Proposal to amend definitions, recording triggering conditions, time zero establishment, crash test requirements, post-crash acceleration measurement, and data recording parameters:

• Amend definitions of automatically commanded steering function categories A, B1, B2, C, D, and E to clarify they are not part of a DCAS,
• Amend definition of “End of event time” to specify conditions for planar and other events,
• Amend definitions of “Engine throttle, percent full,” “Service brake status,” “Time interval between current event and previous event,” “Volatile memory,” and “VRU secondary safety system,”,
• Delete definition of “If recorded,”,
• Amend definition of “Non-volatile memory” to remove redundant text,
• Renumber “Accident Emergency Call System” from paragraph 2.2. to paragraph 2.25.,
• Insert new definitions for rollover protection system, AEBS, trigger activated, pre-event synchronization timer, blind spot monitoring system, emergency stop signal, turn signal, ACPE, ADDW, DCAS, and DDAW,
• Amend paragraph 5.3.1. on conditions for triggering recording to distinguish planar/VRU/rollover events from AEBS events and clarify that vehicles not fitted with certain systems are not required to trigger recording according to those paragraphs,
• Restructure paragraph 5.3.3. on time zero establishment to separately address planar/VRU/rollover events and AEBS events,
• Amend paragraph 5.4.3. to clarify crash test requirements,
• Amend paragraph 6.1. to clarify measurement of post-crash acceleration,
• Insert transitional provisions in paragraphs 12.12. through 12.16. establishing that as from entry into force no Contracting Party shall refuse to grant type-approvals under the 03 series of amendments, as from 1 September 2031/2029 Contracting Parties shall not be obliged to accept approvals to preceding series first issued after that date, until 1 September 2033 Contracting Parties shall continue to accept approvals issued according to preceding series first issued before 1 September 2031/2029, Contracting Parties may grant approvals according to any preceding series, and Contracting Parties shall continue to grant extensions of existing approvals to any preceding series,
• Amend Annex 1 to correct typo,
• Amend Annex 4 Table 1 to separate engine throttle and accelerator pedal data elements, increase recording intervals for rollover data, adjust recording intervals for AEBS events to −2.5 to 2.5 seconds, increase sample rates to 10 Hz for multiple data elements, add data elements for pre-event synchronization timer, trigger activated, ACPE status, ADDW status and time since warning, blind spot monitoring system status, turn signal status, DCAS status and driver monitoring system data, DDAW status and time since warning, and emergency stop signal status, and add time to collision data element for AEBS events.

Proposal to amend definitions 2.22 and 2.49 to modify the descriptions of non-volatile and volatile memory, and amend para. 5.3.1.2. to permit the EDR to write captured data from threshold criterion (a) in volatile memory only, with data from volatile memory written to non-volatile memory if any other trigger of para. 5.3.1. occurs or the vehicle master control switch is deactivated. The modification reduces memory wear in vehicles characterized by frequent stops. A version with tracked changes is available.

Proposal to amend Annex 4 – Data elements and format, Table 1, modifying Advanced driver distraction warning (ADDW) data elements to record status and time since warning issued instead of number of warnings and time elapsed since last warning, modifying Driver control assistance system (DCAS) driver monitoring system data elements to record time since disengagement warning issued and warning type instead of number of hands-on requests, eyes-on requests, direct control alerts, and time elapsed since last warning, and adding Driver drowsiness and attention warning (DDAW) status and time since warning issued data elements while removing number of warnings and time elapsed since last warning, with ADDW and DDAW elements listed up to five times for most recent warnings and DCAS warning type listed up to fifteen times for most recent warnings on current trip.

Proposal to add retrieval of DSSAD time-stamp data elements recorded for at least the last 30 seconds before the last setting of the event flag “Event Data Recorder (EDR) trigger input” alongside EDR data through the same interface, add provisions for retrieval when no such event occurs within the last 30 seconds, add provisions to replace date and time with relative time information when required by national or regional law, and add detected collision by Automated Driving System as an EDR trigger for UN R160 and UN R169.

Proposal to amend the 03 Series of Amendments to UN Regulation No. 160 (Event Data Recorder). The document modifies definitions, recording conditions, and data elements for EDRs. Key changes include: renumbering paragraph 2.2 to 2.25; amending definitions for end of event time, engine throttle, non-volatile memory, and volatile memory; adding new definitions for rollover protection systems, advanced emergency braking systems, and driver assistance systems; clarifying trigger conditions for recording planar, rollover, and vulnerable road user events; specifying time zero establishment; adding transitional provisions; and expanding Annex 4 data elements table to include pre-event synchronization timer, trigger activated status, acceleration control for pedal error, driver distraction warning, driver drowsiness warning, blind spot monitoring, turn signal status, and emergency stop signal status.

