1. 2007/46 EC Article 6 Procedures for EC Whole Vehicle Type Approval
Mike Protheroe
25 April 2012

2. Outline Type Approval Information Type Approval Processes
various terms and what they mean
how information is put together
Type Approval Processes
step by step
single step
mixed approval
multi stage approval

3. Type Approval Information

4. Descriptions of Type Approval Information
See Article 3 (paragraphs 37 – 40) for definitions;
it is permissible to supply information in an electronic file
VCA prefers to receive it this way!
Information document
the document set out in Annex I or Annex III, or in the corresponding Annex to a separate directive, or regulation, that prescribes the information to be supplied by an applicant

5. Descriptions of Type Approval Information
Annex I
Complete Information Document used in Single Step process
just the headings which form the template run to about 70 pages of A4!
Annex III
Partial Information Document used in Step by Step process
the headings in the template are about 7 pages of A4

6. Descriptions of Type Approval Information
Information folder
is supplied by the applicant
the complete folder of information about the type of vehicle
includes the information document, data, drawings, photo’s, etc.
Information package
a compilation of;
the information folder (supplied by the applicant)
test reports, type approval certificates (& other docs) added by a technical service or approval authority
Type Approval

7. Descriptions of Type Approval Information
Index to the information package
the document listing the contents of the information package, it needs to;
be suitably numbered (or identified) so as to identify clearly all the pages / items
present a record of the successive steps in the management of the EC type approval
in particular the dates of the revisions and updating

8. Compiling Information
Photographs & Drawings
Info Doc
Information Document
Index
Information Package
Template
Information Folder
Certificate(s) & Test Report(s)
Type Approval

9. Type Approval Procedures (Article 6)
The manufacturer may choose one of the following procedures:
(a) step by step type approval
(b) single step type approval
(c) mixed type approval

10. Descriptions of the Processes
See Article 3 (paragraphs 7 – 10) for definitions;
Step by step type approval
a procedure where there is an incremental collection of the complete set of EC type approval certificates for the systems, components and separate technical units relating to the vehicle, and which leads, at the final stage, to the approval of the whole vehicle
Single step type approval
a procedure whereby a vehicle is approved as a whole by means of one operation

11. Descriptions of the Processes
Mixed type approval
a step by step type approval procedure where one or more system approvals are achieved during the final stage of the approval of the whole vehicle, without it being necessary to issue the EC type approval certificates for those systems
Multi-stage type approval
a procedure whereby one or more Member States certify that, depending on the state of completion, an incomplete or completed type of vehicle satisfies the relevant administrative provisions and technical requirements

12. Step by Step Type Approval
Traditionally this has been the route chosen by most
Equally well suited to both single stage and multi stage type approval
Each System, Component or Separate Technical Unit (STU) has its own discrete type approval package
is comparatively easy to manage
“pigeon hole” approach

13. Step by Step Type Approval
Some Pros
A systematic approach well suited to project management techniques
Each approval can be treated as a ‘work package’
Makes approvals easily ‘transportable’
A system approval for spray suppression can easily be used on many different whole vehicle types

14. Step by Step Type Approval
Some Cons
Is comparatively more expensive than Single Step as each approval generally has fees for at least a certificate and admin.
There may also be fees for testing and / or technical review time
Each time there is an extension to a lower level approval (e.g. system approvals – such as spray suppression) the whole vehicle approval must be extended

15. Single Step Type Approval
Some use has been made of this in the past
no where near as common as the step by step process
Multi stage approvals may make this more common as there is often not much for the final stage to do so it is more manageable

16. Single Step Type Approval
Some Pros
Is comparatively less expensive than Step by Step as there is only one approval
however, as well as a single certificate fee and an admin fee there are also fees for testing / inspection and / or technical review time

17. Single Step Type Approval
Some Cons
The type approval documentation is very large / ‘heavy’
may run to several hundred pages
It may be harder to manage the overall project
everything has to be made ready at once
there may be difficulty controlling versions

18. Single Step Type Approval
Some Cons
Information is not very ‘portable’
All approval information is ‘embedded’ in the Whole Vehicle Type Approval
e.g. about the spray suppression system data would need to be extracted and recreated in parallel if it is to be used on many different whole vehicle types

19. Mixed Type Approval This is all about choice and flexibility
the applicant chooses which method suits best, based on
any particular type of vehicle (or order)
method of operating manufacturing
A manufacturer in a multi stage approval can always opt for the mixed process

