Proposal to clarify and improve the text of the new Real Driving Emissions type approval regulation per the following justifications:

1. In paragraph 3.3.7. the text in brackets is a repeat of content in an Annex. It is good practice to keep definitions to one sentence where possible. Adding “of the tested vehicle” avoids any confusion with family test mass definitions.
2. The syntax of the term “power-to-mass-ratio” (with hyphens between all words) should be consistent throughout the document.
3. Where a requirement only applies to the approval authority which issued the approval this should be made clear in the text.
4. Additional to the technical specifications listed in Annex 5, the Regulation assumes measurement accuracy of PEMS equipment. It therefore appears reasonable that the PEMS equipment is required to also deliver these measurement accuracy.
5. As vehicles are designed to be driven predominantly forwards, and rearwards driving although normal practice is an exceptional situation, the possibility to drive rearwards for extended periods should be removed.
6. “Velocity” as a physical term is a vector and has to be accompanied by a direction. For clarity this should be replaced with “speed”.
7. A large (> 20 K) ambient temperature difference between one day and the next is not representative of real life and can result in unrepresentative catalyst performance. The possibility of a preconditioning at 23 °C followed by a test at below freezing should therefore be removed.

Proposal to introduce levels in the draft new UN Regulation on Real Driving Emissions type approvals based on the following:

1. Since RDE testing has been introduced in the European Union, there has been criticism of the difficulties encountered when planning a valid RDE test.
2. This situation would be worsened by introducing the requirement for a test to be suitable for analysis according to both 3-phase and 4-phase concepts.
3. As levels have already been introduced in Regulation No. 154 and these are becoming accepted and understood by technical services and approval authorities, the introduction of these levels in this Regulation would be a clear alignment.
4. As the temperature boundary conditions from this draft Regulation are already being transposed into European legislation, OICA members see no need to differentiate between boundary conditions for the proposed levels.
5. The inclusion of these few amendments would return the planning burden to that currently experienced in the EU, at least for markets which apply the 4-phase WLTP concept.

Additional information concerning the 08 series of amendments pursuant to UN R154 (WLTP) and work on real-driving emissions testing.

Proposal to ensure consistency in the vehicle categories within scope across emissions regulations and with regional requirements within Europe.

1. The current scope of the proposed UN Regulation on RDE (GRPE/2023/3) does not cover all vehicle categories within scope of other UN emissions regulations relevant for light duty vehicles and is inconsistent with regional legislation within the UK and Europe.
2. The proposed amendment seeks to allow Contracting Parties to optionally apply this regulation for vehicle category N2 and for M2 vehicles above 3,500 kg technical permissible maximum laden mass when the reference mass is below 2,610 kg. This would enable equivalent coverage of the scope to regional requirements in Europe and the acceptance of a full UNECE emissions regulation package for those vehicle categories in that region.
3. Provisions relating to the extension of type approvals to vehicles with a reference mass not exceeding 2,840 kg have also been applied to categories M2 and N2 where Contracting Parties are applying the broader scope of vehicle categories.

Proposal to postpone the work on a GTR until after pending national/regional legislation has been enacted (e.g., Euro 7 and US proposal on light vehicle emissions).