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Comments on GRE/2017/9, GRE/2017/13 and GRE-77-32
Document GRE-78-26
18 October 2017
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Previous Documents, Discussions, and Outcomes
4. | Simplification of lighting and light-signalling Regulations

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-78-34) in preparing the three new simplified UN Regulations on Light-Signalling Devices (LSD), Road Illumination Devices (RID) and Retro-Reflective Devices (RRD). He presented a draft LSD Regulation (ECE/TRANS/WP.29/GRE/2017/9), amendments to Regulations Nos. 48, 53, 74 and 86 that group the definitions and introduce references to the new simplified Regulations (ECE/TRANS/WP.29/GRE/2017/10, ECE/TRANS/WP.29/GRE/2017/11, GRE-78-11, GRE-78-12, GRE-78-13, GRE-78-14, GRE-78-15 and GRE-78-20), and the new transitional provisions to Regulations Nos. 3, 4, 6, 7, 19, 23, 27, 38, 50, 69, 70, 77, 87, 91, 98, 104, 112, 113, 119 and 123 (ECE/TRANS/WP.29/GRE/2017/13). The expert from India commented on the IWG SLR proposals (GRE-78-26).

8. GRE agreed that the new UN Regulations and the necessary amendments to the existing Regulations should be adopted as a package, possibly at the next session. GRE was of the view that all definitions should be moved to one place and that Regulation No. 48 would be the best choice for that purpose, in spite of the fact that not all Contracting Parties to the 1958 Agreement applied this Regulation. GRE also agreed, in principle, that the transitional period to start the application of the new UN Regulations should be twenty-four months, as proposed by IWG SLR in the draft transitional provisions. GRE decided to revert to this issue once the timeline for the entry into force of the new UN Regulations was known, and which depends on IWG SLR progress.

9. The expert from Germany drew the attention of GRE to the non-availability of the electronic database for the exchange of type approval documentation (DETA) and the Unique Identifier (UI) at the time of the entry into force of the new UN Regulations (GRE-78-27). This might create difficulties for applying approval markings and would make the full benefits of SLR impossible to reap. GRE agreed that the new UN Regulations should include a substitute solution of quasi-traditional approval markings pending the availability of UI.

10. On behalf of IWG SLR, the expert of GTB presented a new concept of “change index” which aims to adapt and simplify the traditional approval markings in the context of the new LSD Regulation (GRE-78-35 and Rev.1). In particular, he proposed a table that lists all devices covered by the LSD Regulation and indicates the series of amendments with the most stringent requirements for each device. Following an in-depth discussion, GRE felt that having in the approval marking both series of amendments and a change index would be superfluous. A number of experts spoke in favour of indicating the series of amendments only, preceded by the Regulation number. The expert from UK pointed out the need to study how the proposed solution would work for extension of type approvals. The Chair requested IWG SLR to address this issue and invited the expert from UK to contribute.

11. GRE requested IWG SLR to consult the European Committee of Associations of Manufacturers of Agricultural Machinery (CEMA) about the draft amendments to Regulation No. 86. GRE also noted that IWG SLR would consult the IWG on the International Whole Vehicle Type Approval (IWVTA) about the approval markings for the new LSD Regulation.

4. | Simplification of lighting and light-signalling Regulations

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.

Related and Previous Documents
GRE/2017/9
GRE/2017/13
GRE-77-32
Relates to UN R148 |