SMMT Type Approval WorkshopDirective compliance – HGV From DOM 29th April 2009 - Noise - Emissions...
Transcript of SMMT Type Approval WorkshopDirective compliance – HGV From DOM 29th April 2009 - Noise - Emissions...
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
SMMT Type Approval Workshop
Wednesday 26th February 2014
Exeter
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
Welcome address
Allan McKenzie.
Deputy Head and Senior Technical Manager,
SMMT
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 3
Purpose of today
To give you:
• An overview of type approval
– What is it?
– The approval routes available
– How to obtain approval
– What's it like to obtain approval
– The tools to assist you
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 4
Draft SMMT Type Approval Interactive Workshops
PROGRAMME
Time Subject Speaker
09:30 - 10:00 Registration - networking and refreshments
10:00 – 10:05 Welcome Allan McKenzie, Deputy Head and Senior Technical Manager,
SMMT
10:05 – 10:50 Individual Vehicle Approval Process
How the process works and how to obtain an approval
Nigel Maden, DVSA
10:50 – 11:30 SMMT Technical Department
How the legislation evolved, how the SMMT has influenced change
and how we are continually influencing the future. How the SMMT
can help your business and the SMMT SENTA tool.
Tony Hopkins, Technical Manager, SMMT
11:30 – 11:45 Refreshments and networking
11:45 – 12:30 Type Approval – The process
Overview of how to obtain Type Approval
Mike Protheroe, VCA
12:30 – 12:45 SMMT Membership
How the SMMT works and benefits of being a member
Tim Hughes, Membership Account Manager, SMMT
12:45 – 13:45 Lunch and networking
13:45 – 16:00 Individual discussions
Opportunity to talk to the agencies and the SMMT
SMMT, DVSA, VCA
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
Nigel Maden,
Approvals Process Manager, VOSA
Individual Vehicle Approval (IVA)
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Individual Vehicle Approval
(IVA)
Vehicle and Operator Services Agency
Swansea
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• EC Whole Vehicle Type Approval - ECWVTA
• National Small Series Type Approval - NSSTA
• Individual Vehicle Approval - IVA
Your options
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Individual Vehicle Approval – Your Choice
• Inspection of an individual vehicle to
establish compliance that results in the issue
of an Individual Approval Certificate
• Least Onerous Criteria - Flexibility
• Compliance – Combination of documentary
evidence of EC Directive compliance,
declaration & visual inspection
What is IVA?
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• Imported HGVs up to 25 years old
• Low volumes or bespoke HGVs multi stage
approval – date of manufacture from 29th
October 2014
What may need HGV IVA
• Low volumes or bespoke HGVs single
stage approval – date of manufacture from
29th October 2012
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• Obtain application form/guidance from Internet
• Complete & send application to VOSA Swansea
• Application check / evidence of compliance / data
• Application sent to station of choice
• Inspection arranged / completed
• If successful Individual Approval Certificate issued
What’s the process?
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• Manufacturer
• Distributor / Dealer / Supplier
• Body Manufacturer / Coach builder
• Operator / Converter
• To take responsibility for submitting the
application and providing the data required.
• Important to obtain Directive compliance to
support application
Who can apply?
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• Web -https://www.gov.uk/vehicle-
approval
IVA 1H - category N2 and N3 (Heavy goods)
• with guidance notes
Complete an application
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General info. eg
• Applicant details
• Appointment and payment details
Vehicle Details eg.
• What type of body is fitted ?
• Fuel Type / Engine number ?
The info. needed
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• Does the vehicle have evidence of Directive
Compliance ?
• Has the vehicle been modified since approval ?
• Is the vehicle being assessed against a Test
Report or Model Report ?
Compliance info.
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• Brakes, Tyres and Suspension
• Type of braking system
• Axles with “Park” brake
• Dimensions
• Overall Length / Overall width
• Weights
Annual Test Information (Plating)
More info.
