[Proposal intended for consideration at the June 2012 WP.29 session.

The EU notes issues that may delay its ability to support the proposal. First, the EU wonders why the proposal contains an unusually long 90 month transition period. If more than seven years is needed before its application, are the provisions really needed? Similarly, the EU wishes to further consider the cost-benefit of the proposed provisions.]

17. The expert from OICA introduced GRE-67-27, raising industry concerns about ECE/TRANS/WP.29/GRE/2012/21, regarding visibility range, glare and a note to the driver. The expert from Poland presented GRE-67-33 supporting ECE/TRANS/WP.29/GRE/2012/21 and GRE-67-37 as a revised version of
ECE/TRANS/WP.29/GRE/2012/21. GRE agreed to resume consideration of ECE/TRANS/WP.29/GRE/2012/21 at its October 2012 session. GRE requested the secretariat to distribute GRE-67-37 with an official symbol for its next session.

18. GRE considered ECE/TRANS/WP.29/GRE/2012/18, introduced by the expert from Germany, intending to eliminate certain inconsistencies in the existing text on reversing lamps. GRE adopted ECE/TRANS/WP.29/GRE/2012/18, as amended below, and requested the secretariat to submit it to WP.29 and AC.1, for consideration at their November 2012 sessions, as draft Supplement 2 to the 05 series of amendments to UN Regulation No. 48.

Page 2, par. 6.4.5.2., amend to read:

19. GRE resumed consideration of ECE/TRANS/WP.29/2011/99 and ECE/TRANS/WP.29/2011/99/Corr.1. GRE agreed to prepare and adopt a document ECE/TRANS/WP.29/2011/99/Corr.2, superseding ECE/TRANS/WP.29/2011/99/Corr.1, including a change of all the references to the 90-month transitional period to a 84-month transitional period, and to furthermore amend all references to Supplement 8 to the 04 series of amendments to Supplement 01 to the 06 series of amendments to UN Regulation No. 48. The secretariat was requested to submit ECE/TRANS/WP.29/2011/99/Corr.2 to WP.29 and AC.1 for consideration at their June 2012 sessions and agreed to keep this item on the agenda of its October 2012 session.

EU notes the unusually long transition period and raises concerns over lack of robust cost/benefit analysis to support the proposed changes, so the Forum sends the proposal back to GRE for futher consideration.

15. GRE adopted ECE/TRANS/WP.29/GRE/2010/27, not amended. The secretariat was requested to submit the proposal to WP.29 and AC.1 at their November 2011 session, as draft Supplement 2 to the 04 series of amendments to Regulation No. 19, as part of (see para. 6) draft Supplement 8 to the 04 series of amendments to Regulation No. 48, as draft Supplement 2 to the 01 series of amendments to Regulation No. 98, as draft Supplement 10 to Regulation No. 113 and as draft Supplement 2 to the 01 series of amendments to Regulation No. 123.

16. GRE noted that WP.29 at its November 2010 session referred back ECE/TRANS/WP.29/2010/107 and ECE/TRANS/WP.29/2010/107/Corr.1 to GRE for further consideration (see ECE/TRANS/WP.29/1087, para 62). GRE adopted ECE/TRANS/WP.29/2010/107, as amended by Annex IV to this report, ECE/TRANS/WP.29/GRE/2011/17, not amended (superseding ECE/TRANS/WP.29/2010/107/Corr.1 and para. 2.7.27. of ECE/TRANS/WP.29/2010/107). The secretariat was requested to submit both proposals to the November 2011 sessions of WP.29 and AC.1 as draft Corrigendum 4 to the 04 series of amendments to Regulation No. 48.

17. GRE considered ECE/TRANS/WP.29/GRE/2011/27, introducing mandatory automatic levelling for headlamps (superseding ECE/TRANS/WP.29/GRE/2011/2 and ECE/TRANS/WP.29/GRE/2011/22). The proposal received comments from the experts of GTB (GRE-65-03 and GRE-65-17) and OICA (GRE-65-16) among others. GRE adopted ECE/TRANS/WP.29/GRE/2011/27, as amended by Annex IV to this report. GRE agreed that this adoption was subject to the development of a further proposal to be prepared by the expert from GTB who would lead a comprehensive study of the whole issue of glare and visibility during night-time driving. Accordingly, it was agreed in case the results of the study revealed alternatives to the adopted mandatory requirements for automatic leveling and cleaning, the provisions of Regulation No. 48 would be re-examined at any time during the 90 months transitional period provided by ECE/TRANS/WP.29/GRE/2011/27. It was further agreed that, while the study would be managed by a dedicated working group based on the GTB structure, participation would be open to any GRE expert wishing to contribute. The secretariat was requested to submit ECE/TRANS/WP.29/GRE/2011/27 to WP.29 and AC.1 at their November 2011 sessions as draft ⁰⁶ series of amendments to Regulation No. 48.

