Input provided by experts from the GRE TF S/R concerning market surveillance needs for LED replacement light sources. LED replacement light sources enable technology transition from incandescent to LED for vehicles in operation, offering longer lifetime, higher vibration resistance, and lower power consumption. Type-approval framework for LEDr has been established through national approvals and UN R37 approvals. Market surveillance must be improved to ensure only safe, compliant LEDr with type approval are used on public roads. Products without type approval should be offered with correct consumer information and clear restriction for off-road use only. Authorities should remove non-compliant products without type approval if used on public roads.
The Task Force on LED Substitutes and Retrofits reports on establishing a type-approval framework for LED replacements to enable safe technology transition from incandescent to LED lighting for cars-in-use. Step 1 completion has resulted in growing LED replacement category sheets in RE5, with national and UN approvals enabled. Step 2 requires improved market surveillance, as unsafe non-approved products reach roads and some R37-approved products show non-compliance. The task force proposes waiting for front fog cycle completion and applying lessons learnt before enforcing the high beam package, addressing keying deficiencies and inadequate warnings on unapproved products. Market surveillance control points span approval, import, point of sales, PTI, and roadside enforcement.
The draft agenda for the 30th meeting of the GRE Task Force on Substitutes / Retrofits, scheduled for 22 September 2026 from 13:00 to 15:30 CEST online, addresses organisational matters, adoption of the agenda, and reports from the 29th meeting. The agenda covers proposals for R.E.5 including H11 LEDr, H8 LEDr, H16 LEDr, and HB4 LEDr entered-into-force provisions, front fog types completing H10 work, high beam types covering HIR2, HB3, and H9, low beam types, clarification of R37 requirements for LEDr, enforcement and market surveillance matters, and preparation of submissions to GRE95 including category sheets and status reports.
Proposal to add resources providing guidance on Safety Performance Indicators. The added resources include J3237, Dynamic Driving Task Assessment (DA) Metrics for Automated Driving Systems; AVSC00006202103, Automated Vehicle Safety Consortium (2021) Best Practice for Metrics and Methods for Assessing Safety Performance of Automated Driving Systems (ADS); AVSC00008202111, Automated Vehicle Safety Consortium (2021) AVSC Best Practice for Evaluation of Behavioural Competencies for ADS-Dedicated Vehicles (ADS-DVs); SAE J2944, Operational Definitions of Driving Performance Measures and Statistics; and SAE J3197, Automated Driving System Data Logger.
Based on ADS-21-68/Rev.1, amend para. 3.2.3.(b) to clarify that the regulation requires the safety level of ADS to be at least to the level of a competent and careful human driver as a general concept and technology-neutral comparator, that manufacturers should explain how they determine and apply this concept accounting for national specificities including those that might arise in relevant cases, that different approaches or combinations of approaches may be used varying depending on the safety concept, claims and argument structure, and approach to safety assessment, that no single approach is presumed better, that manufacturers may use more than one approach, that driver population reference data sets should be subject to appropriate selection, processing and interpretation, and to provide non-exhaustive examples of reference driver based approaches and behaviour-based approaches.
Proposal to revise guidance text in para. 8.1.6.1.(d) to delete the statement that the intention is to ensure safety promotion contributes to ongoing learning and improvement, reinforcing the adaptive nature of the SMS, and insert revised text stating that this point focuses on continued evaluation contributing to ongoing learning so that the SMS remains effective, allowing an adaptive nature through modification and adaptation supported by safety recordkeeping.
Proposal to revise the guidance text in para. 8.1.8.1.(c) by deleting “This element ensures the existence of effective communication channels, both internally and externally, to support awareness and information sharing.” and inserting “This point focuses on the existence of communication channels, both internal and external, to support awareness and information sharing.” The proposal follows comments received in the 18th ADS Workshop where discussion of the SMS section in a dedicated small drafting group was requested, and the current text aims at streamlining the text.
Proposal to delete the requirement that competence is expected to be actively developed and maintained through structured training and insert that this point focuses on the existence and maintenance of SMS training plans to support competence for the SMS management in para. 8.1.6.1.(b).
Proposal to amend provisions in documents GRVA/2025/13 and GRVA/2025/14 concerning the type approval of a park lock device as an alternative to or in combination with the friction parking braking.
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