FINALLY
Jan Paul Peters and Hans Bot,  April 2022

In 2011, together with Ralf-Roland Schmidt-Cotta – President of the EU Commission Veronica I, II and Egon-Christian von Glasner – President of the EVU (Europäischen Vereinigung für Unfallforschung und Unfallanalyse), we wrote a Proposal (draft) to Dr. Koch of the TRAN Commission of the European Parliament. Today, 11 years later, the final document of the Council of the European Union is published in the Official Journal, the number is: (EU) 2022/545.
New type approvals after 6 July 2022 must comply with this EU Regulation.

 
Main provisions:

  • The determination about the last 4 digits of the VIN has been removed.

  • It has been replaced by a general provision stating that the data of the EDR may not contain information that makes it possible to relate this data to a natural person. (Article 4. Par 5).

  • A report produced after reading the EDR must include (among other things): the precise vehicle type and the active safety systems installed in the vehicle. (Art 4. par 3).

  • The data recorded by an EDR may not be available via a vehicle interface for a wireless connection (Article 4. Par 4.).

  • The stored data of an EDR must also comply with ECE Reg 155 (Cyber ​​Security). (Article 3).

 
Until July 6, 2024, there is a transitional provision for cars with approval from outside the EU. They must comply with ECE Reg 160 but do not have to comply with Supplement 01 of ECE Reg 160. (Article 6).
 
See further: https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX:32022R0545

Presentation TESLA

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Latest Information 
Jan Paul Peters and Hans Bot,  April 2022

The EU has still not published the Regulation.
 
Regarding UNECE:
UN Regulation 160 on EDR: https://unece.org/sites/default/files/2021-10/R160e%20_0.pdf
 
On March 11, two changes (additions actually because they are called supplements) to UN Regulation 160 became final:
https://unece.org/sites/default/files/2022-01/ECE-TRANS-WP.29-2022-25r1e.pdf
https://unece.org/sites/default/files/2022-02/ECE_TRANS_WP.29_2022_26E.pdf

 
We do not understand the change with regard to the scope (art 1.3), because it was already in the original text
 
At the last meeting of WP29 the umbrella forum, nothing further was commented on EDR (see page 30)
https://unece.org/sites/default/files/2022-03/DRAFT%20ECE-TRANS-WP29-1164e.pdf
 
See also page 14 or the latest GRSG: https://unece.org/sites/default/files/2022-03/ECE-TRANS-WP.29-GRSG-101e.pdf

After some searching, we have found the exact status of the European EDR Regulation.
https://webgate.ec.europa.eu/regdel/#/delegatedActs/1704
It was adopted by the Commission on 22 January but is still available for inspection at the Council and Parliament, before being published.
 
Furthermore, there is now an overview of all secondary legislation:  https://ec.europa.eu/docsroom/documents/48576/attachments/1/translations/en/renditions/native
UNECE Regulation is already mentioned there, but it says nothing about VIN code.
 
This week there is GRSG in Geneva. The working group on EDR must report on this. In the appendices, you can see a number of reports about EDR that are presented there like; IWG on EDR/DSSAD Status Report and China’s suggestion for EDR regulation

 

Read the interesting additional proposals from France in document GRSG-123-21e about the use of GPS data and telephone use.
 

In addition to what is indicated in the table with regards to items to be stored, France would like to raise the following points:

• Importance of localization: it seems essential to us because:

  • the global studies will need this info to characterize the accident area (turn,summit of a hill, double lane ......) and this would make it possible to respond to lines 134, 135, 
    and 137 at least partially.

  • Useful in the event of an investigation to find out whether the vehicle has been the subject of a jammer or GPS Spoofing attack

 

• Additional items to be stored by EDR:

Infotainment system activities (phone call running, SMS reception on-screen, vocal SMS elaboration, etc.)

 

The Netherlands has requested that the scope be extended to include motorcycles, cyclists, and pedestrians. Would this mean a pocket-sized EDR for every pedestrian? Nice April 1 joke!

 

Way forward for EDR of the Netherlands

  • Since Motorcycles are involved in a lot of accidents, the Netherlands would like to extend the scope of the EDR with motorcycles as soon as possible.

  • Since pedestrians and cyclists are involved in a lot of accidents, the Netherlands would like to extend the scope of the EDR with pedestrians and cyclists as soon as possible.

After passenger cars, the EDR/DSSAD UNECE task force has shifted its scope to the introduction and specification of EDR in heavy vehicles. We have included various presentations to give everyone an idea of the current status of this topic. By clicking on the photo you download the presentations directly from the UNECE site. If you would like more information about HVEDR, you can read all the reports at https://wiki.unece.org/pages/viewpage.action?pageId=87621709.

