The change request seeks clarification that “real-time” operational and tactical functions of the DDT, particularly “sensing and perception” and “planning and decision”, could be achieved through real-time sensor inputs alone or through integration of sensor inputs with other contextual information such as map-based data, to aid technical inspectors during testing and assessment of ADS systems.

The ADS regulations (GTR and UNR) include definitions for reporting thresholds based on EDR triggering. Time-series data recording for heavy vehicles under UN R169 requires triggers and trigger thresholds to record data in specified time periods, which may not immediately precede, follow, or coincide with crashes. Last Stop, Safety Systems, and Sudden Deceleration triggers are unreliable crash indications. Sudden Deceleration is too sensitive for storing time-series data over several months. Optional SRS or a new independent trigger alongside Detected Collision offers the only viable possibility for effective time-series data recording.

Australia proposes to amend para. 2.14. to clarify that the nominal Peak Braking Coefficient value is understood to be the minimum value, and to amend para. 5.2.1.1. to simplify collision warning requirements for vehicles of category M₁. Industry objects the para. 2.14. amendment as unnecessary and potentially subject to misinterpretation as a requirement change. Industry agrees with dropping the 0.8-second prior warning requirement but finds the resulting text difficult to understand and proposes alternative wording that harmonizes para. 5.2.1.1. with paras. 5.2.2.1. and 5.2.3.1., specifying that a collision warning shall be provided no later than the start of emergency braking intervention.

This document contributes to consolidated text and a risk catalogue for artificial intelligence in the automotive sector. It defines AI as a field of computer science focused on creating systems capable of performing tasks requiring human intelligence, including learning, reasoning, problem-solving, natural language processing, and decision-making. High-priority AI use cases include perception, planning, and motion-control driving functions, as well as driver assessment systems. The document identifies 14 risks organized across five lifecycle stages: AI and use case specification, model architecture and training processes, data specification and management, verification and validation, and operation and in-use monitoring. It provides detailed risk descriptions and references emergent practices for managing these risks, including ISO/PAS 8800, NIST AI RMF, and EU AIA approaches. Lower-priority use cases referenced include AI-06-09 for periodic technical inspection and AI-06-12 for cybersecurity threat detection.

Proposals for revisions to Section I including highlighted deletions, addition of two paragraphs (2.3, 2.4) in Section II with a request to add safety benefits to para. 2.6, editorial requests for text placement in Section III introducing use case content, small editorial proposals in Section IV’s introduction, merging of whole lifecycle and organizational risks, removal of para. 4.6 (systematic performance disparities) in favour of para. 4.5, revision of para. 6.2 (concept drift), removal or moving of para. 6.5 to whole lifecycle risks, and substantive suggestions in Section V for deletion, merging and restructuring of Table 2 with standard and title references only. Annex 1 critiques the need for extended descriptions.

In-direct plus is a sensing system that, in addition to its indirect sensing functionality, has the ability to detect the presence of a live person inside the vehicle by means of sensing human attributes such as movement, temperature, sound, weight or any other sign of life. Direct sensing system detects the absolute presence of a human inside the vehicle by means of tracking heartbeat, respiration, movement, or any other sign of life. Indirect sensing system derives the potential presence of a subject or object inside the car based on logic using information such as door opening, pressure or capacitive sensing.

The IWG is discussing the time interval from door lock to initial warning, with options of 15, 25, or 30 seconds as specified in para. 6.4.1. Investigation of door vibration effects during closing at three speeds (strong 3 m/s, medium 2 m/s, weak 1.2 m/s) on a medium SUV showed door vibration diminishes around 10 seconds. The system requires at least 3 times respiration cycles for accurate child detection judgment to reduce false-positive warnings in the field. A 25 seconds delay is recommended to allow appropriate time for accurate detection while accounting for vehicle vibration disturbance.

IWVTA, established in 2017 under UN R0 and the 1958 Agreement, extends mutual recognition from individual vehicle systems to whole vehicles, reducing duplication while preserving safety and environmental standards. Key benefits include simplified approval procedures, reduced testing and administrative costs, and improved time-to-market through a single coherent whole-vehicle approval framework based on UN Regulations. IWVTA acts as a convergence tool between different regulatory systems and offers a flexible framework for emerging markets. Main obstacles include that IWVTA is not yet global, with limited coverage, uneven acceptance, and complexity of introduction.

