Proposal to:

• Amend para. 1.4. to clarify recording obligations for data elements when sensors lack design capability to meet format requirements,
• Amend para. 2.20. to define engine throttle as driver-requested acceleration torque demand,
• Amend para. 2.73. to define trigger activated,
• Amend para. 5.4.3. to clarify crash test requirements and specify data retrievability after impacts of severity levels set by UN Regulations Nos. 94, 95 or 137,
• Insert new paras. 12.12. through 12.17. establishing transitional provisions with dates from entry into force through 1 September 2035,
• Amend Annex 4 Table 1 to add data elements including occupant size classification, vulnerable road user secondary safety system warning indicator status, and advanced driver distraction warning time since warning issued, with modified recording intervals, sample rates, and ranges for existing data elements.

Proposal to amend para. 1.4. to clarify that recording requirements depend on availability of the trigger or data element itself, amend para. 5.3.1.2. to permit the EDR to write last stop trigger data in volatile memory only, accommodating at least five most recent stops to be overwritten on a first-in first-out basis until any other trigger occurs or the vehicle master control switch is deactivated, and amend paras. 2.5., 2.48. and 2.49. for clarity and consistency with UN Regulation No. 160.

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 introduce a unified Position Code (X-Y) for all seating positions, add seven new mandatory data elements for driver operation and seat-track position to Annex 4 Table 1, and harmonize ADAS status enumerations into one unified set eliminating fragmented and inconsistent wording across system entries.

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.

Proposal to amend para. 1.4. to clarify obligations for recording data elements where sensors or systems cannot meet specified format requirements. Recording is not required if no system or sensor is designed to provide the trigger or data element, or if not operational at the time of the trigger condition or recording. However, if the vehicle is fitted with an original equipment manufacturer sensor or system designed to provide the trigger or data element in the specified format, reporting in that format is mandatory when operational. Where sensor or system design capabilities do not allow format requirements to be met, the data element shall nevertheless be recorded and the corresponding limitation reported. Failure states shall be recorded by the EDR.

Document presents Korean research on event data recorder (EDR) data survivability in electric vehicles following post-crash fires. Analysis of nine Korean EV fire cases shows EDR data retrieval failed in three cases due to ACU damage in fully burned vehicles, while six cases achieved data retrieval despite water immersion from firefighting. The document proposes water immersion testing to assess EDR data survivability for inclusion in EDR Step 3, referencing international automotive standards for test method development.