NEWSLETTER - Manchester Metropolitan University · The same test reports could be used for a...

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Two months may have passed since the last STATUS newsletter, but the seasonal celebrations mean there is only one month’s news; people don’t seem to spend much time thinking about road vehicle regulations over Christmas…... There is one significant new development; a member sent us a copy of a leaked draft document which proposes amendments to the Framework Directive 2007/46/EC. We tried to get an official copy without success, but then it was circulated on the EU Commission websites on 28th January. The documents have the Commission’s explanatory notes detailing the background for the proposals and there are roughly 440 pages containing new articles, impact assessments and full technical annexes. There are two Press releases which introduce the work: http://europa.eu/rapid/press-release_MEMO-16-168_de.htm

and:

http://europa.eu/rapid/press-release_IP-16-167_en.htm

The full documents can be seen at:

http://ec.europa.eu/growth/sectors/automotive/technical-

harmonisation/eu/index_en.htm

There were rumours of new work on the Framework Directive roughly twelve months ago when new articles were discussed. We think that legislators were subsequently told to amend the whole Directive including the annexes, and that meant the delay which brings us to 2016. You might remember that the Commission asked for ideas about simplifying the type approval process to make it better for goods vehicles which are usually low volume and multi-stage-build. Individual vehicle approval can be prohibitively labour intensive, and type approval prohibitively slow & expensive for low volume goods vehicles. Amendments to those specific methods of approval are mentioned in the proposal, together with small series and IVA, but it also includes introduction of market surveillance provisions to complement the type approval requirements. The idea was discussed prior to the current emissions problems, but we know that the Commission and many member states are reviewing their approval and CoP systems to see if they control vehicles in-service adequately. Market surveillance might include post-registration vehicle conversions, but we think the Commission has conformance of type approved vehicles in mind. I.e. checking in-service emissions, noise and fuel consumption, rather than conversion of vehicles from vans to crew buses (or whatever). National

Newsletter

December 2015 – January 2016

This Month:

New draft revisions of 2007/46/EC.

Amendments to the Road Vehicles (Approval) Regulations.

UK Vehicle Government Agencies Consultation

Amendments to the Road Vehicles (Approval) Regulations – Republic of Ireland.

Progress of RDE Legislation in Europe.

Automatic Headlamps for New Types of Vehicle.

IVA and Electric Vehicle Safety (ECE R100).

Approval of Safety Glazing Materials UNECE R43.

New Format for “CNITAGE” Applications.

Miscellaneous Members Questions.

New Legislation Published.

Draft Revision of 2007/46/EC

http://europa.eu/rapid/press-release_MEMO-16-168_de.htm

http://europa.eu/rapid/press-release_IP-16-167_en.htm

http://ec.europa.eu/growth/sectors/automotive/technical-harmonisation/eu/index_en.htm

http://ec.europa.eu/growth/sectors/automotive/technical-harmonisation/eu/index_en.htm

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STATUS Newsletter December 2015 & January 2016

authorities are allowed to make their own local regulations for low volume vehicles, including vehicles on the road. However it is remotely possible they will ask for checks on modified vehicles – less than 10% chance we guess. The Commission also wants recall procedures to be clarified and - more significantly - the conditions for granting extensions to approvals for existing types of vehicle. STATUS Members should be interested, because the Commission say they will be:

“improving the suitability of alternative type-approval schemes (national

small series and individual approvals) and of the multi-stage type-approval

process to provide appropriate flexibility for niche markets and SMEs, without

however distorting the level playing field.” There is a completely new part of annex IV which lays down an EU IVA for special purpose vehicles. We do not have time to review the technical requirements, but at first glance they look usable by many members of STATUS. It appears that the current appendices for ECWVTA of SPV’s are used for IVA. The same appendices are used for ECWVTA as well. Many members could choose to use IVA to register special purpose vehicles by using an information package with the individual vehicle which includes all the data and test reports used to apply for ECWVTA as a special purpose vehicle. The same test reports could be used for a European Type Approval, but the manufacturer would need conformity of production clearance and a letter of association with the base vehicle manufacturer. IVA would be much more flexible and minor amendments easier to make. As soon as the testing is complete the manufacturer could apply for EU IVA, even when the CoP and letter of association were not in place. Unfortunately the EU IVA (harmonised IVA or “HIVA”) for M1 and N1 vehicles is still aimed at imported vehicles from outside the EU. The technical requirements still include mandatory ABS, seat testing and evidence that the vehicle will pass the tests laid down in the ECE Regulations for offset frontal impact, side impact and pedestrian protection. An ECSSTA passenger car would not necessarily have the necessary certification; if it did the manufacturer is most of the way to full ECWVTA. Over the last 25 years members have consistently asked for an IVA system for M1 vehicles which is acceptable in all EU countries. Whenever we raise the issue we are told that the current ECSSTA system is regarded as the minimum level that is acceptable by all EU States. HIVA will be allowed for special purpose vehicles, but only because they are multi-stage-build and rely on type approved base vehicles. The problem is that unless the regulations are tight, major manufacturers could use IVA to get around type approval. In reality IVA is too expensive and time consuming to use for large numbers of vehicles, but it could be attractive for low volume specials; perhaps convertibles or go-faster models.

New work to amend Type Approval Framework Directive. Affects vehicles in all categories prior to registration. Future European Approval legislation.

