Clarification request of the consolidated text of paragraph 6.5.10 as amended
by supplement 4

Proposal to amend UN Regulation No. 121 by inserting new paragraph 5.2.1.1 stating that fonts shown in Table 1 are not intended to be restrictive and other fonts may be substituted if legibility is maintained. Table 1, Note No. 20 is amended to clarify that the font of letters “OFF” or “ESC OFF” is not intended to be restrictive. The purpose is to clarify the text, provide flexibility, harmonize with international standards, and adapt to current digital work tools.

Proposal to amend para. 2.5.2. to change the lower vertical datum point from 5 above the horizontal to 4 above the horizontal, and amend Figure 3 to reflect this adjustment. The modification harmonizes the location of the lower datum point with the angle of obstruction requirement and resolves an inconsistency in UN Regulation No. 43.

Proposal to amend para. 5.1.1.3. to adjust the lower vertical datum point from 5 degrees to 4 degrees below the horizontal and update the corresponding figure in Annex 4, Figure 1. This harmonizes the location of the lower datum point with the angle of obstruction requirement in para. 5.1.3., resolving an inconsistency between the allowed area of obstruction and the mandated transparent area of the windscreen.

Proposal to align UN R43 with a proposed amendment to UN R125 (ECE/TRANS/WP.29/GRSG/2026/23), which resolves a longstanding inconsistency between the lower datum point definition (§5.1.1.3) and the obstruction requirement (§5.1.3) by harmonizing the lower datum point angle from 5° to 4°.

Proposal to resolve a longstanding inconsistency in UN R125 between the lower datum point (§5.1.1.3, set at 5°) and the obstruction requirement (§5.1.3, set at 4°), by aligning the lower datum point to 4° while retaining upper and lateral aspects of §5.1.1. unchanged. The 5° datum point has never been used for any technical requirements beyond serving as a reference point, while the 4° obstruction requirement has prior precedent. As this is a vehicle rather than component requirement, the datum point is also proposed for deletion from UN R43, retaining it solely in UN R125.

Proposal to amend UN R167 to address Automated Driving Systems (ADS), exempting category Y vehicles and category X vehicles without a manual on-board mode from the regulation’s scope, while requiring ADS-equipped vehicles to comply when operated manually. Additional amendments update references to the three-dimensional H-point machine per Mutual Resolution No. 1, and revise approval marking provisions to remove the Unique Identifier option.

Proposal to insert new para. 5.2.1.1. stating that fonts shown in Table 1 are not intended to be restrictive and other fonts may be substituted if legibility is maintained, and amend Table 1, Note No. 20 to delete the statement that the font of the letters “OFF” or “ESC OFF” is not intended to be restrictive.

Correction to the justification provided in GRSG/2026/37.

Proposal to amend UN R105:

• Modify para. 5.1. to reflect new structure adopted for ADR 2027 by modifying the table of technical specifications,
• amend para. 5.1.1.8. to replace “electrical circuits” with “electrical systems” and add provisions for electronic features,
• amend para. 5.1.1.8.2. to add requirement for additional control device for vehicles equipped with Camera Monitoring System according to UN Regulation No. 46,
• amend para. 5.1.3.5.1. by deleting external signal requirements,
• amend para. 5.1.3.6. and renumber para. 5.1.3.7. to 5.1.3.6.,
• insert new para. 5.1.7. to require motor vehicles and trailers with maximum mass exceeding 3.5 tonnes to be equipped with tyre pressure monitoring systems according to UN Regulation No. 141 as amended by at least 01 series,
• insert new para. 10.7. containing transitional provisions applicable from official entry into force and from 1 January 2029,
• amend Annex 2 to update approval number series from 07 to 08.

Supporting presentation for proposals to remove para. 6.2. and Annex 9A, remove para. 6.3. and Annex 9B, remove para. 6.5. and Annex 9E including Appendix 1, remove para. 6.10. and Annex 9J, exempt from isolation resistance measurements after each test, allow sequential execution of over-discharge and overcharge tests, remove standard cycle after each test, unify thermal event warning requirement by removing para. 6.14., and allow alternative conditions for ambient temperature for SOC adjustment. The document also proposes guidance on REESS type definition.

