Vehicle Standard (Australian Design Rule 89/00 – Brake Assist Systems (BAS)) 2017

The instrument is structured around a small set of core concepts taken from UN Regulation No. 139 and re-presented as the technical backbone of ADR 89/00. Those concepts and their legal treatment in the Standard are:

• Brake Assist System (BAS): defined in Appendix A, para 2.6 as a function of the braking system that deduces an emergency braking event from a characteristic of the driver’s brake demand and, under such conditions, assists the driver to deliver the maximum achievable braking rate or causes full cycling of the Anti-lock Braking System (ABS). The definition is functional, not prescriptive about the control algorithm (Appendix A, para 2.6).

• Categories of BAS: Appendix A distinguishes Category A BAS (detection based primarily on brake pedal force, para 2.6.1) and Category B BAS (detection based primarily on brake pedal speed, para 2.6.2). The testing and performance criteria differ between categories (Appendix A, Sections 6-9).

• Relation to ABS: Appendix A para 5.1 requires that vehicles equipped with BAS be equipped with ABS in accordance with Regulation 13‑H. However, the Australian standard modifies how that interacts for some vehicles by providing an alternative in clause 6.2 (MB, MC and NA vehicles may use an Antilock System meeting ADR 35/... instead of the ABS requirement in Appendix A para 5.1).

• Technical performance and test regime: the Regulation sets out numerical test and measurement regimes for establishing FABS (the pedal force at which ABS fully cycles), aABS (the deceleration during ABS cycling), calibration and acceptance corridors, instrumentation accuracy, sampling rates, filtering, test speeds (100 ± 2 km/h) and test conditions (unladen vehicle, brake temperature 65-100°C). See Appendix A paragraphs 7-9 and Annexes 3-4 for the full technical specification.

• Manufacturer’s declarations: the technical regime requires manufacturers to supply certain parameters to the Technical Service at the time of type-approval application (e.g. FT, aT for Category A, and pedal speed activation profile for Category B) in the UN regime (Appendix A, paras 8.2.3 and 9.2). The Standard re-maps “Technical Service” to “Manufacturer” (clause 5.3), but clause 6.1 exempts the UNECE application/approval procedures (sections 3-4 of Appendix A), so the usual UNECE application channel is not imposed in full.

• Electromagnetic compatibility and EV considerations: Appendix A para 5.4 requires that BAS effectiveness not be adversely affected by magnetic or electrical fields; it references Regulation No. 10 and different series of amendments depending on whether the vehicle has a coupling system for charging the Rechargeable Electric Energy Storage System (traction batteries).

• Data processing and measurement rigour: Annex 4 requires high-quality data acquisition (≥500 Hz sampling rate at least for digital acquisition per para 7.2.3, specific filter and sampling requirements, 12-bit resolution, anti-aliasing filters of order 4+ and specific limits on allowable errors). These are prescriptive technical obligations for test laboratories and manufacturers.

• Equivalence to UN R139: clause 7.1 deems the UN Regulation No. 139 (00 series) equivalent to the technical requirements of this Standard, meaning the technical text in Appendix A is the operative specification for BAS performance in Australia.

Collectively these concepts move the Standard away from a domestic bespoke technical specification and towards a UNECE-aligned technical regime, while removing or adapting the UNECE administrative processes to sit under Australia’s Motor Vehicle Standards Act 1989 regime (see clauses 5.2 and 6.1).

The Standard directly affects a set of actors and indirectly affects several others through compliance chains and market signalling. The document makes the effects explicit in its applicability table and in its re-mapping of approval roles.

Primary affected parties

• Vehicle manufacturers: they are the central obliged parties. Clause 5.1 requires vehicles to be equipped with a BAS meeting Appendix A technical requirements. Clause 5.3 instructs that “Technical Service” is to be read as “Manufacturer”, which in the Australian context places responsibility for the technical test regime, data provision and ensuring the BAS meets the reproduced UN requirements on the manufacturer.

• Distributors and importers of new-model passenger cars and light goods vehicles: the Standard applies mandatorily to new model vehicles of ADR categories MA and NA from 1 July 2019 (clause 3.1.1 and applicability table at clause 3.3). Persons who import or bring into service new-model vehicles for these categories must ensure compliance with ADR 89/00.

