The International Whole Vehicle Type Approval will involve granting whole vehicle approvals based upon component-level approvals granted to manufacturers (i.e., OEM suppliers) other than the manufacturer (i.e., vehicle maker) applying for the whole vehicle approval. This document provides comments solicited from EU type approval authorities regarding the management of this system of direct and indirect application of UN Regulation approvals to a whole vehicle.

The question and answer document aims to clarify the operation of the international whole vehicle type approval system. This question would confirm that a Contracting Party may apply additional requirements taken from a UN Regulation beyond those regulations specifically required under a limited whole vehicle approval (L-IWVTA). The L-IWVTA partially applies the list of requirements for a “Universal International Whole Vehicle Approval” (U-IWVTA). A CP could list UN Regulations required for an L-IWVTA and then notify WP.29 of additional requirements taken from other UN Regulations.

Update on the Working Party discussions towards including additional UN Regulations within the International Whole Vehicle Type Approval system.

Listing of UN Regulations, including the series level, for inclusion with the scope of the proposed whole vehicle type approval regulation. The entry into force of UN R0 is anticipated for June 2018 with a subsequent update from November 2018.

Reports of the subgroup liaisons with the GR working parties on discussions towards enabling the application of additional UN Regulations to the whole vehicle approval process of UN R0.

At the entry into force of Regulation No. 0, the secure Internet database for the “data exchange of type approvals” (DETA) under Schedule 5 of Revision 3 to the 1958 Agreement may not be fully operational. This proposal from the DETA informal group introduces footnotes to clarify that requirements in paragraphs 4.4., 5.2. and Annex 6 do not apply until the DETA system is complete.

Updated text prepared for review during the 22nd SGR0 IWVTA subgroup meeting.

Draft regulation prepared for consideration during the 21st IWVTA SGR0 session and incorporating proposed revisions concerning “IWVTA class/vehicle type” from the European Commission.

Proposal to clarify that a vehicle type under the IWVTA regulation can only exist if there is at least one IWVTA whole vehicle approval associated with it.

Proposal to clarify that a vehicle type under the IWVTA regulation can only exist if there is at least one IWVTA whole vehicle approval associated with it.

Concept for addressing vehicle approvals incorporating regulated equipment that is mandatory under some jurisdictions while optional under others.

Proposal to clarify that the component approvals underpinning a vehicle type approval do not have to have been issued to the same manufacturer, but that the responsibilities of the manufacturer applying for vehicle type approval to the type approval authority nonetheless remain intact.

Summary of results from checking into “Attestation” from the legal point of view by Japan.

WP.29 adoption of the new IWVTA regulation (UN Regulation No. 0) is anticipated for March 2017 with an entry-into-force the following October. This initial regulation (00 series of amendments) will include UN Regulations as they stand prior to September 2, 2017. However, a number of these regulations contain transitional provisions such that new versions will enter into force during the 12 months following this cut-off date. Therefore, this document (updated from the earlier version) proposes a list of such regulations that would be included in the 01 series of amendments to UN R0 to be submitted for adoption by WP.29 in November 2017. In concept, UN R0 would be updated with these “upgraded” versions of the UN Regulations.

WP.29 adoption of the new IWVTA regulation (UN Regulation No. 0) is anticipated for March 2017 with an entry-into-force the following October. This initial regulation (00 series of amendments) will include UN Regulations as they stand prior to September 2, 2017. However, a number of these regulations contain transitional provisions such that new versions will enter into force during the 12 months following this cut-off date. Therefore, this document (updated from the earlier version) proposes a list of such regulations that would be included in the 01 series of amendments to UN R0 to be submitted for adoption by WP.29 in November 2017. In concept, UN R0 would be updated with these “upgraded” versions of the UN Regulations.

Report on the consideration of additional UN Regulations for incorporation into the proposed international whole vehicle type approval regulation.

Table of reports received on issues or concerns uncovered during the initial validation of the proposed regulation on whole vehicle type approvals.

Proposal for the UN R0 Pretest Task Force in response to issues and concerns raised during the first validation round by Contracting Parties and other stakeholders.

Under the proposed international whole vehicle type approval, Annex 4 to the regulation would provide the list of component regulations. Annex 4 will be updated over time to incorporate new or updated regulations that comprise a whole vehicle approval. These changes in requirements will impact whether a vehicle has a universal or limited approval and will require communication between the holder of the approval and the issuing type approval authority; however, the obligations and procedures for maintaining this coordination are not spelled out in the UN R0 text. Japan proposes a manufacturer obligation to notify of the authority of its intentions when an amendment to Annex 4 would impact an existing approval in its possession.

