OICA/CLEPA comments on the proposal to restrict manual deactivation of AEB systems to speeds under 30 km/h, noting cases where, given the current state of the technology, manual deactivation (regardless of speed) is warranted.

This proposal supplements proposal GRRF/2017/23 which amends UN R13, R13H and R140, to allow the use of the ESC tell-tale to indicate the intervention on the steering angle of one or more wheels for the purpose of vehicle stability. The intention allow design options that avoid two optical warning signals (ESC flashing + constant CSF) during an ESC intervention.

Draft proposal to enable the approval of automated emergency steering systems intended to avoid or mitigate collisions. The proposal based on document ACSF-14-07 submitted by OICA and CLEPA which was discussed during the 14th meeting of the ACSF informal group. The square brackets indicates paragraphs which are still under discussion in the informal group.

Presentation on remanufactured brake calipers as part of the discussion on whether such products should be subject to a new UN Regulation separate from UN R90. CLEPA does not believe these products require a new regulation.

Diagram illustrating the phases of a lane-change maneuver as envisioned by the Category C¹ ACSF amendment to UN R79.

Proposal to cease approvals under the 02 series of amendments from September 2020 in order to allow manufacturers adequate time to adapt to the new requirements;

• ESF, ACSF C and unexpectedly ACSF B1 (despite originally assumed to be compatible with ACSF C new requirements),
• new CEL assessment (documentation, tests…) whose scope is also extended to all non-complex electronic systems under series 03.

Regarding the application to “All Types” (e.g. for new registration), industry proposes to leave unchanged the existing vehicles on the market which are approved on the base of national of regional exemptions by Contracting Parties signatories of the UN R79 regulation, given the heavy technical impacts on ACSF C (sensor range…) which are indirectly affecting ACSF B1 systems that were initially assumed to be compatible with cat. C (e.g. 3s hands-off detection instead of 15s, lane centering prior to the lateral movement towards the marking etc.), and the add-on of requirements restricting design possibilities without clear safety benefits (e.g. the use of direction indicators to suppress the procedure).

Proposal to correct Revision 2 of UN R55 to align with the text of Supplement 04 to 01 series of amendments. This proposal removes a subparagraph under paragraph 13.1 that should not have been included in the Revision.

Revision 7 of Regulation No. 13 includes a former version of Figure 1B which was changed with Amend 4 to Revision 6 of UN Regulation No. 13. This correction is also needed for Revision 8, which contains the same error.

CLEPA presentation on the type approval process for replacement brake pads, linings, and drums and the impact of the new approval numbering system adopted under Revision 3 to the 1958 Agreement on approvals and markings of these products.

Proposal to resolve inconsistencies present from Supplement 2 to the 02 series of amendments resulting from the approval of proposals in documents GRRF/2014/23/Rev.2, GRRF/2015/22 and GRRF/2016/22. The proposal also introduces provisions for L category (motorcycle and related) vehicles.

Text prepared by the European Association of Automotive Suppliers (CLEPA) and from the International Organization of Motor Vehicle Manufacturers (OICA) to clarify the references to Regulation No. 10 within Regulation Nos. 13 and 13-H.

CLEPA and OICA proposal to harmonize Regulations Nos. 13 and 13-H with the Federal Motor Vehicle Safety Standard FMVSS 135 on electric vehicle requirements with regard to the regenerative braking system (RBS).

Proposal to align M1 vehicle braking performance requirements with UN R13-H provisions and clarify those for N1 vehicles in Annex 3 of UN R79.

Proposal for collective amendments of amendments to Regulations Nos. 13 (Heavy vehicle braking), 13-H (Brakes of M1 and N1 vehicles), 79 (Steering equipment) and 89 (Speed limitation devices) and the new Regulations on LDWS and AEBS to clarify the references to Regulation No. 10 into the UN Regulations mentioned above.

Proposal to improve the definition of “identical” parts as applied to replacement brake discs and drums and to introduce an “identical” part definition for brake linings. This documents supersedes document GRRF-75-18.

Proposal for amendments to delete provisions for electronic stability and brake-assist systems from UN R13-H as part of their transposition into new stand-alone regulations.

Proposal to transfer brake assist system systems provisions out of UN Regulation 13-H and into a new stand-alone regulation. The proposal arises from a perceived need to simplify UN R13-H to facilitate its application within the proposed international whole vehicle type approval. This document supersedes document GRRF-75-14.

