1. Transmitted by the expert
from the Russian Federation
IWVTA-27-XX
Agenda item …
Proposed Solutions for the Identified Concerns with Schedule 4 to the 1958 Agreement
June 2018

2. Concern # 1
The provisions of the UN Regulations below stipulate the approach to approval numbering other than that set out in Schedule 4:
R 37, 99, 128: Other structure of a type approval number, which may include letters in addition to numerals
R 90: Other complicated structure of a type approval number
R 108, 109: Same structure of a type approval number but it is assigned to a production unit (facility)
R 117: Same structure of a type approval number, which may be the same as that granted to a tyre type pursuant to R 30 or R 54 with the addition of suffixes corresponding to the level of compliance, which leads to the different length specification in section 2(c).

3. Initially Proposed Solutions for the Concern # 1
As per IWVTA amend Schedule 4 paragraph 3 to read: “3. Unless otherwise specified in the particular UN Regulations, an approval number shall be assigned to each type approved, and the type approval number shall consist of 4 sections. Each section shall be separated by the '*' character…”
In Schedule 4 paragraph 3 make a reference to the particular UN Regulations: “3. Unless otherwise specified in the UN Regulations Nos. 37, 90, 99, 108, 109, 117 and 128, an approval number shall be assigned to each type approved, and the type approval number shall consist of 4 sections. Each section shall be separated by the '*' character…”
Add a note either: after the header of Schedule 4 or after paragraph 4: “Note: The provisions of Schedule 4 do not apply to approvals granted pursuant to UN Regulations Nos. 37, 90, 99, 108, 109, 117 and 128.”

4. Feedback by the Correspondence Group (1)
As per IWVTA amend Schedule 4 paragraph 3 to read: “3. Unless otherwise specified in the particular UN Regulations, an approval number shall be assigned to each type approved, and the type approval number shall consist of 4 sections. Each section shall be separated by the '*' character…”
Japan, Netherlands, ETRTO, EC: Do not support

5. Feedback by the Correspondence Group (2)
In Schedule 4 paragraph 3 make a reference to the particular UN Regulations: “3. Unless otherwise specified in the UN Regulations Nos. 37, 90, 99, 108, 109, 117 and 128, an approval number shall be assigned to each type approved, and the type approval number shall consist of 4 sections. Each section shall be separated by the '*' character…”
Add a note either: after the header of Schedule 4 or after paragraph 4: “Note: The provisions of Schedule 4 do not apply to approvals granted pursuant to UN Regulations Nos. 37, 90, 99, 108, 109, 117 and 128.”
Japan, Netherlands, ETRTO: Support either option.
ETRTO proposes an alternative approach for UN Regulations 108, 109 and 117 without mentioning derogations
Japan, ETRTO: The particular UN Regulations to be referenced should be carefully reviewed by the responsible GRs
Netherlands: Our Type Approval Dept. has changed over to the Schedule 4 for all UN Regulations except for R 90. If the group decides an exemption in Schedule 4 is necessary, it should be left to the Contracting Party to choose for the numbering system according to the particular UN Regulation or to Schedule 4. ETRTO disagrees because of the need for manufacturers of the uniform filling system
Remark by the Russian Federation: The concern seem to be resolved with the introduction of UI
EC: Before such an amendment to Schedule 4, a careful review of all the concerned Regulations should take place and the need to maintain the current numbering system assessed in each case, especially in view of the fact that several CPs have already adapted the numbering of most of the concerned Regs. to Schedule 4. A consistent practice in all CPs should be ensured.

6. Proposal for the Concern # 1
Add a note after paragraph 4:
“[Note:
Until implementation of Unique Identifier as mentioned in Schedule 5 and relevant revision of UN Regulations, as a derogation from the provisions of paragraph 3 above, the type approvals granted pursuant to UN Regulations Nos. [37, 90, 99, 117 and 128] may have numbers with other content and structure.]”
Explanation: The square brackets are added to reflect on the position of EC. The IWG IWVTA may wish not to propose this amendment to WP.29 or to correct the list of UN Regulations. The IWG IWVTA also may wish to refer back to GRs responsible for particular UN Regulations amongst listed above to assess if those could be amended to meet the provisions of Schedule 4. In that case the following action items could be suggested:
Action items:
To request GRE (UN R 37, 99 and 128) GRRF (UN R 90 and 117), GRB (UN R 117) to review the mentioned UN Regulations to assess, if those could be amended to meet the provisions of Schedule 4.
To ask CPs about sharing with IWG IWVTA their experience of adapting the type approval numbering of the concerned UN Regulations to Schedule 4.

