1. Proposal to handle presence of systems and levels of stringency
Transmitted by OICA
SGR
Proposal to handle presence of systems and levels of stringency

2. Background
When developing IWVTA the issue of if-fitted systems in UN Regulations has been repeatedly discussed.
If a requirement is formulated as if-fitted it is not possible under mutual recognition to mandate it.
Solution for systems like ESC, BAS, and TPMS has been to split UN Regulations.
The same kind of discussion arises for DRL and rear fog lamps in conjunction with UN R-48.
EU mandate both DRL and rear fog lamps
Japan will accept the systems in the future but does not intend to mandate them
A related discussion is how to implement different levels of stringency within a UN Regulation, e.g. when implementing WLTP

3. Proposal
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) (proposals for better names are welcome)
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. Example 1: daytime running lights
UN R-48 mandates DRLs
a type approval can only be issued for vehicles with DRLs
an attestation could say: this type of vehicle complies with all requirements of UN R-48 except that it is not fitted with DRLs
EU would accept only vehicles with a full UN R48 type approval
Japan could accept both vehicles with a type approval (thus safeguarding that if DRL is fitted it also meets the technical requirements) or vehicles with an attestation that certifies the absence of DRL but the compliance to all other requirements.
Nevertheless, for vehicles with an attestation no national testing/approval process would be necessary for those items contained in the attestation.

5. Example 2: WLTP
A future “hierarchical” Regulation on WLTP could include the possibility for
type approval in case all requirements are met
One attestation for each hierarchical level that is needed. It is not even necessary that the levels are truly hierarchical
Content of the attestation
When tested under the conditions of test cycle A the vehicle type meets the set of limit values a1
When tested under the conditions of test cycle B the vehicle type meets the set of limit values b2
etc.
Using this concept, the limit values for different regimes (e.g. w/o high speed portion of WLTP) can be updated via single series of amendments

6. Implementation
The concept of an attestation could be introduced into Revision 3 of the 58-agreement once adopted via an additional schedule, i.e.
No need to change the frozen text
No need to delay adoption of Revision 3
Required attestation forms could be included into the respective UN Regulations, e.g. as appendices of the Annex 1 containing the communication form for type approvals