Proposal for Supplement 7 to the original version of Regulation No. 128
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Proposal to introduce requirements and test specifications for light emitting diodes (LED) substitute light sources, including to

  1. introduce provisions for LED substitute light sources into Regulation No. 128;
  2. introduce new category sheets C5W/LED, PY21W/LED and R5W/LED based on LED technology into the Consolidated Resolution (R.E.5);
  3. establish equivalence criteria as guidance for specifying sheets for LED substitute light source categories. (These guidelines are intended for publication, with the agreement of GRE, on the GRE website under “reference documents”, similar to criteria for new filament light sources for head lighting (GRE-77-04). In addition, these criteria are being prepared for insertion in publication IEC 60810.);
  4. introduce equivalence reports for the new categories C5W/LED, PY21W/LED and R5W/LED in LED technology (see GRE-77-02).

Reference Number: GRE/2017/21
Origin: GTB
Date: 7 August 2017
Proposal Status: Superseded
Related Documents:
GRE-77-29 | Comments from Germany on GRE/2017/2 (Proposal for Supplement 7 to the original version of Regulation No. 128)
GRE/2017/2 | Proposal for Supplement 7 to the original version of Regulation No. 128
GRE/2018/39 | UN R128: Proposal for Supplement [9]
TFSR-01-03 | UN R128: Revised GRE/2017/21 regarding subsitute light sources
TFSR-03-02/Rev.1 | UN R128: Revised draft Supplement 8
Discussion(s):
Working Party on Lighting and Light-signalling | Session 78 | 24-27 Oct 2017

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.