1. Explanation Supplemental to the JASIC’s Proposal; GRSP-52-09 RESS-8-7

2. Japanese Proposal Electrical /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 52 nd GRSP) provides flexibility for this by saying; “November 2014Adoption by WP29”

3. 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

4. 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.

5. Consideration of Category L To 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.

6. Integrated Regulations (L/M/N) Integrated Regulations (L/M/N) Which of these two approaches should be used for electric/battery safety for electric vehicles of category L? Separate Regulations (L M/N) Separate Regulations (L M/N) R3 Retro-reflecting devices R6 Direction indicators R7 Lamps R10 Electromagnetic compatibility R16 Safety belts (excluding L1/3) R24 Diesel exhaust emissions R37 Filament lamps R39 Speedometers R43 Glazing materials R45 Headlamp cleaners R65 Special warning lights R87 DRL R90 Brake lining R112 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.