Comments on document GRE-84-16 submitted by the SLR informal group.

Proposal to correct requirements for type-IIA (endurance braking performance) tests.

12. The expert from IWG SLR presented draft modifications to UN Regulation No.149 that would be finalized under stage 2 of the simplification process (GRE-83-24 and GRE-83-25). The expert from Poland expressed concerns about the photometric requirements envisaged by IWG SLR (GRE-83-43).

29. Based on a proposal of IWG SLR, GRE continued its deliberations for preparing a new series of amendments to UN Regulation No. 48 with new requirements for headlamp aiming and automatic levelling (ECE/TRANS/WP.29/GRE/2020/8/Rev.1). The expert from Poland held the view that the justification part contained mistakes and inconsistencies and recalled his earlier proposals on the subject (GRE-83-41). Several experts expressed their support to the IWG SLR proposal.

30. The expert from OICA proposed to keep an option of manual levelling (ECE/TRANS/WP.29/GRE/2020/23 and GRE-83-31). Some experts supported this option, while others were not in favour.

31. In the absence of a consensus, GRE stressed the need to finalize the issue as soon as possible and requested IWG SLR to take into account the comments made and to prepare a revised working document for the next session, based on the following principles:

• the aiming diagram agreed at the eighty-first session of GRE (Annex II to ECE/TRANS/ WP.29/GRE/81);
• automatic levelling;
• manual levelling, only if a consensus is reached within IWG SLR.

33. GRE instructed IWG SLR to organize a separate meeting on this issue and encouraged all experts of Contracting Parties to participate.

Proposal to correct requirements for type-IIA (endurance braking performance) tests.

67. The expert from Poland introduced GRVA-07-67 proposing correction to the table in para. 2.1.1. of Annex 4 in Regulation No. 13. GRVA requested the secretariat to distribute the document with an official symbol at the February 2021 session of GRVA.

30. The expert from Poland requested deferral of discussion on the belt-guide, that was type approved by the authority of her country, to the December 2020 session of GRSP due to the research test results on the belt-guide, which had not yet been made available by the expert of EC. The experts from the Netherlands and ANEC/CI argued that discussion was needed on this subject since they considered this type of CRS as dangerous. The expert from the Netherlands introduced GRSP-67-05 explaining that the belt-guide was not in the scope of the UN Regulation and could not be type approved; as such, the type approval should be withdrawn. Finally, with reference to the procedure of the 1958 Agreement, Revision 3, Articles 4.2., 10.4 and Schedule 6 (paragraphs 2 and 3), he stated that through GRSP-67-05 he sought support from other contracting parties and cooperation from the expert of Poland to avoid starting the arbitration process – according to Schedule 6 of the 1958 Agreement. The expert from ANEC/CI, introduced GRSP-67-10 and GRSP-67-36 showing the high risk of abdominal injuries in both cases due to severe submarining. In anticipation of the above-mentioned test results, the expert from Poland introduced GRSP-67-32, showing some results of tests demonstrating the performance of this belt-guide type under laboratory conditions. She also clarified that the belt-guide was type approved according to Supplement 10 to the 04 series of amendments. However, she added that according to some stakeholder opinions, this belt-guide type should had been tested according to Supplement 11, thus making the device subject to different criteria. However, she stated that in her opinion there was a clear legal basis which demonstrated that the type approval granted under Supplement 10 was the correct one. The expert of the Netherlands responded by stating that, apart from the fact that this device does not comply with several requirements of UN Regulation No. 44, a supplement only clarifies existing requirements or test procedures and does not introduce new requirements. Even when Supplement 10 was in force, it was evident that a belt guide could not be approved as a child restraint.

31. The expert from EC recalled to GRSP, that the group had agreed to his former proposal (ECE/TRANS/WP.29/GRSP/2019/28) to amend the scope of UN Regulation No 44 (Child Restraint Systems) with clarification that a belt-guide cannot be approved under Regulation 44 without being part of a child restraint system (see ECE/TRANS/WP.29/GRSP/66, paragraphs 27 and 28). However, he explained that EC had reconsidered the document submission to WP.29, since the interpretation that a “guide strap” and similar devices cannot be separately approved as a child restraint system, had already been endorsed by WP.29 at its March 2012 session (see ECE/TRANS/WP.29/1095, paragraph 35). Therefore, he introduced GRSP-67-31, that was only on the phase out of UN Regulation No. 44.