This document presents draft amendments to UN Regulation No. 169 for the EDR Step 2 workstream. It defines non-volatile memory as permanent EDR data storage retained after power loss, and volatile memory as temporary buffering that does not retain data. Requirements specify that EDRs capture and record data to non-volatile memory when triggered, with capacity for at least five events. Trigger conditions include sudden deceleration exceeding 3.25 m/s² for 0.7 seconds and vehicle stops at 0 km/h for 20 seconds. An amendment allows certain stop events to be recorded in volatile memory first, transferring to non-volatile memory when other triggers occur or the master switch deactivates, reducing memory wear in vehicles with frequent stops.

The Subgroup on EDR held a conference call to discuss Event Data Recorder Step 2 specifications. Key discussions included: AEB trigger recording intervals, with agreement on -2.5 to 2.5 seconds; ADDW and DDAW data elements referred to GRSG with competing proposals in square brackets; DCAS data elements with unresolved differences between industry and UK proposals on recording intervals and frequency; time to collision (TTC) deferred to Step 3; engine throttle deletion deferred pending further consideration; transitional provisions with industry proposing 2031 implementation versus EC’s 2029; and EDR for ADS requiring further development. Memory definitions for R169 and R160 were agreed upon.

The agenda includes discussion of EDR Step 2 documents and EDR for ADS documents, review of action items and schedule of future meetings, and adjournment. Future meetings are scheduled for September 8, 2026, and October 6-8, 2026.

Proposal to amend UN R160:

• Amend definitions 2.8., 2.10., and 2.11. to clarify that automatically commanded steering function categories B2, D, and E are not part of a DCAS
• Delete definition 2.25.
• Amend definition 2.35. to simplify non-volatile memory
• Amend para. 2.45. to change service brake terminology
• Amend para. 2.51. to clarify time interval between events
• Amend para. 2.65. to abbreviate vulnerable road user
• Insert new definitions 2.71.–2.83. for rollover protection system, advanced emergency braking system, trigger activated, pre-event synchronization timer, blind spot monitoring system, emergency stop signal, turn signal, acceleration control for pedal error, advanced driver distraction warning system, driver drowsiness and attention warning system, driver control assistance system, and time to collision
• Restructure para. 5.3.1. to distinguish planar, VRU, and rollover events from AEBS events with specified triggers
• Amend para. 5.3.2. to clarify data locking conditions
• Restructure para. 5.3.3. to establish time zero for planar, VRU, rollover, and AEBS events
• Amend para. 5.4.3. to specify side and frontal collision tests
• Amend para. 6.1. to clarify post-crash acceleration measurement
• Insert transitional provisions 12.12.–12.16. providing that as from the official date of entry into force Contracting Parties shall not refuse type-approvals under the 03 series, as from 1 September 2031 or 2029 [date TBD] shall not accept type-approvals to preceding series first issued after that date, until 1 September 2033 shall continue accepting preceding series approvals first issued before 1 September 2031 or 2029 [date TBD], may grant approvals to preceding series, and shall grant extensions of existing approvals
• Amend Annex 4 Table 1 to split engine throttle and accelerator pedal data elements, increase sampling rates to 10 Hz, extend recording intervals for rollover events, add pre-event synchronization timer, trigger activated, ACPE status, ADDW status, DDAW status, blind spot monitoring status, turn signal status, DCAS status, DCAS driver monitoring system warnings, emergency stop signal status, and time to collision data elements, and modify footnotes accordingly

France requests that the implementation date for all new vehicles be extended until September 2034 rather than the currently proposed date.

Proposal for a recording interval of 600 seconds prior to collision for driver drowsiness and attention warnings (DDAW), 240 seconds for advanced driver distraction warnings (ADDW), 240 seconds prior to collision for driver monitoring warnings from the driver-control assistance system (DCAS), triggers planar, VRU, Rollover, AEBS, AEBS for pedestrian, AEBS for bicycle, and AEBS for motor vehicle, and event data recording time-to-collision (TTC) range of 0 s to 5.0 s and resolution 0.1 s for AEBS events.

Document SG-EDR-47-02 and SG-EDR-47-03 were discussed. The group agreed to include definitions 2.8, 2.10, 2.11, and 2.20 with edits. Proposed definitions will be circulated by June 15 for review with comments due June 26. For data elements, disagreements on frequency rates between contracting parties and industry remain in square brackets. EDR for ADS will be addressed under GRVA and the ADS IWG. An October in-person meeting in Berlin is planned, pending WP.29 direction on integrating DSSAD into the ADS IWG.

