Comparative Overview EU-US Vehicle Standards

The first column lists the vehicle safety system/measure. These have been divided into safety systems/measures that are mandatory for all M and N vehicle categories, for passenger cars and vans, and for trucks and buses. (Note: L category vehicles such as motorcycles are not covered). ‘Passenger cars and vans’ are usually referred to as light vehicles in the US, and ‘trucks and buses’ are referred to as heavy vehicles. Any difference in application to vehicle categories is mentioned in the EU or USA column.

The ‘European Union’ column lists the current legal basis that mandates the system/measure to be installed as well as the regulatory act setting out the respective technical requirements, followed by the first application date (which is not necessarily the application date in the current legal basis). Any application date prior to 2024 means the system/measure was already required by either the previous GSR (661/2009), the PSR (78/2009) or earlier acts. All EU dates refer to ‘all new vehicles’ sold/registered, to align with the US dates applying to new vehicles manufactured. The EU rules already apply for the approval of new vehicle types two years prior to the listed date, with exceptions to this rule explicitly mentioned. Hyperlinks for UN Regulations link to the text as published in the Official Journal instead of WP.29’s register of UN Regulations; although they may not be the latest version of that UN Regulation available at WP.29, they are the current version of that UN Regulation that is mandatory in the EU.

The ‘United States of America’ column contains references to a Federal Motor Vehicle Safety Standard (FMVSS), a Notice of Proposed Rule Making (NPRM), or an Advanced Notice of Proposed Rule Making (ANPRM), where available.

The EU and US apply two different regulatory models for allowing vehicles on the road. In the EU, the type approval system requires vehicles to be approved by authorities that verify compliance with the applicable standards, before they are allowed to be marketed. In the US, vehicle manufacturers self-certify that their vehicles comply with the applicable standards and can market them without approval from an authority.