EU type approval – revision of Framework Directive 2007/46/EC
On January 27, 2016, the Commission’s proposal 2016/0014 (COD) was published. It aims to improve the type approval procedure in relation to the following points, which have proved contentious in the past:
- Harmonizing interpretation of the requirements by the type approval authorities;
- Stricter, harmonized processes for dealing with non-conformities.
To ensure this, the Commission plans to either introduce or tighten up the following points in the type approval process:
- Market surveillance by the Member States and the Commission,
- Introduction of a national fund system financed by approval fees, to finance type testing, type approval and market surveillance,
- Defining a procedure for dealing with non-conformities and divergent interpretations,
- In the future type approvals should be valid for a maximum of five years.
The VDA explicitly supports the aim of improving the type approval procedure in the sense of the above-mentioned objectives of the Commission.
However, the following points should be taken into consideration:
- A transparent and fair system should be found for conducting and financing market surveillance.
- The requirements for performing tests in the type approval procedure must be equally robust and practicable.
- Measures for dealing with non-conformities should be proportionate.
- Appropriate procedures that are harmonized across the EU should be defined for end-of-series vehicles and for vehicles built in more than one step.
- According to the Commission, a new type has to be approved after a maximum of five years. We cannot support this proposal.
Simple administrative processes should be defined for extending the five-year validity of type approvals. For whole vehicles the VDA proposes instead of a formal renewal an audit by another type approval authority, whereby the existing type approval either remains valid or is prolonged if the audit confirms compliance with the requirements.
The statements can be found in the download section.