Proposal to amend UN R160 definitions and event recording requirements:

• Amend definitions 2.8., 2.10., and 2.11. regarding Automatically Commanded Steering Function categories A, B1, and C,
• Amend definition 2.18. on “End of event time”,
• Amend definition 2.20. on “Engine throttle, percent full”,
• Delete definition 2.25.,
• Amend definition 2.35. on “Non-volatile memory”,
• Amend definition 2.45. on “Service brake status”,
• Amend definition 2.51. on “Time interval between current event and previous event”,
• Amend definition 2.65. on “VRU secondary safety system”,
• Insert new definitions 2.71. through 2.83.,
• Renumber para. 2.2. as 2.25.,
• Amend para. 5.3.1. to establish trigger conditions for planar, VRU, and rollover events separately from AEBS events with provision for events occurring within 300 ms overlap,
• Amend para. 5.3.1.1. through 5.3.1.5. to specify deployment triggers,
• Add new para. 5.3.1.2. for AEBS emergency braking demand trigger,
• Amend para. 5.3.2. and insert new para. 5.3.2.4. on rollover protection system deployment locking,
• Amend para. 5.3.3. to establish time zero for planar, VRU, and rollover events separately from AEBS events,
• Amend para. 5.4.3. to clarify crash test requirements as UN Regulations 95 and either 94 or 137,
• Amend para. 6.1. on acceleration measurement verification,
• Insert transitional provisions in new paras. 12.12. through 12.16. establishing entry into force of 03 series amendments, non-obligation to accept earlier series approvals as from 1 September 2031, and obligation to continue accepting earlier series approvals until 1 September 2033,
• Amend Annex 4 Table 1 data elements for recording intervals, sample rates, ranges, and new elements including Pre-Event Synchronization Timer, Trigger activated, ACPE, ADDW, DDAW, blind spot monitoring, turn signal, DCAS, emergency stop signal, and TTC.

Agenda for the 48th session of the Subgroup on EDR, a hybrid meeting scheduled for 15-16 September 2026 in Berlin. The agenda includes a final review of and potential amendments to official documents to GRSG regarding UN R160 and UN R169, discussion of the need for Step 3 and inventory of potential items for Step 3 workstream with presentations by IWG delegations expected, EDR for ADS, and a list of action items and schedule of future conference call meetings.

Proposal to amend Annex 4 Table 1 to modify the Vulnerable road user secondary safety system warning indicator status data element to record interval -1.1 to 0 sec, modify the VRU Accident emergency call system status data element to recording interval 0-300 ms or 0 to end of event time plus 30 ms whichever is shorter, add Advanced driver distraction warning (ADDW) status as mandatory with On and Off values for Planar, VRU, Rollover, and AEBS events, add ADDW time since warning issued as mandatory with 0 to 240 sec range and +/-1% accuracy at 1 sec resolution, add Driver control assistance system driver monitoring system time since disengagement warning issued as mandatory with 0 to 1000 sec or 0 to 240 sec range and +/-1% accuracy at 1 sec resolution, add Driver drowsiness and attention warning (DDAW) status as mandatory with On and Off values for Planar, VRU, Rollover, and AEBS events, and add DDAW time since warning issued as mandatory with 0 to 60 min or 0 to 600 seconds range, +/-1% accuracy, and 1 min or 1 sec resolution.

Proposal to amend UN R160:

• Insert new paras. 12.12. to 12.17. establishing transitional provisions for the 03 series of amendments, including that:
  • from the official date of entry into force, no Contracting Party shall refuse type approvals under the amended Regulation,
  • from 1 September 2031, Contracting Parties shall not be obliged to accept type approvals to preceding series first issued after that date,
  • until 1 September 2033, Contracting Parties shall accept type approvals to the 02 series first issued before 1 September 2031,
  • from 1 September 2033, Contracting Parties shall not be obliged to accept type approvals to preceding series,
  • Contracting Parties may grant type approvals according to any preceding series,
  • and Contracting Parties shall continue to grant extensions of existing approvals to any preceding series,
• Amend Annex 4 Table 1 and footnotes 28, 29, and 30 regarding trigger activated recording, powertrain torque demand signals, AEBS target classification, and TTC calculation requirements.

Proposal based on GRSG/2026/38 to amend para. 2.18. to define end of event time separately for planar events and all other events, amend para. 2.20. to redefine engine throttle percent full, insert new definitions for Advanced emergency braking system (AEBS) and Trigger activated, amend para. 5.4.3. to modify crash test data requirements and reference UN Regulations Nos. 95 and either 94 or 137, and amend Table 1 in Annex 4 to modify data element requirements including changing Air bag warning lamp and other elements from conditional to Mandatory, adding AEBS event recording, modifying Yaw Rate recording intervals and sample rate, clarifying Vulnerable road user secondary safety system warning indicator status recording, modifying Accident emergency call system status recording interval, and revising footnotes regarding TTC calculation and AEBS requirements, effective upon entry into force of the 03 Series of Amendments.

