Proposal to amend para. 1 to clarify that type approval may be granted to vehicles of categories M₁, M₂, and N₁ with a reference mass not exceeding 2,840 kg at the manufacturer’s request, without requiring an existing approval of a configuration below 2,610 kg. The current wording restricts approval between 2,610 kg and 2,840 kg to extensions of existing approvals, creating market distortion. The concern is becoming more relevant with fleet electrification, as electrified vehicles are heavier and require different type designations in emissions-based regulations.

Proposal to amend para. 1 to provide requirements for four levels of approval including a new Level 1C based on 4-phase WLTC testing with requirements identical to Level 1A but allowing type approval test substitution with declaration of compliance, amend para. 5.2.1.© to indicate implementing stage/level as 1A, 1B, 1C or 02, amend para. 5.4.3. to require approval mark code distinguishing the level granted, and amend Table A3/1 of Annex 3 to assign code 1C to European Union and code 02 to Harmonized.

Proposal to add abbreviations for Fourier Transform InfraRed (FTIR) and Quantum Cascade Laser mid-InfraRed detection (QCL-IR) analysers, amend the definition of ‘Type of analyser’ to reference ‘Instrument manufacturer’, insert a new definition of ‘Instrument manufacturer’, amend paragraph 4.1.1 to permit use of QCL-IR or FTIR analysers for gaseous components except THC, add detailed specifications for FTIR and QCL-IR analysers including installation requirements and assessment procedures according to CEN EN 17507:2021, amend paragraph 4.3.5 to add interference check procedures for FTIR and QCL-IR analysers, and insert new Annexes 13 and 14 establishing a protocol for analyser assessment and a model certificate of acceptable analyser assessment.

Proposal to insert a new definition of hydrogen ICE vehicle, amend para. 8.2. to establish a two-step verification procedure for trip dynamic conditions, amend para. 9.3.1. to include requirements for hydrogen-fueled tests, amend para. 9.5. to require validation of software tools for trip verification and emissions calculation, amend para. 10.2. to establish a three-step trip validity assessment procedure, amend Figure 6 to illustrate the trip validity assessment procedure, amend para. 10.6. to include gaseous pollutant and particle number emissions during cold start in normal evaluation for hydrogen-fueled tests, amend para. 10.7. to apply separate data-set creation for 3-phase and 4-phase evaluation, amend Table A4/1 to add engine fuel flow as a test parameter, amend Table A5/1 footnote 3 to make PN concentration mandatory for hydrogen ICE vehicles, insert a new row in Table A7/1 for hydrogen stoichiometric coefficient values, amend Annex 8 title and para. 1. to clarify application to non-hydrogen vehicles, and add new Annex 8a establishing a moving averaging window method using distance-specific work for hydrogen ICE vehicles and amend Annex 11 paras. 2., 3.1., and 3.2. to include work ratio calculations applicable to hydrogen-fueled tests.

Japan presents positions on working documents for UN R168 (Real Driving Emissions). Japan does not accept the Level 1C concept, proposes deleting the type-approval scheme for equipment to eliminate unnecessary burden, and recommends adding technical requirements for laboratory equipment instead. Japan expresses technical concerns regarding sampling line temperature limits, text structure requiring restructuring, and hydrogen ICE provisions including dry-wet correction applicability and trip validity methods for bi-fuel vehicles.

Proposal to amend Annex 2, point 0.8. of Section I to add a footnote clarifying that documentation of name(s) and address(es) of assembly plant(s) shall only be applicable when the manufacturer’s information document in accordance with Part 2 of Annex 1 was supplied for type-approval purposes. UN Regulation No. 168 includes two versions of the manufacturer’s information document; Part 1 applies when all vehicles covered are also type-approved according to UN Regulation No. 154, while Part 2 applies when at least one vehicle is not covered by UN Regulation No. 154 type-approval.

Proposal to insert a new definition of hydrogen ICE vehicle, add a note to paragraph 6.1 specifying emissions requirements for 4-phase and 3-phase WLTC analysis, amend paragraphs 8.2, 9.3.1, 9.5, 10.2, 10.6, and 10.7 to clarify trip validity assessment procedures, amend Figure 6 to reflect updated assessment procedures, amend Table A4/1 to add engine fuel flow parameter and clarify mandatory parameters for hydrogen ICE vehicles, insert a new row in Table A5/1 for hydrogen, amend Annex 6 paragraph 3.2.2 to require engine speed and torque recording for hydrogen ICE vehicles, insert hydrogen in Table A7/1, retitle Annex 8, amend Annex 8 paragraph 1 to clarify application of moving averaging window method, and add new Annex 8a establishing an alternative moving averaging window methodology based on engine work for hydrogen ICE vehicles, and amend Annex 11 paragraphs 2, 3.1, and 3.2 and Figure A11/1 to incorporate work ratio calculations for hydrogen fuel tests.

Explanatory document on proposed amendments to UN R168 to enable real driving emissions testing of hydrogen internal combustion engine vehicles. The work-based approach replaces the CO-based moving averaging window methodology currently inapplicable to hydrogen-fuelled vehicles. Engine speed and torque data replace carbon monoxide to define window size and calculate the RDE/WLTP work ratio. Testing of a light commercial vehicle demonstrates the methodology’s practical applicability under regular and severe driving conditions, with results processed through independent post-processing tools.

