UN R39 Supplement 2 (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 — Supplement 2 to the 02 series of amendments
Supplement 1 → 2
- What changed
- For vehicles of categories X and Y, an on-board odometer is required, but a speedometer is optional and need not meet this Regulation.
- If the ADS meets the indicator provisions of UN Regulation No [XXX], the speedometer need not indicate the speed while an ADS feature is active.
- The odometer display must be visible or accessible to a driver, if applicable, or any authorised person.
- Why
- The supplement takes into account vehicles of categories X and Y and vehicles with an ADSF-2 and a manual mode above 6 km/h.
- The amendment intends to extend the Regulation to vehicles without a driver and without manual driving controls.
- The change to paragraph 5.5. is to allow authorised persons to read the odometer.
Q1What changed26 changes
New introduction to the supplement (paras 0. to 0.1.4.)
New paragraph 0. is an introduction to Supplement 2. Supplement 2 takes into account vehicles of categories X and Y and vehicles with an ADSF-2 and a manual mode above 6 km/h. Without a driver or manual driving controls, provisions related to them must not be taken into account, unless this amendment already covers them. For vehicles with an ADS other than categories X and Y, no special provisions or exemptions apply in the manual driving mode. In a mode where an ADSF-2 is active, the relevant ADS requirements must be met. Paragraphs 0.1.3. and 0.1.4. explain the changes to paragraphs 5.1. and 5.5.
Definitions of ADSF-1, ADSF-2, odometer and unladen vehicle (paras 2.6., 2.7., 2.9. and 2.10.)
New paragraphs 2.9. and 2.10. define two types of ADS feature. An ADS feature of type 1 (ADSF-1) includes an ADS fallback response that requires a fallback user. An ADS feature of type 2 (ADSF-2) does not include an ADS fallback response that requires a fallback user. In the odometer definition (para. 2.6.), the words “to the driver” are deleted. For vehicles of category X and Y, the unladen vehicle (para. 2.7.) no longer carries a driver of 75 kg.
Odometer and speedometer on the vehicle, and vehicles of categories X and Y (para. 5.1.)
Each vehicle to be approved must have an on-board odometer that complies with this Regulation. An on-board speedometer that complies with this Regulation is required only for vehicles other than those of category X or category Y. A vehicle of category X or category Y may have a speedometer, but it does not have to meet the requirements of this Regulation. Before this supplement, paragraph 5.1. required an on-board speedometer and odometer on the vehicle to be approved. The rules on more than one speedometer or odometer and on tachographs are now in separate paragraphs, with the same requirements.
Speedometer while an ADS feature is active (para. 5.2.)
If the ADS meets the indicator provisions of UN Regulation No [XXX], the speedometer need not indicate the speed while an ADS feature is active. Before this supplement, this paragraph had no rule for vehicles with an ADS. The sentence on the range of speeds displayed moves to a separate paragraph and does not change. In paragraph 5.2., the text that GRSG sent to WP.29 said “unless a driver performs the DDT”, not “while an ADS feature is active”. Annex VI of ECE/TRANS/WP.29/1192 amended paragraph 5.2. to say “while an ADS feature is active”, and AC.1 adopted ECE/TRANS/WP.29/2026/105 as amended by that annex.
Odometer display for authorised persons and unit choice by the ADS (paras 5.5. and 5.5.2.)
The odometer display must be visible or accessible to a driver, if applicable, or any authorised person. Before, the display had to be visible or accessible to the driver. If a setting lets a driver or the ADS select the odometer unit independently of the speedometer, the odometer must identify the unit used. Before, this rule named only the driver.
Odometer malfunction signal to the ADS (para. 5.11.)
Paragraph 5.11. covers an electrically detectable failure that prevents the odometer requirements of this Regulation from being met. The words “if applicable” are added to the malfunction indication to the driver. In vehicles of categories X and Y and where an ADSF-2 is active, the malfunction must be transmitted to the ADS as a logic signal.
Updated references in two footnotes and paragraph 5.9.
Two footnotes now refer to document ECE/TRANS/WP.29/78/Rev.8 instead of Rev. 7 and give a new web address. The footnote that starts “As defined in the Consolidated Resolution” no longer gives “para. 2”; this comes from Annex VI of ECE/TRANS/WP.29/1192. Paragraph 5.9. changes the punctuation of its reference to paragraph 6.5.3. of Appendix 1 of Annex C5 to UN Regulation No. 154.