Unlock refers to transition of a doorlatch system into a state in which operation of the latch-release control is no longer inhibited, allowing the latch to disengage from the striker. Unlatching refers to transition into a state in which the latch and striker are no longer capable of withstanding separation forces, thereby allowing the door to move away from the vehicle body structure. Opening refers to the action by which a door is moved from its closed position to an open position through mechanical force or energizing an actuated device. Child Safety Lock System is a locking device which, when engaged, prevents operation of the interior door handle or other release device.

Clarifications to definitions: “Child-Safety Lock System” to clarify that it prevents unlatching when engaged, regardless of unlock state; amending “Unlock” to specify that child safety lock systems remain effective; amending “Unlatch” to define it as the transition where latch and striker no longer withstand separation forces; adding definitions for “Door Opening”, “Latch release control”, “Door handle”, and “Retractable door handle”.

Proposal to amend UN R11 to modify scope and definitions regarding vehicles of categories M₁ and N₁, introduce provisions for Automated Driving Systems, revise door operation requirements including exterior and interior latch release controls and door handles, add performance requirements for power-assisted systems and intuitive operation, amend provisions on door locks for side rear doors and back doors, include new definitions for latch release control, door handle, retractable door handle, unlock, unlatch, door opening, and power loss, add transitional provisions for the 05 series of amendments, and introduce new test procedures in Annex 7 for power loss events with interior and exterior door opening procedures requiring demonstration of door functionality within 60 minutes of power disconnection and at least five opening cycles. The amendments apply to supplement 3 of the 04 series for vehicles of category X and the 05 series of amendments to UN R11, based on justifications in GRSP-79-19 and GRSP-78-48.

Proposal to amend para. 1.1. to clarify that the Regulation applies to vehicles of categories M₁ and N₁ with respect to latches, door retention components, latch release controls, and door handles to prevent the risk of occupants being thrown from a vehicle and to ensure evacuation at emergency events, insert new paras. 2.30. to 2.36. defining latch release control, door handle, retractable door handle, unlock, unlatch, door opening, and power loss, insert new para. 5.4. establishing exterior and interior door operation requirements, insert new para. 6.4. establishing requirements for latch release controls and door handles to be intuitive and to remain capable of operating after power loss for at least 60 minutes, and insert new Annex 7 establishing a power loss test procedure to verify door opening systems remain functional following an emergency event leading to loss of the vehicle’s ordinary power supply.

Proposal to clarify the EDR trigger input in the case of vehicles approved to UN R169 (M₂, M₃, N₂, N₃) equipped with airbags (Supplemental Restraint Systems).

Comments on the proposal for a03 series of amendments to UN Regulation No. 160. Modifications include renumbering paragraph 2.2 as paragraph 2.25, deleting paragraph 2.25, and amending definitions for “End of event time,” “Engine throttle, percent full,” “Non-volatile memory,” and other terms. New paragraphs 2.71–2.82 introduce definitions for rollover protection system, advanced emergency braking system, blind spot monitoring system, and driver assistance systems. Paragraphs 5.3.1, 5.3.2, and 5.3.3 are amended to clarify triggering and locking conditions for rollover events and vulnerable road user events, and to establish time zero. Paragraph 5.4.3 clarifies crash test requirements.

Flicker measurement: a) reduction of observation time and suppressing Plt limit, b) adapting ESA limit specification aligning with the vehicle requirement, c) suppression of manual switching test, d) Improving measurement consistency between laboratories and clarify test conditions.

Proposal to improve measurement consistency between laboratories and clarify setup conditions.

Proposal to insert new paragraph 5.3. into UN R178 (Emergency Lane Keeping Systems). The new paragraph requires that the effectiveness of ELKS shall not be adversely affected by magnetic or electrical fields, demonstrated by fulfilling technical requirements and respecting transitional provisions of the 06 or any subsequent series of amendments to UN R10. This proposal aims to ensure Electromagnetic Compatibility and make the reference future proof for potential ELKS requirements in future series of amendments to UN R10, based on GRVA-24-05/Rev.2.

