UN R94 Supplement 2 (03 series) · UNECE Regulation No. 94 (ECE R94) — Uniform provisions concerning the approval of vehicles with regard to the protection of the occupants, fuel system integrity and protection against electrical shock in the event of a frontal collision.
UN R94 — Supplement 2 to the 03 series of amendments
Supplement 1 → 2
- What changed
- The Regulation now applies to vehicles of category M1 not exceeding 3,500 kg and of category N1 not exceeding 2,500 kg total permissible mass.
- New paragraphs 5.3.1. and 5.3.2. give conditions under which certain M1 and N1 vehicles are deemed to meet the requirements of paragraph 5.
- Where a seat row has no door, it must be possible to evacuate all occupants, activating the seat displacement system if necessary. Under paragraph 5.2.5.1., this is not applicable to convertibles where the top can be easily opened to allow the evacuation of the occupants.
- Why
- The drafting task force prepared the text to align UN Regulations to the revised General Safety Regulation of the European Union and expand the scope.
- Broad exemptions, for example heavy sport utility vehicles and vans, can no longer be justified in the light of increasing vehicle mass.
- N1 category vehicles with a relatively high maximum permissible mass could have specific commercial vehicle architecture based on N2 category vehicles. This could lead to a disproportionally high crash test severity, so testing them according to Regulation No. 137 is proposed instead.
Q1What changed22 changes
Scope (para. 1)
This Regulation now applies to vehicles of category M1 of a total permissible mass not exceeding 3,500 kg. It now also applies to vehicles of category N1 of a total permissible mass not exceeding 2,500 kg. Before, it applied to vehicles of category M1 of a total permissible mass not exceeding 2.5 tonnes. As before, other vehicles may be approved at the request of the manufacturer. A footnote on the Consolidated Resolution on the Construction of Vehicles (R.E.3.) now cites document ECE/TRANS/WP.29/78/Rev.6, not Rev.2, and adds a web address.
Specific provisions linked to UN Regulation No. 137 (paras. 5.3. to 5.3.2.)
New paragraph 5.3.1. covers M1 vehicles over 2,500 kg total permissible mass that are based on N1 vehicle types over 2,500 kg. New paragraph 5.3.2. covers N1 vehicles over 2,250 kg but not over 2,500 kg total permissible mass whose structural basis is a ladder frame. These vehicles are deemed to meet paragraph 5 where UN Regulation No. 137 is fully complied with and at least one listed condition is met. This must be checked by the Technical Service, subject to the Type Approval Authority's decision, and stated under point 8.2. of Annex 1.
Conditions (a) and (b), and Figure 4 (paras. 5.3. to 5.3.2.)
Paragraphs 5.3.1. and 5.3.2. use the same two conditions, (a) and (b), and both refer to the new Figure 4. Under (a), the acute angle alpha (α) is more than 22°. It is measured between a horizontal plane through the front axle centre and an angular transverse plane through that centre and the driver's R-point. Under (b), the ratio of L101-L114 (driver's R-point to rear axle centre) to L114 (front axle centre to driver's R-point) is more than 1.30.
Opening doors and evacuating occupants after the impact (para. 5.2.5.1.)
Paragraph 5.2.5.1. still starts “To open at least one door”, but no longer says “if there is one”. Where there is no such door, it must be possible to allow the evacuation of all occupants by activating the seat displacement system, if necessary. Before, the text said “to move the seats or tilt their backrests as necessary” to allow the evacuation of all the occupants. The text now says that this is not applicable to convertibles where the top can be easily opened to allow the evacuation of the occupants. Before, it was only applicable to vehicles having a roof of rigid construction. This must be assessed for all configurations or worst-case configuration for the number of doors on each side, for left-hand and right-hand drive, when applicable.
Definitions of “Displacement system” and “Ladder frame” (paras. 2.36. and 2.37.)
New paragraph 2.36. defines “Displacement system”. It means a device by which the seat or one of its parts can be displaced and/or rotated, without a fixed intermediate position. The device is there to permit easy access of occupants to and from the space behind the seat concerned. New paragraph 2.37. defines “Ladder frame”. It means a chassis composed of two longitudinal rails transversally connected by crossbeams and where the cabin, made of panels, is connected to such rails.
Mass of the Vehicle (Annex 1, item 8)
Item 8 of Annex 1 now has the heading “Mass of the Vehicle”. Under it, point 8.1. is “Mass of vehicle submitted for testing:”. New point 8.2., “Where paragraph 5.3.1. or 5.3.2. applies:”, has entries for the total permissible mass and for proof of compliance with UN Regulation 137. This proof is the type approval number or test report.
Q2Why it changed
- Proposed by
- Expert from the European Commission on behalf of the drafting task force
- Working party
- GRSP, 66th session (December 2019)
Reasons
The drafting task force prepared the text to align UN Regulations to the revised General Safety Regulation of the European Union and expand the scope. The European Union is in the process of adopting the revised General Safety Regulation. It also addresses a number of exemptions in essential vehicle safety requirements, for example heavy sport utility vehicles and vans. These broad exemptions can no longer be justified in the light of increasing vehicle mass and the protection of workers that use light commercial vehicles. At GRSP, the expert from EC explained that the proposal could be considered a supplement since it would mostly imply a change of the scope.
Sources (4)
“prepared by the experts of the drafting task force to align UN Regulations to the provisions of the revised General Safety Regulation of the European Union to expand the scope of the UN Regulation”
“It however also addresses a number of exemptions in essential vehicle safety requirements, e.g. heavy sport utility vehicles and vans.”