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From DOM 29th April 2009
- Noise
- Emissions
- Fuel Tanks
- Rear Protective Device
- Steering Effort
- Braking
- EMC
- Anti Theft (if fitted)
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• Age related standards equating to NTA
requirements Eg. 2002 vehicle,
• Noise
• Emissions
• Braking
• EMC (spark Ignition only)
Directive Requirements pre 29/04/2009
HGV
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Lights /
Reflectors
Lateral Protection
Spray
Suppression
Reg. Plate
Space
Dimensions
Seat
Belts/Anchorages
Defrost / Demist
Couplings
Exterior
Projections
Tyres
Glass
Wash Wipe
Towing
Hooks
Headlamps
Controls
Speed
Limiter
Mirrors
Horn
Visual Checks
Statutory
Plates
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• Evidence that Directive standards are met
• Manufacturer’s Letter of Compliance / CoC
• Your own approval(s)
• Directive test at a Technical Service (or Approval Authority)
• Model Report
• Immobiliser/Alarm (both optional) – • Mobile Electronics Security Federation (MESF)
• Thatchem Registered Installer (TRI)
How to prove compliance
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• A technical report that enables a VOSA
examiner to check that the specification of
subsequent vehicles is the same in all
relevant respects to the vehicle originally
tested at the technical service.
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Convertor
• considers worst case scenarios
Basic process (third axle model
report)
• modifies vehicle, uses axles having
approval to ECE Regulations.
• supplies Technical Service with vehicle and
all relative information
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• detailed system schematics,
• completed proforma. (supplied by VOSA)
• braking calculations (obtained from axle
manufacturer or brake system
manufacturer or they can be provided by
Technical Service)
• axle information and brake approvals/test
report to Annex 11 and 19 of ECE
Regulation 13
Info to the Technical Service
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• Technical Service
- carries out tests including response time
energy consumption and dynamics
- verifies compatibility, proforma specification
against vehicle and calculations.
- sends complete package direct to VOSA
Swansea.
• VOSA - receives and collates data and
creates a version 1 (draft) Model Report.
What the Technical Services
do….
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• Evidence of compliance for the items
requiring documentary evidence
• Application form IVA1H
• Fee
Apply to Swansea
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• Technical Service
• Information
• Logistical
• Goods (N2 / N3) £230 £46
• Statutory Fee (pre funded account available)
The costs
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• Edinburgh (Livingston)
• Manchester (Chadderton)
• Derby
• Avonmouth
• Gillingham
• For heavy vehicles, 5 VOSA sites – potential
of private sites
VOSA test sites
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• Privately Owned Test Facility (POTF)
(under contract)
• Manufacturer, Importer, Distributor, etc. owned
facility
• Inspections conducted by VOSA or VCA
VOSA test at your site ?
• Site requirements depending on your needs
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• Building
• Suitable size/specification
• Communication system / office
accommodation
• Underside inspection facility
• Headlamp test equipment
POTF site requirements
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• Outdoor area (potential requirements)
• Turning Circle Area
• Noise Test Area
• Mirror Test Area
POTF site requirements ctd.
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• IVA Inspection time (approx)
HGV ….2.5 hrs.
Approx test times
Click to edit Master title style Inspection criteria
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• Individual Approval Certificate (IAC)
• Notification of Refusal – 6 months to
apply for re–inspection.
• Plate / Plating Certificate Issued
If it passes (or not)
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• Consider how approval will impact
your business
• Communicate
• Start the preparation
• Try it out
Health Warning !!!
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• Web - https://www.gov.uk/vehicle-approval
• e mail – [email protected]
• Phone – 0300 123 9000
Need more info.
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Any Questions...............
................. Sorry too late !
And finally ……….
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
The legislative process and the SMMT
Tony Hopkins.
Technical Manager,
SMMT
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In the past – National Type Approval
To register a Commercial vehicle of Categories N1, 2 & 3
7 areas of the vehicle were covered –
Brakes
Emissions
Noise
Smoke
Front underrun (if applicable)
Tyres
Speed limiter (if applicable)
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In the past -
For trailers of Categories O1, 2, 3 & 4
No requirements
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So what happened?
For all categories of vehicle including trailers –
European Community Whole Vehicle Type Approval
EC Directive 2007/46/EC
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2007/46/EC
380 + Pages
21 Annexes
16 Amending Regulations
Covers all vehicle categories and types
Anything up to 60+ separate directives to comply with
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2007/46/EC
16 Amending Regulations
Regulations 1060/2008, 78/2009, 79/2009, 385/2009,
595/2009, 661/2009, 371/2010, 2010/19, 183/2011,
582/2011, 678/2011, 65/2012, 1229/2012, 1230/2012,
143/2013 and 195/2013
All introduced since 2007
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2007/46/EC
Regulation 1060/2008
Introduced revised Annexes I, III, IV, VI, VII, XI & XV
Annexes I & III are the Information documents to be
supplied to the Approval Authority.