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The same is true of ECSSTA vehicles where SME’s are continually blocked by the Commission when changes to regulations are being discussed. The real driving emissions legislation is a good example, where full exemption for small series cannot be allowed because of abuse of the system by un-named “major manufacturers”. The Commission are not happy with abuse of ECSSTA and genuine small series manufacturers have to deal with additional burdens designed to inhibit major manufacturers. Major manufacturers would not be happy if they cannot use ECSSTA – but they wouldn’t would they? At the moment a car is EC small series if less than 1000 of one type of vehicle is registered, sold or put into service per year in the community. The type definition has been refined in recent years, but we think it could be further revised. This is the opportunity, but it would be necessary for someone to quantify how the ECSSTA system is being abused. Perhaps they could add the phrase “the vehicle may not be a variant or version of a vehicle which has ECWVTA” and agree within TAAM how it should be enforced. A brief scan through the approval procedures for multi-stage-build vehicles has not revealed any significant changes. For example the clauses about exchange of information between base vehicle manufacturer and convertor is the same, with one notable exception. The following text has been deleted:

“The manufacturer of the previous stage shall provide information to the

manufacturer of the subsequent stage regarding any change that may affect

system type-approvals or the whole vehicle type-approval. Such information

shall be provided as soon as the new extension to the whole vehicle type has

been issued and at the latest on the starting date of production of the

incomplete vehicle” Base vehicle manufacturers tend to make the information available when specifically asked, rather than notifying convertors about changes. We personally think the current level of valid approvals should be freely available – even if it was by a web page which states the whole vehicle approval number, extension and date. At the moment it is often necessary to interrogate the homologation department of the importer to find out if the base vehicle approval has been extended. Two further amendments of the Directive are unwelcome to us – the information documents and certificates of conformity are revised. It takes hours of work to go through an existing approval updating the format. We hope that existing manufacturer’s documents will remain valid for as long as possible. We shall have to spend a great deal of time examining the draft documents over the next few months; we cannot claim to have fully read all 440 pages in 24 hours! It is not clear what will happen next, but it can be assumed the papers will be tabled within the EC working groups and then discussed in detail. We guess it will take months before the amendments are finally cleared. If members have any comments to make following reading the drafts we would be grateful to hear them. Please contact Denzil.

New work to amend Type Approval Framework Directive. Affects vehicles in all categories prior to registration. Future European Approval legislation.

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UK Vehicle Government Agencies Consultation. The DfT “Motoring Services Strategy” consultation closed on 6th January. We hope that members took the time to respond. Just after the last newsletter was circulated we became aware of a second consultation from the Driver and Vehicle Standards Agency titled “IVA application and inspection”. Mike circulated the links to members directly via email. That consultation closed on 1st January; they asked for opinions on the application process, usefulness of the guidance notes and inspection locations. Members continually talk to us about their experiences with DVLA, DVSA and VCA, but such comments are of no benefit unless they are made to the agencies which provide the services. If we do it the information is second hand at best. The M1 IVA Inspection Manual has not been updated since June 2013, so we wonder if DVSA currently have sufficient resources to make changes in a timely manner. There are rumours to the contrary, but rumours are obviously not worth the paper they are written on. The postal registration process is not popular with members because the day of registration of a vehicle is usually “pay day” for manufacturers and convertors. Any delay is a delay in the cash flow of all vehicle manufacturing companies. When LVRO’s were open it was possible to travel to the office in person and to make the application directly. The system seems to have gone from a same day personal service to a remote snail mail service. Since the last newsletter the Guardian newspaper published an article which says revenue for vehicle excise duty has dropped by ~£80million since the tax disc was withdrawn. It is possible that vehicles are being driven while on SORN and that the enforcement system is not catching offenders. The article does not go into fine detail, such as the change in revenue due to the tax being related to ownership, rather than use. Remember that the tax disc is retained by the owner when the vehicle changes hands or goes into the trade. That gives further weight to our idea that VED should be scrapped all together and levied on fuel taxation. Tax, MOT and insurance enforcement is now via electronic data bases, where the Police simply check the record to see if a vehicle on the road is properly covered. The VED could possibly be included in fuel duty, which has many elegant advantages:

If a vehicle is driven on the road it must have fuel, if it has fuel the tax is paid; 100% collection. It is already illegal to use red diesel on road.

Foreign vehicles which are driven on UK roads will be taxed if they are fuelled.

No offence of unpaid VED would be possible; no court cases and legal fees.

No reminders or collection is necessary. No refunds required, no transfer of ownership of the tax.

If the vehicle driven for high mileages then more tax is paid.

New work to update DVLA, DVSA and VCA. Affects all vehicles in all categories. Future operation of the registration and approval system.

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If the vehicle uses a lot of fuel (heavy or high powered) more tax is paid.

Economical driving will also reduce the tax burden of the careful user.

Hard driving results in more tax.

The tax collection is directly related to fuel consumption and therefore CO2.

We identified a disadvantage in that zero VED rating becomes impossible, except at first registration. That will affect mobility cars and tax exempt vehicles (even the Queen’s…..). However vehicles used by the disabled and pensioners are used for short distances and would therefore pay less tax. A second, more obvious problem for users is that the Government receives billions of pounds in revenue from VED which would then have to be recovered from fuel pricing. However we still feel that a fuel tax based system would be fairer for all. A vehicle with £110 VED doing 50 mpg and 10,000 miles per year would have to pay roughly 12p extra per litre to recover £110. That would mean a car doing 30 mpg would pay £181, or a truck doing 5 mpg and 20,000 miles per year would pay £2179. That would be excessive for HGV’s, so work would be required to balance the books. Far better to leave fuel pricing as it is, particularly with the reduction in VED admin costs. Members do occasionally complain about the time VCA takes to respond to requests for information and approvals when the time comes. They usually quote two weeks to process technical applications and then two weeks between technical clearance and issue of the final approvals. We hesitate to say this, because VCA do bend over backwards to respond quickly when they can, but in our experience it takes more than two weeks to arrange a face to face meeting and a two week turnaround of paperwork is rare. The Government’s response to the consultation is expected to be published in the spring of 2016. If you have any comments please contact Mike or Denzil.

Amendments to the Road Vehicles (Approval)

Regulations - Republic of Ireland. Work on this subject is on hold while other tasks at the Department for Transport take precedence, so we are not expecting any news. The Republic of Ireland Road Safety Authority are proceeding with an amendment to their own Approval Regulations which is closely related to the UK proposals. Euro 6 and Euro VI emissions standards will be adopted, regulations for alternative fuels adopted, and AEBS/LDWS introduced. We do not intend to discuss this any further, but we can supply a draft document to anyone interested. Returning to the UK proposals, we have a member who is keen on our proposed definition of “Low Volume Vehicle” for BIVA. We want the ancient “Family of Types” definition from 70/156/EEC to be deleted and replaced with a new one based on the 2007/46 definitions for type, variant and version:

Proposed changes to Ireland RVAR. Similar to UK proposals .

