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Proposal for Supplements to UN R148 and to the 06 series of amendments to UN R48
Document GRE/2020/5
5 February 2020

Proposal to allow the use of manufacturer logos in the internal structure of optical components and/or in the outer lens within the apparent surface of a signalling lamp.

Submitted by France and Germany
Status: Superseded
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Previous Documents, Discussions, and Outcomes
6. (a) | UN R48: Proposals for amendments to the latest series of amendments

23. GRE noted that the revised proposal that allows the use of manufacturer logos inside the illuminant surface of a signalling lamps (ECE/TRANS/WP.29/GRE/2020/5/Rev.1) would be postponed to the next session, due to the ongoing work on the proposal. In the interim, GRE reiterated its request to type approval authorities to refrain from granting type approvals to lamps with such logos.

4. (b) | UN Regulation No. 148 (Light-signalling devices)
4. (c) | UN Regulation No. 149 (Road illumination devices)
6. (a) | UN R48: Proposals for amendments to the 05 and 06 series of amendments

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.

4. | Simplification of lighting and light-signalling UN Regulations

16. The experts from France and Germany presented an updated proposal for amendments to UN Regulations Nos. 48 and 148, which introduce conditions for the use of logos of the vehicle or body manufacturer inside the illuminating surface of a signalling lamp (ECE/TRANS/WP.29/GRE/2019/28 and GRE-82-32). The expert from CLEPA proposed adding the logo of the lamp manufacturer (GRE-82-20). The expert from OICA suggested a modified definition of “manufacturer logo” (GRE-82-36).

17. Several experts expressed their preference to completely prohibit the use of logos inside the lamps on safety concerns, while some others pointed out that road safety would not be compromised, as the lamps should meet all requirements in the respective UN Regulations. Some experts wondered whether the use of letters inside the logos was allowed. Following an in-depth discussion, GRE agreed that the “manufacturer logo” definition would need further clarification and invited the experts from France and Germany to submit a revised proposal for consideration at the next session. Pending the outcome of this discussion, GRE invited type approval authorities to refrain from granting type approvals to signalling lamps with logos inside the illuminating surface.

6. (a) | Proposals for amendments to the 05 and 06 series of amendments
4. | Simplification of lighting and light-signalling UN Regulations

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.

9. | New business and late submissions

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.

9. | New business and late submissions

39. Due to a lack of time, GRE was not in a position to consider GRE-78-03.

Related and Previous Documents
GRE-78-03
GRE-80-28
GRE/2019/6
GRE/2019/28
GRE-82-32
GRE-82-20
GRE-82-36
GRE-83-36
GRE-83-46
GRE-83-50
GRE/2020/5/Rev.1
Relates to UN R48 | UN R148 |