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Cars and motorcycles have required Type Approval for over 20 years. However, new regulations mean that, with a few exceptions, all vehicles will in future have to comply with EU Type Approval rules. These are being introduced in stages up until October 2014. Unless a vehicle has type approval it cannot be registered for use on the road and, for the first time, type approval will apply to the entire vehicle, including bodywork and trailers.
What is Type Approval?
Type Approval is confirmation that a vehicle design meets specified performance standards. These standards are approved by an independent body which is responsible for testing, certification and checking that production examples of the vehicle conform to the approval given. The relevant body in the UK is the Vehicle Certification Agency (VCA), an executive agency of the Department for Transport based in Bristol.
What vehicles are covered?
Two systems of Type Approval for cars and motorcycles have been in use in Europe for the past 20 or so years. With effect from 29 October 2011, Type Approval became mandatory for minibuses, buses and coaches. The rules have recently been extended so they will in future (with a few exceptions) apply to all vehicles including light commercials, heavy goods vehicles and trailers. The limited classes of vehicle which are exempt include military vehicles, vehicles used by the Fire Service, tracked vehicles, mobile machinery, large cranes and road sweepers not based on a truck chassis.
What is European Whole Vehicle Type Approval?
The existing type approval regime for commercial vehicles covers a mere seven requirements, although this is supplemented by the need to comply with the Construction and Use Regulations and the Lighting Regulations. European Community Whole Vehicle Type Approval (ECWVTA) covers 42 requirements which extend not only to the vehicle’s chassis and cab but also to its bodywork. The majority of the areas covered by ECWVTA will fall to the vehicle manufacturer but some five or six areas will apply to vehicle bodywork. This means that, for the first time, bodywork builders will need to obtain type approval. It should be noted that where a bodybuilder attaches the same body to a chassis produced by different manufacturers, a separate type approval will be needed for each vehicle type, even where the body is identical. The flipside of this is that many aspects of bodywork don’t affect type approval issues. In principle, it is possible to include box vans, curtainsiders, tippers and flatbeds on the same approval, potentially even where other equipment (such as cranes) is fitted. Unlike a number of other European countries, the UK doesn’t require trailers to be registered. However, with effect from 29 April, this year new requirements for notification and record keeping began to come into force and from 29 October 2012 all new trailers will need to have type approval.
Time Table (Key Dates)
- 29 April 2009 ECWVTA optional for all classes of goods vehicles.
- 29 October 2011 ECWVTA mandatory for minibuses, buses, coaches and single-stage built trucks under 3.5 tonnes.
- 29 April 2012 New requirements for notification and record keeping in respect of trailers
- 29 October 2012 ECWVTA mandatory for new types of goods vehicles over 3.5 tonnes, complete and incomplete trailers and new types of special purpose vehicle.
- 29 April 2013 ECWVTA mandatory for all new goods vehicles of less than 3.5 tonnes & old-style type approval of these vehicles ceases to be valid.
- 29 October 2014 ECWVTA mandatory for all remaining classes of goods vehicles & trailers and old-style approvals cease to be valid.
What are the implications?
Leasing companies and other funders will be largely unaffected where they are funding a vehicle which has been completed and which is registered at the time at which the agreement is written. Provided that registration has taken place then this should mean that evidence has been produced that the vehicle has the appropriate type approval. Funders will, however, need to take more care if they are asked to fund a vehicle which is not yet road-registered.The funding of incomplete vehicles will in future carry greater pitfalls. ECWVTA requires each supplier who contributes affected sections of the vehicle to provide type-approval certification for the parts it supplies. Final certification must be provided by the supplier that contributes the last item of bodywork that completes the vehicle. This creates scope for difficulties to arise in relation to complex vehicles where separate parts requiring type approval are supplied by different suppliers. Manufacturers and suppliers will need to ensure that their contract terms are robust to avoid being drawn into potentially complex disputes. Modifications to new vehicles will need to be handled carefully so as to avoid the risk of infringing a type approval that has already been given. Purchasers and funders will need to ensure that modifications are carried out in a way which complies with the new regime. The new rules are of great significance to bodybuilders who will in future need to get type approval for bodywork. Separate approvals will be required for each different chassis type to which a bodybuilder attaches a body.
More information is available at the VCA