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SMMT Type Approval Workshop

Wednesday 27th February 2013


Newcastle

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 Manager Vehicle Legislation,
SMMT

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
Tony Hopkins.
Technical Manager,
SMMT

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
Agenda
Time Subject Speaker

Welcome, overview of the day and background Allan McKenzie


10:30 – 10:45 to Type Approval including implications for not Tony Hopkins
having an approval SMMT Technical Dept

10:45 – 11:45 Type Approval – How to obtain an approval Mike Protheroe, VCA

11:45 – 12:30 VOSA IVA scheme and how to obtain approval Gary Race, VOSA

12.30 – 12.40 The SMMT Tim Hughes, SMMT

12:40 – 13:30 Lunch

13:30 – 14:00 Example of gaining approval Neil Loy, Mercedes-Benz UK

Conformity of Production and likely costs of


14:00 – 14:45 Mike Protheroe, VCA
gaining an approval

14:45 – 15:15 SENTA presentation Tony Hopkins, SMMT

15:15 – 15:45 Q&A and private discussions All

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 4


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 5


The myths
• It will never happen
• It will not affect me
• The dealer will have to obtain the approval
• I can carry on doing what I am doing
• We will be granted a dispensation because of the
state of the market
• No matter what I do, the vehicle can still be registered
• Tractor units are not covered
• I can always get a VTG10 for my work before
registration

It affects anyone who builds on, converts, modifies, adds to


or changes anything on a Type Approved vehicle

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 6


Timeline

Existing types
of vehicles 2013 2014
(Registrations)

29 April 2013 29 October 2014

Completed vehicles Special purpose


of category N1 vehicles of category
N1, N2, N3, M2, M3,
O1, O2, O3, O4

29 October 2013

Completed vehicles of Completed vehicles


category , O1, O2, O3, O4 of category N2, N3

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 7


Warning

N1 Category Vehicles

29th April 2013

No approval – No registration

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 8


DVLA

The DVLA has issued clear guidance that N1 Category vehicles


will not be registered after the 29th April 2013 unless a
‘COMPLETE’ or ‘COMPLETED’ COC is presented.

‘INCOMPLETE’ COC’s will not be accepted.

‘As from 29th April 2013 you must not register a N1 vehicle using an
incomplete Certificate of Conformity. All N1 vehicles registered on
or after this date must only be registered using the completed
Certificate of Conformity details.’

(Source: DVLA letter ref VPG 2/1/21 dated 14/11/2012)

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 9


In the past -

To register a Commercial vehicle of Categories N1, 2 & 3 –

National Type Approval

Covered 7 areas of the vehicle –

Brakes
Emissions
Noise
Smoke
Front underrun (if applicable)
Tyres
Speed limiter (if applicable)

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 10


In the past -

For trailers of Categories O1, 2, 3 & 4 –

No requirements

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 11


So what's happening?

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 12


2007/46/EC

380 + Pages

21 Annex’s

14 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 13


Type approval routes

• European Community Whole Vehicle type Approval (ECWVTA).

Full approval to register unlimited numbers of a type of


vehicle within the EU

• European Small Series Type Approval (ESSTA).

Approval to register a limited number of a type of


vehicle (M1 / N1) within the EU

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 14


Type approval routes

• National Small series Type Approval (NSSTA).

Approval to register a limited number of a type of


vehicle within the member state issuing the approval

• Individual Vehicle Approval.

Approval of a single type of vehicle. Administered by VOSA.

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 15


Commercial vehicles
Depending on the type of body fitted and the category of vehicle it is
fitted to, it is possible that the following technical requirements will
need to be met:

• Rear protection device


• Side protection device
• Registration plate space
• Statutory plates
• Installation of lighting
• Spray suppression
• Safety glazing
• Masses and dimensions
• Transport of dangerous goods

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 16


SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 17
Trailers
Depending on the type of trailer manufactured, it is likely that the
following technical requirements will need to be met:

• Rear protection device


• Registration plate space
• Steering effort
• Braking
• Radio interference
• Statutory plates
• Installation of lighting
• Spray suppression
• Safety glazing
• Tyres
• Masses and dimensions
• Couplings
• Transport of dangerous goods

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 18


Trailers

• Trailers in the UK are not registered.

• From 29th April 2012, new requirements for notification and record
keeping came into force.

• Consent to Supply document.

• From October 2012 it became mandatory for a large trailer


subject to annual test to be notified to VOSA before it is used on
the public road. VOSA will check the vehicle is approved before
issuing clearance to use the trailer.

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 19


Trailers

Trailers not subject to annual test (under 3500kgs gross weight) or


not used to carry goods.

• From October 2012, it becomes mandatory for the person


retailing the trailer to the public to keep records of every trailer
sold for a period of 10 years.

• The records must show details of the type approval certificate of


conformity or individual vehicle approval (IVA) certificate.

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 20


Items to consider for the future

• Commission Regulation (EU) No 1230/2012 – Masses


& Dimensions

Combines the Masses & Dimensions approvals


92/21/EC (Cars) and 97/27/EC (Other vehicles)
into one unified approval

Allows an exemption for vehicles over 4m high but


only for NSSTA and with restricted numbers that
can be produced per annum

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE 21


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 22


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 23


Type Approval
Mike Protheroe,
Standards and Legislation Manager,
VCA

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
2007/46 EC Article 6
Procedures for EC Whole Vehicle Type
Approval

Mike Protheroe
February 2013

25
www.dft.gov.uk/vca
Outline

• Applying for Type Approval


• Type Approval Information
– various terms and what they mean
– how information is put together
• Type Approval Processes
– step by step
– single step
– mixed approval
– multi stage approval
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Applying for Type Approval

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Applying for Type Approval

• Application form for type approval at the


following URL;
http://www.dft.gov.uk/vca/additional/files/vehicle-type-approval/related-
information/customer-application.pdf

• We need information about you and your


operations before we can start work
– fill in the form
– send in by e-mail / print out & post

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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
organise your application for approval to
ensure that you have done everything you
need
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Examples of items on the check list

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Type Approval Information

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Descriptions of Type Approval
Information
See Article 3 (paragraphs 37 – 40) for definitions;

• it is permissible to supply information in an


electronic file
• VCA prefers to receive it this way!