Proposal to amend para. 1 to clarify that type approval may be granted to vehicles of categories M₁, M₂, and N₁ with a reference mass not exceeding 2,840 kg at the manufacturer’s request, without requiring an existing approval of a configuration below 2,610 kg. The current wording restricts approval between 2,610 kg and 2,840 kg to extensions of existing approvals, creating market distortion. The concern is becoming more relevant with fleet electrification, as electrified vehicles are heavier and require different type designations in emissions-based regulations.

Proposal to amend para. 1 to provide requirements for four levels of approval including a new Level 1C based on 4-phase WLTC testing with requirements identical to Level 1A but allowing type approval test substitution with declaration of compliance, amend para. 5.2.1.© to indicate implementing stage/level as 1A, 1B, 1C or 02, amend para. 5.4.3. to require approval mark code distinguishing the level granted, and amend Table A3/1 of Annex 3 to assign code 1C to European Union and code 02 to Harmonized.

Proposal to add abbreviations for Fourier Transform InfraRed (FTIR) and Quantum Cascade Laser mid-InfraRed detection (QCL-IR) analysers, amend the definition of ‘Type of analyser’ to reference ‘Instrument manufacturer’, insert a new definition of ‘Instrument manufacturer’, amend paragraph 4.1.1 to permit use of QCL-IR or FTIR analysers for gaseous components except THC, add detailed specifications for FTIR and QCL-IR analysers including installation requirements and assessment procedures according to CEN EN 17507:2021, amend paragraph 4.3.5 to add interference check procedures for FTIR and QCL-IR analysers, and insert new Annexes 13 and 14 establishing a protocol for analyser assessment and a model certificate of acceptable analyser assessment.

Proposal to insert a new definition of hydrogen ICE vehicle, amend para. 8.2. to establish a two-step verification procedure for trip dynamic conditions, amend para. 9.3.1. to include requirements for hydrogen-fueled tests, amend para. 9.5. to require validation of software tools for trip verification and emissions calculation, amend para. 10.2. to establish a three-step trip validity assessment procedure, amend Figure 6 to illustrate the trip validity assessment procedure, amend para. 10.6. to include gaseous pollutant and particle number emissions during cold start in normal evaluation for hydrogen-fueled tests, amend para. 10.7. to apply separate data-set creation for 3-phase and 4-phase evaluation, amend Table A4/1 to add engine fuel flow as a test parameter, amend Table A5/1 footnote 3 to make PN concentration mandatory for hydrogen ICE vehicles, insert a new row in Table A7/1 for hydrogen stoichiometric coefficient values, amend Annex 8 title and para. 1. to clarify application to non-hydrogen vehicles, and add new Annex 8a establishing a moving averaging window method using distance-specific work for hydrogen ICE vehicles and amend Annex 11 paras. 2., 3.1., and 3.2. to include work ratio calculations applicable to hydrogen-fueled tests.

Japan presents positions on working documents for UN R168 (Real Driving Emissions). Japan does not accept the Level 1C concept, proposes deleting the type-approval scheme for equipment to eliminate unnecessary burden, and recommends adding technical requirements for laboratory equipment instead. Japan expresses technical concerns regarding sampling line temperature limits, text structure requiring restructuring, and hydrogen ICE provisions including dry-wet correction applicability and trip validity methods for bi-fuel vehicles.

Proposal to amend Annex 2, point 0.8. of Section I to add a footnote clarifying that documentation of name(s) and address(es) of assembly plant(s) shall only be applicable when the manufacturer’s information document in accordance with Part 2 of Annex 1 was supplied for type-approval purposes. UN Regulation No. 168 includes two versions of the manufacturer’s information document; Part 1 applies when all vehicles covered are also type-approved according to UN Regulation No. 154, while Part 2 applies when at least one vehicle is not covered by UN Regulation No. 154 type-approval.

Proposal to insert a new definition of hydrogen ICE vehicle, add a note to paragraph 6.1 specifying emissions requirements for 4-phase and 3-phase WLTC analysis, amend paragraphs 8.2, 9.3.1, 9.5, 10.2, 10.6, and 10.7 to clarify trip validity assessment procedures, amend Figure 6 to reflect updated assessment procedures, amend Table A4/1 to add engine fuel flow parameter and clarify mandatory parameters for hydrogen ICE vehicles, insert a new row in Table A5/1 for hydrogen, amend Annex 6 paragraph 3.2.2 to require engine speed and torque recording for hydrogen ICE vehicles, insert hydrogen in Table A7/1, retitle Annex 8, amend Annex 8 paragraph 1 to clarify application of moving averaging window method, and add new Annex 8a establishing an alternative moving averaging window methodology based on engine work for hydrogen ICE vehicles, and amend Annex 11 paragraphs 2, 3.1, and 3.2 and Figure A11/1 to incorporate work ratio calculations for hydrogen fuel tests.

Explanatory document on proposed amendments to UN R168 to enable real driving emissions testing of hydrogen internal combustion engine vehicles. The work-based approach replaces the CO-based moving averaging window methodology currently inapplicable to hydrogen-fuelled vehicles. Engine speed and torque data replace carbon monoxide to define window size and calculate the RDE/WLTP work ratio. Testing of a light commercial vehicle demonstrates the methodology’s practical applicability under regular and severe driving conditions, with results processed through independent post-processing tools.

