There was insufficient time to discuss the various documents and, as a result, come to a conclusion. However, it was clear that there are still widely differing views on the responsibilities and implications in the use of test reports within a type-approval.

While it was agreed that only the vehicle manufacturer can obtain a braking system type-approval and in the case of a problem related to the type-approval it is the vehicle manufacturer who is responsible for the consequences, there was disagreement as to whether this was clearly the case in the actual use of a test report.

• ► Paragraph 3.3. specifies that “a vehicle, representative of the vehicle type to be approved, shall be submitted to the Technical Service conducting the approval tests.”
  • o Does this mean, for example, that:
    • a) the vehicle referred to in paragraph 3.3. and a vehicle in the test report shall be the same with regard to type, i.e. the same type from the same manufacturer, or
    • b) the vehicle referred to in paragraph 3.3. shall contain the same item that is the subject of the test report and the “approval tests” referred to in paragraph 3.3. are the tests to be carried-out at the time of type-approval for which there are no test reports.
• ► Regarding paragraph 3.4. is the need for the vehicle manufacturer to show conformity of production sufficient for the vehicle manufacturer to be aware of their responsibilities when using test reports.

As a means to resolve the issues surrounding the use of test reports, OICA suggested the replacement of the test report with a component or system type-approval and indicated that this was under investigation by a Germany Industry (VDA) special working group.