Information document
• the document set out in Annex I or Annex III, or
in the corresponding Annex to a separate
directive, or regulation, that prescribes the
information to be supplied by an applicant

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Descriptions of Type Approval
Information
Annex I
• Complete Information Document used in Single
Step process
– about 60 pages of A4

Annex III
• Partial Information Document used in Step by Step
process
– about 7 pages of A4

• These templates are available on SENTA


– it’s a good idea to use SENTA
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Descriptions of Type Approval
Information
Information folder
• is supplied by the applicant
• the complete folder of information about the type of
vehicle
– includes the information document, data, drawings,
photo’s, etc.

Information package
• a compilation of;
Type – the information folder (supplied by the applicant)
Approval – test reports, type approval certificates (& other docs)
added by a technical service or approval authority

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Descriptions of Type Approval
Information
Index to the information package
• the document listing the contents of the
information package, it needs to;
– be suitably numbered (or identified) so as to
identify clearly all the pages / items
– present a record of the successive steps in
the management of the EC type approval
• in particular the dates of the revisions and updating

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Compiling Information
Information
Document Photographs &
Template
Drawings
Info
Doc

Index
Information Folder

Information
Package

Type
Approval
Certificate(s) & Test
Report(s) 37
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Type Approval Procedures
(Article 6)
• The manufacturer may choose one of the
following procedures:
(a) step by step type approval
(b) single step type approval
(c) mixed type approval

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Descriptions of the Processes
See Article 3 (paragraphs 7 – 10) for definitions;
Step by step type approval
• a procedure where there is an incremental
collection of the complete set of EC type approval
certificates for the systems, components and
separate technical units relating to the vehicle, and
which leads, at the final stage, to the approval of
the whole vehicle

Single step type approval


• a procedure whereby a vehicle is approved as a
whole by means of one operation
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Descriptions of the Processes
Mixed type approval
• a step by step type approval procedure where one
or more system approvals are achieved during the
final stage of the approval of the whole vehicle,
without it being necessary to issue the EC type
approval certificates for those systems

Multi-stage type approval


• a procedure whereby one or more Member States
certify that, depending on the state of completion,
an incomplete or completed type of vehicle
satisfies the relevant administrative provisions and
technical requirements
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Step by Step Type Approval

• Traditionally this has been the route


chosen by most
• Equally well suited to both single stage and
multi stage type approval
• Each System, Component or Separate
Technical Unit (STU) has its own discrete
type approval package
– is comparatively easy to manage
– “pigeon hole” approach

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Step by Step Type Approval

Some Pros
• A systematic approach well suited to
project management techniques
– Each approval can be treated as a ‘work
package’
• Makes approvals easily ‘transportable’
– A system approval for spray suppression
can easily be used on many different whole
vehicle types

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Step by Step Type Approval

Some Cons
• Is comparatively more expensive than
Single Step as each approval generally has
fees for at least a certificate and admin.
– there may also be fees for testing and / or
technical review time
• Each time there is an extension to a lower
level approval (e.g. system approvals –
such as spray suppression) the whole
vehicle approval must be extended
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Single Step Type Approval

• Some use has been made of this in the


past
– mainly by vehicle manufacturers (cars)
– no where near as common as the step by
step process

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Single Step Type Approval

Some Pros
• Is comparatively less expensive than Step
by Step as there is only one approval
– a single certificate fee and an admin fee
– however;
there are also fees for testing / inspection and / or
technical review time

45
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Single Step Type Approval

Some Cons
• The type approval documentation is very
large / ‘heavy’
– can be many, many pages
• It may be harder to manage the overall
project
– everything has to be made ready at once
– there may be difficulty controlling versions

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Single Step Type Approval

Some Cons
• Information is not very ‘portable’
– all approval information is ‘embedded’ in the
Whole Vehicle Type Approval
• e.g. the spray suppression system data would need to
be extracted and recreated in parallel if it is to be
used on many different whole vehicle types

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Mixed Type Approval

• This is all about choice and flexibility


– the applicant chooses which method suits
best, based on
• any particular type of vehicle (or order)
• method of operating manufacturing
• A manufacturer in a multi stage approval
can always opt for the mixed process

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Mixed Type Approval

• Benefit of using the mixed approval


process is that
– Annex III Information Document (the ‘light’
one) is used, and
– Annex III can be augmented with
information from Annex I for the subjects
where there are no separate approvals
• The SENTA documents are easy to use in
any case

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Worked example of ECWVTA for a
Trailer (Category O2 vehicle)

Mike Protheroe
February 2013

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Outline

Walkthrough of the Step by Step process


– using a trailer as an example
• What’s needed?
– a look at the type approval requirements
• How to go about it
– getting a system approval
– putting together the information folder
– types, variants and versions

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Technical Requirements
For ECWVTA and NSSTA the technical requirements cover the following:

• Rear Protection Device


• Registration Plate Space
• Steering Effort
• Braking
• Radio Interference
• Statutory Plates
• Installation of Lighting
• Heating Systems
• Spray Suppression
• Safety Glazing
• Tyres
• Masses and Dimensions
• Couplings
• Transport of Dangerous Goods
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Overall Picture
Whole Vehicle Type Approvals (Framework Directive)

Type = 1 Axle Type = 2 Axle Type = 3 Axle

System Type Approvals (‘Daughter’ directives / regulations)


3. Rear 3. Rear 3. Rear
Protection Protection Protection

4. Rear 4. Rear 4. Rear


number plate number plate number plate

5. Steering 5. Steering 5. Steering


Common system approvals Effort Effort Effort
for types 1 Axle, 2 Axle and
3 Axle
9. Braking 9. Braking 9. Braking
Type = 1 Axle Type = 2 Axle Type = 3 Axle

... ... ...

43. Spray 43. Spray 43. Spray


Suppression Suppression Suppression

... ... ...

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Getting Systems Approvals

1. Understand the legislation


2. Build the product in compliance
3. Ensure Conformity of Production (CoP)
systems in place
4. Prepare Information folder
5. Submit for type approval testing
6. Receive Type Approval certificate
7. Continue to build in compliance
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Legislation

Sources
• Legislation is available
– free of charge (help yourself online)
– on a subscription basis (pay someone to
find it and keep track of it for you)
• VCA has subscription based systems
which can help
• There are also other providers

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Building Products in Compliance

• OK - you’ve got access to legislation


– READ IT
– UNDERSTAND THE REQUIREMENTS
– If in doubt ask!

