The e-Trailer Industry Group reports on discussions regarding electrically propelled and recuperating trailers. ISO 11992-2 Edition 4 is not safely implementable due to incompatibility with current UN regulations, missing PGNs, and risks of malfunction. ISO/TC 22/SC 31/WG 4 launched Edition 5, targeting publication in early 2027. Amendments to UN R13 and UN R100 are being developed in phases, with Phase 1 addressing trailer dynamo function and Phase 2 addressing e-axle trailers. Two workshops with Contracting Parties are planned to establish shared understanding and develop concrete parameter extensions for amending UN Regulations.

Proposal to delete paragraph 1.2.6. excluding e-axle trailers with e-axles providing electric propulsion and/or incorporating an electric regenerative braking system from the scope of UN R13, and add definitions of “e-axle,” “e-axle trailer,” “dynamo function,” and “e-trailer”; add special requirements for power-driven vehicles supporting e-trailer operation, e-axle trailers equipped with dynamo function, and e-trailers of category O; add requirements for electric control lines conforming to ISO 11992-2:²⁰²⁷; specify message support and functional compatibility; and add provisions for electric regenerative braking, dynamo function, and propulsion, including parameters such as retarder torque demand priority, propulsion force limits, overriding mode activation at speeds below 15km/h, and vehicle stability function interaction.

Document explains concerns about the approach in GRVA/2026/30 to require a single Approval Authority to issue certificates of compliance for Cyber Security Management Systems and Automated Driving Systems Management Systems and vehicle type approval. The proposed changes would lead to double or triple approvals of management systems, creating administrative burden and unresolved legal consequences regarding challenged certificates of compliance and their effects on other issued certificates for the same management system. The submission proposes clarifying existing wording, documenting implications of challenged certificates, and adding a new paragraph 5.1.5. to UN R155 permitting mutual agreement between Approval Authorities regarding certificate usage.

Proposal to amend Article 2, paragraph 2 to clarify that where a Certificate of Compliance required under a UN Regulation and issued by an Approval Authority of another Contracting Party is accepted by a Contracting Party, the Approval Authority granting the corresponding type approval shall remain responsible for all aspects of that type approval. The amendment addresses management systems and their Certificates of Compliance used in UN Regulations such as UN R155 and UN R156.

Status report on e-axle trailer development within GRVA, covering taxonomy, regulatory approach, and progress. The document presents use cases for electric axles in trailers of categories O2, O3, and O4, comparing simplified frameworks for O2 with fully integrated heavy vehicle frameworks for O3/O4. Progress includes updated taxonomy, ISO 11992 standardization work, and completed workshops. Step 2 adoption is targeted for January 2027, with Step 3 planning for O2 trailers to be clarified.

OICA, CLEPA, and CLCCR oppose the requirement in GRVA/2026/30 for a single Approval Authority to issue the Certificate of Compliance for CSMS/SUMS and vehicle type approval. They contend the approach would create multiple approvals of the same Management System, imposing administrative burden and creating unresolved legal consequences if a CoC is challenged. The organizations propose adding a new paragraph 5.1.5. instead of paragraph 5.1.3. e) to permit mutual agreement between Approval Authorities, allowing usage of a CoC issued by another Approval Authority, with such agreement documented in type approval documentation.

Proposal to insert new paras. 27 and 28 in Part C Guidance for the application of UN Regulation No. 155 to transformed vehicles. Para. 27 states the requirement that the Certificate of Compliance and type approval are issued by the same Approval Authority applies only within the scope of the type approval granted to the manufacturer concerned. Para. 28 states where a vehicle manufacturer modifies a vehicle with existing type approval and applies for new type approval covering the modification, they need not use the same type approval authority as was used by the original vehicle manufacturer.