The proposal revises UN R10 paragraphs 3.1.8, 6.10.7 to clarify that intentional emissions from approved RF transmitters are excluded from emission limits when installed per manufacturer instructions without modification. New paragraph 3.1.9 requires risk assessment documentation for radio equipment installations.

OICA opposes inclusion of four roadmap items in UN R10.08 amendments based on WP.29 principles for evidence-based rulemaking. Items 2 and 2bis (radiated emissions below 30 MHz) fail reproducibility standards, lack validated test methods for all vehicle categories, and rely on standards not applicable to internal combustion engine vehicles. Item 3 (16 GHz range) violates the requirement for specific standard versions as CISPR 12 lacks finalized methodology. Item 4 (variable driving conditions and 4-side antenna assessment) presents measurement reproducibility concerns. OICA recommends deferral pending publication of validated international standards.

OICA proposes that Roadmap Items 2, 2bis, 3, and 4 be withdrawn or deferred until relevant international standardization bodies publish validated methodologies. OICA opposes radiated emissions requirements below 30 MHz in driving and charging modes, radiated emissions in the 16 GHz range, and variable driving conditions assessments, citing lack of technical rationale, absence of published international standards, poor reproducibility for large vehicle categories M₃ and N₃, and inconsistency with WP.29/2024/39 reproducibility standards. New R10.08 work items must demonstrably enhance safety, align with published international standards, and maintain regulatory stability per ECE/TRANS/WP.29/1044/Rev.3 and WP.29-196-07, WP.29-196-26, and ECE/TRANS/WP.29/1182.

Proposal to amend Annexes 11 and 17 to specify an observation time of 2.5 min for quasi-stationary equipment as defined in Table 4 of IEC 61000-3-2, with the equipment operating in the mode expected to produce the maximum total harmonic current under normal operating conditions. Currently, UN R10.07 does not specify an observation time, which may lead to different interpretations of the test method and case-by-case agreement during type approval. Specifying 2.5 min would provide a consistent observation and averaging period for vehicle and ESA type-approval tests without changing existing test conditions, limits, or evaluation method.

During IWG-EMC 53rd meeting, Dutch delegation referenced the 2018 Stint accident in proposals to extend UN R10 radiated emissions below 30 MHz and immunity below 20 MHz requirements. Official forensic investigation reports by TNO and Dutch Safety Board ruled out electromagnetic compatibility as a causal factor. The Stint’s drive system was fully immune under UN R10 Annex 6 at 40 V/m. Level-crossing infrastructure fully complied with EN 50121 railway EMC standards. True root causes were mechanical, electrical, and homologation failures including braking deficiencies, electrical throttle flaw, and vehicle instability. OICA recommends rejecting any expansion of UN R10 scope based on this incident.

Proposal to amend virtual distance to assessment of virtual distance and amend monitor to assessment of virtual distance. The amendments ensure text robustness and alignment between GTR 22 and UN R154/04. The monitor was copied from Part A families and is not mentioned in Part C. The Battery cell characteristic includes the REESS as part of the Family concept.

The document addresses Part C verification of virtual distance for heavy-duty vehicle batteries. OICA reports pilot phase results from Volvo Group and Daimler Truck AG testing measurement procedures and accuracy under driving and stationary conditions. Key findings show measurement accuracy decreases significantly at lower power levels, with deviations of 0.3% to 4% at higher power. PTO system characteristics influence accuracy; internal PTOs performed better than bodybuilder-installed units. The document identifies challenges including formula correction needs, PTO family concept complexity, and proposes further testing before finalizing Part C requirements.

Consolidation in Supplement 11 includes: clarification of Verification/Adjustment and editorial corrections with transitional provisions (GRBP/2025/20 with GRBP-82-07); correction of Tyre Road Sound Measurement for Indoor-Testing (GRBP-82-22); introduction of ASEP in Annex 7 for BEVs and HEVs (GRBP/2026/4 with GRBP-83-xx); update of ISO standards in Annex 3 and Annex 8 (GRBP/2026/5 with GRBP-83-xx); and reference for Power Definition regarding new UN R177 (GRBP/2026/13). The consolidated version of Supplement 11 is to be submitted to the 199th WP.29 in June.