Proposal to amend para. 1 to clarify that type approval may be granted to vehicles of categories M₁, M₂, and N₁ with a reference mass not exceeding 2,840 kg at the manufacturer’s request, without requiring an existing approval of a configuration below 2,610 kg. The current wording restricts approval between 2,610 kg and 2,840 kg to extensions of existing approvals, creating market distortion. The concern is becoming more relevant with fleet electrification, as electrified vehicles are heavier and require different type designations in emissions-based regulations.

Proposal to amend para. 1 to provide requirements for four levels of approval including a new Level 1C based on 4-phase WLTC testing with requirements identical to Level 1A but allowing type approval test substitution with declaration of compliance, amend para. 5.2.1.© to indicate implementing stage/level as 1A, 1B, 1C or 02, amend para. 5.4.3. to require approval mark code distinguishing the level granted, and amend Table A3/1 of Annex 3 to assign code 1C to European Union and code 02 to Harmonized.

Proposal to add abbreviations for Fourier Transform InfraRed (FTIR) and Quantum Cascade Laser mid-InfraRed detection (QCL-IR) analysers, amend the definition of ‘Type of analyser’ to reference ‘Instrument manufacturer’, insert a new definition of ‘Instrument manufacturer’, amend paragraph 4.1.1 to permit use of QCL-IR or FTIR analysers for gaseous components except THC, add detailed specifications for FTIR and QCL-IR analysers including installation requirements and assessment procedures according to CEN EN 17507:2021, amend paragraph 4.3.5 to add interference check procedures for FTIR and QCL-IR analysers, and insert new Annexes 13 and 14 establishing a protocol for analyser assessment and a model certificate of acceptable analyser assessment.

Proposal to insert a new definition of hydrogen ICE vehicle, amend para. 8.2. to establish a two-step verification procedure for trip dynamic conditions, amend para. 9.3.1. to include requirements for hydrogen-fueled tests, amend para. 9.5. to require validation of software tools for trip verification and emissions calculation, amend para. 10.2. to establish a three-step trip validity assessment procedure, amend Figure 6 to illustrate the trip validity assessment procedure, amend para. 10.6. to include gaseous pollutant and particle number emissions during cold start in normal evaluation for hydrogen-fueled tests, amend para. 10.7. to apply separate data-set creation for 3-phase and 4-phase evaluation, amend Table A4/1 to add engine fuel flow as a test parameter, amend Table A5/1 footnote 3 to make PN concentration mandatory for hydrogen ICE vehicles, insert a new row in Table A7/1 for hydrogen stoichiometric coefficient values, amend Annex 8 title and para. 1. to clarify application to non-hydrogen vehicles, and add new Annex 8a establishing a moving averaging window method using distance-specific work for hydrogen ICE vehicles and amend Annex 11 paras. 2., 3.1., and 3.2. to include work ratio calculations applicable to hydrogen-fueled tests.

Japan presents positions on working documents for UN R168 (Real Driving Emissions). Japan does not accept the Level 1C concept, proposes deleting the type-approval scheme for equipment to eliminate unnecessary burden, and recommends adding technical requirements for laboratory equipment instead. Japan expresses technical concerns regarding sampling line temperature limits, text structure requiring restructuring, and hydrogen ICE provisions including dry-wet correction applicability and trip validity methods for bi-fuel vehicles.

Proposal to amend Annex 2, point 0.8. of Section I to add a footnote clarifying that documentation of name(s) and address(es) of assembly plant(s) shall only be applicable when the manufacturer’s information document in accordance with Part 2 of Annex 1 was supplied for type-approval purposes. UN Regulation No. 168 includes two versions of the manufacturer’s information document; Part 1 applies when all vehicles covered are also type-approved according to UN Regulation No. 154, while Part 2 applies when at least one vehicle is not covered by UN Regulation No. 154 type-approval.

Proposal to insert a new definition of hydrogen ICE vehicle, add a note to paragraph 6.1 specifying emissions requirements for 4-phase and 3-phase WLTC analysis, amend paragraphs 8.2, 9.3.1, 9.5, 10.2, 10.6, and 10.7 to clarify trip validity assessment procedures, amend Figure 6 to reflect updated assessment procedures, amend Table A4/1 to add engine fuel flow parameter and clarify mandatory parameters for hydrogen ICE vehicles, insert a new row in Table A5/1 for hydrogen, amend Annex 6 paragraph 3.2.2 to require engine speed and torque recording for hydrogen ICE vehicles, insert hydrogen in Table A7/1, retitle Annex 8, amend Annex 8 paragraph 1 to clarify application of moving averaging window method, and add new Annex 8a establishing an alternative moving averaging window methodology based on engine work for hydrogen ICE vehicles, and amend Annex 11 paragraphs 2, 3.1, and 3.2 and Figure A11/1 to incorporate work ratio calculations for hydrogen fuel tests.

Explanatory document on proposed amendments to UN R168 to enable real driving emissions testing of hydrogen internal combustion engine vehicles. The work-based approach replaces the CO-based moving averaging window methodology currently inapplicable to hydrogen-fuelled vehicles. Engine speed and torque data replace carbon monoxide to define window size and calculate the RDE/WLTP work ratio. Testing of a light commercial vehicle demonstrates the methodology’s practical applicability under regular and severe driving conditions, with results processed through independent post-processing tools.