18. GRE adopted ECE/TRANS/WP.29/GRE/2011/3, not amended. The secretariat was requested to submit ECE/TRANS/WP.29/GRE/2011/3 as draft Supplement 7 to Regulation No. 99 to WP.29 and AC.1 at their November 2011 session.

19. The expert from Poland introduced GRE-65-13-Rev.1 through a presentation (GRE-65-30). GRE requested the secretariat to distribute GRE-65-13-Rev.1 with an official symbol at its October 2011 session. GRE also agreed to consider ECE/TRANS/WP.29/GRE/2011/24 under this item, instead of agenda item 5(i). Finally, GRE agreed to refer the proposal to the dedicated working group of GTB (see para. 17).

9. Taking into account the recent GTB study (GRE-71-32), the expert from France proposed to delete a design restrictive requirement for an automatic levelling device for all headlamps with LED light sources, irrespective of their luminous flux (ECE/TRANS/WP.29/GRE/2014/34). GRE agreed that this proposal should be tackled at the next session, in conjunction with the GTB proposals on visibility and glare issues (see para. 14 below).

14. The expert from GTB recalled the outcome of the GTB study on visibility and glare (GRE-71-32) and presented a first draft of amendments to Regulation No. 48 addressing the visibility distance and glare issues (GRE-72-07). This proposal received comments by the expert from Poland (GRE-72-23-Rev.1). Various experts generally agreed that the current requirement for automatic levelling in Regulation No. 48 (2,000 lm luminous flux of the light source) should be replaced by other deciding factors for headlamp glare, such as the vehicle pitch angle, loading conditions and initial headlamp aiming. However, no consensus was reached on exact replacement criteria. The expert from UK suggested that an informal group be established to speed up the finalization of the amendment proposal. The experts from France, Germany, Italy and the Netherlands were of the view that GTB should be tasked to submit a concrete proposal to the next session of GRE. GRE invited GTB, OICA and interested Contracting Parties to organize a meeting with the aim to elaborate a revised proposal. The experts from France, Germany, Italy, Netherlands, Poland and UK expressed their interest in participating in this meeting.

10. GRE agreed to defer discussion on ECE/TRANS/WP.29/2011/99 and Corr.1 to its next session, awaiting the results of a study conducted by GTB.

11. The expert from GTB introduced the results of their studies on visibility and glare (GRE-71-15 and GRE-71-32). The study concentrated on levelling in relation to load and its major objectives were to improve the understanding of different factors that influence visibility and glare and to identify results of the study that might reveal alternatives for automatic static levelling. The expert from OICA recalled their presentations on loading definitions and achievable aiming tolerances (see also GRE-67-27 and GRE-68-20).

12. The expert from Poland introduced a revised proposal ECE/TRANS/WP.29/GRE/2014/11 on initial aiming of dipped-beam headlamps and considering the original 75 +/-25 m visibility distance requirement.

13. GRE was of the view that the study had pointed out that the type of light source and its luminous flux are not the deciding factors in headlamp glare. Instead, the most important factors seem to be the vehicle pitch angle, loading conditions and initial headlamp aim. Therefore, the light source choice (LED) and the light source 2,000 lm criteria in UN Regulation No. 48 were found unnecessarily restrictive and creating barriers to new technologies. Different views were expressed whether automatic levelling should become a requirement for all categories of vehicles and light sources. Operating voltage was also mentioned as an additional factor of glare.

14. GRE invited the experts from Poland, GTB and OICA to submit one coherent proposal for amendments to UN Regulation No. 48 addressing the visibility distance and glare issuto the next GRE session.

13. GRE agreed to defer consideration of ECE/TRANS/WP.29/2011/99 and Corr.1 (referred back by WP.29) at its October 2013 session.

14. GRE reverted to the proposal by the expert from France to delete a design restrictive requirement in Regulation No. 48 for an auto-levelling device for low beam produced by light emitting diodes (LED) light sources (ECE/TRANS/WP.29/GRE/2015/21 and ECE/TRANS/WP.29/GRE/73, para. 20). The secretariat informed GRE about the discussion on this issue at the June 2015 session of WP.29. The World Forum had stressed that Regulations should be technologically neutral and invited GRE to adopt the French proposal and to submit it to WP.29 for consideration (ECE/TRANS/WP.29/1116, paras. 50 and 51).

