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Document Title Proposal concerning application of marking in global technical regulations
Reference Number WP.29/2010/83
Date
12 Apr 2010
Source(s) Russia
Rulemaking Area(s) GTR Markings
Meeting(s)
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Excerpts from session reports related to this document
WP.29 | Session 151 | 22-25 Jun 2010

105. The representative of the Russian Federation introduced ECE/TRANS/WP.29/2010/83 proposing a global marking in the gtrs with a similar structure and requirements as those of the UNECE Regulations.

The representative of OICA, also on behalf of IMMA and GTB, introduced WP.29-150-20 and WP.29-151-08 proposing the harmonization of only technical markings. He underlined that a global certification mark would not be usable due to the inherent nature of the 1998 Agreement, which among others does not address the certification process and which cannot ensure that all global technical regulations are implemented in the same way in all the Contracting Parties. He suggested that, in order to overcome these difficulties, a possible solution could be that individual products would carry, instead of a certification mark, a unique identification code, through which all certification data could then be obtained in a global database of certified products, linked to the DETA database.

The representative of CLEPA stated that his organization would oppose to any limitation or regulatory restriction on product marking affecting trademark or manufacturer brands, etc.

The secretariat was requested to distribute WP.29-151-08 with an official symbol for consideration at the November 2010 session.

106. The representative of ETRTO stated that his organization did not need harmonization of technical markings. He proposed a possible system for a global administrative marking in the draft gtr on tyres (WP.29-151-03).

The representative of the United States of America underlined that marking should be clear enough for the customs services. He added that, according to the law of his country, the manufacturer putting the mark on the product would be considered responsible for the safety performance of the product over its entire useful life.

107. AC.3 agreed to resume discussion of this subject at its next session for a final decision. The Chair invited all delegates to reflect on a possible optional marking in gtrs.

WP.29 | Session 152 | 9-12 Nov 2010

129. The representative of OICA, also on behalf of IMMA and GTB, introduced ECE/TRANS/WP.29/2010/143. He highlighted that that, according to the legal framework of the 1998 Agreement, global marking was not possible. He underlined that technical markings may be harmonized through global technical regulations, provided that such technical markings are integrated into national/regional legislation without modification. For the administrative certification however, he proposed to use a global database containing all relevant certification data, independently from the 1998 Agreement. He added that, as mentioned in ECE/TRANS/WP.29/GRSG/2007/32, the global harmonization of approval marks was not possible because the 1998 Agreement covers neither certification procedures nor mutual recognition of approvals.

The representative of the Russian Federation recalled the purpose of ECE/TRANS/WP.29/2010/83 on global certification marking based on the UNECE Regulation marking.

The representative of Canada reminded AC.3 that, even if a harmonized certification marking was agreed, this system would work only if gtrs were transposed into national law without any modification.

ETRTO recognized that this issue could not be dealt with at the present time. He suggested introducing the issue of markings in the framework of the 1998 Agreement in the revision of the publication “WP.29: How it works, how to join it”.

AC.3 noted that the issue of marking could be assigned to the informal group on DETA, after the completion of its current mandate. AC.3 wished to be informed of the progress of the DETA project anticipating that it could provide a solution to marking requirements in the framework of the 1998 Agreement.

AC.3 agreed to remove this item from the agenda for the 2011 sessions, unless any new information was forthcoming.