17. The expert from GTB presented revised amendments to Regulation No. 128 and to R.E.5 which introduced requirements, test specifications and new categories for light emitting diode (LED) substitute light sources (ECE/TRANS/WP.29/GRE/2017/17, ECE/TRANS/WP.29/GRE/2017/21). The proposals also included collective amendments to Regulations Nos. 48, 53, 74, 86 (ECE/TRANS/WP.29/GRE/2017/22 and GRE-78-02). The experts from Italy and OICA submitted written comments on the proposals (GRE-78-33 and GRE-78-28).

18. GRE noted that, compared to the original GTB proposals that had been considered at the previous session, the revised proposals contained safeguards against the possible misuse of LED substitutes as retrofits in lamps and/or vehicles that were not type approved for using such light sources. A number of experts were of the view that the proposed measures, such as consumer warning on packaging and a website with a list of compatible vehicle models, were not sufficient and reiterated their concerns as raised at the previous session. The expert of OICA pointed out that, to avoid any responsibility for misusing LED substitutes when installing on old vehicle types, the vehicle manufacturers would have be burdened to extend type approvals pursuant to the earlier series of amendments to Regulation No. 48 (GRE-78-28). GRE acknowledged the problem and noted that the failure detection provisions in Regulation No. 48 should be revised. Some experts advocated the idea of physical keying of LED caps to prevent installing unauthorized substitutes.

19. GRE noted that the discussion addressed two different, but interrelated issues: (a) allowing LED substitutes for new type approvals, as part of Original Equipment Manufacturer (OEM) and Original Equipment Supplier (OES), and (b) using LED as retrofits on old vehicle types. Some experts were of the view that the two cannot be separated from one another. To make progress, GRE agreed to establish a task force. The expert from Germany stated that another expert from his country would act as Chair of the task force, while the expert from UK provisionally agreed to become Co-Chair. The expert from IEC volunteered to provide secretarial support.

12. The expert from GTB presented proposals for amendments to Regulation No. 128 and to the Consolidated Resolution (R.E.5) which introduce requirements and test specifications for light emitting diode (LED) substitute light sources as well as several new LED substitute light source categories (ECE/TRANS/WP.29/GRE/2017/2, ECE/TRANS/WP.29/GRE/2017/3, GRE-77-02, GRE-77-03, GRE-77-15, GRE-77-22). These proposals were accompanied by collective amendments to Regulations Nos. 48, 53, 74, 86 with the requirements for LED substitute light sources (ECE/TRANS/WP.29/GRE/2017/4). The expert from GTB explained that the proposed approach was based on the following principles:

• Lamps may be approved with a filament light source and its corresponding LED substitute light source, when fitting in the same holder, and providing an equivalent photometric performance;
• Lamps equipped with LED substitute light sources should be tested with both the filament lamp and the LED substitute light source.

14. The expert of Germany commented on the GTB proposals (GRE-77-29). GRE generally advocated the idea of allowing for LED substitute lights sources, given their high energy efficiency. At the same time, the experts from France, Germany, Netherlands, Spain and UK pointed out the risks associated with the improper use of aftermarket LED products in lamps, which were not approved for such light sources, and called for developing a set of preventive measures, including raising public awareness and giving warnings to consumers. Several technical issues were also questioned, in particular, the proposed G-marking for LEDs with a correlated colour temperature below 3,000 K. GRE invited GTB to address the comments received and agreed to continue the consideration of this issue at the next session on the basis of revised documents to be prepared by GTB.

53. GRE took note of a status report of the GTB Working Group on Light Sources (GRE-73-24), including the outcome of the GTB LED retrofit feasibility study. Some LED retrofit samples were showcased to demonstrate the equivalence criteria.

50. The experts from GTB presented status reports of the GTB Working Group activities (GRE-72-27, GRE-72-28, GRE-72-29, GRE-72-30). Concerning the GTB activities to improve the situation with non-approved LED retrofit light sources used as replacement parts for filament light source, the experts from France and Italy were of the view that such replacement should be prohibited on safety concerns.

55. The expert from GTB reported on the progress made on the subject of LED retrofit.