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Regulatory work · · 3 min read

It's just a bracket

VincentFounder, RegVault

There's one thing I care about more than anything else in running RegVault.

It's this: who reads the regulations we work on? I think about that person.

Some people might say: it's just copying amendment instructions across, or making the edits, so why make it so complicated?

That's true.

When UNECE holds a WP.29 session, it publishes neat agendas, reports and working documents. Anyone can read them. They say things like "amend paragraph A to read B" and "delete paragraph C."

So you might think RegVault's job is just that simple.

But turn the focus to the person who reads the regulation, and it's not that simple.

Is it really enough to apply exactly what comes off the UNECE website?

After years of doing this work, my answer is a firm no.

Why?

Here's a very good example.

On 18 November, WP.29 votes on a proposal to amend UN R96, the emissions regulation for non-road mobile machinery engines (ECE/TRANS/WP.29/2026/174). It adds two hydrogen annexes, and both use the same dry/wet correction. In one, the equation has brackets. In the other, it doesn't.

The same correction, twice in one proposal. Annex 11 (top) has the bracket; Annex 12 (bottom) does not. Source: ECE/TRANS/WP.29/2026/174.

The factor 1.008 is meant to multiply everything inside the brackets. Drop them, and the result is always 0.008 lower. For a hydrogen engine, whose exhaust is 10–25% water, the reported emissions come out about 1% low.

Every related equation we checked, in R96 itself, in R49, in two UN GTRs and in EU 2017/654, has the brackets. They were already missing in the first working document, and we found no document that corrects it.

Right.

In the end, it's just a bracket.

RegVault doesn't want to take a text like this literally, convert it mechanically, and hand it to you. (Of course, doing it mechanically, or running it through AI, would be far easier!)

RegVault wants the regulation you're reading to be right.

Regulations are made by people, written by people and published by people. They pass through many hands on the way. So, inevitably, errors happen.

And when there's a clear error, a company like RegVault should just publish it as is, because it's only a "regulation database"?

Absolutely not.

That's not how RegVault wants to do business.

Our team of regulatory experts goes through each version, one by one, and catches every clear error.

What we did

With this one, though, we didn't quietly fix it either. This is a proposal, and WP.29 votes on this exact text. If we changed the equation, our page would no longer show what is being proposed.

So we printed (A.12-1) exactly as proposed, put an asterisk on the paragraph number, and added a RegVault Note at the foot of the page. It says what the official text prints, what the same correction says elsewhere, how we read it, and that the note is not part of the official text.

On RegVault: equation (A.12-1) as proposed, with a RegVault Note at the foot of the page. Green marks text that is new in this version.

After the vote, we will check the adopted text and any corrigendum. If the bracket comes back, we follow the official text and remove the note.

Keep the official text. Flag the error. Show the evidence.

Why go to all this trouble?

Because what matters most to RegVault isn't mechanically converting regulations from as many regions as possible.

It's editing even a single regulation properly, and showing it well, to you.

Whatever anyone says, at RegVault, that's what matters most.

Have you found something like this in an official text? How did your team handle it? Tell me in the comments.

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