Proposal to permit the installation of an optional rear-mounted manoeuvring lamp.

Proposal to delete the 2m width requirement for parking lamps.

Comments on the proposal to delete the 2m width requirement for parking lamps.

Proposal to prohibit the inclusion of a manufacturer logo in headlamps under UN R149 and to limit the approval of light-signalling devices with a logo to the 01 series of amendment of UN R149 under UN R48.

Proposal to clarify the requirements for the activation of direction-indicator lamps to ensure compatibility with driver control assistance systems as permitted under UN Regulation No. 171.

Paragraph 5.41 of the proposed amendment to UN Regulation No. 48 introduces a requirement for a physical test drive to verify that an Automated Driving System (ADS) can correctly operate all lighting and light-signalling functions without causing discomfort. While OICA fully supports the objective of ensuring safety and proper functioning of lighting systems under ADS control, we believe this requirement is unnecessary and duplicative in the context of the forthcoming UN Regulation on Automated Driving Systems (ADS Regulation).

Proposal to clarify provision that direction-indicator lamps on one side of a vehicle shall be switched ON and OFF automatically.

Proposal to amend the proposals concerning manufacturer logos.

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.