 

We have also included a UNECE presentation about the EDR Tesla Accuracy Assessment.

Previous articles about EDR developments in Europe can be found on the page "EDR in Europe"

More information: JPPeters@eudarts.com

Presentation TESLA

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CHINA

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EDR

The European requirements for a VIN must comply with COMMISSION IMPLEMENTING REGULATION (EU) 2021/535 or March 31, 2021, by June 6, 2022.
The requirements for the VIN are specified in Annex II of this Regulation.
More info
here

 

In terms of content, they are the same as the requirements from 2011.
 

Students: Our Technician course indicates that the VIN is defined in ISO 3833. For Europe, it should now be Regulation 2021/535.


When assigning the WMI, the competent authorities must consult the international organization (SAE) mentioned in ISO 3833. That is the only link with ISO 3833.
 
Furthermore, the final technical requirements for a number of ADAS systems have now been published:


intelligent speed assistance Commission Delegated Regulation (EU) 2021/1958
driver drowsiness and attention warning Commission Delegated Regulation (EU) 2021/1341
alcohol interlock installation Commission Delegated Regulation (EU) 2021/1243
emergency lane-keeping systems (ELKS) Commission Implementing Regulation (EU) 2021/646

The new European requirements for a VIN
J.P. Peters, Hans Bot December 2021

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EDR

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Last week, the European Commission discussed a new version for the (draft) Commission Delegated Regulation for EDR in MVWG.
In this version there is nothing more about omitting the last 4 digits of the VIN !!
It is now also provided that data can be retrieved directly from the EDR if the OBD port is defective after the crash.

More information: JPPeters@eudarts.com

Latest version draft EU Regulation EDR
J.P. Peters, Hans Bot October 2021

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Privacy issues causing a delay for
EDR introduction.

Did the Commission shoot its own foot?
J.P. Peters, Hans Bot june 2021

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EDR

"Event data recorder" (EDR) means a device or function in a vehicle that records the vehicle's dynamic, time-series data during the time period just prior to an event (e.g., vehicle speed vs. time) or during a crash event (e.g., delta-V vs. time), intended for retrieval after the crash event.

Since traditional methods such as the length of skid marks are often no longer available with the introduction of ABS, EDR has become an essential tool for the reconstruction of road accidents

 

Regulation published, Delegated Act missing

 

The EU has made a first step to introduce the mandatory equipment of EDR with the Regulation (EU) 2019/2144. For the actual introduction of EDR, a so-called delegated act with detailed rules is necessary. According to Article 6 of the regulation the delegated act shall be published at least 15 months before the date manufacturers have to equip new cars with an EDR. As this date is 6 July 2022, the delegated acts should have been published before 6 April 2021. At the moment of writing this date has been largely passed.

The delegated act will have technical and administrative requirements. For the technical part a reference will be made to the new ECE Regulation on EDR. This is a worldwide harmonized technical standard on EDR. The Working Party WP29 and the Groups under it have done their best approve the ECE Regulation on EDR during the March session of WP29,  just in time for the 6th of April, the date set in the EU Regulation.

Out of the scope of the ECE Regulation on EDR are requirements related to privacy, data protection and personal data processing and data elements related to the VIN, associated vehicle details, location/positioning data, information of the driver, and date and time of an event. These elements has to be included in the Delegated Act to complete the EU Regulation.

An early draft of the Delegated Act was circulated the beginning of this year. This draft stated that it is prohibit to capture the last 4 digits of the VIN , the location, date and time of the accident and any information about the vehicle and driver.

NGO's to EC: EDR data impossible to use

Several organizations like ETSC, POLIS, ECF and CITA have stated that this prohibition will made it impossible to use EDR for accident research and accident analysis.

Although the Commission has shown some flexibility on location, date and time there is still the problem of the VIN and information on the vehicle and driver as this requirement is in Regulation (EU) 2019/2144 adopted by European Council and Parliament.

For in-depth accident research it is important to study Man, Machine, environment and their interaction. This is the case for both scientific and forensic research. Therefore it is essential to have information on the driver, the specific vehicle and the road condition at the spot of the accident.

The question is, why the Commission included this prohibition on the last 4 digits of a VIN.  To understand this we have to go back a few years.

VIN is not personal data

 In 2014 the European Commission commissioned a study on the cost benefit of EDR. This study was done by TRL and in the report of this study is a comprehensive chapter on privacy issues linked to EDR.  

It was concluded that a VIN is not personal data because a researcher is not able to make a link between a VIN and the owner. Only police officers are able to make such a link and in those cases safeguards has to be made. Why the European Commission neglected the conclusion from the TRL report on the VIN number?

