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) 41 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… 42 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 45 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 48
In the past - For trailers of Categories O1, 2, 3 & 4 No requirements SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 49
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 50
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 51
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 52
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 53
2007/46/EC Regulation 371/2010 Introduced revised Annexes XV Regulation 183/2011 Introduced revised Annexes IV & VI SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 54
2007/46/EC Regulation 678/2011 Replaced Annex II and revised Annexes IV, IX & XI Regulation 1229/2012 Introduced revised Annexes IV SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 55
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 56
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 57
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 58
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 59
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 60
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 61
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 62
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 63
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 64
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 65
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 66
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 67
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. SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 68
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. SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 69
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. SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 70
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 71
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 72
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 73
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 74
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 75
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 76
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 77
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 78
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 79
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 80
What other ways can we assist you? SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 81
SENTA SMMT European and National Type Approval SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 82
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 83
Opening page SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 84
Opening page - COP SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 85
Conformity of Production (COP) SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 86
Conformity of Production (COP) SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 87
Opening page – Help Guides SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 88
Help Guide - Trucks SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 89
Opening page SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 90
First Page SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 91
Section 1 – Start of page SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 92
Section 1 – Page continuation SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 93
Section 1 – End of page SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 94
Section 2 – Start of page SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 95
Section 2 to Section 8 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. SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 96
Section 9 SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 97
Section 9 - Continued Future legislation SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 98
ANNEX I - Information Document SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 99
ANNEX I – Information Document 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. SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 100
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