Proposal to amend para. 1 to clarify that type approval may be granted to vehicles of categories M₁, M₂, and N₁ with a reference mass not exceeding 2,840 kg at the manufacturer’s request, without requiring an existing approval of a configuration below 2,610 kg. The current wording restricts approval between 2,610 kg and 2,840 kg to extensions of existing approvals, creating market distortion. The concern is becoming more relevant with fleet electrification, as electrified vehicles are heavier and require different type designations in emissions-based regulations.

Proposal to amend para. 1 to provide requirements for four levels of approval including a new Level 1C based on 4-phase WLTC testing with requirements identical to Level 1A but allowing type approval test substitution with declaration of compliance, amend para. 5.2.1.© to indicate implementing stage/level as 1A, 1B, 1C or 02, amend para. 5.4.3. to require approval mark code distinguishing the level granted, and amend Table A3/1 of Annex 3 to assign code 1C to European Union and code 02 to Harmonized.

Proposal to add abbreviations for Fourier Transform InfraRed (FTIR) and Quantum Cascade Laser mid-InfraRed detection (QCL-IR) analysers, amend the definition of ‘Type of analyser’ to reference ‘Instrument manufacturer’, insert a new definition of ‘Instrument manufacturer’, amend paragraph 4.1.1 to permit use of QCL-IR or FTIR analysers for gaseous components except THC, add detailed specifications for FTIR and QCL-IR analysers including installation requirements and assessment procedures according to CEN EN 17507:2021, amend paragraph 4.3.5 to add interference check procedures for FTIR and QCL-IR analysers, and insert new Annexes 13 and 14 establishing a protocol for analyser assessment and a model certificate of acceptable analyser assessment.

Proposal to insert a new definition of hydrogen ICE vehicle, amend para. 8.2. to establish a two-step verification procedure for trip dynamic conditions, amend para. 9.3.1. to include requirements for hydrogen-fueled tests, amend para. 9.5. to require validation of software tools for trip verification and emissions calculation, amend para. 10.2. to establish a three-step trip validity assessment procedure, amend Figure 6 to illustrate the trip validity assessment procedure, amend para. 10.6. to include gaseous pollutant and particle number emissions during cold start in normal evaluation for hydrogen-fueled tests, amend para. 10.7. to apply separate data-set creation for 3-phase and 4-phase evaluation, amend Table A4/1 to add engine fuel flow as a test parameter, amend Table A5/1 footnote 3 to make PN concentration mandatory for hydrogen ICE vehicles, insert a new row in Table A7/1 for hydrogen stoichiometric coefficient values, amend Annex 8 title and para. 1. to clarify application to non-hydrogen vehicles, and add new Annex 8a establishing a moving averaging window method using distance-specific work for hydrogen ICE vehicles and amend Annex 11 paras. 2., 3.1., and 3.2. to include work ratio calculations applicable to hydrogen-fueled tests.

Japan presents positions on working documents for UN R168 (Real Driving Emissions). Japan does not accept the Level 1C concept, proposes deleting the type-approval scheme for equipment to eliminate unnecessary burden, and recommends adding technical requirements for laboratory equipment instead. Japan expresses technical concerns regarding sampling line temperature limits, text structure requiring restructuring, and hydrogen ICE provisions including dry-wet correction applicability and trip validity methods for bi-fuel vehicles.

Proposal to amend Annex 2, point 0.8. of Section I to add a footnote clarifying that documentation of name(s) and address(es) of assembly plant(s) shall only be applicable when the manufacturer’s information document in accordance with Part 2 of Annex 1 was supplied for type-approval purposes. UN Regulation No. 168 includes two versions of the manufacturer’s information document; Part 1 applies when all vehicles covered are also type-approved according to UN Regulation No. 154, while Part 2 applies when at least one vehicle is not covered by UN Regulation No. 154 type-approval.

Proposal to insert a new definition of hydrogen ICE vehicle, add a note to paragraph 6.1 specifying emissions requirements for 4-phase and 3-phase WLTC analysis, amend paragraphs 8.2, 9.3.1, 9.5, 10.2, 10.6, and 10.7 to clarify trip validity assessment procedures, amend Figure 6 to reflect updated assessment procedures, amend Table A4/1 to add engine fuel flow parameter and clarify mandatory parameters for hydrogen ICE vehicles, insert a new row in Table A5/1 for hydrogen, amend Annex 6 paragraph 3.2.2 to require engine speed and torque recording for hydrogen ICE vehicles, insert hydrogen in Table A7/1, retitle Annex 8, amend Annex 8 paragraph 1 to clarify application of moving averaging window method, and add new Annex 8a establishing an alternative moving averaging window methodology based on engine work for hydrogen ICE vehicles, and amend Annex 11 paragraphs 2, 3.1, and 3.2 and Figure A11/1 to incorporate work ratio calculations for hydrogen fuel tests.

Explanatory document on proposed amendments to UN R168 to enable real driving emissions testing of hydrogen internal combustion engine vehicles. The work-based approach replaces the CO-based moving averaging window methodology currently inapplicable to hydrogen-fuelled vehicles. Engine speed and torque data replace carbon monoxide to define window size and calculate the RDE/WLTP work ratio. Testing of a light commercial vehicle demonstrates the methodology’s practical applicability under regular and severe driving conditions, with results processed through independent post-processing tools.

