Association, Inc.

Issue No. 4, 2007

JAMA responds to the public consultation on proposals for a new regulation on advanced safety features and tyres

JAMA responded in October to the European Commission’s consultation on advanced safety features and tyres. The consultation exercise sought to gather the views of all interested parties on proposals for an integrated regulation concerning tyre noise and rolling resistance limits, as well as on timing and feasibility issues regarding the introduction of advanced vehicle safety systems.

The consultation also raised the possibility of using the regulation to replace separate safety-related Directives that come under the vehicle type-approval Framework Directive.  The intention is to replace the technical content of these Directives with equivalent United Nations Economic Commission for Europe (UNECE) Regulations, in line with the recommendations by the CARS 21 group and the subsequent Communications.

Tyre noise, low rolling resistance tyres, and wet grip performance

JAMA recognises that tyre rolling noise is the dominant component of road traffic noise at speeds of over 40 to 50 km/h.  Stricter controls on tyre noise would constitute an effective way of reducing road traffic noise and legislation would therefore be welcomed in this area.  However, JAMA cannot determine the technical feasibility for the regulatory levels proposed by the Commission as a test procedure for rolling resistance has not yet been established.

JAMA also recognises the effectiveness of low rolling resistance tyres in reducing CO2 emissions.  Nevertheless, because a test procedure for rolling resistance is still under study at ISO, a full discussion on low rolling resistance tyres, including specific regulatory values, must be started within UN/ECE/WP29 once the test procedure is established.

TPMS (Tyre Pressure Monitoring Systems)

JAMA considers TPMS to be an effective tool in reducing CO2 emissions. However, prior to any new rule-making, international harmonisation as well as various technical issues will need to be fully discussed, including:

  1. Detection time speed / tyre pressure detected
  2. Applicable vehicle categories
  3. Lead time

ESC (Electronic Stability Control)

JAMA believes that ESC contributes significantly to vehicle safety.  However, the mandatory installation of ESC must be fully examined, taking into consideration such factors as the different accident patterns among regions and the economic losses incurred thereby.

The Commission's policy on EU Directives/UN ECE Regulations

JAMA supports the European Commission's basic policy that certain EU Directives should be replaced by equivalent ECE Regulations.  JAMA also considers that the governments of non-EU countries should refer to UN/ECE Regulations directly, but should not add their own requirements to the UN/ECE Regulations that will replace their equivalent national standards.

It is therefore desirable to have worldwide discussions at WP29 on the provisions that each government considers necessary and to develop UN/ECE Regulations incorporating reasonable and effective technical standards and test procedures based on professional expertise and data.