GSR impact on the small series/ low volume industry
Notably there are no specific derogations in the new General Safety Regulation (EU) 2019/2144 for small series / low volume vehicles. As a result, there is increasing frustration in the low volume vehicle community.
With no derogations, this means that even the smallest manufacturers producing very few vehicles will need to develop potentially difficult and costly engineering solutions for subjects including; crash (front, side, pole & rear); enlarged pedestrian head impact zone; AEBS for cyclists and pedestrians; emergency lane keeping system; driver distraction warning and; driver drowsiness warning.
There is a glimmer of hope in that the Regulation does make reference to such vehicles in paragraph (35): ‘…it is appropriate that requirements set out in this Regulation and the delegated acts and implementing acts adopted pursuant to it take into account such vehicles or classes of vehicles where such requirements are incompatible with the use or design of such vehicles, or where the additional burden imposed by them is disproportionate.’
This effectively leaves the door open for specific derogations to be provided in the implementing acts or delegated acts which are yet to be adopted.
This is far from a guaranteed though, and I suspect there will be significant lobbying of the European Commission from the low volume industry across Europe to ensure their needs are addressed.
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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