India comments on the proposal to enable the approval of sequential activation of light sources of direction indicators lamps for motorcycles.

Proposal to amend the draft text concerning sequential activation of direction indicators. The amendments aim to ensure reasonable uniformity across direction indicators in order to reduce the risk of misinterpretation by other road users. The modifications proposed by the France replace the terms “apparent surface” and “continuous” with specific objective criteria.

The justification for changes to sub-paragraphs 5.6.(e) of Regulation No. 6 and 6.8.(e) of Regulation No. 50 is missing from document GRE/2016/20. The Task Force on Sequential Activation of direction indicators wishes to note that the paragraphs were proposed by GTB and accepted by the Task Force to clarify the text without changing the current technical requirements.

Pursuant to interpretation issues raised by Germany at the seventy-fifth session of GRE, a Task Force on Sequential Activaton was established to clarify the meaning of the “one continuous line” requirement in paragraph 5.6.(c) of Regulation No. 6. The task force proposes to clarify the type definition and reduce the need for dividing sequential direction indicators into different types. This proposal revises the text to be more technology-neutral, removing specifications on how light sources are activated to focus on the visual performance as sequential lighting. The amendment of sub-paragraph 5.6.(c) of UN R6 clarifies what kind of vertical movement is not allowed in the sequential direction indicators, proposing a new new term “vertical oscillations” instead of the current wording “repeating alternation in the vertical direction”. The meaning is that not more than one change of direction upwards or downwards along the vertical axis is possible. The “continuous signal” is also defined in sub-paragraph 5.6.(c) of Regulation No. 6. The allowed distance between adjacent or tangential distinct parts has yet to be defined. TF-SA could not find a consensus about the distance (in mm) before the deadline for submitting official working documents to the seventy-sixth session of GRE. Thus, the value is still marked between square brackets, leaving the final decision to GRE. Before the seventy-sixth session of GRE, TF-SA experts are going to investigate what the suitable value would be. The idea of TF-SA is that the sequential direction indicator should produce a visually clear and continuous signal when viewed by an observer from a 10 m distance. The same amendments as in paragraph 5.6. of the UN R6 are also proposed to paragraph 6.8. of Regulation No. 50 for L-category vehicles. Unlike paragraph 1.3. of Regulation No. 6, paragraph 2.2. of Regulation No. 50 does not define the sequential activation as a type differentiation criterion. Therefore, amendments to paragraph 2.2. of Regulation No. 50 are not necessary.

This proposal removes the requirement to indicate the rated wattage in the marking of lamps equipped with electronic light source control gear and/or non-replaceable light sources and/or light source module(s). From an electronic point of view, the information of the wattage brings no benefit and is confusing if the same module is used in different systems and at different wattages.