UN R39 Base text (02 series) · UNECE Regulation No. 39 (ECE R39) — Uniform provisions concerning the approval of vehicles with regard to the speedometer and odometer equipment including its installation.
UN R39 — 02 series of amendments
Changes from 01 series of amendments (supplement 2)
- What changed
- New paragraph 5.8. sets a ±4.0 per cent limit for the total distance indicated against the true distance travelled in the Annex 4 test.
- New paragraph 5.12. requires protection of the total distance indicated and total distance values against manipulation.
- As from 1 September 2028, Contracting Parties applying this Regulation need not accept approvals to preceding series first issued after that date.
- Why
- The proposal extends the odometer requirements to the accuracy and anti-tampering of mileage values.
- The odometer tolerance applies to the Annex 4 type-approval test, not to vehicles on the road.
- For feasibility and proportionality, the malfunction indication is limited to electrically detectable failures.
Q1What changed155 changes
Definitions for odometers, mileage values and tampering (paras. 2.2.2. to 2.8.)
New paragraphs 2.6.2. to 2.6.4. define “Total distance indicated”, “True distance travelled” and “Total distance value”. New paragraphs 2.6.5. to 2.6.7. define “Tachograph or Recording equipment”, “Tachograph Replacement Unit (TRU)” and “Purely mechanical odometer”. New paragraph 2.8. defines “Tampering” as any activity aiming at inaccurate recording or misrepresenting of mileage values being stored and/or displayed. Paragraph 2.6. now says “the total distance driven by the vehicle” instead of “the total distance recorded by the vehicle since its entry into service”. In paragraph 2.4., the increase for the “Normal running pressure” is now 200 hPa instead of 0.2 bar. The footnote on the speed-indicating part of a tachograph is deleted.
Application, approval and the forms in Annexes 1, 2 and 5 (paras. 3.1. to 4.3.)
Under paragraph 3.1., the application goes to the Type Approval Authority according to Schedule 3 of the 1958 Agreement. Paragraph 3.2. no longer asks for documents in triplicate, and new Annex 5 gives a model information document. Approval numbers are now assigned in accordance with Schedule 4 of the Agreement (paragraph 4.2.). Paragraph 4.3. now also covers notice of extension, withdrawal and production definitively discontinued, and gives no A4 format for the diagrams. New Annex 1 items 6.1. to 6.3. cover the odometer ratio, a purely mechanical odometer and malfunction indication; tyres are now item 7. The Annex 2 examples now show the 02 series, and footnotes refer to document ECE/TRANS/WP.29/78/Rev. 7.
More than one speedometer or odometer, and the speedometer test (paras. 5.1. to 5.3.6.1.)
If more than one onboard speedometer or odometer is fitted, all of them must comply with all the requirements of this Regulation. Additional graduations and numerical values are not permitted. Tachographs or Recording equipment, or Tachograph Replacement Units are not on-board speedometers or odometers for the purpose of paragraph 5.1. The reference temperature of 23 ± 5 °C now applies if relevant for the test, at the discretion of the Technical Service (paragraph 5.3.3.). The test track surface no longer needs to be dry; it must be flat and provide sufficient adhesion (paragraph 5.3.6.1.). Paragraph 5.2. gets the heading “Speedometer”.
Odometer accuracy, the Annex 4 test and resolution (paras. 5.5. and 5.7. to 5.10.)
The odometer accuracy must be tested with the procedure of new Annex 4 (paragraph 5.7.). In that test, the vehicle is driven for a minimum of 10 kilometres or 7 miles as indicated on the odometer. The total distance indicated must not deviate by more than ±4.0 per cent from the true distance travelled (paragraph 5.8.). Total distance values from the data port specified in UN Regulation No. 154 or No. 49 must not deviate from the (rounded) total distance indicated. This does not apply to the total distance travelled (lifetime) as defined in UN Regulation No. 154. Total distance values and the total distance indicated must have a resolution better than or equal to 1 km or 1 mile, as appropriate.
Purely mechanical odometers, L category vehicles and tachographs (para. 5.6.)
Paragraphs 5.7. to 5.9. and 5.11. to 5.12. do not apply to vehicles fitted with purely mechanical odometers. Paragraphs 5.9. and 5.11. to 5.12. do not apply to L category vehicles. Another rule applies to vehicles equipped with a tachograph or recording equipment, or where a tachograph replacement unit is the only source of measuring mileage. Paragraphs 5.7. to 5.9. and 5.12. then count as met if the recording equipment is at least equivalent in security and accuracy to this Regulation.
Malfunction indication and anti-tampering of mileage values (paras. 5.11. and 5.12.)
If an electrically detectable failure prevents the odometer requirements of this Regulation from being met, a malfunction indication must be given to the driver. This is not necessary if other failure warnings and/or other failure conditions already cover it. The indication may be temporarily cancelled, but must be repeated each time the ignition or the vehicle master control switch is activated. The total distance indicated and total distance values must be protected against manipulation (paragraph 5.12.). One condition for this is that the manufacturer’s management system encompassing cyber security complies with the relevant requirements of UN Regulation No. 155. The other condition is that proportionate mitigations are implemented, including, or equivalent to, mitigation 7 of UN Regulation No. 155.
Transitional provisions for the 02 series (paras. 10.5. to 10.11.)
