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.

Document explains concerns about the approach in GRVA/2026/30 to require a single Approval Authority to issue certificates of compliance for Cyber Security Management Systems and Automated Driving Systems Management Systems and vehicle type approval. The proposed changes would lead to double or triple approvals of management systems, creating administrative burden and unresolved legal consequences regarding challenged certificates of compliance and their effects on other issued certificates for the same management system. The submission proposes clarifying existing wording, documenting implications of challenged certificates, and adding a new paragraph 5.1.5. to UN R155 permitting mutual agreement between Approval Authorities regarding certificate usage.

Proposal to amend Article 2, paragraph 2 to clarify that where a Certificate of Compliance required under a UN Regulation and issued by an Approval Authority of another Contracting Party is accepted by a Contracting Party, the Approval Authority granting the corresponding type approval shall remain responsible for all aspects of that type approval. The amendment addresses management systems and their Certificates of Compliance used in UN Regulations such as UN R155 and UN R156.

Proposal to insert a new para. 5.1.12. requiring that whenever an assessment of compliance to a requirement of this regulation is unachievable without reading internal signal(s) of an electronic system, the vehicle manufacturer shall provide instructions and tools to read signals on in-vehicle networks for the technical service to extract and interpret the signal(s), with this information appended to the test report.

Proposal to amend para. 3.4.1. and para. 3.4.4. in Annex 8 to require manufacturers to address how the braking system strategy will not prejudice safe operation due to failures with other systems involved in achieving the function of the system, and insert new para. 4.5. in Annex 6 to require consideration of the effect of implausible wheel-speed information on anti-lock system operation in fault analysis. The proposal responds to a United Kingdom collision involving tyre failure and ABS activation that resulted in unsafe operation.

Status report on e-axle trailer development within GRVA, covering taxonomy, regulatory approach, and progress. The document presents use cases for electric axles in trailers of categories O2, O3, and O4, comparing simplified frameworks for O2 with fully integrated heavy vehicle frameworks for O3/O4. Progress includes updated taxonomy, ISO 11992 standardization work, and completed workshops. Step 2 adoption is targeted for January 2027, with Step 3 planning for O2 trailers to be clarified.

Proposal to amend para. 5.6.1.2.7. to extend the maximum remote control parking (RCP) operating range to a maximum of 15 m if, prior to the operation, a visual message informing the operator of their responsibility is presented to and acknowledged by the operator. The justification notes that RCP systems with ranges exceeding 6 m are already offered in large markets such as Canada and the United States of America, and that such extended-range systems have been used in the field for several years without negative feedback or identified safety threats.

Proposal to insert a new sub-paragraph 5.6.1.1.4.1 to exempt ACSF Category A functions from the requirements of paragraph 5.6.1.1.4, provided that the functions are intended solely to assist the driver in regaining vehicle motion in limited traction conditions in off-road environments up to 5 km/h (+1 km/h tolerance), are activated following a deliberate action by the driver with the driver in the driver’s seat and safety belt fastened, and allow the driver to override or deactivate the function at any time, with the manufacturer to describe system behaviour when operating conditions are no longer met.

Proposal to clarify the provisions
applicable to the type-approval of Risk Mitigation Functions (RMF): Amend para. 5.1.6.3.4. to clarify that the signal to activate hazard warning lights is generated with the start of the intervention and is deemed to start the intervention, amend Annex 8 para. 3.6.1. to specify that hazard warning lights are activated at the earliest five seconds after the warning signal, and amend Annex 8 para. 3.6.2. (Scenarios A and B) to specify the same timing requirement for hazard warning lights activation in tests for RMF bringing the vehicle to a safe stop outside its own lane of travel. The proposal clarifies that the starting time of RMF operation comes with the driver warning and that five seconds should be measured until the hazard warning lights come.