Proposal to amend para. 1 to clarify that type approval may be granted to vehicles of categories M₁, M₂, and N₁ with a reference mass not exceeding 2,840 kg at the manufacturer’s request, without requiring an existing approval of a configuration below 2,610 kg. The current wording restricts approval between 2,610 kg and 2,840 kg to extensions of existing approvals, creating market distortion. The concern is becoming more relevant with fleet electrification, as electrified vehicles are heavier and require different type designations in emissions-based regulations.

Proposal to amend para. 1 to provide requirements for four levels of approval including a new Level 1C based on 4-phase WLTC testing with requirements identical to Level 1A but allowing type approval test substitution with declaration of compliance, amend para. 5.2.1.© to indicate implementing stage/level as 1A, 1B, 1C or 02, amend para. 5.4.3. to require approval mark code distinguishing the level granted, and amend Table A3/1 of Annex 3 to assign code 1C to European Union and code 02 to Harmonized.

Proposal to add abbreviations for Fourier Transform InfraRed (FTIR) and Quantum Cascade Laser mid-InfraRed detection (QCL-IR) analysers, amend the definition of ‘Type of analyser’ to reference ‘Instrument manufacturer’, insert a new definition of ‘Instrument manufacturer’, amend paragraph 4.1.1 to permit use of QCL-IR or FTIR analysers for gaseous components except THC, add detailed specifications for FTIR and QCL-IR analysers including installation requirements and assessment procedures according to CEN EN 17507:2021, amend paragraph 4.3.5 to add interference check procedures for FTIR and QCL-IR analysers, and insert new Annexes 13 and 14 establishing a protocol for analyser assessment and a model certificate of acceptable analyser assessment.

Proposal to insert a new definition of hydrogen ICE vehicle, amend para. 8.2. to establish a two-step verification procedure for trip dynamic conditions, amend para. 9.3.1. to include requirements for hydrogen-fueled tests, amend para. 9.5. to require validation of software tools for trip verification and emissions calculation, amend para. 10.2. to establish a three-step trip validity assessment procedure, amend Figure 6 to illustrate the trip validity assessment procedure, amend para. 10.6. to include gaseous pollutant and particle number emissions during cold start in normal evaluation for hydrogen-fueled tests, amend para. 10.7. to apply separate data-set creation for 3-phase and 4-phase evaluation, amend Table A4/1 to add engine fuel flow as a test parameter, amend Table A5/1 footnote 3 to make PN concentration mandatory for hydrogen ICE vehicles, insert a new row in Table A7/1 for hydrogen stoichiometric coefficient values, amend Annex 8 title and para. 1. to clarify application to non-hydrogen vehicles, and add new Annex 8a establishing a moving averaging window method using distance-specific work for hydrogen ICE vehicles and amend Annex 11 paras. 2., 3.1., and 3.2. to include work ratio calculations applicable to hydrogen-fueled tests.

Japan presents positions on working documents for UN R168 (Real Driving Emissions). Japan does not accept the Level 1C concept, proposes deleting the type-approval scheme for equipment to eliminate unnecessary burden, and recommends adding technical requirements for laboratory equipment instead. Japan expresses technical concerns regarding sampling line temperature limits, text structure requiring restructuring, and hydrogen ICE provisions including dry-wet correction applicability and trip validity methods for bi-fuel vehicles.

Proposal to amend Annex 2, point 0.8. of Section I to add a footnote clarifying that documentation of name(s) and address(es) of assembly plant(s) shall only be applicable when the manufacturer’s information document in accordance with Part 2 of Annex 1 was supplied for type-approval purposes. UN Regulation No. 168 includes two versions of the manufacturer’s information document; Part 1 applies when all vehicles covered are also type-approved according to UN Regulation No. 154, while Part 2 applies when at least one vehicle is not covered by UN Regulation No. 154 type-approval.

Proposal to insert a new definition of hydrogen ICE vehicle, add a note to paragraph 6.1 specifying emissions requirements for 4-phase and 3-phase WLTC analysis, amend paragraphs 8.2, 9.3.1, 9.5, 10.2, 10.6, and 10.7 to clarify trip validity assessment procedures, amend Figure 6 to reflect updated assessment procedures, amend Table A4/1 to add engine fuel flow parameter and clarify mandatory parameters for hydrogen ICE vehicles, insert a new row in Table A5/1 for hydrogen, amend Annex 6 paragraph 3.2.2 to require engine speed and torque recording for hydrogen ICE vehicles, insert hydrogen in Table A7/1, retitle Annex 8, amend Annex 8 paragraph 1 to clarify application of moving averaging window method, and add new Annex 8a establishing an alternative moving averaging window methodology based on engine work for hydrogen ICE vehicles, and amend Annex 11 paragraphs 2, 3.1, and 3.2 and Figure A11/1 to incorporate work ratio calculations for hydrogen fuel tests.

Explanatory document on proposed amendments to UN R168 to enable real driving emissions testing of hydrogen internal combustion engine vehicles. The work-based approach replaces the CO-based moving averaging window methodology currently inapplicable to hydrogen-fuelled vehicles. Engine speed and torque data replace carbon monoxide to define window size and calculate the RDE/WLTP work ratio. Testing of a light commercial vehicle demonstrates the methodology’s practical applicability under regular and severe driving conditions, with results processed through independent post-processing tools.