15. GRE was not in a position to reach a consensus on this matter. The experts from Germany and Japan did not support the French proposal and suggested that it first be referred to the Informal Working Group on Visibility, Glare and Levelling (IWG VGL) and considered in one package with various other proposals. The experts from Belgium, Italy, Finland, France, Spain, EC, CLEPA and OICA supported the French proposal and called for its adoption independently from the IWG VGL activities. The experts from Austria and Poland reserved their positions. Finally, in view of the WP.29 guidance, GRE agreed to adopt the proposal in ECE/TRANS/WP.29/GRE/2015/21 and to submit it to the March 2016 session of WP.29 for a final decision. The Chair was also requested to brief WP.29 on the different views expressed by experts in GRE.

17. The experts from OICA and GTB proposed to introduce new criteria on the automatic levelling of headlamps based on the outcome of the GTB glare and visibility studies (ECE/TRANS/WP.29/GRE/2015/5). The expert from Poland suggested further modifications to this proposal (GRE-73-28). The experts from Germany and Japan proposed to impose automatic levelling in all cases, in order to reduce glare problems for drivers (GRE-73-18). Following an in-depth exchange of views on these three documents, GRE realized that no consensus could be found as long as there was no single proposal.

18. To make progress on this issue and prepare a comprising proposal, GRE decided to establish an Informal Working Group with a draft title “on Visibility, Glare and Levelling” (IWG VGL), for which the experts from Germany and Poland agreed to act as Chair and Secretary, respectively. GRE requested IWG VGL to submit its terms of reference for consideration at the next session of GRE and mandated the Chair to obtain, in June 2015, the consent of WP.29 for the establishment of this IWG.

20. The expert from France proposed to delete a design restrictive requirement in Regulation No. 48 for an auto-levelling device for low beam produced by any LED light sources, while for other light sources this requirement exists only if their reference luminous flux exceeds 2,000 Lm (ECE/TRANS/WP.29/GRE/2015/21 and GRE-73-25). According to the expert, should LED be treated in the same way as other lights sources, this would lead to more LED headlamps fitted on new vehicles, thus improving road safety and reducing CO2 emissions. The experts from Belgium, Germany, Japan and UK were of the view that this issue should be first referred to IWG VGL and be considered in one package with other proposals regarding levelling (see paras. 17 and 18 above), upon the understanding that a final solution developed by IWG VGL should be technology neutral. The experts from Italy, Spain, EC, CLEPA and OICA not only supported the French proposal as removing discrimination between various technologies of light sources, but also called for its adoption without delay, irrespective of the IWG activities. GRE agreed that the Chair would submit this issue to the June 2015 session of WP.29 for guidance and to report back to GRE at its next session.

50. The representative of France proposed to delete a design restrictive requirement in Regulation No. 48 for auto-levelling of headlamps equipped with any Light Emitting Diodes (LED) light sources (ECE/TRANS/WP.29/GRE/2015/21, ECE/TRANS/WP.29/GRE/73 and WP.29-166-23). The representative explained that, if LED were treated the same way as other lights sources, more LED headlamps would be fitted on new vehicles, and thus improving road safety and reducing CO2 emissions. WP.29 noted that recent studies indicate that the type of light source does not seem to be a major factor of headlamp glare, and that GRE had established an IWG to review all levelling requirements in Regulation No. 48 (para. 25 above). The EU representative stressed that also for this subject OLA should be involved to provide their analysis and preferred option.

51. WP.29 stressed that, in line with the text and spirit of the 1958 Agreement, Regulations should be technologically neutral and performance based. Therefore, WP.29 advocated the French proposal and invited GRE to adopt it and to submit it to WP.29 for consideration. WP.29 also pointed out the importance of the newly established IWG for finding a general solution for glare and visibility issues. WP.29 also instructed IWG and GRE to verify, as a matter of priority, that LED headlamps do not produce more glare compared to other light sources, to review all levelling requirements and to report back to WP.29.

55. Under agenda item 4.6.5 (UN Regulation No. 48), the World Forum agreed to defer consideration of document ECE/TRANS/WP.29/2011/99 and Corr.1 to its June 2012 session, subject to a final review by GRE at its March 2012 session.