Idea from Germany to simplify the lifetime requirements for non-replaceable light source(s) and non-replaceable light source module(s) given that the lifetime of a LED light source is much higher than the lifetime of a filament lamp.

Proposal to improve the visibility of direction indicators. The proposal modifies UN R48 and UN R148 requirements for direction indicator lamps grouped with stop lamps. Key changes include: requiring 75% of the rear direction indicator’s apparent surface to be more than 25mm from the stop lamp; positioning direction indicators at specified distances from the vehicle’s outer edge; and establishing a minimum apparent surface area of 30cm² for rear direction indicators. The justification cites existing installations showing inadequate visibility and references luminance studies supporting the 30cm² minimum area requirement.

OICA opposes proposed amendments to UN R48 paragraph 5 that would prohibit lighting devices not explicitly listed in paragraph 6. OICA contends the prohibition creates unnecessary manufacturer burden without safety benefits, conflicts with nationally permitted lamps, and falls outside the 1958 Agreement’s harmonization scope. OICA argues national enforcement, not type-approval restrictions, should manage device installation.

Proposal to amend UN R48 and UN R148 regarding direction indicator visibility when grouped with stop lamps. OICA proposes replacing Germany’s masking-based approach with objective, installation-level acceptance criteria: apparent surface area comparison, luminous intensity ratio at HV of at least 25% higher, or absolute apparent surface of 30 cm². Physical masking eliminates measurement uncertainty and improves test repeatability. Three alternative compliance routes provide flexibility without constraining designs.

The document presents OICA data on rear direction indicator (DI) and stop signal visibility compliance. It evaluates various lamp configurations against UN R48 and UN R148 requirements, examining criteria including photometry areas outside 25mm from stop lamps, DI apparent surface size, separation distances, and intensity ratios. OICA proposes that compliance requirements are met when DI apparent surface equals or exceeds stop lamp surface, intensity exceeds stop lamp by 25% minimum, separation distance reaches 20mm minimum, or DI apparent surface equals or exceeds 30cm.