UN R122 Base text (01 series) · UNECE Regulation No. 122 (ECE R122) — Uniform provisions concerning the approval of vehicles of categories M, N and O with regard to their heating systems.
UN R122 — 01 series of amendments
Changes from 00 series of amendments (supplement 7)
- What changed
- Annex 5, paragraph 2.1. now applies to parts likely to come into contact with occupants during normal road use, instead of the driver. Their limit is 70°C for uncoated metal or 80°C for other materials.
- Annex 5, paragraphs 2.2. and 2.3. are deleted. In M1 and N vehicles, paragraph 2.2. limited parts likely to touch seated passengers during normal road use to 110 °C, except the outlet grille.
- From 1 September 2028, Contracting Parties are not obliged to accept type approvals to the original version first issued after that date (para. 12.2.2.). They must continue to accept original-version approvals of equipment/parts (para. 12.2.4.).
- Why
- The 01 series is introduced to take into account vehicles of categories X and Y, and to align the Annex 5 provisions for all occupants.
- GRSG experts noticed that allowed surface temperatures should not depend on the occupant being driver or passenger, the seat row or the vehicle category.
- Rear seats of M1 vehicles need special care, since they are the typical seating positions to carry children.
Q1What changed23 changes
New Introduction (paras 0. to 0.1.4.)
New paragraph 0. adds an Introduction to the Regulation. Paragraph 0.1.: the 01 series is introduced to take into account vehicles of categories X and Y, and to align Annex 5 for all occupants. Paragraph 0.1.2. says that special care must be given to rear seats of M1, since they are the typical seating positions to carry children. Paragraph 0.1.4. says that paragraph 2 already lets manufacturers justify higher temperatures in a safety concept, without increasing the risk for occupants to get burns. Before this series, the Regulation had no paragraph 0.
“Passenger compartment” and the heating system in each compartment (paras 2.7. and 5.2.1.)
“Passenger compartment” now means the interior part of the vehicle used to accommodate occupants. Before, the definition said “the driver and any passengers”. Paragraph 5.2.1. now requires a heating system to be fitted to each passenger compartment (as applicable) within the vehicle. Before, it required the passenger compartment of every vehicle to be fitted with a heating system. The rule for a heating system for the load area does not change.
Surface temperature limits for occupants (Annex 5, paras 2. to 2.3.)
Paragraph 2.1. now covers parts of the heating system likely to come into contact with occupants in the vehicle, during normal road use. Their surface temperature is limited to 70°C for uncoated metal or 80°C for other materials. Before, paragraph 2.1. covered parts likely to come into contact with the driver. Paragraphs 2.2. and 2.3. are deleted, and paragraph 2. now refers to the limits in “the paragraph below”. In M1 and N vehicles, paragraph 2.2. limited parts likely to touch seated passengers during normal road use to 110 °C, except the outlet grille. Paragraph 2.3. gave the same limits as paragraph 2.1. for parts likely to touch passengers during normal road use in M2 and M3 vehicles.
New transitional provisions (para. 12.)
New paragraph 12. adds transitional provisions. Contracting Parties may grant type approvals according to any of the preceding series of amendments (para. 12.1.1.). They must continue to grant extensions of existing approvals to any of the preceding series (para. 12.1.2.). From the official date of entry into force of the 01 series, no Contracting Party may refuse to grant or accept 01 series approvals. As from 1 September 2028, Contracting Parties are not obliged to accept type approvals to the original version first issued after 1 September 2028. They must continue to accept original-version approvals first issued before that date, and original-version approvals of equipment/parts (paras 12.2.3. and 12.2.4.).
References to R.E.3 in two footnotes
The footnote “As defined in …” now refers to the Consolidated Resolution on the Construction of Vehicles (R.E.3.), document ECE/TRANS/WP.29/78/Rev.8. Before, it referred to Annex 7 to R.E.3 in document TRANS/WP.29/78/Rev.1/Amend.2, as last amended by Amend.4. The footnote on distinguishing numbers no longer lists the numbers of the Contracting Parties. It now refers to Annex 3 to R.E.3, document ECE/TRANS/WP.29/78/Rev. 8.
