpits, to verify full compliance with GDPR.

Verify the capacity of local after-sales and recall systems 

Require Xiaomi to submit a complete plan for its local EU automotive after-sales system, including maintenance network coverage, spare parts supply, defect recall response mechanisms and consumer dispute resolution channels. Regulators shall verify that its service capacity matches its planned sales volume and is capable of fulfilling statutory after-sales and recall obligations under EU law.
Suspend the market access process until the review is completed 

Until all the above reviews are completed and Xiaomi has completed all compliance rectification and passed regulatory verification, suspend the approval of Xiaomi Automobile’s EU WVTA, and prohibit all commercial activities including pre-sales and vehicle delivery within the EU.

4. Rationale and Justification for the Review

4.1 A proactive requirement to protect the legitimate rights and interests of EU consumers

The EU has the world’s strictest consumer rights protection system. Xiaomi already has a record of penalties for violating consumer rights regulations, and its current after-sales system has a systemic tendency to evade obligations. As high-value, safety-critical durable goods, quality and after-sales disputes involving automobiles will cause far greater property and safety losses to consumers than consumer electronics. A pre-market review can prevent risks at the source and avoid a situation where a large number of EU consumers are forced to defend their rights passively after their interests are damaged.

4.2 A statutory duty to maintain fair competition in the EU market

The EU automotive market has mature and unified compliance standards, and all market players must compete under the same rules. If enterprises with defective quality control and after-sales systems enter the market without strict verification, it will not only undermine the fair competitive environment, but also lower the service and quality standards of the entire industry. Launching a review is a necessary measure to ensure the sound development of the EU automotive market and uphold the rules of the single market.

4.3 An inevitable requirement to safeguard EU data security and privacy protection

Intelligent vehicles are mobile data collection terminals directly related to users’ core privacy and travel safety. Xiaomi has a prior record of data compliance violations, and as an enterprise domiciled outside the EU, its cross-border data transmission is more difficult to supervise. A proactive data security review can effectively prevent the risk of user privacy leakage and illegal data transmission, and is consistent with the legislative objectives and regulatory requirements of GDPR.

4.4 A reasonable measure to prevent industrial chain and public safety risks

New energy vehicles are a strategic industry for the EU, as well as a key category involving public safety. As a new entrant, Xiaomi Automobile’s supply chain compliance, product safety stability and defect recall response capabilities have not been tested by the EU market. A comprehensive review in advance can both prevent potential industrial competition risks and avoid public safety incidents caused by vehicles with hidden safety hazards on the road.