In order for the proposed new UN Regulation transposing the GTR on hydrogen fuel-cell vehicles into the 1958 Agreement to be applicable in Japan, the regulation needs to make clear that its scope does not include (i) the electrical safety of electric power train, (ii) the material compatibility and hydrogen embrittlement of the vehicle fuel system and (iii) the post-crash fuel system integrity in the event of full width frontal impact and rear impact. This allows Japanese national regulations to be applied even when accepting a vehicle type-approved under the UN Regulation.
14. WP.29/AC.2 considered WP.29-164-13 on national requirements not covered by the scope of a UN Regulation and endorsed the position of Japan.
71(bis). The representative of OICA supported the adoption of the new draft UN Regulation on hydrogen and fuel cell vehicles as submitted to WP.29 and AC.1. He pointed out that this draft also contains post-crash requirements, because it fully transposes UN GTR No. 13 into the 1958 Agreement framework. He added that the normal procedure would have been to insert these provisions in the relevant UN Regulations on frontal and lateral collision, such as UN Regulations Nos. 94 or 95, similar to the approach used for UN Regulation No. 100 (Safety of battery electric vehicles). Therefore, he suggested that GRSP should revise, in a further step, the UN Regulation focusing on safety requirements for the construction and use of HFCV vehicles, while the post-crash requirements would be transferred to the relevant post-crash Regulations under the 1958 Agreement. WP.29 endorsed this approach.