UN R48 and R148: Comments on document GRE/2019/22
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Japan basically agrees with the proposal made by Germany but considers that certain points need clarification.

Reference Number: GRE-82-38
Origin: Japan
Date: 18 October 2019
Related Documents:
GRE-81-17 | LSD (UN R148): Japan comments on document GRE/2019/7
GRE/2019/22 | Proposal for Supplements to the new UN Regulation No. [148] and to the 06 and [07] series of amendments to UN Regulation No. 48
Working Party on Lighting and Light-signalling | Session 82 | 22-25 Oct 2019

18. The expert from Germany presented an updated proposal which introduces requirements for testing the sun load impact into UN Regulation No. [148] (ECE/TRANS/WP.29/GRE/2019/22). He further indicated that these amendments should be introduced by a new 01 series of amendments to UN Regulation No. [148], together with transitional provisions. The proposal received comments from Japan (GRE-82-38). The experts from the United Kingdom, CLEPA and OICA requested justification for additional testing in ECE/TRANS/WP.29/GRE/2019/22. Finally, GRE invited the expert from Germany, in cooperation with Japan, CLEPA and OICA, to complement the document with transitional provisions and research justification.