OICA Comments to GRE/2017/17 and GRE/2017/22

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Presentation transcript:

OICA Comments to GRE/2017/17 and GRE/2017/22 Submitted by the expert from OICA Informal document GRE-78-28 (78th GRE, 24-27 October 2017, agenda item 5) OICA Comments to GRE/2017/17 and GRE/2017/22

Installation Approval LED Substitute Approval based on ECE R128 & R.E.5 Lamp Approval based on LSD Theory Installation Approval based on ECE R48, 03, 04, 05, 06 series (GRE-2017-22)

Installation Approval Installation Approval LED Substitute Approval based on ECE R128 & R.E.5 LED Substitute Approval based on ECE R128 & R.E.5 Lamp Approval based on LSD Lamp Approval based on LSD 1st Example Installation Approval based on ECE R48, 03, 04, 05, 06 series (GRE-2017-22) Installation Approval based on ECE R48-06

LSD is only introduced for Installation Approval Installation Approval LED Substitute Approval based on ECE R128 & R.E.5 LED Substitute Approval based on ECE R128 & R.E.5 Lamp Approval based on LSD Lamp Approval based on LSD LSD is only introduced for ECE R48-04/05/06 (GRE/2017/11 / GRE-78-14/GRE-78-15) 2nd Example Installation Approval based on ECE R48, 03, 04, 05, 06 series (GRE-2017-22) Installation Approval based on ECE R48-03

OICA Statement regarding GRE/2017/17 and GRE/2017/22 Where a vehicle manufacturer sees potential problems with installing LED substitutes on a previously approved UN R48/03 or 48/04 vehicle type an extension of the approval maybe necessary in order to prevent the vehicle manufacturer being held accountable for misuse. That would be an unacceptable burden for the vehicle manufacturer !