4.13.1. | Proposal of new UN Regulation concerning the Approval of Event Data Recorders for Heavy-Duty Vehicles

12. (c) | New UN Regulation on Event Data Recorder for Heavy Duty Vehicles

25. The expert from the Netherlands on behalf of the IWG on EDR/DSSAD, with GRSG-126-12 introduced GRSG-126-02 superseding ECE/TRANS/WP.29/2023/134, which was adopted by GRSG at its March 2023 session and submitted for consideration and vote to the WP.29 session of November 2023. He clarified that IWG had not yet decided on including the last stop trigger. He added that IWG had agreed, that instead of the EDR-HDV requirements, manufacturers may comply with the EDR-Light Duty Vehicles (LDV) requirements for vehicles with maximum mass of 8,000 to 12,000 kg , but had not agreed:

1. whether this should be addressed in the scope or in the approval section (paragraph 4.); and
2. whether for a maximum mass between 8,000 and 12,000 kg, an additional demonstration by the manufacturer to the approval authority is necessary as evidence of effective triggering.

He also introduced GRSG-126-09 for information only, to provide an overview of the potential provisions under EDR Step 2 to be considered by IWG.

26. The expert from EC supported the proposed text of GRSG-126-02, paragraph 1.2.:

He explained that this compromise for vehicles between 8,000 and 12,000 kgs of maximum mass would prevent the risk of a legislative void, while allowing the Parties to ensure that the EDR data will be recorded in case of vehicles from 8,000 to 12,000 kgs. He also declared that an alternative solution (application of the material provisions of UN Regulation No. 160 to type-approval of vehicles between 8,000 and 12,000 kgs under paragraph 4.) would be acceptable as the second best solution only if the manufacturers were required to demonstrate to the satisfaction of the type-approval authority the equivalence of the triggering performance with the triggering performance under the UN Regulation on EDR-HDV. GRSG requested a vote of experts from the CPs of the 1958 Agreement on the term “may” or “shall” in the scope of the draft UN Regulation. Most CPs were in favour of the term “may” as proposed by the expert from EC. However, the expert from Finland raised concerns on possible dis-harmonization risks with the term “may”. The expert from the United Kingdom introduced GRSG-126-37 proposing the deletion of the alternative LDV requirements to EDR-HDV from the scope and the approval sections, and moving it to the specification section. The expert from OICA stated that the text of the scope proposed by GRSG-126-02 was contrary to the principle of mutual recognition of type approvals of the agreement and introduced GRSG-126-38.

27. The expert from AAPC introduced GRSG-126-30 explaining the opinion of his organization on the draft UN Regulation. He reminded GRSG that EDR are data-recording devices used for crash reconstruction to identify potential areas of improvement in safety designs. He added that UN Regulation No. 160 established EDR requirements aligned with the safety designs of the M1 and N1 categories of vehicles. The HDV-EDR UN Regulation addresses heavier vehicles with substantially different safety architectures. He clarified that medium vehicles (N2) derived from light vehicles (N1) have safety designs consistent with UN Regulation No. 160 across the entire range to 12,000 kg. He stated that the proposed HDV-EDR UN Regulation accepts approvals of such vehicles up to 8 tons under UN Regulation No. 160, but introduces additional requirements for such vehicles between 8,000 and 12,000 kg. Therefore, he noted the absence of evidence-based justifications to support the additional requirements. Thus, he questioned the principle that an EDR compliant with UN Regulation No. 160 could be refused approval under UN Regulation No. 160. Moreover, he stated that AAPC opposed the introduction of uncertainty over whether an N2 category vehicle integrating an EDR matched to its safety design could be refused approval or could be required to integrate an EDR inappropriate to its design, based solely on an arbitrary weight limit. Finally, he stated that his organization requested that its objection to the additional requirements for approvals under the draft HDV-EDR UN Regulation of vehicles having a maximum mass of 8,000 to12,000 kg of category N2 derived from N1 vehicles be recorded in the session report.

28. GRSG also considered amendment GRSG-126-02-Rev.1 to ECE/TRANS/WP.29/2023/134 as a compromise proposal by the IWG Chair.

