EPPR-11-07e
India proposal on EPPR-10-14e
The deletions are struck through like this and additions are in this font
No
Section
Para
1
General Cate
gory
and
refer
ence
to
SR1.
Proposed changes
Justification
India and IMMA had suggested use of the categorization as per SR1.
However, EC reservation to refer classification reference numbers laid down in
SR1 (3-1, 3-3, etc) owing to incompatibility with regional vehicle
classification. Should be re-discussed after revision of SR1 is agreed on.
Expressions like Motorcycle, two wheeled motorcycle, three wheeled vehicle,
tricycle are generic terms. It is necessary to define them clearly in the
regulation.
Since finalization of the amendment to SR1 will take time, it is very likely that
this draft GTR will get delayed. In order to avoid this delay India suggests the
following:
1. Proceed the current GTR work taking into account the current
definitions in SR1 which are also referred in other GTR’s.
2. Build in clauses in text of GTR to provide freedom for Contracting
Parties to make the applicability to suit the local definition in GTR.
These proposals are contained in Sr. No. 2,3,11,12 and Table 3.6-1 item
no 1.1.
2
B.1
2.
Scope
Two- [and three-]wheeled vehicles of [category 3-1, 3-3 and 3-2, 3-4, 3-5] as
defined in S.R. 1, concerning the common definitions of vehicle categories,
masses and dimensions document TRANS/WP29/1045e, as amended by
ECE/TRANS/WP29/1045/Amend.1, equipped with a PI engine in accordance with
Based on comments at Sl.
No.1 above, all the square
brackets may be removed
and reference to SR 1 be
incorporated
table B.1.-1.
1/16
EPPR-11-07e
No
Section
Para
Proposed Justification
changes
3
B.1
Table Modify
the table
1-1
as
indicated
below.
1. Exemption for gas fuel vehicles with a small petrol tank capacity:
 India had proposed addition of a sentence to exempt bi-fuel vehicles with a small petrol tank
( < 2 litre/3 litre) in the scope. Later it was agreed that a definition for a mono-fuel gaseous
vehicle can be incorporated.
 However, certain difficulties have cropped up for evolving this definition. It would take some
time to evolve this definition
 India now suggests that requirement of exemption may be built into the table so that this
document can be finalized.
 As and when the definition is finalized, (which can be built into GTR 2 Rev 1), this document
can be amended suitably.
2. Hybrid vehicles
It was agreed in the 10th EPPR session that the Hybrid vehicles will be considered at a later
stage. Hence it is necessary to remove the hybrid vehicles from this table also.
Vehicles with CI
engines including
hybrids
MonoFlex-fuel
fuel
Vehicle with PI engines including hybrids
Mono-fuel
Petrol
Flex-fuel
Bi-fuel*
LP
G
NG/
Biomethane
Petrol
Petrol
Petrol
Petrol
NG/
Biomethane
Diesel
LPG
NG/
Biomethane
H2
Ethanol
(E85)
H2NG
Biodiesel
H2
Diesel
Pure electric
vehicle
or
vehicle
propelled
with
compressed
air (CA)
Hydrogen
Fuel cell
vehicle
Type III
test
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
Type IV
test
Yes
No
No
No
Yes
(petrol
only) *
Yes
(petrol
only) *
Yes
(petrol
only) *
Yes
(petrol
only) *
No
No
No
No
No
* Type IV test is not applicable for motor vehicle that is designed primarily for permanent running on LPG or NG / bio-methane or hydrogen,
having a petrol system, with petrol tank capacity not exceeding 2 litres in the case of a 3-1, 3-3 and 3-4 category vehicle and not exceeding
3 litres in the case of a 3-2 and 3-5 category vehicles, intended for emergency purposes or starting only.
Table B.1.-1: Scope with regard to the propulsion unit
2/16
EPPR-11-07e
No
Section
Para
4
B.1
3.5.
