JRC proposes three amendments to UN R152 and UN R131: increase crash avoidance speed to 50 km/h for all scenarios (car-to-car, car-to-pedestrian, car-to-bicycle); increase offset to 50% overlap; and discuss adding standing still pedestrian and bicycle scenarios. Evidence from market-surveillance testing shows current systems already meet the 50 km/h requirement in nearly every test and perform well at 50% overlap. Urban speed limits in 75.9% of R152 applying parties are 50 km/h baseline. Approximately 22% of relevant M₁ crashes involved less than 50% overlap.

Document presents Euro NCAP test methodology for passenger cars using increasing speeds up to 50 km/h for stationary vehicle targets with nominal and offset impacts, and up to 60 km/h for crossing pedestrian targets at 25% and 75% impact positions. Each test run generates individual scores with no requirement for specific avoidance speeds. Results indicate all tested cars avoided full overlap collisions up to 50 km/h relative speed over the last three years, and majority of recently tested vehicles should avoid crossing pedestrian accidents up to 60 km/h daytime and 50 km/h nighttime, though results are not directly transferable due to different testing methods.

Case studies analysing real-world UK collisions where Advanced Emergency Braking Systems (AEBS) were fitted using GB STATS19 police and RAIDS national research databases. A total of 287 cases were characterised against UN Regulation No. 152 scenario requirements: car-to-car (141 cases), car-to-pedestrian (81 cases), and car-to-bicycle (28 cases). Cases were scored according to alignment with regulatory test scenarios across nine characteristics: subject vehicle speed, target speed, relative speed, ambient light, lateral overlap, trailer coupled, road layout, road surface condition, and weather conditions. Lateral overlap was the most frequently misaligned characteristic across pedestrian and cyclist scenarios. Road geometry was the most frequent misalignment in car-to-car scenarios. Speed requirements and ambient light conditions warrant consideration for regulatory review.

Document confirms night-time requirements for C2P scenario testing in UN R152, specifying that tests shall apply to M₁ and N₁ vehicles, cover crossing collision only at 5 km/h pedestrian walking speed, include both with lights and without lights conditions, test only 50% collision point using adult dummies, operate at 20–60 km/h activation speed with no obstruction, and align speed reduction calculation with UN R152. Discusses daytime requirements for C2C and C2P scenarios, noting Japan’s position that the IWG should establish priorities among proposed new requirements.

Industry position on night-time testing for car-to-pedestrian scenarios in UN R152. Industry supports night-time testing based on the current version of UN R152 with lighting conditions based on Euro NCAP TB CA 101, limited to crossing collisions with farside pedestrian direction only. Industry proposes modifying illumination conditions in para. 5.2.2.4 and adding a new para. 6.1.6 specifying street lighting setup, and adding a dedicated chapter with visualization of illumination conditions. Testing should use adult pedestrian dummy only, with pedestrian speed, collision point, activation speed, and speed reduction requirements remaining unchanged from UN R152.