Privacy hype

In 2016 several publications revealed the huge amount of data from cars some manufacturers are collecting systematically and sending to their factories. In a response the FIM started the awareness campaign “mycarmydata.eu”. Also in 2016 the EU General Data Protection (GDP) Regulation 2016/679 was published.  The following years all European citizens were confronted with requests to consent for cookies and the use of their name in databases and a privacy hype was started.

Privacy proof

 In an attempt to make  the Regulation 2019/2144  “privacy proof” the European Commission stipulated that the data an EDR is capable to record can be made available to national authorities, …. only for the purpose of accident research and analysis, …. , and in compliance with Regulation (EU) 2016/679, over a standardised interface.

To make it even more “privacy proof” the prohibition to include the last 4 digits of the EDR was added. This prohibition was added to guarantee maximum privacy and to assure an EDR report cannot be linked to a particular car and driver.

EDR data becomes useless

The insertion of 2016/679 is completely superfluous as the GDP Regulation is applicable anyhow. With the prohibition to include the last 4 digits of VIN, the EDR data becomes useless as it cannot be linked to a particular case,  so you can say the Commission shot in its own foot, because the aim was to improve road safety with EDR data playing an important role to monitor that. Now it looks that the anonymity of the driver who overrun a bicyclist or pedestrian  is more important than fate of the victim.

Workable solution needed

The 30th of June the European Commission will held a next meeting on EDR with the Member States experts and Stakeholders. On the agenda is an exchange of views,  on the draft Commission Delegated Act on EDR. Hopefully Member States representatives and Stakeholders will push to a workable solution that will allow to really use EDR data for accident analysis and research. The best solution is an amendment to 2019/2144 deleting the paragraph on the last 4 digits of the VIN.

More information: JPPeters@eudarts.com

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VIN visible behind every windscreen

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US: VIN is listed in every ad

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The only DIESEL recognizable by its VIN

EDR: First Step EDR approved by the GRSG.

Hans Bot and Jan Paul Peters, January 2021

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We would like to inform you that the first draft regulation for EDR,  developed by the Informal Working Group IWG EDR / DSSAD, has now been approved by the parent committee GRSG.

The IWG has drafted two documents: a first with 41 data-elements and a second with an additional 23 data elements that will become mandatory two years later, to allow the car industry more development time.


This first draft has the same 41 data elements as the US regulation CFR 563 although many of the optional data elements have become mandatory in this new draft. (See document ECE-TRANS-WP29-2020-123rev1e.pdf).
At the same time, an amendment to the first draft has been submitted with 23 additional data elements. These additional data elements have an extra transition time of 2 years before they becoming a mandatory requirement. 


These additional data elements are Safety belt status, rear passengers, Tyre Pressure Monitoring, System (TPMS), Longitudinal and lateral pre-crash acceleration, Yaw rate, Traction Control Status,  AEBS status,   Cruise Control System,   Adaptive Cruise Control Status,  VRU secondary safety system deployment,  Far side-impact center airbag,  Lane departure warning system status,   Corrective steering function (CSF) status, Emergency steering function (ESF) status, Automatically commanded steering function (ACSF) and Accident emergency call system status.
(See document
ECE-TRANS-WP29-2021-058e.pdf with the 41 and the 23 additional data elements combined)

The two documents have now been forwarded to the World Forum for Harmonization of Vehicle Regulations (WP.29) so that they can be considered and hopefully approved as UN Regulation in March. 


After adoption by WP29, The European Commission can draft the EU Delegated Act needed to make EDR mandatory in Europe as foreseen in the General Safety Regulation (2019/2144).  The EU Delegated Act will refer to the UNECE Regulation on EDR, complemented with requirements that are not foreseen in the UNECE Regulation, like retrieval, privacy, and security. 


The 41 data-elements will enter into force on the dates foreseen by General Safety Regulation (2019/2144). These dates are for new type-approval (new models) on the 7 of July 2022 and for new registrations on the 7 of July 2024. 


The additional 23 data elements will enter into force two years later: for new type-approval (new models)  July 2024 and for new registrations on July 2026.  Note: these dates apply to passenger cars and light-duty vehicles. EDR for Heavy goods trucks and buses will be introduced in 2029.

 

MORE information: EDR in EUROPE
 

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EDR : Automated/Autonomous and Connected Vehicles (GRVA).

Hans Bot , June 2020

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Here is an update of the progress of the regulations regarding EDR and DSSAD. Progress halted due to the Corona crisis: the session in Washington (at the end of March) was canceled and therefore it took a while to find a way of working. They now have 2-weekly 2-hour online sessions, and work is underway on further proposals. This is difficult, negotiating online is very difficult, but they are slowly working towards a result.
 

Status DSSAD for ALKS (logging of Lane Keeping System actions).


