Japan basically agrees with the proposal made by Germany but considers that certain points need clarification.
18. The expert from Germany presented an updated proposal which introduces requirements for testing the sun load impact into UN Regulation No.  (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. , 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.