Home > Legal Factors > Legal Framework / Differences Per Country

Legal Framework / Differences Per Country

Legal framework and differences per country for automated driving.

When looking at the legal framework for automated driving, it is important to keep an eye on which types of regulations are important for which market.

EEC (Regulations of the EU Commission)

Regulations of the EU Commission are mandatory for Type Approvals in the EU. They have to be converted into national law. In Germany into the StVZO (Straßenverkehrzulassungsordnung).

ECE (Regulations of the UN in Geneva)

ECE (Economic Community Europe) Regulations are developed by the ECE in Geneva. ECE Regulations optionally may be applied for European Type Approvals. They are valid for those who signed the 1958 agreement for reciprocal recognition of approvals. ECE has Europe in its name, but it is open to all countries. Since Russia, Japan, Korea, South-Africa and Australia have also signed, the regulations practically are valid worldwide. The opportunity with ECE Regulations is that for committees responsible for amendments only English, French or Russian language is allowed. Adapting regulations to technical progress therefore is possible in a time much shorter than in the case of EEC Regulations, where each member has to talk in his language, currently 11, in future 20 will be allowed.

FMVSS (Regulations of the US)

FMVSS (Federal Motor Vehicle Safety Standard) regulations are developed by NHTSA (National Highway Traffic Safety Administration). Because of the self certification system common in the US they are constructed differently from the European regulations.
FMVSS regulations have a section describing the necessary tests in detail. This is necessary because the number of persons who perform the tests is unlimited. With European regulations in contrast the number of inspectors is limited to the few specialists at the technical services.

ADR (Regulations of Australia)

ADR (Australien Design Rule) Regulations are practically identical in form and content with the American FMVSS regulations. But Australia has an approval system which is a mixture of Type approval system and self certification system. For a few components a short notice to the Australian agency is required. Testing may be done by the manufacturer himself, however, a registration is necessary.

TRIAS (Regulations of Japan)

TRIAS (Traffic safety and nuisance Research Institute's Automobile type approval Standard) regulations – Japan adopted ECE R 13H for national law.

Got Questions?

Contact our experts:

Contact Form