GTB white paper on priorities and objectives for the simplification of lighting regulations, especially regarding reduction of the current burdens associated with the necessity of collective amendments in the development of these regulations and the longer-term difficulties to be overcome in restructuring these regulations and their legal framework.
33. Having pointing out that the European Union (EU) refers to UN Regulations in its legislation, the expert from EC informed GRE about three concerns that EC and some EU member States have with regard to the GRE scope of activities:
a) A large number of GRE-related UN Regulations (forty-one) and their constant updating are a serious burden for the efficient management of the system, both for the United Nations and EU. Consequently, around one third of all documents under the WP.29 umbrella are from GRE. A lot of resources are required for their official translation into various languages, and there is a considerable backlog in this area. Thus, according to the expert from EC, the incurred costs should be minimized by simplifying and streamlining the documentation originating from GRE;
b) Some UN Regulations prepared and/or amended by GRE in the past were rather descriptive and not enough performance based. According to the expert from EC, descriptive provisions could, in some cases, distort the market competition and impede new technologies and innovations;
c) Too prescriptive and descriptive approach could make UN Regulations less attractive to countries outside the ECE region. According to the expert from EC, probably for this reason two years ago Japan had not adhered to UN Regulation No. 128. Moreover, the United States of America, who has only one regulation related to lighting and light signalling, would oppose developing multitude UN GTRs in this area, given the present number of UN Regulations on this subject. As an alternative example, he mentioned the area of fuel efficiency and emissions where there were fewer documents, that were not too prescriptive, and where the Asian countries supported a new UN GTR which had recently been adopted.
34. The expert from EC was also confident that GRE had all the necessary competencies to address these concerns and urged GRE to do so without delay.
35. The expert from GTB contributed to the discussion by presenting GRE-71-17 and GRE-71-24 containing some ideas on simplification of lighting and light-signalling UN Regulations. According to him, these UN Regulations are at present a mix of regulatory (legal) and technical aspects which should be separated in the future. A solution could be found in creating a three-level documentation structure, as proposed in GRE-71-24, where provisions common for different UN Regulations would be put in a single document similar to Consolidated Resolution R.E.3.