Proposal to clarify:

1. The voltage requirements for light-emitting diodes (LED),
2. The requirements for the activation of direction-indicator lamps to ensure compatibility with driver control assistance systems as permitted under UN Regulation No. 171,
3. That direction-indicator lamps on one side of a vehicle shall be switched ON and OFF automatically, and
4. The provisions for category 5 devices by adding “per side” in the requirements.

Proposal to clarify:

1. The voltage requirements for light-emitting diodes (LED),
2. The requirements for the activation of direction-indicator lamps to ensure compatibility with driver control assistance systems as permitted under UN Regulation No. 171,
3. That direction-indicator lamps on one side of a vehicle shall be switched ON and OFF automatically, and
4. The provisions for category 5 devices by adding “per side” in the requirements.

Proposal to clarify:

1. The voltage requirements for light-emitting diodes (LED),
2. The requirements for the activation of direction-indicator lamps to ensure compatibility with driver control assistance systems as permitted under UN Regulation No. 171,
3. That direction-indicator lamps on one side of a vehicle shall be switched ON and OFF automatically, and
4. The provisions for category 5 devices by adding “per side” in the requirements.

Proposal to clarify:

1. The voltage requirements for light-emitting diodes (LED),
2. The requirements for the activation of direction-indicator lamps to ensure compatibility with driver control assistance systems as permitted under UN Regulation No. 171,
3. That direction-indicator lamps on one side of a vehicle shall be switched ON and OFF automatically, and
4. The provisions for category 5 devices by adding “per side” in the requirements.

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.

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.

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 the proposals concerning manufacturer logos.

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

Proposal clarifies the provisions for category 5 devices by adding “per side” in the requirements

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 define “work lamps” and establish minimum specifications for safe use.

Proposal to delete the 2m width requirement for parking lamps, to allow the installation of side-marker lamps combined with retro-reflectors on the lateral foremost position on semi-trailers, and to enable the approval of reversing projections (projection of patterns on the road).

Proposal to delete the 2m width requirement for parking lamps, allow the installation of side-marker lamps combined with retro-reflectors on the lateral foremost position on semi-trailers, and to introduce provisions for reversing projections (projection of patterns on the road).

Proposal to delete the 2m width requirement for parking lamps, to allow the installation of side-marker lamps combined with retro-reflectors on the lateral foremost position on semi-trailers, and to enable the approval of reversing projections (projection of patterns on the road).

Proposal to amend the Regulation to enable its application to ADS vehicles, including to introduce “vehicles with a driving system [that] controls its operation or may be operated by driver support features or automated driving features or by an Automated Driving System (ADS).”

Proposal to amend UN R48 to enable its application to ADS vehicles, including to introduce vehicles with a “driving system which controls its operation or may be operated by driver support features or automated driving features or by an Automated Driving System (ADS).”

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.