Explanation Supplemental to the JASIC’s Proposal; GRSP-52-09

RESS-8-7

Japanese ProposalElectrical /battery safety requirements for category L vehicles are now under consideration by REESS-Sub G. We think it necessary and therefore support it.We propose that, based on the results of the consideration mentioned above, we decide which of the following two approaches is more appropriate:

A) Extend R100 to cover category L, 　　　　　 or B) Establish a new UN regulation for category L only.

The ToR for formal adoption (i.e. Appendix VII to the minutes of 52nd GRSP) provides flexibility for this by saying;“November 2014 Adoption by WP29”

Analysis of the Approaches

* Advantages - The voting procedure may be shorter.

* Disadvantages　 - CPs can not selectively apply the Regulation only for category L.　 - It will become more complicated to construct appropriate 　 requirements relevant to the variety of body structures 　 (with/without cabin) and design concepts of category L. 　　

A) Extend R100 to cover category L

B) Establish a separate regulation

* Advantages - Easy to construct appropriate requirements for the body　 　 structure and design concept of category L. 　 - CPs can selectively apply the Regulation for category L in accordance with the national/regional demands.

* Disadvantages　 - The voting procedure may be longer.

Consideration of Category LTo establish electric/battery safety requirements for electric vehicles of category L:

・ Safety requirement should be considered with a focus 　 on category L vehicles without cabin .

•Requirements for category L vehicles with cabin 　　 should be considered based on the approach for 　 categories M/N in R100.

IntegratedRegulations (L/M/N)

IntegratedRegulations (L/M/N)

Which of these two approaches should be used for electric/battery safety for electric vehicles of category L?

SeparateRegulations (L<->M/N)

SeparateRegulations (L<->M/N)

R3 Retro-reflecting devicesR6 Direction indicatorsR7 LampsR10 Electromagnetic compatibilityR16 Safety belts (excluding L1/3)R24 Diesel exhaust emissionsR37 Filament lampsR39 SpeedometersR43 Glazing materialsR45 Headlamp cleanersR65 Special warning lightsR87 DRLR90 Brake liningR112 Headlamps with an asymmetrical beam

Noise: R51(M/N)- R9(L2/4/5)-R41(L3)-R63(L1)Brake:R13&13H&51(M/N)-R78(L1-5)Lamps:R4/5/20/31/48/77/91/99/123(MNO)　　　　 R50/53/56/57/74/76/82/113(L1-7)Locking systems:R18/R97/R116(M/N)-R62(L1-5)Emissions:R83(M/N)-R40(L3/4/5)-R47(L1/2)Tires:R30(M/N/O)-R75(L1-5)-R88(L1)Controls/tell-tales:R121(M/N) -R60(L1/3)

Different approaches

The current UN regulations include both; those applicable to several categories, and

those prescribed separately for different categories even in the same field.