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Agenda TAAM Meeting, 6-7 december, Brussels, Belgium

Brussels, 27th November 2012

AGENDA:

1. Opening of the meeting

2. Adoption of the Agenda

3. Adoption of the minutes from Bratislava

4. Follow up on actions from the previous meetings

4.1. Bratislava Agenda item 3.2, TAAM Minutes forwarding to the Commission and TAAEG 4.2. Bratislava Agenda item 4.1, Geneva Agenda item 4.8, Riga Agenda item 5.24: ECE R13: R13 test

reports according annexes 19-21 (Germany) 4.3. Bratislava Agenda item 4.3, Geneva Agenda item 5.5: ECE R103 and Regulation (EC) 715/2007:

Replacement pollution control devices, Particulate filters Provisions for testing (Germany) 4.4. Bratislava Agenda item 4.4, Geneva Agenda item 5.6.: Regulation (EC) 715/2007 and ECE

R83.06: Engine setting for Type I test (UK) 4.5. Bratislava Agenda item 4.6, Geneva Agenda item 8.2.: Final guidelines of the Multi-Stage

Subgroup for the Processing of Multi Stage Approvals (Germany) 4.6. Bratislava Agenda item 5.6, Directive 2007/46/EC: Mobile Air Conditioning for Special Purpose

Vehicle (UK) 4.6.1. Letter to European Commission: Application of the Directive 2006/40/EC for Special

Purpose Vehicles of category M1 (Jean Philippe) 4.6.2. Answer of the European Commission – Note for the file Review of the provisions on

special purpose vehicles (SPV) (EC) 4.7. Bratislava Agenda item 5.17, ECE R7: Front and rear position lamps (Poland) 4.8. Bratislava Agenda item 5.21, Directive 97/27/EC: Determine the technically permissible

maximum laden mass and category for trailers (Estonia) 4.9. Bratislava Agenda item 5.26, Directive 2007/46/EC, ECE R107: Exits (UK)

5. Items relating to Framework Directive 2007/46/EC (Motor Vehicles)

NEW ITEMS:

5.1. Unclear Transitional Provisions of ECE-R 13H up to Supplement 13 (Germany) 5.2. Installation of lighting and light-signalling devices – ECE R48.05

Dipped-beam headlamps switched ON and OFF automatically (Netherlands) 5.3. warning light according R65 on a ‘complete’ vehicle (Netherlands) 5.4. Regulation 48 (UK)

www.mobilit.fgov.be

http://www.mobilit.fgov.be/

sur 2

5.5. Type-approval mark requirement in directive 2009/59/EC (Finland) 5.6. Reg (EU) 678/2011 and log transporters (Germany) 5.7. SG, special purpose vehicle (Netherlands) 5.8. Criteria for category ‘SG” vehicles (Sweden) 5.9. Coupling & Trailer Approval (France) 5.10. ECE R55 Mechanical Couplings – Castor Trailers (UK) 5.11. EC type-approval for mechanical coupling device exclusively designed to be installed on

WVTA without towing mass capacity. How to proceed (registration, …) when this coupling device is fitted to a vehicle? (Belgium)

5.12. Regulation (EU) 582/2011, alternative use of OBD-System for EURO 6 LDV (Germany) 5.13. Monitoring of DPF (A or B in the approval number) 595/2009/EC as amended by

64/2012/EC (Netherlands) 5.14. Use of ECO tyre pressure (Netherlands) 5.15. Deviation from NEDC shift points in favour of “start/stop” systems during idling

(Netherlands) 5.16. IUPR monitors to be declared by vehicle manufacturer (Netherlands) 5.17. Rounding of Pn on Type Approval Certificate (Netherlands) 5.18. MAC Directive 2006/40/EC New Information after Real-Life tests by a manufacturer

(Germany) 5.19. 2007/46 – Article 3 (UK) 5.20. EC Regulation 715/2007 and 692/200 as amended by EU Regulation 630/2012 (UK) 5.21. Are ranges allowed on COC masses and dimensions data for extendible and modular

trailers? (Belgium) 5.22. TAA Meeting on Conformity of Production procedures (Finland) 5.23. Repair-and-Maintenance-Information, RMI-subgroup (Germany) 5.24. 2007/46 – Annex 1 (UK) 5.25. Technically permissible maximum laden mass 5.26. Multistage EC type-approval after 29 Oct 2012 on base WVTA not amended by

678/2011/EC. Meet regulation 678/2011/EC of not? (Belgium) 5.27. Worst-case description in test reports (Germany) 5.28. 630/2012/EC (UK) 5.29. N3 vehicle as lorry BA AND tractor BC. How should its COC be composed? (Belgium)

6. Other 6.1. Presentation by representatives of Japan 6.2 76/114 and 19/2011 Trailer statutory plates (Lithuania) 6.3 ECE R43 (TAAM RIGA item 5.27) Plastic glazing not used for driver field of view (UK)

General remarks: TAAM meeting will begin at 9 and Tuesday noon sandwiches will be provided. www.mobilit.fgov.be

http://www.mobilit.fgov.be/

Section 4:

Items from Prior TAAM - Bratislava

4.1. TAAM Minutes forwarding to the Commission and TAAEG (Bratislava Agenda item 3.2)

The Geneva meeting secretariat agreed to confirm the arrangements for uploading the TAAM Riga minutes onto the Commission website.

Outcome: TAAEG informed that Commission will no longer be attending the TAAM and the minutes will no longer be uploaded onto the Commission website. The Riga minutes has therefore not been forwarded to the Commission.

The Geneva meeting secretariat agreed to prepare a summary document to highlight for the Commission the key action points arising from the TAAM minutes:

Outcome: No longer required (see above) but this summary still completed to facilitate identification of carry over items for Agenda in Bratislava.

Discussion, suggestions from TAAM delegates how to treat with TAAM Minutes and other summaries from TAAM meetings.

Minutes from Bratislava TAAM:

Germany reminded again that the Commission will no longer be participate at the TAAM and the Meeting minutes will no longer be uploaded onto the Commission website. However, Germany opined that the invitation e-mails should be sent to the Commission because of new colleagues who will possibly attend the meeting and at least the Meeting minutes should be sent.

United Kingdom suggested sending only the summary document with action key points from the TAAM minutes to the Commission.

France pointed out that only points of the Agenda that are not clarified during the TAAM shall be sent to the TAAEG.

Germany proposed to create a section under the ETAES and to upload the Meeting minutes there, but in such case the minutes will be available only for TAA (due to access secured by login name and password).

Delegates suggested to create a website “www.taam.eu” where the Meeting minutes will be uploaded and will be available also for public (manufacturers, technical services, etc.). As such website has been already registered by the Slovenia for the purposes of TAAM in Brdo (October 2009), Slovenia will find out the possibilities of restoration of this website and will send the information via e-mail.

This item should be discussed again at the next TAAM.

TAAM Brussels (December 2012):

TAAM.eu has been bought by a private company. Two options were discussed; (a) Each member state could host minutes on their own website. (b) TAAM could buy back TAAM.eu domain

The group discussed that there was no need to have TAAM.eu and favoured option (a) UK confirmed that it could post minutes on its own website.

4.2 R13 test reports according annexes 19-21 (Bratislava Agenda item 4.1, Geneva Agenda item 4.8, Riga Agenda item 5.24)

Germany

Issue

The UNECE-R 13 defines: The application for approval of a vehicle type with regard to braking shall be submitted by the vehicle manufacturer or by his duly accredited representative. A component approval or partial system approval is not possible according to the Regulation. The Regulation allows in some cases alternative procedures for type approving vehicles, utilizing information from test reports issued to brake component or system suppliers (e.g. Annex 11, 19 and 20). This test reports (for e.g. Trailer anti-lock braking system, Vehicle stability function simulation tools, Vehicle stability function, spring brakes) should be signed by the Technical Service and by the TAA. This test reports can be used directly by the vehicle manufacturers for the type-approval of the vehicles. In the past, the KBA signed a lot of reports for braking systems and components for trailers. But these reports are not used for type-approval (at least not in Germany). This will be changed with the obligatory type-approval for trailers and heavy duty motor vehicles. The R-13 defines no administrative requirements for the approval authority with regard to these reports. Question:

1. (How) do you check the report (as a normal report in the type-approval procedure)? 2. Do you perform an initial assessment / COP before you sign the report? 3. Do you accept such kind of reports (issued from another TAA) without any additional checks

for type-approval? 4. How could the vehicle manufacturer be responsible for the whole vehicle brake if he uses

reports delivered by the suppliers without special suitable arrangements with the supplier? 5. Could this procedure be used in the future for ESC-Systems for motor vehicles, too (a first

proposal for this was discussed in the GRRF – the vehicle manufacturer have some doubts) ?

The KBA has serious doubts that the approvals based on this reports are in all cases sound without clear administrative provisions.

Possible solution: Amendment of the UNECE-R 13 as follows:

1. Delete the signature of the TAA in the test reports 2. Delete the unimportant test reports (e.g. spring brakes) 3. Define clear responsibilities for the whole procedure and for all documents and reports

(vehicle manufacturer) 4. Require suitable arrangements between the vehicle manufacturer and supplier, when the

supplier delivers test reports together with the components and systems which should be used for type-approval

5. Check of the whole documentation and of all test reports by the TAA when granting the brake approval of the vehicle.

Type approving authority "e" 1

Selection of solution accepted Refused

1 X 2 X 3 X 4 X 5 X

Minutes from Riga TAAM: Noting that any proposed amendments to ECE R13 would be processed via the UN ECE Working Party on Brakes and Running Gear (GRRF), the meeting discussed the five questions and agreed to send post-meeting responses to Germany.

Minutes from Geneva TAAM: It was explained that GRRF has tabled a proposal for the last WP.29 on the use of test report for the last WP.29 and an additional document from Germany has also been adopted by the TCMV. Nevertheless, WP.29 decided to send the document back to GRRF for improvement of the formulation. This means that the question will remain on the TAAM agenda.

Minutes from Bratislava TAAM: GRRF has not received any conclusion yet, so the question will remain on the next TAAM agenda

TAAM Brussels: (December 2012) Test reports have been submitted to GRRF – information is provided in WP29 GRRF 73 – discussions are ongoing.

4.3 ECE R103 and Regulation (EC) 715/2007: Replacement pollution control devices, Particulate filters Provisions for testing. (Bratislava Agenda item 4.3, Geneva Agenda item 5.5)

Issue

Germany

UN R103 formerly has taken care about replacement catalysers. Typically the original device could be exchanged in the lifetime of a vehicle by a non-original one approved under the UN R103 or EC 70/220/EEC approved one.

Since modern cars now have (not only the Diesel ones!) also particulate filters (PF)/trap as a part of their emission control strategy, also the PF have to be replaced after years of usage.

The old version of the UN R103 did not have any provisions for testing nor the R 83 which is the standard reference for testing inside the R 103.

The new version is now clear in the view of PF. There are clear provisions related to the procedures in R 83 to test e.g. the regeneration and find the KI-factors (see annex part of R 103 and R83)

The KBA wants to focus on the existing provisions which have to be fulfilled while granting an approval for such devices which now are included in the scope and referenced in the new title of the Reg. The above said is also applicable for approvals under the 715/2007 umbrella.

Question: Is it possible to give an approval under the UN R 103 to replacement particulate traps without testing in accordance to UN R83 the particulate filter-ability?

Prescription 715/2007 and UN R103 with provisions of R 83

Possibilities of solution comments

1 No It is not possible to approve an PF without

testing the filter ability (KI, Regeneration..) and only test it’s catalyser function.

2 Yes The filter might be seen as a catalyser and therefore is solely tested under the old simple provisions.


Selection of solution accepted Refused

1 X 2 X

Annex: UN R 103 (suppl.3)

ECE/TRANS/WP.29/2010/131 ……… 5. Requirements

5.1. General requirements 5.1.1. The replacement pollution control device shall be designed, constructed and capable of being mounted so as to enable the vehicle to comply with the provisions of those Regulations which it was originally in compliance with and that pollutant emissions are effectively limited throughout the normal life of the vehicle under normal conditions of use. 5.1.2. The installation of the replacement pollution control device shall be at the exact position of the original pollution control device, and the position on the exhaust line of the oxygen probe(s) and other sensors, if applicable, shall not be modified. ………. 5.1.3. If the original equipment pollution control device includes thermal protections, the replacement pollution control device shall include equivalent protections. 5.1.4. The replacement pollution control device shall be durable, that is designed, constructed and capable of being mounted so that reasonable resistance to the corrosion and oxidation phenomena to which it is exposed is obtained, having regard to the conditions of use of the vehicle. 5.2. Requirements regarding emissions The vehicle(s) indicated in paragraph 3.3.1. of this Regulation, equipped with a replacement pollution control device of the type for which approval is requested, shall be subjected to a type I test under the conditions described in the corresponding annexes of Regulation No. 83 in order to compare its performance with the original pollution control device according to the procedure described below.

Minutes from Geneva TAAM: It was noted that this could depend on the approval level of the vehicle for which the replacement pollution control device is being approved and, in this context, there needs to be a distinction between Euro 4 and Euro 5. The French delegation agreed to progress this via GRPE.


Germany stressed the necessary of testing and observation of the new parts added to antipollution system. French delegation informed that the topic was progressed to GRPE, but they have not received the outcome yet.

German delegation together with French delegation agreed to prepare additional proposal for GRPE.

This question will remain on the TAAM Agenda.


This item was postponed for discussion with 5.13

4.4. Regulation (EC) 715/2007 and ECE R83.06: Engine setting for Type I test (Bratislava Agenda item 4.4, Geneva Agenda item 5.6.)

United Kingdom

BACKGROUND

In describing the test procedure for a Type I light duty emissions test, ECE R83.06 Annex 4a paragraph 3.2.4 states that the settings of the engine and of the vehicle's controls shall be those prescribed by the manufacturer. This requirement also applies, in particular, to the settings for idling (rotation speed and carbon monoxide content of the exhaust gases), for the cold start device and for the exhaust gas cleaning system.

