15. The expert from IEC analysed the approval process of LED replacement light sources according to UN Regulation No. 37 (GRE-87-02), based on the full photometric equivalence according to the guidelines (GRE-83-15). According to him, full-equivalence solutions were not feasible for high flux categories with the today’s LED technology. As a consequence, some countries were issuing national approvals deviating from the full photometric equivalence, based on extensive testing (in headlamps and vehicles) for limited light source specifications and resulting in a positive list for particular vehicle models. GRE stressed the advantages of harmonization at the United Nations level and noted that several contracting parties were in favour of cautious re-evaluation of the equivalence criteria for LED replacement light sources. GRE invited IEC to start this work as a new activity of the Task Force on Substitutes and Retrofits (TF SR) in cooperation with those contracting parties.

18. The expert from TF SR presented a set of proposals for amendments to UN Regulations Nos. 37 and 128 as well as to R.E.5 which introduced LED replacement light sources into UN Regulation No. 37 (ECE/TRANS/WP.29/GRE/2020/15, ECE/TRANS/WP.29/GRE/2020/16, ECE/TRANS/WP.29/GRE/2020/17, GRE-83-05, GRE-83-11, GRE-83-12, GRE-83-13, GRE-83-14, GRE-83-15, GRE-83-16). The expert from OICA commented on these proposals GRE-83-38. The expert from France expressed concerns. GRE re-confirmed the approach chosen by TF SR and decided to revert to the package at the next session. Meanwhile, GRE requested TF SR to liaise with the expert from France with the aim to take into consideration his concerns.