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New work to amend the National Approval Regulations. Affects NSSTA and IVA vehicles in all categories. Future GB Approval legislation.

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“a vehicle that is not a variant or version of a type of a vehicle of which more than 300 were manufactured in the world during any period of 12 months falling within the period of 36 months immediately preceding the month in which the vehicle was manufactured.” We also had a response from a member who is not happy with the ramp angles specified for IVA of M2/M3 wheelchair accessible vehicles. Mike suggested 13 degrees (23%) because of the PAS 2012:2012 requirement for M1 vehicles agreed by WAVCA (who developed the standard) as an acceptable ramp angle without a winch when assisted into the vehicle. We mainly object to the large difference between the ramp angle to a kerb and angle to the ground. DfT have not reacted to several attempts to getting the text changed, but we feel duty bound to ask again. For the moment we do not expect developments in the near future, although if you have any comments please contact Mike or Denzil.

Progress of Real Driving Emissions Legislation in

Europe. The phase 2 package of Real Driving Emissions amendments was agreed in the Technical Committee - Motor Vehicles (TCMV) at the end of October. The proposals lay down the actual exhaust tailpipe emissions limits for Euro 6 light passenger and goods vehicles when measurements are made using portable emission measuring equipment on public roads. The measurements will be made in normal atmospheric conditions and during road driving using test equipment which is not as accurate as the usual lab machines. As a result the working group has negotiated a multiplication factor - “conformity factor” – because no-one expects the road results to be the same as the lab tests. The multiplication factor simply gives a realistic margin to compare the lab and RDE figures. The final proposal allows a CF of 2.1. In reality no one knows exactly how the two methods will compare, but it is clear that the RDE figures could be higher by several times. Numerous environmental assessments have shown that air quality in the EU does not meet EU limits, so we can guarantee exhaust emission regulations will be tightened. The existing “NEDC” drive cycle does look suspect. On 14th December the European Parliament published a press release which says the RDE proposal will be opposed by Environment Committee MEP’s. They say that PEM’s results are a maximum of 18-30% higher than lab results, so a CF of 2.1 appears to undermine existing emissions targets. Consequently the ENVI Committee raised a resolution to oppose the Phase 2 amendment, which was passed with 40 votes to 9; the full text can be seen at: http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-%2f%2fEP%2f%2fNONSGML%2bIM-PRESS%2b20151214IPR07434%2b0%2bDOC%2bPDF%2bV0%2f%2fEN We believe the Environment Committee resolution was tabled at the full Parliament plenary session in Strasbourg on 18-21 January, and formed part

Emissions test methods to be revised. Affects Type Approved M1/N1 vehicles mainly. Future Type Approval legislation.

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http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-%2f%2fEP%2f%2fNONSGML%2bIM-PRESS%2b20151214IPR07434%2b0%2bDOC%2bPDF%2bV0%2f%2fEN



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of the decision making process on RDE legislation. Some MEP’s asked for a new RDE proposal while others want the existing Phase 2 proposal implemented quickly. The Commissioner concluded that opposition to the proposal will only prolong the existing unsatisfactory situation, so she asked for support from the EU Parliament as a whole. The formal vote to adopt or reject the Phase 2 RDE amendments is scheduled for 3rd February. In our opinion the ENVI resolution is flawed, because it ignores the difference between lab and on-road driving conditions. The conformity factor needs to accommodate the 30% tolerance for PEM’s plus a projected allowance for the more severe on-road duty cycle. Several reputable sources are saying that on road measurements are often ten times lab results, with quotes of forty times greater regularly published. The CF of 2.1 looks stingy in those terms – in fact a CF of 10 could provide a large improvement in air quality if existing vehicles are really that bad. We don’t think there is enough data for a reliable decision to be made at this stage, perhaps the first two years of PEM’s measurements will provide a more learned picture. The basic fact remains that the existing drive cycle used for emission testing is clearly not representative of driving behaviour in Europe. It does not include 85 mph cruising for hours on end, it does not seem accurate for urban commuting at 13mph average speed for less than ten miles, nor does it cover driving on a Greek Island in summer or Scandinavian forest in winter. Good luck to the people who have to decide what the average is. We noticed a lone French comment about RDE which reminded us that the world light vehicle test procedure is already being developed. That might cure the problem, so there are two agendas working on the same set of legislation, one for the world, the other for a small part of it. The problem is recognised by many countries around the world, because it is air quality in cities which is most harmful. EU and World Health Organisation limit values are exceeded in many European and world countries. The 2015 report on Air Quality in Europe contains the damning facts. We already have clean air zones in London, but Birmingham, Leeds, Southampton, Nottingham and Derby could be joining the trend. California have been doing it for years and Chicago are carrying out investigations. In Mexico low sulphur diesel is being introduced. In New Delhi there are bans on SUV’s with engines larger than 2 litres, trucks older than 10 years and diesel taxis. In Beijing there are “red alerts” for unhealthy air quality. These news items are depressing, but it creates the Political will to change vehicle regulations. Members need to be aware of future developments so they can prepare in a timely manner. Restrictions on vehicles in cities usually introduce maximum age limits, so only newer vehicles are allowed in city centres. That can only be good for sales. Our Government and the EU Parliament are examining the type approval system to establish whether it adequately controls vehicle manufacture. After all it was the American system which discovered use of defeat devices, which in turn generated investigations in the EU. We are aware that UK MP’s have asked our approval authority to comment on the situation here, and in November the UK Parliament’s Transport Select Committee announced an inquiry to examine whether the vehicle type-approval testing is fit for purpose.

Emissions test methods to be revised. Affects Type Approved M1/N1 vehicles mainly. Future Type Approval legislation.

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The European Parliament has created a committee of inquiry which will investigate possible failures of the Commission and Member States to enforce current EU standards on exhaust emissions. They say the Commission has failed to review the test cycle and replace them with real driving conditions. The investigations and doubts about current emission testing do not create a good environment for negotiating new Regulations, particularly when the opinions of Manufacturers are in question. The new regulations will affect M1 and N1 vehicles subjected to type approval. Most members will not be affected because they rely on the base vehicle approval; if you are involved with powertrain development you will be affected though. There is an exemption for small series manufacturers, but that is time limited. It is possible that stage builders will have to keep an eye on the base vehicle approval and availability of base vehicle versions to ensure the finished vehicles comply with the necessary regulations. If you have any comments to make please contact Denzil.