• Administrator of Vehicle Standards: clause 5.2 reads “Approval Authority” as the Administrator of Vehicle Standards (as defined in the Motor Vehicle Standards Act 1989). The Administrator is therefore the named decision-maker for any approval or administrative function that would have been exercised by a UNECE Approval Authority under the replicated text, to the extent those functions remain relevant after clause 6.1.

Secondary and indirect affected parties

• Component and BAS system suppliers: suppliers of brake control modules, sensors and software will face demand for components that enable BAS functionality to meet the specified performance baskets, and will need to supply documentation, identification of components, and testable data to the manufacturer (Appendix A, para 3.2.2-3.2.4 describe the UNECE application requirements that the technical content presumes, even though some application/approval steps are disapplied by clause 6.1).

• Test laboratories and technical evaluators: while the UNECE Annexes concerning approval communication and marking are disapplied (clause 6.1), the technical test procedures, instrumentation and data-processing requirements (Appendix A, paras 7-9 and Annexes 3-4) remain in force. Parties that undertake the technical testing must implement high-precision measurement systems, filters and data acquisition systems meeting the specified tolerances.

• Secondary markets and repairers: because BAS is an integrated control function of the braking system, vehicle owners, repair shops and crash-repairers will interact with BAS components during maintenance or modification. Appendix A includes provisions on modification and extension of approvals (section 10), but clause 6.1 disapplies those approval procedures for the purposes of this Standard; nevertheless the technical requirement means repairs that alter braking system performance need attention to avoid defeating BAS function.

• Regulators and enforcement agencies under the Motor Vehicle Standards Act 1989: the copy-in of technical obligations and the re-mapping of approval functions to the Administrator mean that regulators responsible for enforcing the MVSA will be the domestic enforcement actors where non-compliance occurs. The Standard itself disapplies Appendix A’s UNECE conformity and penalties sections (clause 6.1), so domestic enforcement will rely on MVSA mechanisms and any associated ADR enforcement instruments.

Particular categories and transitional arrangements

• New-model passenger cars (M1/MA) and new-model light goods vehicles (N1/NA) are in scope from 1 July 2019 (clause 3.1.1 and 3.3). Other vehicles of the specified categories have no mandatory date and may continue to meet ADR 31/03 or ADR 35/05 (clause 3.1.2). This staging concentrates the immediate compliance burden on new-model vehicle introductions.

• Vehicles with design speed ≤ 25 km/h and vehicles fitted for invalid drivers are excluded from the UN Regulation scope (Appendix A, para 1.2.1-1.2.2), and therefore are outside the technical obligations carried into this ADR.

In short, manufacturers and the Administrator bear the primary compliance and approval roles under the text. Suppliers, test houses and downstream repair and service markets are affected indirectly through required technical performance, instrumentation and data-recording obligations set out in Appendix A.

The Standard creates duties principally in two layers: (1) the obligation to equip specified vehicles with BAS meeting the technical requirements in Appendix A, and (2) detailed technical, testing and documentation duties that arise from Appendix A’s procedures and annexes as incorporated and modified.

Primary duties

• Duty to equip vehicles with compliant BAS: clause 5.1 is the primary obligation , “Vehicles must be equipped with a Brake Assist System meeting the requirements of Appendix A, except as varied by clause 6.” That routes manufacturers to the technical content in Appendix A (UN R139) for design, construction, and functional performance obligations.

• Obligation to meet functional and construction requirements: Appendix A paras 5.2-5.4 require that BAS be designed, constructed and fitted so that the vehicle in normal use, despite vibration, complies with the Regulation; resist corrosion and ageing; and not be adversely affected by magnetic or electrical fields (relevant for electric vehicles). Annex 3 further defines FABS and aABS determination procedures; Annex 4 prescribes data acquisition and processing accuracy.

• Test and measurement obligations: Appendix A paras 7.1-7.4 set the variables to be measured (pedal force, vehicle velocity, vehicle deceleration, brake temperature, brake pressure, pedal speed), the accuracy requirements (table at para 7.2.2), the sampling rate for data acquisition (at least 500 Hz per para 7.2.3) and test conditions (test speed 100 ± 2 km/h; brake temperature 65-100°C; reference time t0 when brake pedal force reaches 20 N). Meeting these numerical thresholds is a legalised technical duty for compliance.