Proposal to transfer electronic stability control systems provisions out of UN Regulation 13-H and into a new stand-alone regulation. The proposal arises from a perceived need to simplify UN R13-H to facilitate its application within the proposed international whole vehicle type approval. This document supersedes document GRRF-75-15.

Proposal to clarify braking requirements and to align them with UN R13-H on light vehicle braking.

Proposal based on informal document GRRF-76-21 to remove all references to Annex 10 from Annex 13 by transferring the provisions concerning vehicles with and without anti-lock braking systems to Annex 10.

Proposal to add a maximum supply line pressure of 900kPa when the compressor is at cut-out during testing of electronic braking systems (EBS). The aim is to prevent trailer EBS failure warnings/shut downs when detecting excessive supply line pressure.

Proposal to clarify the definition of a “variant” in order to avoid unintended interpretations of the certification requirements that could result in additional financial and administrative costs. As currently worded the approval of a Test Group requires individual certification for each part contained within the Test Group. Some Test Groups can contain in the region of 30 part numbers. This would align the practice for brake discs and drums with that for brake linings.

Proposal to clarify the text in order to avoid additional administrative and financial costs to the applicant due to misinterpretation of the intent of the text.

Proposal to clarify and align the wording of Regulations Nos. 79, 13-H and 13.

The current text of Annex 3 of UN Regulation No. 79 covers requirements to be met in case the braking and the steering systems have the same energy source (paragraph 5.3.1.4.), and the same energy supply (paragraph 5.3.1.5.). However these requirements are not aligned with those of Regulation No. 13-H. Paragraph 1.1.2. of Annex 4 to Regulation No. 13-H requires the capacity of a certain number of sudden stops after the energy source failed ONLY in the case where the secondary braking performances cannot be met without energy assisting the muscular energy: see paragraph 1.1.2.

The current text of Annex 3 of Regulation No. 79 covers requirements to be met in case the braking and the steering systems have the same energy source (paragraph 5.3.1.4), and the same energy supply (paragraph 5.3.1.5.). However these requirements are not aligned with those of Regulation No. 13. Paragraph 1.1.3. of Annex 7 to Regulation No. 13 requires the capacity for the system of a certain number of sudden stops, after the energy source failed, ONLY in the case where the secondary braking performances cannot be met without energy assisting the muscular energy: see paragraph 1.1.3.

The current text of the provisions in Regulation No. 79 could be interpreted as the required number of sudden stops that must be achieved irrespective of the service braking design, i.e. even in the case of assisted braking system.

Proposal to remove tables specifying general values for replacement discs and drums that are identical to the original (2.3.3.4) since such replacements must by definition have values identical to the corresponding original parts. The proposal also would change the maximum permitted thickness variation of discs for medium and heavy vehicles from 0.030 mm to 0.050 mm (the common OEM specification).

UN R13 allows for the exemption of certain vehicles from the requirement for electronic stability controls. This proposal seeks to clarify the scope of the exemptions to include any special purpose vehicle with a non-standard chassis. The change was prompted by a modified vehicle where use of ESC was not feasible, but where the current UN R13 language left doubt as to whether the ESC requirement was applicable. This revised proposal takes into account comments received during the February 2016 GRRF session.

UN R13 allows for the exemption of certain vehicles from the requirement for electronic stability controls (footnote 12). This proposal (following proposals GRRF/2016/27 as amended by GRRF-82-03 and proposal GRRF-83-31) seeks to clarify the scope of the exemptions to include any special purpose vehicle with a non-standard chassis. The change was prompted by a modified vehicle where use of ESC was not feasible, but where the current UN R13 language left doubt as to whether the ESC requirement was applicable.

CLEPA changes to its earlier proposal (GRSG/2012/4) proposing revisions to a Dutch proposal (GRSG/2011/23) that would enable the replacement of mirrors by camera monitor systems.

CLEPA comments on the OICA proposal for Supplement 3 to the 01 series of amendments to Regulation No. 43 (document GRSG/2014/14) that seeks to avoid imposing administrative burdens on small glazing that is not required for the driver’s forward or rearward field of vision.

This proposal corrects an editorial mistake in the tolerances of Annex 6. In Annex 10, paragraph 3.2.2.2. and in Annex 12, paragraph 3.2.2., the correct tolerance should read: 1.5m +0/-5mm. (The same tolerances also appear in UN GTR No. 6, paragraphs 5.4.3. and 6.5.4.2.)

OICA and CLEPA comments on the Korean proposal to amend GTR No. 6 and UN Regulation No. 43 in response to issues identified in its defect investigation concerning panoramic sunroofs.