European Commission priorities for EDR Step 3 include improving detection of vehicle-to-vulnerable road user collisions and low-severity vehicle-to-vehicle collisions through adjusting delta-v trigger thresholds, developing new jerk-based trigger criteria, and exploring ADS collision detection for EDR triggering in automated vehicles on a long-term timeline. Data elements and format must be ensured to remain up-to-date with new safety system developments and close gaps between light and heavy vehicles through reviewing data elements in light of newly regulated safety systems and mirroring DDAW, ADDW and DCAS data elements from UN R160 to UN R169 on short-term and ongoing timelines.

Proposal to amend footnote 25 to reduce the maximum number of recorded DCAS warnings from 15 to 10 per current ignition cycle. The justification presented cites data burden reduction while retaining information about habitual driver disengagement patterns. Supporting documentation references two autopilot collision cases—Florida 2016 and California 2018—where recorded warnings within existing data retention periods would have revealed repeated disengagement that current recording parameters miss, demonstrating that 10 warnings combined with extended recording duration enables identification of ineffective warning strategies.

Proposal to clarify that the EDR volatile memory buffer for last stop trigger activation shall accommodate data related to at least five different stops to be overwritten on a first-in first-out basis, and that data for the most recent stops shall be written to non-volatile memory in a way that does not interfere with the event record related to any other trigger of paragraph 5.3.1.

For vehicles equipped with an Automated Driving System, it shall be possible to retrieve DSSAD time-stamp data elements specified under paragraph 5.2. of Annex 8 of UN Regulation No. 185 recorded within at least the last 30 seconds prior to triggering of the respective EDR event, regardless of whether the DSSAD and the EDR are implemented as a single system or as separate systems. The time-stamp data elements retrievable from the DSSAD shall include the record for the last activation or deactivation of the feature used at the time of the event within the same power cycle. The data elements shall be retrievable in the format specified in Annex 8 of UN Regulation No. 185, though DSSAD location data may be omitted and dates and times recorded may be replaced with information representing the time elapsed between the recording of each DSSAD data element and the triggering of the EDR.

Proposals for EDR Step 3:

• Improved triggering to increase detection rate of vehicle-to-vulnerable road user collisions and low-severity vehicle-to-vehicle collisions by considering delta-v and jerk-based trigger thresholds and developing updated triggering thresholds,
• Overwriting and multi-event issues by reviewing crash reconstruction experiences and developing updated requirements on overlapping events and overwriting,
• Data elements and formats to improve meaningfulness and close gaps by considering new data elements, modifications to data element format specifications, deviating recording duration, and focus on functions compared to specific systems,
• EDR for vehicles of category L₁–L₇ to establish relevant EDR requirements by understanding specificities of vehicles of category L₁–L₇ and developing triggering conditions, events, data elements, and survivability requirements.

A study of 24 professional truck drivers investigated how drowsiness develops during real-road driving to test a DDAW system. At night, 17 of 24 drivers reached a KSS level of 8, with average time to reach KSS 8 being 56 minutes. Ten drivers chose to stop or were requested to stop in the sleep-deprived condition. A DDAW recording window of 600 s would fail to capture information relevant to the EDR, whereas time windows of up to one hour could provide important indications of increased driver fatigue.

Proposal to:

• insert new paragraphs 2.71. to 2.78. defining
  • Position Code,
  • Turn Signal Switch Status,
  • Hazard Warning Signal Switch Status,
  • Hazard Warning Signal Lamp Status,
  • Turn Signal Lamp Status,
  • Gear Positions,
  • Seat-Track Position-1, and
  • Seat-Track Position-2,
• Delete existing data elements for Safety belt status by driver position, Frontal air bag deployment by driver and front passenger, Side air bag deployment by driver and front passenger, and Pretensioner deployment by driver and front passenger,
• Amend Table 1 to replace position-specific safety belt, frontal air bag, side air bag, knee airbag, far-side airbag, pretensioner, and occupant size classification entries with X-Y Position Code entries,
• Add Turn Signal Lamp status, Hazard Warning Signal Lamp Status, Turn Signal Switch Status, Hazard Warning Signal Switch Status, Gear Positions, and Seat-Track Position entries with recording intervals from -5.0 to 0 seconds or -1.0 seconds and sample rates of 2 samples per second.

Proposal to increase yaw rate recording frequency to 10 Hz. Yaw-rate data recorded at 2 Hz corresponds to one measurement every 500 ms; increasing to 10 Hz provides a measurement every 100 ms, resulting in a fivefold improvement in temporal resolution. This enhancement significantly improves ability to reconstruct pre-crash vehicle dynamics, identify vehicle instability onset and progression, and evaluate Electronic Stability Control functionality. A yaw-rate recording frequency of at least 10 Hz reduces temporal uncertainty from 500 ms to 100 ms and enables more accurate reconstruction of loss-of-control events, vehicle rotation, ESC interventions, and driving dynamical issues.