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Simplification of Regulations Light Sources Regulations Nos. 37, 99, 128

Informal document WP.29-167-19 ( 167 th WP.29 session, 10-13 November 2015, Agenda item 3.5.4). Transmitted by the Informal Working Group Simplification of Lighting Regulations. Simplification of Regulations Light Sources Regulations Nos. 37, 99, 128. Request for guidance.

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Simplification of Regulations Light Sources Regulations Nos. 37, 99, 128

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  1. Informal document WP.29-167-19 (167th WP.29 session, 10-13 November 2015, Agenda item 3.5.4) • Transmitted by the Informal Working Group Simplification of Lighting Regulations Simplification of RegulationsLight Sources RegulationsNos. 37, 99, 128 Request for guidance GRE IWG SLR Informal Working Group Simplification of Lighting Regulations

  2. From WP29-164-18 Introduction 164th WP.29 Session , 11-14 November 2014 • Main objectives of the informal group • Reduce the administrative burden • Reduce burden on governments • Reduce regulatory burden for industry • Analysis and way forward for light sources • Document WP29-164-18 WP.29-167-xx

  3. Bubbles Size Reflects number of pages per paragraph/ annex From WP29-164-18 AnalysisamendmentsStatistics Colour Green Common text shared between light source regulations YellowCommon text with minor technology related lines Purple Common text with frequent technology related lines RedTotally different paragraphs Percentage of supplements amending a paragraph/annex “ The catalogue” Supplement with Annex 1 sheet insertion only R37 03 series In effect for 28 years 44 Supplements A1 A2 A3 A4 A5 A6 A7 A8 A9 Paragraph number WP.29-167-xx

  4. From WP29-164-18 • Concept for L.S. simplification R37 GRE WP.29 OLA New York 6 months Enforcement Administrative AC1 Technical Category Sheets R99 Administrative Technical Resolution “The catalogue” of Category Sheets Category Sheets Publication R128 Administrative Technical Dynamic references (under control of GRE and WP.29) Category Sheets WP.29-167-xx

  5. Introduction 164th WP.29 Session , 11-14 November 2014 • Report WP29-2014-1112, par. 42, GRE chair report “.......For the purposes of simplification and in line with the ideas of SLR, the expert from IEC proposed to separate data sheets for various light sources from Annex 1 to UN Regulations Nos. 37, 99 and 128 and to place them in a repository document administered by WP.29 (WP.29-164-18). WP.29 endorsed the proposed approach. “ WP.29-167-xx

  6. Status October 2015 GRE-74 First reading of the draft proposals • To amend the Regulations Nos. 37, 99 and 128 • To introduce a New Resolution on the Common Specification of Light Source Categories Comments • Editorials • Open items • Most can be resolved by GRE-75 • Guidance from WP.29 is requested, possibly advice from OLA needed WP.29-167-xx

  7. From GRE-74-15 Legal aspects From GRE-74-24 Simplification of Lamp (Device) regulations Consultations of OLA to identify any legal issues “…under the 1958 Agreement, Regulations can only be amended in accordance with the procedure set out in Article 12 of the Agreement. It follows that a Resolution cannot be employed to amend a Regulation.” WP.29-167-xx

  8. From GRE-74-24 Legal aspects Simplification of Light Source Regulations Evaluation • All requirements: still in the Regulations • The light source categories specification: moved to the Resolution (“the catalogue”) • The “list of light source categories allowed for use in lamps”: also moved (from the Light Source Regulations to the Resolution) • No references from the Resolution to Regulations(except for 3 to indicate in which lamps some light source categories are not allowed; no alternative, appropriate generic wording was found so far) WP.29-167-xx

  9. Legal aspects Simplification of light source regulations Conclusion • (Amendment of) the Resolution does not amend a Regulation • Amendment of one Regulation does not amend another Regulation • There seems no contradiction to the response from OLA that this Resolution is employed to amend a Regulation However, some CP’s in GRE seek confirmation Specifically on the “list of light source categories allowed for use in lamps” WP.29-167-xx

  10. Request for guidance • Can WP.29 reconfirm the approach for simplification of light source regulations? • Would it be acceptable if the Resolution is in English only? THANK YOU WP.29-167-xx

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