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2007/46/EC
Regulation 371/2010
Introduced revised Annexes XV
Regulation 183/2011
Introduced revised Annexes IV & VI
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2007/46/EC
Regulation 678/2011
Replaced Annex II and revised Annexes IV, IX & XI
Regulation 1229/2012
Introduced revised Annexes IV
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2007/46/EC
Since 2007:
Annex IV either revised or amended 4 times
Lists of regulatory Acts updated to cover Small Series
changes etc.
How has the SMMT influenced the process?
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2007/46/EC
Worked closely with the Small Series / Low Volume
producers to ensure certain costly testable items are
exempt testing or require reduced levels of testing.
Examples:
Frontal Impact
Enhanced Stability Control
OBD Requirements
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2007/46/EC
Masses & Dimensions - 1230/2012
Incorporated 2 Masses & Dimensions covering
passenger car, commercial vehicles, buses and trailer
M&D requirements into 1 Regulation.
However, in its initial draft it removed the option for
National Markets to allow exemptions to the
requirements for vehicles / trailers operated within
their specific market
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2007/46/EC
Masses & Dimensions - 1230/2012
Further lobbying by the SMMT resulted in
amendments to the final document allowing a 2000
limit on trailers and 1200 limit over 4m height for
National Approval and operations.
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Nationally
Vehicle Enhancement Scheme for N1 and certain N2 ‘Vans’.
Concerns raised by Members regarding how to fit out vans with simple systems that only affect Masses & Dimensions
Do these vehicles require full approval IVA?
If so, additional costs burdens to industry and the end user.
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Nationally
Vehicle Enhancement Scheme for N1 and certain N2
‘Vans’.
Lobbied UK Government to allow these items to be
considered ‘payload’ and hence exempt from approval
requirements.
Presented evidence to support the request based on
other member states interpretation.
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Nationally
Vehicle Enhancement Scheme for N1 and certain N2
‘Vans’.
Outcome –
DFT & VCA introduced the Enhancement Scheme
Low cost scheme to ensure final vehicles comply with
COP and legislative requirements.
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Nationally
Vehicle Enhancement Scheme for N1 and certain N2
‘Vans’.
Outcome –
Discussions currently underway with the EU to amend
2007/46 to incorporate the changes allowed in the
scheme
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2007/46/EC
What is over the horizon?
General Safety Regulation – 661/2009
Comes into Force for new registrations from 14th
November 2014
Draft document covering the specific procedures, tests
and technical requirements currently being finalised at
the EU.
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2007/46/EC
What is over the horizon?
General Safety Regulation – 661/2009
Repeals 50 directives and combines requirements into
1 regulation
Reduces need for testing to EEC requirements as UN
ECE Regulations Approvals accepted where available
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2007/46/EC
General Safety Regulation – 661/2009
Issues with conflict between proposed update to
Annex IV for Small Series vehicles and current
required standards.
What is the SMMT doing?
Ongoing dialogue with the DFT & EU to attempt to
reach a consolidated opinion.
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2007/46/EC
Conformity of Production (COP) is the key part of the type approval process.
It ensures that:
Once a product has been ‘Type Approved’ the holder of the approval has to demonstrate the ability to produce a series of these products that conform to the specification and performance requirements of the relevant regulations or directives.
Will the 10th, 100th 1000th meet the requirements and perform the same as the one type approved?
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2007/46/EC
ARTICLE 5
OBLIGATIONS OF MANUFACTURERS
1. The manufacturer is responsible to the approval authority for all aspects of the approval process and for ensuring conformity of production, whether or not the manufacturer is directly involved in all stages of the construction of a vehicle, system, component or separate technical unit.
2. In the case of multi-stage type-approval, each manufacturer is responsible for the approval and conformity of production of the systems, components or separate technical units added at the stage of vehicle completion handled by him. The manufacturer who modifies components or systems already approved at earlier stages shall be responsible for the approval and conformity of production of those components and systems.
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2007/46/EC
ARTICLE 30
VEHICLES, SYSTEMS, COMPONENTS OR SEPARATE TECHNICAL UNITS NOT IN CONFORMITY WITH THE APPROVED TYPE
1. If a Member State which has granted an EC type-approval finds that new vehicles, systems, components or separate technical units accompanied by a certificate of conformity or bearing an approval mark do not conform to the type it has approved, it shall take the necessary measures, including, where necessary, the withdrawal of type-approval, to ensure that production vehicles, systems, components or separate technical units, as the case may be, are brought into conformity with the approved type. The approval authority of that Member State shall advise the approval authorities of the other Member States of the measures taken.