32. The Chair of GRSP referred to Schedule 6 of the 1958 Agreement, and stressed full consideration of the different opinions of the Type Approval Authorities of the concerned contracting parties, and of contracting parties applying UN Regulation No. 44. Therefore, the experts from France, Germany, Italy, Russian Federation, Spain, Switzerland and United Kingdom explicitly endorsed the request of the expert from the Netherlands to withdraw the type approval granted by Poland on the belt-guide, while none of the other present delegates indicated abstention or disagreement. The experts also noted that the Chair encouraged the expert of the Netherlands to continue discussions with the Type Approval Authority of Poland to seek cooperation with Poland in the aim to avoid the arbitration process according to Schedule 6 of the 1958 Agreement, which would start in the November 2020 session of WP.29.

33. GRSP also considered GRSP-67-14, tabled by the expert from France to correct a date in transitional provisions. Finally, GRSP adopted GRSP-67-14 and GRSP-67-31, as reproduced in Annex V to the session report. The secretariat was requested to submit the two proposals as draft Supplement 18 to the 04 series of amendment to UN Regulation No. 44, for consideration and vote at the November 2020 sessions of WP.29 and AC.1.

Proposal to add a reference to the installation parameters of the licence plate illumination lamps determined during their type approval process. Every type-approved device or pair of devices have their own geometrical position in relation to the rear registration plate which is determined based on the illumination levels, maximum gradient value, angles of visibility and light incidence angle. This proposal would introduce a reference to these parameters in UN R48.

21. The expert from Poland proposed adding a reference to the installation parameters of the licence plate illumination lamps (ECE/TRANS/WP.29/GRE/2020/2). The expert from OICA commented on the proposal (GRE-83-44). GRE adopted the proposal unamended and requested the secretariat to submit it for consideration and vote at the March 2021 sessions of WP.29 and AC.1 as draft Supplement 14 to the 06 series of amendments and draft Supplement 1 to the 07 series of amendments to UN Regulation No. 48.

Proposal to clarify that it is not necessary to require an ISO 10844 asphalt track surface in cases where the vehicle is at a standstill provided that the surface is dense and without substantial absorption characteristics.

11. The expert from Poland proposed to allow surfaces other than ISO 10844 for measurements in standstill condition (GRBP-71-28-Rev.1). GRBP adopted the proposal, as contained in Annex V, and requested the secretariat to submit it to WP.29 and AC.1 for consideration and vote at their June 2020 sessions as a draft Supplement 2 to the 01 series of amendments to UN Regulation No. 138.

Proposal to discuss Supplement 18 to 04 series of amendments to UN R44 in lieu of a specific child restraint system that would fall outside the scope of the regulation

The IWG-VGL group proposed that the CoP requirements would be the same as for the type-approval. Therefore, Poland will not support the proposal to extend them by another 0.4%.

31. The expert from IWG SLR recalled the previous discussions on the aiming diagram in paragraph 6.2.6.1.2. (ECE/TRANS/WP.29/GRE/81, para. 10 and Annex II) and presented GRE-82-25, which had been prepared in line with the GRE request. The expert from Poland proposed a revised diagram (GRE-82-43). For the diagram in GRE-82-25, the experts from Japan, Poland and the United Kingdom expressed their preference to maintain the 2000 lm criteria for automatic levelling and headlamp cleaning. The experts from Germany and the United Kingdom pointed out the need to consider the aiming tolerance for the purposes of, respectively, Periodic Technical Inspections (PTI) and Conformity of Production (CoP). GRE requested IWG SLR to consider the above elements and to prepare a revised document for the next session of GRE.

Proposal to include daytime running lamps in the provision for ‘an assembly of two independent lamps to be type approved as lamp marked “D”’.

50. The expert from Poland proposed to add a reference to DRL in paragraph 4.4.1. of UN Regulations No. [148] (GRE-82-10-Rev.1). The expert from IWG SLR stated that this proposal would be included into the consolidated package of amendments to the above UN Regulation.

Proposal to align UN R48 with provisions in UN R4 by introducing parameters for luminance levels, maximum gradient value, angles of visibility and light incidence angle which are necessary to determine the geometric position of devices in relation to the rear registration plate.

27. The expert from Poland proposed modifications to provisions on the rear registration plate lamps (GRE-82-08). Following a brief exchange of views, GRE invited the expert to submit a formal document for consideration at the next session.

Proposal to clarify the definition of “‘on’ time” (t_H) to address cases where a single flash consists of several flashes.

38. The expert from Poland proposed to clarify the definition of the “on” time for the case of a group of flashes (GRE-82-09). The expert from GTB pointed out that the GTB Working Group Photometry had recently considered an alternative wording for the same purpose. GRE invited both experts to submit a new proposal to the next session.