ACEM Workshop on type-approval regulation
New legislation’s entry into force from 1 January 2014 prompted manufacturers to invite European Council representatives to delve into details of technical aspects
On the 10th of April ACEM, the European Motorcycle Industry Association, invited officials from all European Ministries of Transport for an informal exchange of views on the regulation on the type-approval and market surveillance of two- or three-wheel vehicles and quadricycles (COM 2010/542).
Given the complexity of the proposed legislation and the impending deadline for its application (1.1.2014), ACEM called on the Members of the Technical Working Party of the European Council for a meeting with the aim of offering an additional opportunity to exchange opinions on many open questions of the regulation currently under discussion.
Based on the positive turnout and feedback of the workshop organised in collaboration with the Polish Presidency last September, this event was an opportunity to informally exchange views with industry experts on issues related to the codecision act and the delegated acts. More than forty participants registered for this event showing high interest in the topic.
ACEM’s identified the main priorities for the industry, such as the calendar for technical and administrative requirements, and specific environmental issues, (Euro steps, durability, crankcase emissions, evaporative emissions, annexes).
Jacques Compagne, reiterating the industry concern about the economic crisis, said that this regulation should be proportionate and cost-effective, while also contributing to strengthen the PTW industry in Europe and abroad.
While ACEM supports the EC’s objectives of reducing emissions and improving road safety, it stresses the need to bring this regulation into a greater context, considering the stifling European market conditions as well as the global background.
Given the relatively small size of the EU market compared to other global markets, Mr Compagne underlined the need for global technical harmonisation of rules and urged policymakers to avoid creating a unique European regulatory context that would only create type approval inconveniences without helping the industry to compete on more promising markets.
The consequence of developing regulations only for the EU, will only lead to additional burden and costs for globally active manufacturers without benefits in terms of competitiveness.
Representatives from Italy, Spain, Germany, the Netherlands, Belgium, and the UK attended the workshop. MEPs also responded positively to the invitation, as well as officials from the European Commission and the European Economic and Social Committee.
Mr Wim van De Camp MEP and Rapporteur of the Regulation, confirmed the Parliament’s willingness to reach an adequate solution of the most debated issues.
Furthermore, Mr van De Camp showed the intention of the Parliament to try to find a compromise on the issue of braking, which a recent Impact Assessment Study commissioned by the IMCO Committee could not clarify.
Hendrik von Kuenheim, Acem President and Managing Director of BMW Motorrad, ” Legislation should aim at strengthening manufacturing in Europe as well as efficiently promoting international harmonization of regulations. ACEM recently called on EU Institutions to acknowledge the difficulties faced by the industry in this economic downturn, and asked that some key aspects in the currently discussed type-approval regulation should be carefully re-considered and properly researched, taking stock of the stifling situation in Europe for the manufacturing industry. ACEM welcomes CARS21 discussions developing in this direction, following the moratorium concept proposed by Antonio Tajani, European Commissioner for Industry.”
CARS21
As part of the Commission’s modern industrial policy, the CARS 21 (Competitive Automotive Regulatory System for the 21st century) process, which was initially launched in 2005, aims to make recommendations for the short-, medium-, and long-term public policy and regulatory framework of the European automotive industry. This framework enhances global competitiveness and employment, while sustaining further progress in safety and environmental performance at a price affordable to the consumer.
As a participant in CARS 21 ACEM asked to consider placing the Powered Two-Wheeler sector under the concept of moratorium. Antonio Tajani, EU Commissioner for Industry, previously stated that given the enduring crisis of the automotive industry, in order to safeguard manufacturing in the EU, the idea of a moratorium should be taken into consideration.
A re-evaluation of certain aspects of the regulation appears therefore necessary. The introduction of some of the requirements should be adjusted and phased-in to prevent PTW manufacturers’ costs from rising immoderately beyond consumer acceptance and contribute to the sustainability of European production plants.
For more information CARS 21 visit the CARS21 webpage
ACEM Presentation
Some quotes taken from the ACEM presentation
“Based on reasonable estimate, the regulation will cost to Consumers and Industry over the next 8 years about 2.5 billion Euro”
“ACEM supports the EC’s high level objectives (environment, safety, and simplification) – But some regulatory elements are devised beyond what would be reasonably expected in terms of proportionality”
“If disproportionate approach is maintained, a re-evaluation of ACEM position is needed – Moratorium concept (re VP Tajani’s declaration on automotive legislation early March)”
“Many items are still a complete mystery to industry and to type-approval authorities (RVCR, RAR), – Some important items are still in the initial phase of conception (e.g. OBD) – ◦ Huge disagreement between Commission and industry on some key topics – that will be introduced in the first step (crankcase, durability, …).”
“Industry is not optimistic that this package will still be adopted by 1 January 2013 !”
“It is therefore absolutely not realistic to think that industry can apply the first step on 1 January 2014.”
“Also Type Approval Authorities and national administrations will face serious challenges to meet this deadline.”
“ACEM cannot accept the durability package currently specified by the Commission as it is unnecessarily complex, flawed its fundamental design, totally unproven and ignores harmonisation.”
“Engineering Analysis: TRL, the Commission’s consultants on durability informed us that the cycles were devised on paper, apparently from WMTC and the car SRC. No vehicle has ever completed the proposed test. Unacceptable! How can anyone have faith in a test where the results are unproven? Imagine the consequences for all if our vehicle designs were launched to the public on that basis?”
“Operation at constant full throttle is not real world, nor is it acceptable. How can this be sound engineering or representative of real world useage?”
“T. Bert (Thomas Bertram) Lance, the Director of the Office of Management and Budget in US President Jimmy Carter’s 1977 administration is widely attributed with the phrase “If it ain’t broke, don’t fix it”. In other words, don’t waste money and effort to solve a non-existent issue.”
Click to download the full presentation (PDF)
Original Source ACEM Newsletter – Click Here
Right To Ride Comments
What the industry is stating is that if it ain’t broke don’t fix it and it looks like member states are starting to agree with them.
If the proposal goes down the swanee, for a couple of things that would be a shame, e.g. labelling CO2 emissions and alignment with the automotive industry on emissions, but for all the rest of the stuff, we don’t think alot of people will lose too much sleep.
Regarding the Cars 21 Report this is exactly what we wrote to the Commission right at the beginning, the motorcycle industry should be given the same opportunities under the Cars 21 Report as the automotive industry – including a morotorium.
Brussels Tampers With Motorcycles – view pdf 307kb – Click Here
This is what we wrote in January 2010 in our paper to the Commission:
We would like to draw your attention to the CARS 21 report (2006). In its report on a Competitive Regulatory Framework for the European Automotive Industry, the CARS 21 High Level Group made recommendations in relation to better regulation in the Automotive Industry.
We have identified what we consider to be the most salient points which we would like to refer to the proposals for changes to the framework regulations for L category vehicles.
i) Principles concerning the quality of legislation:
• Generally, the EU should refrain from adopting technical legislation directly affecting the vehicle construction and functioning outside the type approval framework and at the same time consistency of type approval legislations should be improved.
• All automotive legislation should be performance-oriented, technology-neutral, and overprescriptive regulations should be avoided.
• The principle that regulations should only fix objectives in terms of measurable performances, not solutions, should be strictly respected. If there are exceptions, the criteria to accept them should be given.