DISCUSSION

Electronic engine management systems provide manufacturers with opportunities to have more than one engine setting/fuel map available in the same engine. These setting can sometimes be changed by the driver during vehicle operation and, for example, there could be an economy setting, a normal setting and a sports setting.

The legislation does not clearly state the criteria by which the Type Approval authority may judge the validity of the engine settings ‘prescribed by the manufacturer’ for the Type I test and there is a concern that, to give good emissions/fuel consumption results, a manufacturer could specify a special setting that is not normally used for everyday driving.

To overcome this concern, VCA currently adopts the following approach:

- The engine setting used for the Type 1 test should be the key-on default setting for the

vehicle. - If there is no default setting (e.g. at key-on the engine uses the setting that was in operation

at the previous key-off), then the emissions test should be tested in the setting that covers the worst case condition

However, we recognize that the legislation is open to interpretation and we would therefore appreciate the views of the other TAAM delegates.

QUESTION

What criteria should be used to agree the engine settings used for the Type I test?

Possibilities of solution Comments

A

The vehicle manufacturer is completely free to select the setting to be used for the Type I test

This could mean that the test is conducted with a setting that is not normally used for everyday driving

B

The engine setting used for the Type 1 test should be the key-on default setting for the vehicle.

This helps to encourage the driver to use the most environmentally beneficial setting

C

If there is no default setting (e.g. at key-on the engine uses the setting that was in operation at the last key-off), then the emissions test should be tested in the setting that covers the worst case condition

LEGISLATION

R83 Annex 4a 3.2. TEST VEHICLE 3.2.1. The vehicle shall be presented in good mechanical condition. It shall have been run-in and

driven at least 3,000 km before the test. 3.2.2. The exhaust device shall not exhibit any leak likely to reduce the quantity of gas collected,

which quantity shall be that emerging from the engine. 3.2.3. The tightness of the intake system may be checked to ensure that carburation is not

affected by an accidental intake of air. 3.2.4. The settings of the engine and of the vehicle's controls shall be those prescribed by the

manufacturer. This requirement also applies, in particular, to the settings for idling (rotation speed and carbon monoxide content of the exhaust gases), for the cold start device and for the exhaust gas cleaning system.

3.2.5. The vehicle to be tested, or an equivalent vehicle, shall be fitted, if necessary, with a device to permit the measurement of the characteristic parameters necessary for chassis dynamometer setting, in conformity with paragraph 5. of this annex.

3.2.6. The technical service responsible for the tests may verify that the vehicle's performance conforms to that stated by the manufacturer, that it can be used for normal driving and, more particularly, that it is capable of starting when cold and when hot.

Minutes from Geneva TAAM: The general opinion of the meeting was that, for type approval purposes, emissions results should, in principle, represent the worst case. The UK delegation agreed to request its representative at the GRPE to raise this question for further guidance. Pending the outcome of the GRPE discussions, the majority of the meeting was in favour of following Solutions B and C with the condition that, even when a default setting is available, the Approval Authority must still be satisfied that it represents a realistic in-use setting for the vehicle. It should be noted that at least one delegation was in favour of only Solution C for all cases.


United Kingdom suggested to postpone the discussion to this topic to the next TAAM.


Nothing further to add from GRPE at this time, therefore postpone until the next TAAM.

4.5 Final guidelines of the Multi-Stage Subgroup for the Processing of Multi Stage Approvals (Bratislava Agenda item 4.6, Geneva Agenda item 8.2.)

Germany


Mr. Wrobel (GER), Chair of the Multi-Stage Subgroup, presented their work. The guideline for process of the Multi-Stage Approvals is finalized. Latest version of the guideline is in Annex I of this Meeting minutes.

Slight changes will touch the Point 4.15 concerning updating of the 2nd (3rd, etc.) stage type approval after the extension of the base vehicle type approval. The proposal is to allow following stage manufacturer so that he does not need to update his type approval if the changes of base vehicle do not hit the following stage approval.

Mr. Wrobel noticed that the guideline is not a law or legal act, it is only the recommendation for better understanding of the Multi-Stage Approvals.

Remarks from this TAAM discussions will be also incorporated in to the guideline (see Item no. 5.8. – 5.10.).


Germany has passed the findings (- guidelines) of the multistage subgroup to COM. The item should remain for information on the TAAM agenda. The group is awaiting feedback from COM to see how this has progressed.

4.6 Directive 2007/46/EC: Mobile Air Conditioning for Special Purpose Vehicle (Bratislava Agenda item 5.6)

Mobile Air Conditioning for Special Purpose Vehicles

LEGISLATION

Item Subject

United Kingdom 1 M1 ≤ 2 500 (1) kg M1 > 2 500 (1) kg

61 Air-conditioning system-Directive 2006/40/EC X X

X No exemptions except those specified in the regulatory act.

G Requirements according to the category of the base/incomplete vehicle (the chassis of which was used to build the special purpose vehicle). In the case of incomplete/completed vehicles, it is acceptable that the requirements for vehicles of the corresponding category N (based on max. mass) are satisfied.

Discussion Here we see an "X" for M1 >2500 kg. These converters build on N1 class III and N2 and these vehicles are not in the scope of the MAC directive. So we could see conversions on these categories that have an A/C system, but no approval to the base vehicle, yet require an approval to get WV for a SPV. We understand that the Commission has indicated that this requirement was an editorial error and that the X should have been G.

Question?

Will member states accept that for M1 SPV the requirements as laid out in “G” above will be acceptable?

Option Possible Solution Comments

A Yes B No

Minutes from Bratislava TAAM: The discussion showed that most of the delegates are in favour of replacing of the letter “X” by the letter “G”. Also according to the Report of 2nd TAAEG Meeting (6 June 2011) the Commission indicated that this is an error (see Annex III), but no legal correction/change has been made yet. As the conclusion was not reached at the meeting, the Chairman proposed to prepare a letter to the Commission for clarification of this situation and this item should be discussed again at the next TAAM.


Letters and responses reviewed. This is not yet concluded but there is a COM proposal that X will be stated for M1<2.5T and G above 2.5T.

A - Yes B - No

A - Yes B - No

4.7 ECE R7: Front and rear position lamps (Bratislava Agenda item 5.17) Poland 2

Background:

Application of LED’s in vehicles signaling lamps makes it possible to construct lamps meeting the requirements of UN Regulation No. 7, creating unseen, so far, lighting effects. Example of such construction is a rear position lamp made of electronic controlling device and ten non-replaceable LEDs, placed circularly, in which one LED is periodically turned out, creating effect of rotating gap in shining ring. Frequency of rotation is so selected that instead of visible changes of lens luminance, during measurements photometer did not reveal significant changes of luminous intensity (deviations are lower than measurement uncertainty). Based on photometer readings, luminous intensity changes can not be affirmed and according to UN Regulation No. 7 this lamp has steady luminous intensity. Formally such lamp meets the approval requirements of UN Regulation No. 7, concerning luminous intensity for light category R1 and it has been type-approved.

During approval of installation of light-signaling devices, according to UN Regulation No. 48, on vehicle equipped with this kind of lamps, questionable is interpretation of p. 5.9 of this Regulation, which says:

“5.9. In the absence of specific instructions, the photometric characteristics (e.g. intensity, colour,

apparent surface, etc.) of a lamp shall not be intentionally varied during the period of activation of the lamp.

5.9.1. Direction-indicator lamps, the vehicle-hazard warning signal, amber side-marker lamps complying with paragraph 6.18.7. below, and the emergency stop signal shall be flashing lamps.

5.9.2. The photometric characteristics of any lamp may vary: (a) in relation to the ambient light; (b) as a consequence of the activation of other lamps, or (c) when the lamps is being used to provide another lighting function,

technical provisions for the lamp concerned.”

Questions:

1. Can it be assumed, that the above mentioned lamp, meeting requirements of UN Regulation No. 7, did not meet requirements of p. 5.9 UN Regulation no. 48?

2. Poland would be most grateful to know whether this kind of lamp could be type-approved according to the UN Regulation No. 48 by the TAA of each EU Member State.

Question 1


Question 2


TAA code: „e”

„E”

Minutes from Bratislava TAAM: According to opinions of delegations, R 7 does not prohibit to grant an approval for such rear position lamps, if by the testing are not affirmed the luminous intensity changes. However, the lamps do not meet requirements of R 48 and approval according to R 48 can not be granted.

Though, the majority of delegation opined that even the approval according to R 7 should not be granted, if it is obvious that lamps will not fulfill requirements according to p. 5.9 of R 48. The Luxembourg delegation remarked that by any approval it is possible to argue with the safety reasons of the road traffic.

It could be concluded that there was general support in principle for Solution 1A and Solution 2B, but the Netherlands delegation offered to ask his expert in GRE to provide more information about the discussion in GRE on this specific topic.

Therefore the question remains on the next TAAM Agenda.


It was concluded that these could not be refused. We have to leave this for Geneva to resolve in UN Regs.

4.8 Directive 97/27/EC: Determine the technically permissible maximum laden mass and category for trailers (Bratislava Agenda item 5.21)

Directive number Directives 2007/46/EC and 97/27/EC Subject: Determine the technically permissible maximum laden mass and category for trailers

Estonia

Text of legal acts: Annex I point 2.2.4 of directive 97/27/EC defines ‘Centre-axle trailer’ as a rigid drawbar trailer where the axle(s) is (are) positioned close to the centre of gravity of the vehicle (when uniformly loaded) so that only a small static vertical load, not exceeding 10 % of that corresponding to the maximum mass of the trailer or a load of 1 000 daN (whichever is the lesser) is transmitted to the towing vehicle.

Point 2.6 of the same annex specify that the ‘Technically permissible maximum laden mass’ means the maximum mass of the vehicle based on its construction and performance, stated by the manufacturer. Also there is mentioned that the vehicle category should be determined in accordance with Annex II to Directive 70/156/EEC (repealed by directive 2007/46/EC).

According to Annex I point 2.8 and 2.8.1 of directive 2007/46/EC vehicle manufacturer has do state technically permissible maximum laden mass ( i ). Superscript ( i ) means that for trailers or semi-trailers which exert a significant vertical load on the coupling device, this load, divided by standard acceleration of gravity, is included in the maximum technically permissible laden mass.

• Annex II point 1.3.1 of directive 2007/46/EC specifies category O1 as a vehicles of category O having a maximum mass not exceeding 750 kg.

• Annex II point 2.2.3 sets out general provisions when determine maximum mass. It is said that in the case of a centre-axle trailer the maximum mass to be considered for classifying the vehicle shall correspond to the maximum mass transmitted to the ground by the wheels of an axle or group of axles when coupled to the towing vehicle.

Concern: When determine the category for centre-axle trailer, only the maximum mass transmitted t the ground by the wheels of an axle or group of axles when coupled to the towing vehicle should b taken into account. The technically permissible maximum laden mass stated by the manufacture doe not influence the categorisation of centre-axle trailer. Superscript ( i ) of Annex I point 2.8 of directive 2007/46/EC states that for trailers which exert significant vertical load on the coupling device, this load is included in the maximum technicall permissible mass. In case where the maximum mass transmitted to the ground by the wheels of an axle or group of axle when coupled to the towing vehicle is 750 kg and the manufacture considers for O1 category vehicle mass of a 75 kg as a significant vertical load on the coupling device (including this to technicall permissible maximum laden mass), there will be situation where the technically permissible maximum laden mass of O1 category vehicle is 825 kg. The same situation extents to O2 category vehicle which could have a technically permissibl maximum laden mass up to 3850 kg. As the vehicle with the technically permissible maximum laden mass of 825 kg will still be O1 category it will not have to be equipped with brakes etc.

Questions

There is a possibility that the type-approval authority will not accept this kind of solution, but shou mass of a 75 kg be considered as a significant vertical load on the coupling device and should included to the technically permissible maximum laden mass for category O1 vehicle?

d a be

Solution Accepted Refused

A

Yes

There are two kind of masses 1. The technically permissible maximum laden

mass is stated by the manufacturer, which includes the vertical load on the coupling device.

2. The maximum mass transmitted to the ground by the wheels of centre-axle trailer, which categorizes the trailer.

X

B

No

According to Annex I point 2.2.4 of directive 97/27/EC static vertical load not exceeding 10 % of that corresponding to the maximum mass of the trailer will be considered as small, not significant load. According to Annex II point 1.3.1 of directive 2007/46/EC the maximum mass of the trailer of category O1 could not exceed 750 kg.

X

Type approval authority "e" 29

Note: European Commission proposal for a Commission Regulation on masses and dimension (implementing measure of Regulation (EC) No 661/2009 on General Safety) article 2 point 7 defines: 'technically permissible maximum laden mass’ as the maximum mass allocated to a vehicle on the basi of its construction features and its design performances; the technically permissible laden mass of trailer or of a semi-trailer includes the static mass transferred to the towing vehicle when coupled; The proposal does not include wording “significant vertical load”, which makes the situatio complicating. This could lead to confusing situation for police, technical periodical inspection an others because the technically permissible maximum laden mass of O1 category vehicle could be up t 825 kg. Usually, O category vehicle with technically permissible maximum laden mass over 750 kg, i considered as O2 category. http://ec.europa.eu/enterprise/sectors/automotive/files/proposal-masses-and-dimensions_en.pdf

Minutes from Bratislava TAAM: There was not achieved the results from the discussion because several delegations were in favour of Solution A and another delegations in Solution B. It is a borderline case, but counting with the static vertical load on the coupling device, such trailer should not be approved as the vehicle of O1 category. This item need to be newly discussed and the discussions of the masses and Dimensions group have to be taken into account.