• Build your product to meet the requirements

• Ensure adequate quality management


systems are in place to ensure CoP
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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
outlined in their type approval
documentation
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Information Folder

• 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
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System Approval Example
Spray Suppression
Spray Suppression is mandatory for O1 and O2 category trailers;
Regulation (EU) 109/2010
However they are exempt from having to fit a spray suppression
device (e.g. matting)

Requirements
Mudguard
Valances
Rain Flaps
Air/Water Separator (matting)

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System Approval Example
Spray Suppression
• Spray suppression has a wide definition
“type”
From Article 2 of Regulation EU 109/2010;
(17) ‘vehicle type with regard to spray suppression’ means
complete, incomplete or completed vehicles, which do not differ
with respect to the following aspects:
— type of spray suppression device installed on the vehicle,
— manufacturer’s spray suppression system type designation.

• One system approval can cover a range of


vehicles

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System Approval Example
Spray Suppression
Some requirements extracted from Regulation EU
109/2010;
1.0 Category N and O vehicles, … shall be
constructed and/or fitted with spray suppression
systems …

6.3.4. The rain flap must not be more than 300 mm
from the rearmost edge of the tyre, measured
horizontally.

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System Approval Example
Spray Suppression
Figure 4 - Diagram showing assembly of a
spray-suppression system
(mudguard, rain flap, outer valance)
incorporating spray-suppression devices
(energy absorbers)

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Spray Suppression Information
Document
Information document no … relating to EC type-
approval of a vehicle with regard to its spray-
suppression systems (*)
0.1. Make (trade name of manufacturer):
Paragon
0.2. Type:
X Axle (X = 1, 2 or 3)
0.2.1. Commercial name(s) (if available):
Paragon Transporter or ParaTran

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Spray Suppression Information
Document
0.3. Means of identification of type, if marked on
the vehicle (b)
Not applicable
0.3.1. Location of that marking:
Not applicable
0.4. Category of vehicle (c):
O2
0.5. Name and address of manufacturer:
Paragon Ltd, [HQ Address]
0.8. Address(es) of assembly plant(s):
1) Paragon Ltd, [Plant Address]
2) Para Build Ltd, [Plant Address]

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Spray Suppression Information
Document
1. GENERAL CONSTRUCTION
CHARACTERISTICS OF THE VEHICLE
1.1. Photographs and/or drawings of a
representative vehicle:
See attachment 1
1.3. Number of axles and wheels:
1 axle, 2 wheels OR 2 axles, 4 wheels OR
3 axles, 6 wheels
1.3.1. Number and position of axles with twin
wheels:
None
1.3.2. Number and position of steered axles
None 65
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Spray Suppression Information
Document
2. MASSES AND DIMENSIONS (f) (g)(in kg and mm)
(Refer to drawing where applicable)
2.1. Wheelbase(s) (fully loaded) (g) (l):
See attachment 1
2.6.Mass in running order (maximum and minimum for
each variant)
Mass of the vehicle with bodywork and, … in running
order, or mass of the chassis or chassis with cab,
without bodywork and/or coupling device if the
manufacturer does not fit the bodywork and/or coupling
device (including liquids, tools, spare wheel, if fitted,
and driver … (h) (maximum and minimum for each
variant):
See attachment 1

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Spray Suppression Information
Document

2.6.1.Distribution of this mass among the axles and,


in the case of a semi-trailer or centre-axle trailer,
load on the coupling point (maximum and
minimum for each variant):
See attachment 1
2.8.Technically permissible maximum laden mass
stated by the manufacturer (i) (3):
See attachment 1

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Spray Suppression Information
Document
9. BODYWORK
9.20. Spray-suppression system
9.20.0. Presence: yes /XXXXXXXX
no / incomplete (1)
9.20.1. Brief description of the vehicle with regard to its
spray-suppression system and the constituent
components:
Mudwing with incorporated valance and mudflaps
behind rear wheels
9.20.2. Detailed drawings of the spray-suppression system
and its position on the vehicle showing the dimensions
specified in the Figures in Annex VI to Directive
91/226/EEC and taking account of the extremes of
tyre/wheel combinations:
See Attachment 2
9.20.3. Approval number(s) of spray-suppression device(s), if
available: Not applicable 68
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Spray Suppression Information
Document
Attachment 1 (General Information)
• Here you would include the relevant information
referred to earlier
• It is free form, you can use the most appropriate
method to convey your information; e.g.
– photographs, drawings
– lists, tables, etc.
• Include the headings again (or at least the heading
number)
1.1. Photographs and/or drawings of a
representative vehicle:
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Spray Suppression Information
Document
Attachment 2 (Specific Information)
• Include here the detailed information about
the spray suppression equipment itself
• Free form, use the most appropriate
method to convey your information; e.g.
– photographs, drawings
• dimensions (specify min – max range and tolerance)
– lists, tables, etc.
– part numbers & suppliers
– alternatives
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EC Whole Vehicle Type Approval
Example;
Type = 2 Axle
Step by Step method
• Gather all necessary system approvals
– 3. Rear protection
– 4. Rear Registration Plate Space
– 9. Braking
– …
– 43. Spray Suppression
– … etc.

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EC / NSSTA Whole Vehicle Type Approval
Example;
N3 Skiploader

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N3 Skiploader

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Skip Loader NSSTA – What needs testing ?
! Installation check only ! Means check the installation of approved components Masses and
dimensions
! Inspection only !

Rear registration
plate space
! Inspection only !

EMC
Lighting Installation ! Declaration only !
! Installation check only !

Rear-underrun device
! Installation check only !

Spray Suppression Side guards Statutory plates


! Installation check only !
! Inspection only ! 74
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! Installation check only !
The Administration of WVTA

Trade Bodies

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Types, Variants and Versions (TVV)

What is a Type – Variant – Version?


