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In document GRSG/2014/22, the EC proposes to align Annex 11 of UN R107 with Regulation (EU) 1230/2012 (type approval of vehicles with regard to their masses and dimensions). However, the volume and location of masses – including baggage masses – impacts many basic parameters of buses like total mass in running order, axle loads, CG position, etc. and related UN Regulations. This document raises issues for consideration during the review of the EC proposal.
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