Discussion paper concerning the transposition of GTR 15 into a UN Regulation. The paper raises two possible routes: 1) a UN Regulation identical to EU legislation but that would not be not applied (in its entirety as a distinct rule) outside the EU; 2) a “hierarchical” UN Regulation that combines all elements of all emissions thresholds at their most stringent level with lower levels of approval corresponding to regional/national requirements. The EC proposes option 2 as this would allow for a global rule where Contracting Parties could certify systems to standards outside their markets (e.g., Japan could issue approvals to EU standards and vice versa) under the UN Regulation.
44. The representative of the EU presented WP.29-167-20 detailing the following two possible routes for transposing the UN GTR on WLTP into a UN Regulation:
(a) UN Regulation on WLTP would fully reflect EU legislation, whereas non-EU Contracting Parties would need to draft their own national legislation. In this case, the UN Regulation would be drafted so that individual parts of it could be easily referred to in national legislation;
(b) With the second proposed route, a UN Regulation on WLTP would be developed in a hierarchical manner with different levels of stringency. The top level would correspond to the most stringent combination of regional requirements, whereas the levels below would correspond to a specific national or regional legislation in terms of emission limits and region-specific technical and administrative requirements. Non-EU Contracting Parties, such as Japan, having so far different emission legislation could apply the UN Regulation on WLTP. In this case, each Contracting Party applying the UN Regulation on WLTP would only have to accept type approval according to the top level but could also accept those corresponding to its own national or regional level of stringency. The Contracting Parties could issue type approval according to all levels.
45. The representative of the EU highlighted the advantages and drawbacks of each possible route. He expressed the preference of EU for the second option, since it could foster global harmonization at the mid- and long-term and would probably allow the inclusion of the UN Regulation on WLTP into the International Whole Vehicle Type Approval (IWVTA). He sought the view and opinion of WP.29 on the two routes.
46. The representatives of Japan and Switzerland expressed their support for the second route, as it was the best one towards global harmonization despite of its complexity. The representative of OICA also agreed in principle, taking into account the apparent compatibility of route two with IWVTA.
47. WP.29 agreed to transpose the WLTP UN GTR into a UN Regulation according to the second route proposed by the representative of the EU.
48. The representative of Germany, Chair of GRPE, confirmed that GRPE would start work according to the second route at its January 2016 session.
49. The expert from OICA, however, informed WP.29 of the challenges related to route two, given the fact that experts had difficulties in determining worst-case scenarios due to the modular concept of WLTP. The EC representative replied that a hierarchy would only exist between the top level and the regional level alternatives. It was not the intention of route two to introduce hierarchy of testing or of test limits between the regional alternatives. The Chair of GRPE confirmed the complexity of the new UN Regulation following route two. Therefore, GRPE needs to start the work on the transposition of WLTP into a UN Regulation with consideration for the scope and structure.
50. The representative of OICA pointed out that, according to the IWVTA concept, only the highest level of stringency, covering all other levels, would be applicable for universal international whole vehicle type approvals once the new UN Regulation on WLTP is established and included in Annex 4 to UN Regulation No. 0. He, therefore, suggested that this matter needed very careful consideration in order to ensure that the highest level remained feasible in view of the IWVTA development.