Proposal to amend para. 1 to clarify that type approval may be granted to vehicles of categories M₁, M₂, and N₁ with a reference mass not exceeding 2,840 kg at the manufacturer’s request, without requiring an existing approval of a configuration below 2,610 kg. The current wording restricts approval between 2,610 kg and 2,840 kg to extensions of existing approvals, creating market distortion. The concern is becoming more relevant with fleet electrification, as electrified vehicles are heavier and require different type designations in emissions-based regulations.

Proposal to amend para. 1 to provide requirements for four levels of approval including a new Level 1C based on 4-phase WLTC testing with requirements identical to Level 1A but allowing type approval test substitution with declaration of compliance, amend para. 5.2.1.© to indicate implementing stage/level as 1A, 1B, 1C or 02, amend para. 5.4.3. to require approval mark code distinguishing the level granted, and amend Table A3/1 of Annex 3 to assign code 1C to European Union and code 02 to Harmonized.

Proposal to add abbreviations for Fourier Transform InfraRed (FTIR) and Quantum Cascade Laser mid-InfraRed detection (QCL-IR) analysers, amend the definition of ‘Type of analyser’ to reference ‘Instrument manufacturer’, insert a new definition of ‘Instrument manufacturer’, amend paragraph 4.1.1 to permit use of QCL-IR or FTIR analysers for gaseous components except THC, add detailed specifications for FTIR and QCL-IR analysers including installation requirements and assessment procedures according to CEN EN 17507:2021, amend paragraph 4.3.5 to add interference check procedures for FTIR and QCL-IR analysers, and insert new Annexes 13 and 14 establishing a protocol for analyser assessment and a model certificate of acceptable analyser assessment.

Proposal to insert a new definition of hydrogen ICE vehicle, amend para. 8.2. to establish a two-step verification procedure for trip dynamic conditions, amend para. 9.3.1. to include requirements for hydrogen-fueled tests, amend para. 9.5. to require validation of software tools for trip verification and emissions calculation, amend para. 10.2. to establish a three-step trip validity assessment procedure, amend Figure 6 to illustrate the trip validity assessment procedure, amend para. 10.6. to include gaseous pollutant and particle number emissions during cold start in normal evaluation for hydrogen-fueled tests, amend para. 10.7. to apply separate data-set creation for 3-phase and 4-phase evaluation, amend Table A4/1 to add engine fuel flow as a test parameter, amend Table A5/1 footnote 3 to make PN concentration mandatory for hydrogen ICE vehicles, insert a new row in Table A7/1 for hydrogen stoichiometric coefficient values, amend Annex 8 title and para. 1. to clarify application to non-hydrogen vehicles, and add new Annex 8a establishing a moving averaging window method using distance-specific work for hydrogen ICE vehicles and amend Annex 11 paras. 2., 3.1., and 3.2. to include work ratio calculations applicable to hydrogen-fueled tests.

Japan presents positions on working documents for UN R168 (Real Driving Emissions). Japan does not accept the Level 1C concept, proposes deleting the type-approval scheme for equipment to eliminate unnecessary burden, and recommends adding technical requirements for laboratory equipment instead. Japan expresses technical concerns regarding sampling line temperature limits, text structure requiring restructuring, and hydrogen ICE provisions including dry-wet correction applicability and trip validity methods for bi-fuel vehicles.

Proposal to amend Annex 2, point 0.8. of Section I to add a footnote clarifying that documentation of name(s) and address(es) of assembly plant(s) shall only be applicable when the manufacturer’s information document in accordance with Part 2 of Annex 1 was supplied for type-approval purposes. UN Regulation No. 168 includes two versions of the manufacturer’s information document; Part 1 applies when all vehicles covered are also type-approved according to UN Regulation No. 154, while Part 2 applies when at least one vehicle is not covered by UN Regulation No. 154 type-approval.

Proposal to insert a new definition of hydrogen ICE vehicle, add a note to paragraph 6.1 specifying emissions requirements for 4-phase and 3-phase WLTC analysis, amend paragraphs 8.2, 9.3.1, 9.5, 10.2, 10.6, and 10.7 to clarify trip validity assessment procedures, amend Figure 6 to reflect updated assessment procedures, amend Table A4/1 to add engine fuel flow parameter and clarify mandatory parameters for hydrogen ICE vehicles, insert a new row in Table A5/1 for hydrogen, amend Annex 6 paragraph 3.2.2 to require engine speed and torque recording for hydrogen ICE vehicles, insert hydrogen in Table A7/1, retitle Annex 8, amend Annex 8 paragraph 1 to clarify application of moving averaging window method, and add new Annex 8a establishing an alternative moving averaging window methodology based on engine work for hydrogen ICE vehicles, and amend Annex 11 paragraphs 2, 3.1, and 3.2 and Figure A11/1 to incorporate work ratio calculations for hydrogen fuel tests.

Explanatory document on proposed amendments to UN R168 to enable real driving emissions testing of hydrogen internal combustion engine vehicles. The work-based approach replaces the CO-based moving averaging window methodology currently inapplicable to hydrogen-fuelled vehicles. Engine speed and torque data replace carbon monoxide to define window size and calculate the RDE/WLTP work ratio. Testing of a light commercial vehicle demonstrates the methodology’s practical applicability under regular and severe driving conditions, with results processed through independent post-processing tools.

