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Remarks and proposal on

Submitted by the expert from Germany Document IWVTA-SGR0-04-07


Remarks and proposal on

  1. the introduction of a flexible scheme in the UN-Regulation No. 0

  2. the application of Regulations listed in UN-Regulation No. 0 Annex 4, Section 1 (List of mandatory requirements)

  3. the introduction of a database for type approval information



At the 3rd meeting of the subgroup to set up the UN-regulation no. 0 (R0) for the introduction of an international whole vehicle type approval (IWVTA), two proposals from OICA and the UNECE secretariat were discussed to introduce different levels of flexibility in the whole vehicle type approval procedure.


As the expert from the UNECE secretariat has withdrawn his proposal and supports the principle of full flexibility introduced by OICA, only the OICA proposal remains for further discussion.


As presented by OICA, the introduction of a full flexibility would lead to the situation of additional administrative workload in documenting the status of application and accession of individual UN regulations within the IWVTA procedure. This workload will be either for the UNECE secretariat or a third party.


Germany does support the principle to introduce a scheme with flexibility in the R0, as the basic principle for application of earlier amendments of individual UN-regulations will be laid down in the future revision of the UNECE Agreement of 1958 as drafted by the IWVTA subgroup “58 Agreement”.


Germany proposes to combine the two ideas: firstly the application of a different series of amendment of an individual UN-regulation by a Contracting Party (CP) and secondly the acceptance of a series of amendment by a Contracting Party within the R0.

This would mean that a CP that is applying a specific series of amendment of an individual UN-regulation is accepting the same series of amendment of this regulation within R0 as an alternative requirement (Annex 4 Section 3 of R0 or Repository outside R0) to the (latest) series of amendment of this regulation listed in Annex 4 Section 1 of R0.


This approach is on one hand giving full flexibility to CPs in choosing individually the series of amendment that is applied as proposed by OICA and will on the other hand limit the administrative workload by adjusting the series of amendment in the individual regulation with the series of amendment that is applicable within R0. It will also limit the complexity of the potential mixture in applying different series of amendments for different regulations.


The principle of the acceptance of later series of amendments of the individual UN-regulations for individual UN-regulations as well as for R0 remains unchanged by this approach.


The documentation of the application of an earlier series of amendment of an UN-regulation can be linked to the status document for the 1958 Agreement (current document ECE/TRANS/WP.29/343/Rev.20) after the notification by a CP. The documentation for an individual regulation and the R0 would be combined in one document for the 1958 Agreement.


Example for changing status document WP.29/343/Rev.xx:



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Two new columns to be added

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Germany is supporting the approach that a CP acceding R0 shall apply all Regulations listed in Section 1 of Annex 4 of R0 (List of mandatory requirements). This would only possible as long as a CP is acceding to the individual regulations listed in this section.


As Japan pointed out in document IWVTA-SGR0-04-06, this could lead to conflicts for a CP that is applying the individual regulation only for vehicles of category M1 as required for the R0.


Germany would like to discuss the different possible scenarios as proposed by Japan within the IWVTA subgroups.



The introduction of an electronic database is seen as an important step for the introduction of an IWVTA procedure as it will be part of a quality assurance for the whole process (document IWVTA-09-06), not only for the exchange of type approval data.


Germany would like to discuss with the Netherlands and other delegations how the step to introduce a documentation platform and to mandate it for the R0 can be achieved based on the draft proposals submitted by the secretariat of the informal group DETA (IWVTA-SG58-04-05 and IWVTA-SGR0-04-05).



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