Since the end of the 1950s the UN ECE in Geneva has been working on cross-border harmonization of technical regulations. The UN ECE agreement dated 20 March 1958 concerning the adoption of uniform technical prescriptions for wheeled vehicles, equipment and parts that can be fitted and/or be used on wheeled vehicle and the conditions for reciprocal recognition of approvals granted on the basis of these prescriptions, laid a milestone on the path towards uniform technical registration regulations. The agreement now comprises 131 technical regulations. These concern not only systems and components for active and passive safety but also environmentally relevant regulations. Meanwhile the agreement has been signed by 51 countries.
Within the EU, there is complete harmonization of registration regulations and mutual recognition. Outside the EU, not all signatory states apply all regulations. Many countries such as Russia have integrated the regulations into their national registration law. The situation is similar in Japan. However, even if only a few of the ECE regulations are applied, this already represents a first step towards harmonization.
The 1959 agreement is based on the type approval process. An independent test institution is producing a report with the objective of confirming the validation of ECE requirements. A public authority issues the type approval on this basis. As a result, the USA is fundamentally barred from joining the 1958 agreement. This is because the process of self-certification used in the United States is incompatible with the type approval. For this reason, a further agreement has been launched under the auspices of the UN: these are referred to as global technical regulations under the UN ECE agreement of 1998 (“Global technical regulations for wheeled vehicles, equipment and parts that can be fitted and/or be used on wheeled vehicles”). This agreement has now been signed by 33 countries – including some EU member states, the People’s Republic of China, South Korea and the United States of America.
Since 1998, 13 global technical regulations (GTRs) have been worked out in the expert committees of the UN ECE. These refer to, for example, door locks and door retention components – GTR1, head restraints – GTR 7, electronic stability control systems – GTR 8, proposal to develop a global technical regulation concerning heavy-duty vehicle exhaust-emissions – Appendix to GTR 4, pedestrian safety – GTR 9 as well as regulations concerning hydrogen and fuel cell vehicles – GTR 13.
Most GTRs have been implemented in the set of rules contained in the 1958 agreement, as a result of which they are accepted by the signatory states to that agreement and are implemented via ECE regulations. Furthermore, a few GTRs have been adopted into the national law of the states that signed the 1998 agreement. However, the 1998 agreement has a “congenital defect.” According to its Article 7, the contracting state that votes in favor of establishing a specific GTR shall be obligated to implement its provisions into the national laws of that contracting state. Furthermore, regular reports should be submitted to the UN about the further course of the process. There is no obligation for the agreement to be implemented. Many signatory states including the USA only got halfway towards implementing the GTRs in their national law. It remains to be seen whether the negotiations that started at the end of 2013 regarding a bilateral free-trade agreement between the European Union and the United States (TTIP, Transatlantic Trade and Investment Partnership) will lead to mutual recognition of technical regulations and certifications. Examinations are under way as to whether and to what extent a functional equivalence can be validated between the regulations of the EU and the USA, at least with regard to vehicle safety. This would be a basic precondition for imposing the same requirements on certification in the EU and the USA.
The committees of the ECE at the United Nations in Geneva are working in parallel towards the objective of developing the 1958 agreement further and increasing the number of states using this agreement. The agreement should be made more attractive for other states to join. There should also be dialog with developing countries that are not yet in a position to apply the ECE regulations with full stringency. As a result, a process has been launched for expanding the agreement through to an international whole vehicle type approval (IWVTA).
This is being worked out in a working group of the UN WP.29, the world forum for harmonization of technical vehicle regulations. The 1958 agreement is being expanded so as to create not only harmonized regulations for systems or components, but for the whole vehicle. For this purpose, an ECE regulation 0 is being formulated, which describes a whole vehicle approval.
In order to make it easier for developing countries to use the IWVTA, and thus make joining the agreement more attractive, the draft that is currently under discussion allows scope for the contracting parties to take a more flexible approach to the strictness and scope of requirements within the individual countries. Although this will not allow complete mutual recognition of approvals initially, it does represent a first step in that direction. As a result, the first level would involve an approval with limited recognition in the event that it only certifies a lower scope of technical features. The result of this might be that it is not possible to provide validation of compliance with individual regulations. In contrast to this, however, there might also be universal approvals certifying compliance with all requirements (on the highest level). The great advantage compared to the EU type approval already practiced today is that the ECE regulations would apply in a significantly wider area than the European Union.
Contracting parties that intend to apply type approvals with restricted recognition must notify the UN Secretariat which deviations from a universal IWVTA they are prepared to accept. As a first step, the IWVTA will not cover all subsystems of a vehicle, meaning that it is only possible to refer to a partial type approval on an initial basis. Nevertheless, the objective is for the approval to be expanded successively. The goal is and remains whole vehicle approval. On the long path leading to “approved once – accepted everywhere,” at least the first IWVTA approval should be able to be granted by the end of the current decade.