The document presents OICA data on rear direction indicator (DI) and stop signal visibility compliance. It evaluates various lamp configurations against UN R48 and UN R148 requirements, examining criteria including photometry areas outside 25mm from stop lamps, DI apparent surface size, separation distances, and intensity ratios. OICA proposes that compliance requirements are met when DI apparent surface equals or exceeds stop lamp surface, intensity exceeds stop lamp by 25% minimum, separation distance reaches 20mm minimum, or DI apparent surface equals or exceeds 30cm.

Proposal to amend UN R48 and UN R148 regarding direction indicator visibility when grouped with stop lamps. OICA proposes replacing Germany’s masking-based approach with objective, installation-level acceptance criteria: apparent surface area comparison, luminous intensity ratio at HV of at least 25% higher, or absolute apparent surface of 30 cm². Physical masking eliminates measurement uncertainty and improves test repeatability. Three alternative compliance routes provide flexibility without constraining designs.

OICA opposes proposed amendments to UN R48 paragraph 5 that would prohibit lighting devices not explicitly listed in paragraph 6. OICA contends the prohibition creates unnecessary manufacturer burden without safety benefits, conflicts with nationally permitted lamps, and falls outside the 1958 Agreement’s harmonization scope. OICA argues national enforcement, not type-approval restrictions, should manage device installation.

OICA presents research findings on direction indicator perceptibility when stop lamps activate simultaneously. Key findings indicate that spatial separation between functions, increased direction indicator intensity, and relative signal dominance improve perception. Research shows stop lamp luminance can reduce direction indicator recognition, particularly in near-field viewing. OICA concludes that minimum size requirements proposed in the German proposal exceed available evidence and may create unintended consequences without demonstrated safety benefits.

OICA opposes introducing a regulatory requirement for horizontal adjustment of passing-beam/driving-beam and for AFS/ADB to the current SLR agenda. The proposal does not contribute to simplification of lighting regulations, no identified safety concern or ambiguity justifies this requirement, and it lacks a formal proposal from a Contracting Party, NGO, or other stakeholder. The SLR group is managing several longstanding unresolved issues, and introducing this topic risks further delaying progress. Harmonized requirements require comprehensive understanding of Periodic Technical Inspection specifications across all Contracting Parties, which are currently unavailable.

Proposal to clarify the wording regarding the manual deactivation of headlamps. National use requirements are not harmonised and prescribe different scenarios for the use of the dipped beam headlamps. In the case where automatic activation is overridden and the headlamp switch is manually put into the ‘OFF’ position, the paragraph provides for a clear driver message that the headlamps are turned off when ambient conditions change to night time driving conditions.

Proposal for provisions concerning headlamp switching.

OICA request for changes to the (as yet unpublished) report of the 7th VGL informal group session.

OICA proposal for modifications to the justification explaining the VGL informal group proposal defining limits for the headlamp aiming diagram.

Updated version of the OICA proposal including corrections proposed by Italy.