“These broad exemptions can no longer be justified in the light of increasing vehicle mass due to, e.g. electrification of the vehicle fleet as well as protection of workers that use light commercial vehicles.”
“The expert from EC explained that the proposal could be considered a supplement since it would mostly imply a change of the scope.”
N1 category vehicles with a relatively high maximum permissible mass could have specific commercial vehicle architecture based on N2 category vehicles. This could in turn lead to a disproportionally high crash test severity. It is therefore proposed not to include these vehicles in the scope, with a view to test them according to Regulation No. 137 instead. M1 category vehicles based on such N1 vans are proposed to be given the same treatment.
Sources (2)
“N1 category vehicles with a relatively high maximum permissible mass could have specific commercial vehicle architecture based on N2 category vehicles. This could in turn lead to a disproportionally high crash test severity.”
“it is proposed not to include these vehicles in the scope with a view to test them according to Regulation No. 137 instead. M1 category vehicles based on such N1 vans are proposed to be given the same treatment.”
A few of these N1 vehicles with a total permissible mass between 2,500 kg and 3,500 kg are classified as M1 vehicles (camper vans, etc.). They are structurally identical to their N1 base vehicle. It is recognised that these heavy M1 should also be excluded from the extension of scope. For this reason, the same criteria are incorporated from UN Regulation No. 135. Aligning with Regulation No. 135 is more logical than using, for example, the Regulation No. 127 pedestrian protection exemption.
Sources (3)
“A few of these same N1 vehicles with a total permissible mass between 2,500 kg and 3,500 kg are classified as M1 vehicles (camper vans, etc.) although these are structurally identical to their N1 base vehicle.”
“It is recognised that these heavy M1 should also be excluded from the extension of scope, for this reason the same criteria is incorporated from UN Regulation No. 135.”
“It is more logical to align Regulation No. 94 with Regulation No. 135 crash regulation exemptions rather than using e.g. the Regulation No. 127 pedestrian protection exemption.”
N1 category vehicles of a total permissible mass exceeding 2,250 kg but not exceeding 2,500 kg may also have very specific commercial vehicle architecture. Their architecture may be based on other excluded vehicles with a higher maximum permissible mass. This could in turn lead to a disproportionally high crash test severity. It is therefore proposed not to include these vehicles in the scope, with a view to test them according to UN Regulation No. 137 instead.
Sources (2)
“N1 category vehicles of a total permissible mass exceeding 2,250 kg but not exceeding 2,500 kg may also have very specific commercial vehicle architecture based on other excluded vehicles with a higher maximum permissible mass.”
“For this reason, it is proposed not to include these vehicles in the scope with a view to test them according to UN Regulation No. 137 instead.”
In wide vehicles, it may not be necessary for the front seats to have a displacement system (in accordance with UN Regulation No. 17). This is because occupants can move forward between the seats. It is proposed to allow this also in this Regulation, for the evacuation of rear-seated occupants through a front door in case of a crash. The words “by activating the displacement system of seats, if necessary” reflect this option. To avoid diverging interpretations by Technical Services and Type-Approval Authorities, the text clarifies that at least a worst-case configuration for side doors must be assessed.
Sources (3)
“In wide vehicles, it may not be necessary for the front seats to have a displacement system (in accordance with UN Regulation No. 17), as occupants can move forward between the seats.”
“It is proposed to allow this also in this Regulation to allow for the evacuation of rear-seated occupants through a front door in case of a crash.”
“To avoid diverging interpretations by Technical Services and Type-Approval Authorities, it is clarified that at least a worst-case configuration for side doors must be assessed”
Document trail
- 2019-09ProposalECE/TRANS/WP.29/GRSP/2019/29Proposal for Supplement 2 to the 03 series of amendments, by the expert from the European Commission on behalf of the drafting task force
- —Working party adoptsECE/TRANS/WP.29/GRSP/66Session report, para. 31: GRSP adopted the proposal as amended by Annex VI
- 2020-04Sent to WP.29ECE/TRANS/WP.29/2020/54Text that GRSP sent to WP.29 and AC.1
- 2020-06WP.29 adoptsAdopted at the 181st session
- 2021-01-03In forceC.N.29.2021.TREATIES-XI.B.16.94UN depositary notification
Q3Who is affected
Vehicle manufacturer
- Check M1 vehicles up to 3,500 kg and N1 vehicles up to 2,500 kg total permissible mass against this Regulation.
- Where paragraph 5.3.1. or 5.3.2. applies, be ready to show full Regulation No. 137 compliance and condition (a) or (b).
- Where a seat row has no door, check evacuation of all occupants under paragraph 5.2.5.1., except the convertibles it names.
Component supplier
- No direct action for this role.
Technical service / Approval authority
- Be ready to test M1 vehicles up to 3,500 kg and N1 vehicles up to 2,500 kg total permissible mass.
- Where paragraph 5.3.1. or 5.3.2. applies, check full compliance with UN Regulation No. 137 and condition (a) or (b).
- As Type Approval Authority, decide whether paragraph 5.3.1. or 5.3.2. vehicles are deemed to meet paragraph 5.
- Be ready for the new Annex 1, point 8.2. entries where paragraph 5.3.1. or 5.3.2. applies.
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ⓘ This report gives advice only. It is not legal or type-approval advice.