• vehicles, which do not differ in at least
the following essential respects

Types
• Manufacturer
Variants
• Designation • Extent of build
Versions
• Category • Structural concept
• Power plant differences • As base
• Number of Axles
• GVM vehicle
• Fundamental Design
• Powered axles
• Steered axles
• Power plant concept

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TVV Matrix
• Covering the range: Type Variant Version (N/a)

No. & arrangement of cyl

Max laden mass (20& diff)


Power plant principle

Capacity (50% diff)


Power (50% diff)
Type , Variants & Versions

Powered axles
Extent of build

Steered axles
Base vehicle
Master matrix

Construction

Power Plant
No. of axles

Bodywork
Category
Body Builder example
Feb-11

2 axle 2A
N3 N3
C section C
Combustion C
Scania type 1 S1
Scania type 2 S2
Renault type 1 R1
Daf type 1 D1
Daf type 2 D2
MAN type 1 M1
Volvo type 1 V1
Volvotype 2 V2
Completed C
Incomplete I
Diesel D
4 cyl 04
5 cyl 05
6 cyl 06
V8 cyl 08
V12 cyl 12
180 - 270 A
270 - 400 B
400 - 600 C
600 - 900 D
4 - 6 litre S
6 - 9 litre M
9 - 13.5 litre L
13.5 - 20 litre E
3500-4200 M
4200 - 5000 N
5000 - 6000 O
6000 - 7000 P
7000 - 8000 Q
8000 - 9000 R
9000 - 10000 S
10000 - 12000 T
12000 - 14000 U
14001 - 16000 V
16001 - 19200 W
19200 - 23000 X
23000 - 27000 Y
27000 - 32000 Z
4 x 2 42
4 x 4 44
6 x 2 62
6 x 4 64
6 x 6 66
8 x 2 82
8 x 4 84
8 x 6 86
8 x 8 88
front steer FS
front and mid steer FM
front and rear steer FR
GRP Box GB
Curtainside CS
Flatbed FB
Refridgerated RF
Crane CR
etc.

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TVV Matrix for a Skip Loader

So the TVV Code for this skip loader is


“DLF2AN3 / AW / as base”
78
www.dft.gov.uk/vca
Whole Vehicle Type Approval Costs,
the factors …
• Passing and failing, don’t assume!
– more tests or inspections = more money!

• The complication factors – consolidate options that


affect approval

• Adopting early means less panic and more


knowledge of the process

• Maximise the multi-stage process to your benefit


– e.g. outsource to others if your approval doesn’t
cover it

79
www.dft.gov.uk/vca
Demand for VCA Services
– N1 (Light Vans & Trucks)
• Lots of interest but slow placing orders
– Now’s the last minute rush!
– SENTA helps make a good job of applications
• Multi-Stage Approval process
– Lengthy delay getting “Letter of Association”
from 1st stage manufacturers
• Panel Vans; “Equip for Service”
– Enhancement Scheme

www.dft.gov.uk/vca
Some Issues Encountered

Simple stuff seems so easy to get wrong!


• Number plate space
– wrong side, proprietary holder wrong size
• Lamps
– additional lamps (not permitted)
– wrong sort, wrong orientation,
– obscured…

81
www.dft.gov.uk/vca
Some Issues Encountered

• Got CoP, didn’t realise that they needed


– documents
– tests
– inspections, etc.
• Component Approvals
– E / e marks needed
– not just any mark!

82
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!

83
www.dft.gov.uk/vca
And 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

84
www.dft.gov.uk/vca
And after that?

Maintain your approval!!!!


Changes to your specification
Additions to your specification
Changes to base vehicle
Changes to legislation

85
www.dft.gov.uk/vca
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

86
www.dft.gov.uk/vca
So what does it all mean?

• 1st type  £3,000 - £5,000 (approx)

• Subsequent types with same body


from £500
– (e.g. on an alternative chassis)

87
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

88
www.dft.gov.uk/vca
Questions?

Thanks for listening!

89
www.dft.gov.uk/vca
Individual Vehicle Approval (IVA)
Gary Race,
Process Manager - Light Vehicles
& Approvals, VOSA

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
Click to edit Master title style

Individual Vehicle Approval


(IVA)

Vehicle and Operator Services Agency


Swansea
Click to edit Master title style
Your options

• EC Whole Vehicle Type Approval - ECWVTA


• National Small Series Type Approval - NSSTA
• Individual Vehicle Approval - IVA
Click to edit
What
Master
is IVA?
title style

Individual Vehicle Approval – Your Choice


• Inspection of an individual vehicle to establish
compliance that results in the issue of an
Individual Approval Certificate
• Least Onerous Criteria - Flexibility

• Compliance – Combination of documentary


evidence of EC Directive compliance, declaration
& visual inspection
Click
What to edit
may Master
need title
trailer style
IVA?

• Low volumes or bespoke trailers (Single Stage


Approval) date of manufacture after 29th July
2012

• Low volumes or bespoke trailers (Multi Stage


Approval) date of manufacture after 29th July 2013
Click
Whattomay
editneed
Master
HGVtitle
IVAstyle

• Imported HGVs up to 25 years old

• Low volumes or bespoke HGVs single stage


approval – date of manufacture from 29th
October 2012

• Low volumes or bespoke HGVs multi stage


approval – date of manufacture from 29th October
2014
Click What’s
to edit the
Master title style
process?

• 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


Click to edit Master title style
Who can apply?

• 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
Click to edit Master
Complete title style
an application

• Web -https://www.gov.uk/vehicle-
approval
IVA 1H - category N2 and N3 (Heavy goods)

IVA 1T – category O3 and O4 (Large Trailer)


(also includes Consent to Supply)

• with guidance notes


ClickThe
to edit
info.Master
neededtitle style

General info. eg
• Applicant details
• Appointment and payment details

Vehicle/Trailer Details eg.


• What type of body is fitted ?
• Fuel Type / Engine number ?
ClickMore
to edit Master title style
info.

Annual Test Information (Plating)

• Brakes, Tyres and Suspension


• Type of braking system
• Axles with “Park” brake
• Dimensions
• Overall Length / Overall width
• Weights
Click to edit Master title style
Compliance info.

