By Paul-Henri Matha
I took time to check lamp activation on a variety of cars, to see if they comply with UN R48 Series 07, the new Series 08 (mandatory for new vehicle types from January 2023 and all types from September 2027), or the newest Series 09 amendments (mandatory for new types from September 2027 and all types from September 2030). Automakers will have to modify their production vehicles by September 2027 to be compliant with 08 and September 2030 to be compliant with 09.
My focus for R48-08 is based on low beam activation and deactivation. It requires a new approach by automakers, because it is now restricted or disallowed to deactivate the low beam manually while driving, or in parking conditions. This was a strong request from regulators, to avoid vehicles driving around at night with their DRLs on, and without any rear signalling functions. It is a requirement with sharper teeth than the analogous regulatory adjustments in Canada we reported on when they were new; here are the relevant parts of R48-08:
6.2.7.5. The dipped-beam headlamps shall be switched ON and OFF automatically relative to the ambient light conditions (…) In addition, the following subparagraphs 6.2.7.5.1. apply.
6.2.7.5.1. Irrespective of the requirements of paragraph 6.2.7.5., under conditions requiring the dipped beam headlamps to be switched ON, the dipped-beam headlamps may remain switched OFF or, once automatically switched ON, may be switched OFF manually and remain switched OFF while one or more of the following conditions exist:
(a) The automatic transmission control is in the park position;
(b) The parking brake is in the locked position;
(c) Prior to the vehicle being set in motion for the first time after each manual activation of the device, which starts and/or stops the propulsion system;
(d) The control is designed in such a way that manual deactivation shall not be possible with less than two deliberate actions. The lamps referred to in paragraph 5.11. shall be switched ON,
or
If the vehicle speed does not exceed 15 km/h, the control shall be designed in such a way that manual deactivation shall not be possible with less than two deliberate actions. The lamps referred to in paragraph 5.11. may remain switched OFF provided that, throughout the entire period that these lamps are switched OFF, it is indicated to the driver with an optical and with an acoustic or haptic warning signal.
(e) The front fog lamps are switched ON;
The automatic operation of the dipped-beam headlamps shall be resumed as soon as the conditions in this paragraph no longer exist.
6.2.7.6. Irrespective of the requirements of paragraph 6.2.7.5., it shall always be possible to switch the dipped beam headlamps ON manually.6.2.7.7. The driver shall at all times be able to engage the automatic operation.
6.2.7.8. Notwithstanding the provisions of paragraph 6.2.7.5., in cases where the ambient illuminance is 1,000 lx or more the dipped-beam headlamps may switch ON and OFF automatically relative to other factors such as time or ambient conditions (e.g. time of the day, vehicle location, rain, fog, etc.).
Also I am focusing on the new autolevelling requirements in R48-09:
6.2.6.2.1. In the case where a headlamp levelling device is necessary (…), the device shall be automatic
We can see three compliance strategies from automakers: a traditional stalk with stable fixed-detent positions (no longer acceptable as of September 2027), a new type of selector stalk, such as one with unstable positions, compliant with R48-08, or a hybrid solution with a stalk for high beam and turn indicators while all other functions are moved to the centre stack display or elsewhere. Here’s a sample of what I found:
GAC Aion V
Stalk: manual high beam, flash to pass, and turn indicator
Central stack display: manual levelling, activation for low beam, auto, position lamps, rear fog
Hardware is ready for R48-08, but not for R48-09 (automatic levelling). I also note the distance between the two lit DRL surfaces seems to be more than the 75mm limit.
Cadillac Optiq
Stalk: manual high beam, flash to pass, and turn indicator
Central stack display (left area): activation for low beam, auto, position lamps
Central stack display (central): rear fog lights, automatic high beam
Hardware is ready for R48-08; no information about levelling (not found).
BYD Seal
Stalk: manual high beam, flash to pass, turn indicator, low beam, position lamps, auto, rear fog.
Position lamp and ‘zero’ are in a stable position on the stalk.
Hardware seems noncompliant with R48-08; will need an update or software modification. No information about levelling (not found).
Aito M9
Stalk: manual high beam, flash to pass, and turn indicator
Central stack display: activation for low beam, auto, position lamps, rear fog
Hardware is ready for R48-08. No information about levelling (not found).
Leapmotor C10
Stalk: manual high beam, flash to pass, and turn indicator
Central stack display: activation for low beam, auto, position lamps, rear fog, automatic high beam
Hardware is ready for R48-08. No information about levelling (not found)
MINI
Stalk: manual high beam, flash to pass, turn indicator, rear fog
Central stack display: activation for low beam, auto, position lamps, automatic high beam, parking lamps
Hardware is ready for R48-08. No information about levelling (not found).
Citroën e-C3
Stalk: manual high beam, flash to pass, turn indicator, rear fog, position lights, low beam, auto with stable position
Hardware seems noncompliant with R48-08; will need an update or software modification. No information about levelling (not found).
Renault 4
Stalk: manual high beam, flash to pass, turn signals, rear fog, position lamps, low beam with unstable position (selector). Confirmation of lamp selection on Driver information display
Hardware is ready for R48-08.
Levelling selector +/-; will need a hardware modification to comply with R48-09.
Lynk & Co 02
Stalk: manual high beam, flash to pass, and turn signal
Central stalk display: rear fog, position lamps, low beam, off, auto
Double confirmation on steering wheel
Hardware and Software appear ready for R48-08. No information about levelling (not found).
Dacia Duster
Stalk: manual high beam, flash to pass, turn signal, front and rear fogs, low beam, position lamps, and auto with unstable position
Confirmation of lamp selection on driver information display
Hardware appears ready for R48-08.
Manual levelling is not compliant with R48-09.
Kia EV6
Stalk: manual high beam, flash to pass, turn signal, rear fog, auto high beam. Low beam, position lamps, and auto with stable position.
Confirmation of lamp selection on driver information display.
Hardware seems noncompliant with R48-08; will need an update or software modification.
No information about levelling (not found).
Xpeng G6
Stalk: manual high beam, flash to pass, turn indicator.
Central stack display: rear fog, auto high beam, low beam, position lamps, auto, and off.
Hardware is ready for R48-08.
Manual levelling noncompliant with R48-09 (beam aiming selectable on the Central Stack display)
Audi A6 e-tron
Stalk: manual high beam, flash to pass, turn indicator, automatic high beam activation
Side switch in the left door : bad weather light, rear fog, common button selection for low beam, position lamps, auto, and off. Beam selection display on the left area of the Driver Information display behind steering wheel
Hardware appears ready for R48-08.
No information about levelling (not found).