Proposal to clarify the procedure and information to be provided by the manufacturer in the event of a change to a whole vehicle approval type.

When a series of amendments to any UN Regulation included in a whole vehicle approval is changed, it needs to be considered as an extension of approval to UN R0 even if the series of amendments to R0 remains unchanged. Therefore, the text of Revision 3 to the 1958 Agreement (Paragraph 7) should be changed to include the extension/revision criteria for UN R0.

Request for clarification on procedures in paragraphs 7.4 and 7.5 of the Revision 3 to the 1958 Agreement.

Updated report from Japan’s MLIT consideration of the IWVTA procedures, identifying concern over the definition and verification of information contained in type approvals. Attachment 1 to this report lists the various items from type-approval certificates that MLIT found difficult to verify independently.

Updated MLIT report raising concerns over the way approval numbers reflect the supplements covered. The draft Revision 3 of the 1958 Agreement requires that each approval number include the applicable supplement number; however, the application for a change of the supplement number does not constitute application for an extension of the approval. As a result, the approval number will not be changed even if a different supplement comes into force, resulting in a product having a supplement number that is different from the actual number of the supplement in force.

Illustration of the UN Regulation approvals information sheet as proposed in the related document SGR0-19-13, superseding the previous attachment SGR0-19-13/att.1.

Report highlights that regulations under IWVTA may not apply equally to two vehicles of the same type; for example, application of high voltage protection provisions only to electrified vehicles, but not their ICE homologue.

Proposal to clarify that the component approvals underpinning a vehicle type approval do not have to have been issued to the same manufacturer, but that the responsibilities of the manufacturer applying for vehicle type approval to the type approval authority nonetheless remain intact.

Presentation of a proposal for type approval authority “attestations” to address cases where a UN Regulation contains provisions not required in all markets. For example, UN R48 contains provisions for daytime running lamps presently required in the EU but not in Japan. An attestation would declare a vehicle compliant with all aspects of UN R48 except that the vehicle is not fitted with DRL.

Revised question no. 13 pursuant to the subgroup discussions.

Proposal to add item 2, Masses and Dimensions, to the information document in Annex 5 because “the technically permissible maximum laden mass” is a criterion for determining the version.

Proposal to delete references to emission and fuel consumption because these attributes are not currently within the scope of IWVTA.

Proposal to add information provided concerning the vehicle type.

Proposal to delete the Supplement number from the approval since supplements are not extensions and do not require renumbering under 1958 Agreement procedures.

Proposal to delete exhaust and fuel consumption provisions since these attributes are regulated by contracting parties and national authorities.

Description of two approaches for the development of the international whole vehicle approval system either by beginning with a limited regulatory scope (with Contracting Parties specifying additional national requirements) or by beginning with an absolute universal IWVTA covering all applicable regulations with Contracting Parties using limited IWVTA for approvals that are narrower in coverage of underlying component regulations.

Proposal from the Netherlands on behalf of the Database for the Exchange of Type Approval information (DETA) informal group. Similar to the decision to delete Commercial Name from the Document of Conformance (DoC), the DETA group proposes to remove the “Make” (i.e., trade name) and “Location of VIN”.

Presentation concerning how an IWVTA could relate to the structure of individual national or regional whole vehicle approval systems. In some cases, there may be a one-to-one relationship between the international and local whole vehicle approvals. In others, a single IWVTA may correspond to more than one local approval while in others, multiple IWVTA may be required to correspond to a broader local definition of a whole vehicle approval.

Tyre rolling resistance falls outside the scope of UN R0 because this attribute is used in the calculation of C02 emissions and IWVTA does not include UN R83 or UN R101.

UN R0 does not define or describe the family type (Type). Therefore, the first instance of an IWVTA should provide a type in order to establish the family type.

The Communication requirement of UN R0 follows that of the EC-WVTA and refers to the attachment of an information package. Germany proposes that this reference be replaced with an index of attachments referring to the relevant information document and test report(s).

Proposal to exclude exhaust emission level and fuel consumption from the definition of a version until the exhaust emission requirements and the fuel consumption requirements are added to Annex 4. The concern is that limits vary across Contracting Parties and changes to a CP limit would require issuance of an new version based upon a new application for IWVTA approval.

