GAR | GRE-77-22

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Document Title	Introduction into Regulation 128 of LED Substitute Light Sources
Reference Number	GRE-77-22
Date	3 Apr 2017
Source(s)	GTB
Rulemaking Area(s)	RE5: Light-source specifications and UN R128 LED Light Sources
Meeting(s)	GRE \| Session 77 \| 4-7 Apr 2017 5. Regulations Nos. 37, 99, 128 and RE5
Related Documents
	GRE/2017/2		Proposal for Supplement 7 to the original version of Regulation No. 128 (superseded)
	GRE/2017/3		Proposal for amendments to the original version of the Consolidated Resolution on the common specification of light source categories (superseded)
	GRE/2017/4		Proposal for a collective amendment to Regulations Nos. 48, 53, 74, and 86 (superseded)
	GRE-77-02		Equivalence criteria for LED substitute light source categories as equivalents for corresponding filament light source categories
	GRE-77-03		Substitute light sources: equivalence reports for C5W, PY21W, and R5W
	GRE-77-07		Request for guidance concerning proposals for road llumination devices, lighti-signalling devices, and COP for adaptive front lighting
	GRE-77-15		Proposal to introduce requirements for the use of LED substitute light sources in the new Regulation for “Light-signalling devices” (superseded)
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Excerpts from session reports related to this document
GRE \| Session 77 \| 4-7 Apr 2017			7. On behalf of the Informal Working Group ‘Simplification of the Lighting and Light-Signalling Regulations’ (IWG SLR), the expert from GTB reported on the progress and schedule of IWG SLR (GRE-77-32). GRE noted that the three new draft Regulations on Light-Signalling Devices (LSD), Road Illumination Devices (RID) and Retro-Reflective Devices (RRD) would be officially submitted to the next session of GRE. The expert of EC urged GRE experts to study these comprehensive documents and to provide their comments and contributions to IWG SLR without delay, so as to have a smooth adoption of the draft Regulations at the next session. 8. GRE took note of a first draft LSD Regulation prepared by IWG SLR (GRE-77-05). GRE commended IWG SLR on the quality of this document and delivered some preliminary remarks on its content. In particular, GRE requested additional explanations on how the amendment process, including new series of amendments and approval markings, would work for the new LSD Regulation which covers many different devices. 9. GTB invited GRE to provide guidance on how to treat the GTB proposals submitted to the previous session of GRE and deferred to the present session for final decision, in the context of drafting the three new Regulations (GRE-77-07). These proposals included the introduction of light emitting diode (LED) substitute light sources in the LSD Regulation (see para. 13 below), introduction of LED light sources in the RID Regulation (para. 15 below) and simplification of the conformity of production (CoP) requirements for adaptive front-lighting systems (AFS) (para. 28 below). GRE agreed to introduce the proposals, if adopted, into the drafts of the new RID and LSD Regulations so that the whole package would be formally submitted to the next session of GRE. 10. The expert from GTB briefly presented his views on Stage 2 of the SLR process and pointed out that it would provide a unique opportunity for China to harmonize their ongoing national simplification process with the SLR requirements. 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. 13. GRE also noted the proposal by GTB to introduce requirements for the use of LED substitute light sources in the new LSD Regulation (GRE-77-15). 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. 28. GRE reverted to a proposal by the expert from GTB which aligns the conformity of production procedures with the other headlamp Regulations and which simplifies the test methods and requirements relating to conformity of production (ECE/TRANS/WP.29/GRE/2016/28, GRE-77-07). GRE agreed with the proposal and decided to forward it to IWG SLR for inclusion into the new RID Regulation (see paras. 7 and 9 above).