Type approval & Individual vehicle registration - Process

This LAP analyses:
• The classification of hydrogen vehicles for type approval purposes,
• The applicable types of type approvals,
• The responsible approval authorities, and
• The differences in type approval process of hydrogen vehicles compared to conventional vehicles.

Glossary:

Type approval means the procedure whereby a EU Member State certifies that a type of vehicle, system, component or separate technical unit satisfies the relevant administrative provisions and technical requirements.
Motor vehicle registration is the registration of a motor vehicle with a government authority. The purpose of motor vehicle registration is to establish a link between a vehicle and an owner or user of the vehicle. While almost all motor vehicles are uniquely identified by a vehicle identification number, only registered vehicles display a vehicle registration plate and carry a vehicle registration certificate.
Council Directive 1999/37/ EC on the registration documents for vehicle/.
Registration means the administrative authorisation for the entry into service in road traffic of a vehicle, involving the identification of the latter and the issuing to it of a serial number, to be known as the registration number.

Pan-European Assessment:

The type approval process for hydrogen powered vehicles does not in general differ from that of conventional vehicles, however the hydrogen systems and components have to undergo a number of specific tests.

The requirements and procedures for the type approval of hydrogen powered vehicles are harmonized across EU and do not represent a structural barrier or a regulatory gap. Some issues may arise due to differences in interpretation, implementation and enforcement of the EU and UNECE regulations by national type -approval authorities. This may present an operational barrier and thus it is essential to ensure a correct and harmonised application of the type-approval procedures

select country:

Is it a barrier?

Assessment Severity

Assessment

The impact of the LAP is a minor one since if passenger cars or other power driven vehicles – fuelled by hydrogen – are viable from the economic perspective or required because of other politically determined reasons, usually the producers will take care of the approval. The producers are familiar with these procedures thus can achieve the necessary approvals in a very efficient way. An individual approval is not that common subsequently would increase the investment for the transportation device - in particular if taking into account that the type approval for hydrogen "fuelled" vehicles is still relatively seldom thus an individual approval will be time consuming and costly. According to our discussions with ÖAMTC (club of car and motorbike drivers) the type approval – even on an individual basis – is not to be regarded as a barrier

Questions:

Question 1 How is a hydrogen vehicle classified? (as an electric/gas/hydrogen vehicle?) a - cars (incl. taxis)

a - According to the taxation provisions (tax law), a hydrogen fuelled vehicle in which the fuel cell generates electricity is classified – regarding tax benefits – in analogy to an electric vehicle – even in case of a hybrid – fuel cell + battery which supports the market penetration of hydrogen fuelled vehicles because of the tax benefits attributed to this kind of cars. For the type approval the hydrogen vehicles are classified as hydrogen vehicles

Question 1 How is a hydrogen vehicle classified? (as an electric/gas/hydrogen vehicle?) b - buses

b - According to the law on power driven vehicles, hydrogen vehicles are classified as Alternative Fuel Vehicles (AFV).

Question 1 How is a hydrogen vehicle classified? (as an electric/gas/hydrogen vehicle?) c - trolleybuses

b - According to the law on power driven vehicles, hydrogen vehicles are classified as Alternative Fuel Vehicles (AFV).

Question 1 How is a hydrogen vehicle classified? (as an electric/gas/hydrogen vehicle?) d - trucks

b - According to the law on power driven vehicles, hydrogen vehicles are classified as Alternative Fuel Vehicles (AFV).

Question 2 What type of type-approval is applicable? a - EU

a - The Minister of Transportation, Innovation and Technology is responsible for the issuance, amendment, extension and denial of EU type approvals in line with the provisions of Directive 2007/46/EC and Regulations 167/2013 and 168/2013.

Question 2 What type of type-approval is applicable? b - National

b - The Minister of Transportation, Innovation and Technology is responsible for the national type approval. The approval has to be issued if the required data are provided and are in line with the requirements of the law on power driven vehicles and the thereto related ordinances ( see § 28 of the law on power driven vehicles)

Question 2 What type of type-approval is applicable? c - Individual

b - The Minister of Transportation, Innovation and Technology is responsible for the individual approval. The approval has to be issued if the required data are provided and are in line with the requirements of the law on power driven vehicles and the thereto related ordinances ( see § 28 of the law on power driven vehicles)

Question 3 Which is the responsible approval authority? a) for the type approval i. cars (incl. taxis) ii. buses iii. trolleybuses iv. trucks b) for individual vehicle registration i. cars (incl. taxis) ii. buses iii. trolleybuses iv. trucks

a) for the type approval i. cars (incl. taxis) ii. buses iii. trolleybuses iv. trucks – Ministry of transport, Innovation and Technology b) for individual vehicle registration i. cars (incl. taxis) ii. buses iii. trolleybuses iv. trucks – Testing laboratory of the regarding Federal State (Bundesland = KFZ Zulassungsstelle)

Question 4 Is there a difference in the type approval process for a hydrogen vehicle compared to a conventional vehicle? a - cars (incl. taxis)

b - A hydrogen "fuelled" car is regarded as power driven vehicle, thus has to follow - as “conventional” vehicles - the provisions of the law on power driven vehicles.Therefore there is no difference regarding type approval process.

Question 4 Is there a difference in the type approval process for a hydrogen vehicle compared to a conventional vehicle? b - buses

b - A hydrogen "fuelled" bus is regarded as power driven vehicle, thus has to follow - as “conventional” vehicles - the provisions of the law on power driven vehicles.Therefore there is no difference regarding type approval process.

