What's new for manufactureres?
This week I am going to look to provide a summary of what manufacturers need to be aware of with the implementation of the new Type Approval Framework Regulation (EU) 2018/858 on 1st September 2020.
Arguably the biggest change for manufacturers is the introduction of maximum validity periods for whole vehicle type approvals. This has been set at seven years for passenger cars and light vans and ten years for other categories including trucks and buses. This means that if a vehicle approval package has not been updated by the point the validity period has been reached the approval authority must verify that the vehicle complies with the regulatory acts applicable to it; if the requirements are not met, the approval becomes invalid. The vehicle approval would also become invalid if, amongst other reasons, a subject approval within it can no longer be extended to the required level or if the original approval is found to have been based on false declarations or data. Information in relation to each vehicle placed on the market, including date of manufacture and VIN will be made available by the approval authority to the approval authorities of other Member States and the European Commission.
Staying with availability of data; from 5th July 2026 the data entered onto a Certificate of Conformity (CoC) will need to be made publicly available through a common, secure exchange system developed by the Commission. Until then, producing CoCs electronically will be optional, with the paper CoC remaining acceptable; albeit with the potential to utilise more advanced anti-forgery printing techniques. Content of CoCs remains similar but notably the date of manufacture of the subject vehicle must be included. The revised templates for CoCs are provided in Annex VIII to the implementing Regulation (EU) 2020/683. Details around the introduction of electronic CoCs will be provided in a further implementing act.
Currently the requirements for access to repair and maintenance information (RMI) for vehicles approved for sale in the EU is contained within the emissions legislation. The new Regulation draws this into the type approval framework and enhances the requirements which need to be satisfied in full issued before vehicle type approval can be granted. The vehicle repair and maintenance information and On-Board Diagnostics (OBD) data, including subsequent amendments and supplements, is to be made available on a website in a non-discriminatory format.
Some derogations are offered for low volume manufacturers and the national approval schemes, as well as, light trailers and the final stage of multi-stage approvals where the changes are purely bodywork.
Finally, the regulation recognises that in order to ensure that market surveillance activities function correctly, the legal responsibilities of manufacturers, representative, importers and distributors within the Union must be established beyond any doubt. For this reason, enhanced requirements have been introduced for all of these actors in the type approval process. The details are included in Articles 13 to 21.
These are just some of the highlights; there are many other changes within Regulation (EU) 2018/858 and implementing Regulation (EU) 2020/683 with further amendments expected as the new processes and requirements become embedded.
In my next blog, I will switch attention to the impact on authorities and technical services.
Castec Consulting Limited an independent Type Approval, Certification and Compliance consultancy.
We provide specialist services, predominantly in the automotive sector, for companies in the UK and globally seeking assistance in a range of areas including; Type Approval and Compliance, Vehicle Technology and Safety Research, plus the interpretation of automotive legislation.
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