Proposal to establish items for the 08 series of UN R10: address immunity-related functions required by multiple UN Regulations through discussion of whether to include these features in UN R10 or relocate electromagnetic compatibility provisions to individual UN Regulations; amend test procedures for complex systems including steer-by-wire, brake-by-wire, and ADAS features to establish clear protocols and reduce unlevel playing field items; improve the general approval process through precise vehicle type description and definition of high-level objectives; describe dwell time selection through ISO standard 1154 as minimum; discuss ISO 17025 evaluation principles; discuss antenna position at 3m versus 10m for best-case and worst-case scenarios; and require robust electromagnetic compatibility protection with critical details described in test reports and information documents.

The Netherlands proposes introducing a separate part 2 addressing immunity-related functionality on lateral movement for steer-by-wire and automated driving systems. Harmonics should be tested when issues are observed; in the cited example, step sizes above and below 745–755 MHz and harmonic frequencies at 1500 MHz and 375 MHz require testing. UN R10 should address specific immunity features across multiple UN Regulations, or references should be moved to individual regulations. Test procedures for complex systems like steer-by-wire and brake-by-wire require improvement, including clearer protocols and discussion of specialized technical units. Dwell time must be sufficient to observe all potential fail criteria in agreement between manufacturer and technical service. Antenna switching during testing at 3m versus 10m positions should be forbidden. EMC shielding must be robust and durable, excluding non-integral ferrite blocks and loose components, with critical details recorded in test reports.

Proposal to require test reports provided by manufacturers to comply with paragraph 3.3. and to be attached to the test report of the technical service.

Proposal to insert a new definition of functional test configuration, amend para. 2.1.1.2. to clarify that test conditions are agreed between manufacturer and technical service and that tables provide guidance which may be extended or amended depending on vehicle characteristics, add tables specifying basic vehicle test conditions for “50 km/h mode,” “Brake mode,” and “Active ADS Mode,” add an alternative “Brake mode” with active ADS for vehicles where braking mode cannot be applied with ADS operational without ADS feature(s) activated, add AECS and AVAS test condition tables, and insert a new table cross-referencing UN Regulations with specific provisions and test configurations to demonstrate compliance with UN R10.

Proposal to amend Table 2 in Annex 4, paragraph 4.3. to add “Scanning receiver parameters” as heading and add footnote b to minimum dwell time columns stating the selected dwell time shall, in addition, consider the cycle time of certain vehicle functions, e.g. the wiper system, amend Table 2 in Annex 5, paragraph 4.3. to add “Scanning receiver parameters” as heading and add footnote a with identical language, and amend Annex 6, paragraph 4.1. to add language that the selected dwell time shall, in addition, be sufficient for the observer(s) to assess all related vehicle functions, while also considering the cycle time of certain vehicle functions, e.g., the wiper system.

Proposal to insert new para. 3.3. requiring that the use of non-durable protection shields (e.g., non-integral ferrite blocks, aluminium foil) shall be prevented, and if used, shall be duly described in the information document and test report.