Report raising concerns over the verification of compliance with lighting installation requirements under whole vehicle approval.

Proposal to remove the requirements to provide approval certificates for bulbs used in lamp units because approval procedures for lamp units involve the testing of the units with bulbs that comply with the requirements. Therefore, the UN R0 requirement to provide approval certificates for both lamp units and the bulbs used in those units appears redundant.

Report from Japan’s MLIT consideration of the IWVTA procedures, identifying concern over the definition and verification of information contained in type approvals. Attachment 1 to this report lists the various items from type-approval certificates that MLIT found difficult to verify independently.

Under the draft IN R0, Annex 5, Part III requires applicants to furnish the list of type approvals, including approval number, upon which the whole vehicle approval will be based. UN R0 would allow for limited whole vehicle (L-IWVTA) approvals based upon compliance with some, but not all of the UN Regulations incorporated within UN R0. MLIT believes that the information requested under Annex 5, Part III is insufficient to understand whether an application for an L-IWVTA or a universal approval (U-IWVTA) is complete with regard to the equipment installed on the vehicle to be approved or whether applicant has simply failed to provide complete information. MLIT proposes adding a column for the applicant to briefly note a reason for omitting a regulation.

Illustration of the UN Regulation approvals information sheet as proposed in the related document SGR0-19-13.

WP.29 adoption of the new IWVTA regulation (UN Regulation No. 0) is anticipated for March 2017 with an entry-into-force the following October. This initial regulation (00 series of amendments) will include UN Regulations as they stand prior to September 2, 2017. However, a number of these regulations contain transitional provisions such that new versions will enter into force during the 12 months following this cut-off date. Therefore, this document (updated from the earlier version) proposes a list of such regulations that would be included in the 01 series of amendments to UN R0 to be submitted for adoption by WP.29 in November 2017. In concept, UN R0 would be updated with these “upgraded” versions of the UN Regulations.

MLIT report raising concerns over the way approval numbers reflect the supplements covered. The draft Revision 3 of the 1958 Agreement requires that each approval number include the applicable supplement number; however, the application for a change of the supplement number does not constitute application for an extension of the approval. As a result, the approval number will not be changed even if a different supplement comes into force, resulting in a product having a supplement number that is different from the actual number of the supplement in force.

OICA proposal, updated by the SGR0 Pre-test task force coordinator, for the organization and rules of procedure for validating the proposed whole vehicle type approval regulation.

WP.29 adoption of the new IWVTA regulation (UN Regulation No. 0) is anticipated for March 2017 with an entry-into-force the following October. This initial regulation (00 series of amendments) will include UN Regulations as they stand prior to September 2, 2017. However, a number of these regulations contain transitional provisions such that new versions will enter into force during the 12 months following this cut-off date. Therefore, this document proposes a list of such regulations that would be included in the 01 series of amendments to UN R0 to be submitted for adoption by WP.29 in November 2017. In concept, UN R0 would be updated with these “upgraded” versions of the UN Regulations.

Review of work towards adapting and/or approving certain UN Regulations for use within the International Whole Vehicle Type Approval regulation.

A complete and comprehensive review of the UN R0 base document for the 19th SGR0 meeting performed by experts from OICA.

Current draft text including changes made during the 18th subgroup session and prepared as the basis for discussions during the 19th subgroup session.

This document provides information on the expected operation of the IWVTA system and includes a new question on the impact of changes to a UN Regulation included within the IWVTA on whole vehicle approvals issued prior to the modification of the individual regulation.

Proposed agenda for the September 9, 2015 session of the task force coordinating the testing of the International Whole Vehicle Type Approval system.

Second proposal from the UN R0 Pre-testing Task Force for validating the international whole vehicle type approval regulation.

Draft form for pre-testing participants to use in reporting errors, concerns, or other issues during the validation phase of the international whole vehicle type approval regulation.

Proposal to clarify the wording of the type approval communication form.

Status of work on certain regulations, including braking, lighting, fuel tanks, rear vision, and tyres, towards their inclusion within the international whole vehicle type approval program.

Proposed text to explain procedures for the withdrawal or revocation of a whole vehicle type approval, including differences between a universal (U-IWVTA) approval and a limited (L-IWVTA) approval.

Draft text reflecting the outcomes of the 16th subgroup session.

Proposal to address situations where the requirements or scope of a regulation change between versions in order to ensure that each whole vehicle type approval meets the requirements of the later version.