TAAM Brussels (December 2012): The case was presented that mass for determining category is the mass transmitted through the axles (framework annex II para 2.2.3. Max mass (not working out the category, but the TPMLM) includes coupling load – i.e. for O1 categorisation, max axle mass = 750kg. TPMLM could be +10% (i.e. 825kg). Option A was agreed. We will await publication of the new masses and dimensions regulation to see if this has been made clear.

http://ec.europa.eu/enterprise/sectors/automotive/files/proposal-masses-and-dimensions_en.pdf

4.9 Directive 2007/46/EC, ECE R107: Exits (Bratislava Agenda item 5.26)

2001/85EEC & ECE R107:

Bus and Coach – Exits

United Kingdom 3

LEGISLATION SCOPE 2001/85/EC 1.1. This Directive applies to every single deck, double deck, rigid or articulated vehicle of

category M 2 or M 3 as defined in Annex II, Part A, of Council Directive 70/156/EEC

7.6.10. Technical requirements for retractable steps (identical wording ECE R107.04)

Retractable steps if fitted shall comply with the following requirements:

7.6.10.2. when the door is closed no part of the retractable step shall project more than 10 mm beyond the adjacent line of the bodywork;

Discussion

Buses have traditionally been vehicles with flat sides making the interpretation of the adjacent body work fairly simple however we are now seeing more, contoured body shapes, which makes that interpretation more difficult. We would like the TAAM members views on the interpretation of “adjacent” in this case.

Question: Looking at the two cross sectional options below which of the two examples complies with the requirements of the legislation; “when the door is closed no part of the retractable step shall project more than 10 mm beyond the adjacent line of the bodywork”?

Cross Section “A” Cross Section “B”

Body Panel

X

STEP 10mm

STEP

10mm

X = Widest part of body

Option Possible Solution Comments A Cross Section “A” acceptable B Cross Section “B” acceptable C Other

Minutes from Bratislava TAAM: Majority of the delegations supported Solution A. However, for some delegations also the Solution B was acceptable because of the shape of the body such retractable step is not dangerous for pedestrians staying next to the bus. The French delegation suggested to progress this item to GRSG. The UK delegation prepares proposals for GRSG discussions and will report at the next TAAM.

TAAM Brussels (December 2012): UK reports this has not yet progressed to GRSG. Carry forward agenda item to next TAAM.

Section 5:

Agenda Items from Brussels TAAM

5.1 (Germany 1) : UN-ECE Regulation 13H Transitional Provisions

Issue: Unclear Transistional Provisions of ECE-R 13H up to Supplement 13

backup:

12.1. Until 24 months after the date of entry into force of Supplement 5 to the original

version of this Regulation, Contracting Parties applying this Regulation may continue to grant ECE approvals to the un-amended Regulation. (until 10.11.2009)

12.2. As from 1 November 2011, Contracting Parties applying this Regulation may refuse to

grant national or regional type approval if the vehicle type does not meet the requirements of this Regulation as amended by Supplement 9 or Supplement 10 or Supplement 11 and is not fitted with an Electronic Stability Control System and a Brake Assist System, both meeting the requirements of Annex 9 to this Regulation.

12.3. As from 1 November 2013, Contracting Parties applying this Regulation may refuse

first national registration of a vehicle which does not meet the requirements of this Regulation as amended by Supplement 9 or Supplement 10 or Supplement 11 and is not fitted with an Electronic Stability Control System and a Brake Assist System, both meeting the requirements of Annex 9 to this Regulation.

12.4. As from the official date of entry into force of Supplement 9 to the original version of

this Regulation, Contracting Parties applying this Regulation: (a) shall not refuse to grant approval under this Regulation to a vehicle complying

with the requirements as amended by Supplement 9 to the original version of this Regulation.

(b) shall refuse to grant approval under this Regulation as amended by Supplement 7 to the original version of this Regulation.

12.5. Contracting Parties applying this Regulation shall continue to grant approvals to those

types of vehicles which comply with the requirements of this Regulation as amended by Supplement 6 to the original version of this Regulation. (this paragraph has not been deleted up to now)

12.6. As from the official date of entry into force of the Supplement 11 (30 January 2011) to

the original version of this Regulation, no Contracting Party applying this Regulation shall refuse to grant ECE approval under this Regulation as amended by Supplement 11.


types of vehicles which comply with the requirements of this Regulation as amended by Supplement 10 to the original version of this Regulation during the 36 months period which follows the date of entry into force of Supplement 11. (until 29.01.2014)

12.8. As from the official date of entry into force of the Supplement 12 to the original version

of this Regulation, no Contracting Party applying this Regulation shall refuse to grant approval under this Regulation as amended by Supplement 12 to the original version of this Regulation. (28.10.2012)


types of vehicles which comply with the requirements of this Regulation as amended by Supplement 11 to the original version of this Regulation during the 12 month

period which follows the date of entry into force of supplement 12 to the original version of this Regulation. (until 27.10.2012)

12.10. Contracting Parties applying this Regulation shall not refuse to grant extensions of

approval according to this Regulation as amended by Supplement 11 to the original version of this Regulation.

Entry into force of supplement 13 was on 13.10.2013

Requirements 1:

According to the above mentioned transitional provisions, type approval for a new vehicle type with regard to the braking system may only be granted for vehicles which fulfil the requirements of supplement 13 (including 12 since 29.10.2010 which refers to the marking of brake disks and drums).

For the time between 13.10.2012 (entry into force of supplement 13) and 27.10.2012 the supplements 11 and 12 has not been mandatory but supplement 13 was.

Question 1:

Is it possible to grant a type-approval for supplement 13 to ECE-R 13H expressively excluding the requirements of suppl. 11 and 12?

Possible solutions:


Selection of solution accepted refused

A Yes it is possible, according to the transitional provisions under 12.7 and 12.9

B No, it is not possible to exclude earlier supplements of a regulation even if the transitional provisions for this earlier suppl. would allow so

Comment:

KBA did already grant approvals according to suppl. 13 without the marking of brake disks according to suppl. 12 before the date when suppl. 12 becomes mandatory.

Requirements 2:

Since the transitional provisions in paragraph 12.5 and 12.7 has not been deleted according to later supplements, one could think that it is still possible to grant approvals for new vehicle types according to supplement 6 without taking into account all later supplements and also to supplement 10 until 29.01.2013!

Question 2:

Is it possible to grant a type-approval for supplement 6 or 10 to ECE-R 13H expressively excluding the requirements of all later supplements?

Possible solutions:



A Yes it is possible, according to the transitional provisions under 12.5 and 12.7

B No, it is not possible because later supplements become mandatory due to their own transitional provisions

C Other solution

Comment:

The "General Guidelines for UN regulatory procedures and transitional provisions in UN Regulations", ECE/TRANS/WP.29/1044/rev1, namely para. C.30, reads:

“Unless specifically foreseen otherwise, extensions of existing approvals may continue to be granted on the basis of the provisions valid at the time of the original approval”

Therefore it should be possible to grant extensions for approvals with earlier supplements!

TAAM Minutes:

The meeting discussed the conflict in transitional provisions above: the dates for application of various supplements are non-sequential. [In 12.7, Supp 10 may be applied until 29.01.2014; but in 12.9, supp 11 can be applied only until 27.10.2012 - making supp 12 currently mandatory. Further, supp 13 does not include transitional provisions so should be applied from its EIF date!]

UK briefed that contact had been made with Francois Guichaud (UN secretariat), whose guidance was to issue latest supplement level. and he had invited TAAM input. UK questioned the German consolidation above – this will be checked by UK. Outlined UK policy to issue “latest unless expressly permitted otherwise” and “extend unless expressly prohibited”.

Poland raised that GRRF session 72 includes two useful informal documents (GRRF- 72-29 & GRRF-72-30)

The group discussed that this needs to be clarified by GRRF (requested this should be using a series of amendments as opposed to supplements and corrigenda.) UK representative is at GRRF. Therefore UK to propose for GRRF agenda via UK DfT IVS division. Next meeting Feb 2013.

The Meeting did not reach a conclusion and will await the outcome from GRRF.

Vehicle Technology Division

5.2 Installation of lighting and light-signalling devices – ECE R48.05 Dipped-beam headlamps switched ON and OFF automatically (Netherlands)

RDW_TAAM-2012-006 Directive : ECE R48.05 Subject : installation of lighting and light-signalling devices

Issue : 6.2.7.5 Dipped-beam headlamps may be switched ON or OF

automatically. However, it shall be always possible to switch these dipped-beam headlamps ON and OFF manually.

6.2.7.6. If daytime running lamps are present and operate according to paragraph 6.19., either

6.2.7.6.1. The dipped-beam headlamps shall be switched ON and OFF automatically relative to the ambient light conditions (e.g. switch ON during night time driving conditions, tunnels, etc.) according to the requirements of Annex 12; or

6.2.7.6.2. Daytime running lamps operate in conjunction with the lamps listed in paragraph 5.11. where, as a minimum requirement, at least the rear position lamps shall be activated; or

6.2.7.6.3. Distinctive means are provided to inform the driver that the headlamps, position lamps and if so equipped end outline marker lamps and side marker lamps are not illuminated. Such means are:

6.2.7.6.3.1. Two distinctly different levels of instrument panel illumination intensity are provided during night and day, indicating to the driver that the dipped beam headlamps shall be switched ON; or

6.2.7.6.3.2. Non-illuminated indicators and identification of hand controls that are required by Regulation No. 121 to be illuminated when the headlamps are activated; or

6.2.7.6.3.3. A tell-tale visual, auditory or both, shall be activated only in reduced ambient lighting conditions as defined in Annex 12 to inform the driver that the dipped beam headlamps should be switched ON. Once the tell-tale is activated, it shall only be extinguished when the dipped beam headlamps have been switched on or the device which starts and/or stops the engine (propulsion system) is set in a position which makes it impossible for the engine (propulsion system) to operate.

6.2.7.7. Without prejudice to paragraph 6.2.7.6.1., the dipped-beam headlamps may switch ON and OFF automatically relative to other factors such as time or ambient conditions (e.g. time of the day, vehicle location, rain, fog, etc.).

Conclusion: If daytime running lamps are present and operate according to paragraph 6.19. the vehicle shall comply with the requirements mentioned in one of the paragraphs 6.2.7.6.1., 6.2.7.6.2. or 6.2.7.6.3..


Question : Must the requirements mentioned in paragraph 6.2.7.6.1., i.e. the dipped beam headlamps shall be switched ON and OFF automatically, be fulfilled independently from the position of the master lighting switch, i.e. must the requirements also be fulfilled when the switch is in position “0” or “ ” and not only in the position “AUTO” when available?

Solutions

A

Yes, the requirements of paragraph 6.2.7.6.1. must be fulfilled independently from the position of the master lighting switch, i.e. the requirements must also be fulfilled when the switch is in position “0” or “ ”.

B

No, the currently in many vehicle types fitted master lighting switch with position “AUTO” where the dipped-beam headlamps only switch ON and OFF automatically to the ambient light conditions is acceptable for fulfilling the requirements of paragraph 6.2.7.6.1..

Decision Type Approval Authority e/E 4

Solution Accepted Refused A X B X

Remarks :

TAAM Minutes:

UK: response A is supported in respect of para 6.2.7.6 only.

The meeting discussed that para 6.2.7.6.1 is one of several options for compliance. NL proposed B. UK & Spain supported solution B.

The Meeting chose solution B.


5.3. Warning light according R65 on a ‘complete’ vehicle (Netherlands)

Directive or Regulation number: 76/756/EC ECE R48 Subject:

RDW-TAAM-00x v1.00 – 14 March 2008

Is it allowed to have an warning light according R65 on a ‘complete’ vehicle covered by 2007/46?

Reference to Annex, etc in the Directive or Regulation: 2007/46 Annex IV and R65

Text: R48 5.22. With the exception of retro-reflectors, a lamp even bearing an approval mark is deemed not to be present when it cannot be made to operate by the sole installation of a light source and/or a fuse.

76/756/EC 3. Without prejudice to the requirements of Article 8(2)(a) and (c) and (3) of Directive 70/156/EEC, of this Annex and to any requirements in any of the separate directives, the installation of any other lighting or light-signalling device than those defined in paragraph 2.7 of UN/ECE Regulation No 48 is prohibited.

A warning light according to R65 is no mandatory or optional light according 76/756 / R48. It has no individual specification according 76/756 / R48. According to R48 other lightning than specified are not allowed.

Although amber warning lights are common, they aren’t allowed to be installed on vehicles covered by a complete WVTA

Question:

Solutions:

A No, it isn’t allowed to have an additional R65 warning light

B Yes, it is allowed to have an additional warning light according to R65

VT-OS-01-F2 v2.00 page 1 of 2


5.3. Warning light according R65 on a ‘complete’ vehicle (Netherlands)

RDW-TAAM-00x v1.00 – 14 March 2008

Decision: Solution Accepted Refused A X B X

Authority: Type approval Authority e/E 4

Remarks:

TAAM Minutes:

Austria: have national rules and do not subscribe to R65. Germany: does issue ECWVTA but has a remark to be mindful of national laws. France: R65 not mentioned in framework annex IV so not possible to issue ECWVTA, only national. UK: R65 lamps must be disabled by 2 means to be acceptable for WVTA – if inactive these can still be fitted at time of approval.

Germany to have the lamps prepared for use but disabled is a good solution. Austria expressed concerns about the creep toward bringing in blue lamps. The group discussed that Geneva need to work on this question and clarify.

The Meeting chose solution A for WVTA, however acknowledged that national approval is acceptable.


VEHICLE CERTIFICATION AGENCY

THE UNITED KINGDOM VEHICLE APPROVAL AUTHORITY

1 The Eastgate Office Centre Eastgate Road Bristol, BS5 6XX United Kingdom : + 44 117 952 4112 Fax: + 44 117 952 4163

5.4. ECE Regulation 48 (UK4)

LEGISLATION

6.10. REAR POSITION LAMP (REGULATION NO. 7)

6.10.1. Presence: Devices of R or R1 or R2 categories: Mandatory

6.10.2. Number: Two.

Background

Recently VCA have been presented with a number of trailers for inspection which have approved combined lights (see pictures below). When activated the rear position light and the number plate light give the appearance of two position lights.