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2007/46/EC
ARTICLE 30
VEHICLES, SYSTEMS, COMPONENTS OR SEPARATE TECHNICAL
UNITS NOT IN CONFORMITY WITH THE APPROVED TYPE
2. For the purposes of Paragraph 1, deviations from the particulars in
the EC type-approval certificate or the information package shall be
deemed to constitute failure to conform to the approved type. A
vehicle shall not be deemed to deviate from the approved type where
tolerances are permitted by the relevant regulatory acts and those
tolerances are respected.
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2007/46/EC
ARTICLE 3
DEFINITIONS
For the purposes of this Directive and of the regulatory acts listed in Annex IV, save as otherwise provided therein:
27. 'manufacturer' means the person or body who is responsible to the approval authority for all aspects of the type-approval or authorisation process and for ensuring conformity of production. It is not essential that the person or body be directly involved in all stages of the construction of the vehicle, system, component or separate technical unit which is the subject of the approval process;
36. 'certificate of conformity' means the document set out in Annex IX, issued by the manufacturer and certifying that a vehicle belonging to the series of the type approved in accordance with this Directive complied with all regulatory acts at the time of its production;
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 61
SI 2009 No 717
Part 6 - Miscellaneous
Enforcement - Forgery, false statements, etc
33. (1) A person commits an offence if, with intent to deceive, that person−
(a) forges, alters or uses a document to which Paragraph (2) applies, or
(b) lends to, or allows to be used by, any other person a document to which Paragraph (2) applies, or
(c) makes, or has possession of, any document so closely resembling a document to which Paragraph (2) applies as to be calculated to deceive.
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 62
SI 2009 No 717
Part 6 - Miscellaneous
Enforcement - Forgery, false statements, etc
(2) This Paragraph applies to−
(a) an EC type approval certificate,
(b) an EC certificate of conformity,
(c) a national small series type approval,
(d) a national small series certificate of conformity, or
(e) an individual approval certificate.
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SI 2009 No 717
Part 6 - Miscellaneous
Enforcement - Forgery, false statements, etc
(3) A person guilty of an offence under Paragraph (1) is liable−
(a) on summary conviction, to a fine not exceeding the
statutory maximum, or
(b) on conviction on indictment, to imprisonment for a
term not exceeding 2 years, or to a fine, or to both.
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 64
SI 2009 No 717
Part 6 - Miscellaneous
Enforcement - Forgery, false statements, etc
(4) A person commits an offence if, in supplying information or
producing a document for the purpose of these Regulations,
that person−
(a) makes a statement which that person knows to be false in a material particular or recklessly makes a statement which is false in a material particular, or
(b) produces, provides, sends or otherwise makes use of a document which that person knows to be false in a material particular or recklessly produces, provides or sends or otherwise makes use of a document which is false in a material particular.
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 65
SI 2009 No 717
Part 6 - Miscellaneous
Enforcement - Forgery, false statements, etc
(5) A person who contravenes Regulation 16, 22(1) or 23(1)
commits an offence.
(6) A person guilty of an offence under Paragraph (4) or (5) is
liable−
(a) on summary conviction, to a fine not exceeding the
statutory maximum, or
(b) on conviction on indictment, to a fine.
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Items to consider for the future
Electronic Stability Control (ESC) & Advanced Emergency Braking Systems (AEBS)
Introduction from now in stages on different categories of vehicle. Conversion of a vehicle of one category to another may have an influence on if such systems should be fitted.
EU considering the issue and SMMT actively participates in the current discussions and lobbies as required.
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Items to consider for the future
As a Bodybuilder, you need to understand the what
legislation is forthcoming and how it could affect the
vehicles you are building.
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Nationally:
Revisions have been published to the VOSA IVA
Manuals for N2/3 and M2/3
Brake test requirements have been published relating
to IVA testing of trailers
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Summary
Automotive legislation is continually moving and changing.
What has been indicated here has been derived from the
SMMT and Members discussions and consultations at the
UK, EC and Globally through the UNECE.
The legislation is usually written to cover all categories of
vehicles. It is one of the roles of the SMMT to filter out only
those parts that are applicable to the vehicles that you
manufacture. This is especially true of the SENTA guide
which I will speak about further later.
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What other ways can we
assist you?
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SENTA
SMMT European and National
Type Approval
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A step-by-step web-based programme to guide vehicle
manufacturers, bodybuilders and suppliers through the European
Community Whole Vehicle Type Approval application system. It
also allows for national approval schemes for low volume
manufacturers.