29. The expert from the United States of America stated that in the spirit of harmonization and cooperation, her country has spent significant resources and time providing expert advice to the IWG from the Department of Transportation’s decades of experience with light-duty Event Data Recorders. She clarified that United States Regulation Part 563 serves as the foundation for UN Regulation No. 160. She stated that when the IWG focused on creating a regulation for heavy-duty (H.D.) EDRs under demanding timelines, the United States of America cautioned that the lack of global data and experience with HD EDRs could be a problem. Despite these efforts, the European Commission and European member States chose to focus the UN Regulation on vehicles of 8,000 kg and above, and ignored repeated concerns about the technical deficiencies with the last stop trigger. The United States does not consider the above proposal (ECE/TRANS/WP.29/2023/134 as amended by GRSG-126-02-Rev.1) technically ready for endorsement by GRSG. Without additional flexibilities in the regulatory language to reflect that not all medium- and heavy-duty vehicles mirror the types of vehicles in the European market, the draft UN Regulation may potentially create trade barriers for vehicles produced in North America. Further, she stated that the above proposal does not meet the longstanding objectives of WP.29 to promote safety and harmonization, and therefore it should be returned to the IWG for further work.

30. The expert from Canada supported the statement of the expert of the United States of America and the comments from the expert from AAPC regarding the applicability of UN Regulation No. 160 to medium vehicles derived from light vehicles. He believed the adoption of the proposal was premature because of lack of data and time to fully assess it and expressed support for continued technical discussion of the outstanding issues within the IWG. The expert from France suggested that a case-by-case solution could be the best one for a phase approach and that the proposal could be improved in a second step. The expert from Spain agreed with the approach of the expert from France. The GRSG Chair suggested that after data collection in using the UN Regulation, GRSG would have the basis to amend it. The experts from EC and Germany argued that it was requested several times to provide evidence and data about the concerns expressed by the United States of America.

31. Finally, most CPs to the 1958 Agreement adopted ECE/TRANS/WP.29/2023/134 as amended by GRSG-126-02-Rev.1. The secretariat was requested to replace ECE/TRANS/WP.29/2023/134 with ECE/TRANS/WP.29/2023/134/Rev.1 (ECE/TRANS/WP.29/2023/134 as amended by GRSG-126-02-Rev.1) as a proposal of new a UN Regulation for the Approval of Event Data Recorders on Heavy-Duty Vehicles for consideration and vote at the November 2023 sessions of WP.29 and AC.1.

10. (a) | Guidance on Event Data Recorder Performance Elements Appropriate for Adoption in the 1958 and 1998 Agreements Resolutions or Regulations

27. The expert from the Netherlands on behalf of the IWG on Event Data Recorder (EDR) / Data Storage system for Automated Driving Vehicles (DSSAD) introduced the status report (GRSG-125-25) of the group. He informed GRSG that the IWG had completed the light duty vehicle EDR performance elements appropriate for adoption in the 1958 and 1998 Agreement Resolutions or UN Regulations, completed UN Regulation No. 160 accordingly and DSSAD requirements within UN Regulation No. 157 (Automated Lane Keeping System). He also announced ECE/TRANS/WP.29/GRSG/2023/11, ECE/TRANS/WP.29/GRSG/2023/12 and ECE/TRANS/WP.29/GRSG/2023/15 on the acceleration data accuracy verification procedures. Moreover, he explained that the IWG had developed proposals on EDR for Heavy Duty Vehicles (HDV), as a: (a) new UN Regulation (ECE/TRANS/WP.29/GRSG/2023/13 amended by GRSG-125-07) and (b) a guidance document on EDR for HDV appropriate for adoption in 1958 and 1998 Agreement Resolutions or Regulations (ECE/TRANS/WP.29/GRSG/2023/14 amended by GRSG-125-08). He explained that the proposals were based on an existing Society of Automotive Engineers standard, data, analyses, research and contains unique triggering of acceleration, safety-systems and last stop.

28. Finally, GRSG agreed to combine ECE/TRANS/WP.29/GRSG/2023/12, as amended below, and ECE/TRANS/WP.29/GRSG/2021/32 as amended by GRSG-122-35 and submit them as proposal for amending the Guidance on EDR Performance Elements to the November 2023 session of WP.29 for information only. Moreover, it was agreed to send ECE/TRANS/WP.29/GRSG/2023/14 and GRSG-125-08 to the IWG for reconsideration.

