OICA assessment of the proposed changes to the 58

Agreement

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Transmitted by OICADoc.No.IWVTA-SG58-07-11

Table of contents

Article 1 - IWVTA Article 1 - Information documents Article 2 - Quality of approvals Article 3 - Mutual Recognition Article 5 - DETA and Unique Identifier Article 12 - Amendment procedure Article 12 - Earlier versions of UN Regulations Article 12 - New technologies Voting procedure Virtual testing Placeholder

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Article 1 - IWVTA

Proposed amendment introduces concept of IWVTA and new UN R0

Facilitation of national whole vehicle approval by combining various UN system and component approvals into Whole Vehicle Type Approval

Ultimate goal to have vehicle approval universally accepted, with total elimination national approval

IWVTA with limited recognition takes into account the different markets worldwide

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Article 1 - IWVTA

OICA strongly supports concept, but some challenges remain IWVTA must retain degree of flexibility In step 1, some national requirements will remain, such

that IWVTA will not cover "whole" vehicle Concept of IWVTA with limited recognition must be

further refined

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Article 1 - Information document

Proposed revision of 58 Agreement introduces concept of "information document Each Regulation to foresee such "information document" Expected to be based on general, complete list of data

for all information documents Should enable standard IT procedures for development

of paperwork Should facilitate certification paperwork

Supported by OICA

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Article 2 - Quality of approvals

Clarifications and new requirements in 58 Agreement on assessment and designation of technical services (placeholder) Improves quality of approvals Therefore also improves mutual trust Improves functioning of mutual recognition

Improves overall quality of 58 Agreement Whole concept strongly supported by OICA

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Article 3 - Mutual recognition of approvals

Amendments to Article 3 clarify and stress concept of mutual recognition of approvals Without further testing, documentation, certification and

marking Amendments to Article 3 also delete previous requirements

that product must be manufactured in designated territory (was probably contradicting WTO rules!)

New Article 3 strongly supported by OICA

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Article 5 - DETA and Unique Identifier

Proposed revision of 58 Agreement foresees introduction of DETA (Database for Exchange of Type Approval information)

Proposal also foresees introduction of Unique Identifier (UI) UI would replace approval mark on product UI enables all approval information to be obtained through DETA UI enables simplified product marking

Strongly modernises the current system of approval mark and exchange of approval information

Supported by OICA

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Article 12 - Amendments to UN Regulations

Article 12 currently foresees rather complicated procedure to amend Regulations, with possibility to retain current unamended versions as "alternative" is some CPs

Article 12 also is unclear as to what happens with CPs opposing the amendment

Proposed revision of Article 12: Once an amendment is established, it must be accepted

by all, even by those CPs who opposed originally (democracy by majority)

Unamended version of the Regulation remains valid (see next slides)

New Article 12 guarantees mutual recognition of approvals to latest levels and clarifies rights and obligations of all CPs

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Article 12 - Earlier versions of UN Regulations

Current situation: When a Regulation is amended, no possibility anymore to obtain approval to previous version as from a certain date

Latest level of Regulations sometimes incompatible with situation of some countries (infrastructure, economics, etc.), including CPs

Emerging markets, not CP, often accept UNECE approvals, but approvals to latest levels are often unnecessarily stringent, costly and impractical

Result: Manufacturers cannot obtain UN approval to earlier

versions Manufacturers must repeat national approvals, based

on test report to national standards/previous UN Regulations. 10

Article 12 - Earlier versions of UN Regulations

Proposed revision to 58 A foresees new possibility (no obligation!) to grant and accept approvals to any previous series of amendments Increases manufacturer flexibility to "tailor" products to

different markets: several markets may be covered by single UN approval to a previous version (reduction of national approval activities)

Concept is expected to attract more countries to 58 A: possibility to grant approval to previous version(s) for export to emerging markets

All CPs applying a UN R must accept approval to latest series Ensures mutual recognition of approvals

Whole concept strongly supported by OICA 11

Article 12 - New Technologies

New possibility to obtain "exemption" approval for new technologies that cannot be approved to existing UN Regulations Concept strongly based on current EU system,

experience of which is largely positive Will facilitate introduction of new technologies and

thereby accelerate safety and environment improvements

Whole concept strongly supported by OICA, but concerns remain that the "exemption approval" is not fully in line with other Articles, especially Article 3 and 12 (a CP applying the Regulation could nevertheless reject approvals granted under the "new technologies" regime!)

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Voting procedure

Possibility foreseen of voting by proxy (CP can delegate its vote to another CP) Expected to make 58 Agreement more attractive,

especially for far away countries

Any move to make 58 Agreement more attractive to more countries is strongly supported by OICA

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Virtual Testing

Proposed revision of 58 Agreement introduces concept of virtual testing (calculations, simulations) possibly replacing physical testing Based on EU experience Safeguard clauses are foreseen

Virtual testing already common practice during vehicle/component development

Virtual testing at type approval expected to shorten certification time

Strongly supported by OICA

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Placeholder - general concept

Proposal to group, in 58 Agreement, several WP29 documents (COP, criteria for technical services, procedures for type approval, interpretation issues)

Improves legal certainty of these WP29 documents Improves overall quality of 58 Agreement process Supported by OICA

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