1. Attestation Concept additional explanation and implementation proposal
Transmitted by OICA
SGR
Attestation Concept additional explanation and implementation proposal

2. Preamble
The concept of an attestation is mainly motivated by discussions in SGR0 about certain lighting functions which may be mandated in some CPs but remain voluntary in other CPs (albeit with if-fitted performance requirements) (e.g. DRL, rear fog lamps).
With document SGR OICA proposed the concept of an attestation as a possible way to handle this situation.
This document further elaborates the concept and proposes a first step of implementation while hinting at potential future steps.

3. Proposal (taken from SGR0-20-06)
Within one version of a UN Regulation a type approval authority can issue
a type approval (as we are used to) or
an attestation (new concept)
An attestation could be used when not all requirements of a UN Regulation are met
It would explicitly identify the differences compared to a type approval (respective forms could be added to the Regulation text as appendices to Annex 1/communication form)
It would not be subject to full mutual recognition, except for those markets having the same requirements as those contained in the attestation
However, it would have to be recognized by all CPs applying the UN Regulation for the content that it "certifies“
In a way, the concept of an attestation is like a L-IWVTA applied on the level of individual Regulations instead of on whole vehicle level.

4. Comparison of type approval and attestation
Subject to mutual recognition (if issued according to latest version)
Basis for U-IWVTA: TAs for all applicable UN-Regulations listed in Annex 4 are necessary
Vehicle meets all requirements for all lighting functions
To be accepted by all CPs applying R-48
Attestation
Not subject to mutual recognition
Basis for L-IWVTA: as soon as an attestation is used no U-IWVTA is possible
Vehicle meets all requirements for lighting functions except that no DRLs are fitted
To be accepted by all CPs applying R-48, but also accepting nationally vehicles without DRLs
Example UN R-48

5. Proposal for implementation (1st step)
The concept of attestation shall be introduced via an additional Schedule of administrative and procedural provisions to the 1958 agreement.
An attestation can be issued only in cases where a UN-Regulation explicitly foresees this. (For an example see next slides)
For this purpose a form for communication shall be included in the respective UN Regulation.
A typical case for application would be the presence of certain systems or subsystems (e.g. DRL, rear fog lamps, vehicle alarm system, etc.) that are required for type approval:
A type approval can only be issued if the system is present and complies with the requirements
An attestation can be issued if the system is not fitted
Neither a type approval nor an attestation can be issued if the system is fitted but does not comply with the requirements !

6. Example: UN R-48 (slide 1 of 2)
List of contents
1. Scope
2. Definitions …
12. Transitional Provisions
Annex 1: Communication form
Appendix 1: Attestation form
Annex 2: Arrangements of approval marks
Appendix 1: Arrangements of attestation marks

7. Example: UN R-48 (slide 2 of 2)
ANNEX 1 COMMUNICATION (Maximum format: A4 (210 x 297 mm)) issued by: Name of administration: concerning: Approval granted Approval extended Approval refused Approval withdrawn Production definitively discontinued of a type of vehicle with regard to the installation of lighting and light-signalling devices, pursuant to Regulation No. 48. Approval No.: Extension No.: Trade name or mark of the vehicle: Manufacturer's name for the type of vehicle: …
Appendix 1 COMMUNICATION CONCERNING ATTESTATION (Maximum format: A4 (210 x 297 mm)) (example only, appearance of marking tbd) issued by: Name of administration: concerning: Attestation granted Attestation extended Attestation refused Attestation withdrawn Production definitively discontinued of a type of vehicle with regard to the installation of lighting and light-signalling devices, pursuant to Regulation No. 48. The type of vehicle is not fitted with the following lighting functions which are mandatory in the Regulation (Strike out which does not apply) Rear fog lamps (cf. para.6.11) Day-time running lamps (cf. para.6.19) Attestation No.: Extension No.: Trade name or mark of the vehicle: Manufacturer's name for the type of vehicle: … E… 1

8. Potential future use of attestations
It is recommended to first implement attestations only where explicitly foreseen in an individual UN Regulation.
However, the concept would allow for further application once practical experience has yielded a necessary level of confidence
implement different applications of WLTP (GTR 15) into a UN Regulation
Exemptions for new technologies

9. Potential use of attestation concept for WLTP
Different “dialects of WLTP” (e.g. differences in required test procedures) can be implemented as Annexes of a single UN Regulation. Attestations instead of type approvals can be used to certify compliance with any such variant.
The type approval according to this Regulation would still be subject to mutual recognition and would cover a vehicle which meets the requirements of all Annexes.
For the EU an attestation testifying compliance to the “EU-Annex” (all parts of the cycle, 14° test, EU limit values) could be used and would have to be accepted
For Japan an attestation testifying compliance to the “Japan-Annex” (no extra high phase, no 14° test, Japan limit values) could be used and would have to be accepted
All Annexes could be updated within a single Regulation (maintaining the concept of mutual recognition of type approvals and safeguarding harmonisation as much as possible) but independently from each other
Series of amendments
Regulation body
Technical Annexes
EU-Annex
Japan-Annex
Other Annexes 00 X
EU-procedural provisions from the technical annexes
EU-limits A
J-procedural provisions from the technical annexes
J-limits A
???
Possible if needed 01 =
 J-limits B 02
 EU-limits B …
Mutual recognition of type approval if all Annexes are complied with

10. Potential use of attestation for new technologies
Schedule 7 of the revised 58 agreement foresees that an exemption approval for new technologies can be issued upon decision of the Administrative Committee.
While such decision is pending, a Contracting Party “may grant provisional approval for its territory only. Other Contracting Parties applying that UN Regulation may decide to accept this provisional approval in their territory.” (Schedule 7, para.2)
It is not specified how such a provisional approval shall be identified.
An attestation could be used for this purpose to clearly distinguish it from a type approval subject to mutual recognition.