• 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 ?
Directive compliance – HGV
Click to edit
th
Master title style
From DOM 29 April 2009
- Noise
- Emissions
- Fuel Tanks
- Rear Protective Device
- Steering Effort
- Braking
- EMC
- Anti Theft (if fitted)
Click to edit Master title style
Directive Requirements pre 29/04/2009
HGV

• Age related standards equating to NTA


requirements Eg. 2002 vehicle,
• Noise
• Emissions
• Braking
• EMC (spark Ignition only)
Visual Checks
Click to Seat
edit Master title style
Belts/Anchorages

Defrost / Demist
Dimensions
Mirrors
Reg. Plate
Glass
Space

Couplings Wash Wipe


Controls
Lights / Reflectors
Headlamps

Statutory Horn
Plates
Exterior
Spray Projections
Suppression Tyres
Towing Hooks
Lateral Protection Speed
Limiter
Click tocompliance
Directive edit Master- title style
Trailer

- Rear Protection Device


- Steering Effort
- Braking
Click to editChecks
Visual Master title style

Dimensions

Statutory Plates

Couplings
Lights / Reflectors
Reg. Plate Space

Lateral Protection Tyres

Spray Suppression
Click
Howtotoedit
prove
Master
compliance
title style

• 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)
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.
Basic
Click to process (trailer
edit Master model
title style
report)
Manufacturer
• considers worst case scenarios
• builds trailer, uses axles and ABS/EBS
system having approval to ECE Regulations.

• supplies Technical Service with trailer and all


relative information
Info to
Click tothe
editTechnical Service
Master title style

• 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
What
Click the
to edit
Technical
Master
Services
title style
do….

• Technical Service
- carries out tests including response time and
energy consumption
- verifies compatibility, proforma specification
against trailer and calculations (References to
R13).
- sends complete package direct to VOSA
Swansea.
• VOSA - receives and collates data and creates
a version 1 (draft) Model Report.
Click to edit Master title style
Apply to Swansea

• Application form IVA1 T / IVA1H

• Evidence of compliance for the items


requiring documentary evidence

• Fee
Click toThe
editcosts
Master title style

• Statutory Fee (pre funded account available)

• Goods (N2 / N3) £230 £46


• Trailer (O3 / O4) £145 £29

• Technical Service
• Information
• Logistical
VOSA
Click testMaster
to edit sites title style

• For heavy vehicles/trailers, 5 VOSA sites –


potential of private sites
• Edinburgh (Livingston)
• Manchester (Chadderton)
• Derby
• Avonmouth
• Gillingham
Click to edit
VOSA testMaster
at your title style
site ?

• Privately Owned Test Facility (POTF)

• Manufacturer, Importer, Distributor, etc. owned


facility

• Inspections conducted by VOSA or VCA

• Site requirements depending on your needs


Click to edit Master title style
POTF site requirements

• Building
• Suitable size/specification
• Communication system / office
accommodation
• Underside inspection facility
• Headlamp test equipment
Click
POTF tosite
editrequirements
Master title ctd.
style

• Outdoor area (potential requirements)


• Turning Circle Area
• Noise Test Area
• Mirror Test Area
Click Approx
to edit Master title style
test times

• IVA Inspection time (approx)


HGV ….2.5 hrs.
Trailer…1.5 hrs.
Click toInspection
edit Master title style
criteria
Click
If ittopasses
edit Master
(or not)
title style

• Individual Approval Certificate (IAC)

• Notification of Refusal – 6 months to apply


for re–inspection.

• Plate / Plating Certificate Issued

• Consent to Supply (trailer only)


Click
Health
to edit
Warning
Master
!!! title style

• Consider how approval will impact


your business

• Communicate

• Start the preparation

• Try it out
Click
Need
to edit
moreMaster
info. title style

• Web - https://www.gov.uk/vehicle-approval

• e mail – approvals@vosa.gov.uk

• Phone – 0300 123 9000


And
Click to finally ……….
edit Master title style

Any Questions...............

................. Sorry too late !


Click to edit Master title style

Trailer Entry into Service


Consent to Supply

Vehicle and Operator Services Agency


Swansea
Click
What isto
it?edit Master title style
The requirement

• for anyone supplying a new trailer to obtain


permission to put that trailer into service from
the Secretary of State (SoS).
• SoS to keep a record of trailers put into service

• to have an approval
Click to edit Master title style
The regulations

Road Vehicles (Approval) Regulations 2009

• Reg. 7, Consent to supply of “large trailers” for


use on a road

• Reg. 8, Records of large trailers


Click to edit Master title style
“Large Trailers”
• Large Trailer, means a trailer constructed or
adapted for the carriage of goods and which is:-

• a semi trailer of any weight

• a trailer other than a semi trailer the unladen


weight of which exceeds 1020 kgs.
• which is not listed in schedule 2 of the “Plating and Testing” regs.
Click to edit Master title style
Consent required - single stage;

• 29th October 2012 for a “single stage


build/approval” – a trailer approved in a single
stage

• in general terms, built to completion in respect of


chassis and body by a single manufacturer
Click to edit Master title style
Consent required - multi stage;

• 29th October 2013 for a “multi stage build” – a


trailer approved in more than one stage

• in general terms, those where the chassis


manufacturer and body manufacturer are different
and each plays a part in the approval of the trailer
ClickNeed an Master
to edit Approval ? style
title

• for a “single stage” (consent from 29th October


2012) – a form of approval if built after 29th July 2012
• (built before 30th July consent without approval)

• for a “multi stage” (consent from 29th October 2013)


– a form of approval if built after 29th July 2013
• (built before 30th July consent with a form of
incomplete approval)
Click to edit
Correct Master
approval title style
level

• Single Stage - “Complete” approval

• Multi Stage – “Completed” approval

“Incomplete” - NOT ACCEPTABLE


Click to edit Master title style
Who’s responsible for applying
• The Final Supplier – person who carries on a
business of supplying trailers to end users

• manufacturer, distributor / dealer / body manufacturer


• notify his intention
• provide information
• obtain consent to supply for use.
Click
The to edit Master title style
process

• Obtain form / guidance from Internet “TES 1”

• Submitted application to VOSA Swansea


• Application / evidence compliance check

• VOSA record mandatory data – Issue Ministry ID


• Consent Letter and Plating Docs Issued.
• No Inspection – no station involvement – No Fee
Click to edit Master title style
And after consent,
• Consent issued, trailer with approval
• data all available on application to create record
• no standards list needed
• record confirmed and plates Issued
• annual test only

• data not all available – record remains provisional


• plates not issued
• first test required
Click to edit Master title style

• Consent issued, trailer with no approval

• standards list needed (12 months on)


• no plates to be issued
• first test (after 12 months)
Click to edit Master title style

and if I don’t have a consent ?

