1. New COP for WLTP André Rijnders Senior advisor vehicle emissions and fuels Vehicle Standards Development RDW, The Netherlands 1 Conformity of production Admin WLTP 06-07-2015

2. 1906 Conformity of production (COP) for WLTP 2 COP Define a frequency of control (audit)  TAA and TS experience is needed to highlight ‘good practice’ Choice of the tested vehicle: -Combined approach VH/VL  V ind tested -“Worst case” approach  VH tested Tolerance on results in accordance with -Confidence on the combined approach -Verifying the production -Control of the definition of V ind and the calculation of its CO 2 /FC values (purpose of COP)  transparency of the process ongoing Evolution factor (Dekra+RDW): ongoing New statistical approach: TNO, RDW, Renault ‘s work ongoing ongoing WLTP in TA process RDW/NL proposal for a set of requirements on the conformity of production (COP) to be included in the new EU WLTP regulation xx/2015 TF document AdminWG-TA5 2015/04/23

3. 1906 Conformity of production (COP) for WLTP 3 COP Define a frequency of control (audit)  TAA and TS experience is needed to highlight ‘good practice’ Choice of the tested vehicle: -Combined approach VH/VL  V ind tested -“Worst case” approach  VH tested Tolerance on results in accordance with -Confidence on the combined approach -Verifying the production -Control of the definition of V ind and the calculation of its CO 2 /FC values (purpose of COP)  transparency of the process ongoing Evolution factor (Dekra+RDW): ongoing New statistical approach: TNO, RDW, Renault ‘s work ongoing ongoing A.What are the COP requirements and how is this organized in the emission regulation? B.Are there frequency requirements for verification of COP for the manufacturer and authority (audits)? C.What could be improved, based on experience from TAA and TS “good practice”?

4. 1906 4 Regulation 715/2007 -- COP Article 4 Manufacturers’ obligations 1.Manufacturers shall demonstrate that all new vehicles sold, registered or put into service in the Community are type approved in accordance with this Regulation and its implementing measures. 2.Manufacturers shall ensure that type approval procedures for verifying conformity of production, durability of pollution control devices and in-service conformity are met. Regulation 692/2008 _-- COP Article 8 COP 1. Measures to ensure the conformity of production shall be taken in accordance with the provisions of Article 12 of Directive 2007/46/EC. 2. Conformity of production shall be checked on the basis of the description in the type-approval certificate set out in Appendix 4 to Annex I to this Regulation. 3. The specific provisions concerning conformity of production are laid down in Section 4 of Annex I to this Regulation and the relevant statistical methods in Appendices 1 and 2 to that Annex. A: What are the COP requirements and how is this organized in the emission regulation?

5. 1906 5 Conformity of production in 692/2008 Article 8 1. Measures to ensure the conformity of production shall be taken in accordance with the provisions of Article 12 of Directive 2007/46/EC. Directive 2007/46 (frame work directive) Article 12 Conformity of production arrangements 1.INITIAL ASSESSMENT: MS which grants an EC type-approval shall take the necessary measures (Annex X) to verify that adequate arrangements have been made to ensure that production vehicles conform to the approved type. (if need be in cooperation with the approval authorities of the other Member States) 2.PRODUCT CONFORMITY ARRANGEMENTS: MS which has granted an EC type-approval shall take the necessary measures (Annex X) to verify, that the arrangements referred to in paragraph 1 continue to be adequate and that production vehicles, continue to conform to the approved type. MS which has granted the EC type-approval may carry out any of the checks or tests prescribed in any of the regulatory acts listed in Annex IV or Annex XI on samples taken in the premises of the manufacturer, including production facilities. (limited to the procedures set out in Annex X and in those regulatory acts that contain specific requirements)

