The document addresses simplification of the definition of “apparent surface” and single lamp distance requirements in UN R48. It presents a new CAD-based concept defining apparent surface using light emitting surface with clear outer lens disregarded. The document notes that current regulation allows multiple ways to define apparent surface resulting in different distances, with existing approvals having distances significantly larger than 75mm between distinct parts without known safety issues. GTB agrees on simplifying the apparent surface definition to describe function contours as seen by road users, while acknowledging this should not restrict possible designs. The document references a 1999 INF Milano study concluding symmetric appearance is relevant for vehicle identification and larger distances are acceptable for symmetric compared to asymmetric constellations.