1. Transmitted by the expert
from the Russian Federation
IWVTA-25-09
Agenda items 6 & 8
A Concept of Limited Recognition of Type Approvals Pursuant to UN Regulations
November 2017

2. Background
Not a long time ago, within the activities of IWG IWVTA, OICA indicated a need to reflect a possibility of partial type approval pursuant at least to two regulatory items (UN R 48 & WLTP) so called “Attestation concept”.
However, previously there were examples of limited recognition of type approvals. It was possible to issue type approvals pursuant to UN R 13H with and without ESC. The same situation is with UN R 64, where type approval can be issued with and without TPMS.
The concept of limited type approval is realized in draft UN Regulation No. 0.
Notes:
1. Limited type approval scheme was realized in UN R 13H & 64 with the previous version of the 1958 Agreement
2. For the IWVTA development purpose the said UN Regulations were split to avoid the situation with variations of type approvals. But, if the concept of limited type approval were introduced earlier, division of the said Regulations would not be necessary.

3. Proposal (1)
To introduce a concept of limited recognition of (partial) type approvals pursuant to UN Regulations, which would add flexibility in implementation of UN Regulations.
This concept would be applicable to vehicle voluntary systems, which may become mandated at least by some Contracting Parties
Mandating presence of such systems may be done at national/regional level unless there would be a consensus of all Contracting Parties about such mandating in a UN Regulation.
This approach excludes a need of an additional separate UN Regulation mandating presence of such systems
However, the application of this concept should be limited to specific requirements and/or equipment of the particular UN Regulations.

4. Proposal (2)
Basically there is a need neither to amend 1958 Agreement nor to add a new Schedule to it.
All relevant provisions can be added to the particular UN Regulations
Type approvals of general and limited recognition can be distinguished by type approval numbers and marking
The concept of type approvals of limited recognition may be described in a separate document like Q & A or in amended General Guidelines of UN Regulatory Procedures.
Meanwhile, it is proposed not to use the term "attestation"
This would help to avoid confusion
Implementation of the concept of partial type approval would be easier and smoother

5. Legal Justification
The proposed type approval of limited recognition is still type approval, therefore the amendment of Article 3 of the revised Agreement is not foreseen.
A possibility of issuing type approvals of limited recognition relates to the conditions for granting type approvals stipulated in Article 1 paragraph 2 subparagraph (d) of the revised 1958 Agreement, so such possibility is already covered by the 1958 Agreement.

6. Implementation of the concept of type approvals of limited recognition in UN Regulations
Select the appropriate UN Regulations, for which this concept would be considered relevant.
Transposition of WLTP provisions in a UN Regulation may be done using this concept
The provisions implementing the concept of type approval of limited recognition relate to the chapter "Approval", the annexes with communication forms and arrangements of the approval marks, which should include the new option of type approval of limited recognition.

7. Examples of approval marks
(Actual provisions) Pursuant to UN R 13H with (left) & without (right) Electronic Stability Control (ESC)
(Hypothetical) Pursuant to UN R full compliance (left) and partial compliance without DRL(right). “L” lover “E” means “Limited”
E11 13HRESC
E11 13HR
E11 48R
E11 48RWODRL
E11 48R L