Automatic Headlights for New Types of Vehicle. We recently began a Type Approval Program to certify an electric passenger car for sale in Europe. During the worst case meeting the approval authority reminded us that new types of vehicle must have automatic headlamp switching from July this year. As a result it became necessary to look into the background of the subject to help our understanding. Lighting Installation is regulated by UNECE Regulation 48 for type approved vehicles in all categories. When R48 is amended it does not usually affect existing vehicle types, because lighting technology is relatively mature and European legislators know the technology is very expensive to implement. The costs of tooling body shells and lighting components are very high. Consequently many existing vehicles can be certified using old levels of R48; for example R48.03 is not unusual even though the current level is R48.06. Manufacturers of multi-stage-build vehicles will be able to rely on the base vehicle approval in this respect. The same goes for special purpose vehicles. New types of EC Small Series vehicles will be affected because there is no special exemption in the ECSSTA annex of 2007/46/EC. We have been told that existing types of ECSSTA vehicle can use an existing R48.03 approval indefinitely, even when existing ECSSTA approvals are revoked from 31/10/2016. We presume that this is because the type of lighting installation is not new. Approvals granted under the Road Vehicles Approval Regulations (NSSTA, IVA, BIVA) will not be affected. The step change between 48.03 and 48.04 is quite large because Daytime Running Lamps were made mandatory on new types of vehicle by the ’04 amendment. DRL’s were optional under ’03 and became mandatory under ’04. This is significant for older types where the cost and benefit of

Switching requirements for headlights of new vehicle types. Affecting all categories of type approved vehicle. Existing Legislation.

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engineering DRL’s does not add up. These days DRL’s are much easier to install on new designs because components (to R87) are becoming available. We mention DRL’s because the transitional arrangements for automatic headlamp switching are related to them. The legislators originally treated the two as complementary, so that they tolerated manual headlamp switching where DRL’s were fitted. Dip beam headlamps are brighter than DRL’s, but if the DRL’s are on all the time the need for dip beam headlamps is diminished. Nevertheless, automatic dip beam headlight switching becomes mandatory for new types in 2016. We started by creating a table to compare the R48.05 requirements with the newer R48.06. That enabled us to see the differences much easier than juggling the actual regulations. The “individual specifications” for dip beam headlamps in R48.05 include the following text:

6.2.7.5. Dipped-beam headlamps may be switched ON or OFF automatically.

However, it shall be always possible to switch these dipped-beam headlamps

ON and OFF manually.

6.2.7.6. If daytime running lamps are present and operate according to

paragraph 6.19., either

6.2.7.6.1. The dipped-beam headlamps shall be switched ON and OFF

automatically relative to the ambient light conditions (e.g. switch ON during

night time driving conditions, tunnels, etc.) according to the requirements of

Annex 12; or

6.2.7.6.2. Daytime running lamps operate in conjunction with the lamps

listed in paragraph 5.11. where, as a minimum requirement, at least the rear

position lamps shall be activated; or

6.2.7.6.3. Distinctive means are provided to inform the driver that the

headlamps, position lamps and if so equipped end outline marker lamps and

side marker lamps are not illuminated. Such means are:

6.2.7.6.3.1. Two distinctly different levels of instrument panel illumination

intensity are provided during night and day, indicating to the driver that the

dipped-beam headlamps shall be switched ON; or

6.2.7.6.3.2. Non-illuminated indicators and identification of hand controls

that are required by Regulation No. 121 to be illuminated when the

headlamps are activated; or

6.2.7.6.3.3. A tell-tale visual, auditory or both, shall be activated only in

reduced ambient lighting conditions as defined in Annex 13 to inform the

driver that the dipped-beam headlamps should be switched ON. Once the

tell-tale is activated, it shall only be extinguished when the dipped-beam

headlamps have been switched on or the device which starts and/or stops the

engine (propulsion system) is set in a position which makes it impossible for

the engine (propulsion system) to operate.

6.2.7.7. Without prejudice to paragraph 6.2.7.6.1., 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.)


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The transitional provisions of R48.05 are quite difficult to interpret, so we have re-written them in plain English: 12.22 simplified: As from 30/01/2015 approvals shall only be granted if the vehicle type to be approved meets the requirements of the 05 series of amendments. However, from 30/07/2016 for new vehicles types of categories M1 and N1 and 30/01/2018 for new vehicle types of other categories, approvals shall only be granted if the new vehicle type to be approved meet the requirements of R48.05 excluding paragraphs 6.2.7.6.2. and 6.2.7.6.3. to 6.2.7.6.3.3.

“Existing approvals under R48 granted before these dates will remain valid

indefinitely and extensions of these approvals shall continue to be granted

after.” In other words 12.22 removes the option of DRL switching and tell tales, so that automatic dip beam switching becomes compulsory for new types. Note that this concerns all of the motor vehicle categories M1, M2, M3, N1, N2, N2 and N3. The equivalent text in R48.06 is mildly confusing because it says the lights must have one of the DRL switching options, instead of forbidding it after the dates – it is written the other way around. It essentially means the same as above though:

12.4. Transitional provisions applicable to 05 series of amendments.

Contracting Parties applying this Regulation:

(a) From 30 January 2015 (48 months from the official date of entry into

force) shall grant approvals only if the vehicle type to be approved meets the

requirements of this Regulation as amended by the 05 series of amendments.