• Manufacturer’s declaration of parameters: Appendix A requires that threshold parameters (e.g. FT and aT for category A, and the pedal speed activation profile for category B) be supplied to the Technical Service at the time of type-approval application (Appendix A, paras 8.2.3 and 9.2), with the Standard instructing that “Technical Service” may be read as “Manufacturer” (clause 5.3).

• Requirements for periodic inspection visibility: Appendix A para 5.6 requires it be possible at periodic technical inspection to confirm correct operational status by visual observation of warning signals following power-on; and the Type Approval process must outline means to protect warning signals against simple unauthorised modification or provide a secondary means of checking correct operation (para 5.6.2).

Rights and defined readings

• Reading of Approval Authority and Technical Service: clause 5.2 and clause 5.3 respectively stipulate that “Approval Authority” be read as the Administrator of Vehicle Standards and “Technical Service” as Manufacturer. This is not a conferment of new statutory powers but a directional re-mapping so the references in Appendix A align with the domestic statutory actors under the Motor Vehicle Standards Act 1989.

• Equivalence to UN R139: clause 7.1 gives manufacturers a recognised route to demonstrate compliance by meeting the UN Regulation No. 139 (00 series), so international test data and design conformity to that Regulation are legally acceptable evidence of compliance in Australia.

Variations and exemptions (duties not imposed)

• Disapplication of UNECE approval and conformity sections: clause 6.1 disapplies Appendix A sections that would otherwise require an application for approval, a UNECE type-approval number, conformity of production procedures, penalties for non-conformity, production discontinuation communications, and the names and addresses of Technical Services/Type Approval Authorities, and excludes Annexes 1 and 2 (communication forms and approval marks). The result is that the UNECE administrative approval and marking machinery is not required by this Standard; instead, manufacturers must comply with the technical requirements but the administrative approval pathway is handled through the Administrator under the Motor Vehicle Standards Act 1989 , the Standard re-maps the vocabulary but removes the UNECE-type approval obligations.

• Alternative for certain vehicle types to ABS requirement: clause 6.2 provides that MB, MC and NA vehicles can, as an alternative to the ABS requirement in Appendix A para 5.1, be equipped with an Antilock System complying with ADR 35/… (the exact ADR reference is left as an ellipsis in the text). This gives a specific, limited flexibility in how the ABS-related duty is discharged for those categories.

The Standard therefore imposes precise technical duties on manufacturers to design, test and document BAS to UNECE technical standards, while removing UNECE administrative procedural duties and re-mapping approval language to domestic institutional actors.

The text of the Standard addresses enforcement and penalties indirectly by disapplying many of the UNECE approval and conformity procedures and by specifying how certain references should be read under the domestic statute. It does not itself introduce a new penalties schedule; instead, it incorporates technical obligations and points to domestic enforcement via the Motor Vehicle Standards Act 1989 through the re-mapping of Approval Authority to Administrator.

What the instrument says about enforcement and penalties

• Disapplication of UNECE conformity and penalty machinery: clause 6.1 lists in full the parts of Appendix A that are not required for the purposes of this Standard, including Section 11 (Conformity of production), Section 12 (Penalties for non-conformity of production) and Sections 13-14 (production discontinued, names and addresses). By disapplying these sections, the Standard removes the UNECE regime’s internal mechanisms for withdrawal of type approvals and the communication procedure for sanctions under the UNECE process as applied in Appendix A.

• Re-mapping to domestic decision-maker: clause 5.2 directs that “Approval Authority” be read as the Administrator of Vehicle Standards under the Motor Vehicle Standards Act 1989. That re-mapping indicates that enforcement and approval decisions which do survive in the Standard will be administered by the Administrator, under whatever enforcement powers and penalty regimes exist in the MVSA and subordinate instruments. The Standard itself does not restate those MVSA powers.

• No separate penalty schedule in this Standard: the instrument contains no separate civil or criminal penalties, fine schedules, or explicit enforcement processes beyond the technical obligations and the textual re-mappings. The only penalties language that exists in Appendix A (section 12) is explicitly disapplied by clause 6.1.

Practical enforcement implications implied by the text

• Technical compliance is enforceable only through domestic mechanisms: because the Standard imposes technical obligations (Appendix A) but disapplies UNECE conformity/penalty procedures, enforcement will depend upon the Administrator and the enforcement powers and processes available under the Motor Vehicle Standards Act 1989 and any subordinate ADR enforcement instruments. The Standard itself establishes what behaviour is required; it does not recite the domestic enforcement steps; clause 5.2 makes the Administrator the domestic counterpart to the UNECE Approval Authority.