20. Mixed Type Approval
As the name suggests a mixture of both step by step and single step are used
Almost any combination is allowed
Examples
Base Vehicle
Stages
Mixed
Y / N
Steps N
Single Y …

21. Mixed Type Approval
The principal benefit of using the mixed approval process is that the Annex III information document (the light one) is used and augmented with information extracted from Annex I for the subjects where there are no separate approvals
gives the best of both worlds

22. Worked example of ECWVTA
Mike Protheroe
25 April 2012

23. Outline Walkthrough of the Step by Step process What’s needed?
using a trailer as an example
What’s needed?
a look at the type approval requirements
How to go about it
getting a system approval
putting together the information folder
types, variants and versions

24. Overall Picture

25. Getting Systems Approvals
Understand the legislation
Build the product in compliance
Ensure Conformity of Production (CoP) systems in place
Prepare Information folder
Submit for type approval testing
Receive Type Approval certificate
Continue to build in compliance

26. Legislation Sources Legislation is available
free of charge (help yourself online)
on a subscription basis (pay someone to find it and keep track of it for you)
VCA has subscription based systems which can help
There are also other providers

27. Building Products in Compliance
OK - you’ve got access to legislation
READ IT
UNDERSTAND THE REQUIREMENTS
If in doubt ask!
Build your product to meet the requirements
Ensure adequate quality management systems are in place to ensure CoP

28. Information Folder
Most of the directives or regulations will have a template for an information document
Information documents follow a basic and recognisable format and contain information about;
You (the manufacturer)
Your products (the type of vehicle or system)

29. System Approval Example Spray Suppression
2010/19/EU enforced on 9 April 2011
Requirements
Mudguard
Valances
Rain Flaps
Air/Water Separator (matting)

30. System Approval Example Spray Suppression
Spray suppression has a wide definition “type”
From Annex I of 91/226/EEC as amended;
15. Type of vehicle
“Type of vehicle” means, in relation to spray suppression complete, incomplete or completed vehicles, which do not differ with respect to the following aspects:
— type of spray suppression device (installed on the vehicle),
— manufacturer’s spray suppression system type designation.
One system approval can cover a range of vehicles

31. System Approval Example Spray Suppression
Some requirements extracted from directive 91/226/EEC as amended;
1.0 Category N and O vehicles, … shall be constructed and/or fitted with spray suppression systems … …
In the case of multiple axles where distance ‘d’ between the tyres on adjacent axles is less than 250 mm, only the rear set of wheels must be fitted with rain flaps. There must be a rain flap behind each wheel when distance ‘d’ between the tyres on adjacent axles is at least 250 mm (Figure 4 of Annex V).  

32. System Approval Example Spray Suppression
Figure 4 - Diagram showing assembly of a spray-suppression system
(mudguard, rain flap, outer valance) incorporating spray-suppression devices (energy absorbers)

33. Spray Suppression Information Document
Information document no … relating to EC type-approval of a vehicle with respect to the fitting of spray-suppression systems (directive 91/226/EEC, as last amended by directive 2010/19/EU) (*)
0. GENERAL
0.1. Make (trade name of manufacturer):
Paragon
0.2. Type:
X Axle (X = 1, 2 or 3)
Commercial name(s) (if available):
Paragon Transporter or ParaTran

34. Spray Suppression Information Document
0.3. Means of identification of type, if marked on the vehicle (b)
Not applicable
Location of that marking:
0.4. Category of vehicle (c):
N1, N2, N3, O3, O4
0.5. Name and address of manufacturer:
Paragon Ltd, [HQ Address]
0.8. Address(es) of assembly plant(s):
1) Paragon Ltd, [Plant Address]
2) Para Build Ltd, [Plant Address]

35. Spray Suppression Information Document
1. GENERAL CONSTRUCTION CHARACTERISTICS OF THE VEHICLE
1.1. Photographs and/or drawings of a representative vehicle:
See attachment 1
1.3. Number of axles and wheels:
1 axle, 2 wheels OR 2 axles, 4 wheels OR
3 axles, 6 wheels
Number and position of axles with twin wheels:
None
Number and position of steered axles

36. Spray Suppression Information Document
2. MASSES AND DIMENSIONS (f) (g)(in kg and mm) (Refer to drawing where applicable)
2.1. Wheelbase(s) (fully loaded) (g) (l):
See attachment 1
2.6.Mass in running order (maximum and minimum for each variant)
Mass of the vehicle with bodywork and, … in running order, or mass of the chassis or chassis with cab, without bodywork and/or coupling device if the manufacturer does not fit the bodywork and/or coupling device (including liquids, tools, spare wheel, if fitted, and driver … (h) (maximum and minimum for each variant):

