GAR | GRE/2018/42

GRE/2018/42

LSD: Proposal to introduce requirements for the use of LED substitute light sources

Source(s)

Date

9 Aug 2018

Status

Superseded

Subject

UN R148 Light-Signalling Devices

Meeting(s)

GRE | Session 80 | 23-26 Oct 2018

Agenda item 4. Simplification of lighting and light-signalling UN Regulations

Agenda item 5. UN Regulations Nos. 37 (Filament lamps), 99 (Gas discharge light sources), 128 (Light emitting diodes light sources) and the Consolidated Resolution on the common specification of light source categories)

Proposal to introduce the following changes into the draft new Regulation on light-signalling devices:

Use of LED substitute light source(s) is allowed and does not constitute a change of the lamp type. However, lamp performances shall be tested during type approval also with the LED substitute light source. Approval of the lamp using filament light source(s) is a prerequisite for approval of the lamp using LED substitute light source(s).
Testing with LED substitute light sources is exempted from conformity of production control.
The technical description shall include notice that the lamp also has to be approved with the LED substitute light source(s) according to UN R128 if the applicant has so determined.
The approval marking or the Unique Identifier as well as the category or categories of LED substitute light source(s) prescribed, if any, shall be visible.
The indication of both the holder of the filament light source and of its LED counterpart light source, if any, shall be explicitly provided.

Downloads

UNECE server

Related documents

Excerpts from session reports

GRE | Session 79 | 24-27 Apr 2018

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.

20. On behalf of the Task Force on LED retrofits and substitutes (TF SR), the expert from Germany presented their status report (GRE-79-16). GRE supported the proposed two-step approach and mechanical interlock as a solution to avoid misuse of light emitting diode (LED) substitutes.

21. GRE recalled the earlier proposals by GTB to introduce LED substitutes and replaceable light sources into the new LSD and RID Regulations (ECE/TRANS/WP.29/GRE/2017/14, ECE/TRANS/WP.29/GRE/2017/15 and GRE-78-04) and noted that ECE/TRANS/WP.29/GRE/2017/15 had been incorporated in ECE/TRANS/WP.29/GRE/2018/3. GRE invited TF SR to update ECE/TRANS/WP.29/GRE/2017/14 and GRE-78-04.

22. The expert from GTB pointed out that the GTB guidelines for introducing and evaluating LED light source categories that were intended for forward lighting applications (GRE-77-04) should be published as a reference document on the GRE website. GRE agreed to this request.

GRE | Session 77 | 4-7 Apr 2017

13. GRE also noted the proposal by GTB to introduce requirements for the use of LED substitute light sources in the new LSD Regulation (GRE-77-15).

GRE | Session 78 | 24-27 Oct 2017

14. Pending the outcome of the discussion on light emitting diode (LED) substitute light sources (see agenda item 5, paras. 17-19), GRE agreed to postpone consideration of ECE/TRANS/WP.29/GRE/2017/14, ECE/TRANS/WP.29/GRE/2017/15 and GRE-78-04.

GRE | Session 80 | 23-26 Oct 2018

20. GRE also considered a parallel proposal by TF SR which introduced requirements for the use of LED substitute light sources in the new LSD UN Regulation (ECE/TRANS/WP.29/GRE/2018/42). GRE adopted the proposal, as amended by Annex III, and requested the secretariat to submit them to WP.29 and AC.1 for consideration at their June 2019 sessions.

21. The expert of SAE delivered a presentation on standardization of technical requirements for forward lighting LED replacement light sources (GRE-80-34) and offered to organize a live demonstration at the next session of GRE. The expert from FIA highlighted the advantages of using LED retrofits for front lighting application of vehicles in use and argued in favour of developing regulations in this area (GRE-80-33). He suggested that TF SR should prepare proposals. In this regard, some GRE experts expressed doubts whether this issue could be solved by UN Regulations and felt that it should be treated within national law. Those experts were also of the view that TF SR should finalize LED substitutes for front-lighting applications and then stop its activities without addressing LED retrofits. GRE decided to revert to this discussion at the next session and requested TF SR to continue its work in the interim.

GRE | Session 82 | 22-25 Oct 2019

24. GRE recalled that, for UN Regulation No. [148], the new provisions on substitute light sources had already been submitted to the November 2019 sessions of WP.29 and AC.1 as part of draft Supplement 1 to the original series (ECE/TRANS/WP.29/2019/81). Following the same approach, GRE agreed that these provisions should be removed from the original series of UN Regulation No. [148], once the 01 series of amendments is established.

WP.29 | Session 179 | 12-14 Nov 2019

69. The World Forum considered the draft amendments under agenda items 4.6.1 to 4.6.15 and recommended their submission to AC.1 for voting, subject to the following modifications:

Item 4.6.3, document ECE/TRANS/WP.29/2019/81, last page, Table A2-1, line “Rear position pair (MR)”, replace “15°/15°” with “15°/10°”.
Item 4.6.5, document ECE/TRANS/WP.29/2019/125, amend the title to read “Supplement 1 to the original series of UN Regulation No. [149] on Road Illumination Devices (RID)”.