Anyone knowledgeable about laws behind safety/assist systems?

NLMGSAN

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We all know there is quite a lot to improve with the safety/assist systems. So I was looking into the articles of the latest regulations about them and found some interesting parts that could benefit us all. In particular in case of issues with LKA.

However, I'm not a lawyer and I feel I need another pair of eyes to check if what I read and how I interpret it actually sticks.
As far as I understood, UK follows the EU laws and rregulations on safety/assist systems in cars.

So, the reason I’m asking it here and not in a forum in i.e. the Netherlands is
1. UK is a much bigger market for MG, so impact for MG can be bigger. And, if it fits UK users, it probably will help us in Europe as well (v.v.)
2. Forum characteristics: you have a bigger and more active community which makes it more likely someone can join in.

The focus for now is on the articles describing when and how LKA systems should operate, and what is actually mandatory. This applies for two types of systems. The so called Alert system and systems that actually Corrective systems.

Anyone interested?
 
I think it is more about regulations than laws.

The UK is still part of EuroNCAP, which is essentially a voluntary group made up of industry bodies from a variety of countries.

Nobody has to pay attention to their work, indeed Renault decided to ignore it notably for some specifc versions of their low-end products to keep costs down.

EuroNCAP have a ton of publications (detailed testing specs) and some future 2030 vision documents where it is clear they are heading for more and more intrusive driver systems including mandatory speed limit controls and disabling the ability for drivers to turn the assistance systems off (they already make it hard).

Any manufacturer could decide to go their own route and not follow these rules and if they go too far, perhaps that is what will happen.

Oh, one of the things NCAP are keen on is mandatory alcohol and drug testing - you know that lovely idea of requiring you to do a breath test every time you sit in the car. Just the kind of appealing feature that bureaucrats think makes perfect sense - after all, if you have nothing to hide why would you be against it??! ?
 
Indeed. EuroNCAP are relying on the fact that they are known, and that them awarding 5 star ratings to cars is a marketing "advantage" to the car makers, hence why they strive to comply with EuroNCAP regulations. If the consumer base became less bothered about 5 star ratings (i.e. based on the 2030 vision ) then car makers would follow whatever made their products most attractive to the general consumer market. At that point EuroNCAP would likely have to follow the market drivers in order to remain relevant.
 
Although in the EU I believe this stuff is driven by actual regulations, but I don't believe that is the case in the UK post-brexit (at least for new ones), so where you live makes a difference.

But IANAL, so I could be wrong.
 
Well, in fact it is a EU regulation 2021/646 here. Regulations take effect immediately once signed, or at a specific date mentioned, and connects to national laws.

I just did a check how this regulation landed in the UK. It has not. On July 11th this year an article was posted on the fleetnews.co.uk site that several parties had sent a letter to the transport secretary urging her to adopt GSR2. This GSR2 includes the aspects of the eu regulation I mentione above (effective as per 2022) and several of the latest gimmicks such as an intelligent speed assist and...yes, ELKS.
ELKS initially was described as a system that contains warnings when crossing lane markers(1) and a corrective function to keep you in that lane(2). The latest description of ELKS specifically mentions prevention of frontal collisions when leaving the lane (3). Hence, it needs cameras in the outside mirrors.
If you have a Luxury you will have the three types already: Alert mode, Lane Departure Assist and Emergency Lane Keeping. The last one is already available on many cars, but is was't mandatory before July 2024.

One of the interesting things about the original regulation (prior to 2024) was that the systems were limited to their purpose and circumstances. Whereas the Warning system was allowed to trigger signals when crossing solid and dashed lines, a steering intervention was only allowed when crossing solid lines (eu regulation 2021/646, page 2 under 6.)! Reason: to prevent unneccesary interventions! Many brands simply ignored this. And this, amongst others, is exactly where the MG4 system fails to work properly......

Question is, if GSR2 is going to be implemented, will the UK stick to ELKS only operative when crossing solid lines? In that case, MG has some work to do.
I will check the implementation in the EU for the same reason.
 
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Well, in fact it is a EU regulation 2021/646 here. R3jegulations take effect immediately once signed, or at a specific date mentioned, and connects to national laws.
Yes.
I just did a check how this regulation landed in the UK. It has not. On July 11th this year an article was posted on the fleetnews.co.uk site that several parties had sent a letter to the transport secretary urging her to adopt GSR2. This GSR2 includes the aspects of the eu regulation I mentione above (effective as per 2022) and several of the latest gimmicks such as an intelligent speed assist and...yes, ELKS.
ELKS initially was described as a system that contains warnings when crossing lane markers(1) and a corrective function to keep you in that lane(2). The latest description of ELKS specifically mentions prevention of frontal collisions when leaving the lane (3). Hence, it needs cameras in the outside mirrors.
If you have a Luxury you will have the three types already: Alert mode, Lane Departure Assist and Emergency Lane Keeping. The last one is already available on many cars, but is was't mandatory before July 2024.
I don't know if it will be adopted here formally. However, because manufacturers don't like to make exceptions it is highly likely they will just implement whatever they need for the EU here anyway. This has turned out to be one of the effects post-Brexit, that we don't bother adopting new EU regulations but get them by default anyway.