6. 1906 6 2007/46 ----Annex X COP Initial assessment The TAA must verify, to the satisfaction, before granting EC type-approval, the existence of satisfactory arrangements and procedures for ensuring effective control so that vehicles (or components) when in production conform to the approved type. The EC type-approval authority must also accept the manufacturer’s suitable certification to harmonised standard EN ISO 9002-1994 (whose scope covers the locations of production and product(s) to be approved), or EN ISO 9001-2000 with the permissible exclusion of the requirements related to the concepts of design and development, sub-clause 7.3 ‘….. …. (well described) Product conformity arrangements The EC type-approval authority of a Member State, at the time of granting an EC type- approval, must verify the existence of adequate arrangements and documented control plans, to be agreed with the manufacturer for each approval, to carry out at specified intervals those tests or associated checks necessary to verify continued conformity with the approved type including specifically, where applicable, tests specified in the separate directives or regulations.

7. 1906 7 2007/46 ----Annex X COP Continued verification arrangements 3.1 The authority which has granted EC type-approval may at any time verify the conformity control methods applied in each production facility. 3.1.1. The normal arrangements shall be to monitor the continued effectiveness of the procedures established at 1.2 (initial assessment and product conformity) of this Annex. 3.1.1.1. Surveillance activities carried out by a certification body (qualified or recognised as required by paragraph 1.2.3 of this Annex) must be accepted as satisfying the requirements of 3.1.1 with regard to the procedures established at initial assessment (paragraph 1.2.3). an appointed body acting on behalf of the EC type-approval authority. 3.1.1.2. The normal frequency of verifications by the EC type-approval authority (other than those at 3.1.1.1) shall be such as to ensure that the relevant controls applied in accordance with Sections 1 and 2 of this Annex are reviewed over a period consistent with the climate of trust established by the type-approval authority. Remark : frequency for the TAA audits are : any time and this period ? Should we define a minimum in 629/2008? B: Are there frequency requirements for verification of COP for the manufacturer and authority (audits)?

8. 1906 8 2007/46 ----Annex X COP Continued verification arrangements 3.2. At every review, records of tests or checks and records of production shall be made available to the inspector; in particular, records of those tests or checks documented as required by point 2.2 of this Annex. 2.2. The EC type-approval authority of a Member State, at the time of granting an EC type- approval, must verify the existence of adequate arrangements and documented control plans, to be agreed with the manufacturer for each approval, to carry out at specified intervals those tests or associated checks necessary to verify continued conformity with the approved type including specifically, where applicable, tests specified in the separate directives or regulations. Should we not define a minimum of intervals from the Manufacture in the emission regulation depending on the vehicles produced ?? Type 1 tests for emissions and CO2 (no RL test regulated yet) At the moment there is no level playing field  among TAA and Manufacturers B: Are there frequency requirements for verification of COP for the manufacturer and authority (audits)?

9. 1906 9 2007/46 ----Annex X COP Continued verification arrangements 3.3. Where the nature of the test is appropriate, the inspector may select samples at random to be tested in the manufacturer’s laboratory (or by the technical service where the separate directive or regulation so provides). The minimum number of samples may be determined according to the results of the manufacturer’s own verification. Remark: vague formulation! 3.4. Where the level of control appears unsatisfactory, or when it seems necessary to verify the validity of the tests carried out in application of point 3.2, the inspector must select samples to be sent to the technical service which conducted the EC type-approval tests. 3.5. In cases where unsatisfactory results are found during an inspection or a monitoring review, the EC type-approval authority must ensure that all necessary steps are taken to restore conformity of production as rapidly as possible. B: Are there frequency requirements for verification of COP for the manufacturer and authority (audits)?

10. 1906 10 Directive 2007/46 (frame work directive) Continuing Article 12 3.When a Member State which has granted an EC type approval establishes that the arrangements referred to in paragraph 1 are not being applied, deviate significantly from the arrangements and control plans agreed, or have ceased to be applied, although production is not discontinued, that Member State shall take the necessary measures, including the withdrawal of the type-approval, to ensure that the conformity of production procedure is followed correctly. A: What are the COP requirements and how is this organized in the emission regulation? If COP is not in conformity.. necessary measures.