For a new and subsequent approval application, SENTA will ease
the lengthy documentary process.
SENTA takes a manufacturer through Conformity of Production
(COP) principles and examples, component and system
applications, application documents and finally a Certificate of
Conformity (COC).
SENTA - SMMT European and National
Type Approval guide
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Opening page
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Opening page - COP
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Conformity of Production (COP)
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Conformity of Production (COP)
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Opening page – Help Guides
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Help Guide - Trucks
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Opening page
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First Page
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Section 1 – Start of page
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Section 1 – Page continuation
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Section 1 – End of page
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Section 2 – Start of page
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Complete any relevant questions within these sections
as required.
Any sections left blank will result in ‘N/A’ entered in the
relevant section within the final document
If a ‘positive’ answer is required within the relevant
sections, then this must be entered.
Section 2 to Section 8
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Section 9
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Future legislation
Section 9 - Continued
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ANNEX I - Information Document
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The Annex 1 document produced will require minor
modifications and or adjustments where the answer is
highlighted in red. This will include:
• Removing ‘N/A’ or reference to a section
number depending on the answer to be given.
• General alignment of answer into ‘silo’ where
required.
• Add reference to any Annexes as required
Technical file required covering any annexes
The finished document will be in excess of 50 pages.
ANNEX I – Information Document
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Section 11 - General Type Approval
Reference documents
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Section 12 – Component information documents
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Component approval information document Opening page - Scope
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Component approval information document
Cover page
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Component approval information document
Information document pt 1
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Component approval information document
Information document pt 2
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Component approval information document
Information document pt 3
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Component approval information document
Information document pt 4
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Section 13 – Types, Variants & Versions (TVV)
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Section 15 – Certificates of Conformity
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100
MODEL B – SIDE 1
ECWVTA COMPLETED VEHICLES
EC CERTIFICATE OF CONFORMITY
Side 1
The undersigned ………………………………………………………..(Full name and position)
hereby certifies that the vehicle:
0.1Make (Trade name of the manufacturer): ………………………………………………….
0.2: Type: ………………………………………………………………………………………………………….
Variant(a):…………………………………………………………………………………………………..
Version(a) ………………………………………………………………………………………………………..
0.2.1 Commercial name: …………………………………………………………………………………………
0.4 Vehicle category: ……………………………………………………………………………………………
0.5: Name and address of the manufacturer: ………………………………………………………
0.6 Location and method of attachment of the statutory plates: ………………………
Location of the vehicle identification number: ………………………………………..
0.9 Name and address of the manufacturer’s representative (if any):
…………………………………………………………………………………………………………………………
0.10 Vehicle identification number: …………………………………………..…………………………………..
a) has been completed and altered(1) as follows: ………………………………………and
b) conforms in all respects to the type described in approval (…type-approval number including extension number) issued
on (…date of issue) and
c) can be permanently registered in Member States having right/left (b) hand traffic and using metric/imperial(c) units for
the speedometer(d)
…………………………………………… ........................................................
(Place)(Date) (Signature)
Attachments: Certificate of conformity delivered at each previous stage.
Side 1 of the Certificate of Conformity
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The Tour is a snapshot of what is contained in the
SENTA Guide which is written to cover all categories
of vehicles and the possible Approval Routes.
It gives an indication of how the Guide works by
showing parts of the Section pages and how they may
be used.
The application and compliance data included in the
Tour is based on a European Approval for a large
Truck built in two stages – ECWVTA N3 MSB
Take a Tour guideline information
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Summary
How can the SMMT help your business?
• As a user of the SENTA system – Full technical support
in creating your documentation
• As a member – Full support of the SMMT Technical
Department
• Promoting your issues to the UK and wider
institutions
• Assisting with general Type Approval issues
• Keeping you informed of future legislation changes
• Lobbying for change where required
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE
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Summary
How can the SMMT help your business?