As from 1 September 2028, Contracting Parties applying this Regulation need not accept approvals to preceding series first issued after that date. Until 1 September 2030, Contracting Parties applying this Regulation must accept 01 series approvals first issued before 1 September 2028. As from 1 September 2030, Contracting Parties applying this Regulation need not accept approvals issued to any preceding series. The malfunction indication of paragraph 5.11. is not compulsory for 02 series type approvals until 1 September 2030. This exemption stays applicable for extensions of approvals first granted before 1 September 2030. Contracting Parties applying this Regulation may grant approvals to any preceding series and must continue to grant extensions of existing approvals to them.
Q2Why it changed
- Proposed by
- Task Force on UN Regulation No. 39 covering mileage values
- Working party
- GRSG, 128th session (October 2024)
Reasons
A task force was established to develop a proposal for the odometer equipment with regard to mileage values processing. Its terms of reference cover the accuracy of on-board odometer mileage values. They also cover security management and anti-tampering, to prevent and/or detect, to the greatest extent possible, manipulation of these values.
Sources (2)
“a Task Force (TF) was established to develop a draft regulatory proposal with regard to the odometer equipment in respect of mileage values processing”
“security management and anti-tampering, to prevent and/or detect, to the greatest extent possible, manipulation of the on-board odometer mileage values in vehicles”
The odometer tolerance applies to the Annex 4 type-approval test. It does not relate to real-life situations, for example vehicles on the road. Annex 4 was drafted as a simple and effective procedure for a test track or a roller dynamometer.
Sources (2)
“The required tolerance value is within the scope of type-approval as established by the type-approval procedure described in Annex 4 and does not relate to real-life situations, e.g. actual vehicles on the road.”
“It is drafted as a simple and effective procedure which can be performed on a test track or roller dynamometer chassis and can potentially be combined with the speedometer testing.”
The malfunction indication to the driver is for defective odometer equipment. For reasons of feasibility and proportionality, it is limited to electrically detectable failures, and other failure warnings or conditions may cover it. Industry considered the malfunction indicator particularly relevant for the introduction dates.
Sources (2)
“A malfunction indication to the driver in case of defective odometer equipment is included. For reasons of feasibility and proportionality, this is limited to electrically detectable failures and the indication may be covered by other failure warnings or conditions.”
“Industry considers that, the introduction of the malfunction indicator is particularly relevant for deciding on the appropriate introduction dates.”
Mileage values must be protected against tampering. The proposal links this to the manufacturer’s cyber security management system under UN Regulation No. 155. Cyber security experts helped to draft this wording for mileage values.
Sources (2)
“This can be deemed to be complied with when the manufacturer’s cyber security management system complies with the relevant requirements of UN Regulation No. 155, and when the vehicle type complies with the relevant technical requirements of that Regulation.”
“With help of cyber security experts, a proper language was drafted to make this applicable in the most appropriate way for the purpose of mileage values processing.”
Vehicles with a purely mechanical odometer technically cannot comply with the new level of accuracy and security. It is expected that only a very small number of vehicles may have mechanical odometers. Equipment such as tachographs often measures and stores the mileage with a high level of accuracy and security.
Sources (3)
“It had been identified that vehicles fitted with “purely mechanical odometer” can technically not comply with the level of accuracy and security introduced by this UN Regulation.”
“It is also expected that only a very small number of vehicles may be equipped with mechanical odometers.”
“vehicles fitted with equipment like, for example, tachographs, often measure and store the mileage with a high level of accuracy and security.”
Document trail
- —ProposalGRSG-127-06Earlier proposal on paragraph 5.1. by the Netherlands and the United Kingdom
- 2024-07ProposalECE/TRANS/WP.29/GRSG/2024/36Proposal by the Task Force on UN Regulation No. 39 covering mileage values
- —Amended in sessionGRSG-128-02-Rev.3Compromise proposal that GRSG considered
- —Working party adoptsECE/TRANS/WP.29/GRSG/107Session report, para. 16
- 2025-01Sent to WP.29ECE/TRANS/WP.29/2025/18/Rev.1Text that GRSG sent to WP.29 and AC.1
- 2025-03WP.29 adoptsECE/TRANS/WP.29/1184Adopted at the 195th session (session report, para. 109)
- 2025-09-26In forceC.N.506.2025.TREATIES-XI.B.16.39UN depositary notification
Q3Who is affected
Vehicle manufacturer
- Unless paragraph 5.6. exempts the vehicle, keep the total distance indicated within ±4.0 per cent in the Annex 4 test.
- Check that the management system encompassing cyber security meets the relevant UN Regulation No. 155 requirements for paragraph 5.12.
- Be ready to give a confidential outline of your chosen means of malfunction indication at type approval (paragraph 5.11.2.).
- Use the new Annex 5 model information document for the application (paragraph 3.2.).
Component supplier
- Make sure that the odometer equipment supports the malfunction indication of paragraph 5.11. for electrically detectable failures.
- Give the vehicle manufacturer the data for the Annex 5 items on the speedometer and odometer (item 4.8.).
Technical service / Approval authority
- Before agreeing to an alternative odometer test procedure, check that it gives at least the same test accuracy.
- Decide if the 23 ± 5 °C reference temperature is relevant for the speedometer test (paragraph 5.3.3.).
- Note that the malfunction indication of paragraph 5.11. is not compulsory for 02 series approvals until 1 September 2030.
- Fill in the new Annex 1 items 6.1. to 6.3. in the communication form.
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ⓘ This report gives advice only. It is not legal or type-approval advice.