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RDE: Proposal to amend GRPE/2023/3

Document GRPE-87-08

28 December 2022

87th GRPE session (10-13 Jan 2023)

Proposal to clarify and improve the text of the new Real Driving Emissions type approval regulation per the following justifications:

In paragraph 3.3.7. the text in brackets is a repeat of content in an Annex. It is good practice to keep definitions to one sentence where possible. Adding “of the tested vehicle” avoids any confusion with family test mass definitions.
The syntax of the term “power-to-mass-ratio” (with hyphens between all words) should be consistent throughout the document.
Where a requirement only applies to the approval authority which issued the approval this should be made clear in the text.
Additional to the technical specifications listed in Annex 5, the Regulation assumes measurement accuracy of PEMS equipment. It therefore appears reasonable that the PEMS equipment is required to also deliver these measurement accuracy.
As vehicles are designed to be driven predominantly forwards, and rearwards driving although normal practice is an exceptional situation, the possibility to drive rearwards for extended periods should be removed.
“Velocity” as a physical term is a vector and has to be accompanied by a direction. For clarity this should be replaced with “speed”.
A large (> 20 K) ambient temperature difference between one day and the next is not representative of real life and can result in unrepresentative catalyst performance. The possibility of a preconditioning at 23 °C followed by a test at below freezing should therefore be removed.

Submitted by OICA

Status: Superseded

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Previous Documents, Discussions, and Outcomes

87th GRPE session (10-13 Jan 2023)

3. (c) | Worldwide harmonized Real Driving Emissions (RDE) test procedure

39. The representative from the EC introduced ECE/TRANS/WP.29/GRPE/2023/3. This document is submitted by the experts of Japan and the European Commission. The text contains changes introduced into European legislation (Euro 6e) since the adoption of the previous version of the draft UN Regulation on RDE prepared by GRPE at its eighty-first session (ECE/TRANS/WP.29/GRPE/81/Add.2 and ECE/TRANS/WP.29/2020/120). The representative from OICA introduced GRPE-87-08 and GRPE-87-09. The representative from Japan supported ECE/TRANS/WP.29/GRPE/2023/3 and GRPE-87-08. The representative from the European Commission had some objections to some elements included in GRPE-87-08 and sought further clarification to make sure over-regulation is not included in the proposal, as might be the case where requiring not to perform RDE trips in reverse gear.

40. The representative from OICA highlighted absolute legal clarity was needed, as stakeholders in other fora had made statement about attempts to make vehicles fail RDE tests, legally compliant but driven in unrealistic conditions.

41. The representative from the European Commission did not support GRPE-87-09, requesting to try and avoid repeat the sub-optimal situation that led to last resort decision in other GRPE legislation and confirmed the European Commission had no mandate to agree on the inclusion of 2 levels in UN Regulation on Global RDE. The representative from Italy understood the intention of the OICA’s proposal, and was open to OICA’s proposal in the spirit of harmonization that is operational.

42. The representative from the UK introduced GRPE-87-44 and GRPE-87-45 and supported an adoption of UN regulation on Global RDE during this session of GRPE.

43. Following additional activities from all concerned parties during the session, the representative from the European Commission introduced GRPE-87-49 as a revised proposal for a new UN Regulation on Global RDE which represented a consensus on the various proposals presented previously.

44. The representatives from France, Germany, Italy, Japan, the UK and the European Commission supported the proposal. GRPE agreed with the content of GRPE-87-49.

45. GRPE adopted ECE/TRANS/WP.29/GRPE/2023/3 as amended by GRPE-87-49, as reflected in Addendum 2, and requested the secretariat to submit it to WP.29 and AC.1 for consideration and vote at their June 2023 sessions as draft new UN Regulation No. [XXX] on Global RDE.

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