11. 1906 11 Conformity of production in 692/2008 Article 8 2.Conformity of production shall be checked on the basis of the description in the type-approval certificate set out in Appendix 4 to Annex I to this Regulation. What are the COP requirements in the emission regulation? Appendix 4 is the EC TA certificate If we also want to check the RL during COP in the future, then the RL values needed to be well documented. The coast down values are normally given in the test report as an attachment to the certificate).

12. 1906 12 Conformity of production in 692/2008 Article 8 3.The specific provisions concerning conformity of production are laid down in Section 4 of Annex I to this Regulation and the relevant statistical methods in Appendices 1 and 2 to that Annex. Section 4 of Annex  additional to the general COP provisions, here the specific COP provisions Appendix 1 and 2  statistical methods A: What are the COP requirements and how is this organized in the emission regulation?

13. 1906 C: What could be improved, based on experience from TAA and TS “good practice”? 13 4. CONFORMITY OF PRODUCTION 4.1. Introduction 4.1.1. Where applicable the tests of types 1, 2, 3, 4, the test for OBD, the test for CO2 emissions and fuel consumption and the test for smoke opacity shall be performed, as described in section 2.4. The specific procedures for conformity of production are set out in the sections 4.2 to 4.10. Remarks: In this introduction it is not clear what kind of COP we are describing here, only “ Where applicable” In 692/2008 there is no clarity on frequency. Part of the Initial assessment ? Part of the product conformity arrangement? Or only during the verifications by the EC type-approval authority? What are the applicable tests of type 1 : only emissions and CO2 testing! Which Vehicle? COP not yet possible on elements of the type 1 test (like RL testing)?

14. 1906 C: What could be improved, based on experience from TAA and TS “good practice”? 14 4.2. Checking the conformity of the vehicle for a type 1 test 4.2.1. The type 1 test shall be carried out on a vehicle of the same specification as described in the type-approval certificate. When a type 1 test is to be carried out for a vehicle type-approval that has one or several extensions, the type 1 tests shall be carried out either on the vehicle described in the initial information package or on the vehicle described in the information package relating to the relevant extension. Remarks: COP type I test should be carried out on a production vehicle of a valid member of the family as described in the TA certificate including extension.

15. 1906 C: What could be improved, based on experience from TAA and TS “good practice”? 15 4.2. Checking the conformity of the vehicle for a type 1 test 4.2.1. The type 1 test shall be carried out on a vehicle of the same specification as described in the type-approval certificate. When a type 1 test is to be carried out for a vehicle type-approval that has one or several extensions, the type 1 tests shall be carried out either on the vehicle described in the initial information package or on the vehicle described in the information package relating to the relevant extension. Remarks: COP type I test should be carried out on a production vehicle of a valid member of the family as described in the TA certificate including extension.

16. 1906 C: What could be improved, based on experience from TAA and TS “good practice”? 16 4.2. Checking the conformity of the vehicle for a type 1 test 4.2.2. After selection by the approval authority, the manufacturer shall not undertake any adjustment to the vehicles selected.  No changes 4.2.2.1. Three vehicles shall be selected at random in the series and tested as described in Annex III to this Regulation. The deterioration factors shall be used in the same way. The limit values are set out in Tables 1 and 2 of Annex I to Regulation (EC) No 715/2007. 4.2.2.2. If the approval authority is satisfied with the production standard deviation given by the manufacturer in accordance with Annex X to Directive 2007/46/EC, the tests shall be carried out according to Appendix 1 of this Annex. If the approval authority is not satisfied with the production standard deviation given by the manufacturer in accordance with Annex X to Directive 2007/46/EC, the tests shall be carried out according to Appendix 2 of this Annex. Remark: the production stand deviation is for emission testing in general not known so we can delete the possibility of Appendix 1.