37. Spray Suppression Information Document
2.6.1.Distribution of this mass among the axles and, in the case of a semi-trailer or centre-axle trailer, load on the coupling point (maximum and minimum for each variant):
See attachment 1
2.8.Technically permissible maximum laden mass stated by the manufacturer (i) (3):

38. Spray Suppression Information Document
9. BODYWORK
9.20. Spray-suppression system
Presence: yes / no / incomplete (1)
Brief description of the vehicle with regard to its spray-suppression system and the constituent components:
Mudwing with incorporated valance and mudflaps behind rear wheels
Detailed drawings of the spray-suppression system and its position on the vehicle showing the dimensions specified in the Figures in Annex V to Directive 91/226/EEC and taking account of the extremes of tyre/wheel combinations:
See Attachment 2
Approval number(s) of spray-suppression device(s), if available: Not applicable
XXXXXXXX

39. Spray Suppression Information Document
Attachment 1 (General Information)
Here you would include the relevant information referred to earlier
It is free form, you can use the most appropriate method to convey your information; e.g.
photographs, drawings
lists, tables, etc.
Include the headings again (or at least the heading number)
1.1. Photographs and/or drawings of a representative vehicle:

40. Spray Suppression Information Document
Attachment 2 (Specific Information)
Include here the detailed information about the spray suppression equipment itself
Free form, use the most appropriate method to convey your information; e.g.
photographs, drawings
lists, tables, etc.
part numbers & suppliers
alternatives

41. Systems - Type Approval Testing
Book an appointment!
System type approval costs with VCA are;
Cert Fee £37 (£56 for paired Dir & Reg)
Admin Fee £73
Tech Fee £89 per hour
Approval granted if all requirements are met;
e11*91/226*2010/19*nnnn*00

42. EC Whole Vehicle Type Approval Example; Type = 2 Axle
Step by Step method
Gather all necessary system approvals
3. Rear protection
4. Rear Registration Plate Space
9. Braking …
43. Spray Suppression
… etc.
Complete Annex III information document from Framework Directive 2007/46/EC

43. EC / NSSTA Whole Vehicle Type Approval Example; O4 Trailer

44. O4 Trailer – What needs approving?
Masses and dimensions
Rear registration plate space
Tyres
Rear-underrun device
Spray Suppression
Coupling & Drawbar
Side guards
Brakes
Lighting Installation
Statutory plates

45. The Administration of ECWVTA
CMS Compliance Management System

46. Managing your administration - CMS

47. Types, Variants and Versions
What is a type?
What is a Variant?
What is a version?
Variants

48. TVV Matrix for a Trailer
So the TVV Code for this trailer is 3AO4DB / P / 18

49. The mixed type approval
A combination of Annex 1 (massive info doc) and Annex 3 (smaller info doc with systems approvals)
Lighting section + VCA test report
Annex 3 Info Doc
Annex 1 Info Doc
Mixed Whole Vehicle approval
Rear Underrun approval + =
Side guards approval
Statutory plates approval
Masses and dimensions approval
Rear Registration plate space approval
Spray Suppression section + VCA test report

50. Whole Vehicle Type Approval Costs the detail…….
Whole vehicle type approval costs with VCA are;
S&C Cert Fee £37 (£56 for paired Dir & Reg)
S&C Admin Fee £73 per job
Tech Fee £89 per hour
CoP review / audit £250 / £890 / £1785
Whole Vehicle Cert fee £75
Whole Vehicle Admin fee £73
Tech fee £89

51. Whole Vehicle Type Approval Costs the factors…
Passing and failing, don’t assume! more tests or inspections = more money!
The complication factors – consolidate options that affect approval
Adopting early means less panic and more knowledge of the process
Maximise the multi-stage process to your benefit – e.g outsource to others if your approval doesn’t cover it

52. 1st type; Subsequent types; So what does it all mean?
approx £5,000-£7,000
Subsequent types;
may be less for similar vehicles or similar chassis

53. Issue Certificates of Conformity
And afterwards?
Issue Certificates of Conformity
Your declaration that the vehicle in question meets the requirements
Only add information that you have affected

55. And after that? Maintain your approval!!!!
Changes to your specification Additions to your specification Changes to base vehicle Changes to legislation

56. Questions? Contacts Gareth Jones, Chief Engineer, VCA Bristol
Dave Picker, Chief Engineer, VCA Midlands