Dutch discussion paper arguing that the DETA system unique identifier should not be mandatory under IWVTA.

Proposal to clarify that IWVTA-aproved vehicles remain subject to any additional national or regional requirements that may apply within a given market.

Proposal to set up a trial/pilot program involving type approval authorities, technical services and manufacturers to test the operation of the International Whole Vehicle Type Approval system.

Proposal for a working group on the “Administration of the International Whole Vehicle Type Approval System and the Exchange of Type Approval Data” to oversee the implementation and administration of the IWVTA and DETA systems.

This document proposes to replace an item in the information document for IWVTA. The reason is that the previous entry “maximum hourly output” is not defined anywhere in the UN Regulations whereas the newly proposed item “maximum 30 min. power” is defined in UN R85.

Status of work on adapting current UN Regulations for use in the whole vehicle type approval system. “List B” covers UN Regulations that should be included in the approval system but which require some adjustments before they can be transferred to the “List A” of regulations confirmed for inclusion in the whole vehicle approval.

Proposal for a permanent working group to manage the administration and further development of the international whole vehicle type approval system.

Proposal to amend the paragraph concerning the modification of a vehicle type and extension or modification of approval.

Proposal to amend the paragraph concerning the modification of a vehicle type and extension or modification of approval.

Proposal for provisions concerning a “Declaration of Conformance” for vehicles approved under the International Whole Vehicle Type Approval regulation.

Proposal to insert language into the definition of a vehicle type clarifying the application (or non-application) of regulations included in the IWVTA across variants of a single type-approved vehicle in order to avoid scenarios where a single vehicle type could have more than one type approval or an approval under a non-applicable regulation (say, electrified vehicle requirements for a non-electrified variant of a vehicle type) could be demanded for a vehicle variant.

Proposal for a permanent working group to manage the administration and further development of the international whole vehicle type approval system.

Proposal for a permanent working group to manage the administration and future development of the international whole vehicle type approval system.

Request to move UN R44 on child restraint systems to the “B list” of regulations (eventual consideration for inclusion in the whole vehicle type approval) from the “A list” of regulations identified for use in the first phase implementation of the IWVTA system.

OICA request to omit the proposed declaration of conformity provisions from the first phase implementation of the IWVTA, essentially arguing that the additional declaration is not justified in the context of type approval.

Annex 4 (“List of requirements for the purpose of IWVTA: List of regulatory acts”) contains the list of UN Regulations that would comprise the whole vehicle type approvals.

Draft presentation for review by the SGR0 subgroup on the second draft of UN Regulation No. 0 second as
submitted to WP.29 for consideration during its 164th (November 2014) session.

Draft UN R0 with introduction and revised paragraphs 12 and 13.

OICA proposal for the “Information document for the purpose of IWVTA” that retains in the document only those entries that are essential for the identification of a vehicle type and its variants or describe important properties of the whole vehicle. This proposal also deletes entries not relevant for category M1 vehicles.

The document proposes revised wording for the introduction of a Declaration of Conformance (DoC) for the vehicles approved according to the draft UN Regulation No. 0 concerning whole vehicle type approvals.

Proposals to modify UN Regulations 10 and 14 to address requirements under Australian law.

OICA strongly supports the German proposal and seeks clarification of certain points.

Responses to the IWVTA group questionnaire sent to Contracting Parties to the 1958 Agreement in order to determine readiness to apply the international whole vehicle type approval system (UN Regulation No. 0) and to raise any issues that might impede its development and use.

Proposal for revised guidelines and procedures for UN Regulations pursuant to the development of the International Whole Vehicle Type Approval system, including a procedure for exemptions of new technologies from current UN Regulation requirements and the procedure for updating the IWVTA regulation (proposed UN R0).

Version including a revised paragraph 12 transmitted by the Russian Federation and OICA.

Updated status of deliberations on aligning certain UN Regulations with the requirements of the proposed international whole vehicle type approval system.

Questionnaire for 1958 Agreement contracting parties to solicit input on the UN Regulations to include in the whole vehicle type approval. In addition, the questionnaire solicits input concerning replacement parts. Under IWVTA, a contracting party could apply UN Regulation 0 and accept type-approved vehicles while not necessarily applying all the regulations included in the whole vehicle approval. This raises the prospect of a situation where a contracting party accepts a type-approved vehicle but not all the type-approvals of replacement parts used for its maintenance.