GAR | GRVA-15-14

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Document Title	UN R90: Proposal for amendments
Reference Number	GRVA-15-14
Date	11 Jan 2023
Summary	Proposal for the following amendments: Paragraphs 6.1.1. and 6.1.2.: In the case of category L vehicles application, the same brake lining assemblies could be fitted across a variety of applications. For example, the same brake pads/shoes could be fitted both on vehicle with single disc and on vehicle with double discs. Moreover, the same brake pads/shoes could be fitted both on front application and on rear application vehicle. Since there are too many cases or variables and it’s impossible to have a package based on the axle set for category L vehicles, the proposal of amendment is meant to consider the caliper set/drum set, instead of the axle set. Paragraph 6.1.3.4.: Packaging of brake pads/drums has a limited dimension and it’s impossible to report in the packaging all applications approved, because there is no space available. In addition, should all applications approved be reported in the packaging, the updating of each packaging every time there is a new application available in the market would be needed. This is not feasible and it represents a risk to have a product with no updated information for the final consumer. For these reasons, the proposal aims to allow, as option, to report the approved vehicles/brakes/axle information through digital format (e.g. QR code, website) leading at least to a general catalogue. Moreover, using digital elements, it’s also possible to have a green solution and having a less environmental impact. The modification proposal is optional, and not exclusively for category L vehicles, but it is meant for every type of motor vehicles even if the major criticalities are with category L vehicles because their packaging is smaller than brake pads/drums of passenger car. Paragraph 6.1.4.: The current requirement asks to have fitting instructions inside the packaging with at least an ECE language supplemented by the corresponding text of the language of the country where the product is sold. It means two options: To have a specific fitting instruction for each country where the component is sold; or To have a unique fitting instruction with all languages. Option 1 is not feasible from management and logistic point of view. Option 2 is not feasible because there is limit space available in the packaging: For example, to be sold in EU (that recognize UN R90), it's needed to have all official 24 languages of the EU in a unique fitting instruction paper, but there are applications where the packaging is too small to contain the fitting instruction paper. For these reasons, the proposal of modification asks the possibility to have these fitting instructions also through digital format only (e.g. QR code, internet website, ...). Moreover, using digital elements/formats, it's possible to reduce the environmental impact because the instructions become paperless. The modification proposal is optional, and not exclusively for category L vehicles, but it is meant for every type of motor vehicle even though the major criticalities are with category L vehicles because their packaging is smaller than brake pads/drums of passenger cars.
Source(s)	Italy
Rulemaking Area(s)	UN R90 Replacement Brake Components
Proposal Status	Superseded
Meeting(s)	GRVA \| Session 15 \| 23-27 Jan 2023 10. UN Regulation No. 90
Related Documents
	GRVA-15-48	UN R90: Explanation of the proposal for amendments in GRVA-15-14
	GRVA/2023/11	UN R90: Proposal for a Supplement 12 to the 01 series of amendments (superseded)
	GRVA/2023/12	UN R90: Proposal for a Supplement 11 to the 02 series of amendments (superseded)
	GRVA/2023/15	UN R90: Proposal for amendments (superseded)
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Excerpts from session reports related to this document
GRVA \| Session 15 \| 23-27 Jan 2023		123. The expert from Italy presented GRVA-15-48, introducing GRVA-15-14, which includes the proposal to allow the use of a digital medium (e.g. QR-code, website) as an alternative to the existing information requirements in paragraph 6.1.3.4 in the regulation. 124. The expert from CLEPA provided comments (GRVA-15-24 and GRVA-15-25). 125. The expert from FEMFM agreed in general that digital media could be used but he argued that some information, provided in the packaging of the replacement parts, should not be replaced by information provided via digital media. 126. The expert from Germany explained that there was already a precedent with UN Regulation No. 129. He explained that UN Regulation No. 129 specified a duration of 10 years and wondered if there was a justification for a lower duration (five years) as proposed by Italy. 127. The expert from France explained that, in the European Union context, information provided via a QR-code would be acceptable provided that this is specified in UN Regulation No. 90. The expert from the European Commission confirmed this interpretation. 128. The expert from Italy volunteered to submit a revised proposal for consideration at the next session. The expert from FEMFM also volunteered to submit an alternative proposal.