The commercial and passenger vehicle supply chain faces a major challenge next April with the introduction of new EC Whole Vehicle Type Approval (ECWVTA) legislation
While the legislation comes into force in the UK on 29 April 2009, it will operate on a voluntary basis for the first 18 months. It will become mandatory from 29 October 2010, with compliance dates dependent on the vehicle category.
Already in use for cars, the extension of the regime will affect all businesses involved in the manufacture, conversion, build, import, sale and rental of new trucks, trailers, coaches, minibuses, motor homes and vans. All new commercial vehicles will have to be built to approved standards and be issued with a Certificate of Conformity (CoC) before they can be sold or used in EU member states.
Four forms of approval
Both the vehicle (i.e. chassis and bodywork combined), and the production process will require initial approval. This comes in four forms to take account of the wide range of companies involved in the commercial vehicle supply chain – from volume producers down to specialist converters:
The approval process
To obtain ECWVTA or NSSTA chassis cab, bodywork and supply chain manufacturers will need to undergo a thorough inspection of their pre-production vehicles and a Conformity of Production (CoP) assessment on their production processes. Once a company has received type approval for a particular vehicle design, it is able to issue a Certificate of Conformity for each vehicle of that type without further testing. Because the NSSTA process is intended for low-volume manufacturers who are targeting the UK market, the CoP requirement is less stringent.
IVA does not require CoP but each vehicle will need to be inspected and approved at a Vehicle and Operator Services Agency (VOSA) test station in Great Britain, or a Driver Vehicle Agency (DVA) test station in Northern Ireland.
Introduced to create a pan-European Union vehicle approval scheme, the architects of the new legislation hope it will ensure that new trucks, vans and special-purpose goods vehicles are safe for all EU roads and conform to all environmental standards, without the need to inspect and test every single one.
Although it may help raise and maintain commercial and passenger vehicle standards across the EU, complying with the new regime will not be an easy process. On an operational level, companies may have to make significant changes to the way they do business. For example, a manufacturer may have to change their product design or manufacturing process to meet new technical or quality control requirements (these are listed in the ECWVTA Directive). This could involve changing the way people work and introducing new training.
The UK perspective
The legislation is likely to have a particularly big impact on the domestic market where customers are used to tailoring the size and shape of their vehicles to suit very specific business needs. Britain has around 1,100 commercial vehicle bodybuilders and the SMMT says that 100,000 vans and trucks required bodywork last year.
The new directive is likely to significantly increase the cost and complexity involved in manufacturing and procuring bespoke or small production run vehicles, particularly those that are built in more than one stage. For example, a chassis and powertrain may come from one source, a cab unit from another, a body added by a further contractor, and so on.
This sort of complex supply chain will require a fundamental re-think of how the process is co-ordinated and administered. It is estimated that ensuring that ECWVTA procedures are adhered to at every stage could add up to ten weeks to the build time for bespoke vehicles. Customers will need to take sort of delay into account when planning new additions to their fleet.
Extra cost is another major implication of the new testing regime. Large scale manufacturers will be able to dilute the costs associated with compliance across their fleet of new vehicles, something that smaller producers will have difficulty doing.
Perhaps the biggest challenge of ECWVTA is a communications one. Everyone involved in the commercial vehicle supply chain, from component producers through to manufacturers, body builders and dealers, needs to ensure that they are fully aware of what approvals are needed and that they keep proper records. For multi-stage builds in particular, all parties should review all the commercial and contractual processes involved to make sure that all responsibilities and roles are fully understood.
Finally, customers also need to be made aware of the potential increase in vehicle costs and ordering times, particularly for bespoke or multi-stage vehicles.