Proposal to amend para. 1 to clarify that type approval may be granted to vehicles of categories M₁, M₂, and N₁ with a reference mass not exceeding 2,840 kg at the manufacturer’s request, without requiring an existing approval of a configuration below 2,610 kg. The current wording restricts approval between 2,610 kg and 2,840 kg to extensions of existing approvals, creating market distortion. The concern is becoming more relevant with fleet electrification, as electrified vehicles are heavier and require different type designations in emissions-based regulations.

Proposal to amend para. 1 to provide requirements for four levels of approval including a new Level 1C based on 4-phase WLTC testing with requirements identical to Level 1A but allowing type approval test substitution with declaration of compliance, amend para. 5.2.1.© to indicate implementing stage/level as 1A, 1B, 1C or 02, amend para. 5.4.3. to require approval mark code distinguishing the level granted, and amend Table A3/1 of Annex 3 to assign code 1C to European Union and code 02 to Harmonized.

Proposal to add abbreviations for Fourier Transform InfraRed (FTIR) and Quantum Cascade Laser mid-InfraRed detection (QCL-IR) analysers, amend the definition of ‘Type of analyser’ to reference ‘Instrument manufacturer’, insert a new definition of ‘Instrument manufacturer’, amend paragraph 4.1.1 to permit use of QCL-IR or FTIR analysers for gaseous components except THC, add detailed specifications for FTIR and QCL-IR analysers including installation requirements and assessment procedures according to CEN EN 17507:2021, amend paragraph 4.3.5 to add interference check procedures for FTIR and QCL-IR analysers, and insert new Annexes 13 and 14 establishing a protocol for analyser assessment and a model certificate of acceptable analyser assessment.

Proposal to insert a new definition of hydrogen ICE vehicle, amend para. 8.2. to establish a two-step verification procedure for trip dynamic conditions, amend para. 9.3.1. to include requirements for hydrogen-fueled tests, amend para. 9.5. to require validation of software tools for trip verification and emissions calculation, amend para. 10.2. to establish a three-step trip validity assessment procedure, amend Figure 6 to illustrate the trip validity assessment procedure, amend para. 10.6. to include gaseous pollutant and particle number emissions during cold start in normal evaluation for hydrogen-fueled tests, amend para. 10.7. to apply separate data-set creation for 3-phase and 4-phase evaluation, amend Table A4/1 to add engine fuel flow as a test parameter, amend Table A5/1 footnote 3 to make PN concentration mandatory for hydrogen ICE vehicles, insert a new row in Table A7/1 for hydrogen stoichiometric coefficient values, amend Annex 8 title and para. 1. to clarify application to non-hydrogen vehicles, and add new Annex 8a establishing a moving averaging window method using distance-specific work for hydrogen ICE vehicles and amend Annex 11 paras. 2., 3.1., and 3.2. to include work ratio calculations applicable to hydrogen-fueled tests.

Japan presents positions on working documents for UN R168 (Real Driving Emissions). Japan does not accept the Level 1C concept, proposes deleting the type-approval scheme for equipment to eliminate unnecessary burden, and recommends adding technical requirements for laboratory equipment instead. Japan expresses technical concerns regarding sampling line temperature limits, text structure requiring restructuring, and hydrogen ICE provisions including dry-wet correction applicability and trip validity methods for bi-fuel vehicles.

Proposal to amend Annex 2, point 0.8. of Section I to add a footnote clarifying that documentation of name(s) and address(es) of assembly plant(s) shall only be applicable when the manufacturer’s information document in accordance with Part 2 of Annex 1 was supplied for type-approval purposes. UN Regulation No. 168 includes two versions of the manufacturer’s information document; Part 1 applies when all vehicles covered are also type-approved according to UN Regulation No. 154, while Part 2 applies when at least one vehicle is not covered by UN Regulation No. 154 type-approval.

Proposal to insert a new definition of hydrogen ICE vehicle, add a note to paragraph 6.1 specifying emissions requirements for 4-phase and 3-phase WLTC analysis, amend paragraphs 8.2, 9.3.1, 9.5, 10.2, 10.6, and 10.7 to clarify trip validity assessment procedures, amend Figure 6 to reflect updated assessment procedures, amend Table A4/1 to add engine fuel flow parameter and clarify mandatory parameters for hydrogen ICE vehicles, insert a new row in Table A5/1 for hydrogen, amend Annex 6 paragraph 3.2.2 to require engine speed and torque recording for hydrogen ICE vehicles, insert hydrogen in Table A7/1, retitle Annex 8, amend Annex 8 paragraph 1 to clarify application of moving averaging window method, and add new Annex 8a establishing an alternative moving averaging window methodology based on engine work for hydrogen ICE vehicles, and amend Annex 11 paragraphs 2, 3.1, and 3.2 and Figure A11/1 to incorporate work ratio calculations for hydrogen fuel tests.

Explanatory document on proposed amendments to UN R168 to enable real driving emissions testing of hydrogen internal combustion engine vehicles. The work-based approach replaces the CO-based moving averaging window methodology currently inapplicable to hydrogen-fuelled vehicles. Engine speed and torque data replace carbon monoxide to define window size and calculate the RDE/WLTP work ratio. Testing of a light commercial vehicle demonstrates the methodology’s practical applicability under regular and severe driving conditions, with results processed through independent post-processing tools.