Offence to
• supply (also to supply without approval)
• use
• cause or permits to be used
Click to edit Master title style

Any Questions ?
The SMMT
Tim Hughes.
Membership Account Manager,
SMMT

www.dft.gov.uk/vca
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
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.

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE


139
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 Technical Groups


Aftermarket Digital Radio Vehicle Legislation:
Automotive Components Economics Animal Transport
Bus and Coach Education and Development ATP
Car Engineering Dangerous Goods (ADR)
Commercial Vehicle Group Environmental Policy Load Restraints
Design Engineering Group International business group Road Tank
Electric Vehicle Group Legal Side Guards
Engines E-business and Logistics Forum Rear Under-run
Light Trailer and Trailer Equip MVRIS Management Brakes
Policy Co-ordination Swop Bodies
Public Affairs Committee TIR
Customer Service (Motor Trailer & Bodywork
Codes) Spray Suppression
Technology Lighting and signalling
Vehicle Warranty Products Passive safety
(Motor Codes) Type approval

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE


140
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 organisations.
• Providing technical and market information and business statistics.
• Consulting and informing its members on legislative developments.

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE


141
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 official 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 of
motor vehicle and trailer manufacture.

Main activities:
• Representing members’ interests to the UK government and other
relevant organisations.
• Providing technical and market information and business statistics.
• Consulting and informing its members on legislative developments.
• Representing members’ interests to the relevant EC and ECE Technical
Committees.

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE


142
Public Policy and Vehicle Legislation services
SMMT’s Public Policy and Vehicle Legislation department provides up-to-date
information and expert analysis on a wide range of policy, economic,
environmental and vehicle legislative issues affecting the UK motor industry and
comprises of four teams:
Economics Team
Environment Team
Policy Team
Vehicle Legislation Team
Responsibilities:
• Engagement with decision makers at UK and EU level and representing the
industry in Westminster, Whitehall and Brussels.
• Develop effective working relations with ministers, Members of Parliament and
officials with an interest in the automotive industry in Whitehall and Brussels.
• Organise regular events around political party conferences and for the All-Party
Parliamentary Motor Group.
• Brief parliamentarians and leading officials organised across the main
government departments.

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED PAGE


143
Click to edit Master title style

Lunch

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
Click to edit Master title style

SMMT Type Approval Workshop


Welcome back

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
What's it like to obtain an approval
Neil Loy, Homologation.
Mercedes-Benz Trucks

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
SMMT Seminar

Neil Loy Mercedes Benz Sales Engineering/Homologation


February 2013
Starting the Process
•Some standard of Conformity of Production will be required for series approval

•If you have an ISO Certificate to UKAS (United Kingdom Accreditation Standard)
or recognised equivalent you may not need an Audit

•No ISO, but have some COP recognition, or system for Conformity, an inspection by
the VCA
Auditors will be required, cost £712 per day

•Clearance of COP will be essential to be able to apply for any Job numbers,
Systems testing, or the 2nd and further Stage Approval Inspections

•A production plan will be required

transition_MB_presentation-slides_EN.pot Title of presentation, CorpoS, (9Pt.), Date Slide 148


Step by Step Process

transition_MB_presentation-slides_EN.pot Title of presentation, CorpoS, (9Pt.), Date Slide 149


Letter of Association
– [NAME]
– [ADDRESS]
– [ADDRESS]
– [ADDRESS]
– [ADDRESS]
– [ADDRESS]
– Our ref: [if applicable]
– Your ref: [If applicable]
– [25 October 2012]
– Dear Mr [NAME]
– Letter of Association with [A N Other Limited]
– This letter of association confirms that A N Other Limited (“the Body Builder”) is in dialogue with Mercedes
Benz UK Limited (“MBUK”) in respect of the matters set out below.
– By way of a licensed contract between Daimler AG and the Body Builder for the purpose of Whole Vehicle Type
Approval of multi stage build vehicles, the Body Builder has access only rights to Daimler AG and MBUK’s type
approval documentation through a portal known as CERON. Access to CERON is only provided once the Body
Builder is registered on the Daimler AG Body Builder Portal. The Body Builder must comply with the Body
Builder guidelines set out in the Daimler AG Body Builder Portal.
– The Body Builder also has access only rights to system approvals held by the Department for Transport and
their agencies for the purpose of type approval matters.
– By granting access to the above systems, Daimler AG and MBUK do not accept liability for any modifications
carried out by a Body Builder or other third party.
– Yours sincerely
– Neil Loy
– Homologation Engineer
– Mercedes Benz UK Limited

transition_MB_presentation-slides_EN.pot Title of presentation, CorpoS, (9Pt.), Date Slide 150


Chose your preferred route
IVA or Series Approval

•IVA, is costly compared with a Series approval NSSTA/ECWVTA

•Bespoke ?

•Type, Variant, Version

•IVA, £230 + Transport, Labour, Fuel, Systems testing etc, Advantage no COP
Still only 5 sites designated in the UK for N2/N3,
Glasgow (Edinburgh), Manchester, Derby, Gillingham and Bristol

•NSSTA, £3500 + Systems testing, one inspection,


500 vehicles N1 per year, 250 vehicles N2/N3, UK only, less onerous 40
systems approvals, little advantage over ECWVTA

•ECWVTA, £3500 + Systems testing, one inspection, unlimited numbers,


Europe wide, 61 systems approvals

transition_MB_presentation-slides_EN.pot Title of presentation, CorpoS, (9Pt.), Date Slide 151


IVA Statements VIN Specific

transition_MB_presentation-slides_EN.pot Title of presentation, CorpoS, (9Pt.), Date Slide 152


2nd Stage VIN Plate

2nd Stage VIN Plate


Mercedes – Benz e11*2007/46*????
WDF63960123000001
Stage 2
GVW – 3050kg
GTW – 4940kg
1 – 1550kg
2 – 1550kg
Dimensions of the official part of the factory plate
Height 61 mm
Width 82 mm
Height of vehicle identification number 4 mm

transition_MB_presentation-slides_EN.pot Title of presentation, CorpoS, (9Pt.), Date Slide 153


Ability to print Certificate of Conformity

transition_MB_presentation-slides_EN.pot Title of presentation, CorpoS, (9Pt.), Date Slide 154


Step by Step Process

•COP Application and Clearance granted (currently 3 months)

•Meet Manufacturers requirements to issue Letter of Association

•Apply for Job numbers

•Approval Information from the Manufacturer may be required

•New Systems approvals applied for and cleared

•Inspection arranged/cleared

•WVTA approval granted

•COC created

•Vehicle Registered

transition_MB_presentation-slides_EN.pot Title of presentation, CorpoS, (9Pt.), Date Slide 155


Conformity of Production (COP)
Mike Protheroe - VCA

SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
Conformity of Production (CoP)
Agenda:
What is COP?
Vehicle Categories
Legislation
Who Needs COP and what does it affect?
What do I need to do?
Control Plans and Change Control
Initial Assessments
Submit Documentation and request Audit
Costs of Type Approval and COP
Contact:
Angie.Bissett@vca.gov.uk
VCA COP Technical Manager EU Op’s 157
www.dft.gov.uk/vca
What is Conformity of Production?

