Regulatory strategy when voluntary systems become mandated Transmitted by the experts from OICA IWVTA-SGR0-23-05 Regulatory strategy when voluntary systems become mandated

Background GRRF-ACSF informal group is working on modifying UN R-79 in order to allow several automatically controlled steering functions. One of the systems considered for inclusion is LKAS (lane keeping assistance system). OICA expects LKAS to be included in R-79 as a voluntary system (if-fitted). On the other hand, OICA understands that within the ongoing revision process of the EU general safety regulation (GSR, (EC) 661/2009) it is evaluated to mandate LKAS. This could lead to a situation similar to the one encountered during the development of IWVTA e.g. for ESC and BAS which were originally included in UN R-13H as "if-fitted". With the following slides OICA wants to trigger a discussion how to handle such situations. R-79 is used as an example but the topic is more generally the situation where some but not all CPs want to make a system mandatory that was voluntary before.

Approaches to handle this situation OICA would like to make IG-IWVTASGR0 aware of the situation that may evolve due among others to the revision of the GSR. OICA sees different ways to handle the change from voluntary to mandated system. Splitting LKAS from UN R-79 to become a separate new UN Regulation. (This approach has already been taken for e.g. ESC, BAS, TPMS) Leaving LKAS as an if-fitted system in UN R-79 but creating an additional new UN Regulation which has the sole content of requiring an LKAS system type-approved to UN R-79. These 2 options are explained on the following slides. At this point in time there is no clear OICA preference. OICA however points out that the splitting approach satisfies the WP.29 general policy (see WP.29/1044/Rev.1, §16) In parallel, OICA is investigating whether other approaches (e.g. using IWVTA or attestation) could be helpful for such situations in the future. OICA also suggests that the ongoing development of UN R79 should continue till its completion, and that any used approach should not delay the adoption of the amendments to UN R79

Option 1: Splitting the mandated function from the Regulation Benefit: clear separation of the functionality Successfully applied for ESC BAS, TPMS In line with the current WP.29 policy Disbenefit Many Regulations needed: additional Regulation for every mandated system Some duplication of text may be necessary (redundancy) Parallel updating of any common text may be necessary UN R-79 Steering (general) LKAS (if-fitted) Other ACSF-functions (if-fitted) … UN R-79 Steering (general) Other ACSF-functions (if-fitted) … UN R-1xx LKAS +

Option 2: Additional Regulation for the presence of a system Benefit: R-79 can remain as it is being developed Disbenefit Many Regulations needed: one additional Regulation for each newly mandated system UN R-79 Steering (general) LKAS (if-fitted) Other ACSF-functions (if-fitted) … UN R-79 Steering (general) LKAS (if-fitted) Other ACSF-functions (if-fitted) … UN R-1xx Presence of LKAS Reference to R-79 for Technical requirements +