H9, H10, HB3 and HIR2 LEDr at GRE95: Proposal Filed, High-Beam Hold Recommended

From the July task-force discussion to a formal GRE95 document

At the 29th TF S/R meeting on July 13, the group consolidated the four proposed category sheets under TFSR-29-02 and prepared the technical rationale under TFSR-29-03. The resulting package appears on the official GRE95 document list as formal working document GRE/2026/19, accompanied by supporting information in GRE-95-04.

On September 22, the 30th TF S/R meeting addressed the follow-on strategy. The status-report revision dated October 5 (TFSR-30-02/Rev.1) sets out a recommendation to wait before sending the high-beam category sheets onward to WP.29, allowing lessons from the front-fog category work and market-surveillance concerns to be addressed.

Three high-beam categories and one front-fog category in one document

The four sheets form one R.E.5 proposal, but they do not all have the same lighting function. H9, HB3 and HIR2 are addressed as high-beam applications; H10 completes the front-fog application group. Referring to all four as “high-beam categories” would be misleading.

The supporting justification discusses equivalence in photometric, thermal and electrical performance. For H9_LEDr, it describes a proposed single luminous-flux value of 1,875 lm at 13.2 V to accommodate different applications. This is a draft specification, not proof that an individual H9 LEDr product is approved.

Why the task force is reluctant to advance the high-beam sheets immediately

During its July discussion, TF S/R examined reports of LED replacement products carrying approval markings but showing potential non-conformity in cap keying; the mechanical features intended to prevent a light source from being installed in an incompatible holder. The concern is not merely cosmetic: an incorrect fit can defeat the intended separation between light-source applications and produce inappropriate light output or beam performance.

The task force's subsequent report links the high-beam timing recommendation with a broader need to improve conformity controls and market surveillance. It would be premature to infer from these cases that all marked LEDr products are defective, that a specific approval authority failed, or that the entire approval system is invalid. The public discussion identifies a risk requiring investigation and corrective action.

The resulting policy question for GRE is whether to advance the high-beam sheets now or to wait until lessons from the front-fog work and enforcement measures have been addressed. Filing the technical proposal and recommending a pause are therefore not contradictory: they concern different stages of the process.

PTI is a separate challenge: an approval marking may be hidden after installation

PTI means Periodic Technical Inspection: roadworthiness checks on vehicles already in service. In the EU, periodic roadworthiness testing is governed at framework level by Directive 2014/45/EU and implemented by Member States. This is distinct from the UN R37 type-approval route for a defined light-source type and its specifications under R.E.5.

Once an LED replacement bulb is installed in a headlamp, the approval marking on the light source may be inaccessible to an inspector. TF S/R and PTI discussions have therefore considered supporting evidence such as installation or approval documentation, markings or labels on the headlamp housing, and; in some circumstances; removal of the light source for verification. The accepted inspection method remains subject to applicable national rules; none of these items should be described as a universal substitute for approval.

For a buyer, two checks are essential and different: Does the exact manufactured bulb conform to its claimed approval? And can its approval and permitted installation scope be established when the vehicle is inspected? A visible E-mark alone does not answer both questions.

What GRE95 can decide and what does not follow automatically

GRE may discuss, amend, support, defer or otherwise dispose of the R.E.5 category proposal. Only a subsequent, applicable WP.29 process can establish the formal outcome for the resolution amendment. Even after a category is adopted, a manufacturer still needs approval evidence for the specific light-source product under the applicable regulatory route.

As a result, the three phrases “submitted to GRE,” “forwarded to WP.29,” and “adopted in R.E.5” must not be treated as synonyms. Nor should any of them be treated as equivalent to an individual commercial product's UN R37 approval or unconditional road-use permission in every market.

The previously discussed 2027 timetable is now particularly uncertain for the high-beam group. It remains a possible future monitoring window, not an assured adoption or market-entry date.

What buyers, brands and LEDr manufacturers should do before committing

• Separate the products in the roadmap. Track H9, HB3 and HIR2 high-beam development separately from the H10 front-fog proposal, even though they share one GRE document.
• Request mechanical evidence. Ask suppliers for controlled cap drawings, keying dimensions, physical fit checks and manufacturing inspection records; not only photographs of an E-mark.
• Verify the approval chain. Match the exact part number, production configuration, approval documents, relevant category specification and intended application; do not infer compliance from a proposal number.
• Prepare inspection documentation. Clarify how the approved product and installation scope can be identified during PTI, subject to the destination country's procedures.
• Gate irreversible spending. Continue controlled prototypes and validation, but avoid “ECE approved” packaging, fixed launch commitments or large category-dependent inventory positions before formal decisions and product-level evidence exist.

For RFQs, ask the supplier to distinguish “engineered to the draft” from “approved to an adopted requirement,” and require evidence of what will be re-tested if the final GRE or WP.29 text changes.

Continue the LEDr topic

• ECE R37 LEDr Status in 2026
• How LED Retrofit Claims Are Checked by Inspectors and Market Surveillance
• How to Source LEDr Bulbs: A Buyer Checklist

GRE95 LEDr proposal questions

Have the H9, H10, HB3 and HIR2 category sheets been submitted?

Yes. GRE/2026/19 is listed as a formal GRE95 working document, with supporting information in GRE-95-04.

Did TF S/R reject all four proposed categories?

No. The task force supported submission of the consolidated proposal. Its later recommendation concerns not forwarding the high-beam sheets to WP.29 at this stage. H10 is a front-fog category in the same proposal, and GRE's decision remains pending.

Are H9, HB3 and HIR2 LEDr products already UN R37 approved?

The GRE submission does not establish that. A category proposal is not an adopted category or an individual product type approval.

Does PTI determine whether an LEDr category exists?

No. PTI concerns inspection of vehicles in use. It raises practical questions about proving an installed light source's approval and correct application, while R.E.5 and UN R37 address different parts of the category and type-approval framework.

What should industry monitor after October 23?

The published GRE95 meeting outcome, the disposition of GRE/2026/19, and whether any high-beam sheets are actually recommended onward for WP.29 consideration.

Official sources and supporting documents

• UNECE: GRE95 session and document register (October 20 to 23, 2026)
• ECE/TRANS/WP.29/GRE/2026/19: Proposal for an R.E.5 amendment
• GRE-95-04: Additional information and justification for the proposed categories
• TFSR-30-02/Rev.1: TF S/R status report for GRE95 (October 5, 2026)
• PTI-43-05: Inspection aspects of LED replacement light sources
• EU Directive 2014/45/EU: Periodic roadworthiness testing

Status cutoff: October 15, 2026, before GRE95. A submitted proposal and a task-force recommendation are not an adopted regulation or a product approval. Some UNECE working-file links may require access through their document register.