Proposed changes
Justification
‘fuel storage system’ means a type of energy
storage system that stores [chemical] energy
carriers and which is refillable the liquid fuel;
This GTR is for evaporative emissions and is
relevant only to liquid fuels. While a more generic
definition may be needed in other GTR (e.g. GTR 2
Revision 1), it is suggested that reference to liquid
fuel is good enough to complete this definitions in
this document.
5
B.1
3.7, 3.8, 3.10
and 3.11
These definitions may be deleted
These terms relate to hybrid vehicles. Now that the
hybrid vehicles are out of scope of this GTR, these
can be deleted. These definitions can be added in
GTR 2 Rev.1 appropriately
6
B.1
3.16
This definition may be deleted
The definition as it is worded currently does not
serve the intended purpose, since the limitation of
the petrol tank capacity is not included. Alternate
method of taking care of this is suggested by
amending the table 1-1 as suggested at sl. No. 3.
‘Mono-fuel gaseous vehicle’ means a vehicle
that is designed primarily for permanent
running on LPG or NG / bio methane or
hydrogen, but may also have a petrol system
for emergency purposes or starting only,
7
B.1
3.##
New definition to be added:
"useful life" means the relevant period of
distance and/or time over which the vehicle
comply with the detailed technical
requirements specified in this GTR when the
vehicle is used normally and maintained
according to the prescriptions of the
manufacturer.
Since the expression useful life is used in the
document, India feels that it is better to define the
terms. The phraseology is selected from the details
given in document EPPR 10-15e.
It will be necessary to use the same term while
preparing the GTR for the Type V test also.
3/16
EPPR-11-07e
No
Section
Para
Proposed changes
Justification
8
B.2
Foot note 1
The Type III test procedure to be conducted
in accordance with the requirements to be
agreed upon by the UN EPPR informal
working group and to be supplemented in
subsequent amendment No 1 to this GTR.
1. India agrees with the proposal to delete para
2.1.2 and prescribe its contents in the foot note.
2. An editorial correction is suggested in foot note.
Necessity may come to issue amendments prior
to finalization of the crank case emission test
procedure. Hence using the expression
“amendment No.1” could lead to operational
difficulties.
9
B.2
2.2.
The manufacturer shall provide [the approval
authority of the Contracting party or its
designated agency] with technical details and
drawings to prove that the engine or engines
are so constructed as to prevent vapour of any
fuel, lubrication oil or crankcase gases from
escaping to the atmosphere from the
crankcase gas ventilation system.
Expressions “approval authority”, “technical
services”, certification etc. are used differently at
different places generally with the same intention.
Some terms (e.g. Techinical Service”) are not used
in India.
India suggests to use the expression “approval
authority of the Contracting Party or its designated
agencies” at all places to avoid difficulties later.
A Physical verification may be conducted that
the crankcase breather is not let out into
atmosphere.
10
B.3.
2.1.
The vehicle manufacturer shall prove [to the
approval authority of the Contracting party or
its designated agency technical service and to
the satisfaction of the approval authority] that
the fuel storage and supply system are leaktight in accordance with point 2.2.
11
B.3
2.4.2
A two-wheeled motorcycle, [a motorcycle
with sidecar and a tricycle] of Category 3-3,
3-4 and three wheeled vehicle of category 3-5
1. See serial No. 9
2. The current wording also leads to wrong
understanding that the demonstration has to
be done twice, once to technical services and
again to the certifying agency.
As explained at Sl. No.1, document does not
become complete unless motor cycles and three
wheeled vehicles are defined.
shall be tested according to the class C
evaporative emission test procedure
4/16
EPPR-11-07e
No
Section
Para
Proposed changes
Justification
12
B.3
2.4.3
For any other type of a two- [or three-]wheeled [3-1
and 3-3] vehicle, including the category or
The word “other” need to be deleted, since
some CP may prefer to use Class A or Class
B procedure even for Class 3-3, 3-4 or 3-5.
subcategory as per the classification followed by the
Contracting Party the Contracting Party may decide
to apply one test procedure only from the three listed
evaporative emission test procedure classes for the
[approval] / [certification] of a vehicle laid down in
point 2.3.
The need to give freedom for CPs to make
use of their national/regional classification
has been built in. India believes that this
could address the concerns of EC.
