GRE-95-40
UN R48: OICA Comments on Supplement 10 to 07 series of amendments

OICA comments on proposed amendments to introduce minimum separation requirements for stop lamps and position lamps in GRE-95-11. OICA contests the justification for the proposed 400 mm separation requirement for M₁ and N₁ vehicles and 600 mm for all vehicle categories, arguing the EC has not established a causal link between continuous lighting and safety deficits, that the claimed recognition distance differences lack meaningful influence on safe driving, and that introducing divergent UN requirements would create technical barriers to international trade contrary to the 1958 Agreement. OICA references published research indicating strip-type taillights provide optimal ergonomic solutions for vehicle conspicuity.

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