One of the interesting things about the original regulation (prior to 2024) was that the systems were limited to their purpose and circumstances. Whereas the Warning system was allowed to trigger signals when crossing solid and dashed lines, a steering intervention was only allowed when crossing solid lines (eu regulation 2021/646, page 2 under 6.)! Reason: to prevent unneccesary interventions! Many brands simply ignored this. And this, amongst others, is exactly where the MG4 system fails to work properly......
Yes, although I don't think it is only MG. Most of the systems are made by the same suppliers so it is really about how they are integrated into the car, but other makes have also had difficulties with making ELK work well.
Question is, if GSR2 is going to be implemented, will the UK stick to ELKS only operative when crossing solid lines? In that case, MG has some work to do.
I will check the implementation in the EU for the same reason.
As I said, I think MG will give us the EU solution either way.
 
Yes.

I don't know if it will be adopted here formally. However, because manufacturers don't like to make exceptions it is highly likely they will just implement whatever they need for the EU here anyway. This has turned out to be one of the effects post-Brexit, that we don't bother adopting new EU regulations but get them by default anyway.


Yes, although I don't think it is only MG. Most of the systems are made by the same suppliers so it is really about how they are integrated into the car, but other makes have also had difficulties with making ELK work well.

As I said, I think MG will give us the EU solution either way.
Yes, you will likely have to do with EU specced cars. However:
  • so far the two most sophisticated lka systems are not according to EU specs
  • UK citizens may not have a legal base to challenge conformity to a law/regulation, since UK has none.... yet.
 
Yes, you will likely have to do with EU specced cars. However:
  • so far the two most sophisticated lka systems are not according to EU specs
  • UK citizens may not have a legal base to challenge conformity to a law/regulation, since UK has none.... yet.
We will probably see some exceptions as well - we have already with Renault/Dacia - where a few makers experiment with not following these regulations because they can make their cars cheaper without these systems. It will be interesting to see.
 
We will probably see some exceptions as well - we have already with Renault/Dacia - where a few makers experiment with not following these regulations because they can make their cars cheaper without these systems. It will be interesting to see.
There is a misunderstanding here. The 2021 regulation is designed as a specification of a type approval regarding ELKS. Cars homologated before july 2024 do not have to have ELKS. They do have have a warning system though (like the old dacia spring had). After July 2024 ELKS is mandatory. Also for Dacia. It is on their website.
 
There is a misunderstanding here. The 2021 regulation is designed as a specification of a type approval regarding ELKS. Cars homologated before july 2024 do not have to have ELKS. They do have have a warning system though (like the old dacia spring had). After July 2024 ELKS is mandatory. Also for Dacia. It is on their website.
In the UK, I meant, where it is not mandatory.
 
Out of curiosity is the MG4 NCAP 5? On the diagnostic software it said NCAP 4

As someone said about alcohol test each time you drive, I did notice that the latest documents on the RMI page were alcohol interlocks
Screenshot_20240821-060023.png


Things could be getting interesting
 
Out of curiosity is the MG4 NCAP 5? On the diagnostic software it said NCAP 4

As someone said about alcohol test each time you drive, I did notice that the latest documents on the RMI page were alcohol interlocks
View attachment 29327

Things could be getting interesting
They are no doubt preparing for it, since it seems likely this will be adopted. The backlash from drivers, however, will be huge if they ever attempt to make this mandatory.

More and more systems, more and more software complexity, more and more irritating bugs and distractions for the driver.
 
I totally begrudge having safety systems forced upon me and I have never ever bought a car based on how safe it is or what safety rating it has.
 
The MG4 is NCAP 5 stars, as it was type approved in 2022 per the (then) current regulations.

VDS for mine definitely says 4 star, wonder if they dropped a star in 2023
Screenshot_20240821-213055.png
 
Well, in fact it is a EU regulation 2021/646 here. Regulations take effect immediately once signed, or at a specific date mentioned, and connects to national laws.