Once a product has been ‘Type Approved’ the


customer has to demonstrate the ability to
produce a series of these products which
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?

158
www.dft.gov.uk/vca
What is Conformity of Production?

Company must demonstrate that they have a


system in place so that production conforms
to the requirements:
This system needs to be in place before COP
can be granted
This can be a formal accredited ISO
9001:2008 or TS16949 certified system
(UKAS or equivalent certified body)

159
www.dft.gov.uk/vca
What is Conformity of Production?

Or a non-accredited system that will then


require a COP audit

Quality manual, Document control, Storage


and retention of Records, Change control,
Control plans etc.

160
www.dft.gov.uk/vca
What is Conformity of Production?
• Type Approval is granted to a product that
meets a minimum set of regulatory, technical
and safety requirements.

161
www.dft.gov.uk/vca
Type Approval and CoP cover:-
Passenger vehicles

M1

M2

M3 162
www.dft.gov.uk/vca
Goods Vehicles (N)

N1
N2

N3 163
www.dft.gov.uk/vca
Trailers (O)
O1
O2

O3 O4
164
www.dft.gov.uk/vca
Motorcycles and Tractors (L/T)

165
www.dft.gov.uk/vca
Components

Plus many more


166
www.dft.gov.uk/vca
Multi stage builds

• Second stage not responsible for base


vehicle, only the components or systems
added by the second stage
– Close tie’s required (Example; Letter of
association)
– Base builder may change something that could
affect 2nd stage approval, without this tie up 2nd
stage approval may become invalid.
– Example, change of load rating on tyres

167
www.dft.gov.uk/vca
CoP and Multi Stage Build
One manufacturer builds a base vehicle, another manufacturer(s)
finishes it off.
Stage 1 Build – Chassis Cab
Manufacturer responsible for this stage only

168
www.dft.gov.uk/vca
Multi Stage Build
Second stage – New manufacturer adds axle and body.
Second stage manufacturer only responsible for their additions and if
they make or affect any changes to first stage

Additional body

New mirrors
New tyre
Additional axle 169
www.dft.gov.uk/vca
What legislation applies?

• For the European Union (EEC


Directives/European Regulations)
• Legislation negotiated and agreed in
Brussels
• For ECE Regulations we get our legislation
negotiated and agreed in Geneva
• Worth noting that the Regulations &
Directives are usually similar but not always
in sync

170
www.dft.gov.uk/vca
Legislation and CoP
Some regulations have specific requirements
Test frequencies
Sampling regimes
Pass/Fail criteria

Some are general:


“Measures to ensure the conformity of production shall
be taken in accordance with the provisions laid down
in Article 10 of Directive 2007/46/EEC.”

171
www.dft.gov.uk/vca
Legislative references
• We can go to the UNECE or EEC web sites
and trawl through all the info.
or
• We can use one of VCA best tool’s VISTA

172
www.dft.gov.uk/vca
Who needs CoP Clearance?

Any Manufacturer that requires a Type Approval


Certificate requires COP
To gain Type Approval, any manufacturer of the
vehicles and components covered must have
achieved CoP clearance first.
The approval holder (type approval) is responsible for
the CoP for the production life of the
vehicle/system/component

173
www.dft.gov.uk/vca
Who needs CoP Clearance?

The approval holder is still responsible for the


conformity of the product even if they sub
contract the manufacturing/assembly to a
third party
In this instance the manufacturing plant would
also require CoP

174
www.dft.gov.uk/vca
CoP – What does it affect?

• CoP is only concerned with those aspects of a


vehicle that are Type Approved
• Examples; Change to the loading conditions
May affect;
• Brakes, Tyres, Masses and Dimensions…..
• Change to the colour of a vehicle may affect,
Basically nothing
• If you add another subject, you need to
consider the CoP implications

175
www.dft.gov.uk/vca
What do I need to do?

• A Quality System

176
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What do I need to do?

• The quality system:


– Formal quality system ISO9001/TS16949 +
Control plans + Access to legislation
– However, formal certified quality system not
mandatory, therefore:
– Quality documentation (manual) + Detailed
control plans + Access to legislation + On-site
assessment (COP audit)

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Quality Documentation

– Quality Manual or documents used to


ensure product consistency should contain, but
not be limited to at least the following:
– Approved suppliers
– How does the company select and monitor
suppliers?
– Incoming goods
– How does the company ensure supplied goods
conform?

178
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Quality Documentation

• Non-conforming goods
• How does the company ensure that goods
purchased or manufactured that do not conform
are not used for production?
• Staff training/Competence
• How does the company ensure staff are properly
trained? How is this recorded?
• Calibration
• How does the company ensure that all relevant
equipment is calibrated?
179
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Quality Documentation

Incoming goods and storage


How does the company ensure supplied goods
conform?

180
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Quality Documentation

• Document Control and Records


• How do you ensure that everyone has
access to the latest documents/drawings
• How are the records held and for how
long?
• Final Inspection
• How does the company ensure that the product or
vehicle conforms
• Tied in with Control Plans?
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Quality Documentation
Change Control

• For Type Approval and CoP this is one of the most important
aspects of the approval
• Change to product may change validity of the approval
• Type Approvals can be extended to accommodate changeHow
does the company ensure that any changes to the design or
performance of the product which might affect the validity of
the Approval is notified to the authority?

182
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Quality Documentation

• How is this managed?