Question 1. Should it be possible to issue a combined lighting approval (inc R7/R4) which

when illuminated gives the impression of two position lamps? 2. If the answer to question number1 is yes, is it acceptable to approve the same

combined lamp to R48?

Option Possible Solution Comments A Yes it is possible to approve a combined lamp

as the individual regulations are tested separately

X

B No it should not be possible to approve a combined lamp which when illuminated gives the impression of having two position lamps

C Yes it is possible to approve this type of combined lamp to R48

X

D No it is not possible to approve this type of combined lamp to R48

TAAM Minutes:

The meeting accepted that the number plate lamp and “position lamp/EOML” could be approved as part of a combined lamp – subject to each element having approval to R7/R4, being separately tested and marked.

If not marked/approved, the lamp element showing red light from the number plate lamp source should be masked off. (i.e. no “bleed” permitted)

Regarding installation, UK suggested this could be EOML or position lamp according to Reg 7, R/R1/R2 category device. Two additional position lamps can optionally be fitted on O2/O3/O4 if EOML is not installed. (R48: 6.10.2.1) EOML are optional on vehicles between 1.8m and 2.1m wide, compulsory over 2.1m wide. (R48: 6.13.1)

Spain: agreed that R7 approval can be allowed; Qu1 option A, Qu 2; could be approved as R48 para 5.7.2.1 as a 2-part lamp.

Austria: highlighted proximity of reg plate lamp to the plate (believed non-compliant) EOML and position must both be within 400mm of the extreme outer edge of the vehicle. (post-meeting - noting installation requirements of 6.13.9)

The Meeting chose: Question 1, solution A Question 2, solution C (subject to installation position requirements)

5.5. Type-approval mark requirement in 2009/59/EC TAAM QUESTION, Brussels 6.–7.12.2012

TAAM QUESTION – FINLAND 1

14.9.2012

COUNTRY: Finland

QUESTION NR.: 1

SUBJECT: Type-approval mark requirement in directive 2009/59/EC (codification of 74/346/EEC)

REFERENCES (DIRECTIVE/ANNEX/ETC):

Directive 2009/59/EC on rear-view mirrors for wheeled agricultural or forestry tractors

2.1.1. Tractors may be fitted with rear-view mirrors of classes I and II only bearing the EC type- approval mark laid down in Directive 2003/97/EC of the European Parliament and of the Council of 10 November 2003 on the approximation of the laws of the Member States relating to the type- approval of devices for indirect vision and of vehicles equipped with these devices, amending Directive 70/156/EEC and repealing Directive 71/127/EEC ( 1 ).

EC regulation 661/2009 (GSR), Article 19 1. Directives… …2003/97/EC shall be repealed with effect from 1 November 2014. 3. References to the repealed Directives shall be construed as references to this Regulation.

QUESTION/PROBLEM/CONCERN: New component type approval according to directive 2003/97/EC cannot be granted after 1.11.2012 (GSR, article 13, point 2). The Framework directive 2003/37/EC does not list UN/ECE regulation 46 as an alternative to 74/346/EEC (codified with 2009/59/EC). This leads to situation in which the new EC type approval cannot be granted and mirrors bearing UN/ECE Regulation 46 type approval mark are not mentioned in directive 2009/59/EC.

1. Should the reference to the directive 2003/97/EC be construed as a reference to the GS regulation and therefore to UN/ECE Regulation 46 after 1.11.2012?

2. May tractors be fitted with rear-view mirrors bearing the UN/ECE Regulation 46 type-approval mark after 1.11.2012?

1. Please consider the following options A and B:

e17

Accepted Refused A Yes - - B No - -

2. Please consider the following options A and B:

e17 Accepted Refused A Yes x B No x

If you answer no, how should the situation be tackled?

Comments:

TAAM Minutes: Component approvals cannot be approved under the old directive; but tractor framework does not have cross reference to R46. UK, Belgium, Netherlands, Germany agreed with Finland that (2A) R46 mirrors may be fitted. UK expressed a view that we should expect the regs from Com to take care of this.

The Meeting could not respond to question 1; however chose solution 2A.

5.6 Germany 2 : Reg (EU) 678/2011 and log transporters

Requirement

Annex II of 2007/46/EC amended by EU-Regulation No. 678/2011 makes a statement to tractors (code BC) in part C, pos. 3.3: “a towing vehicle which is designed and constructed exclusively or principally to tow semi- trailers;” while semi-trailers (Code DA), part C, pos. 4.1 are: “a trailer which is designed and constructed to be coupled to a tractor unit or to a converter dolly and to impose a substantial vertical load on the towing vehicle or on the converter dolly.” However, the next sentence implies that only one kind of coupling is admissible: “The coupling to be used for a vehicle combination shall consist of a king pin and a fifth wheel.”

Question A usual log transporter concept is a tractor-trailer combination, in terms of 97/27/EC. The coupling having similar properties like a king pin and a fifth wheel is entirely part of the towing vehicle and as the logs make an integral part of the “semi-trailer” coupling is done as the logs are clamped into a U-shaped retainer, thus held in place greatly by friction. If the last sentence of 4.1 is understood to be merely explanatory this remains to be a tractor- semi-trailer combination, but what is it if it should be a requirement? If it should deemed to be a combination of truck and trailer

• the static load of the trailer on the towing vehicle makes it also difficult to classify the trailer,

• compatibility bands to braking are different and • the combination overall length is allowed to be greater than that of a tractor-semi-

trailer-combination.

Possible solutions: A


Selection of solution Yes No

A A log transporter of this kind is a tractor-trailer-combination. The last sentence to pos. 4.1 is just explanatory

X

B A log transporter of this kind is not a tractor-trailer- combination. The last sentence to pos. 4.1 is a requirement. This combination is a …….

X

C Handle nationally, Germany to take to Com SPV group X

TAAM Minutes: Germany proposed solution A and UK supported. France asked if the coupling could be approved to R55. Poland reminded TAAM that they asked the same question at TAAM Vienna in 2006, and had a strong objection on safety grounds; security of load, no side lighting etc. Germany proposed that this vehicle combination should go to the SPV group in Com. (Austria agree) Spain’s view was that it was a tractor; Austria’s that is a truck as it carried the trailer dolly.

UK proposed a new option C which is to handle on a national basis. Germany supported this option in the meantime while this question goes to Com.

The meeting agreed a new Option (C) to handle nationally and Germany take to Com SPV group.


5.7. SG, special purpose vehicle

Directive or Regulation number: - 2007/46/EC Subject: - SG, special purpose vehicle

RDW-TAAM-001

Netherlands v1.00 – 14 March 2008

Reference to Annex, etc in the Directive or Regulation: - Annex II, Part A, paragraph 5

Text: 5.8. Special group: SG, a special purpose vehicle which does not enter in any of the definitions mentioned in this section.

Question: In Annex II, Part A, paragraph 5 there are several well defined special purpose vehicles. The group at point 5.8 is not so well defined which vehicles belongs to this group of special purpose vehicles.

It can be interesting for manufacturers to define their their vehicle as a special purpose vehicle. Special purpose vehicles don’t have to comply with EVSC, LDWS, AEBS, etc.

Can a street sweeper be considered as a special purpose vehicle?

Solutions:

A

Yes This is a very specific vehicle with specific use which should be covered in the SG group

B

No This is a normal truck (N2) and should not be considered as a special purpose vehicle

Decision: Solution Accepted Refused

A B


TAAM Minutes: NOTE: Question combined with 5.8 Czech Republic, Poland agree this is an SPV. Germany stated that in order to be considered an SPV, this should be unable to comply with some requirement by virtue of its special purpose. Concurred by UK and Netherlands. France and Germany say this should be discussed by the SPV group at Com. Finland and (by proxy) Sweden say this is a truck. UK stated that there are certain exemptions for vehicles in some acts, such as side guards and rear underrun. These state that where a vehicle has a special purpose use that means it cannot comply, it need not. UK asked does this mean that it is already an SPV by default? Is it enough that there are exemptions at the lower level? Netherlands (H Jongenelen) will take this to Com. The Meeting did not choose a solution .


Sweden 1

TAAM 6-7 December 2012, Brussels

Page

1(2)

Road and Rail Department

5.8 Criteria for category “SG” vehicles

DIRECTIVE: 2007/46/EC

RELEVANT SECTION:

Annex II: introductory part item 3, part A item 2.2 and part A section 5 Annex XI: appendix 4

Concern:

With regard to new regulations becoming mandatory for type-approvals of new types and where SPV´s are exempted from the scope, e.g. AEBS starting from 1st November 2013, there is an interest from manufacturers to inform themselves about criteria to categorise a vehicle as “SG”.

Annex II: 3. Categorisation into vehicle categories 3.1. The manufacturer is responsible for the categorisation of a type of vehicle into a specific

category.

For such purposes, all the relevant criteria described in this Annex shall be met.

3.2. The approval authority may request from the manufacturer appropriate additional information with the aim of demonstrating that a vehicle type needs to be categorised as special purpose vehicle in the special group (‘SG Code’).

Part A: 2.2. Special purpose vehicles

2.2.1. ‘Special purpose vehicle (SPV)’ means a vehicle of category M, N or O having specific

technical features in order to perform a function which requires special arrangements and/or equipment.

For incomplete vehicles that are intended to fall into the SPV subcategory, the letter ‘S’ shall be added as suffix to the letter and numeral identifying the vehicle category.

The various types of special purpose vehicles are defined and listed in Section 5.

Section 5: --- 5.8. Special group SG a special purpose vehicle which does not enter in any of the

definitions mentioned in this section. ---

Annex XI:

Swedish Transport Agency Box 267, SE-781 23 Borlänge www.transportstyrelsen.se [email protected] Street address: Hagavägen 2 telephone: +46 771 503 503

http://www.transportstyrelsen.se/

mailto:[email protected]

Sweden 1


Page

2(2)


Appendix 4

Other special purpose vehicles (including trailer caravans)

Application of the exemptions is only permitted if the manufacturer demonstrates to the satisfaction of the approval authority that the vehicle, due to the special function, cannot meet all the requirements.

As an example: A refuse collection vehicle or, “garbage disposal truck”, is, based on Annex II, categorised as a “N” vehicle with body-work code “BA18”. Could such a vehicle also be seen as a vehicle categorised as “SG”, based on it´s specific technical features and special equipment for garbage disposal? The vehicle can be approved without exemptions set out in Annex XI, appendix 4.

QUESTION:

What procedure is correct if a manufacturer applies for a type-approval for a vehicle categorised as “SG”?

A

Category “SG” may be used for a vehicle although the technical features and special arrangements for its intended use doesn´t mean that the exemptions in Annex XI, Appendix 4 must be used to grant a type-approval.

B Category “SG” is only to be used for a vehicle which can´t meet the requirements for type-approval without the exemptions in Annex XI, Appendix 4, based on its specific technical features and special arrangements for its intended use.

5

Type approving authority "e"

Selection of solution accepted refused A B X

TAAM Minutes:

Current understanding is option B. Question combined with 5.7: Netherlands (H Jongenelen) to take to Com.




TAAM Brussels, December 2012 - France 1

5.9 Coupling & Trailer Approval

• Regulation number:

- Directive 94/20/EC related to the mechanical coupling devices of motor vehicles and their trailers and their attachment to those vehicles

- Framework Directive 2007/46/EC

Type approving authority « e » 2

• Issue

Question 1:

Would it be possible to grant an approval for a motor vehicle and a trailer so that the combination of them is not articulated ? (For example, let consider a N1 and an O2 -> see picture n°1)


A Yes

X B No Without articulation, this combination is similar to a N2 vehicle (N1 : 3.5t + O2 : 3t = 6.5 t) and this “vehicle” do not fulfil the requirements of N2 category (RUP, Braking, speed limiter ...) This case would be a competitive distortion in relation to “true” high duty vehicle.

TAAM Brussels, December 2012 - France 1

Question 2:

Would it be possible to grant an approval for a motor vehicle with a coupling which is not a fifth wheel, immediately behind the cab ? (see picture n°2)

A Yes

B No X

TAAM Minutes:

UK and Spain did not believe this could be approved and asked whether the coupling could be approved to R55. Austria mentioned that this was covered by TAAM Bratislava question 5.4 Luxembourg had approved the trailer nationally, and Belgium approved the coupling. Austria mentioned that the tractor regs talked about articulation. Germany agreed with the UK, Spain and Austria – this cannot be approved..

Netherlands thought it possible to grant approval to combination as one vehicle, for the truck but not the trailer.- this is seen as one vehicle from which parts can be removed. Spain and Germany mentioned that where 3 axles are approved, the vehicle must have them ; UK asked how this is different than a lift-axle. Austria and Netherlands mentioned they have two approvals with both 2 and 3 axles. Germany saw this as the same per Bratislava item 5.4.

The Meeting chose Qu1 solution (B), Qu2 solution (B).




5.10. ECE R55 Mechanical Couplings – Castor Trailers (UK1)

LEGISLATION

Background

VCA has been approached by the manufacturer of an unconventional trailer (see below) this trailer has multiple fixing points to the towing vehicle and does not articulate as a conventional trailer would or have a single conventional mounting point. The wheels are of a castor type.

Question: Because the trailer has multiple attachment points we would like to ask TAAM if it is possible to approve such a trailer? If so, how should the testing be done?


A Yes it is possible B No it is not possible X C Other

TAAM Minutes:

The group discussed that this could be considered a rigid drawbar trailer since there is no lateral articulation. Framework directive states that a drawbar trailer cannot be approved (according to new annex II.) Extension of drawing vehicle wheelbase and cornering outswing issues were also raised.

France couldn’t approve (option B) but expressed a desire for consistent answer with question 5.9 (France, non-articulated coupling)

Germany believe it cannot be approved (option B) according to their national law, but it seems to be a wider problem so perhaps it could be brought to Com.

Austria has seen the CoC for at least 1 type of vehicle like this, and highlighted driving licence issues. Belgium have not granted approvals.

