Table offering the Japanese position on new limit values for 03 series of amendments to Regulation No.51. The limit values are based on the TNO assessment study and German proposal with sub-categories proposed by Japan based upon a database of noise levels of Japanese vehicles.

Based on informal documents GRB-54-03 and GRB-55-01, Japan proposes noise limit values with some modification of the threshold of sub-categories as a possible basis for reaching a common position.

Proposal based on Informal document GRB-54-03 submitted by the expert from Germany and on Informal document GRB-55-01 submitted by the expert from Japan, including limit values with some modification of threshold of subcategories, which could be the basis of a common position.

Proposal to amend the classifications of vehicle type in the consolidated version of the proposal for draft 03 series of amendments to Regulation No. 51.

There are two types of N1 having GVM<2.5t. One is front engine type. The other is a flat front vehicle with the engine under the seat and typical in Asian countries. Japan proposes that the sound limit of the latter type should be considered since the sound characteristics of the vehicles are same as that of the N1 having GVM<2.5t.

Japan opposes the inclusion of specifications for Acoustic Vehicle Alerting Systems (AVAS) as contained within the consolidated proposal for the 03 series of amendments to UN R51 (GRB-58-04). AVAS specifications are actively under development as a new GTR and therefore, Japan cannot accept their definition under UN R51 until the GTR deliberations have been concluded.

Proposal to amend the classifications of vehicle type in the consolidated version of the proposal for draft 03 series of amendments to Regulation No. 51. There are two types of N1 having GVM<2.5t. One is front engine type. The other is a flat front vehicle with the engine under the seat and typical in Asian countries. Japan proposes that the sound limit of the latter type should be considered since the sound characteristics of the vehicles are same as that of the N1 having GVM<2.5t.

Input for drafting provisions to introduce procedures for real-driving testing.

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.