Future Car Black Boxes To Record Location,

Date and Time, ROADPOL Insists


1Location, date and time data are crucial for collision analysis. PHOTO: POLICJA.PL

30 MARCH - ROADPOL holds firm on its demand that future Event Data Recorders (EDR) should record location, time and date of events.

The stance was reiterated in a letter by ROADPOL’s President Volker Orben to European Commission’s Directorates-General for Internal Market, Industry, Entrepreneurship and SMEs (DG GROW). The move was provoked by the forthcoming delegated act destined to implement the EU’s new General Safety Regulation (GSR) for motor vehicles.


As stipulated by the GSR EDRs have the purpose of recording and storing critical crash-related parameters shortly before, during and immediately after a road collision. Also called “automotive black boxes” ((by analogy with the common nickname for flight recorders), they are set to be mandatory for EU type-approval of vehicles of M1 category (cars) from 6 July 2022 onwards. No vehicle without EDR is to be registered within the EU from 7 July 2024 onwards.


Now ROADPOL is greatly concerned about the proposed requirement that the EDR should not be able to capture and store data elements on the location, date and time of events, as evident in the “EDR: Draft elements for EU Regulation” document prepared by contractor TRL, the letter states.

Volker Orben 300President Volker Orben


Mr. Orben informs that determining the cause of a collision is becoming increasingly difficult as less traces are available due to the increase of assistance systems in vehicles. As a result, the data recorded by the EDR are increasingly relied upon, as the data allows to objectify the causal relationship in road collisions. EDRs are therefore vital for gathering collision data for accident analysis especially considering the increasingly important future role of  assisted and automated driving systems in road traffic. Hence, prohibiting EDRs to capture and store data on location, date and time of events would mean that they do not record data that is indispensable for collision analysis – the very purpose for which they are mandated by the GSR, Mr. Orben claims. According to him without information of time and location the data cannot be clearly analysed in the correct environmental context (e.g. whether a red light was ignored).


Mr. Orben acknowledges the authors’ desire to comply with rules on data protection, but finds that this was done too stringently, especially considering that the GSR itself mandates that the data can only be made available to national authorities on the basis of Union and national law and in compliance with the General Data Protection Regulation. He expresses fear that this stringent interpretation of data protection rules would be detrimental for the analysis of collisions involving vehicles with automated driving systems, as the time stamp is crucial to link the EDR data to data from the Data Storage System for Automated Driving (DSSAD). According to ROADPOL’s President data protection could be guaranteed even with EDRs collecting information on location, date and time. This can be achieved by more rigorous provisions for how, when and by whom these specific data can be retrieved.