A version of the DSSAD text had already been delivered during the Tokyo session (January) and has now also been discussed in the GRVA (Groupe Rapporteur Vehicle Automatic, the parent group for DSSAD). Most elements have been approved, and the text has therefore largely been taken over as a paragraph in the ALKS regulations. The ALKS regulations are on the agenda for discussion in the WP.29 on June 23/24.
The ALKS regulations, with the DSSAD description in paragraph 8, can be found at
https://www.unece.org/fileadmin/DAM/trans/doc/2020/wp29/ECE-TRANS-WP29-2020-081e. pdf
 
EDR status.


Discussions on the EDR are much more diverse, and it has taken a long time to find a reasonable online working method. The assignment from WP.29 was to deliver a First Step EDR at the November session, plus a document (roadmap) for the Next Step EDR. This means that a First Step EDR regulation must already be submitted to the GRSG (Groupe Rapporteur Securite Generale, our parent group for EDR) July 1st This may still be worked on in Q3, but no "major" adjustments or new elements may be included.
 

Partly because of time constraints and divergent views, the Presidents have now chosen to focus on what they do agree on. The basis is the US CFR 563 scheme, this is a good scheme, but more than 10 years old and in need of modernization. In any case, there will be a number of adjustments and expansions that they can agree on internationally. However, due to the time pressure, it is quite possible that some of our European wishes will not be honored, but will be transferred to the Next Step EDR.

.
To get an idea of ​​the content of the discussions, you can look in the following folder:

https://wiki.unece.org/display/trans/SG-EDR-06+Web+Meeting


The document SG-EDR-06-01 EDR-Working-Draft.doc is the provisional version of the regulation, the other documents are proposals from OICA, China, and a number of European parties.

EDR : Automated/Autonomous and Connected Vehicles (GRVA).

Hans Bot , June 2020

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Here is an update of the progress of the regulations regarding EDR and DSSAD. Progress halted due to the Corona crisis: the session in Washington (at the end of March) was canceled and therefore it took a while to find a way of working. They now have 2-weekly 2-hour online sessions, and work is underway on further proposals. This is difficult, negotiating online is very difficult, but they are slowly working towards a result.
 

Status DSSAD for ALKS (logging of Lane Keeping System actions).


A version of the DSSAD text had already been delivered during the Tokyo session (January) and has now also been discussed in the GRVA (Groupe Rapporteur Vehicle Automatic, the parent group for DSSAD). Most elements have been approved, and the text has therefore largely been taken over as a paragraph in the ALKS regulations. The ALKS regulations are on the agenda for discussion in the WP.29 on June 23/24.
The ALKS regulations, with the DSSAD description in paragraph 8, can be found at
https://www.unece.org/fileadmin/DAM/trans/doc/2020/wp29/ECE-TRANS-WP29-2020-081e. pdf
 
EDR status.


Discussions on the EDR are much more diverse, and it has taken a long time to find a reasonable online working method. The assignment from WP.29 was to deliver a First Step EDR at the November session, plus a document (roadmap) for the Next Step EDR. This means that a First Step EDR regulation must already be submitted to the GRSG (Groupe Rapporteur Securite Generale, our parent group for EDR) July 1st This may still be worked on in Q3, but no "major" adjustments or new elements may be included.
 

Partly because of time constraints and divergent views, the Presidents have now chosen to focus on what they do agree on. The basis is the US CFR 563 scheme, this is a good scheme, but more than 10 years old and in need of modernization. In any case, there will be a number of adjustments and expansions that they can agree on internationally. However, due to the time pressure, it is quite possible that some of our European wishes will not be honored, but will be transferred to the Next Step EDR.

.
To get an idea of ​​the content of the discussions, you can look in the following folder:

https://wiki.unece.org/display/trans/SG-EDR-06+Web+Meeting


The document SG-EDR-06-01 EDR-Working-Draft.doc is the provisional version of the regulation, the other documents are proposals from OICA, China, and a number of European parties.

EDR : Automated/Autonomous and Connected Vehicles (GRVA).

Hans Bot , February 2020

To achieve the implementation of the GSR, TRL has been entrusted by the European Commission with a task to provide technical support in the development of the regulation text. The objective of the Commission is to achieve a high level of harmonization among the Parties, based on the text stipulating the collection and in-vehicle storage of a wide range of collision-related data elements, for both conventional and automated vehicles, and providing for appropriate privacy-by-design requirements. The Commission expects the Regulation to be endorsed by the WP29 in November 2020. This is necessary to take the future UN Regulation into account while drafting the implementing measures under the GSR. After November 2020, the work should continue on the provisions on EDR for heavy vehicles, required in the EU as from 2026.