Belgium, Germany, UK and France supported option (B). This cannot be approved under EWVTA although the possibility of national approvals was raised.


City Atrium - Vooruitgangstraat 56 - 1210 Brussel Lokaal 2A06

Tel. : 02 / 277.30.50 - Fax : 02 / 277.40.84

5.11. EC type-approval for mechanical coupling device exclusively designed to be installed on WVTA without towing mass capacity Questions by the Belgian TAAM delegation: BMOT-TAAM-2012-001

Directive or Regulation number: - 2007/46/EC - 94/20/EC or ECE R55 - 2001/95/EC

Subject:

v1.00 – 27 November 2012

Installation of aftermarket equipment which causes maximum technical masses or dimensions to exceed.

Reference to Annex, etc in the Directive or Regulation:

- 2001/95/EC Art1. 2 - 2007/46/EC Art29 - 94/20/EC Annex VII

Background:

Vehicles without towing capacity are being equipped with mechanical coupling devices. The mechanical coupling device has an EC type approval. Its installation and operating instruction guide indicates that the coupling devices are manufactured for installation on one specific vehicle type. All variant versions of this vehicle type are without towing capacity. Towing masses are mentioned in the installation guide that accompanies the towing device itself. The vehicle manufacturer himself is not aware of these modifications. Therefore he could not advice nor make any provisions in order to extend influenced directives: - masse and dimensions - breaking - steering - emissions


A X B X C X D X

Text: Annex VII of 94/20/EC REQUIREMENTS RELATING TO THE TYPE-APPROVAL OF THE VEHICLE TYPE WITH REGARD TO THE OPTIONAL ATTACHMENT OF MECHANICAL COUPLING DEVICES TO THIS VEHICLE. 1. GENERAL REQUIREMENTS 1.1. The vehicle manufacturer shall state which types and classes of coupling devices may be fitted to the vehicle type giving the values of D, V (1), S or U (if applicable) which are based on the construction of the vehicle type in combination with the type(s) of the coupling device(s) intended to be used. The characteristics D, V, S or U of the coupling devices approved in accordance with this Directive shall be equal or greater than the characteristics given for the combination concerned.

Article 29 of 2007/46/EC

1. If a Member State finds that new vehicles, systems, components or separate technical units, albeit in compliance with the applicable requirements or properly marked, present a serious risk to road safety, or seriously harm the environment or public health, that Member State may, for a maximum period of six months, refuse to register such vehicles or to permit the sale or entry into service in its territory of such vehicles, components or separate technical units.

In such cases, the Member State concerned shall immediately notify the manufacturer, the other Member States and the Commission accordingly, stating the reasons on which its decision is based and, in particular, whether it is the result of: — shortcomings in the relevant regulatory acts, or — incorrect application of the relevant requirements.

Question: However the base EC type-approval of the vehicle was valid upon registration, its approval expires as soon the installation of aftermarket equipment leaves the vehicle out of the boundaries, set by the manufacturer. What actions should be taken?

Solutions: A Bring vehicle in its original state.

B Start procedure according Art 29.

- Prohibit service for these vehicles in the Member-State - Notify manufacturer, other Member States and Commission.

C Leave vehicles with coupling device installed but keep towing capacity to zero. D Manage this issue on a national / individual approval level only

Authority: Type approval Authority 6 e/E

Remarks:

TAAM Minutes: Germany would only give a national approval to allow a towing mass. UK suggested this was a matter for each member state, that all four options were acceptable. The Chair stated this was not practical.

The meeting then chose solution D.

5.12. Germany 3: Regulation (EU) 582/2011, alternative use of OBD- System for EURO 6 LDV

KBA

Issue:

Germany 3; Brussels 2012

Annex X of EU-Reg 582/2011 allows manufacturers to use an alternative OBD System which is based on those of Reg 692/2008 . The EURO 6 OBD-levels of LDV start with EURO 6- following 6-1 and 6-2. The HDV EURO VI levels are categorised VI-A, B, C. The transitional provisions are very similar but not congruent!

Which approach is the correct one if the regulation allows to use ‘EURO 6’-OBD? The approach shall take into account the transitional provisions of the next OBD levels 6-1, 6-2 and / or align the implementing dates to those of EURO VI A, B, C!

Questions:

Is it possible or feasible to start with EURO 6- level using the alternative approval??

Prescription:

2.4. Alternative approval 2.4.1. If requested by the manufacturer, for vehicles of category M 1 , M 2 , N 1 and N 2 with a maximum permissible mass not exceeding 7,5 tonnes and M 3 Class I, Class II and Class A and Class B as defined in Annex I to Directive 2001/85/EC with a permissible mass not exceeding 7,5 tonnes, compliance with the requirements of Annex XI to Regulation (EC) No 692/2008 according to OBD standard Euro 6 as defined in Appendix 6 to Annex I to Regulation (EC) No 692/2008 shall be considered equivalent to the compliance with this Annex.

If such alternative approval is used, the information related to OBD systems in Sections 3.2.12.2.7.1 to 3.2.12.2.7.4 of Part 2 of Appendix 4 to Annex I is replaced by the information of Section 3.2.12.2.7 of Appendix 3 to Annex I to Regulation (EC) No 692/2008. Selective application of the provisions of this Annex and of the provisions of Annex XVI to Regulation (EC) No 692/2008 shall not be permitted except to the extent explicitly set out in Section 2.4.1.

Annex: Timeline for OBD


1 A Manufacturer can start with the EURO

6- level which is comparable to the EURO VI A

At time of the Original 582/2011 the 6-1 level was not decided – so in the Reg. the reference was simply called EURO 6, which therefore can be interpreted as the first EURO 6 OBD level = EURO 6-. This seems to be logical comparing the transitional provisions of LDV and HDV legislation! (see annex)

B Manufacturer has to start with OBD level 6-1 because: Euro 6 means a real EURO 6, which then is the level 6-1!



A X B X

TAAM Minutes: Germany explained the proposal – and that there was no clarity in the expression “Euro-6”. However there would be a clearer definition if it was considered as 6-, 6-1, 6-2. UK and Belgium supported the German proposal

UK clarified that in multistage build an “N1 to M1” conversion would keep the same N1 (base vehicle) OBD limit requirements.

The Meeting chose solution A.

New Types

LD Ml All regs

Euro 6-2

New Types

LD Nl

PM threshold .,partial

All regs

0 I New 1:0 Types

Q) HD

Euro

VIC c

E I I All regs i=

c c <(

Nox threshold 2,6 x TA limit PM threshold,partial failure"


5.13. Monitoring of DPF (A or B in the approval number) 595/2009/EC as amended by 64/2012/EC (Netherlands)

Directive or Regulation number: 595/2009/EC as amended by 64/2012/EC

RDW-TAAM-2012-008 v1.00 – 14 March 2008

Subject: Monitoring of DPF (A or B in the approval number)

Reference to Annex, etc in the Directive or Regulation: Annex I, Appendix 9 of the 582/2011 Annex X of the 582/2011

Text:

According to this table you need for Row A for PM OTL performance monitoring and for Row B monitoring against the PM OTL limits




RDW-TAAM-2012-008 v1.00 – 14 March 2008

Question: When you perform performance monitoring of the DPF and you can demonstrate that in case of deterioration there is a positive correlation between the loss of filtration efficiency and the loss of pressure drop across the DPF under the operation conditions of the engine specified in the test. Can this been considered that as OTL monitoring which means a letter B in the approval number?

Can you get only a letter B in the approval number when you monitor directly the PM emissions in the tailpipe with for instance a soot sensor?

Solutions: A Delta P monitoring without positive correlation gives an A in the approval number B Delta P monitoring with positive correlation gives an A in the approval number C Delta P monitoring with positive correlation gives an B in the approval number

D Only PM OTL monitoring with an active sensor in the exhaust (soot sensor) gives an B in the approval number


A X B X C X D X





Remarks:

RDW-TAAM-2012-008 v1.00 – 14 March 2008

TAAM Minutes:

The UK felt it could not support solution A so proposed B & D.

The group agreed that correlation is accepted, and that approvals with Row B in the approval number would not be refused.

The Meeting chose solutions B & D.


5.14. Use of ECO tyre pressure (Netherlands)


Netherlands 2012

Directive or Regulation number: - Regulation (EU) 661/2009 - ECE Regulation 64.02

Subject: Use of ECO tyre pressure

RDW-TAAM-2012-003 v1.00 – 14 March 2008


- Article 9 of the mentioned Regulation(s) (EU) - Paragraph 5.3 and Annex 5 of ECE Regulation 64.02.

Text: Section 2 of Article 9 states: 2. Vehicles of category M1 shall be equipped with an accurate tyre pressure monitoring system capable

of giving, when necessary, an in-car warning to the driver when a loss of pressure occurs in any tyre, in the interests of optimum fuel consumption and road safety

ECE R64.02 – Definitions: 2.16. "Recommended cold inflation pressure (Prec )" means the pressure recommended for each tyre position

by the vehicle manufacturer, for the intended service conditions (e.g. speed and load) of the given vehicle, as defined on the vehicle placard and/or the vehicle owner's manual

Annex 5 section 1.4 and 2.1: 1.4.1. Test weight.

The vehicle may be tested at any condition of load, the distribution of the mass among the axles being that stated by the vehicle manufacturer without exceeding any of the maximum permissible mass for each axle. However, in the case where there is no possibility to set or reset the system, the vehicle shall be unladen.

2.1 …Inflate the vehicle's tyres to the vehicle manufacturer's recommended cold inflation pressure (Prec ), in accordance with the vehicle manufacturer's recommendation for the speed and load conditions, and tyre positions…

Question: In case the manufacturer declares 2 cold inflation pressures for normal use (vehicle condition unladen), e.g. “comfort pressure” and “ECO pressure”, which pressure has to be regarded Prec for a TMPS with no possibility to set or reset the system ?

Solutions: A “comfort pressure” B “ECO pressure” C both pressures have to be considered and must meet the requirements


A X B X C X




Remarks: One of the main reasons for the EU Commission to implement TPMS as part of the General Safety requirements, is to reduce the overall fuel consumption in daily use, by making consumers aware of the situation where the tyre pressure has dropped to a value below what is recommended. Manufacturers nowadays often recommend ECO tyre pressures along with comfort tyre pressures to their customers, and carry out the Emission and Fuel Consumption tests and Road Load determination with this ECO pressure. The more advanced TPM-systems on the market today can be set at any pressure by means of a learning mode, the less advanced systems are set by the factory at a pre-set value. In the latter case it is important that the ECO pressure is regarded Prec thus not undermining one of the main purposes of TPMS. For a manufacturer of a vehicle with a TPMS with only a pre-set pressure, he must make sure that the defined “comfort pressure” falls within the range of application of his system, in other words, does not trigger the malfunction indication. Solution C would mean that either the manufacturer may not offer a TPMS with pre-set pressure or if he did, could only recommend one tyre pressure for that loading condition.

TAAM Minutes:

Germany proposed C as did France. UK option B was first choice then C. Austria stated that the purpose was about reducing CO2 , so B should be the aim. Germany stated that B satisfies both comfort and safety considerations.

The Meeting chose solutions B & C



Netherlands 2012-0XX 5.15. Deviation from NEDC shift points in favour of “start/stop” systems during idling

Directive or Regulation number:

RDW-TAAM-2012-0XX v1.00 – 14 March 2008

- Regulation (EU) 715/2007 and 692/2008 as amended by 459/2012 - ECE Regulation 83.06

Subject: Deviation from NEDC shift points in favour of “start/stop” systems during idling.


- Section 6 of Annex 4a of ECE Regulation 83.06 and table 2 of this Annex.

Text: “PM” means “gearbox in neutral, clutch engaged” “K1” means “first gear engaged, clutch disengaged”

Question:

In the first stage of the Extra-urban cycle, a period of 20s is defined with the vehicle idling with the gear engaged and clutch disengaged before the first acceleration starts. Would you allow to reduce this idling time to e.g. 5s to allow optimum benefit of start stop systems ? In other words: split the K1 time of 20s in 15s PM and 5s K1.

Solutions: 1 No, the Type 1 test drive cycle is clearly specified and must be followed literally

2 Yes, we do allow to deviate from the prescribed shift points during idling time to allow for optimum use of the start/stop system during the Extra-urban drive cycle.


1 X 2 X


Remarks: During the TAAM in Riga in 2011 it was discussed whether it would be allowed to deviate from the prescribed shift points during the 5s idling period in the urban cycle (agenda item 5.15). In the end, it was concluded that no deviation from the prescribed shift points should be allowed. Several delegates were initially willing to accept deviation from the prescribed shift points. This question is raised because it was not discussed at that time whether deviation during the Extra-urban cycle would be allowed, during the first 20s idling period.

So far, RDW has followed the drive cycle exactly the way it is described. We believe deviation from the prescribed drive cycle is not possible within the current legislation, although we do not oppose the idea itself to benefit “start/stop” systems. It is important though that everyone is following the same approach such that no manufacturer has a benefit over the other. If consensus is reached that deviation should be allowed (solution 2), we believe this is only possible after the legislation is amended accordingly.



TAAM Minutes:

Germany explained the proposal. The group discussed that the– start/stop systems are relatively new technology and did not offer any mandate to modify or deviate from the drive cycle. Austria stated that the drive cycle would have to be changed by Geneva to enable the possible benefits provided by these start/stop systems to be demonstrated.

The Meeting chose solution 1.



5.16. IUPR monitors to be declared by vehicle manufacturer RDW-TAAM-2012-002

Netherlands 2012 v1.00 – 14 March 2008

Directive or Regulation number: - Regulation (EU) 715/2007 and 692/2008 as amended by 566/2011 - ECE Regulation 83.06

Subject: IUPR monitors to be declared by vehicle manufacturer


- Annex XI of the mentioned Regulation(s) (EU) - Annex 11 of ECE Regulation 83.06.

