Wednesday 26 th February 2014 Exeter SMMT, the S symbol and the - - PowerPoint PPT Presentation

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)

Click to edit Master title style 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

• f 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.

Click to edit Master title style Directive compliance – HGV

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

Click to edit Master title style A Model Report is..

• 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
• f 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 – approvals@vosa.gov.uk
• Phone – 0300 123 9000

Need more info.

Click to edit Master title style 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

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 37

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

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 42

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 43

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

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 48

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 49

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

• ther member states interpretation.

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 51

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 52

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.

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 54

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

• f 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

• r 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

• f 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

• f 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.

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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 63

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.

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 66

Items to consider for the future

Electronic Stability Control (ESC) & Advanced Emergency Braking Systems (AEBS) Introduction from now in stages on different categories

• f 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 67

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

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 69

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 70

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

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 73

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

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 80

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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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

• n (…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

• f 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

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 102

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 103

Summary

How can the SMMT help your business? To help you further and new for 2014, the SMMT will be

• ffering:
• 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

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www.dft.gov.uk/vca

Type Approval Process

What this really means;

Vehicles Vehicles Systems Systems

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
• rganise your application for approval to

ensure that you have done everything you need

130

www.dft.gov.uk/vca

131

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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

• utlined 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

– gareth.jones@vca.gov.uk

• Dave Picker, Chief Engineer, Nuneaton

– dave.picker@vca.gov.uk

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.

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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

THE SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 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 nbase@smmt.co.uk

THE SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 152

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 wwilliamson@smmt.co.uk

THE SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 153

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

• rganisations.
• Providing technical and market

information and business statistics.

• Consulting and informing its members
• n legislative developments.

Wendy Williamson Aftermarket Development Manager wwilliamson@smmt.co.uk

THE SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 154

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 mcroucher@smmt.co.uk

THE SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 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 thopkins@smmt.co.uk

THE SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 156

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

• fficial 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

• f 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 thopkins@smmt.co.uk

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 157

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SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED

SMMT, the ‘S’ symbol and the ‘Driving the motor industry’ brandline are trademarks of SMMT Ltd

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SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED

SMMT, the ‘S’ symbol and the ‘Driving the motor industry’ brandline are trademarks of SMMT Ltd

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