Dr Keith Ellis European Friction Industries Regulation 90 Dr Keith Ellis European Friction Industries
Introduction R90 or Annex 15 to 98/12 R90 Annexes 3 to 7 Testing and COP Packaging Costs Approval routes Mandatory dates and scope Policing
R90 or Annex 15 to 98/12 R90 ECE United Nations - not mandatory Annex 15 of EEC Directive 98/12 - mandatory for under 3.5 tonnes R90/01 accepted for Annex 15 SI 2978 The road vehicles (brake linings safety) regulations 1999
R90/01 - Annexes 3 to 7 Annex 3 M1,M2,N1 Motor vehicles up to 3.5 tonnes Annex 4 M3, N2,N3 Motor vehicles over 3.5 tonnes Annex 5 O1,O2 Trailers up to 3.5 tonnes Annex 6 O3,O4 Trailers over 3.5 tonnes Annex 7 L1,2,3,4,5 Motorcycles
Testing and C.O.P. Annex 3 - vehicle or vehicle and dynamometer Annexes 4 and 6 - vehicle or dynamometer or rolling road Annex 7 - Vehicle only Tests cover OE approval plus additional comparison tests C.O.P. tests are for friction, shear and compression.
Packaging Axle sets, tamper proof Rivets of suitable size and material for drum linings Package to show E mark, manufacturers mark, make and type of pad/lining, approved vehicles, fitting instruction Pad/lining to show E-mark, batch code, make and type of lining
Costs of R90 Annex 3 master £2000 - £4000 Annex 4 master £4000 - £6000 Cost per approval depends on number of references grandfathered per master approval and which approval authority/test authority is used. 300 - 400 car references 100+ CV references
Approval Routes TUV / KBA - E1 VTAC / VCA - E11 TUV / RDW - E4 SPAIN / RDW - E4 Managed approvals by EFI
Dates and scope Annex 3 became mandatory on 1st April 2001 for sale or fitment to all V reg (1st Sept 99) and on vehicles Annexes 4, 6 and 7 recently set aside after industry consultation Possible introduction for CV disc pads only in UK R90/01 mandatory in Spain from Oct 2003 for all vehicles from Oct 2003
Policing In UK by Trading Standards By the industry - report to BFMC OES sales Protecting an investment in excess of £1Million per company