(b) Until 30 July 2016 for new vehicles types of categories M1 and N1 and

until 30 January 2018 for new vehicle types of other categories (respectively

66 and 84 months after the official date of entry into force) shall grant

approvals if the new vehicle type to be approved meets the requirements of one

or more of paragraphs 6.2.7.6.2. or 6.2.7.6.3. to 6.2.7.6.3.3. instead of those of

paragraph 6.2.7.6.1. of this Regulation as amended by the 05 series of

amendments. We understand that there is an amendment to R48.06 going through which makes it clear that auto switching is mandatory – the current text is not as clear as ’ 05. Some Members of STATUS do produce single stage build vehicles (goods vehicles, buses, passenger cars), so they will be affected by this subject when they produce a new vehicle design. The others should make sure that they understand when automatic headlamps are required so that they know if they are genuinely exempt. If you have any comments to make on this subject please contact Denzil.


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IVA and Electric Vehicle Safety (ECE R100). Electric vehicles are getting more popular; a member asked us to clarify what the Basic IVA requirements are for an M1 vehicles. The N1 and N2/N3 IVA inspection manuals recently received new sections for Electric and Hybrid Vehicles, but the equivalent manual for M1 vehicles remains unchanged. Incidentally, at the end of last year, the UK Department for Transport circulated a draft amendment of the Road Vehicle Approval Regulations which proposed new UK regulations for implementation of ECE Regulation 100 for IVA and NSSTA for all categories of vehicle. In other words the existing UK Regulations do not formally include R100 at the time of writing. It seems that DVSA have altered the N1/N2/N3 manuals to allow people to use IVA in advance of the RVAR changes. Mike contacted DVSA to ask what the BIVA & IVA requirements are for electric M1 vehicles; they quickly replied as follows:

“With regard to the requirements for Electric vehicles, the Regulation

standard can be found in the summarised list of requirements in the Foreword

section of the IVA N1 manual. This states that currently we require UNECE

Regulation 100.02. As you have correctly identified, this is currently not listed

in the M1 manual.” An amended M1 Inspection Manual is expected in the near future, but in the meantime the text in the N1 manual is a close substitute. The Summarised list of requirements for Basic IVA and Normal IVA for N1 Light Goods Vehicles currently gives R100.02 as the level of regulation, but we think that it should say R100.01. DVSA confirmed that they expect the N1 manual to be corrected to put it in line with the N2/N3 manual which already states R100. The DfT proposals detailed in the last two newsletters says R100.01, so all the relevant texts would then be the same. The 01 series of amendments only requires a few tests for full Type Approval, for example for protection against electric shock, functional safety and hydrogen emissions. Conversely the 02 amendment requires extensive testing of the “Rechargeable Energy Storage System” (the battery in plain English (!)). The tests include dynamic testing, vibration testing, shock etc. which are extremely expensive tests because they are crash or high G sled tests. The 02 series of amendments is not mandatory for ECWVTA until June this year so we assumed it would not be required for IVA currently. DVSA agreed with our assumption, saying:

“For the avoidance of doubt, where Section 69 electric vehicles are concerned

DVSA will work to ECE R100.01 as the least onerous route for IVA, “ People who present an electric or hybrid vehicle for IVA will still be expected to produce satisfactory evidence of compliance with R100, either by showing the vehicle is an original mass produced vehicle, or by supplying a test report from VCA or Technical and Support Services Swansea. In addition the inspector will physically check the vehicle against the required standards given in the N1 IVA Manual.

IVA requirements for electric IVA vehicles. Mainly affects M1 vehicles prior to registration. Implementation of IVA.

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Even though the test report only has to show compliance with R100.01, it is still a fairly involved job for the test house. For example, all electrically live parts must be protected to prevent shocks. All connectors must be inspected to see if they can be disassembled without tools, the electrical system is thoroughly inspected, the REESS must not overheat in use, the amount of hydrogen emitted has to be measured, etc, etc. Manufacturers should read R100 at an early stage in the design process; that is to say not in the week before the IVA inspection! The degree of inspection and proof of compliance with R100 is quite high for a BIVA inspection, but we can see the logic when the risks of new (possibly amateur built) technology is involved. Small volume vehicle manufacturers or convertors could cope with the engineering, but it is definitely outside mainstream automotive design. If you would like to share your own experiences with BIVA or IVA please contact Denzil or Mike.

Approval of Safety Glazing Materials UNECE R43 Plastic glazing materials have traditionally been forbidden from use on type approved passenger vehicles, goods vehicles and trailers. Some plastic panes were permitted, but only in relatively unimportant protected positions. Plastic glazing does not usually exhibit the necessary durability to make it suitable for use in normal road going vehicles, particularly for windscreens where the wipers abrade the surface. New high-tech processes are able to make plastics a viable alternative to glass in a wider range of applications – including windscreens - but it was still not possible to type approve them because the ECE Regulation for Glazing did not allow them. At the end of last year UNECE R43 was amended to include new test procedures which will allow type approval of rigid plastic windscreens, laminated rigid plastic panes and laminated rigid plastic windscreens. Several new annexes were added which mandate tests for impact, light transmission, optical distortion, fire resistance, chemical resistance, abrasion, weathering, humidity, cross-cut (whatever that is), high temperature, radiation resistance and resistance to temperature changes. Just looking at the titles we can assume that it will take a special type of glazing to meet all the requirements. The technology must be relatively new, so it would be necessary to team up with a competent supplier to complete an approval program before production. The UK Approval Regulations are not currently written with plastics windscreens in mind. For example the new panes have their own approval code markings which are not listed yet in the IVA manuals. IVA and National Small Series Approvals may be granted where there is evidence that the glazing meets R43, but it should not be assumed that such panes will be accepted automatically. It would be necessary to approach DVSA to discuss the problem.

IVA requirements for electric IVA vehicles. Mainly affects M1 vehicles prior to registration. Implementation of IVA.

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New amendment of the glazing regulation. Affects all type approved vehicles prior to registration. New ECE Regulation.

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The regulation (UNECE R43.01 supplement 4) came into force on 08/10/2015. It does not give any special transitional provisions, so glazing may be approved to the new standard immediately. You can see it at: http://www.unece.org/fileadmin/DAM/trans/main/wp29/wp29regs/updates/R043r3am4e.pdf

New Format for “CNITAGE” Applications. If you register vehicles in France you will be familiar with the “CNITAGE” system they use over there. Before a vehicle can be registered the French registration authority requires manufacturers to complete a database of information they use internally; it is information from the certificate of conformity and manufacturers information document. Each version of vehicle is listed separately, together with masses, tyre sizes, test results, French fiscal rating and so on. The French authority kindly contacted us to say the format of the application has changed:

“As part of our file exchange procedures for our business "cnitage", we

inform you that the formats for file categories M1 and N1 will evolve. You will

find these new formats as attachments. They differ slightly from those

submitted after the meeting of 10 June 2015 (2 columns delete "Number of

particles - Gas").

