UNECE-Regeln tot für Teslas FSD/TAD: Warum nur noch Artikel 39 zählt

Tesla’s Path to European Approval

TeslaTobi argues that the standard UNECE approval route for bringing Tesla’s supervised driving system to Europe may not work for Tesla. Even if UNECE Regulation R171.02 takes effect soon, it would establish a common rulebook—not automatically authorize FSD/TAD. A manufacturer would still need to apply, undergo testing, and demonstrate compliance.

The presenter identifies eight requirements he considers problematic, though he discusses three in detail:

• Three-second maneuver announcement: The system must signal a maneuver three seconds before carrying it out. He believes Tesla is unlikely to redesign its behavior to meet this requirement.
• Speed offset: The presenter says Tesla’s reported agreement with German Transport Minister Bilger permits briefly driving up to 10% over the limit when traffic flow requires it. He considers this incompatible with the rule.
• Lateral acceleration: Automatic steering is generally limited to 3 m/s², with a short-duration allowance to exceed the limit. Tesla has reportedly withdrawn its request for an exemption on this point. The presenter says his initial dashcam-data analysis showed average lateral acceleration below the limit, but he plans more focused testing to assess how it affects cornering speed.

The presenter concludes that Tesla may instead need an Article 39 exemption. He cautions that a vote on the exemption is not guaranteed in December and that implementation could take additional months.

Regulatory and Safety Updates

• Norway’s road authority reports that no vote took place at the TCMV meeting on 6 October because authorities in most member states were not ready. Another meeting is scheduled for December, but a vote remains uncertain.
• Norway has approved three modified Tesla vehicles for testing. The authority has not approved customer demonstrations because it considers Tesla’s information material misleading: it did not clearly explain that the system is a driver-assistance system. Tesla was asked to revise it.
• The Norwegian authority also raises concerns about hands-off use in complex traffic, possible speeding, driver over-reliance, and whether driver-monitoring technology has been tested sufficiently.
• The presenter notes that the system’s European name and marketing have reportedly been adjusted in response to European feedback.

Other Reporting and Planned Coverage

TeslaTobi plans to monitor updates from the Norwegian authority and a French Tesla publication’s inquiry to EU countries. He reports that the publication contacted 28 countries with questions about approval procedures, driver responsibilities, road coverage, monitoring, and broader electromobility priorities.

The inquiry’s reported status includes:

• Green checkmarks for 10 countries
• Three replies awaiting permission to publish
• Four refusals to participate
• No response reported from 14 countries

These figures describe the magazine’s inquiry status, not a complete account of national approvals.

Guides, Reviews, and Tests

• The presenter refers viewers to an earlier video for a detailed walkthrough of the eight UNECE requirements.
• He plans further testing of lateral acceleration using data encoded in Tesla dashcam footage to determine whether the limit materially slows the system in curves.

Main Speakers and Sources

• TeslaTobi: Sole presenter and commentator; provides the analysis and proposed testing.
• Norwegian road authority: Source for the TCMV status, safety concerns, and updates on Tesla testing and customer demonstrations.
• Tesla Mark Magazine: Source for the survey of EU-country positions.
• UNECE R171.02 / TCMV process: Regulatory framework discussed in the video.