• Evidence and certification pathways: clause 7.1’s deeming of UN R139 equivalence means that manufacturers who can demonstrate compliance with UN R139 technical requirements (testing, FABS/aABS determination, Annex 3/4 data processing) have the technical evidence to present to the Administrator. The Standard, however, does not reinstate the UNECE marking or communication requirements (Annexes 1-2 disapplied), so the UNECE type-approval number and mark are not required under this Standard.

• Withdrawal and non-conformity: Appendix A section 12 (withdrawal of approval for non-conformity) is disapplied. The UNECE procedure for withdrawal and cross-notification among Contracting Parties is not operative under the ADR, per clause 6.1. Any withdrawal or remedial action will need to be taken under Australia’s domestic statutory mechanisms.

In short, the Standard sets out technical duties and reassigns administrative roles to the Administrator, but strips out the UNECE's own application/withdrawal and cross-notification machinery. It therefore creates reliance on existing domestic enforcement regimes (the Motor Vehicle Standards Act 1989 and associated ADR enforcement instruments) to police compliance, while not providing a parallel UNECE-style penalty and approval revocation mechanism within the text.

The Standard is explicitly designed to sit within Australia’s Motor Vehicle Standards Act 1989 framework and to align technical requirements with international UNECE rules while disapplying some of the UNECE administrative procedures. The text contains explicit cross-references that define the interaction with other national and international regulatory instruments.

Interaction with the Motor Vehicle Standards Act 1989

• Administrative alignment: clause 5.2 instructs that “Approval Authority” in Appendix A be read as “Administrator of Vehicle Standards” under the Motor Vehicle Standards Act 1989. That indicates the Standard’s administrative and regulatory interface is the MVSA framework; the Administrator is the domestic actor for approval-related matters referenced in the incorporated technical text.

• Decision and enforcement locus: because the Standard disapplies UNECE sections dealing with approvals, conformity, penalties and communications (clause 6.1), the domestic MVSA framework is the operative enforcement and approval pathway. The Standard does not restate MVSA powers; it presumes the MVSA will supply the legal machinery for market entry, non-compliance responses and enforcement.

Interaction with other Australian Design Rules (ADRs)

• Transitional or alternative compliance: clause 3.1.2 states that vehicles other than new-models may comply with this Standard or continue to comply with ADR 31/03 or ADR 35/05, as applicable. Clause 6.2 permits certain vehicle categories (MB, MC and NA) to use an Antilock System meeting ADR 35/... as an alternative to the ABS requirement contained in Appendix A paragraph 5.1. Those provisions create interoperability with older ADRs and provide manufacturers with alternative compliance routes for particular vehicle categories or vehicle generations.

• Relation to ABS Regulation: Appendix A para 5.1 requires ABS compliant with Regulation 13‑H in addition to BAS. The ADRs that implement Regulation 13‑H in Australia will therefore interact with ADR 89/00 in determining whether a vehicle meets both BAS and ABS obligations.

Interaction with international instruments (UNECE)

• Technical equivalence: clause 7.1 deems UN Regulation No. 139 (00 series) equivalent to the technical requirements of the Standard, so compliance tests and data that meet UN R139 will be treated as meeting the technical content of ADR 89/00.

• Administrative divergence: clause 6.1 disapplies UNECE approval and communication procedures (Appendix A sections 3-4, 10-14 and Annexes 1-2). That removes the UNECE type-approval number, communication forms and international approval mark from being required under this ADR, and instead moves administrative functions to the domestic Administrator. Therefore, vehicles meeting UN R139 through UNECE type-approval processes may present those technical data, but any domestic approval or market entry must follow Australia’s MVSA and ADR compliance processes.

Interaction with electromagnetic compatibility regimes and EV charging standards

• Regulation No. 10 cross-reference: Appendix A para 5.4 requires that the BAS effectiveness not be adversely affected by electromagnetic fields and directs that the technical requirements and transitional provisions of Regulation No. 10 be applied, choosing the 03 series of amendments for vehicles without a coupling system and the 04 series for vehicles with a coupling system for charging Rechargeable Electric Energy Storage Systems. This means that electrified vehicles and vehicles with on-board charging interfaces must also meet the relevant electromagnetic compatibility requirements as part of BAS compliance.

