GRSP-62-14
Proposal for collective amendments to UN Regulations Nos. 16, 94, and 137
Proposal for collective amendments to UN Regulations Nos. 16, 94, and 137
As a counterproposal to document GRSP/2017/27 submitted by the EC, OICA suggests to group all the airbag warning requirements in one single UN Regulation (i.e. UN R16); this would avoid future administrative burden when these may need adaptation. Another solution could be to simply refer, in UN R94 and UN R137, to the label defined in UN R16; OICA suggests that GRSP discusses the most suitable approach.
In addition, OICA agrees with the EC proposal to better define the required label, in order to avoid potential misinterpretations. However, when it comes to the printing of the user information in a multitude of languages, OICA considers this is an unnecessary burden, with no benefit to the user. User manuals are placed in the vehicles at the point of sale and therefore in the local language(s); in the not so frequent cases whereby a vehicle, during its lifetime, ends up in a different country/language, the user will always be able to obtain the manual in his own language, if he so asks. OICA consequently proposes not to amend the current requirements on the issue of languages.
GRSP-62-14
Proposal for collective amendments to UN Regulations Nos. 16, 94, and 137
Proposal for collective amendments to UN Regulations Nos. 16, 94, and 137
As a counterproposal to document GRSP/2017/27 submitted by the EC, OICA suggests to group all the airbag warning requirements in one single UN Regulation (i.e. UN R16); this would avoid future administrative burden when these may need adaptation. Another solution could be to simply refer, in UN R94 and UN R137, to the label defined in UN R16; OICA suggests that GRSP discusses the most suitable approach.
In addition, OICA agrees with the EC proposal to better define the required label, in order to avoid potential misinterpretations. However, when it comes to the printing of the user information in a multitude of languages, OICA considers this is an unnecessary burden, with no benefit to the user. User manuals are placed in the vehicles at the point of sale and therefore in the local language(s); in the not so frequent cases whereby a vehicle, during its lifetime, ends up in a different country/language, the user will always be able to obtain the manual in his own language, if he so asks. OICA consequently proposes not to amend the current requirements on the issue of languages.