The "format" files include:

- A tab "File" column indicating that the file should have transmitted,

- A "Note" tab provides information on the rules for filling the file,

- A "location marker" tab giving the codification to be used for the markings

locations.

You can use these new formats right now. However we can work with the old

format until the end of 2016.

Reminder: The "incomplete" format is only usable in the case of an

information package covering only incomplete TVVs.”

Just in case you make these applications and have not heard direct from CNRV we reproduce the information above. Denzil has copies of the new forms if you need them.

French registration database. Affects all type approved vehicles registered in France. New procedure applies from the end of 2016.

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http://www.unece.org/fileadmin/DAM/trans/main/wp29/wp29regs/updates/R043r3am4e.pdf

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Miscellaneous Members Questions: If you have any questions about vehicle legislation please let us know; don’t forget to tell us if you would like the answer to remain in confidence. The articles in this newsletter are our opinions based on many years’ experience in the specialist vehicle industry; however the law remains the sole prerogative of the courts.

Q1. “I have been asked to investigate legislation concerning whether a

parking brake can be held off (air release, spring apply) by an electric solenoid controlled by a switch mounted on the dash rather than having to have an air control valve mounted in the dash to make the system easier to package etc. The electric handbrake release would be fitted to a heavy goods vehicle with an air brake system which is conventional.” Braking regulations require that the part of the parking brake system (which holds the vehicle stationary even when the driver is not present) must be a purely mechanical system. The majority of cars use a mechanical lever to apply force to the wheel brakes via a cable. The mechanism has to compensate for changes in braking force which can occur because of the brakes cooling while stationary. Parking brake systems must not rely on electrical, hydraulic or air transmission of braking force to keep the brakes on. The regulations ensure that the vehicle will not run away when left unattended if the electricity, air or hydraulic sources diminish due to a fault. The same basic principle applies whether the vehicle will be registered using IVA, NSSTA, ECSSTA or ECWVTA. It also applies to vehicles in service provided they are required to have a parking brake by the Construction and Use Regulations. Heavy vehicles usually employ spring brakes which use the springs themselves to apply the brake force at the wheels. The air system is used to release the brake, rather than apply it. As a result the brakes will lock on if the air system fails. The parking brake control is an air valve which releases the air to apply the parking brake. The system is separate to the service brake system. If an electric control was used instead of the air valve the same principle could apply, in that a power failure would apply the brakes. We are presuming that the electric handbrake control would operate a pneumatic valve in the air brake system, rather than a direct electric control of the wheel brakes. In this case an electrical failure or air supply failure could apply the brakes provided the electric switch disengages the brake, rather than applying it. However we think that a failure mode analysis should be carried out to examine if it is truly safe. Knowing that this manufacturer designs vehicles for sale as new, the brake system design must satisfy ECE R13. An electrically switched air operated parking brake does seem to be allowed, but we recommend that the design

A variety of technical FAQ's See each answer for the Vehicle Category. Current Legislation.

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team reads an up-to-date copy of R13 thoroughly to make sure it complies with all aspects of the regulation. When the system is designed then we would contact the approval authority to talk it through. Our reference copy of R13 is amendment 11 supplement 13. You can find a copy via: http://www.unece.org/trans/main/wp29/wp29regs1-20.html Apparently Volvo FM trucks have an electronic handbrake, but we are not sure how difficult it is to manufacture and approve a system like that. If you need more information or assistance please contact Mike or Denzil

Q2. “We manufacture bespoke passenger cars which are registered

using the IVA Very Low Volume category. The cars are basically similar in construction and they tend to be lumped into one type by DVSA. Just under 300 vehicles of one type are registered all over the world, which means that we cannot sell more and still use UK IVA. If we produce a new model how could we make sure that it is a different type? If we could sell the cars as kits for assembly by amateurs would they be counted?” The definition of a very low volume vehicle is laid down in the Road Vehicles Approval Regulations (S.I.2009 number 717):

“7. (1) A vehicle is a vehicle manufactured in very low volume if the condition

in subparagraph (2) is satisfied.

(2) The condition is that the total number of vehicles of the family of types to

which the vehicle in question belongs which are manufactured in the world

during any period of 12 months falling within the period of 36 months

immediately preceding the month in which the vehicle was manufactured does

not exceed 300.” If a vehicle complies with that definition the vehicle may undergo a basic IVA inspection, and if it passes it would be granted registration in the UK. The term “family of types” is not defined in the RVAR, but an explanation is given in the M1 IVA Inspection Manual:

NOTE: “family of types” means, of the same manufacturer, of the same basic

chassis/floor pan. We presume that VCA and DVSA have taken advice from their lawyers and have decided that they should apply the above family of type’s definition when enforcing the RVAR. It follows that DVSA are at liberty to decide when different vehicles have the same basic chassis/floorpan. Only they can answer the question, but for example we recently became aware of an N1 goods vehicle which had been converted to a low floor design. The convertor


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takes a standard base vehicle, cuts the original chassis off behind the cab and replaces it with their own chassis frame, rear axle and suspension. The chassis and suspension were made for the convertor and were not related to the base vehicle manufacturer. The wheelbase length was increased and the rear track width widened. We thought that the modifications were sufficient for the converted vehicle to be termed radically altered and not of the same basic chassis, but it was designated the same family by DVSA. The question about amateur built kits is more difficult. The definition in the RVAR is:

6. (1) A vehicle is an amateur built vehicle if−

(a) the vehicle was−

(i) constructed or assembled or

(ii) having previously been registered under the 1994 Act, structurally

modified, for the personal use of a person (R) who is a relevant individual,

and

(b) the whole, or a substantial part, of the construction, assembly or

modification was carried out−

(i) by R,

(ii) by one or more relevant individuals acting on behalf, and under the

direction, of R, or

(iii) by R and one or more relevant individuals acting on behalf, and under the

direction, of R. The person who registers the car could claim it was amateur built for IVA if the construction complied with the definition, but the description for purposes of registration could be the same. The VIN could be the same or identical and if you are simply providing a kit which is the same as your production car it would definitely be the same family of types. If the car was type approved the definition of type includes the manufacturer’s name. Amateurs cannot build a car and use the type approval of a factory built car. An Individually approved car does not have a type in the same terms, but it could be the same family. We simply do not know if the registration system would count each amateur built vehicle in the same type or not. The definitions and the registration system are ambiguous in these terms, so we think it would be risky to assume amateur built vehicles would not be in the same type family. If we get any further information we shall let members know via these pages. If you have any comments to make on this subject, please contact Mike or Denzil.

