1. Commission position on the introduction of CoP provisions for WLTP
Brussels, 12 Dec. 2018
DG GROW/C4

2. Background (1)
The development of the Conformity of Production (CoP) provisions as one of the elements of Phase 2 of the WLTP IWG was agreed by the sponsors several years ago. The initial plan was to start a CoP Task Force (TF) already in 2016, however, due to the diesel emissions scandal and the extreme urgency for the Commission to act at European level, this had to be postponed. The CoP TF was finally activated at the 24th WLTP IWG meeting in Tokyo, which took place from September 2018.

3. Background (2)
In the meantime two important developments have occurred:
The WLTP (including CoP) has been introduced in the European emission type approval legislation since 1st September 2017;
The Transposition of the WLTP from the UNECE 1998 to the 1958 agreement was agreed by the sponsors and is currently ongoing.
During the 24th WLTP IWG meeting in Tokyo, it was stressed by the chair of the Transposition TF that according to the 1958 Agreement, the CoP procedure is a necessary element for the transposition of the WLTP GTR into a UN Regulation WLTP.

4. Current situation (1)
Regarding the Transposition project, the Commission has proposed to Japan to reconsider the timetable and agree on an extension of the project by one GRPE session. According to this Commission proposal, the informal UN R WLTP would be presented at the GRPE session of May 2019, together with the UN R series. The working documents would be submitted by October 2019 for the GRPE session of January 2020.

5. Current situation (2)
Even in the light of this postponement, which the Commission considers inevitable, the timetable for the completion of the Transposition project is quite tight and challenging. The following elements have to be worked out:
GTR 15 and GTR 19
Level 2, level 1a, level 1b
Approach for the Transposition
UNR Series
CoP
Durability

6. Current situation (3)
Europe has already introduced WLTP in its Euro 6 emission type approval legislation since 1st September To do so, also the WLTP specific CoP provisions have been developed and introduced (which had not been developed in the GTR 15). The starting point was the CoP procedure in the UNR 83 and UNR 101, with all the necessary adaptation needed to move from the NEDC-based system to WLTP.

7. Commission proposal for the CoP
In the light of the time schedule for the CoP and the Transposition project, and in the light of the work already done at European level, it would be highly inefficient to repeat such work.
Therefore we propose that the CoP TF, using the European WLTP CoP as basis for the harmonised procedure, should proceed as follows:
Assess the Japanese CoP procedure to identify similarities and differences;
Collect existing CoP data to find the best solution where differences can be sorted out;
Endeavour to propose a harmonised CoP procedure.

8. Questions?