Q2Why it changed
- Proposed by
- Expert from the Kingdom of the Netherlands, on behalf of the Task Force on Automated Vehicles Regulatory Screening (TF-AVRS)
- Working party
- GRSG, 131st session (April 2026)
Reasons
Supplement 2 takes into account vehicles of categories X and Y. It also covers vehicles that have an Automated Driving System Feature of Type 2 (ADSF-2) and a manual mode above 6 km/h.
Sources (2)
“Supplement 2 to the 02 series of amendments is introduced to take into account vehicles of categories X and Y”
“as well as vehicles with a manual mode operating at speeds above 6 km/h which are equipped with an Automated Driving System Feature of Type 2 (ADSF-2)”
The Regulation was first written for vehicles with a driver and manual driving controls. The amendment intends to keep the spirit of the Regulation and to extend it to vehicles without a driver and without manual driving controls.
Sources (2)
“The UN 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 in the vehicle.”
The change to paragraph 5.1. is to show that the speedometer requirements do not apply to vehicles of categories X and Y. If such a vehicle shows its speed to the occupants, the manufacturer is responsible for what it shows and how. This is not subject to type approval.
Sources (3)
“Paragraph 5.1. is amended, to indicate that”
“the requirements related to the speedometer, do not apply to vehicles of categories X and Y”
“This means, that even if the vehicle’s speed is displayed to the occupants, the responsibility for what is shown and how, is the responsibility of the manufacturer and not subject to Type Approval.”
The change to paragraph 5.1. is to show that the speedometer requirements do not apply to a vehicle while an ADSF-2 is active. While an ADSF-2 is active, the manufacturer is responsible for what the speed display shows and how, and this is not subject to type approval.
Sources (3)
“Paragraph 5.1. is amended, to indicate that”
“the requirements related to the speedometer, do not apply to a vehicle, while an ADSF-2 is active”
“the responsibility for what is shown and how, while an ADSF-2 is active, is the responsibility of the manufacturer and not subject to Type Approval”
The change to paragraph 5.5. is to allow authorised persons to read the odometer. Examples are a person who uses, checks or maintains the vehicle.
Source
“Paragraph 5.5. is amended, to allow authorised persons, e.g. a person using, checking, maintaining the vehicle, to read the odometer.”
Document trail
- 2025-07ProposalECE/TRANS/WP.29/GRSG/2025/18Proposal by the expert from the Kingdom of the Netherlands on behalf of TF-AVRS
- —RevisedGRSG-130-66-Rev.2Revised TF-AVRS proposal for the 130th GRSG session
- —RevisedGRSG-131-22Changed proposal from TF-AVRS that replaced ECE/TRANS/WP.29/GRSG/2025/18
- —Working party adoptsECE/TRANS/WP.29/GRSG/110GRSG session report, para. 37
- 2026-04Sent to WP.29ECE/TRANS/WP.29/2026/105Text that GRSG 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
- Make sure each vehicle of category X or Y has an on-board odometer that complies with this Regulation (para. 5.1.).
- On vehicles of category X or Y, a speedometer is optional: decide whether to fit one (para. 5.1.).
- For vehicles with an ADS, find out if the ADS meets the provisions on indicators of UN Regulation No [XXX]. If it does, decide whether the speedometer indicates the speed while an ADS feature is active.
- Make sure the odometer display is visible or accessible to a driver, if applicable, or any authorised person (para. 5.5.).
- Paragraph 5.11. covers an electrically detectable failure that prevents the odometer requirements of this Regulation from being met. For vehicles of categories X and Y, and vehicles where an ADSF-2 is active, send this failure to the ADS. Use a logic signal for this (para. 5.11.).
Component supplier
- Make the odometer identify its unit when the ADS can select it independently of the speedometer (para. 5.5.2.).
Technical service / Approval authority
- Do not require a speedometer on vehicles of category X or Y to meet this Regulation (para. 5.1.).
- Check that vehicles of categories X and Y have an odometer that complies with this Regulation (para. 5.1.).
- For vehicles of category X and Y, do not add the 75 kg driver to the unladen vehicle (para. 2.7.).
- For a vehicle with an ADS, check whether the ADS meets the provisions on indicators of UN Regulation No [XXX]. If it does, accept a speedometer that does not indicate the speed while an ADS feature is active.
See every change side by side
RegVault customers compare every version of UN regulations, read the consolidated text and download the PDF.
ⓘ This report gives advice only. It is not legal or type-approval advice.