17. 1906 C: What could be improved, based on experience from TAA and TS “good practice”? 17 4.2. Checking the conformity of the vehicle for a type 1 test 4.2.2.3. The production of a series shall be deemed to conform or not to conform on the basis of a sampling test of the vehicles once a pass decision is reached for all the pollutants or a fail decision is reached for one pollutant, according to the test criteria applied in the appropriate appendix. When a pass decision has been reached for one pollutant, that decision shall not be changed by any additional tests carried out to reach a decision for the other pollutants. If no pass decision is reached for all the pollutants and no fail decision is reached for one pollutant, a test shall be carried out on another vehicle (see Figure I.4.2). Remark: Pass and fail decisions for pollutants and in paragraph 4.3.4 this is also made applicable for emission of CO2

18. 1906 C: What could be improved, based on experience from TAA and TS “good practice”? 18 Figure I.4.2

19. 1906 C: What could be improved, based on experience from TAA and TS “good practice”? 19 4.2.3. Notwithstanding the requirements of Annex III, the tests shall be carried out on vehicles coming straight off the production line. 4.2.3.1. However, at the request of the manufacturer, the tests may be carried out on vehicles which have completed: (a) A maximum of 3 000 km for vehicles equipped with a positive ignition engine; (b) A maximum of 15 000 km for vehicles equipped with a compression ignition engine. The running-in procedure shall be conducted by the manufacturer, who shall undertake not to make any adjustments to these vehicles. Remark: In the GTR the run-in is in between 3000 and 15000 km. No difference for PI and CI engines.

20. 1906 C: What could be improved, based on experience from TAA and TS “good practice”? 20 4.2.3.2. If the manufacturer wishes to run in the vehicles, (‘x’ km, where x ≤ 3 000 km (15000 …. Emissions ‘x’ km / Emissions zero km use evolution coefficient calculated from the measured difference. 4.2.3.3. All these tests shall be conducted with commercial fuel. However, at the manufacturer’s request, the reference fuels described in Annex IX may be used. Remark: Include that “ zero km” is in practice between 0 and 80 km. For pollutant emissions we can use commercial fuels and for CO 2 testing only the reference fuels shall be used! A lot of failures in practice. Make requirements equal.

21. 1906 C: What could be improved, based on experience from TAA and TS “good practice”? 21 4.3. Checking the conformity of the vehicle for CO2 emissions 4.3.4.2. The provisions of Section 4.2.3.1 shall be replaced by the following: However, at the request of the manufacturer, the tests may be carried out on vehicles which have completed a maximum of 15 000 km. If the manufacturer wishes to run in the vehicles, (‘x’ km, where x ≤ 15 000 km), Emissions ‘x’ km / Emissions zero km use evolution coefficient calculated from the measured difference

22. 1906 C: What could be improved, based on experience from TAA and TS “good practice”? 22 4.3. Checking the conformity of the vehicle for CO2 emissions 4.3.4.5. When checking the conformity of vehicle for CO2 emissions, as an alternative to the procedure mentioned in Section 4.3.4.3, the vehicle manufacturer may use a fixed evolution coefficient EC of 0,92 and multiply all values of CO2 measured at zero km by this factor. Remark: This alternative default fixed evolution coefficient should have some safeguards not to overestimate. After investigations a 8% CO2 improvement from zero to 15.000 km is not justified. After discussion in Admin WLTP group the fixed evolution coefficient EC should be [0.97, 0.96 or 0.95].

23. 1906 C: What could be improved, based on experience from TAA and TS “good practice”? 23 4.4. Vehicles powered by an electric power train only 4.5. Vehicles powered by a hybrid electric power train

24. 1906 C: What could be improved, based on experience from TAA and TS “good practice”? 24 Appendix 1 and 2  statistical methods Delete Appendix 1 New Appendix 2 Appendix 2 Verification of conformity of production — Second statistical method Remark: No reference to R83 any more. Amendment R83 together with GTR phase II. Appendix 1 Verification of conformity of production — First statistical method

25. 1906 C: What could be improved, based on experience from TAA and TS “good practice”? 25

26. 1906 C: What could be improved, based on experience from TAA and TS “good practice”? 26

27. 1906 C: What could be improved, based on experience from TAA and TS “good practice”? 27