Text: Section 3.2.1. of Annex XI (similar to Section 7.2.1. of Annex 11 to ECE R83.06) The numerator of a specific monitor is a counter measuring the number of times a vehicle has been operated such that all monitoring conditions necessary for the specific monitor to detect a malfunction in order to warn the driver, as they have been implemented by the manufacturer, have been encountered

Section 3.6.1. of Annex XI (similar to Section 7.6.1. of Annex 11 to ECE R83.06) states: The OBD system shall report in accordance with the ISO 15031-5 specifications the ignition cycle counter and general denominator as well as separate numerators and denominators for the following monitors, if their presence on the vehicle is required by this Annex:

- Catalysts (each bank to be reported separately) - Oxygen/exhaust gas sensors, including secondary oxygen sensors (each sensor to be reported

separately) - Evaporative system - EGR system - VVT system - Secondary air system - Particulate filter - NOx after treatment system (e.g. NOx adsorber, NOx reagent/catalyst system) - Boost pressure control system

Question: Which monitors must be considered as a minimum with regard to IUPR ? It seems that there are different opinions among Type Approval Authorities and Technical Services about how to interpret the legislation on this point and therefore manufacturers and Type Approval Authorities are not sure what needs to be provided as a minimum.



Solutions: A all monitors of emission related systems that could generate a P0XX code

B all monitors of emission related systems that could activate the MIL, regardless if the EOBD threshold limits are exceeded (e.g. misfiring)

C all monitors related to the systems mentioned under section 3.6.1./7.6.1. that could activate the MIL, regardless if the EOBD threshold limits are exceeded.

D all monitors of emission related systems where in case of a failure, the EOBD threshold limits are exceeded

E all monitors related to the systems mentioned under section 3.6.1./7.6.1. where in case of a failure, the EOBD threshold limits are exceeded


A X B X C X D X E X


Remarks: The sentence: “if their presence on the vehicle is required by this Annex” refers to Annex 11 of ECE R83.06. In our opinion it does not state that a system, if it is monitored by the EOBD system but would not result in exceeding the EOBD threshold limits, need not be part of IUPR requirements.

TAAM Minutes:

Netherlands proposed solution C. France and Germany concurred.

The Meeting chose solution C.



5.17. Rounding of Pn on Type Approval Certificate RDW-TAAM-2012-004

Netherlands 2012 v1.00 – 14 March 2008

Directive or Regulation number: - Regulation (EU) 715/2007 and 692/2008 as amended by 459/2012 - ECE Regulation 83.06

Subject: Rounding of Pn on Type Approval Certificate


- Section 2.1 of Appendix 4 to Annex I of the Regulation(s) (EU) - Section 2.1 of Annex 2 of ECE Regulation 83.06

Text: According to footnote “vi” accompanying the tables in above mentioned sections, the final mean value calculated with Ki and DF (M.Ki.DF) should be rounded to one decimal place more than the limit value.

Question: The limit for Pn is set at 6.0 x 1011 [#/km] (Euro 5/Euro 6)* The test results are often given in a value other than 1011 for example: 3.82 x 109 [#/km]. This is also what has been stated in the Type Approval Certificate by several Type Approval Authorities (incl. RDW) so far.

Actually we think that the correct way would be to state 0.04 x 1011 [#/km] on the Type Approval Certificate in this case. This also means that if the result had been for example: 3.82 x 108 [#/km], the Type Approval Certificate would state 0.00 x 1011 [#/km]. Would you agree to state the Pn in [#1011/km] and mention only the value as indicated in the example below ?

Type 1 result

Test

CO (mg/km)

THC (mg/km)

NMHC (mg/km)

NOx

(mg/km)

THC + NOx

(mg/km)

Particu- lates

(mg/km)

Particu- lates

(#1011/km)

Measured (i) (iv)

1 2 3

Measured mean value (M) (i) (iv)

Ki (i) (v) (ii)

Mean value calculated with Ki (M.Ki) (iv)

(iii)

DF (i) (v)

Final mean value calculated with Ki and DF (M.Ki.DF) (vi)

0.04

Limit value 6.0 (i) Where applicable. (ii) Not applicable. (iii) Mean value calculated by adding mean values (M.Ki.) calculated for THC and NO x . (iv) Round to 2 decimal places. (v) Round to 4 decimal places. (vi) Round to 1 decimal place more than limit value.

* see remarks



Solutions:

1 No, we would like to round the result to whole numbers incl. 2 decimal places; if the result were 3.82 x 109 [#/km], that is what we will state on the Type Approval Certificate

2 Yes, we agree that the best approach is to state the result in [#1011/km] in the header and state only the value 0.04 in the cell in such case


1 X 2 X


Remarks: The same approach should be followed in the Annex VIII and Annex IX to 2007/46/EC. If consensus can be reached it will make life easier for Type Approval Authorities to fill their national database with test results in a consistent format, thus preventing errors. If the limit value of 6.0 x 1012 is used for positive ignition engines with direct injection for the transitional period if applicable as indicated in Regulation (EU) 459/2012, the same logic can be applied for the limit value. This limit value shall be changed to 60 which is than 60 x 1011 . Because the header will not change.

TAAM Minutes:

The group discussed that since the header states [#1011/km] we should present the result in this form – and including any rounding which is incurred, to one decimal place more than the limit value.



5.18 Germany 4: MAC Directive 2006/40/EC New Information after Real- Life tests by a manufacturer

KBA

Info: The KBA would like to inform about a recall campaign in Germany.


A German car manufacturer made just recently a so called Real-Life test with some of his vehicles to provide additional … of the safety of that vehicles accompanying ISO 13043 FMEA analysis. During this tests the vehicle was conditioned in a way of normal usage. The car was driven with a speed of up to motorway limits on a track to provide higher exhaust temperature. After parking the car a light-crash and refrigerant leakage was simulated by opening the bonnet for a few cm and open a valve which releases the refrigerant under normal pressure conditions. The refrigerant caught fire and was in the test distinguished by an switchable fire distinguisher. The KBA classified the vehicle type as being a severe risk for traffic safety. The vehicle manufacturer announced, that this incident will be transferable to other types and not only happen to this vehicle type only! This might also be the case for other vehicle manufacturers. The KBA would like to inform and if possible to get the view of other TAA.

TAAM Minutes: [Pre- meeting: UK DfT advise that TAAM does not have jurisdiction/ remit here therefore any discussion represents opinions only.TCMV will discuss this item mid December. ] The issue was outlined by Germany in terms of vehicle-specific and event-specific conditions. Germany stated within the laws of physics, 3 fundamentals are required: (1) Heat = Hot surface >400’C (2) Fuel = Leak (3) Oxygen = gas concentration within 6 - 12% There seem to be two groups – manufacturers who can mitigate the effects of the new refrigerant, and those who cannot. The moratorium on old gas expires at the end of December 2012 – which is likely to cause a CoP issue. Germany points out that this has no basis in law and is an “agreement”. Belgium questioned regarding old R134a vs new R1234yf gas – had understood flammability conditions were comparable. UK stated that some material presented indicated the flammability is due to the PAG oil. Germany stated that tests show the flammability is gas not PAG oil. Luxembourg stated that all member states are in the same situation and it did not support extending old approvals. Netherlands stated that member states should respect the moratorium. NL belief is that this goes further than CoP and is a design question for manufacturers to address. Germany suggested to look at CoP leakage test data for new applications, and ask the manufacturer to explain system safety. UK stated a belief that the commission were unhappy and would not support further delays – Commission (Phillippe Jean) has made a decision. UK expressed that safety is a responsibility that the manufacturer has to address according to separate product safety regulations. UK also expressed some sympathy with the position of the German authority in it’s role as both the Road Safety Authority and Type Approval Authority, but that this was the Type Approval Authoriy Meeting and the TAA in Member States had an obligation to ensure the type approval legislation was correctly applied. Also that the TAAM has no remit to alter or disregard the regulations where they are clear. The UK position is that manufacturers must use the correct R1234yf gas as of 1 Jan 2013, with no extension of moratorium; UK

highlighted safeguard clauses in the framework directive which could be cited if Member States remained unhappy. Germany invited views and feedback from other Member States, to be provided following the meeting.




5.19. 2007/46 – Article 3 (UK2) QUESTION FOR TAAM Belgium – December 2012 2007/46

LEGISLATION

Article 3 – Definitions ‘EC type-approval certificate’ means the certificate set out in Annex VI or in the corresponding annex to a separate directive or regulation, the communication form set out in the relevant Annex to one of the UNECE Regulations listed in Part I or Part II of Annex IV to this Directive, being deemed to be equivalent thereto;

Background

Several regulations now have additional suffix letters or numbers added to the approval number in order to identify a specific approval level or the inclusion of additional requirements, for example Regulation 64 states the following:

4.4. There shall be affixed, conspicuously and in a readily accessible place specified on the approval form, to every vehicle conforming to a vehicle type approved under this Regulation an international approval mark consisting of: 4.4.1. A circle surrounding the letter "E" followed by the distinguishing number of the country which granted approval ; 4.4.2. The number of this Regulation, followed by: 4.4.2.1. The letter "R" in the case of vehicles approved in accordance with paragraph 4.1.1. only; 4.4.2.2. The letter "P" in the case of vehicles approved in accordance with paragraph 4.1.2. only; 4.4.2.3.The letters "RP" in the case of vehicles approved in accordance with both paragraphs 4.1.1. and 4.1.2; 4.4.3. A dash and the approval number to the right of the markings prescribed in paragraphs 4.4.1. and 4.4.2.

Therefore for a vehicle that complies with the requirements of 4.4.2.3 of the regulation will carry the approval number E11 64RP-021234. However it is not clear if this number should appear on the certificate including the additional suffixes

Question: Should the approval certificate contain all or any additional letters/numbers?

Option Possible Solution Comments A No. The approval number on the certificate

should only contain the approval authority identification (E11) the regulation number (64R 02) and the individual approval number (1234)

B Yes. The approval number on the certificate should contain all the identification requirements above and any additional suffixes

C Other

TAAM Minutes:

Prior to the meeting, internal VCA confirmation had been received that the additional characters would be acceptable for GEARS.

This item was discussed in relation to R64, also R13H, R97, R116 and lighting subjects, and mention was made that parties present should consider their administrative systems.

Germany, Austria supported option B. Belgium confirmed that option B is used in practice. Netherlands confirmed RDW approvals are practically to option B, although A would be accepted. Netherlands confirmed this was already under discussion, and will be taken this to Geneva to be fixed in the wording as various UNECE regs are amended. Austria commented that the special character “AR” (combined letters) required in context of R23 annex 2 does not exist.

The Meeting chose solution B. No objections were raised.




5.20.EC Regulation 715/2007 and 692/200 as amended by EU Regulation 630/2012 (UK3)

TAAM Belgium – December 2012

EC Regulation 715/2007 and 692/200 as amended by EU Regulation 630/2012: Emissions from light passenger and commercial vehicles (Euro 5 and Euro 6) and on access to repair and maintenance information

LEGISLATION Annex XVI – requirements for vehicles that use a reagent for the exhaust after treatment system

BACKGROUND

Annex XVI of the above mentioned legislation includes requirements for operation of the driver inducement systems if the reagent tank is allowed to become empty, or the reagent dosing system is not operational.

There are four inducement options available to the manufacturer, described in paragraph 8.3 of Annex XVI. The ‘no engine restart after countdown’ approach (8.3.1) includes a gradual introduction before the full inducement system is activated and engine starts are prevented.

“8.3.1. A ‘no engine restart after countdown’ approach allows a countdown of restarts

or distance remaining once the inducement system activates. Engine starts initiated by the vehicle control system, such as start-stop systems, are not included in this countdown. Engine restarts shall be prevented immediately after the reagent tank becomes empty or a distance equivalent to a complete tank of fuel has been exceeded since the activation of the inducement system, whichever occurs earlier.”

Paragraph 8.4 of Annex XVI specifies the following:

“8.4. Once the inducement system has fully activated and disabled the vehicle, the

inducement system shall only be deactivated if the quantity of reagent added to the vehicle is equivalent to 2 400 km average driving range, or the failures specified in sections 4, 5, or 6 have been rectified. After a repair has been carried out to correct a fault where the OBD system has been triggered under point 7.2, the inducement system may be reinitialised via the OBD serial port (e.g. by a generic scan tool) to enable the vehicle to be restarted for self-

diagnosis purposes. The vehicle shall operate for a maximum of 50 km to enable the success of the repair to be validated. The inducement system shall be fully reactivated if the fault persists after this validation.”

QUESTION

The final sentence of paragraph 8.4 specifies that the inducement system is “fully reactivated” if the fault still persists after the validation period.

In the case of the ‘no engine restart after countdown’ approach, does “fully reactivated” mean that the countdown starts again from the beginning, or does “fully reactivated” mean that engine restarts are immediately prevented?

Possibilities of solution

Option Possible Solution Comments A “Fully reactivated” means the countdown starts

from the beginning

B “Fully reactivated” means that engine starts are immediately prevented

X

TAAM Minutes:

France suggested reactivated relates to engine run (solution B). Germany, Netherlands and Belgium agreed with option B.



Tel. : 02 / 277.30.50 - Fax : 02 / 277.40.84

5.21. Are ranges allowed on COC masses and dimensions data for extendible and modular trailers?

Directive or Regulation number: - 2007/46/EC - ECE R54

Subject:

BMOT-TAAM-2012-002 v1.00 – 27 November 2012

Dimensions and masses on COC for extendible trailers for exceptional load transport trailers O4.

Reference to Annex, etc in the Directive or Regulation: - 2007/46/EC Annex II Part A 5.10 - 2007/46/EC Annex IX 0.

Background: As mentioned into the Directive 2007/46/EC, it’s not permitted to mention any range of values in the various entries of the CoC.

A lot of vehicles concerned by the definition of exceptional load transport are extendible therefore concerned by at least a range regarding the length, wheelbase and width in some cases.

