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Comments on the proposed draft 01 series of amendments to Regulation No. 39
Document GRSG-108-38
5 May 2015

OICA comments expressing opposition to the proposed measures to combat odometer fraud in the used vehicle market.

Submitted by OICA
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Previous Documents, Discussions, and Outcomes
4. | Regulation No. 39

17. Referring to the role of his organization, the expert from FIA recalled the purpose of ECE/TRANS/WP.29/GRSG/2015/16 proposing further provisions on the protection against mileage fraud. He introduced GRSG-109-04 justifying the need to establish an informal working group (IWG) on anti-tampering measures for electronic vehicle interfaces, such as odometer, and underlining the need to cope, in a more general manner, with risks of in-vehicle technologies and cyber security. His proposal to set up an IWG received the support of a number of experts. However, some other experts felt it was too premature to set up such an IWG as WP.29 already established, under its IWG on Intelligent Transport Systems (ITS), a subgroup on “Automated Driving” dealing with this subject among others. Therefore, they preferred to start on the basis of an expert group first. The expert from FIA volunteered to organize in the near future a Task Force meeting in Paris. Thus, he invited all interested experts to contact him (

3. | Regulation No. 39 (Speedometer)

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.

Related and Previous Documents
Relates to Odometers | UN R39 |