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

India comments raising concerns over the feasibility of the proposal to combat odometer fraud in used car sales.

Submitted by India
Discussions and Outcomes
GRSG/2015/16

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.