Other technical standards referenced

• Measurement standards: Annex 4 and Appendix A para 7.2.1 reference ISO Standard 15037-1:2006 for instrumentation accuracy, filtering techniques and data processing requirements. Compliance therefore requires conformance with that ISO standard as a technical prerequisite to the test methods prescribed.

Net effect

ADR 89/00 imports UNECE R139’s technical content but removes its type-approval and international marking machinery, replaces UNECE administrative actors with the domestic Administrator under the Motor Vehicle Standards Act 1989, and preserves interactions with other ADRs (notably ADR 31/03 and ADR 35/05), Regulation 13‑H (ABS), Regulation 10 (electromagnetic compatibility) and the referenced ISO standard. The Standard therefore functions as a technical harmonisation instrument within the domestic MVSA framework rather than a full transposition of UNECE approvals and communications processes.

The text provided is the Vehicle Standard (Australian Design Rule 89/00 , Brake Assist Systems (BAS)) 2017, determined by the Minister for Urban Infrastructure and dated 25 August 2017. The Standard reproduces UN Regulation No. 139 and includes an addendum incorporating the 00 series of amendments with date of entry into force 22 January 2017 (Appendix A header). The instrument itself sets its commencement as “the day after it is registered” (clause 1.2.1) and establishes a mandatory date for new model vehicles of 1 July 2019 (clause 3.1.1).

Documented amendment sources within the Standard

• UN R139 00 series: Appendix A notes that it incorporates “all valid text up to 00 series of amendments - Date of entry into force: 22 January 2017.” Clause 7.1 further deems UN R139 (00 series) equivalent to the technical requirements of this Standard.

• Domestic modifications to the UNECE text: clause 6.1 explicitly varies the application of Appendix A by disapplying specific sections (sections 3-4, 10-14 and Annexes 1-2) for the purposes of the Australian Standard. Clauses 5.2 and 5.3 reinterpret the UNECE vocabulary by saying “Approval Authority” must be read as the Administrator and “Technical Service” as Manufacturer. Clause 6.2 adds an alternative compliance route for specific categories in relation to the ABS requirement.

Instruments creating the Standard

• The front page records that the Standard is determined under section 7 of the Motor Vehicle Standards Act 1989. The document itself does not list prior amendments to the ADR because it is an ADR determination intended to take effect from registration and the specific operational change is the adoption of UN R139 (00 series) as ADR 89/00.

Temporal staging and commencement

• Commencement: the Standard “commences on the day after it is registered” (clause 1.2.1).

• Mandatory application date for new models: 1 July 2019 for all new model vehicles in the affected categories (clause 3.1.1 and applicability table at clause 3.3). The instrument therefore provides a lead time between registration and the 1 July 2019 effective date for new models.

Absent amendment trace in the text

• No amendment schedule for the ADR itself is embedded beyond the adoption of the UN R139 00 series. The text contains no schedule of later prospective amendments to the ADR nor any explicit sunset clauses. Any future technical updates to UN R139 after the 00 series would not automatically be adopted; clause 7.1 confines equivalence to the 00 series text as incorporated.

Practical import

• The Standard is presented as a 2017 ADR that aligns Australia’s technical BAS requirements with UN R139 as of the 00 series of amendments, modifies the UNECE approval and communication procedures by disapplying them, and stages mandatory application for new models from 1 July 2019. Any later changes to the ADR would be recorded in subsequent determinations under the Motor Vehicle Standards Act 1989; none are recorded in this text.

The instrument provided contains no references to case law, judicial interpretation, or litigation outcomes. There are no judicial decisions, appeals or disputes recorded within this text, and no cases are cited in the Standard or in Appendix A. The UNECE Regulation reproduced in Appendix A does not include litigation history; it is a technical regulatory text, not a record of disputes.

What the absence of litigation in the text means for practitioners

• No domestic jurisprudence in the instrument: the ADR determination itself is an administrative instrument; it sets obligations but does not report any court decisions. Practitioners will therefore need to look elsewhere (MVSA enforcement decisions, tribunal determinations, or court cases) for any judicial interpretation of the ADR or dispute resolution under the MVSA. The Standard does not provide that history.

