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.

Draft proposal to align the Regulation with the latest regional requirements (e.g., Euro 7) as submitted to GRPE (Informal document GRPE-92-09e).

Small Volume Manufacturers (SVMs) are defined as manufacturers producing fewer than 10,000 M1 or 22,000 N1 vehicles annually in the European Union. Ultra Small Volume Manufacturers (USVMs) produce fewer than 1,000 vehicles annually. SVMs receive exemptions from certain systems and testing requirements, including OBM, EEEDWS, and OBFCM installations for M1 and N1 vehicles. Type approvals granted before July 1, 2030 remain valid. In-service conformity checks are not mandatory for SVMs.