Comments on GRE/2017/9, GRE/2017/13 and GRE-77-32
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Reference Number: GRE-78-26
Date: 18 October 2017
Related Documents:
GRE-77-32 | Status update and next steps of the Simplification of Lighting Regulations informal group
GRE/2017/9 | Draft new Regulation on uniform provisions concerning the approval of light-signalling devices
GRE/2017/13 | Collective amendments to Regulations Nos. 3, 4, 6, 7, 19, 23, 27, 38, 50, 69, 70, 77, 87, 91, 98, 104, 112, 113, 119 and 123
Discussion(s):
Working Party on Lighting and Light-signalling | Session 78 | 24-27 Oct 2017

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.