GRVA's priorities include: 

  • Safety and security of vehicle automation and connectivity:

    • (See the Framework Document on Automated Vehicles)

    • Functional requirements ("FRAV")

    • Validation Method for Automated Driving ("VMAD")

    • Cybersecurity (and software updates)

    • EDR / Data Storage System for Automated Driving (currently)

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LATEST UPDATE

FEBRUARY 21

2020

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Click on the Agenda to download the complete notes of the latest meeting.

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Click on the picture to download the complete presentation from Western Digital 

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Click on the Excel scheme to download the complete TRL list with EDR data elements

Latest update about the new General Safety Regulation:

Jan Paul Peters / Hans Bot,  April 18th, 2019

 

Event Data Recorders (EDR) will soon become mandatory in the EU for new cars, vans, heavy goods vehicles, and buses, as a part of a package of safety measures in the General Safety Regulation (GSR), approved by  European Parliament on the 16th of April 2019. The new regulation will require new vehicles to be fitted with a large number of Advanced Driver Assistance Systems (ADAS). The European Parliament managed to approve the text for the regulation in its last session before the upcoming European elections and avoided a delay due to the installation of the new parliament. The text needs still to be verified by the linguistic and legal services and to be approved by the Council of Ministers. As there was already an informal agreement by the Council, no major changes to the text are expected. Application dates Publication of the Regulation is expected in September/October, the entry into force is 20 days after the date of publication. New type approvals for cars and vans have to comply 30 months after the entry into force (March 2022 expected) and new registrations have to comply after 54 months (March 2024 expected). Heavy Good Vehicles and Busses (Category M2, M3, N2, and N3) have to comply after 42 resp. 78 months.

ADAS required

 

The new regulation will require motor-vehicles to be equipped with the following advanced safety devices:

  1. Advanced emergency braking (cars, vans)  

  2. Alcohol interlock installation facilitation (cars, vans, trucks, buses)

  3. Drowsiness and attention detection (cars, vans, trucks, buses)

  4. Distraction recognition / prevention (cars, vans, trucks, buses)

  5. Event data recorder (cars, vans, trucks, buses)

  6. Emergency stop signal (cars, vans, trucks, buses)

  7. Full-width frontal occupant protection crash test improved seatbelts (cars and vans)

  8. Head impact zone enlargement for pedestrians and cyclists -safety glass in case of a crash (cars and vans)

  9. Intelligent speed assistance (cars, vans, trucks, buses)

  10. Lane keeping assist (cars, vans)

  11. Pole side-impact occupant protection (cars, vans)

  12. Reversing camera or detection system (cars, vans, trucks, buses)

  13. Tyre pressure monitoring system (vans, trucks, buses)

  14. Vulnerable road user detection and warning on the front and side of the vehicle (trucks and buses)

  15. Vulnerable road user improved direct vision from the driver’s position (trucks and buses)

 

Event data recorders

 

Art 6 of the new regulation specifies the EDR: Event data recorders shall meet the following requirements in particular:

(a) the data that they are capable of recording and storing with respect of the period shortly before, during and immediately after a collision shall include the vehicle's speed, braking, position and tilt of the vehicle on the road, the state and rate of activation of all its safety systems, 112-based eCall in-vehicle system, brake activation and relevant input parameters of the onboard active safety and accident avoidance systems, with high level of accuracy and ensured survivability of data;

(b) it shall not be possible to deactivate the devices;

(c) the way in which they are capable of recording and storing data shall be such that:

     (i) they operate on a closed-loop system;

     (ii) the data collected is anonymized and protected against manipulation and misuse;

     (iii) precise vehicle type, version and variant, and in particular the active safety and accident avoidance systems fitted to the vehicle, can be       identified;

(d) the data can be made available to national authorities, on the basis of Union or national law only for the purpose of accident research and analysis, including for the purposes of type-approval of systems and components and in compliance with Regulation (EU) 2016/679, over a standardized interface.

 

An event data recorder shall not be capable of recording and storing the last four digits of the vehicle indicator section of the vehicle identification number or any other information which could allow the individual vehicle itself, its owner or holder, to be identified. The European Commission shall adopt delegated acts in accordance laying down detailed rules. Those delegated acts shall be published at least 15 months before the relevant application dates.

Comparison with US regulation on EDR

 

The new EU regulation will require the fitment of an EDR, while the US regulation 49CFR Part 563 does not require the EDR itself, but requires a minimum set of parameters if an EDR is fitted. The new EU regulation will require an EDR to record more parameters than the current US regulation. A separate US law (Driver Privacy Act of 2015) specifies the ownership of the EDR data and the conditions of use, for example, to facilitate emergency medical responses or in court, or after written consent. The new EU regulation requires to respect the General Data Protection Regulation 2016/679 (GDPR), doesn’t allow the storing of the last 4 digits of the VIN, but doesn’t specify the ownership or use.

