I had it from the proverbial ‘horses mouth’ a couple of weeks ago, and basically the design has been finalised and 2 of the 3 approval stages have been finalised. Once the third stage is completed, early next year, then the companies can begin production.
The implementation date set out in the Regulations (European Journal 1360/2002) requires them to be fitted to any vehicle first registered 5.8.2004 onwards. Whilst the manufacturers could (possibly) gear up to supply the demand for new vehicles, the systems are not yet in place in respect of training for the four groups of workers involved. Workshop->Driver->Company->Enforcement.
“Training for the Trainers” is expected to start next Spring.
Where this thing gets silly is that the dat 5.8.2004 is set in stone. It cannot be changed without being put back before the Council of Ministers. However, if they did that, with all the additional Countries joining the EC, the whole thing could get voted out. 
So it appears that what has been thrashed out is that there will be a ‘Gentleman’s Agreement’. i.e. The regulation will remain but will be overlooked for about 12 months.
Will there be benefits? Firstly there will be a cost saving in analysing charts, which if I correctly remember seeing something recently, costs between 20 and 30 pence per chart. With the correct software infringements can readily be checked at a much lower per unit cost.
Secondly, if the vehicle is connected back to the Company via a data link, then Planners will be able to check both the number of Duty hours and Driving hours that have been used in the current week/fortnight, thereby being able to forecast more efficiently.
One thing that does not seem to have been fully considered is the requirement to have the Driver Card downloaded at periods of not more than 21 days. (Similar to handing in tacho charts.)
If you take the case of an Agency driver who, within that 21 day period, drives for companies A, B, C and D. Come day 21, the driver cannot be expected to get in his car and drive around the four companies having the card downloaded, particularly if company B was a ‘special’ job which involved significant travelling to collect the vehicle and ‘Nights Out’. Let’s then assume that the work for company C was based at a satellite yard where there are no Office staff employed.
Working for company A is fine. Working out of a major depot and at the end of every working day, the company download the Driver card. (21 days is a maximum limit - downloading every day complies with this requirement). Company D is another major depot, so no problems there, except, they will also be downloading the data in respect of company C and possibly company B, and this data may be commercially sensitive. The logical answer would be for company D to hold the data relating to companies C & B as archive. i.e. Only accessible with a Control (Enforcement) Card.
So. A Solution
The Agency downloads the data. No, what if that driver in the 21 day period has worked for Agency A, B, C & D. The same arguments then apply.
And where would an O/D download their data? We didn’t even get that far.
There will be a large number of smaller companies that will not get geared up for the introduction of these cards and I envisage Transport Consultants will be getting in there fast to fill the void.