• This is a minimum list, quality documentation
should be sufficient for the product and have
continual improvement in mind

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For Initial Assessment (New Customer)
• Manufacturer with recognised (IAF/IATF)
certified quality system (ISO9001/TS16949),
then initial CoP audit not mandatory

• Documentation to be supplied
• Detailed control plans
• Copy of accredited ISO certificate (scope to be
appropriate for the product)
• Copy of quality manual may be requested by the
approval authority

184
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Initial Assessment Continued

• Manufacturer with no accredited certified


quality system or ISO - CoP audit
mandatory
• Audit based on standard quality
principles and regulatory requirements
• Documentation required
• Copy of quality manual or quality documents
• Detailed control plans

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CoP Audit for Non ISO
• CoP audit based on:-
Quality Manual
Control Plans
Supplier selection
Incoming goods
Non conforming goods
Staff competency
Calibration
Change control
Manufacturing facility

186
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Manufacturing Facility
Real Experience of Bad Practice

Test equipment that does not


work – ever! Bad working conditions

187
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Change Control

• For Type Approval and CoP this is one of the


most important aspects of the approval
• Change to product may change validity of the
approval
• Type Approvals can be extended to
accommodate change

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CoP as Part of ISO - Control Plans

A control plan is a documented


description of the procedures, checks
and activities necessary to verify that the
production unit continues to conform to
the type approval requirements with
regard to specification, marking and
performance

189
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CoP Specific - Control Plans

• No specific design mandated,


manufacturer can choose.

• Testing is not always mandatory

• Control plan should demonstrate how


the manufacturer ensures compliance

• Control plans must be compared against


the specific regulatory requirements
190
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Control Plans – Example: Vehicle
Manufacturer
Legislation CoP Requirements
DIR REG Insp Freq Control
Subject Type Doc
Speedo - 39 1 1/ Year IVXX5
4 100%

Key
Inspection Type 1 Vehicle test (Reg)
Inspection Type 2 Visual/Dimensional verification
Inspection Type 3 Record details build log
Inspection Type 4 Functional check
Inspection Type 5 Supplier CoP

191
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Control Documents

Control Description Sheet - IVXX5


Speedo
Procedure Description Inspection Responsibility Record
Type
SP1 Regulation 1 Homologation/ CoP
Check Legislation Record
SP1 Functional 4 Quality dept Build log
check

192
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Control Documents
Procedure SP/SF1

Regulation Ensure vehicle is prepared in accordance with


check regulatory requirements
Run vehicle on rolling road at indicated 40kmh, 80kmh,
120kmh ensure speedometer relationship is as follows
0 < (V1 – V2) < 0.1 V2 + 6 km/h; (V1 Display speed;
V2 actual speed)
Functional Run vehicle on rolling road at indicated 50kmh 120kmh
check on rolling road ensure speedometer reads +0 -5% of
true speed

?????? ??????????
193
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So again; Vista is the key –

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Surveillance
CoP for Non ISO
– Frequency in line with risk based result
– Reduced audit dependant on previous findings
– Review control plan results
– Witness CoP test if required (not normal practice)
COP for ISO
Frequency of audit determined by Regulation or
Directive and Technical review

195
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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 Technical Review
for an ISO company
• Non-ISO company £962 = 1 day audit and
Technical clearance + travel costs
• Non-ISO company £1674 2 day audit and
Technical Clearance + travel / £1,785 max (in the
UK)
• Whole Vehicle Cert fee £75
• Whole Vehicle Admin fee £73
• Technical fee £89 per hour 196
www.dft.gov.uk/vca
So what does it all mean?

• 1st type  £3,000 - £5,000 (approx)

• Subsequent types with same body


from £500
– (e.g. on an alternative chassis)

197
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Questions
Thank you for listening

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SENTA
Tony Hopkins.
Technical Manager,
SMMT

www.dft.gov.uk/vca
SOCIETY OF MOTOR MANUFACTURERS AND TRADERS LIMITED SMMT, the ‘S’ symbol and the ‘Driving the motor
industry’ brandline are trademarks of SMMT Ltd
SENTA

SMMT European and National


Type Approval

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SENTA - SMMT European and National Type
Approval guide

A step-by-step web-based programme to guide vehicle


manufacturers, bodybuilders and suppliers through the
complicated European Community Whole Vehicle Type Approval
system. It also allows for national approval schemes for low
volume manufacturers.

For a new approval application, SENTA will ease the lengthy


documentary process.

SENTA details what a manufacturer must do from the original


design idea, through the development and construction stages to
completion of the approval process.

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SENTA - SMMT European and National Type
Approval guide

The guide helps in three specific areas.

A methodical guide through the paperwork process from start to


finish based on the specific requirements.

For multi-stage and single stage builds, the system creates the
relevant documents for the approval route required.

Help information and worked examples for each section of the


guide.

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Opening page

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203
First Page

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204
Section 1 – Start of page

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205
Section 1 – Page continuation

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206
Section 1 – End of page

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207
Section 2 – Start of page

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208
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.

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Section 9

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Section 9 - Continued

Future legislation

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ANNEX I - Information Document

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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

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ANNEX I – Information Document

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ANNEX I – Information Document

The Annex 1 document produced will also require the


following to be added as part of the package to be
submitted to the approval authority:

•Technical file covering any Appendices mentioned

•Type, Variant & Version Chart (TVV)

•Declaration of access to RMI information

•Index

•Revision log

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Section 11 - General Type Approval Reference
documents

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216
Section 12 – Component information documents

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Component approval information document - Example
Opening page - Scope

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Component approval information document
Cover page

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219
Component approval information document
Information document pt 1

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220
Component approval information document
Information document pt 2

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221
Component approval information document
Information document pt 3

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222
Component approval information document
Information document pt 4

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223
Section 13 – Types, Variants & Versions (TVV)

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224
Section 15 – Certificates of Conformity

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Side 1 of the Certificate of Conformity

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
on (…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.

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Take a Tour guideline information

The Tour is a snapshot of what is contained in the SENTA Guide


which is written to cover all categories of 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

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SENTA information and registration

Go to the SMMT website,

www.smmt.co.uk

and click on the SENTA button in


the top right hand corner

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228
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
Thank you for attending
Society of Motor Manufacturers and Traders Ltd
71 Great Peter Street, London, SW1P 2BN
www.smmt.co.uk

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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