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| Document Title | Comments on the candidate items for technical regulations applicable to IWVTA | ||||||||
| Reference Number | IWVTA-09-09 | ||||||||
| Date |
6 Mar 2012
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| Summary | Proposed revisions to the chart of vehicle regulations that would apply under the International Whole Vehicle Type Approval system. | ||||||||
| Source(s) | OICA | ||||||||
| Rulemaking Area(s) | UN R0 International Whole Vehicle Type Approval | ||||||||
| Meeting(s) | |||||||||
| Downloads | |||||||||
| UNECE server | .pdf format | ||||||||
| Excerpts from session reports related to this document | |||||||||
| IWVTA | Session 9 | 9 Mar 2012 |
Technical Secretary illustrated the outline of the document “Proposal for candidate items for technical regulations applicable to IWVTA and the guideline for GRs to review technical regulations applicable to IWVTA” (IWVTA-09-04) and introduced comments submitted by GR Chairpersons on the document. Germany recommended that IWVTA Informal Group should coordinate and consolidate GR activities and report to WP.29 because it would not be effective for each GR to approach WP.29 with different positions on various issues. Germany also stated the necessity of a special meeting attended by GR Chairpersons and IWVTA Informal Group to discuss the guideline issues and to clarify open questions, which could be held on Thursday afternoon of WP.29 session. The Chairman stated that it would be difficult to hold such a meeting in June because Enforcement Informal Group meeting is scheduled on the afternoon of June 28 (Thursday). Germany replied that Thursday afternoon of November WP.29 session would be appropriate for the meeting because GRRF and GRB do not have meetings until September. Japan explained about “IWVTA ambassador” which was new to the IWVTA Informal Group. Japan suggested that CPs attending IWVTA Informal meetings should proactively consider becoming IWVTA ambassadors because it would play an important role of liaison between GRs and IWVTA Informal Group. OICA supported the proposal of Germany and added that a special meeting attended by GR Chairpersons and IWVTA Informal Group should be held periodically. OICA proposed to remove items for individual unit such as headlamp from the candidate items for technical regulations applicable to IWVTA. OICA also proposed to add consideration of the possibility of virtual testing to the reviewing points by GRs. UK stated that it would be natural for the industry to pursue virtual testing but it would be difficult for GR to forward it because virtual testing has uncertainties. EC stated that basic concept for virtual testing should be placed in “Placeholder” and individual cases should be considered at each GR. OICA agreed with EC on the approach to forward virtual testing. Germany pointed out the importance to communicate with GRs via IWVTA Ambassador because it would be difficult for GRs to understand the guideline only through papers. The Chairman supported the proposal by Germany because direct report to AC1 from GR might cause some confusion. EC stated that it was legitimate for IWVTA Informal Group to update and summarize the progress of each GR in reviewing IWVTA technical regulations at IWVTA Informal meeting and report it to WP.29 to be held in the following week, which enabling us to take a consistent approach to WP.29. Japan asked OICA its intention to raise the issue of virtual testing. More specifically, Japan asked, if OICA intends to offer another new proposal regarding virtual testing since the inventory (WP.29-155-27) already includes virtual testing as main issues. OICA replied that it would like the concept of virtual testing to be introduced in the placeholder of the revised 1958 Agreement and the possibility for virtual testing on a case-by-case basis to be considered by respective GR. UK stated that there has been no agreement regarding virtual testing so far. Next, IWVTA Informal Group discussed OICA comments on the flow chart for “Guideline for each GR to review technical regulations applicable to IWVTA” (IWVTA-09-10) and agreed to amend it as follows.
Next, IWVTA Informal Group discussed OICA comments on the candidate items for technical regulations applicable to IWVTA (IWVTA-09-09). OICA put remarks of “No” for the items whose contents were unclear, such as item “Running system”. OICA also stated that items for individual parts would be unnecessary for IWVTA. EC asked whether OICA regarded NTA as necessary on top of IWVTA approval if OICA said “No” for the nationally applicable unique items. OICA responded that eliminating NTA is ideal but in practice it is difficult. OICA suggested taking a three-step approach illustrated by the document IWVTA-04-10; start with Step1 allowing national requirements and NTA, evolve over time to Step 2 reducing national requirements, and finally reach Step 3 realizing complete mutual recognition of WVTA. OICA added that OICA did not say parts requirements should not be considered, rather the relation between the parts requirements and their installation requirements should be reviewed and might be rearranged. Japan stated that it was important to firstly put all national requirements on the agenda of this meeting even if some of them might be given lower priority. Then, if there were national requirements which were judged to be inappropriate as the international regulations in this meeting, those regulation could tentatively be removed from the candidate items for technical regulations applicable to IWVTA. OICA had concern that the existence of ten or more items which has no UN Regulations might hinder the whole process to review technical regulations applicable to IWVTA. OICA suggested that items having no UN Regulations should be considered at a later stage. EC proposed to prioritize the candidate items for technical regulations applicable to IWVTA. Germany stated that adding national requirements to technical regulations applicable to IWVTA has lower priority. The Chairman asked the meaning of “No” expressed in OICA comments; second priority or elimination? OICA responded that “No” meant the necessity of the item was unclear. OICA did not request to eliminate the items with the remarks “No” right away. Rather, OICA would like GR members to take OICA comments into consideration in reviewing technical regulations applicable to IWVTA. Japan stated the issue of reproduction and reference to private standards in UN Regulations should also be considered. CLEPA pointed out eliminating parts requirements might lead to a loophole in IWVTA. EC suggested that a remark “covered by R48” should be added to the note for the lamp unit items. In conclusion IWVTA Informal Group agreed, in principle, to report the document IWVTA-09-04 to WP29 for its consideration with a note saying the candidate items for technical regulations applicable to IWVTA would be prioritized later and reported to WP.29 at its June session. The Russian Federation representative, WP29 Chairman, Mr. B. Kisulenko informed informal group about the new Custom Union Regulation on Motor Vehicle Safety, which was adopted in December 2011 and will enter into force from 1.01.2015 for the Russian Federation, Belorussia and Kazakhstan. This Regulation is based on Russian Regulation on Motor Vehicle Safety, and also uses ECE UN Regulation and GTRs as normative references. After 1.01.2015 no national legislation in the Russian Federation, Belorussia and Kazakhstan for motor vehicles will exist. [The meeting schedule was discussed before moving to agenda item 6] IWVTA Informal Group agreed on the meeting schedule as follows.
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