Annex 1, Table 1, amend to read:

Longitudinal acceleration (post-crash)	If Recorded	0–250 ms or 0 to End of Event Time plus 30 ms, whichever is shorter.	500	-50 to 50g	/- 10%10	1g	Planar
Footnote 11, the reference to paragraph 6.1.5., correct as 4.1.5.

10. (c) | New UN Regulation on Event Data Recorder for Heavy Duty Vehicles

31. The expert from the Netherlands on behalf of the IWG on EDR/DSSAD introduced ECE/TRANS/WP.29/GRSG/2023/13, amended by GRSG-125-07, as a proposal for new UN Regulation on EDR for HDV.

32. The expert from Germany introduced GRSG-125-26 and shared views based upon data from the Federal Statistical Office of his country which showed that a significant proportion of accidents involving HDVs and VRUs occurred in the speed range below 50 km/h. Therefore, he suggested that improvements in road safety could be achieved if road accidents involving VRUs were better understood. He underlined that suitable triggers had been developed in the IWG (e.g. “last-stop triggers”), but were not accepted by all contracting parties. He stated that data from EDR-HDV would form the basis for future traffic safety research, especially for the protection of VRUs. He therefore supported the draft proposal of a new UN Regulation on EDR including the “last-stop-trigger” provision. The expert from EC supported the adoption of ECE/TRANS/WP.29/GRSG/2023/13, as amended by GRSG-125-07 including the above-mentioned provision as suggested by the expert from Germany.

33. The expert from the United States of America stated that her country had been an active member of IWG EDR at the technical level. She added that the group had been working hard to produce these documents (ECE/TRANS/WP.29/GRSG/2023/13 and GRSG-125-07) under demanding timelines. She added that despite these efforts, and as indicated by the large amount of text between brackets in the EDR-HDV documents, much more work is required at the technical level. Moreover, she stated that the United States of America did not support the incomplete proposal (in the framework of the 1958 Agreement) moving forward until the IWG finished its work. She also said that her delegation does not consider these documents technically ready for review by GRSG. She underlined that there would be also many technical concerns and issues to discuss when IWG considered the common technical requirements document. Finally, she stated that her country is not a signatory to the 1958 Agreement, but due to the global nature of the automotive industry, her delegation knows that UN Regulations would still impact vehicle safety in 1998 Agreement countries, and she respectfully requested that GRSG sends these documents back to the IWG on EDR/DSSAD for more technical review.

34. The expert from OICA stated that the proposal contained open questions on data elements. He stressed the need of the automotive industry to have a clear vision for the future, and he stated that his organization was not in the position to support the proposal. The experts from Canada and the Netherlands recommended that IWG finalize the work on the remaining issues. The expert from EC expressed the need to adopt the new UN Regulation at the November 2023 session of WP.29 to trigger the same mandatory provisions under the General Safety Regulation of the European Union. He reminded GRSG that this need had been taken into consideration by WP.29, and that GRSG was invited by the World Forum to maintain a high pace on this issue (see ECE/TRANS/WP.29/1168, paragraph 39). The experts from China and Japan supported the position of the expert from EC. The Chair of GRSG suggested adopting ECE/TRANS/WP.29/GRSG/2023/13, amended by GRSG-125-07 to make progress. At the same time, he recommended that IWG provide an informal or an official document for the deadline of submission of GRSG official documents (18 July 2023), to enable discussion at the October 2023 session of GRSG. The expert from OICA introduced a road map (GRSG-125-36-Rev.1) on the way forward to guide IWG towards finalization of the proposal.

35. Finally, GRSG agreed on the way forward proposed by the Chair and by the expert from OICA, though GRSG-125-36-Rev.1 was not considered binding. Therefore, GRSG adopted the proposal and requested the secretariat to submit ECE/TRANS/WP.29/GRSG/2023/13, as amended by GRSG-125-07, as proposal of new UN Regulation concerning the Approval of Event Data Recorders for Heavy-Duty Vehicles to the November 2023 sessions of WP.29 and AC.1. However, it was expected to resume discussion on this proposal based on revised documents submitted by IWG at the October 2023 session of GRSG.

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