 

Next steps

 

First of all, it will be necessary to monitor the drafting of the detailed rules during the coming months. The requirements for EDR are mainly aimed to collect data for research purposes. Future will learn how EDR can be used in individual accident cases. In some Member States, the use of  EDR after an accident has become a routine and several court cases have given a solid jurisprudence, but there are also the Member States with almost no experience. Monitoring of national legislation on EDR is needed.

 

Further information The provisional text of the regulation can be found at the following link: http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//NONSGML+TA+P8-TA-2019-0391+0+DOC+PDF+V0//EN

To read the text in a different language replace “EN” at the end of the link by the code of the desired language.

More Information

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EU progress EDR / General Safety Regulation:

Hans Bot January 2019

 

Progress:

The Environment Committee has already prepared and adopted its report (1 vote against UKIP)

http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//NONSGML+COMPARL+PE-629.435+01+DOC+PDF+V0//EN&language=EN

The Transport Committee has decided on 3 December on the amendments (167) to the draft report previously sent.
http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//NONSGML+COMPARL+PE-627.562+01+DOC+PDF+V0//EN&language=EN

http://www.europarl.europa.eu/sides/getDoc.do?type=COMPARL&reference=PE-629.447&format=PDF&language=EN&secondRef=01
Voting: January 2019
 
The Internal Market Committee (IMCO) has published its draft report (deadline was December 6)

http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//NONSGML+COMPARL+PE-629.496+01+DOC+PDF+V0//EN&language=EN

Discussion in IMCO 21/22 January 2019
Vote 20/21 Feb 2019

Note: EDR is now called ADR!
 
The EP (European Parliament) has itself written a background document:

http://www.europarl.europa.eu/RegData/etudes/BRIE/2018/625192/EPRS_BRI(2018)625192_EN.pdf

Motorbikes: last week agreement was reached for tightening the requirements for motorcycles incl. OBD, but the date of entry has been shifted to 2024:
https://www.consilium.europa.eu/en/press/press-releases/2018/11/14/review-of-type-approval-rules-for-two-three-or-four-wheel-vehicles-agreement-reached-with-the-european-parliament/
 
Antonio Perlot, Secretary General, European Association of Motorcycle Manufacturers has informed me that he will put my request "EDR in Motorcycles" on the agenda for the meeting in January.

Latest update about the new General Safety Regulation:

Hans Bot December 2018

 

As you may know, in May this year the Commission published a proposal to replace the current General Safety Regulation 661/2009 (the 'General Safety Regulation') and also to introduce a large number of new safety measures. In addition, adjustments are proposed in the field of pedestrian protection and hydrogen vehicles and the impetus for the inclusion of automated vehicles within the type approval framework. This proposal is part of the third mobility package.
 
November 29, at the European Council of Competitiveness, the Council adopted a 'general approach' on the proposal. This means that the Member States have agreed on the text, see: 
http://data.consilium.europa.eu/doc/document/ST-14467-2018-INIT/en/pdf.
A large number of non-essential adjustments have been made with regard to the original proposal. In addition, a number of improvements that are important for the Netherlands have been omitted. In particular, the provisions for ISA (intelligent speed assistant) are insufficiently discouraging for drivers to exceed the speed limit. An important adaptation for our members is that the data from the Event Data Recorder (EDR) may still be used for accident analysis. (Albeit without storage of the entire VIN, the Ministry of Justice is still investigating the legal consequences). More applications for EDR were unfortunately not feasible.
 

Finally, an important adjustment is that virtually all elaboration of the underlying legislation will take place through implementing acts so that decision-making on these matters lies with the Member States.
 
The negotiations are expected to start with the EP in February. For the provisional position of the (responsible) committee, see
https://simdash.io/uploads/upload/file/49179/getDoc.pdf.
 
Given the position of the EP, I do not expect the final text to change essentially. However, I do expect earlier implementation and application dates.

 

More information about this topic.

  

EUROPEAN COMMISSION COMMENTS

Posted by J.P. Peters,  June, 2018

 

Below you can read several comments by the EUDARTS members about the EU Commission Proposal; 

We advise you to take actions to your EP representative or your government to get a regulation that fits the needs of all of us in the near future.

 

  • The Commission proposal is entirely focused on obtaining data for scientific research.

  • Large parts of the report made by TRL for the Commission have not been taken over: EDR is only mentioned for scientific research and not for all other parties that benefit from it (see TRL report par 10.3)

  • According to TRL, privacy is not an issue since normal persons cannot find a driver on the basis of a VIN number. (conclusion TRL see par 4 and App D) In the Commission proposal, the last 4 digits of the VIN number cannot be registered or stored by the EDR.

  • The deletion of the last 4 VIN digits makes it impossible to check whether the correct safety components (eg airbags) are present.

