Welcome to the latest installment of “International Update” – a monthly feature of the Washington Insider from John Creamer, MEMA’s advisor on international regulatory affairs. This update focuses on emissions and energy related activities under the UN World Forum for the Harmonization of Vehicle Regulations (WP.29) and its Working Party on Pollution and Energy (GRPE). Also noted is the official publication of the new EU General Safety Regulation (GSR).
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Global Real Driving Emissions Test Procedures
The draft Global Technical Regulation to establish generic Global Real Driving Emissions test procedures (Global RDE) should be delivered for adoption during the November 2020 session of the World Forum. The global procedures are based largely on the European Union’s 4th RDE Package (RDE4) as codified by Commission Regulation (EU) 2018/1832 of Nov. 5, 2018.
The U.S. Environmental Protection Agency (EPA), as part of the global discussions, has reviewed its test routes against RDE4. According to testing conducted by EPA’s National Vehicle and Fuel Emissions Laboratory (NVFEL) in Ann Arbor, Mich., the EPA routes can be arranged to meet RDE4 requirements for test validity even though they were not designed with RDE in mind. The broad conclusion was that vehicles tested by the EPA would generally pass RDE4. As a result, the EPA’s main concern with the draft GTR has been its focus on prescribed routes. EPA would prefer to see more flexibility to make the test procedures less route-dependent, possibly by defining standards for different driving conditions and segmenting the data requirements.
Although EPA has no mandate to align U.S. emissions standards with RDE, the agency sees potential in the draft GTR to reduce what are currently lengthy procedures for the validation of auxiliary emission control devices.
The Global RDE regulation is being developed in parallel with a variant for use under type-approval systems. As a result, a separate regulation is expected shortly after the GTR is finalized. The formal proposal of the GTR for review and approval by GRPE for submission to the World Forum is expected in June 2020.
Type Approval under WLTP Emissions Protocols
In 2015, the UN World Forum established new emissions and fuel-efficiency test procedures for light vehicles. Although not adopted under North American emissions standards, the Worldwide Harmonized Light Vehicle Emissions Test Procedure (WLTP) has become the centerpiece for next generation emissions requirements in Europe, Japan, and most other automotive markets. However, most markets use the international type approval system, which presents issues in transposing the WLTP methods to conform with government certification programs and national regulatory requirements.
The formal proposals for a new UN Regulation on light vehicle emissions have been submitted for approval by the GRPE. In order to provide time for adaptation, the proposals envision harmonization in two stages by establishing the new regulation (a “00 series of amendments” UN parlance), followed by a 01 series of amendments. Broadly, the initial regulation allows for a Level 1a (Europe regional option) and Level 1b (Japan regional option) approval. The 01 series of amendments would establish a globally harmonized Level 2, enabling internationally recognized approvals. An EU presentation includes a useful overview of the contents.
The International Motor Vehicle Inspection Committee (CITA) has proposed to require on-board diagnostic (OBD) systems to detect and record tampering with “any emissions-related controller.” The draft proposal would define tampering as the “inactivation, removal, disconnection, adjustment or modification of the emission control system, including any software, other logical control elements or components of such a system, that has the effect, whether intended or not, of worsening the emissions performance of the vehicle”.
Energy and Emissions Priorities on the Horizon
In addition to the preceding items, the world’s regulatory agencies are working on new requirements expected to reach formal adoption stages later this year or early next year. These priority initiatives include:
- Procedures for measuring sub-23 nanometer exhaust emission particles (June 2020)
- Harmonized procedures for the determination of electrified vehicle power (January 2021)
- Global requirements for electric vehicle battery durability (June 2021)
- Procedures for measurement of brake particle emissions, possibly towards mandatory requirements (June 2021)
EU General Safety Regulation
As we have been reporting periodically over the past couple of years, the European Commission has been working on a new regulation that sets out its objectives for safety requirements (see the March 2019 edition). The European Union has now officially published the new General Safety Regulation, which what it is commonly called. (Technically, the law has a much longer title: “Regulation (EU) 2019/2144 of the European Parliament and of the Council of 27 November 2019 on type-approval requirements for motor vehicles and their trailers, and systems, components and separate technical units intended for such vehicles, as regards their general safety and the protection of vehicle occupants and vulnerable road users”).
With this act, the new European agenda for upcoming vehicle safety requirements, including mandatory light vehicle automatic emergency braking and major changes to heavy vehicle direct vision requirements, has become law.