Document presents concerns regarding an OICA proposal to introduce a new Level of Approval (Level 1C) to UN R154 to recognise EU small volume manufacturer provisions. The proposal would exclude technical requirements regarding OBFCM, incorporate OBM and EEEDWS into a new UN Regulation, add allowances to replace Type Approval tests with manufacturer declarations, and include exemption from Conformity of Production testing. Japan expressed a reservation concerning this concept. A process was agreed whereby OICA will draft a question to WP.29 and Japan will draft an explanation of their reservation.