Q2Why it changed
- Proposed by
- Expert from the Kingdom of the Netherlands on behalf of the Task Force on Automated Vehicles Regulatory Screening (TF-AVRS)
- Working party
- GRSG, 131st session (April 2026)
Reasons
The 01 series of amendments is introduced to take into account vehicles of categories X and Y. It is also introduced to align the provisions in Annex 5 for all occupants.
Source
“The 01 series of amendments is introduced to take into account vehicles of categories X and Y1, and to align the provisions in Annex 5 for all occupants.”
GRSG experts noticed that, for the allowed surface temperatures, it should not matter whether the occupant is the driver or a passenger. It also should not matter if an occupant sits in the front seat row or a rear seat and/or in which vehicle category.
Sources (2)
“It was noticed by GRSG experts that for the allowed surface temperatures, it should not matter whether the occupant is performing the Dynamic Driving Task (DDT)1”
“is the driver) or is a passenger and it also should not matter if an occupant is sitting in the front seat row or a rear seat and/or in which vehicle category.”
Special care must be given to rear seats of M1 vehicles, since they are the typical seating positions to carry children.
Source
“Special care shall be given to rear seats of M1, since they are the typical seating positions to carry children.”
At its 128th session, GRSG decided that TF-AVRS would take this topic on board its work. The aim of this work is to update the UN Regulation for the purpose of fitness for Automated Driving System (ADS). This helps TF-AVRS to have the same provisions for driver and passengers, that is for all occupants. It also increases the level of safety with regard to minimising the risk of burns.
Sources (2)
“Therefore, GRSG in its 128th session decided that TF-AVRS would take this topic on board their work to update the UN Regulation for the purpose of fitness for Automated Driving System (ADS)1.”
“It helps TF-AVRS, to be able to have the same provisions for driver and passengers, i.e. for all occupants and increases the level of safety with regard to minimising the risk of burns.”
Document trail
- 2026-01ProposalECE/TRANS/WP.29/GRSG/2026/7Proposal submitted by the expert from the Kingdom of the Netherlands on behalf of TF-AVRS
- —RevisedGRSG-131-32Revised TF-AVRS proposal that replaced ECE/TRANS/WP.29/GRSG/2026/7
- —Working party adoptsECE/TRANS/WP.29/GRSG/110Session report, para. 37
- 2026-04Sent to WP.29ECE/TRANS/WP.29/2026/121Text that GRSG sent to WP.29 and AC.1
- —Amended in sessionWP.29-199-10Amendments for the AC.1 vote, reproduced in Annex VI of ECE/TRANS/WP.29/1192
- 2026-06-24WP.29 adoptsECE/TRANS/WP.29/1192Adopted at the 199th session (session report, para. 103)
- PendingIn forceDate not yet known
Q3Who is affected
Vehicle manufacturer
- For M1 and N vehicles, check parts likely to touch seated passengers against paragraph 2.1., not the deleted 110 °C.
- Update the documents that cite Annex 5, paragraph 2.2. or 2.3.; both paragraphs are deleted.
- Make sure that each passenger compartment (as applicable) within the vehicle is fitted with a heating system (para. 5.2.1.).
- Plan 01 series approvals; original-version approvals first issued after 1 September 2028, except equipment/parts, need not be accepted (para. 12.2.2.).
Component supplier
- Check heating-system parts likely to touch occupants during normal road use against 70°C (uncoated metal) or 80°C (other materials).
Technical service / Approval authority
- Be ready to measure M1 and N parts likely to touch seated passengers against paragraph 2.1., not 110 °C.
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ⓘ This report gives advice only. It is not legal or type-approval advice.