VGL-01-02/2
Poland comments on the draft VGL informal group terms of reference
UNECE server
Excerpts from session reports
GRE | Session 66 | 4-6 Oct 2011

10. The expert from Poland presented GRE-66-17 superseding ECE/TRANS/WP.29/GRE/2011/32, taking into consideration real visibility distance and glaring according to headlamp Regulations. GRE noted a number of comments and agreed to consider again, at its next session, GRE-66-17 with an official symbol or a revised proposal by the expert from Poland.

11. The expert from Canada introduced ECE/TRANS/WP.29/GRE/2011/63 clarifying the conditions for simultaneous illumination of marking lamps and daytime running lamps. GRE adopted ECE/TRANS/WP.29/GRE/2011/63, not amended, and requested the secretariat to submit the proposal to WP.29 and to AC.1 at their November 2011 sessions, as part of draft Supplement 2 to the 05 series of Regulation No. 48 (see also para. 22).

GRE | Session 67 | 26-29 Mar 2012

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:


“6.4.5.2.… longitudinal plane of the vehicle. The vertical aim of the two optional
devices may be directed downwards.”

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.

GRE | Session 68 | 16-18 Oct 2012

9. The Expert from Poland introduced ECE/TRANS/WP.29/GRE/2012/27 proposing to remove the present 2000 lm borderline and the Light Emitting Diodes (LED) automatic levelling requirement. The proposal received several comments (GRE-68-20, GRE-68-31, GRE-68-32 and GRE-68-34).

10. GRE agreed with the suggestion of the expert from the Netherlands to concentrate requirements only on the “initial aiming” (and leave out the other parts on labelling, photometrics, etc.). It was also suggested that the proposal would focus on possible overlaps to the headlamp mounting height and would consider this “new approach” for the initial aiming requirements as an alternative to the existing (“old approach”) requirements in UN Regulation No. 48. GRE agreed to resume consideration of this subject at its next session on the basis of a revised proposal tabled by the expert from Poland including the suggestions mentioned above.

11. GRE noted that the World Forum (WP.29) referred back ECE/TRANS/WP.29/2011/99 and Corr. 1 for further consideration. GRE agreed to resume consideration of this subject at its April 2013 session. The expert from GTB introduced GRE-68-38, GRE-68-39 and GRE-68-40 providing a status report of the GTB’s activities on Glare and Visibility

GRE | Session 69 | 8-11 Apr 2013

12. The expert from Poland introduced ECE/TRANS/WP.29/GRE/2013/15 proposing an alternative to the existing initial aiming provisions. The experts from France and the United Kingdom requested the author to clarify the aspect linked to the measurements and to specify the measurement method as well as the tools to be used. The expert from the Netherlands supported, in general, the proposal but questioned waiving automatic levelling as an incentive to use this alternative method. GRE agreed to resume consideration on this matter at its October 2013 session on the basis of an updated proposal prepared by the expert from Poland in collaboration with experts from France, the Netherlands and the United Kingdom.

GRE | Session 70 | 21-23 Oct 2013

12. The expert from Poland presented GRE-70-41, introducing ECE/TRANS/WP.29/GRE/2013/57 and proposing performance based requirements on initial aiming of dipped-beam headlamps as an alternative to the existing requirements. The proposal received some comments (GRE-70-42). The expert from France requested adding proper tolerances from the Conformity of Production provisions. GRE agreed to revisit this subject (on initial aiming and considering the original 50 m visibility distance requirement) at its next session on the basis of a revised document, which the expert from Poland volunteered to prepare.

GRE | Session 71 | 31 Mar-3 Apr 2014

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.

GRE | Session 73 | 13-17 Apr 2015

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.