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UN R90: Proposal for amendments

Document GRVA-15-14

11 January 2023

15th GRVA session (23-27 Jan 2023)

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.

Submitted by Italy

Status: Superseded

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Previous Documents, Discussions, and Outcomes

16th GRVA session (22-26 May 2023)

10. | UN Regulation No. 90

118. The expert from CLEPA introduced the proposals for amendments to the 01 and 02 series of amendments to UN Regulation No. 90 (ECE/TRANS/WP.29/GRVA/2023/11 and ECE/TRANS/WP.29/GRVA/2023/12, as amended by GRVA-16-14), submitted by CLEPA and Italy. He informed GRVA that these proposals aimed at introducing amendments for calliper/ drum set packaging and at allowing, as an option, to report the approved vehicles/brakes/axle information as well as fitting instructions through digital format (e.g. Quick Response (QR) code, website).

119. The experts from France, Germany and UK supported the amendments.

120. The expert from FIA asked what would happen in case there was no available internet connection. He added that the consumer should not be asked for personal data when he asks for the QR code.

121. The expert from CLEPA responded that the proposal did not prevent that instructions are made available in printable format. He agreed that it should be avoided that any person is asked to provide personal data.

121. GRVA adopted ECE/TRANS/WP.29/GRVA/2023/11 and requested the secretariat to submit it as a supplement to the 01 series of amendments to UN Regulation No. 90 to WP.29 and AC.1 for consideration and vote at their November 2023 sessions.

122. GRVA adopted ECE/TRANS/WP.29/GRVA/2023/12, as amended by GRVA-16-14, and requested the secretariat to submit it as a supplement to the 02 series of amendments to UN Regulation No. 90 to WP.29 and AC.1 for consideration and vote at their November 2023 sessions.

123. GRVA noted the documents ECE/TRANS/WP.29/GRVA/2023/13, ECE/TRANS/WP.29/GRVA/2023/14 and ECE/TRANS/WP.29/GRVA/2023/15, which were not introduced as no representative of FEMFM was present.

124. The experts from CLEPA and the Netherlands stated that they could not support these documents.

125. GRVA agreed to keep the documents ECE/TRANS/WP.29/GRVA/2023/13, ECE/TRANS/WP.29/GRVA/2023/14 and ECE/TRANS/WP.29/GRVA/2023/15 on the agenda until its next session.

15th GRVA session (23-27 Jan 2023)

10. | UN Regulation No. 90

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.

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