European Type Approval Requirements for Multi Stage Built Vehicles Updated
Since its original publication, EC Directive 2007/46/EC on European type approval, also known as the Framework Directive, has always contained specific requirements for vehicles built in multiple stages, e.g. trucks where the chassis cab is produced by one manufacturer and the bodywork is added by a different manufacturer. However, as the vast majority of M1 category vehicles are built in a single stage, experience with the application of these multi stage build requirements has only been gained since mandatory European type approval has been extended to non-M1vehicle categories where multi stage build is far more common.
Initial experience gained in the application of the multi stage build requirements highlighted a number of areas where the existing requirements were deficient and needed revision and clarification. Recognising this issue, the European Commission set up a special sub-group to undertake this activity and, between September 2012 and January 2014, this sub-group met eight times.
The amendments to 2007/46/EC that were developed by this sub-group were published in the Official Journal on 1st November 2014 as EU Regulation No. 1171/2014.
The amendments to 2007/46/EC introduced by (EU) No. 1171/2014 include revisions to the information document formats specified in Annexes I and III, revisions to the type approval certificate format specified in Annex VI and revisions to the Certificate of Conformity formats specified in Annex IX. However, the most significant amendments are those to Annex XVII which specifies the procedures to be followed during multi stage European type approval. The main changes to Annex XVII clarify the application of the multi stage build requirements and can be summarised as follows:
- The multi stage build procedure may be used by a single manufacturer, as long as the manufacturer is not using the procedure to circumvent requirements that would be applicable to the vehicle if it were built in a single stage.
- The legislative requirements applicable to subsequent stages of build should be no more stringent than those that were applicable to the base vehicle, unless the vehicle category is changed as part of subsequent stage build.
- Where a modification to the vehicle has partially invalidated the system type approval for the base vehicle, e.g. invalidating the lighting installation type approval by repositioning the rear lamps, any new type approval tests / inspections shall be limited to the items that have changed.
- Subject to agreement from the Approval Authority, when an extension to the previous stage whole vehicle type approval is issued, it is not necessary to extend the subsequent stage whole vehicle type approval if the changes introduced on the previous stage vehicle type approval do not affect the subsequent stage of vehicle build.
- For N category vehicles (goods vehicles) and O category vehicles (trailers), type approval will not be required for the fitment of removable equipment for the storage and securing of cargo, e.g. load space linings, interior racking, roof racks, etc. Such equipment will be treated as part of the vehicle’s payload providing that the equipment has no effect on the vehicle’s type approval apart from increasing the unladen mass of the vehicle.
Compliance with the new requirements introduced by (EU) No. 1171/2014 becomes mandatory for new types of vehicle from 1st January 2016. However, the requirements may be applied ahead of that date at the manufacturer’s request.
With regard to the revised Certificate of Conformity formats introduced by (EU) No. 1171/2014, all manufacturers must utilise the revised formats for any Certificates of Conformity that they produce from 1st January 2016.