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Proposal for a collective amendment to Regulations Nos. 48, 53, 74 and 86
Document TFSR-03-05
13 March 2018

Proposal under development by the Task Force on Substitutes/Retrofits (TF S/R) to introduce requirements for light emitting diode (LED) substitute light sources into Regulations Nos. 48, 53, 74 and 86.

Status: Superseded
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Previous Documents, Discussions, and Outcomes
4. | Simplification of lighting and light-signalling Regulations

8. On behalf of the Informal Working Group on Simplification of the Lighting and Light-Signalling Regulations (IWG SLR), the expert from GTB reported on the finalization of stage 1 of SLR (GRE-79-28). He further provided a draft schedule for stage 2 which would include two steps. Step 1 would cover objectives which could be achieved by the end of 2019, such as introducing technology neutral and performance based requirements, as well as objectively testable provisions. Step 2 would start in 2020 with the aim to simplify the installation Regulations Nos. 48, 53, 74 and 86. As an additional task, he suggested harmonization with the applicable standards in China. GRE experts also proposed other issues for stage 2 of SLR.

9. The expert from GTB presented the full package of amendment proposals drafted by IWG SLR under stage 1 of SLR:

a) The three new simplified UN Regulations on Light-Signalling Devices (LSD), Road Illumination Devices (RID) and Retro-Reflective Devices (RRD) (ECE/TRANS/WP.29/GRE/2018/2, ECE/TRANS/WP.29/GRE/2018/3, ECE/TRANS/WP.29/GRE/2018/4, GRE-79-10 and GRE-79-14);

b) Draft 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/2018/6, ECE/TRANS/WP.29/GRE/2018/7, ECE/TRANS/WP.29/GRE/2018/8, ECE/TRANS/WP.29/GRE/2018/9, ECE/TRANS/WP.29/GRE/2018/10, ECE/TRANS/WP.29/GRE/2018/12, ECE/TRANS/WP.29/GRE/2018/13, ECE/TRANS/WP.29/GRE/2018/14, ECE/TRANS/WP.29/GRE/2018/15, ECE/TRANS/WP.29/GRE/2018/17, ECE/TRANS/WP.29/GRE/2018/30, GRE-79-08, GRE-79-09 and GRE-79-13);

c) Transitional provisions to “freeze” 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/2018/11).

10. The expert from EC was not in a position to support the indefinite validity of type approvals granted under the frozen Regulations, as proposed in ECE/TRANS/WP.29/GRE/2018/11, because of the General Safety Regulation of the European Union. He proposed revised transitional provisions for these Regulations (GRE-79-31, part I), together with new transitional provisions for the installation Regulations Nos. 48, 53, 74 and 86 (GRE-79-31, part II). While several experts agreed in principle with part I, they were not in a position to support part II. The experts from Finland and UK made study reservations. The expert from OICA expressed the concern that the revised transitional provisions might be rejected by WP.29.

11. To not delay the submission of the whole package of amendment proposals that had been developed in stage 1 of SLR, GRE decided to provisionally adopt the transitional provisions in ECE/TRANS/WP.29/GRE/2018/11, but to put in square brackets the third transitional provision for each Regulation mentioned in the document. At the same time, GRE recognized the urgency of the issue raised by the expert from EC and requested all GRE experts, as well as IWG SLR, to carefully consider the EC proposals with a view to taking a final position at the next session.

12. The expert from IWG SLR proposed correcting minor errors and inconsistencies identified in the documents mentioned under para. 9 (a) above (GRE-79-14). GRE adopted these corrections, as laid down in Annex II.

13. The expert from IWG SLR also suggested rectifying minor errors and inconsistencies in the documents listed in para. 9 (b) above (GRE-79-13). GRE adopted these corrections, as laid down in Annex III, and decided to opt for the alternative wording (in square brackets) of paragraph 6.3.9. of different series of amendments to Regulation No. 48.

14. The expert from India suggested corrections to ECE/TRANS/WP.29/GRE/2018/2 and ECE/TRANS/WP.29/GRE/2018/3 (GRE-79-17-Rev.1 and GRE-79-18-Rev.1 new text). GRE adopted the corrections, as laid down in Annexes IV and V. The expert from India withdrew GRE-79-19, in order to first present it at the next session of IWG SLR.

15. The expert from IWG SLR recalled that all identical definitions should only be kept in Regulation No. 48. Thus, he proposed to review the definitions in Regulations Nos. 53 and 74 (GRE-79-08 and GRE-79-09, respectively). GRE adopted these modifications, as contained in Annex VI.

16. The expert from IWG SLR presented the concept of “change index” developed for the LSD, RID and RRD Regulations (GRE-79-12-Rev.1). He further introduced amendment proposals on the change index to Regulations Nos. 48, 53, 74 and 86 (ECE/TRANS/WP.29/GRE/2018/16, ECE/TRANS/WP.29/GRE/2018/18 and GRE-79-11). GRE adopted these proposals, as amended by Annex VII). In addition, GRE agreed to include transitional provisions on the change index in the text of the LSD, RID and RRD Regulations (GRE-79-10 and Annex VIII). The expert from India pointed out that he would refer GRE-79-22 to IWG SLR.

17. Subject to the modifications mentioned in paras. 10–16 above, GRE adopted the package of amendment proposals drafted by IWG SLR and listed in para. 9 a) – c). The secretariat was requested to submit the amendments proposals to WP.29 and to the Administrative Committee of the 1958 Agreement (AC.1) for consideration and vote at their November 2018 sessions. GRE noted that any modification of the transitional provisions, mentioned in para. 11 above, that GRE might agree upon at the next GRE session in October 2018, would be submitted to the November 2018 session of WP.29 as corrigenda to the basic SLR package which otherwise would be issued in August 2018.

18. The expert of SAE proposed to keep Regulations Nos. 98, 112, 113 and 123 “alive” for the purpose of the recently updated Canadian Federal Motor Vehicle Safety Standard (CMVSS) No. 108 (GRE-79-32-Rev.1). GRE referred this document to IWG SLR for consideration.

7. (c) | Other Regulations: Regulation No. 53
7. (d) | Other Regulations: Regulation No. 74
5. | Regulations Nos. 37, 99, 128 and RE5 (light-source specifications)

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.

6. (a) | Regulation No. 48: Proposals for amendments to the 05 and 06 series of amendments
5. | Regulations Nos. 37, 99, 128 and RE5

12. The expert from GTB presented proposals for amendments to Regulation No. 128 and to the Consolidated Resolution (R.E.5) which introduce requirements and test specifications for light emitting diode (LED) substitute light sources as well as several new LED substitute light source categories (ECE/TRANS/WP.29/GRE/2017/2, ECE/TRANS/WP.29/GRE/2017/3, GRE-77-02, GRE-77-03, GRE-77-15, GRE-77-22). These proposals were accompanied by collective amendments to Regulations Nos. 48, 53, 74, 86 with the requirements for LED substitute light sources (ECE/TRANS/WP.29/GRE/2017/4). The expert from GTB explained that the proposed approach was based on the following principles:

  • Lamps may be approved with a filament light source and its corresponding LED substitute light source, when fitting in the same holder, and providing an equivalent photometric performance;
  • Lamps equipped with LED substitute light sources should be tested with both the filament lamp and the LED substitute light source.

Related and Previous Documents
GRE/2017/4
GRE/2017/22
GRE-78-02
GRE-78-28
GRE-78-33
GRE/2018/6
GRE/2018/13
GRE/2018/12
GRE/2018/18
Relates to UN R48 | UN R53 | UN R74 | UN R86 |