This can be reviewed and corrected later,
once the changes in SR 1 are finalized by
WP29/AC3.
13
B.3
2.5
14
B.3
2.5.1
The appropriate test fuel, as defined in Annex 2 of
GTR No 2 (for E0) and Annex XX (for E5 and E 10)
to this GTR, shall be used, as decided by the
Since three type of fuels are involved, it is
necessary to provide the option for CPs to
choose the one applicable to their region/
Contracting Party
nation. It has been established by documents
submitted by EC (EPPR-10-19) that all the
Add the following new clause:
three classes of evaporative emission (A, B
The Contracting Parties shall accept test reports for
and C) are adversely affected by volume of
the approval of a vehicle according to the test fuel
Ethanol added to the blend.
used given in Table – B.3.#
Test fuel mandated
by the Contracting
Party
Compliance to
type IV test using
E10
E10
E5
E5/E10
E0
E10/E5/E0
Hence, it necessary to prescribe the
hierarchy of the different blends. The
formulation suggested is based on the
practice used for defining the hierarchy for
the evaporative emission tests mentioned in
clause 2.4.4 in section B.3.
Table – B.3.# Hierarchy of acceptance
of test reports with different test fuel
blends.
5/16
EPPR-11-07e
No
Section
Para
Proposed changes
Justification
15
B.3
4
[The manufacturer shall ensure that the vehicle will
meet the evaporative emission standards over the
useful life of the vehicle.] The manufacturer shall
demonstrate the durability of the evaporative emission
control system using the applicable durability test
procedure as follows
If India’s suggestion to include the
definition for useful life , (SL.NO.7 above)
is accepted, the wording of this clause is
acceptable and the square bracket can be
removed.
16
B.3
Table B.3.-2
The square brackets around the limits values may be
deleted.
The proposed limits are acceptable to India.
So far there have not been any comments on
these limit values.
Table B.3.-2
para 5.1
Permeability test (mg/m2/24h) to be corrected to
Permeability test (mg/m2/24h)
Unit correction appropriately.
India feels that UN 1 should be specified to
start with. And when the GTR is stabilized,
the UN 2 can be added later.
17
B.3
Table B.3.-3
This table may be shifted to Section A with addition
of permeability limits as a future plan for CPs to adopt
after this GTR has been adopted.
18
B.3
6.
Propulsion family definition with regard to test See Sl. No 9
type IV
A representative parent vehicle shall be selected to test
[and demonstrate to the approval authority of the
Contracting party or its designated agency] the test
type IV requirements based on the propulsion family
definition in accordance with Annex B.3.6.
19
B.3
7.
Documentation
See sl. No. 9
The vehicle manufacturer shall fill out the information
document in accordance with the template laid down
in Annex B.3.7. [and submit it to the approval
authority of the Contracting party or its designated
agency].
6/16
EPPR-11-07e
No
Section
Para
Proposed changes
20
Annex
B.3.1
1.1.
This requirement shall apply to all two- [and three-]wheeled Since these requirements are basically
vehicles equipped with a non-metallic fuel tank to store liquid, for the fuel tank, a generic description
volatile fuel, as applicable for vehicles equipped with a positive of the vehicle will suffice and the
ignition combustion engine.
square brackets may be deleted.
21
Annex
B.3.2
3.1.
The fuel storage tank shall be filled with reference fuel and sealed. See Sl no. 9
The filled tank shall be soaked at an ambient temperature of 28 °C
± 5 °C for 20 weeks or at 43 °C ± 5 °C for ten weeks. Alternatively,
a shorter period of time at a higher -temperature may be used as
soak time if the manufacturer can prove [to the approval authority
of the Contracting party or its designated agency] that the
hydrocarbon permeation rate has stabilised.
22
Annex
B.3.2
6.1.3.
Slosh testing
Annex
B.3.2
6.3.
