EMC-53-10
UN R10: Input from the Netherlands
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The Netherlands proposes introducing a separate part 2 addressing immunity-related functionality on lateral movement for steer-by-wire and automated driving systems. Harmonics should be tested when issues are observed; in the cited example, step sizes above and below 745-755 MHz and harmonic frequencies at 1500 MHz and 375 MHz require testing. UN R10 should address specific immunity features across multiple UN Regulations, or references should be moved to individual regulations. Test procedures for complex systems like steer-by-wire and brake-by-wire require improvement, including clearer protocols and discussion of specialized technical units. Dwell time must be sufficient to observe all potential fail criteria in agreement between manufacturer and technical service. Antenna switching during testing at 3m versus 10m positions should be forbidden. EMC shielding must be robust and durable, excluding non-integral ferrite blocks and loose components, with critical details recorded in test reports.