IVECO Proposal for Revised CoP Procedure Regulation 1151/2017 IVECO Proposal for Revised CoP Procedure Brussells November, 21st 2017 Contains confidential proprietary and trade secrets information of CNH Industrial. Any use of this work without express written consent is strictly prohibited.

Requirements in Reg 1151/2017 and Issue Identification Agenda Possible slide subtitle Requirements in Reg 1151/2017 and Issue Identification Commission Regulation (EU) 2017/1151 IP family in T.A. – framework IVECO proposals CoP families definition Proposal Justification Statistical Test Method

Commission Regulation (EU) 2017/1151 Frame - New Interpolation concept Regulation (EU) 2017/1151 – Annex 1, point 4.2.1 «4.2.1. The Type 1 test shall be carried out on production vehicles of a valid member of the CO2 interpolation family as described in the TA certificate. The limit values against which to check conformity for pollutants are set out in Table 2 of Annex I to Regulation (EC) No 715/2007. As regards CO2 emissions, the limit value shall be the value determined by the manufacturer for the selected vehicle in accordance with the interpolation methodology set out in Sub-Annex 7 of Annex XXI. The interpolation calculation shall be verified by the approval authority.» Conformity of Production (CoP) requirement is 100% the «replication» of CO2 Interpolation Family approach applied in T.A. phase: “For Type 1 with a minimum frequency of one verification per 5 000 vehicles produced per family or once per year, whichever comes first.” The higher the «IP family number» is, the higher the number of CoP tests per year will be

Commission Regulation (EU) 2017/1151 Possible CO2 Interpolation Family to be adopted by an LCV OEM Type of internal combustion engine Operation strategy of all CO2 mass emissions Transmission type (e.g. manual, automatic) n / v ratios (8%) Number of powered axles ATCT family (Ambient Temperature Correction Test) Vehicle Class (Class 1, 2 or 3) Other possible characteristics for «tecnical/commercial» reasons This may leads to more than 100 IP Families

IP family in T.A. – COP framework (example) Number of tests considering the application of “minimum” requirements” It’s realistic to have in the homologations more than 100 CO2 Interpolation Families, each one from about 100 up to about 3000 units produced per year Following this example of 100 interpolation families: Huge amount of tests (one verification per year, on a sample of min. three vehicles per family) and considering two production plants > 600 tests as Best Case* > 3500 tests as Worst Case** Mandatory tests on OBD, PHEV vehicles (in case the commercial offer will include electric vehicles) or vehicles equipped with different Internal Combustion Engine (i.e. CNG, LNG) not taken into consideration. Those tests will increase the above numbers. * Decision always taken with the minimum sample size (3 vehicles) ** Decision always taken with the maximus sample size (16 vehicles)

CoP definition in D. 2007/46/EC Conformity of Production (COP) represents an integral part of the approval process. Conformity of production procedures are intended to ensure that each vehicle, system, component and/or technical unit is in conformity with the approved type (Annex X, point 0.1). Focus of «COP arrangements» is to check the «stability of product characteristics making allowance for variation of an industrial production » Monitor the stability of production processes (in each production facility) Assure checks on products in all production phases, from «incoming parts» up to «final products»

Statistical assumptions based on T.A. IP families vs COP The sampling frequency (For Type 1 with a minimum frequency of one verification per 5 000 vehicles produced per family or once per year, whichever comes first) is acceptable and in accordance with the principles of the Quality Management. The IP Family concept, developed for T.A., is “technically” applicable but without any effectiveness in CoP due to the following reasons: CO2 in COP managed as a normalized parameter: (for each vehicle: x=CO2 measured/ CO2 declared) Pollutants have a legal limit, a sample with vehicles coming from different Families is impacting basically on variance but with «zero» effectiveness: to group all or part of IP Families leads to reasonable number of tests without other «undesirable consequences»

COP Family definition (proposal) COP Family = Aggregation of two or more IP Families focusing on parameters that are influencing emissions and relevant on production process in order to assure the «coverage» of different product configurations in sampling procedure Minimum set for COP Family Type of internal combustion engine: unify Engines with same HW and ATS Transmission type Number of power axles Operation strategy of all CO2 mass emissions

Decision Making Models (statistical test) Test procedure Issues found and prioposals Decision Making Models (statistical test)

Statistical method in Reg. 1151/2017 Current version of the test and weaknesses With this method using a sample of only three vehicles you have more than 99% of probability to take a decision with very high risk in both case due to a very thin uncertainty region. Pass/Fail rule in current version of Reg. 1151/2017 Pass/Fail rule in Reg. 83/2015 – NEDC Decision «always» taken with min sample size (three veh.) with big risks (unknown)

COP Pass/Fail statistic (cont.) Test by Attributes derived from ISC procedure PROPOSAL - as proposed for RDE/ISC (Ref. Draft RDE Package 4) but with specific «COP rule» for Outliers identification

COP Pass/Fail statistic (cont.) Ouliers identification - Proposal Tolerances in R1151/2017 are T1=5% for Pollutants and T2=1% for CO2 : note: they’re intended not for a single vehicle but for average sample. It’s acceptable but base on this we propose a tolerance on a single vehicle as follow: L= legal limits for each Pollutant D= 1 (theoretical normalized value for CO2 in T.A.