Note from the WP.29 secretariat
58. The representative of Germany, Chair of the IWG on DETA, presented WP.29-188-18, introducing WP.29-188-19, the draft report of the fourty-fifth session of the IWG on DETA and also updating WP.29 on the work done during that session, held in Geneva on 10 November 2022. He laid out the current state of play, noting the number of approvals uploaded. He detailed activities of the IWG related to the Unique Identifier (UI) and suggested to circulate WP.29-188-20 to the GRs, containing proposed actions for the IWG on DETA, GRs and WP.29 as well as a table for the assessment of UN Regulations under the purview of the respective GR regarding the usage of UI. He reported on the progress related to the DETA feature for the mass upload of type approvals and the implementation by three Type Approval Authorities. He reiterated the request for decision by WP.29 regarding the access to DETA by Technical Services in case these Technical Services are performing an authoritative task under governmental control (as opposed to other Technical Services being commercial economic operators).
59. The representative of France commended the work of Germany in setting the upload function on the database and informed WP.29 that France would use the upload to ensure its functionality in France. He volunteered to give a feedback to WP.29 on the use of this functionality in case any issue would arise.
60. The representative of Spain suggested that WP.29 allow all Technical Services to have access to DETA. The representative of the United Kingdom of Great Britain and Northern Ireland raised a question regarding the access to DETA for Technical Services, in particular concerning the commercial confidentiality of the information contained in the system. He suggested that Technical Services would only be granted access to approval pursuant to UN Regulations for which they are nominated by their Type Approval Authorities. WP.29 concluded that further elaborations were needed and recommended the group to define criteria regarding the access to information in DETA.
61. WP.29 invited all the Contracting Parties to start the work for allowing relevant organisations to upload all the approvals they issue to DETA.
62. WP.29 authorized the group to distribute informal document WP.29-188-20 to its subsidiary bodies.
63. The representative of France suggested that the IWG would elaborate a standard clause to be used in any UN Regulation for prohibiting the use of UI. In this respect, the representative of Germany, Chair of IWG on DETA suggested that an amendment to Schedule 5 of the 1958 Agreement could also be considered. WP.29 agreed that these suggestions should be considered by its subsidiary bodies.
64. The secretariat reminded the World Forum that the situation related to hosting DETA at UNECE remained unchanged. The representative of the United States of America reconfirmed their objection to the hosting of DETA at ECE under regular budget.
65. The World Forum thanked Germany for continuing to host DETA.
36. GRSG recalled that its experts were invited to provide further comments and indications on which UN Regulations would not be affected by Unique Identifier (UI). GRSG also noted that it was expected to complete the tentative list provided in GRSG-124-21 distributed at its October 2022 session (ECE/TRANS/WP.29/GRSG/103, paragraph 31).
37. The expert from the Netherlands, secretary of IWG DETA, clarified that the unique identifier is a number generated by the DETA database, and allocated to a type approval when uploaded to the database. He added that the UI number may also be used by the manufacturer as product marking, and that the traditional E marking may be replaced by this UI mark. However, he clarified that some UN Regulations required additional marking information. He added that when traditional marking was replaced by UI marking, this additional marking would be potentially removed. However, he noted that this information could be needed for surveillance or periodical technical inspections (PTI) purposes. Accordingly, WP.29 agreed to request its subsidiary bodies to screen all UN Regulations to find if the E marking could be replaced by the UI marking. If any UN Regulation allows replacement, he informed GRSG that WP.29 had proposed a template (WP.29-188-20) to indicate which additional marking information shall remain on the product. He also underlined that UI marking was primarily of benefit for automotive component industry (large markings on small components) while for contracting parties no benefit was provided.
38. The expert from CITA introduced GRSG-125-35 (based on WP.29-188-20) listing all UN Regulations under the purview of GRSG providing information that his organization deems relevant. The expert from OICA argued that the document diverted from the general use of UI as agreed by WP.29: (a) UI shall be applied by default, only exceptions may prohibit it, (b) from UI, PTI can retrieve all the necessary information and (c) some markings were too large on safety glazing thereby compromising light transmittance requirements. The expert from CITA mentioned that E marking provided instant information while UI was time consuming and added extra costs to PTI. He argued that glazing is large enough to host E markings and should be checked frequently because of frequent replacement. Therefore, even in this case he saw the UI solution as time and resource consuming. The expert from the Netherlands suggested that concerned parties had learned much about the use of UI since its establishment by way of the Revision 3 of the 1958 Agreement. Moreover, he suggested that the complexity introduced by UI led to rethinking its use. The expert from the United Kingdom suggested that GRSG-125-35 was a useful document. However, he insisted that this screening needed a coordinated and consistent position and use throughout all the subsidiary bodies of WP.29. The expert from Germany expressed sympathy for GRSG-125-35, however he requested a time reservation. The Chair of GRSG stated that he would inform WP.29 that GRSG-125-35 represented the opinion of the expert from CITA and that GRSG retains a further revision of GRSG-125-35. GRSG agreed with the suggestion of its Chair, to resume discussion at its October 2023 session and to keep GRSG-125-35 as an informal document.
33. GRBP was briefed on the activities of the Informal Working Group for the Electronic Database for the Exchange of Type Approval Documentation (IWG DETA) with the aim to start the use of the “Unique Identifier” (UI) in UN Regulations. In particular, GRBP noted that IWG on DETA had provided a template to be used by the WP.29 subsidiary Working Parties (GRs) for the implementation of UI in UN Regulations (WP.29-188-20).
34. GRBP recalled that, at its previous session, it had agreed that the use of UI in the context of GRBP UN Regulations would not bring additional benefits. GRBP noted that, according to Schedule 5 to the 1958 Agreement, the use of UI is allowed, unless provided otherwise in a UN Regulation. GRBP was informed that, at the WP.29 session in November 2022, two solutions had been suggested to ban the use of UI:
35. Some experts pointed out that option (b) would be less time consuming. At the same time, GRBP noted that, in case of need, UN Regulations in the scope of GRBP could be amended one by one or in blocks with the standard clause under option (a).