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UN R169 Supplement 2 (00 series) · UNECE Regulation No. 169 (ECE R169) — Uniform Provisions Concerning the Approval of Event Data Recorders (EDR) for Heavy-Duty Vehicles.

UN R169 — Supplement 2 to the 00 series of amendments

Supplement 1 → 2

WP.29 vote: 200th session (17–20 November 2026)
What changed
  • For vehicle types of 8,000 to 12,000 kg maximum mass, paragraph 4.2.2. sets how to demonstrate equivalent EDR triggering.
  • New paragraph 4.2. grants approval, at the request of the manufacturer, for any vehicle type up to a maximum mass of 12,000 kg.
  • The former paragraphs 4.2. to 4.6. become paragraphs 4.3. to 4.7.
Why
  • The amendment removes any potential subjectiveness in the demonstration of equally effective triggering performance for vehicles between 8,000 and 12,000 kg.
  • It gives clarity on what is expected from manufacturers for this demonstration.

Q1What changed25 changes

Approval of vehicle types up to 12,000 kg (paras. 4.1. and 4.2.)

Paragraph 4.1. keeps only its first sentence: approval is granted if the vehicle type meets the requirements of paragraph 5. New paragraph 4.2. grants approval, at the request of the manufacturer, for any vehicle type up to a maximum mass of 12,000 kg. The conditions are a deployable occupant restraint system and compliance with the technical requirements of the 01 or later series of UN Regulation No. 160. Before this change, the alternative approval in paragraph 4.1. also referred to the transitional provisions of that series.

If the vehicle type submitted for approval pursuant to this Regulation meets the requirements of paragraph 5. below approval of that vehicle type shall be granted. Alternatively, approval shall be granted, at the request of the manufacturer and in case of a vehicle type equipped with deployable restraint system with maximum mass up to 12,000 kg if:
- this vehicle type meets the technical requirements and the transitional provisions of the 01 or later series of amendments to UN Regulation No. 160 and
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Equivalent EDR triggering for 8,000 to 12,000 kg vehicle types (paras. 4.2.1. and 4.2.2.)

For a vehicle type of 8,000 to 12,000 kg maximum mass, paragraph 4.2.1. requires EDR triggering performance equivalent to the M1/N1 vehicle type. In addition to paragraph 4.2., the vehicle type must be derived from a vehicle type of category M1 or N1. That M1/N1 vehicle type must meet the technical requirements of the 01 or later series of UN Regulation No. 160. To demonstrate equivalence, the manufacturer must determine the lowest deployment thresholds of the M1/N1 occupant restraint system in longitudinal and lateral collision scenarios. The manufacturer must describe the scenarios and their suitability; physical or simulation tests of the vehicle type must trigger the EDR in all of them. Before this change, the manufacturer had to demonstrate to the satisfaction of the approval authority that the triggering performance is equally effective.

In addition to the requirements in paragraph 4.2. above, in the case of a vehicle type with a maximum mass between 8,000 and 12,000 kg, approval shall be granted provided that:
the vehicle type is derived from a vehicle type of category M1 or N1,
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Triggering strategies and vehicle types without crash tests (paras. 4.2.3. and 4.2.4.)

The manufacturer’s documentation must give the EDR triggering strategies, for example the integration of other active safety systems or modified delta-v trigger thresholds. Vehicle types without the crash tests of paragraphs 5.4.1. and 5.4.2. of UN Regulation No. 160 are subject to paragraph 5.4. of this Regulation. Deleted paragraph 4.1.1. applied paragraph 5.4. to vehicles of paragraph 4.1. not subject to national and regional regulations providing for those crash test requirements.

The manufacturer’s documentation shall provide the EDR triggering strategies for the vehicle type such as the integration of other active safety systems or modified delta-v trigger thresholds.
Vehicle types that have not been subjected to crash tests as specified under paragraphs 5.4.1. and 5.4.2. of UN Regulation No. 160 shall be subject to paragraph 5.4. of this Regulation.
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New numbers for paragraphs 4.3. to 4.7. and updated references (para. 6.2. and Annex 3)

The former paragraphs 4.2. to 4.6. become paragraphs 4.3. to 4.7. Paragraph 6.2. now refers to paragraph 4.4., and the Annex 3 heading refers to paragraphs 4.5. to 4.5.1.

4.2.4.3.
4.3.4.4.
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Q2Why it changed

Proposed by
Experts of the Informal Working Group on Event Data Recorder / Data Storage System for Automated Driving
Working party
GRSG, 131st session (April 2026)

Reasons

  • The amendment removes any potential subjectiveness in the demonstration of equally effective triggering performance for vehicles with a maximum mass between 8,000 and 12,000 kg. It gives clarity on what is expected from manufacturers for this demonstration.

    Sources (2)
    “The UN Regulation is amended to remove any potential subjectiveness with regards to the demonstration of equally effectiveness of the triggering performance for vehicles with a maximum mass between 8,000 and 12,000 kg.”
    “This amendment provides clarity on what is expected from manufacturers for this demonstration.”

Document trail

  1. 2026-01ProposalECE/TRANS/WP.29/GRSG/2026/21Proposal by the experts of the IWG on EDR/DSSAD
  2. —Working party adoptsECE/TRANS/WP.29/GRSG/110Session report, para. 31
  3. 2026-08Sent to WP.29ECE/TRANS/WP.29/2026/182Text that GRSG sent to WP.29 and AC.1
  4. PendingWP.29 voteScheduled for the 200th session (17–20 November 2026)
  5. PendingIn forceDate not yet known

Q3Who is affected

Vehicle manufacturer

  • For 8,000 to 12,000 kg vehicle types, determine the lowest M1/N1 deployment thresholds in longitudinal and lateral collision scenarios (4.2.2.).
  • Describe these scenarios and their suitability for application to the vehicle type under approval (4.2.2.).
  • Make sure physical or simulation testing of the vehicle type results in EDR triggering across all the specified scenarios (4.2.2.).
  • Give the EDR triggering strategies of the vehicle type in the manufacturer’s documentation (4.2.3.).

Component supplier

  • No direct action for this role.

Technical service / Approval authority

  • Be ready to assess the EDR triggering equivalence demonstration for 8,000 to 12,000 kg vehicle types (4.2.2.).
  • Apply paragraph 5.4. to vehicle types without the crash tests of paragraphs 5.4.1. and 5.4.2. of UN Regulation No. 160.

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ⓘ This report gives advice only. It is not legal or type-approval advice.

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