4.3

To limit these problems, the Committee thinks that some amendments could be made in order to make the process more efficient and effective, without however distorting or weakening the spirit and aims of the proposal. More particularly, the Committee proposes revising the following articles. Article 4(5): The reference vehicle on which the type-approval tests are to be conducted is defined as the version of vehicle which is identified by the approval authority as being the most problematic in terms of re-usability, recyclability and recoverability. If one considers all the fittings generally found in the same type of vehicle, identifying the reference vehicle is not always easy. To avoid misunderstandings between the different parties and save valuable time, it would be best to state explicitly that the reference vehicle will be decided by common accord of the manufacturer and the approval authority as being the most problematic in terms of re-usability, recyclability and recoverability. Article 5(3): Point 6.2.2 of the explanatory memorandum states that there will be physical checks on vehicle prototypes to verify the information submitted by the manufacturer and its suppliers as regards markings, nature of materials, masses of component parts, etc. Article 5(3) specifically mentions checks on the marking of component parts made of polymers or elastomers. In practice, however, the type-approval check is conducted on prototypes whose materials are ‘pre-series’ and are therefore not marked. A literal application of this provision would oblige the manufacturer to make special prototypes solely for the purpose of the inspections, thus exacerbating the already high cost of meeting all the other requirements of the directive. A less costly solution would be to amend Article 5(3) so as to require the approval authority to check that the manufacturer has taken steps (and the responsibility) to ensure that serially produced component parts made of polymers or elastomers are marked in accordance with requirements. The physical checks could always be carried out before the vehicles are put on the market, using those built during the type-approval process and used for the various tests (brakes, noise, safety, etc.), or – better still – could be carried out on the vehicles used for the production conformity checks. Article 10(3): This specifies that the requirements of the directive will be applied both to newly type-approved vehicles (i.e. new types) and newly registered vehicles (i.e. entire production range) 36 months after the directive enters into force. This deadline seems much shorter than that usually required in such situations; the deadlines for newly registered vehicles are usually two or three years after those for newly type-approved vehicles, as this gives manufacturers time to adapt vehicles already in production to the new requirements. Having a single deadline would create considerable problems for manufacturers as regards adapting their product and in terms of time and availability for obtaining type-approval of all their vehicle models. It must also be remembered that the type-approval process does not only involve manufacturers, but also technical bodies and approval authorities, who may also find it difficult to type-approve so many different types of vehicle in a short space of time. Accordingly, whilst not joining the calls for vehicles already in production to be exempted from the directive, the Committee thinks that Article 10(3) should be amended so that the new rules apply to newly registered vehicles not so soon after the entry into force of the directive (48 or 60 months rather than 36 months). Annex I(9): This specifies that for the purposes of checks on the materials and masses of component parts, the manufacturer must make available representative vehicles for each type of bodywork and component parts intended for these vehicles. This requirement again places significant burdens on both manufacturers and type-approval authorities, and does not seem essential for a proper type-approval process. For instance, there does not seem to be any point in testing all types of bodywork (three doors, five doors, people carrier), when here too it would be simpler just to take the version of the vehicle which presents the greatest recyclability problems.