UN R135 Supplement 4 (02 series) · UNECE Regulation No. 135 (ECE R135) — Uniform provisions concerning the approval of vehicles with regard to their Pole Side Impact performance (PSI).
UN R135 — Supplement 4 to the 02 series of amendments
Supplement 3 → 4
- What changed
- The Regulation now accounts for vehicles of category X and does not apply to vehicles of category Y.
- For vehicles of category X, the manufacturer must propose the tested side (paragraph 5.1.1.).
- The definition of “Vehicle width” (paragraph 2.27.) now also excludes sensors for Advanced Driver Assistance Systems and sensors for Automated Driving Systems.
- Why
- The TF-AVRS proposal was prepared to enable the application of the Regulation to vehicles equipped with an Automated Driving System (ADS).
- The amendment intends to keep the spirit of the Regulation. It also intends to extend its application to vehicles without a driver and without manual driving controls inside the vehicle.
- WP.29 aimed to adopt all documents of the review of existing UN Regulations for Automated Driving Systems (ADS) at its June 2026 session.
Q1What changed21 changes
Introduction and scope for vehicles of categories X and Y (sections 0. and 1.)
New section 0. says that the Regulation is amended to account for vehicles of category X. New paragraph 1.3. says that the Regulation does not apply to vehicles of category Y. Without a driver or manual driving controls in the vehicle, related provisions must not be taken into account, unless this amendment already covers them. For vehicles with an ADS other than category X, no special provisions or exemptions apply in the manual driving mode. In a mode where an ADS feature is active, the relevant ADS requirements apply. In item (b), on category N1 vehicles, for vehicles of category X the "R" point of the most forward passenger seat replaces the driver's R-point.
Tested side for vehicles of category X (paragraphs 5.1.1., 5.1.2., 5.1.2.1. and 5.1.2.2.)
Paragraph 5.1.1. adds that, in the case of vehicles of category X, the manufacturer must propose the tested side. Paragraph 5.1.2. now also applies to vehicles of category X. For these vehicles, the Approval Authority may use either of the alternatives in paragraph 5.1.2.1. or 5.1.2.2. Paragraphs 5.1.2.1. and 5.1.2.2. now refer to “the side defined under paragraph 5.1.1.” instead of “the driver's side”.
Sensors excluded from the vehicle width (paragraph 2.27.)
The definition of “Vehicle width” (paragraph 2.27.) now also excludes sensors for Advanced Driver Assistance Systems and sensors for Automated Driving Systems.
Driver and steering wheel provisions in Annex 3 (paragraph 2.14.) and Annex 4 (paragraphs 2.2., 5.1.2.1., 8.4.7. and 8.4.7.3.)
In Annex 4, paragraph 2.2., the sentence on driver bench seating positions now ends with “steering wheel hub (if applicable)”. Annex 4, paragraph 5.1.2.1., now starts “An adjustable steering wheel (if applicable)”. Annex 4, paragraph 8.4.7., now reads “For a driver seating position (if applicable)”. New paragraph 8.4.7.3. of Annex 4 says that, in the case of vehicles of category X, paragraph 8.4.8. applies. Otherwise, paragraphs 8.4.7.1. and 8.4.7.2. apply. In Annex 3, the definition of “Vehicle master control switch” (paragraph 2.14.) now says “without a driver present” instead of “without the driver present”.
References to R.E.3 in footnotes, including the footnote of paragraph 4.5.1.
The footnote with the definitions in R.E.3 now refers to document ECE/TRANS/WP.29/78/Rev.8 instead of Rev.7. The footnote of paragraph 4.5.1. on the distinguishing numbers of the Contracting Parties now refers to Rev.8 instead of Rev.7.
Q2Why it changed
- Proposed by
- Expert from Germany on behalf of the GRSP Task Force on Automated Vehicles Regulation Screening (TF-AVRS)
- Working party
- GRSP, 78th session (December 2025)
Reasons
The TF-AVRS proposal was prepared to enable the application of the Regulation to vehicles equipped with an Automated Driving System (ADS). The Regulation was first written for vehicles with a driver and manual driving controls. The amendment intends to keep the spirit of the Regulation. It also intends to extend its application to vehicles without a driver and without manual driving controls inside the vehicle.
Sources (4)
“to enable the application of the regulation to vehicles equipped with an Automated Driving System (ADS)”
“See paragraph 0. in the proposal”
“The Regulation was originally drafted for vehicles with driver and manual driving controls”
“It is the intention of this amendment to keep the spirit of the regulation and to extend its application to vehicles without driver and without manual driving controls inside the vehicle”
WP.29 aimed to adopt all documents of the review of existing UN Regulations for Automated Driving Systems (ADS) at its June 2026 session.
Source
“WP.29 reaffirmed its objective to adopt all documents related to the review of existing UN Regulations related to Automated Driving Systems (ADS) at its June 2026 session”
Document trail
- 2025-09ProposalECE/TRANS/WP.29/GRSP/2025/34Proposal by the expert from Germany on behalf of TF-AVRS
- —Amended in sessionGRSP-78-43TF-AVRS changes to ECE/TRANS/WP.29/GRSP/2025/34
- —Working party adoptsECE/TRANS/WP.29/GRSP/78GRSP session report, para. 43 and Annex XVIII
- 2026-04Sent to WP.29ECE/TRANS/WP.29/2026/67Text that GRSP sent to WP.29 and AC.1
- —Amended in sessionWP.29-199-10Amendments for the AC.1 vote, reproduced in Annex VI of ECE/TRANS/WP.29/1192
- 2026-06-24WP.29 adoptsECE/TRANS/WP.29/1192Adopted at the 199th session (session report, para. 103)
- PendingIn forceDate not yet known
Q3Who is affected
Vehicle manufacturer
- Check in R.E.3 (ECE/TRANS/WP.29/78/Rev.8) if your vehicles are of category X or category Y.
- For vehicles of category X, propose the tested side (paragraph 5.1.1.).
- For category N1 vehicles of category X in item (b), take the "R" point of the most forward passenger seat.
Component supplier
- Tell the vehicle manufacturer which parts you supply are sensors for Advanced Driver Assistance Systems or Automated Driving Systems.
Technical service / Approval authority
- If the vehicle has no driver or manual driving controls, ignore related provisions unless this amendment already covers them.
- When you determine the vehicle width, exclude sensors for Advanced Driver Assistance Systems and for Automated Driving Systems (paragraph 2.27.).
- For vehicles of category X, apply Annex 4, paragraph 8.4.8., as new paragraph 8.4.7.3. says.
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ⓘ This report gives advice only. It is not legal or type-approval advice.