Whilst the UN ECE Regulations that must be complied with to obtain European Whole Vehicle Type Approval (ECWVTA) are specified in Annex IV to 2007/46/EC, as last amended by (EU) No. 2015/758, the precise amendment levels for each of the UN ECE Regulations that apply on a compulsory basis are specified in Annex IV to EC Regulation No. 661/2009, as last amended by (EU) No. 2015/166, concerning "type approval requirements for the general safety of motor vehicles, their trailers and systems, components and separate technical units intended therefor" (often referred to as the General Safety Regulation or GSR). Annex IV to (EC) No. 661/2009 also includes an Appendix which specifies the instances where type approvals to the EC Directives which were repealed by (EC) No. 661/2009 can continue to be used instead of complying with the specified UN ECE Regulations due to the equivalency of their requirements.
Recognising the fact that the referenced UN ECE Regulations are subject to frequent updating and amendment, the European Commission have acknowledged the need to regularly review and update both Annex IV and its Appendix. Therefore, at a meeting of the Technical Committee - Motor Vehicles (TCMV) held on 6th October, 2015, the European Commission submitted a proposal to update Annex IV and its Appendix to reflect the latest status of the referenced UN ECE Regulations.
In addition to amending Annex IV to update the amendment levels of UN ECE Regulation No's 13, 13-H, 14, 16, 95, 100, 107, 110, 118 and 121 to their latest published levels, the proposal also proposes changes to the Appendix to Annex IV relating to the indirect vision requirements applicable to N2 and N3 category vehicles (i.e. heavy trucks) and to the material flammability requirements applicable to M3 category vehicles (i.e. buses and coaches).
Currently, for indirect vision, Annex IV requires compliance with ECE 46.04 and the Appendix to Annex IV permits the continued use of type approvals to EC Directive 2003/97/EC. However, in the case of N2 and N3 category vehicles, the requirements specified by EC Directive 2003/97/EC are not equivalent to those specified by ECE 46.04 because ECE 46.04 requires Class V close proximity mirrors fitted to the passenger side of the vehicle to provide a larger field of vision than is required by EC Directive 2003/97/EC. Therefore, an amendment to the Appendix to Annex IV is proposed to prohibit the use of type approvals to EC Directive 2003/97/EC for N2 and N3 category vehicles.
For material flammability, Annex IV currently requires compliance with ECE 118.00 and the Appendix to Annex IV permits the continued use of type approvals to EC Directive 95/28/EC. The proposed amendment to Annex IV updates ECE Regulation No. 118 to its latest published amendment level (i.e. Supplement 1 to the 02 series of amendments) and both the 01 and 02 series of amendments to ECE Regulation No. 118 introduced requirements that are additional to those contained in EC Directive 95/28/EC (e.g. extension of the requirements to cover materials used in engine compartments, the introduction of requirements on the capability of materials to repel fuel and lubricants, etc.). For this reason, EC Directive 95/28/EC cannot be considered to be equivalent to either ECE 118.01 or ECE 118.02 and, hence, it is proposed to amend the Appendix to Annex IV to prohibit the continued use of type approvals to EC Directive 95/28/EC.
With regard to introduction dates, it is proposed that compliance with the updated requirements on indirect vision and material flammability become mandatory for all vehicles first registered on or after 1st April, 2016.