7. Possible follow-up for the Concern # 1
Following the proposal by EC, possible scenarios may have foreseen for amending the type approval numbering system in the concerned UN Regulations to address the relevance with the provisions of Schedule 4
UN Reg.
Solution for short term
Solution for long term
37, 99, 128
Separate type approval number from type approval marking. In this case the algorithm for assignment of characters in type approval marking should be developed to ensure that the same marking would not appear on different types
Introduction of Unique Identifier 90 ?
117
Do not mention suffixes in type approval numbers, but keep those on tyre sidewall marking

8. Concern # 2
The approval numbers granted before the entry into force of the Revised 1958 Agreement and Schedule 4 may have up to 6 digits in sequential number (referred to Section 3 in paragraph 3), although Section 3 allows just a 4-digit number.
In order to avoid confusion, it is considered appropriate to keep the same sequential number (i.e. more than 4 digits) for the extensions to approvals issued after the entry into force of the Revised Agreement and Schedule 4.
This case is not foreseen in the actual text of Schedule 4.

9. Initially Proposed Solutions for the Concern # 2
As per IWVTA amend Schedule 4 paragraph 3 Section 3 to read: “A four-digit An up to six-digit sequential number (with leading zeros as applicable). The sequence shall start from 0001.” The leading zeros in the sequence number are deleted to address the case when Contracting Parties use for leading digits, for example, the last two digits of a calendar year.
Add a note either: after the header of Schedule 4 or after paragraph 4: “Note: The provisions of Schedule 4 do not apply to extensions to approvals granted before the entry into force of the Revised 1958 Agreement.”

10. Feedback by the Correspondence Group (3)
As per IWVTA amend Schedule 4 paragraph 3 Section 3 to read: “A four-digit An up to six-digit sequential number (with leading zeros as applicable). The sequence shall start from 0001.” The leading zeros in the sequence number are deleted to address the case when Contracting Parties use for leading digits, for example, the last two digits of a calendar year.
Japan, Netherlands, ETRTO: Support increase the number of digits. Using in the number the last two digits of a calendar year should mean that the number becomes not more sequential, so that would not be in line with Schedule 4.
Japan: Propose to check with KBA (IWG DETA) that the increase of the number of digits is technically feasible.
ETRTO comment: Already now the structure of the approval number according to Paragraph 3 is not fixed because Section 2(c) may be empty (“if applicable”); so it would be good to check with KBA if the DETA structure has conditions or limits with regard to the number of digits (either fixed or limited to a max).

11. Feedback by the Correspondence Group (4)
Add a note either: after the header of Schedule 4 or after paragraph 4: “Note: The provisions of Schedule 4 do not apply to extensions to approvals granted before the entry into force of the Revised 1958 Agreement.”
Japan: Would like to discuss further the necessity to add the note in Schedule 4 since it may be considered obvious. (Currently this interpretation is included in Q&A document on Revision 3 of the 1958 Agreement and it would be enough)
In the Q&A # 20: "a Contracting Party may decide, if agreed by the holder of the UN type approval, to apply the numbering in accordance with Schedule 4 also to extensions of approvals that were originally issued prior to the entry into force of the Revision 3", which means the provisions of Schedule 4 are not applied to that extension of approvals that were originally issued prior to the entry into force of the Revision 3 in normal cases.
Netherlands, ETRTO: Not agreed. The IWG IWVTA already concluded that it should be left to the approval authority, in agreement with the manufacturer (as holder of the type approval), to choose the Schedule 4 numbering system for extensions to approvals granted before the entry into force of Revision 3.
EC: Q&A # 20 should be enough to solve this transitional issue.

12. Proposal for the Concern # 2
Amend Schedule 4 paragraph 3 Section 3 to read: “A four-digit An up to six-digit sequential number (with leading zeros as applicable). The sequence shall start from 0001.”
Plus:
Action item: Check with IWG DETA (and KBA) if the DETA structure has conditions or limits with regard to the number of digits (either fixed or limited to a max).
EC: Agree with this wording (up to six digit + keeping the 0001) and with the action item.

13. ANNEX - ETRTO alternative proposal to solve concern # 1
from the R108, R109 and R117 point of view.
Paragraph 3 amend to read:
“3. An approval number shall be assigned to each type* approved” with the asterisk at the footnote stating:
“* or retreading production unit (as per UN Regulations 108 and 109)”
Section 2 amend to read:
“Section 2: The number of the relevant UN Regulation, followed by the letter 'R', successively followed by:
Two digits (with leading zeros as applicable) indicating the series of amendments incorporating the technical provisions of the UN Regulation applied to the approval (00 for the UN Regulation in its original form);
A slash and two digits (with leading zeros as applicable) indicating the number of supplement to the series of amendments applied to the approval (00 for the series of amendments in its original form);
A slash and one or two a sequence of characters indicating the implementing stage(s) as specified in the relevant UN Regulation, if applicable.”
Comment by the Russian Federation: The addition of the note is considered more simple for justification compare to the addition of the proposed text taking into account the remaining UN Regulations not covered by this proposal.
Comment by EC: Is the clarification in the asterisk necessary? Maybe consider a Q&A? As for the change in c), the consequences for DETA should be checked.