Proposal to streamline the Regulation by eliminating redundant requirements and their test procedures as well as to clarify the possible alternative methods to improve the efficiency of the tests: Delete paragraphs 6.2. and 6.3., delete paragraph 6.5., delete paragraph 6.10., reserve paragraphs 9A, 9B, and 9E, delete paragraph 6.14., amend paragraph 6.15. to add comprehensive thermal propagation verification procedures including risk management analysis alternatives, add paragraph 6.16. for REESS and vehicle communication compatibility, add new Part III (para. 7.) for approved REESS installation requirements, renumber existing paragraphs 8.–13. as paragraphs 8.–13. and add corresponding section numbering, amend scope provisions to clarify application to vehicles of categories M, N, and O with specified e-axle battery provisions, add vehicle category O definitions including “e-axle” and “trailer load compartment,” amend various paragraphs to reference vehicles of categories O₃ and O₄, amend protection requirements to include trailer load compartments, amend over-discharge and overcharge test procedures to permit sequential execution, amend isolation resistance measurement requirements to exempt measurement when isolation resistance monitoring systems are installed and confirmed functional, clarify SOC adjustment procedures to permit alternative ambient temperatures when highest SOC is achievable independently, add labelling requirements for vehicles of categories M₂/N₂ and M₃/N₃ in accordance with ISO 17840-4:2018, add provisions for Automated Driving System (ADS) features and warnings, add provisions for vehicles of category Y regarding mechanical integrity validation at component level, amend Annex 1 Part 2 to revise installation restriction references, add Annex 9K describing four thermal propagation trigger methods with four appendices, and add Annex 10 specifying label provisions for electric power train vehicles.

Proposal to provide guidance for interpretation of “Type of REESS” (Rechargeable Electrical Energy Storage System) as defined in UN R100 para. 2.48. The document establishes that differences in REESS should be evaluated from the perspective of substantial impact on safety performance. It describes key elements for assessing impact on safety within each essential aspect: manufacturer responsibility, cell chemistry/capacity/physical dimensions, cell number/connection/support, casing construction/materials/dimensions, and ancillary devices. The guidance provides examples of changes not causing or potentially causing significant differences, including production location changes, multi-sourcing of cells, and process improvements.

Proposal to insert new paragraphs 0.2. and 0.2.1. to clarify the assessment procedure for door opening and permit the use of an external vehicle lift to return a vehicle to its wheels following the side impact test for workshop health and safety compliance, and insert new para. 5.3.3.1.1. to specify that if necessary the vehicle shall be put back on its wheels and paragraphs 5.3.3. and 5.3.3.1. shall apply once in this condition.

Proposal to insert a new paragraph 0.4. explaining that the second level warning of safety-belt reminders is intended to warn if one safety-belt is unfastened during normal driving conditions as specified in paragraph 5.2.4.1., and that other safety warnings may alert the driver to check overall safety of occupants and stop the vehicle, with the second level warning discontinued per paragraphs 5.2.4.3.(a) to (c)©, and amend paragraph 5.2.4.3. to add a new subparagraph (d) allowing discontinuation of the audible signal when other audible safety warnings are triggered in circumstances of imminent danger where the vehicle has to be stopped.

Updated document with in-session comments.

Proposal to introduce a new paragraph 0.4 clarifying that second-level warnings apply when one seat-belt is unfastened during normal driving, excluding situations of higher priority warnings such as door opening or thermal propagation, to amend the definition of “normal operation” to specify forward motion above 10 km/h without other safety warnings triggered, and modify paragraph 5.2.4.3 to allow discontinuation of second-level warnings when other audible safety warnings are triggered in circumstances of imminent danger.

Proposal to clarify that the parking brake may be actuated while the vehicle is in motion via actuation of the vehicle’s service braking system by means of an auxiliary control which could be an Electronic Parking Brake (EPB) and to promote consistent interpretation of the activation conditions for an Emergency Stop Signal (ESS), including by application of the service braking system via the EPB control.

Proposal to require the approval authority to upload information received from the manufacturer concerning remedial action(s) addressing an ALKS design to the DETA platform and to clarify the use of DETA with regard to ALKS approved under UN R157.

