EU: Type approval of event data recorders for heavy duty vehicles – delegated act

 

The European Commission has launched a public consultation to set out the requirements for the type approval of M2, M3, N2 and N3 vehicles with regard to their event data recorders (EDR).

EDRs assist in gathering more precise and comprehensive data for accident research and analysis. They are already required for new models of passenger cars and vans. The General Safety Regulation mandates that the Commission also establish EDR technical requirements and testing procedures for new models of heavy-duty vehicles, with these requirements set to take effect from January 2026.

Regulation (EU) 2019/2144 mandates that motor vehicles be equipped with specific advanced vehicle systems. Annex II of this Regulation should outline the requirements for type-approval of motor vehicles regarding their event data recorders (EDRs) and the type-approval of these systems as separate technical units. It is necessary to supplement these requirements by establishing detailed harmonized rules on the specific test procedures and technical requirements for such type-approval.

The technical requirements and test procedures detailed in this Regulation apply to motor vehicle categories M2, M3, N2, and N3, in accordance with the applicable dates for refusal to grant EU type-approval for these categories as set out in Regulation (EU) 2019/2144. According to Article 3, point (13), of Regulation (EU) 2019/2144, an EDR is a system designed solely to record and store critical crash-related parameters and information shortly before, during, and immediately after a collision. This system aims to provide more accurate, in-depth accident data, enabling Member States to conduct road safety analysis and evaluate the effectiveness of specific measures.

The test procedures and detailed technical requirements for type-approval of vehicle types with regard to EDRs are governed by the provisions of UN Regulation No 169. Consequently, this UN Regulation should be included in the list of applicable requirements referenced in Article 4(5) of Regulation (EU) 2019/2144. UN Regulation No 169 outlines the requirements for data elements that EDRs must record, the data format, and the requirements for data capture, recording, and on-board storage, as well as survivability requirements.

To ensure vehicle manufacturers implement measures to protect EDR data against manipulation, ensure data availability over a standardized interface, and enable data anonymization, additional requirements for data retrieval, privacy, and security should be established. Manufacturers must take appropriate measures to ensure that EDR data remain anonymized, preventing these data from being reported or retrieved alongside any information related to an individual.

Until standardized communication protocols for accessing and retrieving event data are established through a Commission delegated act, vehicle manufacturers should provide relevant parties with information on how to access, retrieve, and interpret the data stored in the EDR. The operational status, functionality, and software integrity of EDRs should be verified through periodic roadworthiness tests of vehicles.

The table in Annex II to Regulation (EU) 2019/2144 currently lacks references to regulatory acts concerning EDRs for categories M2, M3, N2, and N3. Therefore, it is necessary to introduce references to this Regulation and UN Regulation No 169 in that Annex. As a result of the interconnected nature of the provisions in this Regulation, which establish rules for the type-approval of motor vehicles regarding their EDRs and for the type-approval of EDRs as a separate technical unit, it is appropriate to include these provisions in a single Delegated Regulation.

Since the requirements of Regulation (EU) 2019/2144 regarding EDRs for vehicles in categories M2, M3, N2, and N3 are set to apply from January 7, 2026, this Regulation should also apply from the same date.

To find out more about vehicle requirements and vehicle type approval in the EU, please do not hesitate to contact the Institute for Global Automotive Regulatory Research Directly.