Q3 “We have an M1 passenger vehicle which has folding seats in the

rear. The vehicle was type approved some time ago using the Directive 74/408/EEC. Various directives were revoked by the General Safety Regulation, so we are extending the whole vehicle approval. However we now notice that R17 for seats requires locking mechanisms for folding seats. That forces a re-design.


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Are we correct and is there a way of keeping the design which satisfies 74/408?” As you say the GSR does revoke 74/408; a full list of deleted Directives appears in article 19 of the original version of 661/2009. The subjects which must be updated are usually related to safety, environmental performance and advanced systems such as lane departure warnings. A later amendment of the GSR includes a list of Directive approvals which may be used and extended for existing vehicle approvals, but predictably article 19 prevents inclusion of 74/408 seat approvals. A similar list of Directives was originally published as a separate guide by the Commission, but it is now in the GSR; see EU Regulation 2015/166 at: http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32015R0166 The GSR also lists the applicable UNECE approvals and says ECE R17.08 must be used. From our discussion with our member, we know that the scope of R17.08 does include the vehicle in question:

1. SCOPE

This Regulation applies to:

(a) Vehicles of categories M1 and N with regard to the strength of seats and

their anchorages and with regard to their head restraints;

(b) Vehicles of categories M2 and M3 with regard to seats not covered by

Regulation No. 80, in respect of the strength of seats and their anchorages,

and in respect of their head restraints;

(c) Vehicles of category M1 with regard to the design of the rear parts of seat

backs and the design of devices intended to protect the occupants from the

danger resulting from the displacement of luggage in a frontal impact.

It does not apply to vehicles with regard to side-facing or rearward-facing

seats, or to any head restraint fitted to these seats.

As usual the devil is in the detail, because the previous version of R17 said the following in the last line of the scope:

“It does not apply to vehicles with regard to folding, side-facing or rearward-

facing seats, or to any head restraint fitted to these seats. “ As a result under R17.07 folding seats did not need locking mechanisms and under R17.08 they do need them. In October last year VCA issued a technical interpretation which reinforces the point:

TI-SAHR-0004

Question:

Is it permissible not apply a locking device to a folding seat?

Interpretation:

If the seat is a ‘folding seat’ as defined in item 2.9 of Regulation 17.07, then it

is outside the scope of the Regulation, so locking devices are not required for

R17 up to 07.


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However, Regulation 17.08 amendment removed the reference to folding seats

which are no longer excluded from the scope and now requirements apply to

them for R17.08.

R17.08 came into force on 22nd July 2009 and the transitional provisions say:

13.9. As from 36 months after the date of entry into force of the 08 series of

amendments, Contracting Parties applying this Regulation may refuse to

recognize approvals which were not granted in accordance with the 08 series

of amendments to this Regulation. So from 22nd July 2012 R17.07 approvals could be refused. In the case of multi-stage-build vehicles we wondered if there were any exemptions in 2007/46/EC, because many can be converted from N1 base vehicles. The requirements for seats in N category vehicles are less onerous than those for M1 vehicles. When we checked it seems that they are affected as well:

“5.3. General specifications applicable to seats of vehicles of categories N1,

N2 and N3 and to seats of vehicles of categories M2 and M3 not covered by

Regulation No. 80

With the exception of the provisions of paragraph 5.1., the requirements also

apply to side-facing seats of all categories of vehicles.

5.3.1. Seats and bench seats shall be firmly attached to the vehicle.

5.3.2. Sliding seats and bench seats shall be automatically lockable in all the

positions provided.

5.3.3. Adjustable seat-backs shall be lockable in all the positions provided.

5.3.4. All seats which can be tipped forward or have fold-on backs and

folding seats shall lock automatically in the position of use by occupants.

These requirement do not apply to folding seats fitted in wheelchair spaces or

areas for standing passengers of vehicles category M2 or M3 of Class I, II or

A. and folding seat(s) fitted in the access passages of vehicles of category M2

or M3.

The General Safety Regulation is profound in its effect on vehicle design and approval, but this is an example of its more subtle overtones. The whole thing seems to be deliberately designed to trip up everyone from engineers to approval authorities. Incidentally the Road Vehicles Approval Regulations still refer to the EC Directives for subject approvals (in the majority of circumstances), so it is possible to apply for a National Small Series type approval of an existing vehicle if the GSR makes an old product prohibitively expensive to approve for Europe. If you have any comments to make, please contact Denzil or Mike.


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New Legislation Published.