Proposal to amend para. 1 to clarify that type approval may be granted to vehicles of categories M₁, M₂, and N₁ with a reference mass not exceeding 2,840 kg at the manufacturer’s request, without requiring an existing approval of a configuration below 2,610 kg. The current wording restricts approval between 2,610 kg and 2,840 kg to extensions of existing approvals, creating market distortion. The concern is becoming more relevant with fleet electrification, as electrified vehicles are heavier and require different type designations in emissions-based regulations.

Proposal to amend para. 1 to provide requirements for four levels of approval including a new Level 1C based on 4-phase WLTC testing with requirements identical to Level 1A but allowing type approval test substitution with declaration of compliance, amend para. 5.2.1.© to indicate implementing stage/level as 1A, 1B, 1C or 02, amend para. 5.4.3. to require approval mark code distinguishing the level granted, and amend Table A3/1 of Annex 3 to assign code 1C to European Union and code 02 to Harmonized.

Proposal to add abbreviations for Fourier Transform InfraRed (FTIR) and Quantum Cascade Laser mid-InfraRed detection (QCL-IR) analysers, amend the definition of ‘Type of analyser’ to reference ‘Instrument manufacturer’, insert a new definition of ‘Instrument manufacturer’, amend paragraph 4.1.1 to permit use of QCL-IR or FTIR analysers for gaseous components except THC, add detailed specifications for FTIR and QCL-IR analysers including installation requirements and assessment procedures according to CEN EN 17507:2021, amend paragraph 4.3.5 to add interference check procedures for FTIR and QCL-IR analysers, and insert new Annexes 13 and 14 establishing a protocol for analyser assessment and a model certificate of acceptable analyser assessment.

Proposal to insert a new definition of hydrogen ICE vehicle, amend para. 8.2. to establish a two-step verification procedure for trip dynamic conditions, amend para. 9.3.1. to include requirements for hydrogen-fueled tests, amend para. 9.5. to require validation of software tools for trip verification and emissions calculation, amend para. 10.2. to establish a three-step trip validity assessment procedure, amend Figure 6 to illustrate the trip validity assessment procedure, amend para. 10.6. to include gaseous pollutant and particle number emissions during cold start in normal evaluation for hydrogen-fueled tests, amend para. 10.7. to apply separate data-set creation for 3-phase and 4-phase evaluation, amend Table A4/1 to add engine fuel flow as a test parameter, amend Table A5/1 footnote 3 to make PN concentration mandatory for hydrogen ICE vehicles, insert a new row in Table A7/1 for hydrogen stoichiometric coefficient values, amend Annex 8 title and para. 1. to clarify application to non-hydrogen vehicles, and add new Annex 8a establishing a moving averaging window method using distance-specific work for hydrogen ICE vehicles and amend Annex 11 paras. 2., 3.1., and 3.2. to include work ratio calculations applicable to hydrogen-fueled tests.

Japan presents positions on working documents for UN R168 (Real Driving Emissions). Japan does not accept the Level 1C concept, proposes deleting the type-approval scheme for equipment to eliminate unnecessary burden, and recommends adding technical requirements for laboratory equipment instead. Japan expresses technical concerns regarding sampling line temperature limits, text structure requiring restructuring, and hydrogen ICE provisions including dry-wet correction applicability and trip validity methods for bi-fuel vehicles.

Proposal to amend Annex 2, point 0.8. of Section I to add a footnote clarifying that documentation of name(s) and address(es) of assembly plant(s) shall only be applicable when the manufacturer’s information document in accordance with Part 2 of Annex 1 was supplied for type-approval purposes. UN Regulation No. 168 includes two versions of the manufacturer’s information document; Part 1 applies when all vehicles covered are also type-approved according to UN Regulation No. 154, while Part 2 applies when at least one vehicle is not covered by UN Regulation No. 154 type-approval.

Proposal to insert a new definition of hydrogen ICE vehicle, add a note to paragraph 6.1 specifying emissions requirements for 4-phase and 3-phase WLTC analysis, amend paragraphs 8.2, 9.3.1, 9.5, 10.2, 10.6, and 10.7 to clarify trip validity assessment procedures, amend Figure 6 to reflect updated assessment procedures, amend Table A4/1 to add engine fuel flow parameter and clarify mandatory parameters for hydrogen ICE vehicles, insert a new row in Table A5/1 for hydrogen, amend Annex 6 paragraph 3.2.2 to require engine speed and torque recording for hydrogen ICE vehicles, insert hydrogen in Table A7/1, retitle Annex 8, amend Annex 8 paragraph 1 to clarify application of moving averaging window method, and add new Annex 8a establishing an alternative moving averaging window methodology based on engine work for hydrogen ICE vehicles, and amend Annex 11 paragraphs 2, 3.1, and 3.2 and Figure A11/1 to incorporate work ratio calculations for hydrogen fuel tests.

Explanatory document on proposed amendments to UN R168 to enable real driving emissions testing of hydrogen internal combustion engine vehicles. The work-based approach replaces the CO-based moving averaging window methodology currently inapplicable to hydrogen-fuelled vehicles. Engine speed and torque data replace carbon monoxide to define window size and calculate the RDE/WLTP work ratio. Testing of a light commercial vehicle demonstrates the methodology’s practical applicability under regular and severe driving conditions, with results processed through independent post-processing tools.