Explanation of changes between the proposal to introduce requirements for light emitting diode (LED) substitute light sources into Regulations Nos. 48, 53, 74 and 86 presented at GRE-77E/2017/4) and the revised proposal (GRE/2017/22) submitted for consideration at GRE-78.
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.