• Potential sources of future disputes: while the document is silent on past litigation, the combination of importing an international technical standard, disapplying UNECE approval procedures and re-mapping approval roles to the Administrator may give rise to disputes about enforcement and the interaction between UNECE type-approval evidence and domestic approval or compliance obligations , for example, questions could arise as to what evidence suffices to demonstrate compliance to the Administrator when the UNECE communication/marking machinery is not required. Those potential lines of litigation are logical possibilities grounded in the structure of the instrument, but they are not reflected in any recorded litigation history in the text.

• Absence of reported litigation related to the UNECE text: Appendix A is a reproduction of UN R139 (a multilateral technical regulation). It does not include any judicially determined interpretation. UN Regulations are implemented by Contracting Parties via domestic law, and any legal disputes would appear in national courts or administrative decisions; none are included here.

In sum, there is no litigation history recorded in the instrument. Practitioners should therefore rely on the statutory text of ADR 89/00, the Motor Vehicle Standards Act 1989, and any subsequent administrative guidance or case law emanating from Australian enforcement bodies for authoritative interpretation and dispute outcomes.

The Standard contains several detailed technical and administrative features that may be easy to overlook and have practical consequences for compliance, testing, documentation and enforcement. The following are source-grounded “gotchas” that practitioners should note.

1. Disapplication of UNECE approval and conformity provisions (clause 6.1)

• The Standard explicitly states that certain sections and annexes of Appendix A are not required “for the purposes of this standard”: Section 3 (Application for approval), Section 4 (Approval), Section 10 (Modification and extension), Section 11 (Conformity of production), Section 12 (Penalties), Section 13 (Production definitively discontinued), Section 14 (Names and addresses of Technical Services), Annex 1 (Communication) and Annex 2 (Approval marks). That means the UNECE type-approval application process, approval number assignment, approval mark affixing and the UNECE conformity/penalty machinery are not operative under the ADR. Manufacturers relying on UNECE approvals must not assume that the international approval mark or the UNECE communication process discharges all domestic obligations.

2. Reinterpretation of Approval Authority and Technical Service (clauses 5.2-5.3)

• The Standard instructs that “Approval Authority” should be read as the Administrator of Vehicle Standards and “Technical Service” as “Manufacturer”. This re-labelling changes expected responsibilities. Where Appendix A contemplates a Technical Service that is independent of the manufacturer, the ADR directs that the manufacturer assumes that role, which affects impartiality of testing and the documentation flow in Australia.

3. ABS requirement and limited alternative (Appendix A para 5.1 and clause 6.2)

• Appendix A para 5.1 requires that vehicles equipped with BAS also be equipped with ABS in accordance with Regulation 13‑H. Clause 6.2, however, allows MB, MC and NA vehicles as an alternative to the Appendix A ABS requirement to be equipped with an Antilock System meeting ADR 35/…. The exact citation in clause 6.2 is unfinished (“ADR 35/…”); practitioners should not assume an identical ADR number and must verify which ADR 35 variant is intended for the particular vehicle category.

4. Heavy technical measurement and data processing obligations (Appendix A paras 7.2.3, Annex 4)

• Annex 4 prescribes stringent measurement and processing requirements: a sampling rate for data acquisition of at least 500 Hz is required (Appendix A para 7.2.3), analogue/digital filtering orders, anti-aliasing, 12-bit resolution with ±0.05% resolution and other precise tolerances (Annex 4). These are exacting laboratory-level obligations and impose equipment, calibration and data-processing costs. Non-compliance with these numeric accuracy requirements will undermine the technical demonstration of BAS performance.

5. Manufacturer-supplied thresholds and activation specifications (Appendix A paras 8.2.3, 9.2, Annex 1)

• For Category A, FT and aT thresholds must be supplied to the Technical Service at the time of application (Appendix A para 8.2.3); for Category B, the manufacturer must specify the brake pedal speed required to activate BAS (Appendix A para 9.2 and Annex 1, item 16.1.2). The ADR re-maps “Technical Service” to “Manufacturer” (clause 5.3) and disapplies application form requirements (clause 6.1), creating potential ambiguity about where and how these manufacture-supplied parameters are lodged with the Administrator. Practitioners should ensure those parameters are documented and available to the Administrator.

