Document GRSG/2015/15
Proposal for draft 01 series of amendments to Regulation No. 39
Status: Superseded

Proposal to insert performance requirements for the installation of odometers on vehicles.

Submitted by Belgium
Discussions and Outcomes

9. Recalling the purpose of ECE/TRANS/WP.29/GRSG/2015/16 presented at the previous session of GRSG, the expert from FIA reiterated his position on the need to protect odometer equipment against mileage fraud and, therefore, to place the subject in a broader context. He introduced GRSG-110-17 on the current status of the discussion on cybersecurity in the subgroup Autonomous Driving of the WP.29 informal working group on Intelligent Transport Systems (ITS-AD). He proposed to further discuss with OICA experts the security and functional safety specifications of ISO standards 26262 and 15408 on cybersecurity, data protection and remote access to in-vehicle data. The expert from OICA announced his intention to coordinate, in the near future, a common position from his stakeholder and volunteered to report back to GRSG at the forthcoming session.

10. The GRSG Chair suggested resuming consideration of this subject at the next session of GRSG and invited the expert from FIA to get in contact with OICA.


14. The expert from Belgium introduced ECE/TRANS/WP.29/GRSG/2015/15, as amended by GRSG-108-30, proposing to insert new provisions for the installation of odometers on vehicles. GRSG noted general support on the proposal.

15. Following the discussion, GRSG adopted ECE/TRANS/WP.29/GRSG/2015/15, as amended below, and requested the secretariat to submit it to WP.29 and the Administrative Committee of the 1958 Agreement (AC.1) for consideration at their November 2015 sessions, as draft 01 series of amendments to UN Regulation No. 39.
Paragraph 2.6., correct “information equipment” to read “odometer equipment”.
Paragraph 5.5.1., correct “odometer may be” to read “odometer shall be”.

16. The expert from FIA gave a presentation (GRSG-108-37) justifying the need for protection against mileage fraud and proposing to set up an informal working group on this subject. He presented ECE/TRANS/WP.29/GRSG/2015/16 proposing further amendments to the proposal submitted by Belgium and inserting a reference to the common criteria published in ISO/IEC 15408 (GRSG-108-06). He concluded that the common criteria would result in a higher level of stringency in the security requirements for odometers and thus improve the protection of odometers against mileage fraud. The expert from India raised concerns (GRSG-108-39) to the proposal from FIA. The expert from OICA introduced GRSG-108-38 clarifying the subject and presenting the concerns of the automotive industry to the proposal from FIA. GRSG experts were invited to send their comments to the expert from FIA. GRSG did not support the adoption of the proposal but agreed to keep ECE/TRANS/WP.29/GRSG/2015/16 and GRSG-108-38 on its agenda as a reference document for further consideration at its next session.


10. The expert from Belgium introduced ECE/TRANS/WP.29/GRSG/2014/32, proposing new requirements for odometers into UN Regulation No. 39. She presented GRSG-107-29-Rev.1 amending her proposal to include the comments received by the expert from OICA (GRSG-107-20). GRSG supported in principle the proposal. However, there was a general agreement among experts that the mandatory fitting of odometers should be completed by transitional provisions, anti-tampering requirements and type approval markings. GRSG agreed to resume consideration on this subject at its May 2015 session on the basis of a revised proposal from the expert of Belgium and on a proposal of transitional provisions from the experts of OICA and IMMA.