  • There is no provision for the ownership of the EDR data. This is an issue in several states in the USA. There is nothing to do if the owner does not give permission to read the EDR data. (see TRL par 4.3)

  • EDR’s are driven from the systems for maintenance (Repair and maintenance). This is not discussed at all. Also, the possibility to view the status of a car via the EDR is not discussed.

  • The idea of an electronic passport for cars is made impossible because the VIN number cannot be stored.

  • In the USA the VIN number has to be stored, which means that a separate version for Europe will have to be made.

  • The proposal always refers to the General Data Protection Regulation 2016/679, but it is overlooked that a separate directive applies to investigative authorities.

  • Art 7 paragraphs 5 and 6 must be completely rewritten.

  • Both the European insurers' association and the German insurers only consider EDR necessary for trucks and buses;

  • The FIA does not see the usefulness and necessity of EDR and is afraid of human rights. (document)

  • The FIA document rattles on all sides. They say that 90% of cars in the EU already have EDR and they doubt the reliability of EDR.

 

 

  

EUROPEAN COMMISSION

Posted by Hans Bot,  May 17, 2018, Brussels,

 

Hans Bot - EUDARTS organization & Development, Ralf-Roland Schmidt-Cotta – President EU Commissie Veronica I, II en Egon-Christian von Glasner– President of the EVU (Europäischen Vereinigung für Unfallforschung und Unfallanalyse write a: Proposal (draft) to the TRAN.  Today the final document of the Council of the European Union is published.

 

Download documents

Doc 9006/18

Doc 9006/18 ADD2

Doc 9006/18 ADD 1

Doc 9006/18 ADD3

An overview of our activities: the introduction and regulation in Europe regarding EDR in (motor) vehicles.

Schematic overview of EDR in the USA;

Schematic overview of the state of affairs in Europe;

  • 2003 : Veronica (Vehicle Event Recording based on Intelligent Crash Assessment: EU DG TREN project within the EU Road Safety Action Plan 2003: Objective : the definition of technical , legal and possible prevention requirements for mandatory introduction of accident data recording devices including pre -requisites for automatic crash notification;

  • 2003 : Veronica I ( 2003-06); Report 2006;

  • 2004 : Report: Ministry of Transport of the Czech Republic in the period IV.2004-XII.2006;

  • 2007 : Veronica II ( 2007-09); Report 2009.

 

Schematic overview of the state of affairs by the Hans Bot and Jeroen van Essen (members of the EDR SUPPORT GROUP)

  • 2008: Seattle: “Crash Data Retrieval Technician Course”, “Crash Data Retrieval Data Analyst Course”;

  • 2008: Christmas: Accident Rotterdam solved bij using EDR; Press ADValidation Paper

  • 2009: Houston: ‘Train the trainer” ;

  • Determining the strategy;

  • 2010 : Start CrashCube project: Press; 

  • 2011: Presentation TRAN committee (2011-01); together with Ralf-Roland Schmidt-Cotta – President EU Commissie Veronica I, II en Egon-Christian von Glasner– President of the EVU (Europäischen Vereinigung für Unfallforschung und Unfallanalyse,  consultations with EP members; Mr. El Khadraoui (Belgium), Mrs. Sender (Spain) Mrs. Meissner (Germany) en Peter van Dalen (Netherlands and vice-president of the TRAN committee)

  • 2011 : Proposal (draft) written to the TRAN committee.

  • 2011 : Draft resulted in an amendment of parliament Mr. Koch (promo)

  • 2011 : Debate in plenary of the European Parliament (2011-09-25).

  • 2011 : Vote in plenary session of the EP with the result ; (2011-09-27)

 

35a . Calls on the Commission to submit a legislative part proposal, Including a timetable and a detailed approval procedure by the end of 2012 providing for the phased introduction , Initially in : rented vehicles and subsequently useful in commercial and private vehicles or an integrated accident recorder system with a standardized readout Which records relevant data before , during and after accidents ( ' Event Data recording '); stresses in That connection , the need to protect Individuals ' personal data and to use the data recorded EXCLUSIVELY for accident research.

 

 

​The European Commission (EC) has commissioned a study on the benefits for road safety resulting from the installation of event data recorders. Event Data Recorders (EDRs) record a range of vehicle data over a short timeframe before, during and after a triggering threshold and are typically used to record information about road traffic accidents. The aim of this study is to assist the Commission in deciding whether the fitting of EDRs in all vehicles or certain categories of vehicles could result in an improvement of road safety or have other possible consequences that would justify the costs associated with the adoption of EU legislative measures. The study aims to quantify the costs and benefits for heavy goods vehicles, light goods vehicles, buses and coaches, and passenger cars (for private and commercial use).