6. Reference time and pedal-force threshold details (Appendix A paras 7.4.3 and 8.2.4)

• The definition of reference time t0 is precise: the moment when brake pedal force reaches 20 N (para 7.4.3). Many test results and corridors are defined relative to t0 and to FT, FABS, and aABS. Small measurement differences in where t0 is recorded or how pedal force is measured can materially affect pass/fail outcomes.

7. Periodic inspection visibility (Appendix A para 5.6)

• Appendix A para 5.6 requires that correct operational status be verifiable at periodic technical inspection by visual observation of warning signals following power-on or by a secondary check. The Standard requires manufacturers to confidentially outline means to protect warning signals against simple unauthorised modification, or to provide a secondary means of checking. Manufacturers need to ensure that vehicles present an observable signal at power-on and retain means to demonstrate correct operation at inspection time.

8. EV electromagnetic compatibility cross-references (Appendix A para 5.4)

• For vehicles with coupling systems for charging REESS, Appendix A directs application of Regulation No. 10’s 04 series of amendments; without coupling systems, the 03 series applies. Manufacturers of electrified vehicles must ensure the BAS is tested for EMC per the specified series, otherwise the requirement that BAS effectiveness not be affected by electromagnetic fields (para 5.4) may be unmet.

9. “New model” definition and staging (clause 3.2 and 3.1.1)

• Clause 3.2 defines a “new model” as a vehicle model first produced with a ‘Date of manufacture’ on or after 1 July 2019. This creates a clear staging point but exposes manufacturers to an administrative decision about whether a particular VIN/production run is a “new model”. Small variations in production dates or “first produced” determinations could affect whether a vehicle must comply immediately.

10. Annexes relating to approval marks and communications are disapplied (clause 6.1)

• Annex 1 (communication) and Annex 2 (approval mark arrangements) are not required. Practitioners should not expect to see or use the UNECE approval mark formats as compliance evidence under this ADR; instead, they must rely on domestic documentation and any evidence acceptable to the Administrator.

Each of these is grounded in the text of the Standard and Appendix A. They highlight where technical detail, administrative remapping and the disapplication of UNECE administrative procedures intersect to create practical compliance challenges.

This section sets out a stepwise, source-grounded compliance roadmap for manufacturers, importers and compliance advisers based on the text of the Standard and the reproduced UN R139 content. Follow the textual obligations rather than relying on UNECE administrative marks because the ADR disapplies the UNECE approval/communication machinery.

1. Confirm applicability and staging

• Determine vehicle category against the applicability table at clause 3.3. The Standard applies to ADR categories MA (passenger car), MB, MC and NA (light goods) as listed. For new model vehicles (vehicles “first produced” with a Date of manufacture on or after 1 July 2019) the Standard is mandatory (clause 3.1.1). Other vehicles may remain under ADR 31/03 or ADR 35/05 (clause 3.1.2).

2. Decide which BAS category your system is intended to meet

• Classify the BAS as Category A or B per Appendix A paras 2.6.1-2.6.2. Category A systems detect an emergency braking condition primarily by pedal force; Category B primarily by pedal speed. Performance and test requirements differ for each category (Appendix A Sections 6-9).

3. Ensure BAS design meets the general construction and EMC requirements

• Design the BAS to be “designed, constructed and fitted” to withstand vibration, corrosion and ageing and to ensure BAS effectiveness is not adversely affected by magnetic or electrical fields (Appendix A paras 5.2-5.4). For vehicles with charging coupling systems for REESS, apply the 04 series EMC amendments; otherwise apply the 03 series (para 5.4).

4. Plan and equip for the required test regime

• Prepare test equipment and procedures consistent with Appendix A paras 7.1-7.4 and Annex 4:
  • Measure variables: brake pedal force (Fp), vehicle velocity (vx), vehicle deceleration (ax), brake temperature (Td), brake pressure (P) where applicable and pedal speed (vp) (Appendix A para 7.1).
  • Adopt measurement accuracy per para 7.2.2 (e.g. pedal force recording error ±10 N over 0-2000 N).
  • Ensure data acquisition sampling at least 500 Hz (para 7.2.3) and that filtering, anti-aliasing and resolution meet Annex 4 specifications (12-bit resolution or better, anti-aliasing filters order 4+, bandwidth and sampling relationships as prescribed).
  • Ensure the test vehicle is unladen, tests are on a dry surface with good adhesion, brake temperatures are 65-100°C prior to any brake application, and the test speed is 100 ± 2 km/h (paras 7.3.1-7.4.2). The reference time t0 is when pedal force reaches 20 N (para 7.4.3).