Moreover in some cases and with speed restrictions (see UNECE 54), the maximum permissible load per tyre may vary. This will lead to variations of the maximum permissible axle load and the technically permissible maximum laden mass of the vehicle.


A B C

Text: 2007/46/CE

ANNEX II

PART A

Criteria for vehicle categorization 5. Special purpose vehicles 5.10. Exceptional load transport trailer SK a vehicle of category O 4 intended for the transport of indivisible loads that is subject to speed and traffic restrictions because of its dimensions. Under this term are also included hydraulic modular trailers irrespective of the number of modules

ANNEX IX

EC CERTIFICATE OF CONFORMITY 0. OBJECTIVES The certificate of conformity is a statement delivered by the vehicle manufacturer to the buyer in order to assure him that the vehicle he has acquired complies with the legislation in force in the European Union at the time it was produced. The certificate of conformity also serves the purpose to enable the competent authorities of the Member States to register vehicles without having to require the applicant to supply additional technical documentation. For these purposes, the certificate of conformity has to include:

(a) the Vehicle Identification Number; (b) the exact technical characteristics of the vehicle (i.e. it is not permitted to mention any range of value in the various entries).

Question: How to handle the length range and technical maximum permissible masses?

Solutions:

A Variations in vehicle length should be mentioned as a remark on the COC.

B

Mass increments based on speed related increments in tyre load capacity ECE R54 are subject to specific national regulations for each Member State individually. A specific national annex regarding masses may be included in the information document. These values may be mentioned as a remark on the COC.

C Manage the issue on a national / individual approval level only.

Authority: Type approval Authority 6 e/E

Remarks:

TAAM Minutes: Austria confirmed that minimum length is entered in the relevant CoC field. All possible lengths would also be listed under remarks section of CoC. (essentially solution A) Ireland supported option A. Germany reported that the new Masses and dimensions regulation (GSR) - when published – provides text that would support both solutions A & B. UK supported option C, under national approval. Raised national approval vs EWVTA.

The meeting accepted that a minimum length should be shown on the CoC and any additional (longer lengths) in remarks. Further, new GSR Masses & Dimension regulation should be reviewed when published for any nationally based derogation clauses.


TAAM QUESTION – FINLAND 2

1(1) 16.11.2012

5.22. TAA Meeting on Conformity of Production procedures

TAAM QUESTION, Brussels 6.–7.12.2012

COUNTRY: Finland

QUESTION NR.: 2

SUBJECT: TAA Meeting on Conformity of Production procedures

REFERENCES (DIRECTIVE/ANNEX/ETC):

Framework Directive 2007/46/EC

QUESTION/PROBLEM/CONCERN: Directive 2007/46/EC among other responsibilities mandates in Article 5 the manufacturer to ensure conformity of production. In Article 12, the Member State granting the approval is required to verify the presence of adequate conformity of production measures established by the manufacturer and, to do this by means limited to the procedures set out in Annex X of the Framework Directive and in those regulatory acts that contain specific requirements. Furthermore, when requested by the approval authority of the Member State granting the approval the actual initial assessment and/or verification of product conformity arrangements may also be carried out by the approval authority of another Member State or the appointed body designated for this purpose by the approval authority. The procedures and practises chosen by different Member States may vary from one another, and as the increasing number of Member States also produces increasing number of bodies practising conformity of production measures under the Framework directive.

Finland would like to raise a question whether other delegates of the TAAM have interest in having a meeting around topics related to conformity of production measures? Learning, sharing and benchmarking amongst the approval authorities could be useful. One issue could be discussing the influence of the new regulations on L- and T- categories in the context of conformity of production measures.

Realizing that, this is a little off-topic on the agenda of the TAAM and the experts on CoP would in many cases be other than those attending the TAAM, Finland would like to express a will to host such a meeting if considered desirable by other delegates of the TAAM.

Comments:

TAAM Minutes:

Prior to the meeting, Helen Gant was approached and confirmed intent to participate. Meeting around CoP measures: Belgium, Germany, UK, Netherlands, Spain and Estonia all confirmed intent to participate in this meeting (plus presumably Finland). Also proposed to combine RMI discussion (question 5.23) into this group. Dates will be proposed and circulated by Finland.

5.23 Germany 5: Repair-and-Maintenance-Information, RMI-subgroup

KBA

Info:


As already announced in the first 2012 TAAM in Bratislava, the KBA would like to share experiences to the application of the provisions of RMI with other TAA.

Therefore we would like to prepare a meeting as a TAAM-subgroup which may be situated in parallel to the GSR-SG.

TAAM Minutes:

The group agreed that the RMI discussion is to be held as part of the CoP meeting. See question 5.22




5.24. 2007/46 – Annex 1 (UK5)

TAAM Belgium – December 2012 LEGISLATION Annex 1 - 2.6 Mass in running order; Mass of the vehicle with bodywork and, in the case of a towing vehicle of category other than M1 , with coupling device, if fitted by the manufacturer, in running order, or mass of the chassis or chassis with cab, without bodywork and/or coupling device if the manufacturer does not fit the bodywork and/or coupling device (including liquids, tools, spare wheel, if fitted, and driver and, for buses and coaches, a crew member if there is a crew seat in the vehicle) (h) (maximum and minimum for each variant): . . .

Background

VCA would like the opinion of the TAAM on how to define the racking that is fitted to some vans (see examples below).

If the racking is considered as part of the type approval system there are three possibilities for dealing with this situation

One of the main reasons for invalidating the type approval will be the potential increase in mass in running order which exceeds the permitted tolerance. The correct mass in running order should be stated at item 13 of the CoC.

If the racking is considered as part of the vehicle payload then this does not affect the type approval and no further action is required

Question: Should the racking be classed as part of the mass in running order or should the racking be classed as payload?


A The racking should be part of the mass in running order

B The racking should be considered part of the payload

X

C Other

TAAM Minutes: (Note: “MiRO“ = Mass in Running Order) UK: Outlined the question. Asked if the racking etc is part of the MiRO does this mean the CoC no longer has effect? Austria stated that a flexible approach is taken and for registration, MiRO is altered from that on the CoC at the request of the owner. Spain stated that this is part of MiRO – payload can be removed without use of tools. Belgium stated that it has a list of permitted “payload” items including interior racks, roof racks etc. Belgium will circulate. Ireland stated that if vehicle exceeds CoC MiRO by the percentage tolerance the vehicle would require IVA. UK stated that based on framework article 24, IVA could be issued based on appropriate process and CoP measures. Austria: responded that they would not require IVA, data update only. Luxembourg stated that as a stage 1 build only, this vehicle racking would be payload. If a stage 2 build were involved then the MiRO could be updated. Germany stated that if fitted by the vehicle manufacturer they could accept either payload or MiRO approach, but chose option B. (payload). Latvia stated that they would use the actual MiRO and alter CoC but consider WVTA to still be valid.


Sweden 2


Page

1(2)


5.25. Technically permissible maximum laden mass

SUBJECT: Technically permissible maximum laden mass (TPMLM)

DIRECTIVE: 2007/46/EC

RELEVANT SECTION:

Annex II: Part B (old and new) Concern: Multiple TPMLM for one version of O1 and O2 vehicles.

Annex II (old): B. Definition of vehicle type --- 4. For the purpose of categories O1, O2, O3 and O4: --- ‘Version’ of a variant means vehicles, which consist of a combination of items shown in the information package. ---

5. For all categories:

Full identification of the vehicle just from the designations of type, variant and version must be consistent with a single accurate definition of all the technical characteristics required for the vehicle to be put into service.

Annex II (New): Part B Criteria for vehicle types, variants and versions --- 5. Categories O1 and O2

--- 5.3. Version 5.3.1. A ‘version’ within a variant shall group the vehicles which have all the following features in common: (a) the technically permissible maximum laden mass; (b) the concept of the suspension (air, steel or rubber suspension, torsion bar or other); (c) the concept of the drawbar (triangle, tube or other).

QUESTIONS:

1. Can there be more than one TPMLM for one version of a vehicle in categories O1 and O2 based on the definitions above?

2. The CoC should have the TPMLM given under item 16, so there can only be one value for one version. (the procedure with intended




Sweden 2


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2(2)


registration/in service TPMLM under item 17 is not applicable for categories O1 and O2 according to Annex IX.)

5 Type approving authority "e"


1 X 2 X

TAAM Minutes:

Austria accept minimum 60% of TPMLM (F1) as registration mass (F2) (however this is not the question!)

Germany, Spain, UK, Lithuania agreed with the Swedish proposal. The group agreed that only one TPMLM per version would be permitted.




mailto:[email protected]


A x B x C x


Tel. : 02 / 277.30.50 - Fax : 02 / 277.40.84

5.26. Multistage EC type-approval after 29 Oct 2012 on base WVTA not amended by 678/2011/EC. Meet regulation 678/2011/EC of not?

Directive or Regulation number: - 2007/46/EC

Subject:

BMOT-TAAM-2012-003

v1.00 – 28 November 2012

Effect of mandatory amendations on directives during multistage type-approval.

Reference to Annex, etc in the Directive or Regulation: - 2007/46/EC

Background: The possibility exists to have a multi-stage EC type-approval, in which the first stage is approved in accordance with framework directive 2007/46/EC not amended by regulation 678/2011/EC and the second and following stages are issued after 29 October 2012 and therefore approved in accordance with the framework AND amended by regulation 678/2011/EC.

Since regulation 678/2011/EC re-defines type, variant and version there may be a hard to resolve incompatibility between the vehicle matrix and key from the different stages.

Question: May regulation 678/2011/EC be ignored after 29 October 2012 for multistage type-approvals when the previous type-approval is not amended by 678/2011/EC?

Solutions: A Yes, the multistage type-approval must at least comply with the amendation of the previous stage.

B No, the multistage type-approval must comply with the actual amendation. This can imply a full revision of the base approval and its consecutive stages.

C Manage the issue on a national / individual approval level only.


Remarks:

TAAM Minutes: France and UK both agreed with A. Germany take a case by case approach (giving an example of box van vs ladder chassis and cab) but agree with A. Spain proposed B.

A multistage group discussion was proposed – a clear statement is needed in the framework annex regarding precise criteria for multistage.


5.27 Germany 6: Directive 2007/46/EC Worst-case description in test reports Issue:

Directive 2007/46/EC annex V appendix 3 number 5 states that the test report shall include a reference stating how the worst-case selection has been made by the manufacturer, if applicable. In the past, there were issues of obviously wrong worst-case selection. The requirement concerning a clear analysis (and in result clear description) of possible combinations of most unfavourable features would avoid submission of unacceptable test reports. If it is not possible or not practicable to test the one combination of most unfavourable features, a detailed description would help to evaluate if the selection (the test report) is acceptable. Germany would like to avoid different interpretation of the corresponding clause in 2007/46/EC and thus in possible disadvantages for approval authorities requiring a detailed description. Questions: Which level of detail describing the worst case selection is required in test reports? Prescription Directive 2007/46/EC


A The selection is to be described in detail.

Easy to evaluate each case by the approval authority. Maximum workload for the technical service.

B Reference to internal documented procedures of the technical service describing the selection is acceptable. Deviations must be described in detail.

Example:

Worst-case selection in accordance with procedure A-123. For the given type, it is impossible to take … Hence the combination of … is seen as worst case.

The general approach (internal procedures) will be evaluated within the designation process (incl. surveillance). All required information for approval granting is available. Optimal workload for the technical service.

C A statement that the worst case was tested is sufficient (no detailed description). The technical service has documented procedures describing the selection. Deviations are documented only internally by the technical service.

The general approach (internal procedures) and documentation of deviations will be evaluated within the designation process (incl. surveillance). Small sample sizes in designation. Required information for approval granting is available only on request. Minimal workload for the technical service.

Type approving authority "e" 1 Selection of solution accepted refused

A x B x C x

TAAM Minutes: UK proposed solution B. Worst case practice should be followed and any exceptions noted. Belgium and Netherlands concurred, providing information is available on request. The Meeting chose solution B.

C:\Users\egiblen\Desktop\TAAM report\Brussels Agenda item 5.27. - Germany_6 Directive 2007_46_TestReports.doc




5.28. 630/2012/EC (UK6) TAAM Belgium – December 2012

LEGISLATION

Annex III 3.5 states the following. From the relevant dates set out in Article 10(4) and 10(5) of Regulation (EC) No 715/2007, paragraph 4.1.2. of Appendix 3 to Annex 4 shall be understood as follows:

Tyres The choice of tyres shall be based on the rolling resistance. The tyres with the highest rolling resistance shall be chosen, measured according to ISO 28580. If there are more than three tyre rolling resistances, the tyre with the second highest rolling resistance shall be chosen. The rolling resistance characteristics of the tyres fitted to production vehicles shall reflect those of the tyres used for type-approval

Background Some countries require all the tyre and wheel combination to be listed in the approval, therefore if all combinations are listed in the emissions documentation then they should all be considered for type approval purposes, however winter tyres are generally option tyres and are not fitted in production

Question: If a manufacturer wants to declare 2 normal tyres + 3 winter tyres would TAAM members expect the manufacturer to conduct coast downs and emissions test on the winter tyre which would generally have the worst rolling resistance or would they except that winter tyres are not normally production tyres?


A All options should be considered including winter tyres and the worst case tyre selected in accordance with the tyre selection requirements of section 3.5

B Only tyres fitted on production vehicles should be considered, if winter tyres are not fitted to production vehicles they should not be considered.

TAAM Minutes: UK and Germany proposed solution B. After a group discussion it was agreed that it was unclear regarding the definition of “winter tyres”, and the question should be reformulated and return at a future TAAM.


Tel. : 02 / 277.30.50 - Fax : 02 / 277.40.84

5.29. N3 vehicle as lorry BA AND tractor BC. How should its COC be composed? BMOT-TAAM-2012-004

Directive or Regulation number:

- 2007/46/EC - 70/221/EEC - 89/297/EEC - 94/20/EC and ECE R55

Subject: A N3 vehicle being used lorry and tractor for semi-trailers

v1.00 – 28 November 2012


- 2007/46/EC Annex II - 70/221/EEC Annex II, 5.5 - 89/297/EEC Annex I, 1.1

Background:

• Lorry: a vehicle which is designed and constructed exclusively or principally for conveying goods (bodywork type BA).

