Document GRE-80-28
Evaluation of the questionnaire on evocative, suggestive or figurative apparent surfaces
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.

37. The experts of France and Germany presented the preliminary results of their questionnaire on national treatment of evocative, suggestive or figurative apparent surfaces (GRE-80-28). GRE noted that the reported results seemed to indicate the need to harmonize national regulations on the issue. GRE decided to continue this discussion at the next session, based on a more detailed document to be prepared by the experts from France and Germany.