Self-certification scheme in Canada – motor vehicle safety regulation

Any vehicle regulated under the Motor Vehicle Safety Act, which is imported or offered for sale in(to) Canada has to be self-certified by the OEM at the time the main assembly of the vehicle is completed. It is the responsibility of the OEM to ensure compliance of its products with existing legislation. Documentation showing proof of compliance must be produced and retained for at least five years from date of manufacturing or importation and supplied to Transport Canada upon request. The test methodologies used by the OEM to certify their products should be in accordance with the test requirements detailed in the Motor Vehicle Safety Regulations.

Self-Certification scheme in the United States

The OEM is obliged to meet certain requirements, testing is not mandatory. It is not a violation of US law if no in-house reports are available. However usually he would do the testing do to be confident that requirements are met. NHTSA will do performance testing with vehicle samples that are acquired anonymously. If in this test requirements are not met, NHTSA will request certification data from the OEM. If data made available by the OEM does not prove compliance, this may ultimately lead to recall civil penalties. This is for safety certification. Environmental aspects may be treated differently. EPA in some cases, e.g. Exhaust Emissions, issues certificates, yet they are not based on EPA testing but on information delivered by the OEM. Compliance with requirements is typically verified with field surveillance testing that is carried by EPA in its own labs. Just as with Safety requirements, the OEM will be requested to deliver evidence in the case of non-compliance. For Exterior Noise, no certificates will be issued; it is assumed that vehicles are in compliance by virtue of bringing the product to the market.

Compared with the type approval process applied in some countries, for self-certification compliance a product must fulfill requirements at all possible conditions covered in the standard. In contrast for type approval one specific condition of the range of possible conditions is tested and leads to approval. Example: In a given temperature range from 20-30°C, the OEM must take care that his product is in fulfillment of all possible combinations of conditions while for TA, if it is proven that for one condition the product is compliant, there is no necessity to prove other conditions.

A presentation of TA system and principles will be given at a later stage.