CLEPA proposed a framework for relating independent regulations on electronic subsystems of braking or steering systems to the primary braking/steering regulations. This proposal revises the wording, focusing on ESC systems with relation to the requirements for complex electronic control systems under Regulation 13-H.

For testing purposes, UN R90 defines a “test group” as a grouping of parts having the same characteristics. The regulation then defines a “variant” as a part within a “test group”. However, the approval numbers under the rule stipulate the identification of each variant certified. As a result, the text technically requires certification of each individual part (variant) which was not the intention of the drafters. CLEPA raises this for information purposes with the intention to put forward a proposal at the next GRRF session.

IMMA comments on the suggestion to include a cross reference to UN R10 in UN R78 in order to ensure that electromagnetic interference does not affect electronic brake modules in a way that causes unsafe brake operation as was adopted for UN R13.