23
Justification
See Sl no. 9
A slosh test shall be conducted by filling the non-metallic fuel
storage tank to 40 percent of its capacity with the reference fuel or
with a commercial premium-grade fuel at the choice of the
manufacturer and [to the satisfaction of the approval authority of
the Contracting party or its designated agency ]. The fuel storage
tank assembly shall be rocked at a rate of 15 cycles per minute until
one million total cycles are reached. An angle deviation of +15° to
−15° from level shall be used and the slosh test shall be conducted
at an ambient temperature of 28 °C ± 5 °C.
The manufacturer may request that any of the durability tests be See Sl no. 9
excluded if it can be clearly demonstrated [to the approval
authorities authority of the Contracting party or its designated
agency] that this does not affect the emissions from the fuel storage
tank.
7/16
EPPR-11-07e
No
Section
Para
Proposed changes
Justification
24
Annex
B.3.2
7.1.
Fuel line assembly permeation physical testing procedure
See Sl no. 9
The manufacturer shall ---- follows:
(a) in accordance ------series production; or
15.5 0C to 35.5 0C in 60 minutes
(b) the manufacturer may use a proprietary test procedure if it can
be demonstrated [to the approval authority of the Contracting party
or its designated agency] that this test is just as severe as test
method (a).
25
Annex
3.3
Figure
B.3.3-1
The figure may be replaced with the figure given below
Figure with a change of temperature
units from K to 0C.
Figure B.3.3.-1: Flow chart – evaporative emission SHED test
8/16
EPPR-11-07e
No
Section
Para
Proposed changes
Justification
26
Annex
3.3
3.1.
India had suggested this language for
The chassis dynamometer shall meet the requirements of Annex 6 taking care of three wheeled vehicles
of GTR No 2 provided that in the case of 3 wheeled vehicles the (Sl. No.18 of EPPR-10-07). This
chassis dynamometer shall be capable of accommodating 3 inclusion is required since current
wheeled vehicles (e.g. 2 rollers , long single roller)
GTR 2 does not anticipate a three
wheeled vehicles
27
Annex
3.3
3.4.1.
The fuel storage tank heating system shall consist of at least two See Sl no. 9
separate heat sources with two temperature controllers. A typical
heat source shall be a pair of heating pads. Other heat sources may
be used as required by the circumstances at the request of the
manufacturer to the satisfaction of the [approval of the Contracting
party or its designated agency] / [certification] authority for
[compliance] / [approval] testing. Temperature ----- recommended
both for the fuel and the vapour.
28
Annex
3.3
3.9.1
At the request of the manufacturer [and with the agreement of the See Sl no. 9
approval authority of the Contracting party or its designated
agency, the technical service] may authorise the use of alternative
equipment provided that it can be demonstrated that it gives
equivalent results.
29
Annex
3.3
4.2.2.
The vehicle is placed on a chassis dynamometer and driven a single Editorial correction
time through the test cycle specified in Annex 5 of GTR No 2 as
appropriate for the class of vehicle being tested, in the case of
category 3-3 vehicles.
The cycles used for the Type I test prescribed in the national
regulation of the Contracting Party in the case of other categories of
vehicles.
9/16
EPPR-11-07e
No
Section
Para
Proposed changes
Justification
30
Annex
3.3
4.3.2.1.
Following the tank breathing losses test, the vehicle is pushed or
otherwise manoeuvred onto the chassis dynamometer with the
engine switched off. It is then driven through the driving cycle
specified for the class of vehicle on test. At the request of the
manufacturer, exhaust emissions may be sampled during this
operation, but the results shall not be used [for the purpose of
exhaust emission type-approval].
It is felt that the permission to
measure the exhaust emissions is a
redundant requirement and may be
deleted.
31
Annex
3.3
4.3.1.5.
The fuel and vapour may be artificially heated to the starting Editorial correction.
temperatures of 15.5 °C and 21.0 °C ± 1 °C K respectively. An
initial -----e shall be followed.
32
Annex
3.3
4.4.1.
At the request of the manufacturer [, with the agreement of the
technical service and to the satisfaction of the approval authority of
See sl. No 9
the Contracting party or its designated agency
] alternative methods may be used to demonstrate compliance with
the requirements of this Annex. In such cases, the manufacturer
shall satisfy the technical service that the results from the
alternative test can be correlated with those resulting from the
procedure described in this Annex. This correlation shall be
documented and added to the information folder.