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 insert new sub-paragraph 5.6.1.1.4.1 establishing that requirements of paragraph 5.6.1.1.4 shall not apply to ACSF Category A functions provided they are intended solely to support low-speed vehicle controllability manoeuvres in off-road environments, operate only until 5km/h with 1km/h tolerance, require deliberate driver activation, require driver presence in driver’s seat with fastened safety belt, and allow driver to retain control and override or deactivate the system at any time.

Proposal to amend para. 5.6.1.2.7. to increase the maximum RCP operating range from 6 m to 15 m. UN R79 currently limits the maximum RCP operating range to 6 m, resulting in effective usable range of 2 or 3 m due to radio wave-based ranging inaccuracy. A 15-meter range would enhance RCP function usefulness and safety, reducing driver movement and blind areas. RCP systems with extended ranges have been used in large markets without identified safety threats. The amendment is proposed as a supplement to the 03 and 04 series of amendments to UN R79.

Proposal to insert new para. 3.1.1. and 3.1.2. requiring manufacturers to provide information to approval authorities prior to application and upon extension of type approval; insert new para. 3.2.2. requiring manufacturers to provide summaries of safety definitions, driver safety levels, traffic rules assessment, and testing for each territory where ALKS can be active; and insert new paras. 4.6. to 4.6.6. establishing procedures for approvals covering multiple territories, including notification of receiving approval authorities at least 30 days before approval, review periods, and dispute resolution under the 1958 Agreement. OICA and CLEPA do not support mandatory pre-announcement but would support sharing Safe Operation documentation and lists of compliant territories during the approval process.

Supporting presentation on the proposal to insert a new sub-paragraph 5.6.1.1.4.1 to exempt ACSF Category A functions intended solely to support low-speed vehicle controllability manoeuvres in off-road environments from the obstacle detection requirements of paragraph 5.6.1.1.4, provided the function operates only until 5 km/h with 1 km/h tolerance, is activated deliberately by the driver in off-road environments only, requires the driver to be in the driver’s seat with safety belt fastened, and allows the driver to retain control and override or deactivate the system at any time.

OICA-CLEPA-EME comments on German proposal GRVA-25-07 to require the approval authority granting UN R155 or UN R156 type approvals to use CSMS or SUMS certificates signed by the same approval authority. OICA-CLEPA-EME identify that CSMS and SUMS are Management Systems covering entire manufacturer organizations, and mandating the same approval authority for Management Systems certificates and approvals will have significant consequences for original equipment manufacturers typically using multiple approval authorities in homologation. The submission proposes keeping text unchanged to allow different approval authorities for Management Systems certificates and type approval based on voluntary acceptance, implementing wording on information exchange if different approval authorities are involved, and establishing a horizontal approach for Management Systems with mutual recognition aspects considered.

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.

Proposal to amend GRVA/2026/14 and GRVA/2026/18: insert new paragraph 2.28.1. defining “Highway-like road” as a non-highway section with at least two lanes, designated speed limit of at least 80 km/h, no prohibition of pedestrians and cyclists, physical separation dividing opposite traffic, and no at-grade marked pedestrian crossings, rail crossings, or road intersections; amend paragraphs 5.3.7.2.3.1. and 5.5.4.2.6.5. to address highway-like road operation and withholding of HORs; insert new paragraph 4.2.5.2.16. to Annex 4. specifying testing for longitudinally moving bicycle targets; amend Annex 1. to add items 6.4. and 6.4.1. regarding withholding of HORs; and insert new paragraph 16.2.3. establishing that as from 1 September 2029 Contracting Parties shall not be obliged to accept type approvals issued to the preceding series of amendments for systems capable of withholding HORs on highway-like roads.

Proposal to modify the specified maximum remote controlled parking operating range from 6 m to 15 m. Large markets including Canada, USA, and China do not regulate maximum remote controlled parking operating range. Remote controlled parking systems exceeding 6 m operating range are already offered in the field. Radio wave-based ranging is inherently inaccurate due to complicated and varying electromagnetic environment in garage and changing orientation of remote device, requiring safety margin integration into product design, which reduces effective usable range below 6 m maximum. Extended range remote controlled parking systems have been used in the field for several years without negative feedback or identified safety threats.

