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The regulators permit something akin to kickdown. While the cars will limit you under gentle/steady state driving, if you floor the accelerator to avoid an accident, the limiters will disengage:

3.6.1.4. It shall be possible for the driver to override the SCF intervention by performing a positive action, for example by pressing the accelerator control harder or deeper.

from https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:...

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at the cost of a delay which could make the difference between life and death

The system acts slowly and and is only active if the driver has engaged it (like cruise control).

You'll be driving at 120kph and you'll notice the car has slowed to 118kph because it thinks the speed limit is 100kph. You push the accelerator and update the speed limit. Done.

I honestly can't see this causing an accident. The thing isn't performing an emergency stop or anything.

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