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

2. 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 )

3. 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 )
Installation Approval
based on ECE R48-06

4. 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 )
Installation Approval
based on ECE R48-03

5. 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 !