Type-approval framework directive revision

In this document we want to record all the issues that we think should be considered when revising directive 2007/46/EC. The type-approval framework directive is managed by DG ENTR, unit of Phillipe Jean.

When working on vehicle legislation we constantly notice issues that are 'wrong' with the directive. However this happens bit by bit and over time and we notice different problems with it when working on different laws.

The purpose of this document is to collect all the information in one place, so we can submit relevant proposals the next time this directive is revised.

Issues that need addressing:

• • extended type-approval under EURO 5+6, upper weight limit (#this needs further checking - KM)

  • type-approval of multistage vehicles

  • change the weight specs for the provisions of maximal towing masses (when vhls pull trailers)

Multistage Vehicles (N1):

The lack of available emission data from MSV has proven to be problematic wrt the vans & CO2 legislation.

The assessment of consumption and CO2 from completed multi stage vehicles would require a simulation or a test after completion. 

Real life testing after completion does not happen. Stakeholders argue that it would be too much of a testing burden given that the body builder market is very divers.

There also is currently no indication about simulation approaches.

State of play: chassis are being tested on a dynamometer.

wrt the vans & CO2 legislation: This being the only measured set of values will probably be taken as the bases to assign the emissions of multistage vehicles in the forthcoming vans and CO2 legislation.

Problem: this does not reflect the real emissions, but underestimates them.

A better solution would be to do several test runs for each chassis simulating a range of different reference masses - according to the UK consultation (http://www.dft.gov.uk/consultations/open/2010-19/consultation.pdf), there are seven standard inertia settings that could be applied. This would mean that for each chassis seven test-runs would be undertaken, simulating seven weight classes of bodies to be mounted. (ranging from the reference mass of the chassis to the maximum reference mass covered in the type approval.

When the vehicle is individually type approved after completion, the assessed reference mass of the completed vehicle would then determine which of the seven data sets to apply to it.    

If such an approach will enter into the legislation, it would be important to have as many weight classes as possible. If not, the intervals are to great there will be very few incentive for light weight as the lighter classes are difficult to acheive. 

A remaining issue: what is  the appropriate reference mass value to use for these vehicles. (chassis weight or weight of the completed vhl?) - Problem of unpredictability for manufacturers!