OICA/CLEPA comments on the proposal to restrict manual deactivation of AEB systems to speeds under 30 km/h, noting cases where, given the current state of the technology, manual deactivation (regardless of speed) is warranted.

OICA counter-proposal to address the German concern over manual deactivations of AEB systems. The original document (GRRF/2017/24) proposed automatic reactivation of the AEBS when the vehicle speed exceeds 30 km/h. OICA proposes reactivation after 15 minutes of continuous operation at a speed above 70 km/h.

Germany proposed, in document GRRF/2017/24, to require automatic reactivation of a manually deactivated automatic braking system. One concern with the proposal invoked the need for prolonged deactivation under certain circumstances, such as when a vehicle is fitted temporarily with a snow plow. This proposal would explicitly require AEBS to be capable of detecting a blocked sensor (already implicit in the regulation) such that AEBS would not reactivate in such cases.