Document GRE-78-03
Evocative, suggestive or figurative apparent surfaces

Request for guidance regarding interpretation of UN lighting rules:

  1. Is it allowed that the shape of the apparent surface can be the logo of the manufacturer brand or other brand-identifying figures?
  2. Is it allowed that the shape of the apparent surface can be the same as an evocative/suggestive figure? Even as an informative figure such as road traffic
  3. Is the advertising lighting allowed at the national level in the Contracting parties, regarding to its influence on road safety and distraction?
  4. Do we have to consider an apparent surface, whose shape is the logo of a brand manufacturer or other brand-identifying figures, as a advertising lighting?

Submitted by France and Germany
Discussions and Outcomes

24. The experts from France and Germany introduced a revised proposal for amendments to UN Regulations Nos. 48 and 148 that regulates the use of manufacturer logos inside the illuminant surface of a lamp (ECE/TRANS/WP.29/GRE/2020/5 and GRE-83-50). The experts from the Russian Federation and OICA commented on the proposal (GRE-83-36 and GRE-83-46). Taking into account concerns expressed by the experts from EC and the Russian Federation, GRE invited the authors to liaise with those experts and to prepare an updated text for the next session. In the interim, GRE reiterated its request to type approval authorities to refrain from granting type approvals to lamps with such logos.


11. The experts from France and Germany proposed introducing conditions for the use of logos inside the illuminating surface of a signalling lamp in the UN LSD Regulation and UN Regulation No. 48 (ECE/TRANS/WP.29/GRE/2019/6). Various experts commented and posed questions on the proposal. GRE noted that a clear definition of “logo” would be needed and that technological neutrality should be ensured. The expert from EC was of the view that the underlying issue did not have bearing on road safety and, thus, should not be discussed by GRE. The proponents agreed to revise the proposal in accordance with the comments received. The expert of OICA offered its assistance.

47. The experts of France and Germany initiated a discussion on how to treat lamps with apparent surfaces in the form of a company logo or other brand-identifying figures (GRE-78-03). The experts from Finland, France, Italy Netherlands, Poland, Spain and UK reported on their national experiences on the subject. GRE noted that, in many countries, specific illuminated advertisement on vehicles was prohibited. However, no clear restrictions existed for lamps which otherwise met the requirements of lighting and light-signalling Regulations, and particularly of Regulation No. 48. GRE was also informed about optional additional lamps that were allowed in some countries for the purposes of road safety, for example, additional direction indicators for trucks in the form of a cyclist. The experts from France and Germany pointed out that they would distribute a questionnaire to GRE experts to solicit detailed information on relevant national practices. In addition, the expert from the Netherlands suggested establishing a task force. GRE agreed to revert to this issue at the next session, based on the outcome of the survey.

39. Due to a lack of time, GRE was not in a position to consider GRE-78-03.