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OICA assessment of the proposed changes to the 58 Agreement

OICA assessment of the proposed changes to the 58 Agreement

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OICA assessment of the proposed changes to the 58 Agreement

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

  2. 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

  3. 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

  4. 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

  5. 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

  6. 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

  7. 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

  8. 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

  9. 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

  10. 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.

  11. 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

  12. 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!)

  13. 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

  14. 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

  15. 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