Proposal to amend GRVA/2026/34 proposing to amend para. 5.6.1.2.7. to modify the specified maximum RCP operating range from 6 m to 10 m, with provision to extend to a maximum of 15 m if direct line of sight between the remote-control device and the vehicle is ensured. The justification notes that RCP systems with extended ranges are already offered in large markets without regulatory limits, that radio wave-based ranging requires safety margins reducing effective usable range, and that increased range would reduce blind areas behind vehicles and allow drivers to better monitor surroundings while manoeuvring, reducing risks and increasing overall safety.

Proposal for amendments to the requirements for Automatically Commanded Steering Functions (ACSF) of Category C, introducing specific provisions for the use of a lane change function with a two-step Human Machine Interface (HMI).

Document to provide information on the proposed “3-pillar approach” certification scheme to demonstrate the level of safety and reliability which allows for safe market introduction of automated/autonomous vehicles.

Proposal to allow for the use of the maximum operable steering wheel angle of a steering system’s design in cases where the normalized angle as calculated under the regulation cannot meet the fixed values of the regulation (i.e., between 270 and 300 degrees). The intention is to enable approval of eventual systems (e.g., steer-by-wire) that may use low steering gear ratios.

Proposal to introduce provisions for a “two-step Human Machine Interface” in the requirements for Automatically Commanded Steering Functions (ACSF) of Category C lane-change functions.

Since an Automatically Commanded Steering Function (ACSF) of Category B is required to demonstrate compliance with regard to the warning cascade under testing at low speed, it is proposed to stop the high-speed test after the system has given the optical warning, meaning it has correctly detected the hands to be off the steering wheel.

Proposal to allow a corrective steering function to use haptic signals as an alternative to acoustic signals for M₂ and M₃ vehicles equipped with Lane Departure Warning System compliant with UN R130. The proposal would specify that the haptic warning may not be given solely via the steering wheel (e.g., provided in the driver’s seat).

Proposal to allow for the use of the maximum operable steering wheel angle of a steering system’s design in cases where the normalized angle as calculated under the regulation cannot meet the fixed values of the regulation (i.e., between 270 and 300 degrees). The intention is to enable approval of eventual systems (e.g., steer-by-wire) that may use low steering gear ratios.

Proposal to permit a function to cope with temporary driver inability to control the vehicle (e.g. caused by a health problem). The proposed emergency steering function of type (c) would warn and possibly revive the driver while automatically performing emergency lane change(s) with the aim to bring the vehicle to a standstill in an area with a low risk of collision (“target stop area” e.g. hard shoulder).

Proposal for provisions concerning:

1. B1 lane centering
2. ACSF activation conditions
3. Driver override
4. Clarification of ACSF standby-mode
5. Clarification of “ready-to-intervene"
6. Indication to the driver in case of suppression
7. Clarification of suppression criteria
8. Sensor test before activation.

Proposal to clarify that the AEBS may be automatically deactivated in the event that the electronic stability control system is deactivated.

Proposal to introduce provisions for approving single vehicles involved in modular vehicle combinations, e.g. towing trailers, “road trains”.

Proposal to improve the uniformity of requirements for stop lamp illumination with regard to various types of braking systems, including those of electric vehicles.

Proposal to introduce requirements for endurance braking systems for vehicles equipped with an electric regenerative endurance braking system.

Proposal to permit automatic activation of functions providing continuous lateral and/or longitudinal control after ALKS deactivation.

Proposal to expand the scope to include N category vehicles and to apply the minimum performance for service braking systems (5 m/s²) as required in the 11 series of amendments to UN Regulation No. 13, for vehicles of the Categories M2, M3, N2 and N3. The overall objective of the former Informal Working Group (IWG) on Automatically Commanded Steering Function (ACSF) was to develop technical requirements for Automated Lane Keeping Systems (ALKS). The initial limitation to passenger cars (M1 category vehicles) was agreed in order to deliver within the given timeline. After having successfully accomplished the work for the system in a first step, the automotive industry has now reviewed and examined the existing requirements under the premise of including all vehicle categories M and N.

Proposal to permit lane changes during a Minimum Risk Manoeuvre (MRM).