To help you further and new for 2014, the SMMT will be
offering:
• Cost effective consultation
• Cost effective training
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
Q&A session
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
Mike Protheroe,
Standards and Legislation Manager,
VCA
Type Approval
www.dft.gov.uk/vca
Type Approval
Mike Protheroe
February 2014
www.dft.gov.uk/vca
Outline
• Type Approval Regulations
• Type Approval Process
• Type Approval Documents
• Conformity of Production
www.dft.gov.uk/vca
Type Approval in a Nutshell
• Whole Vehicle Type Approval authorises a
manufacturer to:
– produce vehicles to a proven specification
– self-certify these as compliant with relevant
legislation
• Two fundamental requirements:
– Meeting the technical and administrative
requirements and capturing the design
– Ensuring that subsequent production
vehicles are manufactured in conformance
with the approved design
108
www.dft.gov.uk/vca
Type Approval Regulations
• The type approval regulations are;
– UK Statutory Instrument 2009 No. 717
www.legislation.gov.uk/uksi/2009/717/contents/made
• These enact directive 2007/46/EC into law
• Manufacturers can choose between;
– ECWVTA
– NSSTA
– IVA
www.dft.gov.uk/vca
Type Approval Regulations
29 October 2014 - Final Implementation Date
• Applies to
– Multi stage approval for medium & heavy
trucks (category N2 & N3)
– Single & Multi stage approval for Special
Purpose Vehicles (category N1 – N3, M2,
M3, O1 – O4)
• See Schedule 3 of the UK Statutory Inst.
www.dft.gov.uk/vca
Type Approval Process
• From website
(click image to
jump to the
page)
www.dft.gov.uk/vca
Type Approval Process
What this really means;
VehiclesVehicles
SystemsSystems
Understand
the legislation
Plan what
needs to be
done
Develop
compliant
designs
Prepare
approval
documents
Get tests &
reports done
Develop (&
use!) Quality
Manual
Create Control
Plans
Write Process
Documents
Maintain
Records
ObtaIn CoP Clearance
Get final approval
4 months (minimum) à ? months (it depends on …)
www.dft.gov.uk/vca
Type Approval Process
Vehicles can be approved in either;
• Single stage approval
Image: Magnus Manske
• Multi stage approval
Image: Unisouth
www.dft.gov.uk/vca
Type Approval Process
• Single stage approval
– in general terms, built to completion in
respect of chassis and body by a single
manufacturer
• Multi stage approval
– in general terms, those where the chassis
manufacturer and body manufacturer are
different and each plays a part in the
approval of the vehicle
www.dft.gov.uk/vca
Type Approval Process
Focus on Multi stage approval
• Stage 1 (Base Vehicle) manufacturer has
already done most of the hard work!
• Stage 2 (3 in some cases) manufacturer(s) /
body builder(s) responsible only for aspects
they add / change
– Maybe 6 or 7 items
www.dft.gov.uk/vca
Type Approval Documents
• Information documents follow a basic and
recognisable format and have information
about;
– you (the manufacturer)
– your products (the type of vehicle or system)
• Most directives / regulations will have a
template for an information document
– if there isn’t one the relevant parts should be
taken from Annex I of 2007/46/EC or SENTA
www.dft.gov.uk/vca
Compiling Information
Information
Document Info
Doc
Certificate(s) &
Test Report(s)
Photographs &
Drawings
Type
Approval
Template
Information Folder
Index
Information
Package
www.dft.gov.uk/vca
Type Approval Documents
www.dft.gov.uk/vca
Type Approval Documents
www.dft.gov.uk/vca
Type Approval Documents
www.dft.gov.uk/vca
Type Approval Documents
www.dft.gov.uk/vca
Type Approval Documents
www.dft.gov.uk/vca
Type Approval Documents
www.dft.gov.uk/vca
Type Approval Documents
www.dft.gov.uk/vca
Type Approval Documents
www.dft.gov.uk/vca
Type Approval Documents
www.dft.gov.uk/vca
Type Approval Documents
www.dft.gov.uk/vca
Type Approval Documents
Letter of Association
• Sets out relationship
between stages
– Always required for
ECWVTA
– May not be needed
if you apply for
NSSTA
www.dft.gov.uk/vca
Example TVV Matrix
Stage 1: BX1FAC1 à Stage 2: BX1FVAC1M10
129
From earlier slide;
1.3.3. Powered axles (number, position,
interconnection):
??FV??????:1, axle 1, Not applicable
??RV??????:1, axle 2, Not applicable
www.dft.gov.uk/vca
Applying for Type Approval
• There is also some ‘scene setting’ guidance
attached to the application form
– Type Approval in general
– Conformity of Production (CoP)
• more on CoP later!
• We have a checklist which will help you
organise your application for approval to
ensure that you have done everything you
need
130
www.dft.gov.uk/vca
131
www.dft.gov.uk/vca
Examples of items on the check list
132
www.dft.gov.uk/vca 133
N3 Skiploader
www.dft.gov.uk/vca 134
Skip Loader NSSTA – What needs testing ?