5. Determine FABS and aABS using Annex 3

• Conduct the Annex 3 procedure to establish the brake pedal force FABS required to achieve full ABS cycling and the deceleration aABS during ABS cycling:
  • Apply the pedal slowly to achieve full deceleration within 2.0 ± 0.5 s and maintain ABS cycling; perform five valid runs meeting the deceleration corridor; compute the maF mean curve and derive aABS and FABS per Annex 3 paras 1.2-1.9.

6. Run the activation and performance tests appropriate to BAS category

• Category A (Appendix A Section 8): Run the reference test and activation test per paras 8.1-8.3; ensure the specific brake application exhibits a 40-80% decrease in required pedal force for (FABS - FT) compared to (FABS, extrapolated - FT) and that the data-evaluation inequalities in para 8.3 are satisfied. Note FT and aT thresholds must be between specified ranges (aT between 3.5-5.0 m/s², para 8.2.3).
• Category B (Appendix A Section 9): Execute the reference test and the activation test per paras 9.1-9.3; apply the pedal quickly according to the manufacturer-specified input (manufacturer must notify the Technical Service of required pedal input at time of submission , Appendix A para 9.2), and demonstrate that mean deceleration aBAS≥0.85×aABS from t0 + 0.8 s until 15 km/h.

7. Prepare and retain manufacturer-supplied parameters and documentation

• Although Appendix A’s UNECE application/approval forms are disapplied (clause 6.1), the technical regime requires certain manufacturer-supplied parameters (FT, aT for Category A; pedal speed activation definition for Category B, Appendix A paras 8.2.3 and 9.2 and Annex 1 item 16.1). Record these thresholds and the underlying test data and retain them for presentation to the Administrator as evidence of technical compliance.

8. Provide means for periodic inspection verification

• Ensure that warning signals indicating BAS status are visible at power-on and that measures are in place to protect against simple unauthorised modification or provide a secondary check, as required by Appendix A para 5.6.2.

9. Address ABS and alternative compliance paths

• If the vehicle is required to have ABS by Appendix A para 5.1, ensure ABS meets Regulation 13‑H technical requirements. For MB, MC and NA vehicles, evaluate whether clause 6.2’s alternative , an Antilock System meeting ADR 35/… , is applicable and preferable for compliance.

10. Manage recordkeeping and interaction with the Administrator

• The ADR disapplies UNECE application and marking steps (clause 6.1) and re-maps Approval Authority to the Administrator (clause 5.2). Therefore, prepare a complete technical compliance dossier (test data, Annex 3/aABS determination, Annex 4 data-processing documentation, manufacturer-declared thresholds and procedures, EMC evidence) and be ready to provide it to the Administrator or to domestic enforcement bodies as required under the Motor Vehicle Standards Act 1989.

11. Consider manufacturing and production checks

• Although Appendix A’s Section 11 on conformity of production and Section 12 on penalties are disapplied (clause 6.1), manufacturers should nevertheless implement in-factory quality assurance to ensure that production vehicles match the tested type, because the Standard still requires vehicles to meet the Appendix A technical requirements and enforcement will be via domestic mechanisms.

12. Verify EV-specific EMC and charging considerations

• If the vehicle has a coupling system for charging the REESS, apply the 04 series of amendments of Regulation No. 10 as per Appendix A para 5.4. Document EMC testing and results to show BAS performance is not compromised by electromagnetic interference.

13. Continuous monitoring and updates

• Keep records of test rigs, calibration certificates, raw datasets and processing scripts to demonstrate the required accuracy and repeatability. Annex 4 sets strict requirements for sampling, filtering and phase-shift management that may be scrutinised by the Administrator.

This is a compliance pathway strictly grounded in the requirements stated in the Standard and Appendix A. Because the Standard disapplies UNECE approval transmission mechanisms and remaps approval terminology, the practical compliance step of presenting evidence to the Administrator will be critical. Manufacturers should ensure test rig capabilities and documentation match the stringent numerical tolerances in Annex 3 and Annex 4.