Japan comments on the draft 04 series of amendments to UN R51 (Noise of M1–M3 and N1–N3 Categories of Vehicles). Japan highlights several editorial and technical issues. Regarding para. 2.24.1, Japan suggests the table of symbols for Annex 3 should state symbols are “used for the first time” consistent with ISO standards. For para. 3.1.2.1.4.3, Japan requests deletion of “but no more than 2.0 m/s²” as unnecessary for RD-ASEP applied to electric vehicles. Japan notes para. 6.2.3.4 should reference appropriate appendices for the RD-ASEP statement of compliance requirement. Paragraphs 11.1.4 and 11.1.5 are identical and one should be deleted. Japan flags para. 3.2.3.4.2 requires tyre conditioning on outdoor test tracks for indoor testing. For Annex 6, para. 3 should clarify that compliance assessment references para. 5 of Annex 7 for expected sound pressure level limits applicable to conformity of production testing.
NEFOM and S.O.S. represent over 1 million European citizens experiencing noise from light vehicles inconsistent with Certificate of Conformity figures. The LENS project conducted 2300 measurements of 2300 vehicles, finding measured noise levels in practice much higher than type approval, sometimes reaching 100 dB(A). The A-filter used in Certificates of Conformity is unsuitable for noise levels above 70 dB and does not represent human perception. Sound limits for motorcycles have not changed since 2015 and remain too high. The document requests further improvements to RD-ASEP testing, replacement of the A-filter with a C-filter, and significant reduction of sound level limits for motorcycles.
Proposal to define service life values by region or country of usage, establish methodology for calculating realistic GHG emissions and energy consumption during vehicle use stage at various detail levels, determine discrepancy factors based on real-world performance data, apply deterioration factors to account for vehicle aging effects, quantify leakage emissions including hydrogen and methane, assess maintenance and consumables impacts through manufacturer-provided frequency data or alternative methodologies, and collect primary and secondary data on driving activity, vehicle lifetime, fuel consumption, and maintenance replacement intervals. Service life values for passenger cars shall align with average age of vehicles at point of recycling within the same country, with regional default values provided in Annex 1 to the Resolution.
Proposal to amend the original version (GRVA/2026/15), insert para. 5.3.7.2.1.13. to require the manufacturer to describe in the safety concept the system behaviour in case the driver is detected to be disengaged during a manoeuvre; amend the original version and the 01 series (GRVA/2026/15 and GRVA/2026/17), amend para. 3.5.1. of Annex 3 to require the manufacturer to demonstrate to the Type Approval Authority at least every three years that the safety management system continues to comply with requirements; amend the 01 and 02 series (GRVA/2026/17 and WP.29/2026/86), amend para. 2.3.2. of Appendix 2 of Annex 3; amend the 02 series (WP.29/2026/86), amend para. 4.2.5.2.19.2.1. of Annex 4; and amend the original version, 01 series and 02 series (GRVA/2026/15, GRVA/2026/17 and WP.29/2026/86), amend para. 4.2.5.2.14.1.2. of Annex 4 and para. 4.2.5.2.14.2.1. of Annex 4.
Proposal to amend ECE/TRANS/WP.29/2026/137 to replace placeholder text “[ADS]”, “[XXX]”, and “[number of this Regulation]” with the UN Regulation number upon adoption, amend the cross-reference in paragraph 1.2. to “7.2.3.17.”, amend paragraph 6.2.2.3.8.1. subparagraph (b) to specify gaze directed to “the” driving task relevant area, remove brackets around “7.4.” in paragraph 11.2., add a period after the number in Annex 1 paragraph 5.1., amend Annex 1 Appendix 1 paragraphs 1.4.5. and 1.4.7., renumber paragraphs 1.4.12., 1.4.12.1., and 1.4.12.2. as 1.4.11.5., 1.4.11.5.1., and 1.4.11.5.2., amend Annex 1 Appendix 2, amend Annex 7 table 5 rows 1 and 2 column 7, remove brackets in Annex 8 paragraphs 5.3.1. and 5.3.2., and insert “Mandatory” in Annex 8 table row 1 column 2.
Proposal to amend WP.29/2026/139 to amend para. 4.2.2.3.8.1. subparagraph (b) regarding user engagement to resume the DDT, insert new para. 5.2.1.8.1. requiring manufacturers to document simulation toolchain scope and limitations, amend para. 5.2.1.3.1. regarding manufacturer management of relevant data, amend para. 5.3.1.16. describing ADS responses to failure situations, amend para. 6.3.2.2.3. regarding scenario assessment, amend para. 6.3.3.3.1. regarding confirmatory track testing provisions, amend Annex 5 Tables 3, 4, and 5 regarding scenario specifications and risk manoeuvre conditions, and amend Annex 6 para. 5.3.1. and 5.3.2. regarding DSSAD recording requirements and intervals.
Proposal to introduce new regional requirements from Contracting Parties, in particular from Euro 7 in the EU, including new particle number (PN10) provisions, a new SHED limit for evaporative emissions, updated On-board Fuel Consumption Monitoring provisions, and new annexes with requirements relating to in-vehicle battery durability and a new test for range of Pure Electric Vehicles at low temperatures for UN R154 (Worldwide harmonized Light vehicles Test Procedures (WLTP)).
Proposal to correct the text where the word “tyres” was inadvertently omitted from Paragraph 2.1.
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