 

  • 2014 : eu Data Analysis Research Training & Service (euDARTS Group - asDARTS - trDARTS)

  • 2014 : Volvo activates EDR on its new models in Europe.

  • 2014 : On Thursday 5 June 2014, a Stakeholders meeting on the benefits for road safety resulting from the installation of event data recorders take place. It was held at Meeting room L130.B Rue de la Loi 130, Brussels en was coordinated by TRL London.

    The Directorate General for Mobility and Transport has commissioned a study on the use of Event Data Recorders (EDR). In the context of this study, EDRs are understood as devices which continuously register and store the values taken by a series of vehicle parameters so that a sequence of those records covering some seconds before, during and after a crash can be recovered. The purpose of the contract is to assist the Commission in deciding whether the fitting of EDR in all vehicles or certain categories of vehicles could result in an improvement of road safety or have other positive consequences that would justify the adoption of EU legislative measures and to assess the costs and benefits of such measures.
    The work of the Commission on this topic falls under the framework of its Policy Orientations for Road Safety 2011-2020 , in particular under Objective 5 (Promote the use of modern technology to increase road safety).
    Attendance was by invitation only. The stakeholders present gave their opinion about EDR in Europe to Transport Research Laboratory, TRL, which is the consultant in charge of the study (edr@trl.co.uk). A large majority were positive about in the possible introduction of EDR in Europe. More information you can find in the folowing documents: 
    the slides presented at the meeting & a summary document covering the main meeting discussion points & EDR Cost Benefits. TRL expected in September to have their report read. Additional clarifications can be requested to the Road safety Unit in the Directorate-General for Mobility and Transport:MOVE-C4-SECRETARIAT@ec.europa.eu.

 

 

  • 2014 May: Toyota activates EDR on its new models in Europe.

  • 2014 June: Lexus activates EDR on its new models in Europe.

 

  • 2015:New European Commissioner for Transport makes road safety a priority.

 

Violeta Bulc is the new European Commissioner for Transport for the period 2014-19. Before entering politics, Ms Bulc held several top corporate positions both in Slovenia, her native country, and in the US in fields including logistics, telecommunications and sustainable and innovative business solutions. She was Deputy Prime Minister and Minister for Development, Strategic Projects and Cohesion before moving to Brussels.

Commission looks at benefits of event data recorders
A recent road safety-related study examines the benefits resulting from installation of event data recorders (EDR) on motor vehicles. EDR record vehicle data from before, during and after a crash so that a sequence of records can be recovered. This helps with investigation of the circumstances of an accident, determination of liability and data collection for safety research aimed at improving understanding of causes of accidents and applying appropriate safety measures to prevent them.

Two technical studies with important road safety implications have recently been carried out on behalf of the European Commission, the first of which deals with safety aspects of tyre use. Good tyres enhance road holding, particularly in wet or slippery conditions, or when braking.
Commission looks at benefits of event data recorders
The second recent road safety-related study examines the benefits resulting from installation of event data recorders (EDR) on motor vehicles. EDR record vehicle data from before, during and after a crash so that a sequence of records can be recovered. This helps with investigation of the circumstances of an accident, determination of liability and data collection for safety research aimed at improving understanding of causes of accidents and applying appropriate safety measures to prevent them.


Europe Direct Contact Centre provides invaluable road safety support
The Europe Direct Contact Centre (EDCC) in Brussels provides a central information service which citizens can contact by phone or e-mail in any official EU language in order to get answers to questions on a range of subjects related to the EU. It can also point citizens in the direction of information and advice sources and EU-, national- or local-level contacts, give information on EU citizens’ rights and opportunities and how to use them and provide specialized information.

 

More information - click on NEWSLETTER

For a type-approval of motor vehicles making demands include enshrined in the EC regulation 661/2009. (N.B. In addition to this Regulation, other regulations, particularly in the area of ​​emissions and the protection of pedestrians.). Article 7 of Regulation 661/2009 states that it evaluated every three years. For purposes of this evaluation, the European Commission DG Internal Market, Industry, Entrepreneurship and SMEs draw up a report on the feasibility and cost benefits of a large number of very diverse number of measures. Installation of EDR in motor vehicles had a positive benefit / cost ratio.

 

Finally, on the basis of this report, drawn up a list of potential measures and discussed in the Motor Vehicle Working Group (WVWG) A working group composed of representatives of the Member States, industry and consumers who advises not bound by the European Commission through new regulations. In July 2016, the final version of the list is discussed in the WVWG. Proposed Crash Event Data Recorders is mandatory for M1 (passenger cars for no more than eight passengers excl. Driver) and N1 (vans up to 3500 kg) from September 1, 2020 for new models and from September 1, 2022 for new registrations.

 

It is now waiting for the effect of the proposed regulations.