• Tractor unit for semi-trailer: a towing vehicle which is designed and constructed exclusively or

principally to tow semi-trailers (bodywork type BC).

The requirements do not match for both bodywork types BA & BC for following regulatory acts: • 70/221/EEC Rear under run protection, Annex II, 5.5 • 71/3220/EEC Breaking • 89/297/EEC Lateral protection, Annexe I, 1.1 • 94/20/EC Mechanical couplings

Text:

Question: 1. What should be the primary bodywork type? 2. On what level should the bodywork type selection be managed? 1. Solutions:

A BA Lorry. B BC Tractor of semi-Trailer C The manufacturer may chose between BA and BC.

Decision 1: Solution Accepted Refused A X B X C X Decision 2: Solution Accepted Refused A X B X C X

2. Solutions: A The issue is managed on national/individual approval level only B Manage on EC type approval level and indicate the double vehicle status as remark on its COC. C Both A & B solutions are possible.


Remarks:

TAAM Minutes:

Question 1: After a group discussion, the meeting proposed question 1 option C. Question 2: France stated this would be handled nationally (Q2: option A) Germany concurred, stating that no EWVTA is possible therefore handle nationally / IVA.

The Meeting chose: Question 1 solution C. Question 2: solution A

Section 6:

Other Agenda Items from Brussels TAAM

A No B Yes C Other

6.2 76/114 and 19/2011 Trailer statutory plates Lithuania

Directive 76/114/EEC and Regulation No. 19/2011

Statutory plate Issue Directive 76/114/EEC and Regulation No. 19/2011 prescribes requirements for statutory plates. Question:

Is the statutory plate for two axles trailer fulfilled correct? Possibilities of solution Comments


Selection of solution accepted refused A X B X C X

TAAM Minutes:

The meeting discussed the example stat plate, which is not acceptable. It should fulfill the specific provisions of 19/2011 para 3.1 a key issue being a combined mass stated for axle 1 and axle 2, these must be separately enumerated line items.


6.3 ECE R43 Plastic glazing not used for driver field of view (TAAM RIGA item 5.27) UK ECE R43: Requirements for plastic glazing not used for driver’s field of view UK 2

BACKGROUND

EU and ECE Legislation for Forward Vision (77/649/EEC, as amended, and ECE R125.00) and Indirect Vision (2003/97/EC, as amended, and ECE R46.02) makes provision for specific fields of view to be visible to the driver through the vehicle‟s glazing and mirrors respectively

R43 covers component approval and vehicle installation requirements for "Safety glazing material requisite for driver visibility". This is furthre clarified by Section 2.18 (2.18.1 and 2.18.2) to mean "Safety glazing material requisite for driver visibility" through which the driver can view the road when driving or manoeuvring the vehicle.

Under the provisions of ECE R43, safety glazing used on vehicles must be approved and appropriately marked. In the case of rigid plastic glazing the marking will be VIII together with one of the following symbols:

/A for forward facing panels

/B for side, rear and roof glazing

/C in locations where there is little or no chance of head impact

The test requirements for rigid plastic glazing include abrasion tests (see Paragraph 8.2.1.2 and Annex 14 Section 6.1). There are two performance levels identified for the abrasion test and these are identified via addition markings as follows:

- High Performance: /L for panes with a light scatter not exceeding 2 per cent after 1,000 cycles on the outer surface and 4 per cent after 100 cycles on the inner surface (see annexes 14 and 16, paragraph 6.1.3.1.)

- Lower Performance: /M for panes with a light scatter not exceeding 10 per cent after 500 cycles on the outer surface and 4 per cent after 100 cycles on the inner surface (see annexes 14 and 16, paragraph 6.1.3.2.)

DISCUSSION

Many cars are now specified with rigid plastic glazing and, in addition to glazing used to meet the forward and indirect (rearward) vision legislation prescribed by 2007/46/EC, plastic glazing is also often used for supplementary glazing and even for vehicle styling purposes.

It is clear that, according to EC R43, all safety glazing used for installation on vehicles must be approved and appropriately marked.

The installation requirements in Annex 21 (Paragraph 4.2.2) state that plastic safety glazing used for the driver‟s forward and/or rearward vision shall bear an additional symbol A/L or B/L, as defined in paragraphs 5.5.5 (noting that, as an alternative, the rear glazing in the folding roof of a convertible vehicle may bear the additional symbol /B/M).

It therefore also seems clear that all plastic glazing must be subjected to one of the two abrasion tests and that plastic glazing used for the regulated fields of view must be marked A/L or B/L (depending on its location)

However Annex 21 Paragraph 4.2.3 also makes some provisions for „other safety glazing‟ and it is not completely clear whether there is some flexibility for the lower performance abrasion test to be accepted for glazing located in areas not used to meet the prescribed R125 and R46 fields of view.

QUESTION 1

When a vehicle is specified with rigid plastic glazing that is not needed in order to meet the fields of view prescribed by ECE Regulations 46 and 125, but through which it is still possible to see the road surface, is it necessary for the glazing to be marked with the additional symbol A/L or B/L (depending on its location) or would A/M or B/M respectively (i.e. a lower level of abrasive resistance) be acceptable?


A

The glazing must be marked with the additional symbol A/L or B/L (depending on its location)

B

The glazing may be marked with the additional symbol A/M or B/M (depending on its location) for glazing not needed in order to meet the fields of view prescribed by ECE R46 and ECE R125

QUESTION 2

Would plastic sheet with any light transmission above zero be considered to be

glazing? Possibilities of solution Comments

A

Yes, any plastic sheet located within the scope of R43 Section 2.18 and with any light transmission above zero would be considered to be glazing and would have to be approved accordingly

B

No

In this case what would be the threshold for light transmission? This can be identified during the TAAM discussion

LEGISLATION ECE R43 (Supplement 13)

1. SCOPE

This Regulation applies to:

(a) safety glazing materials intended for installation as windscreens or other panes, or as partitioning, on vehicles of category L with bodywork, M, N, O, and T 1/;

(b) vehicles of category M, N and O with regard to the installation of these

materials;

in both cases, to the exclusion of glazing for lighting and light-signalling devices and instrument panels, of special bullet-proof glazing and of double-windows. [r43s13-9]

2. DEFINITIONS 2.18. "Safety glazing material requisite for driver visibility"

2.18.1. "Safety glazing material requisite for the driver's forward field of vision" means all the

glazing situated in front of a plane passing through the driver's R point and perpendicular to the longitudinal median plane of the vehicle through which the driver can view the road when driving or manoeuvring the vehicle.

2.18.2. "Safety glazing material requisite for the driver's rearward vision" means all glazing

situated behind a plane passing through the driver's R point perpendicular to the longitudinal median plane of the vehicle through which the driver can view the road when driving or manoeuvring the vehicle.

2.19. "Opaque obscuration" means any area of the glazing preventing light transmission.

4. MARKINGS 4.1. Every piece of safety glazing material, including the samples and test pieces submitted for

approval, shall bear a trade name or mark as listed under item 3 of annex 1. Manufactured parts must bear the ECE Regulation No. 43 number allocated to the prime manufacturer. The marking shall be clearly legible and indelible.

5. APPROVAL

5.5.5. VIII In the case of rigid plastic glazing. In addition the appropriate application will be signified by:

/A for forward facing panels

/B for side, rear and roof glazing

/C in locations where there is little or no chance of head impact

In addition, for plastic glazing which has been submitted to the abrasion resistance tests described in annex 3, paragraph 4, the following markings shall also be applied as appropriate:

/L for panes with a light scatter not exceeding 2 per cent after 1,000 cycles on the outer surface and 4 per cent after 100 cycles on the inner surface (see annexes 14 and 16, paragraph 6.1.3.1.)

/M for panes with a light scatter not exceeding 10 per cent after 500 cycles on the outer surface and 4 per cent after 100 cycles on the inner surface (see annexes 14 and 16, paragraph 6.1.3.2.)

6. GENERAL REQUIREMENTS 6.1. All glazing materials, including glazing material for the manufacture of windscreens, shall

be such that, in the event of shattering, the danger of bodily injury is reduced as far as possible. The glazing material shall be sufficiently resistant to the incidents likely to occur in normal traffic, and to atmospheric and temperature conditions, chemical action, combustion and abrasion.

6.2. Safety glazing materials shall in addition be sufficiently transparent, shall not cause any

noticeable distortions of objects as seen through the windscreen, and shall not give rise to any confusion between the colours used in road-traffic signs and signals. In the event of the windscreen's shattering, the driver must still be able to see the road clearly enough to be able to brake and stop his vehicle safely.

7. PARTICULAR REQUIREMENTS

All types of safety glazing shall, depending on the category to which they belong, comply with the following particular requirements:

7.1. as regards toughened-glass windscreens, the requirements contained in annex 4;

7.2. as regards uniformly-toughened glass panes, the requirements contained in annex 5;

7.3. as regards ordinary laminated-glass windscreens, the requirements contained in annex 6;

7.4. as regards ordinary laminated-glass panes other than windscreens, the requirements

contained in annex 7; 7.5. as regards treated laminated-glass windscreens, the requirements contained in annex 8;

7.6. as regards safety-glass panes faced with plastics material, in addition to the relevant

requirements listed above, the requirements contained in annex 9; 7.7. as regards glass-plastics windscreens, the requirements contained in annex 10;

7.8. as regards glass-plastics panes other than windscreens, the requirements contained in

annex 11; 7.9. as regards double-glazed units, the requirements contained in annex 12.

7.10. as regards rigid plastic glazings, the requirements contained in annex 14.

7.11. as regards flexible plastic glazings, the requirements contained in annex 15.

7.12. as regards rigid plastic double-glazed units, the requirements contained in annex 16.

8. TESTS 8.2.1.1. Safety glass panes shall be subjected to the tests listed in the following table

Plstics other than windscreen: Rigid Plastics for motorised vehicles:

- Abrasion : A14/6.1

Annex 14 - RIGID PLASTIC GLAZINGS OTHER THAN WINDSCREENS

6. TEST RESISTANCE TO THE ENVIRONMENT 6.1. TEST OF RESISTANCE TO ABRASION

6.1.3. Interpretation of results

6.1.3.1. In the case of glazing of class L, the abrasion test shall be considered to have given a

satisfactory result if the total light scatter after abrasion does not exceed 2 per cent after 1,000 cycles on the outer surface of the test sample and 4 per cent after 100 cycles on the inner surface of the test sample.

6.1.3.2. In the case of glazing of class M, the abrasion test shall be considered to have given a

satisfactory result if the total light scatter after abrasion does not exceed 10 per cent after 500 cycles on the outer surface of the test sample and 4 per cent after 100 cycles on the inner surface of the test sample.

6.1.3.3. For sun roofs, no abrasion test is required.

Annex 21 - PROVISIONS REGARDING THE INSTALLATION OF SAFETY GLAZING ON VEHICLES

4. SPECIFIC PROVISIONS APPLICABLE T0 VEHICLES OF CATEGORIES M AND N 1/ 4.2.1.1. The safety glazing through which the driver's forwards field of vision as defined in

paragraph 2.18.1. of this Regulation is obtained, must have a regular light transmittance of at least 70 per cent.

4.2.1.2. Plastic safety glazing shall bear an additional symbol /B/L, as defined in paragraphs

5.5.5. and 5.5.7. of this Regulation. 4.2.2. Safety glazing requisite for the driver's rearward vision

4.2.2.1. The safety glazing defined in paragraph 2.18.2. of this Regulation must have a light

transmittance of at least 70 per cent, but where two exterior rear view mirrors are fitted, the glazing is allowed to have a light transmittance below 70 per cent, provided that it shall bear the additional symbol V specified in paragraph 5.5.2. of this Regulation.

4.2.2.2. Plastic safety glazing shall bear an additional symbol A/L or B/L, as defined in

paragraphs 5.5.5. and 5.5.7. of this Regulation.

As an alternative, the rear glazing in the folding roof of a convertible vehicle may bear the additional symbol /B/M.

The rear glazing in the folding roof of a convertible vehicle may be made of a flexible plastic pane.

4.2.3. Other safety glazing

4.2.3.1. The safety glazing not covered by the definitions of paragraphs 2.18.1. and 2.18.2. of this Regulation shall bear the additional symbol V specified in paragraph 5.5.2. of this Regulation, if the light transmittance is below 70 per cent.

4.2.3.2. Plastic safety glazings shall bear one of the additional symbols defined in paragraphs

5.5.5., 5.5.6., and 5.5.7. of this Regulation. However, when the vehicle is intended for conveying passengers, glazings with the additional symbols /C/L or /C/M are not allowed at locations where there is a risk of head impact.

4.2.4. Exemptions

In the case of plastic safety glazings, the provisions related to abrasion resistance as referred in paragraphs 4.2.2.2. and 4.2.3.2. of this annex do not apply for the vehicles and glazing locations listed below:

( a ) ambulances

(b) hearses

(c) trailers, including caravans

(d) sunroofs and glazings located in the roof of a vehicle

(e) all glazings of the upper deck of a double-deck vehicle

No abrasion test/symbol is required.

Minutes from Riga TAAM (June 2011)

The meeting agreed as follows: Question 1: solution A Question 2: solution A

TAAM Brussels (December 2012)

UK outlined a prior agreement from TAAM at RIGA (item 5.27) although it did not appear that all member states are adhering to it. Germany stated that they recall discussions, and although an answer was forthcoming it could still be open to interpretation. Therefore Germany suggested that the issue be reviewed and discussed again. Netherlands did not have records to hand therefore could not comment very much but were content to discuss again.

UK to work with Belgium and Germany to prepare a question for the next TAAM.

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