Lighting Installation
Rear-underrun device
Masses and
dimensions
Statutory plates Side guards Spray Suppression
! Installation check only !
! Installation check only !
! Installation check only ! ! Installation check only !
Rear registration
plate space ! Inspection only !
! Inspection only !
! Inspection only !
EMC
! Declaration only !
! Installation check only ! Means check the installation of approved components
www.dft.gov.uk/vca
Conformity of Production (CoP)
• CoP checks are done in parallel with Type
Approval tests and / or inspections
• You can’t get Type Approval without CoP
– Manufacturers need to provide evidence of
the ability to produce a series of products
that exactly match the specification,
performance and marking requirements
outlined in their type approval
documentation
www.dft.gov.uk/vca
Conformity of Production (CoP)
• CoP is fundamental to Type Approval
– VCA must have confidence in your
manufacturing and change control systems
to enable you to issue Certificates of
Conformity (CoC)
– Quality Management System – controlling
the policies and day-to-day activities of the
business that could influence conformity of
the product to the approved ‘Type’
• ISO9001 / TS16949 satisfy this requirement but are
not mandatory
136
www.dft.gov.uk/vca
Conformity of Production (CoP)
• CoP clearance is required for Type Approval
– ISO 9001:2008 (IAF recognised) & Control Plan
Or
– Recognisable QMS & Control Plan & Audit
• Control Plan – a detailed description of all the
checks performed that ensure completed
product conforms to each aspect of the
approval
137
www.dft.gov.uk/vca 138
Afterwards?
• Issue Certificates of
Conformity (CoC)
– Your declaration that the
vehicle in question
meets the requirements
– Used with previous
stages CoC’s for
registration
– Only add information
that you have affected
www.dft.gov.uk/vca
• Changes to your specification
• Additions to your specification
• Changes to base vehicle
• Changes to legislation
139
Maintain your approval!!!!
www.dft.gov.uk/vca 140
Whole Vehicle Type Approval Costs,
the detail …
Whole vehicle type approval costs with VCA are;
• S&C Admin & Cert fee £110
• Technical fee £89 per hour
• CoP review / audit £250 / £890 / £1,785
• Whole Vehicle Cert fee £75
• Whole Vehicle Admin fee £73
• Technical fee £89 per hour
www.dft.gov.uk/vca
So what does it all mean?
• 1st type £2,000 (approx)
– Add CoP costs (often £250 to £1,000 approx)
• Subsequent types with same body from
£1,300 (approx)
– (e.g. on an alternative chassis)
141
www.dft.gov.uk/vca
Some Issues Encountered
Simple stuff seems so easy to get wrong!
• Number plate space (surface)
– wrong side, proprietary holder wrong size
• Lamps
– additional lamps (not permitted)
– wrong sort, wrong orientation
– obscured…
142
www.dft.gov.uk/vca
Some Issues Encountered
• Got CoP, didn’t realise that they needed
– documents
– tests
– inspections, etc.
• Component Approvals
– E marks needed
– not just any mark!
www.dft.gov.uk/vca
Some Issues Encountered
Documentation
• Thought it was VCA’s job to make
manufacturers information document
• Docs sent in one page at a time, not PDF
• No drawings / drawings not good enough
• Docs only on paper
– in a shopping basket!
www.dft.gov.uk/vca 145
Contacts
• Gareth Jones, Chief Engineer, Bristol
• Dave Picker, Chief Engineer, Nuneaton
www.dft.gov.uk/vca
Questions?
Thanks for listening!
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THE SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
About SMMT
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THE SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
Tim Hughes.
Membership Account Manager,
About the SMMT
PAGE
149
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED
What is the SMMT?
Established in 1902, SMMT supports the interests of UK automotive.
One of the largest and most influential trade bodies in the UK, SMMT is a member organisation
that represents over 500 automotive companies.
Promoting the interests of industry at home and abroad, SMMT acts as the voice for UK
automotive promoting a united position to government, stakeholders and the media.
SMMT provides members with:
• A representative forum to engage with UK governments and EU institutions.
• Automotive data and market intelligence.
• Data analysis services.
• International and national exhibition opportunities.
• Practical technical advice.