I just did a check how this regulation landed in the UK. It has not. On July 11th this year an article was posted on the fleetnews.co.uk site that several parties had sent a letter to the transport secretary urging her to adopt GSR2. This GSR2 includes the aspects of the eu regulation I mentione above (effective as per 2022) and several of the latest gimmicks such as an intelligent speed assist and...yes, ELKS.
ELKS initially was described as a system that contains warnings when crossing lane markers(1) and a corrective function to keep you in that lane(2). The latest description of ELKS specifically mentions prevention of frontal collisions when leaving the lane (3). Hence, it needs cameras in the outside mirrors.
If you have a Luxury you will have the three types already: Alert mode, Lane Departure Assist and Emergency Lane Keeping. The last one is already available on many cars, but is was't mandatory before July 2024.

One of the interesting things about the original regulation (prior to 2024) was that the systems were limited to their purpose and circumstances. Whereas the Warning system was allowed to trigger signals when crossing solid and dashed lines, a steering intervention was only allowed when crossing solid lines (eu regulation 2021/646, page 2 under 6.)! Reason: to prevent unneccesary interventions! Many brands simply ignored this. And this, amongst others, is exactly where the MG4 system fails to work properly......

Question is, if GSR2 is going to be implemented, will the UK stick to ELKS only operative when crossing solid lines? In that case, MG has some work to do.
I will check the implementation in the EU for the same reason.
GSR2 is nothing else but an update of Regulation (EU) 2019/2144. This is generic regulation about all mandatory systems on cars, such as ELK systems. Regulation (EU) 2021/646, which specifically describes the ELK systems, has not been updated. This means it is still the standard for the implementation of ELK systems.
This is positive thing because the following still applies:
1. An emergency lane-keeping system (ELKS) shall comprise a lane departure warning system (LDWS) (Alert mode in MG4) and a corrective directional control function (CDCF) (Lane Departure Assist or Emergency Lane Keeping mode).
2. The emergency lane-keeping system is a driver assisting system that should provide warning to the driver and correct the trajectory only when the driver is unintentionally leaving the lane.
3. In order to avoid unnecessary interventions by the emergency lane-keeping system, which may prompt the driver to switch the system off and thus lead to loss of potential safety benefit, the emergency lane-keeping system should be required only to warn the driver and not to correct the vehicle trajectory when crossing dashed-lane markings.
4. When activated and operated within the prescribed speed range, the LDWS shall be able to warn the driver at the latest if the vehicle crosses over a visible lane marking for the lane in which it is running by more than a DTLM of – 0,3 m:
(c) for solid line and dashed lane markings in line with one of those described in Annex 3 (Visible lane marking identification) to Regulation No 130 of the United Nations Economic Commission for Europe (UNECE) – Uniform provisions concerning the approval of motor vehicles with regard to the Lane Departure Warning System (3) and on other markings expected on EU roads; (however, for testing purposes they only refer to No 130!)

5. In the absence of conditions leading to deactivation or suppression of the system, the CDCF shall be able to prevent lane departure by crossing of visible lane markings in the scenarios shown in the following table by more than a DTLM of – 0,3 m:
(c) for solid lane markings in line with one of those described in Annex 3 (Visible lane marking identification) to UN Regulation No 130; (confirming the above statement of operational limitations ELK systems).

Moreover, about deactivation:
6. The manual deactivation of the full ELKS shall not be possible with less than two deliberate actions, e.g. press and hold on a button, or select and confirm on menu option. In other words, press and holding a button is sufficient (confirmed in docs elsewhere).

Summary
A. Mg4 Alert mode should function on any decent EU road, and on those described in UN regulation 130. This covers many if not all UK roads as well.
It doesn't. As an example, double solids as lane separators are not recognized on my Trophy. End there many of such roads here, all above 60 kmh.

B.LDA or ELK mode is not allowed to intervene with the steering when crossing dashed lane markings. This means it should act as in Alert mode.
It does not. In the two MG4 modes it does apply steering adjustments when crossing dashed lines.

C. Disabling or enabling promptly lane assist, as adviced by MG themselves, can be arranged by press and hold the infotainment button. Single press does normal switching.

Particularly A. and B. mean that the ELK systems on an MG4 are not compliant with EU regulations. And, if the UK follows these regulations, neither are they compliant in the UK.

This will be may the major argument against MG NL (Benelux in fact). I will start the procedure in September, after I get back from a short holiday. Unless someone else explains to me that I'm wrong....
 
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If you have an MG4 with trailer hitch, engaging "Towing Mode" turns off almost all the nanny systems. They will remain off as long as "Towing Mode" is active and do not reactivate after a stop.
At least in Australian spec.
 
That is a workaround I do not prefer. I do not have a choice but paying for these systems if I need a new car. So they better work.
 

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