We monitor the EU Official Journal (“OJ”) to check for new legislation when it is published; it gives a good insight into the massive volume of EU legislation produced – It affects every aspect of life in the EU. The process did not stop over the Christmas holiday, because from December 1st to January 31st the following new EU texts products were published. Thankfully no changes to vehicles will be required as a result:

COMMISSION IMPLEMENTING DECISION (EU) 2015/2251 of 26

November 2015 confirming or amending the average specific emission of CO2

and specific emissions targets for manufacturers of passenger cars for the

calendar year 2014 pursuant to Regulation (EC) No 443/2009 of the European

Parliament and of the Council EU data for manufacturer’s average CO2 emissions for passenger cars is published on a Commission website. When the data is initially compiled a draft database is published so that manufacturers can check and amend the results. EC Decision 2015/2251 is the final agreed version. This year is unusual because the entries for Audi, Bentley, Bugatti, Lamborghini, Seat, Skoda and Volkswagen have been temporarily removed. http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32015D2251&from=EN

COMMISSION IMPLEMENTING DECISION (EU) 2015/2250 of 26

November 2015 confirming or amending the average specific emissions of

CO2 and specific emissions targets for manufacturers of new light commercial

vehicles for the calendar year 2014 pursuant to Regulation (EU) No 510/2011

of the European Parliament and of the Council A similar procedure takes place for N1 light goods vehicles – this EC Decision parallels the one for passenger vehicles: http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32015D2250&from=EN

Regulation No 13-H of the Economic Commission for Europe of the United

Nations (UN/ECE) — Uniform provisions concerning the approval of

passenger cars with regard to braking Supplement 16 to the original version

of the Regulation — Date of entry into force: 15 June 2015 The EU has adopted the latest amendment of the M1 and N1 braking regulation R13H. The regulation has not been amended. http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:42015X1222(01)&from=EN

Regulation No 121 of the Economic Commission for Europe of the United

Nations (UN/ECE) — Uniform provisions concerning the approval of vehicles

http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32015D2251&from=EN




http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:42015X1222(01)&from=EN

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with regard to the location and identification of hand controls, tell-tales and

indicators - 01 series of amendments — Date of entry into force: 15 June 2015 The EU has adopted the latest amendment of the Identification of Controls regulation R121. The regulation has not been amended.

“DECISION (EU) 2016/34 OF THE EUROPEAN PARLIAMENT of 17

December 2015 on setting up a Committee of Inquiry into emission

measurements in the automotive sector, its powers, numerical strength and

term of office” The European Parliament has decided “to set up a Committee of Inquiry to investigate alleged contraventions and maladministration in the application of Union law in relation to emission measurements in the automotive sector, without prejudice to the jurisdiction of national or Union courts”. This document is the formal notification of that. The decision also mentions a review of the current EU emissions test cycles to establish whether they are adequate. Projects like these seem to be underway in several EU Member States. http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016D0034&from=EN

“Sound level of motor vehicles European Parliament legislative resolution of

6 February 2013 on the proposal for a regulation of the European Parliament

and of the Council on the sound level of motor vehicles (COM(2011)0856 —

C7-0487/2011 — 2011/ 0409(COD))” If we understand correctly, there is a new initiative for reduction of road vehicle noise from The European Parliament. It refers to a resolution from February 2013 and is directed at the European Commission; it does not affect vehicle construction yet. The paper directs the Commission to re-examine noise from road vehicles with reference to road layout and road surface design as well as noise from tyres. In addition the noise results from type approval testing would be included on the environmental labelling of vehicles at point of sale. It states that road layout and road surface design can reduce noise pollution, but that it would be difficult to enforce redesign of roads in a time of austerity. We are not expert in the intricacies of European Government organisation, but this appears to be the first step towards new work on vehicle noise reduction post 540/2014. The draft paper refers to the previous Directive 70/157. We will report on developments as they appear in the Official Journal and/or the working groups. http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52013AP0041&from=EN (Editorial note: L313 to L023, C016 to C036)



http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52013AP0041&from=EN

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UK Statutory Instruments The UK Government publishes hundreds of new statutory instruments every year. Five documents of minor interest to members were posted on the Legislation.gov.uk website between 1st December and 31st January. Most are related to pay and taxation, with the exception of amendment to driving licence regulations.

“2015 No. 1949 - The Value Added Tax (Caravans) Order 2015” The 1994 VAT regulations have been amended to update the British Standard for residential caravans from BS 3632:2005 to BS 3632:2015. It does not seem to apply to touring caravans. http://www.legislation.gov.uk/uksi/2015/1949/pdfs/uksi_20151949_en.pdf

“2015 No. 2004 - The Road Traffic Offenders Act 1988 and Motor Vehicles

(Driving Licences) (Amendment) Regulations 2015” From 4th January 2016, someone who is disqualified from driving will be permitted to drive as a provisional licence holder. The new regulation will allow them to demonstrate their eligibility to take a new driving test. http://www.legislation.gov.uk/uksi/2015/2004/pdfs/uksi_20152004_en.pdf

2015 No. 1979, INCOME TAX, The Van Benefit and Car and Van Fuel Benefit

Order 2015 For the tax year 2016-17 onwards the car fuel cash equivalent increases from £22,100 to £22,200. The cash equivalent for the benefit of a van increases from £3,150 to £3,170 for van fuel: the cash equivalent rises from £594 to £598. http://www.legislation.gov.uk/uksi/2015/1979/pdfs/uksi_20151979_en.pdf

“2015 No. 2024 - The Vehicle Drivers (Certificates of Professional

Competence) (Amendment) Regulations 2015” The regulations are amended from 25th January 2016; various references to EC Directives and the corresponding UK Regulations have been updated. A new exemption for vehicles under the control of the Prison Service is introduced. An empty vehicle may now be driven up to 100 km from the driver’s base if they do not have CPC. http://www.legislation.gov.uk/uksi/2015/2024/pdfs/uksi_20152024_en.pdf

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“2016 No. 68 - The National Minimum Wage (Amendment) Regulations 2016” The minimum wage regulations have been amended again, with an in-force date of 01/04/2016. The amendment refers to the living wage, penalties for underpayment and the normal minimum wage by the age of the worker. http://www.legislation.gov.uk/uksi/2016/68/pdfs/uksi_20160068_en.pdf

Current IVA Inspection Manuals. The manual for M1 passenger vehicles is due for an update in line with the recent goods vehicle manuals; we shall report on it when it becomes available.

Current IVA Manuals

As at 22/01/2016.

Vehicle Category

Current Version Date issued.

M1 9.0 17/06/2013

M2, M3 10.1 04/03/2013

N1 3.0 05/10/2015

N2, N3 9 01/09/2015

All O’s 6 29/10/2014

The link to the IVA Manual page is: https://www.gov.uk/vehicle-approval/individual-vehicle-approval-

manuals

Written by Denzil Brunning and Mike Hughes.

Editing by Mike Hughes, STATUS Manager.


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