ECE R46 Certification — Mirrors & Indirect Vision Devices

Introduction to ECE R46

UNECE Regulation No. 46 (ECE R46) sets uniform provisions concerning the approval of devices for indirect vision and of motor vehicles with regard to the installation of these devices. Indirect vision devices allow the driver to observe areas around the vehicle that are not directly visible. Traditionally limited to optical mirrors, the regulation now encompasses camera-monitor systems (CMS), detection systems, and other technologies that provide indirect vision capability.

ECE R46 is one of the most widely adopted UNECE regulations and is mandatory for vehicle type approval in all contracting parties to the 1958 Agreement. With the increasing adoption of camera-monitor systems as replacements for traditional mirrors, the EMC and electronic performance aspects of ECE R46 have gained significant importance.

Scope and Applicable Devices

ECE R46 applies to the following categories of indirect vision devices:

Optical Mirrors

Traditional glass mirrors remain the most common indirect vision devices. ECE R46 classifies them by function:

Mirror Class	Description	Typical Location
Class I	Interior rear-view mirror	Windshield-mounted, inside cabin
Class II	Main exterior rear-view mirror (large)	Door-mounted, trucks and buses
Class III	Main exterior rear-view mirror (standard)	Door-mounted, passenger cars
Class IV	Wide-angle exterior mirror	Door or fender, trucks and buses
Class V	Close-proximity mirror	Front or side, trucks and buses
Class VI	Front mirror	Above windshield, trucks
Class VII	Short-arm exterior mirror	Compact vehicles

Camera-Monitor Systems (CMS)

Camera-monitor systems are electronic alternatives to optical mirrors. A CMS consists of an exterior camera, wiring, processing electronics, and an interior monitor. ECE R46 sets specific performance requirements for CMS including field of vision, image quality, resolution, contrast, and response time.

Detection Systems

These include ultrasonic and radar-based systems that detect the presence of other road users in blind spots. While not a full replacement for mirrors, detection systems may supplement the indirect vision capability.

Approval Requirements

For Devices (Component Approval)

Manufacturers of mirrors or camera-monitor systems must apply for component type approval. The device is tested against the technical requirements in ECE R46 annexes, including:

Reflective properties (mirrors): Reflectance values, radius of curvature tolerances, and surface quality.
Mechanical tests: Impact resistance, vibration, and corrosion resistance.
Image quality (CMS): Resolution, field of view, luminance range, contrast ratio, color rendering, and latency.
Environmental tests (CMS): Temperature cycling, humidity, dust, water spray, and UV exposure.

For Vehicles (Installation Approval)

Vehicle manufacturers must demonstrate that the installed indirect vision devices provide the required field of vision for the vehicle category. This involves geometric validation of the visible area from the driver’s eye point using either physical measurement or computer simulation.

Field of Vision Requirements

ECE R46 defines mandatory fields of vision for each mirror class and vehicle category. The field of vision is specified as a ground plane area that must be visible to the driver through the indirect vision device. Key requirements include:

Class III mirrors on M1 vehicles: The driver must see a flat road surface extending from 20 meters behind the driver’s eye point to the horizon, with a width sufficient to cover adjacent traffic lanes.
Class II and Class IV mirrors on N2/N3 vehicles: Wider fields of vision are required due to the larger blind spots of trucks and buses.
Class V close-proximity mirrors: Must cover the area immediately adjacent to the passenger side of the vehicle, down to road level.

For camera-monitor systems, the field of vision must be at least equivalent to the mirror class being replaced. Additionally, the displayed image must present a coherent spatial relationship so that the driver can accurately judge distances and relative positions of other road users.

EMC Aspects for Camera-Monitor Systems

Camera-monitor systems are electronic devices and therefore fall under the EMC requirements of UNECE Regulation No. 10 (ECE R10) in addition to the functional requirements of ECE R46. The EMC considerations are critical because:

Radiated emissions: The camera, monitor, and connecting cabling can emit RF interference that affects vehicle radio reception, mobile communications, and other electronic systems.
Radiated immunity: The CMS must continue to produce a usable image when exposed to RF fields from nearby transmitters, mobile phones, and other vehicles.
Transient immunity: Power supply transients such as load dump, jump-start, and inductive switching must not cause permanent loss of the displayed image.
ESD immunity: The monitor and camera housings must withstand electrostatic discharge events that occur during normal vehicle entry and exit.

Failure of a camera-monitor system during driving is a safety concern, so immunity test levels for CMS are often higher than for non-safety electronic systems. The test levels and methods reference ISO 11452-2, ISO 7637-2, and ISO 10605.

Marking

Approved indirect vision devices carry an E-mark consisting of the letter “E” followed by the country code of the approving authority, the regulation number (R46), and a sequential approval number. For camera-monitor systems, the marking must appear on both the camera unit and the monitor unit.

Certification Process

Device design and prototype: Develop the mirror or CMS to meet the technical requirements of ECE R46 and the EMC requirements of ECE R10.
Laboratory testing: Submit samples to an accredited test laboratory for optical, mechanical, environmental, and EMC tests.
Vehicle installation assessment: Demonstrate that the installed device provides the required field of vision on the intended vehicle platform.
Application submission: File the type-approval application with a UNECE contracting party’s Type Approval Authority.
Approval issuance: Receive the type-approval certificate and apply the E-mark to production devices.

How TESTUPS Can Help

TESTUPS provides end-to-end certification support for ECE R46, including laboratory testing for optical mirrors and camera-monitor systems. For CMS products, we coordinate the ECE R46 functional testing with ECE R10 EMC testing in a single program, reducing time to market. Our team assists with documentation, test planning, and liaison with Type Approval Authorities across multiple UNECE contracting parties.

For related topics, see our articles on UNECE regulations and ECE R118 flammability testing.