THE SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE
150
Representation through the SMMT
SMMT provides a forum for debate and representation on issues affecting industry. (Please note this table it is not complete with all the committees and working groups. Click here to view all)
Trade Sections Committees Working Groups
Aftermarket
Automotive Components
Bus and Coach
Car
Commercial Vehicle Group
Design Engineering Group
Electric Vehicle Group
Engines
Light Trailer and Trailer Equip
Digital Radio
Economics
Education and Development
Engineering
Environmental Policy
International business group
Legal
E-business and Logistics Forum
MVRIS Management
Policy Co-ordination
Public Affairs Committee
Quality Panel
Customer Service (Motor
Codes)
Technology
Vehicle Warranty Products
(Motor Codes)
Vehicle Legislation:
Brakes WG
Light vehicle powertrain WG
Lighting and signalling WG
Passive safety WG
Type approval WG
Vehicle security and insurance
WG
Environment:
End of life vehicle WG
Fuels WG
Hazardous materials WG
Manufacturing environment WG
Noise WG
Sustainability WG
Low volume manufacturers WG
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151
Commercial Vehicle Group
The Commercial Vehicle Group (CVG)
deals with commercial vehicles from light
vans to maximum capacity trucks.
It supports businesses across the sector,
including vehicle manufacturers, importers
bodybuilders, trailer manufacturers,
component industries, aftermarket services
and other interested groups.
Main activities:
• Representing the commercial vehicle
sector’s interests at UK and EU level
• Informing and consulting on legislative
developments
• Providing technical and market
information
Nigel Base
Commercial Vehicle
Development Manager
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Bus and Coach Section
The Bus and Coach Section represents members who manufacture retail or import buses or coaches, or produce ramps or lifts for such vehicles. The scope of the committee has recently been extended to include component and systems supplies.
Main activities:
• Lobbying the UK Government and other relevant national. organisations on matters influencing the market e.g Green Bus fund, Air Quality, Noise & ULEZ.
• Providing market information.
• Informing and consulting its members on legislative developments.
• Co-ordinating the Digital radio project on behalf of vehicle manufacturers and the aftermarket.
Trade sections : Bus & Coach
Wendy Williamson
Aftermarket Development Manager
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Light Trailer and Trailer Equipment Section
This section represents the interests of SMMT members
who manufacture, import, distribute or retail any of the
following:
• Trailer caravans, or light trailers (not exceeding 3.5t).
• Trailer kits.
• Towing attachments for vehicles.
• Trailer components or accessories.
Main activities:
• Representing members’ interests to
the UK government and other relevant
organisations.
• Providing technical and market
information and business statistics.
• Consulting and informing its members
on legislative developments.
Wendy Williamson
Aftermarket Development Manager
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Manufacturing Environment WG
Manufacturing Environment WG (MEWG) assists members with
work in the following key areas:
• Environmental permitting: Industrial Emissions Directive, Integrated
Pollution. Prevention and Control (IPPC), PPC, Local Air Pollution
Prevention and Control.
• Volatile Organic Compounds (VOCs) in paints (including vehicle
refinishing paints) and Solvent Emissions Directive.
• Process guidance notes for the above, including European BREF notes.
• Waste management.
• Producer responsibility for packaging waste.
• Landfill Directive/Regulations.
• Environmental management systems such as ISO 14001, EMAS, and
risk based regulation.
Matthew Croucher
Economics Manager
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155
Brakes WG
The Brakes Working Group monitors draft Braking regulations,
standards, and vehicle legislation through participation with UK
government bodies (i.e. DfT) and official bodies in the UN and in
Europe.
Subject areas covered include the following:
• UNECE R13H for passenger cars and R13 for all other
categories of vehicles.
• Electronic Stability Control (ESC) and Brake Assist System
(BAS).
• Emergency Stop Signal (ESS).
• Regenerative braking.
Tony Hopkins
Technical Manager
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Type Approval WG
The Type Approval Working Group monitors future Type
Approval draft regulations, standards, and vehicle legislation
through participation with UK government bodies (i.e. DfT) and
official bodies in the UN and in Europe. There are over 60 EC
Directives and Regulations and also over 120 UNECE
Regulations relating to Type Approval, covering every aspects
of motor vehicle and trailer manufacture.
These requirements can be found in 2007/46/EC the
Framework Directive.
This Directive allows for many routes for vehicle type
approval:
• European Whole Vehicle Type Approval (ECWVTA).
• European Small Series Type Approval (ESSTA).
• National Small Series Type Approval (NSSTA).
• National Individual Vehicle Approval (NIVA).
Tony Hopkins
Technical Manager
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 157
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