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.

After a long discussion there remained widely differing views, with the consensus being that none of the proposals being considered provided a clear way forward in resolving these differences.

Therefore, it was agreed that no specific amendment proposal would be made to GRRF and the chairman would report on the various points that had been discussed with a view to GRRF deciding:

• - Is there a problem that requires resolution?
  • o Annex 21 specific, ECE R13 specific or ’58 Agreement specific?

In the event of a yes decision, the recommendation would be the establishment of a new informal working group.

• - Before the introduction of test reports within the type-approval process it was appropriate that the Technical Service conducting the type approval was provided with a vehicle on which to conduct the tests as required by the regulation, hence paragraph 3.3. – “a vehicle, representative of the vehicle type to be approved, shall be submitted to the Technical Service conducting the approval tests.” With the addition of test reports within the type-approval process, and no change to paragraph 3.3. 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.

• - Should an Approval Authority only grant an approval when all the Technical Services providing test reports used in a braking system type-approval are designated by them for that specific work? Is there a difference in the case of a system type-approval and in the case of a vehicle type-approval?

Discussion points:

• - Is there a difference in responsibility when a Technical Service sub-contracts type-approval test work (with or without an Approval Authority approved test report) or when they receive an Approval Authority approved test report from another Technical Service that they then use in a type-approval? Is there a difference between a system type-approval and a vehicle type-approval?

• - Although it is only the vehicle manufacturer who can obtain a braking system type-approval and, as a result, it is the vehicle manufacturer who is responsible in the first instance for any resulting consequences, is it clear that this responsibility goes not go away when a provided test report is used in the type approval?

• - Is the need for the vehicle manufacturer to show satisfactory arrangements at the time of type-approval with regard to conformity of production, as required by paragraph 3.4., sufficient for the vehicle manufacturers to be aware of their responsibilities when using test reports?