Proposal to clarify the packaging and labelling requirements for some types of brake lining assemblies, which could be fitted on various different applications and to allow the option of using a QR code (or another type of digital data carrier) to replace some information printed on or included in the packaging.
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.
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.
| GRVA-15-14 | |
| GRVA-15-25 | |
| GRVA/2023/13 | |
| WP.29/2023/130 |