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 24 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; Vehicles Vehicles Plan what Develop Prepare Understand Get tests & Get final needs to be compliant approval the legislation reports done approval done designs documents 4 months (minimum) à ? months ( it depends on … ) Systems Systems Develop (& Write Process Create Control Maintain ObtaIn CoP use!) Quality Documents Plans Records Clearance Manual www.dft.gov.uk/vca
Type Approval Process Vehicles can be approved in either; • Single stage approval • Multi stage approval Image: Magnus Manske 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 Photographs & Document Drawings Template Info Doc Index Information Folder Information Package Type Approval Certificate(s) & www.dft.gov.uk/vca Test Report(s)
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: BX1F V AC1 M10 From earlier slide; 1.3.3. Powered axles (number, position, interconnection): ?? F V??????:1, axle 1 , Not applicable ?? R V??????:1, axle 2 , Not applicable 45 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 46 www.dft.gov.uk/vca
47 www.dft.gov.uk/vca
Examples of items on the check list 48 www.dft.gov.uk/vca
N3 Skiploader 49 www.dft.gov.uk/vca
Skip Loader NSSTA – What needs testing ? Masses and Means check the installation of approved components ! Installation check only ! dimensions ! Inspection only ! Rear registration plate space ! Inspection only ! EMC Lighting Installation ! Declaration only ! ! Installation check only ! Rear-underrun device ! Installation check only ! Spray Suppression Statutory plates Side guards ! Installation check only ! ! Inspection only ! 50 www.dft.gov.uk/vca ! Installation check only !
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 52 www.dft.gov.uk/vca
Conformity of Production (CoP) • CoP clearance is required for Type Approval – 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 – Control Plan – a detailed description of all the checks performed that ensure completed product conforms to each aspect of the approval 53 www.dft.gov.uk/vca
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 54 www.dft.gov.uk/vca
Maintain your approval!!!! • Changes to your specification • Additions to your specification • Changes to base vehicle • Changes to legislation 55 www.dft.gov.uk/vca
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 56 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) 57 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… 58 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
Contacts • Gareth Jones, Chief Engineer, Bristol – gareth.jones@vca.gov.uk • Dave Picker, Chief Engineer, Nuneaton – dave.picker@vca.gov.uk 61 www.dft.gov.uk/vca
Questions? Thanks for listening! www.dft.gov.uk/vca
The legislative process and the SMMT Tony Hopkins. Technical Manager, SMMT SMMT, the ‘S’ symbol and the ‘Driving the motor SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED industry’ brandline are trademarks of SMMT Ltd
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) SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 64
In the past - For trailers of Categories O1, 2, 3 & 4 No requirements SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 65
So what happened? For all categories of vehicle including trailers – European Community Whole Vehicle Type Approval EC Directive 2007/46/EC SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 66
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 SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 67
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 SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 68
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. SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 69
2007/46/EC Regulation 371/2010 Introduced revised Annex XV – Manufacturer as a Technical Service Regulation 183/2011 Introduced revised Annexes IV & VI – Requirements for the purpose of type approval & model of certificate SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 70
2007/46/EC Regulation 678/2011 Replaced Annex II and revised Annexes IV, IX & XI Requirements, Definitions, COC’s & Regulatory acts Regulation 1229/2012 Introduced revised Annexes IV - Requirements SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 71
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? SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 72
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 SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 73
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 SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 74
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. SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 75
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. SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 76
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. SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 77
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. SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 78
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 SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 79
2007/46/EC What is over the horizon? General Safety Regulation – 661/2009 Comes into Force for new registrations from 14 th November 2014 Draft document covering the specific procedures, tests and technical requirements currently being finalised at the EU. SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 80
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 SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 81
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. SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 82
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? SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 83
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 84
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. SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 85
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 86
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 87
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. SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 88
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. SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 89
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. SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 90
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 SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 91
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. SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 92
What other ways can we assist you? SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 93
SENTA SMMT European and National Type Approval SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 94
SENTA - SMMT European and National Type Approval guide 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). SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 95
Opening page SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 96
Opening page - COP SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 97
Conformity of Production (COP) SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 98
Conformity of Production (COP) SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 99
Opening page – Help Guides SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 100
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