Proposal to clarify that a continuation of support by a Category B1 ACSF after its boundary conditions have been exceeded may not be possible under conditions as outlined in the manufacturer’s safety concept.

Proposal to

1. Align lane-centering provisions with principles applied to UN R157 (ALKS)
2. Permit Category C ACSF to remain in stand-by during temporary roadway transitions
3. Clarify overriding provision (para. 5.6.4.3) reference to stand-by mode
4. Introduce a tolerance factor for “critical situation” lane changes
5. clarification to test conditions
6. Align direction indicator deactivation under a pass conditions with previously adopted provisions.

Proposal to introduce provisions for truck/trailer data transmission for Category C ACSF.

Proposal to allow continuous movement of the driver as an alternative to the continuous actuation of the remote-control device as a means to assure driver attentiveness.

Proposal to introduce a Risk Mitigation Function designed to bring a vehicle to a safe stop in the event of fallback driver unavailability.

The proposal is to ensure that the adhesion of the road surface will not limit AEBS performance during test.

Proposes to align the wording with regard to “dry road affording good adhesion” also in the 02 series of amendments with the purpose of avoiding confusion with other regulations that might refer to a “dry road” in a different context

Proposal to clarify the different interpretation from Authorities and Technical Services on how the requirements of paragraph 5.2.22.2. are to be understood with regard to the conditions under which the signal is still to be generated.

Proposal to clarify provisions regarding the actuation of the parking brake warning device to cover the case of electric control transmission systems where there may be a transition between parked (applied) and un-parked (released) braking states. The aim is to reduce risks of user confusion by specifying that the warning device would be actuated only after the parking brake has achieved a stable applied state.

Proposal to ensure the continuity of the American Society for Testing and Materials (ASTM) Method E1337 for the measurement of the Peak Braking Coefficient (PBC) in UN Regulation No. 140, by introducing a reference to the new ASTM Standard Reference Test Tyre F2493.

Proposal to clarify the logical cascade of actions relative to ACSF B1 and ACSF C systems:

When the same means is used by the driver to simultaneously activate the Automatically Commanded Steering Function of Category B1 (ACSF B1) and of category C (ACSF C), both functions switch to standby mode when the vehicle enters an ACSF C eligible road. But if the road is non-eligible to ACSF C, then only the ACSF B1 is activated.

With the current text of the regulation, once the vehicle moves to an ACSF C eligible road, the driver must operate again the means to activate the ACSF C. This second deliberate action is confusing for the driver since it makes the manipulation more complex. The current wording actually discourages most drivers from using this assistance function.

The proposed wording permits the following, logical, cascade of actions:

1. The driver has done a deliberate action to activate ACSF B1 and ACSF C (on a non-eligible road); then
2. He drives into an eligible road, and is clearly informed thereof; then
3. He initiates a lane change procedure by activating e.g. the direction indicator.

Proposal to add the text, "In case that saturation of the front tyres happens before the above calculated magnitude angle, this angle may be used as the final steering amplitude, but only if this angle is greater or equal to 6.5 A.” based on the following justification:

1. Reaching fixed amplitude, i.e., fixed steering wheel angular speed due to given 0.7 Hz sine frequency, needs much more torque with quick steering gear ratio systems than with slow steering gear ratio systems, and produces much more wheel steer.
2. Car behavior (yaw rate, lateral acceleration and thus trajectory) is similar for all amplitudes above approx. 7 to 8 A (i.e., more than 7 times the steering wheel angle corresponding to 0.3 g), because front tires are saturated. More steer of the tires doesn’t provide more lateral force, so yaw rate and lateral acceleration don’t increase. Continuing to increase steering wheel amplitude after front tire saturation doesn’t give more information.
3. There might appear in the future some vehicles which have significantly low steering gear ratio (i.e., quick steering characteristics) and may need too much steering wheel torque to achieve the 270 degrees sine amplitude at 0.7 Hz (not reachable by conventional steering robots), then jeopardizing the easy approval of future beneficial steering equipment e.g. steering-by-wire systems.