Proposal to amend Annex 4 and introduce Annex 7 regarding critical incident reporting:

• Amend paragraph 3.5.4 to require the manufacturer to report critical incidents to the granting type-approval authority
• Insert new paragraph 3.5.4.1 requiring the type approval authority to upload information received from the manufacturer in English language to the secure internet database “DETA” without undue delay but no later than 14 days after receipt
• Introduce new Annex 7 providing guidance for data exchange via DETA in accordance with paragraph 3.5.4.1.

Proposal to insert para. 3.2.2. requiring manufacturers of Automated Lane Keeping Systems active in multiple Contracting Party territories to provide information on traffic rules identification, territory-specific testing, and contact details, insert paras. 4.8. to 4.8.6. establishing procedures for granting approval authorities to inform and consult receiving approval authorities at least 30 days before approval, allow receiving authorities 30 days to comment on regulation interpretation, require dispute resolution under Article 10 and Schedule 6 of the 1958 Agreement, and insert footnote [Y] stating these provisions shall be kept under periodic review by GRVA for amendment as necessary.

Proposal to amend para. 5.1.6.3.4. to specify that the intervention shall generate the signal to activate hazard warning lights and to clarify that for verification of timing requirements applicable to Risk Mitigation Functions, the signal to activate hazard warning lights is deemed to start the intervention, and amend Annex 8, para. 3.6.1.(b) to specify that the signal to activate hazard warning lights is generated at the earliest five seconds after the warning signal specified in para. 5.1.6.3.2. has been generated.

Proposal to insert a new sub-paragraph 5.6.1.1.4.1 to establish exemptions for Automatically Commanded Steering Function Category A functions designed for off-road low-speed vehicle recovery manoeuvres, and amend para. 5.6.1.2.7 to increase the specified maximum Remote-Control Parking operating range from 6 m to 15 m.

OICA proposes amendments to LUPC-09-04: amend para. 2.5.22. to expand the definition of energy status indicator to include information on the operational status of energy transfer and illumination to assist in locating electrical connection; delete existing para. 3.2.10. and its subparagraphs; add new paras. 3.2.10. and 3.2.11. requiring statements on energy status indicator lamps and lamp test mode; and amend para. 6.29.9. to clarify that multiple energy status indicators may be installed, change the flashing frequency limit from 2.0 Hz to 5.0 Hz, and enlarge the maximum apparent surface area to accommodate various plug sizes and surrounding illumination designs.

OICA proposes:

• Amend the heading of para. 2.11.5. to clarify that additional colours are introduced specifically for energy status indication,
• Add colour requirements in para. 5.15. permitting white, amber, red, selective-yellow, indicator blue, or indicator green for energy status indicators, with indicator blue and indicator green reserved for charging, discharging, or scheduling of energy transfer to or from the rechargeable electrical energy storage system,
• Replace multiple charging connector provisions in para. 6.29.9.1. to specify conditions for energy status indicator activation,
• Add para. 6.29.9.1.1. permitting independent activation of multiple energy status indicators,
• Insert para. 6.29.9.6. requiring vehicle manufacturers to declare intended use of indicator blue and indicator green in the information document,
• Add para. 6.29.9.2. establishing observation area intensity requirements and limiting intensity outside this area to 140 cd,
• Amend Annex 14 to include energy status indicators.

PMP Task Force 3b held kick-off on 07.05.2026 to address vehicles with legal limited speed, vehicles unable to follow cycle trace, and vehicles with capped speed by OEM decision. Proposals include adaptation of UN R179 cycle and procedure for vehicles with legal limited speed at 90 kph, with same duration for acceleration, cruise, and deceleration events, same acceleration and deceleration rates, and speed capped when needed. Introduction of such vehicles into brake corner emission families and vehicle types requires methodology to calculate adapted cycle and procedure, including c-factor measurement as alternative to fixed c-factor, and adaptation of Annex 5 procedure.

An improvement intended to increase vehicle robustness in Annex 3 creates more difficulties in RD-ASEP assessment. Small variations in Annex 3 parameters may result in unexpected substantial exceedances in Annex 7. Minimal changes in the calculated tyre share at the anchor point may cause vehicles to fail Annex 7. The regulation should ensure realistic test effort and workload for compliance verification, as current requirements may require up to 180 combinations per type across test tracks, temperatures, driving modes, and tyres.