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.

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.

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.

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OICA proposes that Roadmap Items 2, 2bis, 3, and 4 be withdrawn or deferred until relevant international standardization bodies publish validated methodologies.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.