It was agreed that the discussion should initially concentrate on the Annexes. Stein asked that the durability requirements in para. 9 be discussed first as he could not be present for day 2.

Review of marked-up version of the draft REC
Small changes to the draft were noted below.

In later discussion of the annexes it was recognised that throughout the document it will be necessary to add references to ‘NRMM and category T’ rather than just NRMM. This is because although both are covered by Reg.96, NRMM and category T are separately defined within that regulation.

Consideration of the draft REC Regulations

REC-12-03 (rev.00 of the Regulation)

Paragraph 9:
Following a discussion on the availability of machines to run 1000 hrs durability in a reasonable time, Stein agreed to provide US guidance wording used for on- and off-highway applications.

In answer to a question regarding the requirements for data logging (to be provided to the Type Approval authority), it was agreed that a short break in data logging due to, for instance, data logger failure would not be seen as a problem that invalidated the test.

Annex 1:
In paragraph 2.1 it was agreed that to avoid confusion with type of REC, “manufacturer’s type identification” should be changed to “manufacturer’s model identification”. This will need cross-checking for other similar references in the document.

Regarding the identifying part number of the REC (para. 2.1.1), it was agreed the definition of the part number is up to the manufacturer. It needs to enable traceability from approval documentation to actual fitted systems.

Para. 3.4.2: Not all regeneration methods will fit neatly into ‘continuous’ or ‘active’. A more comprehensive description is expected from the manufacturer.

With the content of the section of this Annex on PM reduction RECs agreed, the editorial group will work on similar text for NOx and NOx+PM RECs.

Annex 2:
Small modifications were made to the text, including the substitution of “model” for “type” as in

Annex 1:
Section 16.7 is redundant as the information is included in Annex 2A.

The definition of application range in para. 3.3 of the body of the regulation does not match the use of the phrase in Annexes 1 and 4. It was agreed to amend the definition to:
“Application range” means the range of vehicles engines to which a retrofit emission control device (REC) approved according to in accordance with this regulation can be applied;”

The second paragraph of section 10 also needs to be modified. This was modified to:
“The application range is defined by limited to the engine family to which the test engine as defined in paragraph 12 belongs.”

Annex 3:
The manufacturer cannot define the model year and engine type to which the REC is fitted. The plate (which is a cut and paste from another regulation) therefore needs to be amended.

There was a discussion on the need to include ‘level’ in the markings. It was noted that the revisions version of the document is already included in the first 2 digits of the type approval number. It was suggested that the levels be renamed 00 and 01 so as to align with the revisions of the regulation. This would avoid that 00 = level 1 and 01 = level 2.

Paragraph 5 of the Regulation requires information on the manufacturer etc. to be provided on the label, therefore the second picture and following text are both redundant.

Annex 4:
The content (not headings) of the table needs to be deleted – this was an example only. It was questioned whether both Annex 4 and the second table in Annex 2A are needed.

Annex 5:
Mr Galey commented that not all systems fit simply into the definition of periodically or continuously regenerating. There are, for instance, continuously regenerating systems that have a back-up assisted regeneration capability. Williams noted that, as with OEM requirements, this annex refers to regeneration during the test cycle. This is therefore covered by the proposal.

The figure of 15% CoV for PM and back pressure variation over 25 cycles will need to be checked.

Mr Uhlik raised a concern that there is a difference between what the group is doing and the Terms of Reference, particularly in relation to the inclusion of requirements on NO2, as NO2 is not taken into account in the environmental classification of vehicles or in emissions standards for original equipment. Other EU member States considered that the inclusion of NO2 was understood from the element of the ToR that specifies that the regulation should be an enabler for LEZs and because the evidence is that retrofits for particulate have often resulted in increases in NO2. Mr Galey, however, considered that the REC requirements should not be more onerous than OE requirements, where there is no NO2 limit VI. He argued that at most there should be a ‘rate and report’. Member States present noted that NO2 had been part of the discussions in Council for Euro VI, that the EC intends to bring forward proposals for specific NO2 limits, and that the lack of an NO2 limitation would detract from the aim of providing a single system that would allow access to different LEZs. At the end of the discussion the chairman concluded that NO2 requirements would be retained and that the specific NO2 levels will be discussed later.

The issues of application range raised in the Hungarian document and on the two stringency levels had been dealt with in yesterday’s part of the meeting.

Mr Uhlik said that there should be a requirement for some system to indicate whether the DPF is working properly (e.g. back-pressure device). Schulte noted that para. 3.6 defines “Emission control monitoring system” but the definition is not then used. It was agreed that the editorial group would incorporate a paragraph based on the Hungarian proposal.