Position of Japan concerning the further development of the International Whole Vehicle Type Approval system, including work on UN Regulations 34, 46, and 125 and possible support for GTR 6 (UN R43), WLTP GTR and UN R51.

MLIT report raising concerns over the way approval numbers reflect the supplements covered. The draft Revision 3 of the 1958 Agreement requires that each approval number include the applicable supplement number; however, the application for a change of the supplement number does not constitute application for an extension of the approval. As a result, the approval number will not be changed even if a different supplement comes into force, resulting in a product having a supplement number that is different from the actual number of the supplement in force.

Illustration of the UN Regulation approvals information sheet as proposed in the related document SGR0-19-13.

Under the draft IN R0, Annex 5, Part III requires applicants to furnish the list of type approvals, including approval number, upon which the whole vehicle approval will be based. UN R0 would allow for limited whole vehicle (L-IWVTA) approvals based upon compliance with some, but not all of the UN Regulations incorporated within UN R0. MLIT believes that the information requested under Annex 5, Part III is insufficient to understand whether an application for an L-IWVTA or a universal approval (U-IWVTA) is complete with regard to the equipment installed on the vehicle to be approved or whether applicant has simply failed to provide complete information. MLIT proposes adding a column for the applicant to briefly note a reason for omitting a regulation.

Report from Japan’s MLIT consideration of the IWVTA procedures, identifying concern over the definition and verification of information contained in type approvals. Attachment 1 to this report lists the various items from type-approval certificates that MLIT found difficult to verify independently.

Proposal to exclude exhaust emission level and fuel consumption from the definition of a version until the exhaust emission requirements and the fuel consumption requirements are added to Annex 4. The concern is that limits vary across Contracting Parties and changes to a CP limit would require issuance of an new version based upon a new application for IWVTA approval.

Report raising concerns over the verification of compliance with lighting installation requirements under whole vehicle approval.

Proposal to remove the requirements to provide approval certificates for bulbs used in lamp units because approval procedures for lamp units involve the testing of the units with bulbs that comply with the requirements. Therefore, the UN R0 requirement to provide approval certificates for both lamp units and the bulbs used in those units appears redundant.

Updated report from Japan’s MLIT consideration of the IWVTA procedures, identifying concern over the definition and verification of information contained in type approvals. Attachment 1 to this report lists the various items from type-approval certificates that MLIT found difficult to verify independently.

Proposal to clarify that the component approvals underpinning a vehicle type approval do not have to have been issued to the same manufacturer, but that the responsibilities of the manufacturer applying for vehicle type approval to the type approval authority nonetheless remain intact.

Report highlights that regulations under IWVTA may not apply equally to two vehicles of the same type; for example, application of high voltage protection provisions only to electrified vehicles, but not their ICE homologue.

Updated MLIT report raising concerns over the way approval numbers reflect the supplements covered. The draft Revision 3 of the 1958 Agreement requires that each approval number include the applicable supplement number; however, the application for a change of the supplement number does not constitute application for an extension of the approval. As a result, the approval number will not be changed even if a different supplement comes into force, resulting in a product having a supplement number that is different from the actual number of the supplement in force.

Proposal to clarify the procedure and information to be provided by the manufacturer in the event of a change to a whole vehicle approval type.

Request for clarification on procedures in paragraphs 7.4 and 7.5 of the Revision 3 to the 1958 Agreement.

When a series of amendments to any UN Regulation included in a whole vehicle approval is changed, it needs to be considered as an extension of approval to UN R0 even if the series of amendments to R0 remains unchanged. Therefore, the text of Revision 3 to the 1958 Agreement (Paragraph 7) should be changed to include the extension/revision criteria for UN R0.

Under the proposed international whole vehicle type approval, Annex 4 to the regulation would provide the list of component regulations. Annex 4 will be updated over time to incorporate new or updated regulations that comprise a whole vehicle approval. These changes in requirements will impact whether a vehicle has a universal or limited approval and will require communication between the holder of the approval and the issuing type approval authority; however, the obligations and procedures for maintaining this coordination are not spelled out in the UN R0 text. Japan proposes a manufacturer obligation to notify of the authority of its intentions when an amendment to Annex 4 would impact an existing approval in its possession.