33
Annex
B.3.3
5.1
V = net enclosure volume in cubic metres corrected for the volume
of the vehicle. If the volume of the vehicle is not determined,
a volume of 0.14 m3 in the case of two wheeled vehicles and
[0.25]m3 for three wheeled vehicle shall be subtracted;
Srl. No. 22 of the comments from
India (EPPR-10-07e), India had
mentioned that volume of three
wheeled vehicles will be indicated
after collecting data.
Typical average volume of Indian 3
wheelers has been found to be 0.25
m3
10/16
EPPR-11-07e
No
Section
Para
Proposed changes
Justification
34
Annex
B.3.4
Figure
B.3.4-1:
Replace existing figure with following figure:
For better clarity as per the text
Figure B.3.4-1: carbon canister gas flow diagram and ports
35
Annex
B.3.4
2
A carbon canister representative of the propulsion family of the
two- [and three-]wheeled vehicle as set out in Annex B.3.6.
shall be selected as test canister [Canister aging shall be
conducted at the choice of manufacturer by the canister aging
procedure A or B.]
36
Annex
B.3.4
2.1
Canister ageing test procedure [A]
In the case of a multiple canister system, each canister shall
undergo the procedure separately. The minimum number of test
cycles of canister loading and discharging shall correspond to
the number set out in Table B.3.4-1:
Since reference is made to Annex B3.6, it
is felt that generic description two and
three wheeled vehicle is sufficient in this
clause. The options for using procedure A
or B also have been accepted. Hence the
square bracket may be removed
1. India understands that agreement has
reached regarding options of canister
ageing procedure A and B. Hence the
square bracket may be removed.
2. India supports the deletion of the word
“minimum” proposed by Japan vide
EPPR-11-03.
11/16
EPPR-11-07e
No
Section
Para
Proposed changes
Justification
37
Annex
B.3.4
2.2 and
its sub
clauses
The square bracket may be removed
India understands that agreement has reached
regarding options of canister ageing
procedure A and B. Hence the square bracket
may be removed.
38
Annex
B.3.4
2.2.3.
Total distance is followed as the durability distance India supports the Japan proposal for
accumulation test cycle (type V test) applied by a following same cycle as for procedure A.
Contracting Party. Each test cycle is equivalent to 100 km (EPPR-11-03)
on the road.]
The number of test cycles of canister loading and
discharging shall correspond to the numbers set out in
Table B.3.4-1.
39
Annex
B.3.4
3.1.
India is awaiting information from IMMA
regarding the SAE standard.
The present clause has many difficulties
The durability test shall actuate control valves, cables, and
linkages, where applicable and be representative for the
operation conditions of these parts during the useful life of
the vehicle if used under normal conditions and serviced in
accordance with the manufacturer’s recommendations. The
accumulated distance and operation conditions of the type V
durability test may be regarded as representative for the
useful life of the vehicle.
1. Type V test is still to be finalized.
2. The useful life in this document is in
terms of no. of cycles for canister
durability.
3. Even if the useful life in terms of
kilometre is known, the simulation of
test cycle for rig testing and
correlating to a vehicle will differ
from model to model.
In case the SAE standard is not available,
India will reiterate the stand that this
requirement be kept for a next stage till a
proper test procedure is formulated based on
the duty cycle.
12/16
EPPR-11-07e
No
Section
Para
Proposed changes
Justification
40
Annex
B.3.5
2.1.2
The net internal volume is determined by subtracting 0.14 m3 in Srl. No. 26 of the comments from
the case of two wheeled vehicles and [0.25]m3 for three wheeled India (EPPR-10-07e), India had
vehicle from the internal volume of the chamber. Alternatively, mentioned that volume of three
the actual volume of the test vehicle may be subtracted.
wheeled vehicles will be indicated
after collecting data.
Typical average volume of Indian
3 wheelers has been found to be
0.25 m3
41
Annex
B.3.3.
