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RDE: Proposal to amend GRPE/2023/3
Document GRPE-87-09
28 December 2022

Proposal to introduce levels in the draft new UN Regulation on Real Driving Emissions type approvals based on the following:

  1. Since RDE testing has been introduced in the European Union, there has been criticism of the difficulties encountered when planning a valid RDE test.
  2. This situation would be worsened by introducing the requirement for a test to be suitable for analysis according to both 3-phase and 4-phase concepts.
  3. As levels have already been introduced in Regulation No. 154 and these are becoming accepted and understood by technical services and approval authorities, the introduction of these levels in this Regulation would be a clear alignment.
  4. As the temperature boundary conditions from this draft Regulation are already being transposed into European legislation, OICA members see no need to differentiate between boundary conditions for the proposed levels.
  5. The inclusion of these few amendments would return the planning burden to that currently experienced in the EU, at least for markets which apply the 4-phase WLTP concept.

Submitted by OICA
Status: Superseded
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Previous Documents, Discussions, and Outcomes
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.

Relates to UN R168 |