OICA assessment of the proposed changes to the 58 Agreement 1 Transmitted by OICA Doc.No.IWVTA-SG58-07-11.

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Presentation transcript:

OICA assessment of the proposed changes to the 58 Agreement 1 Transmitted by OICA Doc.No.IWVTA-SG

Table of contents  Article 1 - IWVTA  Article 1 - Information documents  Article 2 - Quality of approvals  Article 3 - Mutual Recognition  Article 5 - DETA and Unique Identifier  Article 12 - Amendment procedure  Article 12 - Earlier versions of UN Regulations  Article 12 - New technologies  Voting procedure  Virtual testing  Placeholder 2

Article 1 - IWVTA  Proposed amendment introduces concept of IWVTA and new UN R0  Facilitation of national whole vehicle approval by combining various UN system and component approvals into Whole Vehicle Type Approval  Ultimate goal to have vehicle approval universally accepted, with total elimination national approval  IWVTA with limited recognition takes into account the different markets worldwide 3

Article 1 - IWVTA  OICA strongly supports concept, but some challenges remain IWVTA must retain degree of flexibility In step 1, some national requirements will remain, such that IWVTA will not cover "whole" vehicle Concept of IWVTA with limited recognition must be further refined 4

Article 1 - Information document  Proposed revision of 58 Agreement introduces concept of "information document Each Regulation to foresee such "information document" Expected to be based on general, complete list of data for all information documents Should enable standard IT procedures for development of paperwork Should facilitate certification paperwork  Supported by OICA 5

Article 2 - Quality of approvals  Clarifications and new requirements in 58 Agreement on assessment and designation of technical services (placeholder) Improves quality of approvals Therefore also improves mutual trust Improves functioning of mutual recognition  Improves overall quality of 58 Agreement  Whole concept strongly supported by OICA 6

Article 3 - Mutual recognition of approvals  Amendments to Article 3 clarify and stress concept of mutual recognition of approvals Without further testing, documentation, certification and marking  Amendments to Article 3 also delete previous requirements that product must be manufactured in designated territory (was probably contradicting WTO rules!)  New Article 3 strongly supported by OICA 7

Article 5 - DETA and Unique Identifier  Proposed revision of 58 Agreement foresees introduction of DETA (Database for Exchange of Type Approval information)  Proposal also foresees introduction of Unique Identifier (UI) UI would replace approval mark on product UI enables all approval information to be obtained through DETA UI enables simplified product marking  Strongly modernises the current system of approval mark and exchange of approval information  Supported by OICA 8

Article 12 - Amendments to UN Regulations  Article 12 currently foresees rather complicated procedure to amend Regulations, with possibility to retain current unamended versions as "alternative" is some CPs  Article 12 also is unclear as to what happens with CPs opposing the amendment  Proposed revision of Article 12: Once an amendment is established, it must be accepted by all, even by those CPs who opposed originally (democracy by majority) Unamended version of the Regulation remains valid (see next slides)  New Article 12 guarantees mutual recognition of approvals to latest levels and clarifies rights and obligations of all CPs 9

Article 12 - Earlier versions of UN Regulations  Current situation: When a Regulation is amended, no possibility anymore to obtain approval to previous version as from a certain date  Latest level of Regulations sometimes incompatible with situation of some countries (infrastructure, economics, etc.), including CPs  Emerging markets, not CP, often accept UNECE approvals, but approvals to latest levels are often unnecessarily stringent, costly and impractical  Result:  Manufacturers cannot obtain UN approval to earlier versions  Manufacturers must repeat national approvals, based on test report to national standards/previous UN Regulations. 10

Article 12 - Earlier versions of UN Regulations  Proposed revision to 58 A foresees new possibility (no obligation!) to grant and accept approvals to any previous series of amendments Increases manufacturer flexibility to "tailor" products to different markets: several markets may be covered by single UN approval to a previous version (reduction of national approval activities) Concept is expected to attract more countries to 58 A: possibility to grant approval to previous version(s) for export to emerging markets  All CPs applying a UN R must accept approval to latest series Ensures mutual recognition of approvals  Whole concept strongly supported by OICA 11

Article 12 - New Technologies  New possibility to obtain "exemption" approval for new technologies that cannot be approved to existing UN Regulations Concept strongly based on current EU system, experience of which is largely positive Will facilitate introduction of new technologies and thereby accelerate safety and environment improvements  Whole concept strongly supported by OICA, but concerns remain that the "exemption approval" is not fully in line with other Articles, especially Article 3 and 12 (a CP applying the Regulation could nevertheless reject approvals granted under the "new technologies" regime!) 12

Voting procedure  Possibility foreseen of voting by proxy (CP can delegate its vote to another CP) Expected to make 58 Agreement more attractive, especially for far away countries  Any move to make 58 Agreement more attractive to more countries is strongly supported by OICA 13

Virtual Testing  Proposed revision of 58 Agreement introduces concept of virtual testing (calculations, simulations) possibly replacing physical testing Based on EU experience Safeguard clauses are foreseen  Virtual testing already common practice during vehicle/component development  Virtual testing at type approval expected to shorten certification time  Strongly supported by OICA 14

Placeholder - general concept  Proposal to group, in 58 Agreement, several WP29 documents (COP, criteria for technical services, procedures for type approval, interpretation issues)  Improves legal certainty of these WP29 documents  Improves overall quality of 58 Agreement process  Supported by OICA 15