4.3.1.10.
Annex
B.3.4.:
2.0, 2.1,
2.1.1,
2.1.1.1,
2.1.1.2,
2.1.1.3,
2.1.1.3.2.,
2.1.2., 2.1.3,
2.1.3.1.,
2.1.3.2., 2.2.
Annex
B.3.7
The term “canister” in these clauses may be replaced as “carbon India suggest that, the term
canister”
“canister” wherever appears in this
GTR as appropriate may be
rephrased as “carbon canister”
A note at appropriate place in the document may be added for the which are currently available by
term “carbon canister” as below
technology.
Note: or the canister with HC adsorbent material or other
equivalent.
Freedom is suggested to use other
equivalent materials due to
technology change.
1.2.2.11.,
1.2.2.15.,
1.2.2.16.
13/16
EPPR-11-07e
No
Section
Para
Proposed changes
42
Annex
B.3.6
New clause
2.1
Insert a new clause:
43
Annex
B.3.6
New clause
2.2
Annex
B.3.6
New clause
2.3
Insert a new clause:
Annex
B.3.6
Table
B.3.6.-1
Pl see the revised table below
44
45
Justification
The current table covers the family
2.1 In the case of Evaporative emission class C, the details given definition for class C (for SHED
test). For Class A and B tests only
in Table 3.6-1
the related parameter need to be
Insert a new clause:
mentioned.
2.2 In the case of Evaporative emission class B, the details given
at serial no. 2.1, 2.2.4, 2.2.5 and 2.2.6 of Table 3.6-1.
2.3 In the case of Evaporative emission class A, the details given at
serial no. 2.1, 2.2.4 and 2.2.6 in Table 3.6-1.
14/16
EPPR-11-07e
Proposed changes in Table 3.6-1
#
Classification criteria description
1.
Vehicle
Category;
1.1.
Note: Class 3-3 and 3-4 are considered to be same
family
1.2.
Note: Will become applicable after SR1 includes
subcategories
2.
System
2.1
Applicability of Evaporative emission test class A, B
or C, subject to provisions of item 2.4.4 of Section
B.3
Test type
IV
X
Fitment of side car does not affect the evaporative
emission performance
X
At present SR1 does not have a subcategory. Once EC
proposal is finalized, this clause will become applicable
X
Since CPs have freedom to mandate any of the classes of
evaporative emission test, this should be reflected in this
table.
Subcategory;
2.2.
2.2.1.
2.2.2.
2.2.3.
2.2.4
2.2.5
2.2.6
propulsion (not) equipped with evaporative emission
control system;
evaporative emission control system type;
operation principle of evaporative emission control
system (active / passive / mechanically or
electronically controlled);
identical basic principle of fuel/air metering (e.g.
carburettor / single point injection / multi point
injection / engine speed density through MAP/ mass
airflow);
identical material of the fuel storage tank and liquid
fuel hoses is identical;
Note: Material of all metallic fuel storage tanks are
considered to be identical.
liquid fuel hoses is identical and the surface area is
lower;
the fuel storage volume capacity declared by the
manufacturer ;is within a range of +/- 50 % - +10%/50% the nominal volume
Remarks
X
X
X
X
X
To incorporate the proposal Indian proposal (Sl. No 27
of EPPR-10-07 with changes carried for better clarity
and taking into consideration the discussion in the 10th
EPPR
X
X
India accepts the reservation from Japan (EPPR-11-##)
regarding permitting +50%. Data shows that a decrease
on the nominal volume of the fuel tank will not adversely
affect the evaporative emission and -50% can be
15/16
EPPR-11-07e
permitted.
2.2.7
2.2.8
2.2.9
2.2.10
the fuel storage relief valve pressure setting is
identical or higher;
Identical method of storage of the fuel vapour (i.e.
trap form and volume, storage medium, air cleaner
(if used for evaporative emission control) etc.);
identical method of purging of the stored vapour
(e.g. air flow, purge volume over the driving cycle);
identical method of sealing and venting of the fuel
metering system;
X
X
X
X
16/16