EC Whole Vehicle Type Approval and Light Commercial Vehicle Accessories
What is EC Whole Vehicle Type Approval (ECWVTA)?
ECWVTA is a way of making sure vehicles are safe to use on the road without having to inspect and test every single one. Under the vehicle type approval system, a prototype is tested. If it passes the tests and the production arrangements also pass inspection, then vehicles or components of the same type are approved for production and sale within Europe, without further testing. This is known as Conformity of Production (CoP).
ECWVTA is administered by the Vehicle Certification Agency (VCA).
What is changing and when?
ECWVTA began its phased introduction in April 2009 (for passenger cars), with the rest of the scheme being rolled out over the various other vehicle categories over the 5 years following. The scheme will eventually cover all new vehicles and trailers including special purpose vehicles.
The date that has sparked recent concerns about the scheme and its relevance to our industry is 29th April 2013. After this date, type approval becomes mandatory for all new light commercial vehicles up to 3.5 tonnes. If the vehicle does not have a Certificate of Conformity (CoC) it cannot be registered with DVLA for use on the road.
Who does this affect?
Subject to certain exceptions this directly affects importers, manufacturers and converters (including chassis makers and those who build onto a chassis) of vehicles.
It also indirectly affects dealers, sellers and purchasers of new vehicles.
However, because of the level of testing involved, type approval is really aimed at vehicle manufacturers or their authorised importers.
Once Type Approval has been awarded, the manufacturer will be solely responsible for ensuring CoP remains valid for all vehicles produced under that approval. The manufacturer will then be able to issue a CoC for each vehicle produced of that type.
It is only the vehicle “type” (a representative prototype) that is tested under ECWVTA; not individual vehicles or the accessories that might later be fitted to them. Therefore it is the vehicle manufacturer that is affected. Where the vehicle is converted to a different “type” by a separate company (for example a panel van into a minibus) the convertor will need to apply for Type Approval for the conversion “type”. This does NOT include aftermarket accessories.
Type approval legislation doesn’t cover aftermarket accessories.” – Mohammed Farooq, Legislation Manager, VCA.
A CoC is not required for aftermarket accessories. There is no legal requirement to issue or produce one. It is correct that the vehicle must have a CoC – but as a “whole vehicle”. The individual pieces or components of a vehicle cannot obtain one, only vehicles in their entirety.
In addition, the Society of Motor Manufacturers and Traders has worked with a group of their members, the VCA, VOSA and the DfT to try and reduce the regulatory burden of ECWVTA. The process has achieved a result that will see around 80% of vans sold in the UK avoid the burdensome ECWVTA requirements, with another 15% of the market benefitting from an enhanced process of application and approval of multiple vehicle types.
What if accessories are fitted before registration for the road?
Registration for the road is not the same thing as gaining Type approval. It is a pre-production prototype that is tested by VCA under the ECWVTA scheme – once this test has been carried out on a vehicle “type”; no further testing is required for subsequent production vehicles of the same “type”.
The fitting of accessories does not constitute a change of “type” and therefore is not subject to further testing or approval.
Since pre-registration vehicles will have already been covered by Type Approval inspection and testing back at the manufacturing stage, they do not require any further Type Approval certification, regardless of any accessories fitted before registration.
How does this affect vehicle conversion
This depends on the extent of the modifications carried out.
The fitting of accessories like roof racks and ply lining kits is not covered by ECWVTA legislation and so are not affected, even if the accessories are fitted before registration for the road.
Where the structure of the vehicle is modified, for example by fitting windows or seats; the conversion specialist will have to communicate with the VCA to see if the modifications constitute a change of “type”. If they do, then the conversion specialist will have to apply for Type Approval.