Junichi Hara - Comment

1) Harmonization with GTR for the test requirements Although the proposed amendment of FMVSS205 is aimed at harmonization of technological requirements with GTR, it differs from GTR in a few details. For example, the classification of vehicles of FMVSS is different from GTR for optical distortion etc., which will complicate the test procedures. From the viewpoint of quality assessment also, there should be no difference between GTR and FMVSS to enable evaluation by the same criteria. 2) Requirements for identification marks on glazing materials The requirements for identification marking on glazing materials are different from those of GTR. We require harmonization with the latest GTR requirements for identification marks on glazing materials. Kind of glazing material GTR6 FMVSS Uniformly tempered glass no marking Ⅰ Windshield laminated glass Ⅱ Ⅱ Laminated glass other than windshield ⅩⅠ Ⅱ 3) Requirements for identification marks of light transmittance We request deletion of the requirements for marking areas with not less than 70 percent light transmittance. We recognize that the mark (AS ↑) were necessary to clearly indicate to drivers the areas with light transmittance of not less than 70 percent. However, the NPRM determined, as a result of application of GTR, the area for which light transmittance of the said level is required. Therefore, safe vision areas are certainly provided for drivers. As a conclusion, the marks (↓II and ↑III) are not necessary. 4) Transition to the amended FMVSS: It will be necessary to certify conformity for each vehicle model. Obtaining certification through an outside accreditation organization, instead of by self-certification, will require a lot of manpower and period. Therefore, we request that the start of enforcement be three years after the final amendment is approved, instead of one year. For aftermarket parts, we request that both the new FMVSS marking and the conventional AS marking be approved.