Question 4 Is there a difference in the type approval process for a hydrogen vehicle compared to a conventional vehicle? c - trolleybuses

c - A hydrogen "fuelled" trolley bus is regarded as power driven vehicle and has to follow - as conventional vehicles - the provisions stated in the law on power driven vehicles, therefore there is no difference regarding type approval process.

Question 4 Is there a difference in the type approval process for a hydrogen vehicle compared to a conventional vehicle? d - trucks If yes, please specify, e.g. how long does the procedure take and what are the costs to obtain a type approval?

c - A hydrogen "fuelled" truck is regarded as power driven vehicle and has to follow - as conventional vehicles - the provisions stated in the law on power driven vehicles, therefore there is no difference regarding type approval process.

Describe the comparable technology and its relevance with regard to hydrogen

The type approval can be regarded as comparable to the type approval of a CNG, LNG or electric vehicle. CNG means the application of high pressurized natural gas – highly explosive whereas LNG uses – as storage – liquefied natural gas – which generates boil off gas

National legislation:

Law on power driven vehicles = Kraftfahrgesetz
The provisions of this Federal Act apply to motor vehicles and trailers used on public roads (section 1 (1) of the Law on power driven vehicles 1960 – StVO, 1960, BGBl. and to apply to traffic with these vehicles on such roads.
Regulation on the execution of the Law on power driven vehicles = Kraftfahrgesetz–Durchführungsverordnung

EU Legislation:

Directive 2007/46/EC of the European Parliament and of the Council of 5 September 2007 establishing a framework for the approval of motor vehicles and their trailers, and of systems, components and separate technical units intended for such vehicles
Directive 2007/46 establishes a framework for the type approval of motor vehicles classes M (passenger cars and busses), N (trucks), O (trailers), and of systems and components intended for such vehicles
Specific technical requirements concerning the construction and functioning of vehicles is laid down in subsequent regulatory acts, the exhaustive list of which is set out in Annex IV.
Regulation (EC) No 79/2009 of the European Parliament and of the Council of 14 January 2009 on type–approval of hydrogen–powered motor vehicles, and amending Directive 2007/46/EC
This Regulation shall apply to hydrogen–powered vehicles of categories M and N, as defined in Section A of Annex II to Directive 2007/46/EC, including impact protection and the electric safety of such vehicles.

Regulation (EC) No. 79/2009 (hydrogen regulation) amends Directive 2007/46 with the aim to specify harmonized safety requirements for hydrogen-powered vehicles based on an internal combustion engine or a fuel cell.

Regulation 79/2009 lays down fundamental provisions on requirements for the type–approval of motor vehicles with regard to hydrogen propulsion, for the type–approval of hydrogen components and hydrogen systems and for the installation of such components and systems.
Commission Regulation (EU) No 406/2010 of 26 April 2010 implementing Regulation (EC) No 79/2009 of the European Parliament and of the Council on type–approval of hydrogen–powered motor vehicles
Regulation 406/2010 contains detailed technical specifications and test procedures, including, but not limited to:
• Administrative provisions for EC type-approval of a vehicle with regard to hydrogen propulsion (Article 2)
• Administrative provisions for EC component type-approval of hydrogen components and systems (Article 3)
• Requirements for the installation of hydrogen components and systems designed to use liquid hydrogen on hydrogen powered vehicles
• Requirements for hydrogen containers designed to use compressed (gaseous) hydrogen
• Vehicle identification requirements
Commission Regulation (EU) No 630/2012 of 12 July 2012 amending Regulation (EC) No 692/2008, as regards type–approval requirements for motor vehicles fuelled by hydrogen and mixtures of hydrogen and natural gas with respect to emissions, and the inclusion of specific information regarding vehicles fitted with an electric power train in the information document for the purpose of EC type–approval.
Regulation 692 / 2008 contains inter alia general requirements for type-approval and other provisions related to the application for EC type-approval of a vehicle with regard to emissions and access to vehicle repair and maintenance information

Regulation 630/2012 extends the scope of Regulation (EC) No 692/2008 to hydrogen fuel cell vehicle
Commission Regulation (EC) No 692/2008 of 18 July 2008 implementing and amending Regulation (EC) No 715/2007 of the European Parliament and of the Council on type–approval of motor vehicles with respect to emissions from light passenger and commercial vehicles (Euro 5 and Euro 6) and on access to vehicle repair and maintenance information.
Regulation 692 / 2008 contains inter alia general requirements for type-approval and other provisions related to the application for EC type-approval of a vehicle with regard to emissions and access to vehicle repair and maintenance information

Regulation 630/2012 extends the scope of Regulation (EC) No 692/2008 to hydrogen fuel cell vehicle
Commission Directive 2003/127/EC of 23 December 2003 amending Council Directive 1999/37/EC on the registration documents for vehicles
In view of the increasing introduction of electronic and telematics equipment in vehicles, the Annexes to Directive 1999/37/EC should be adapted to scientific and technical progress to allow Member States to issue vehicle registration documents in microprocessor smart card format instead of paper documents.
Council Directive 1999/37/EC of 29 April 1999 on the registration documents for vehicles
Council Directive 1999/37/EC of 29 April 1999 on the registration documents for vehicles The registration of vehicles in EU, irrespective on the power train or type of fuel is partly regulated by Council Directive 1999/37/EC on the registration documents of vehicles, amended with Directive 2003/127/EC. Both directives are transposed in partner countries and for registration documents applies mutual recognition. Vehicle registration requirements and procedures are subject to the national law.
Directive 2014/45/EU of the European Parliament and of the Council of 3 April 2014 on periodic roadworthiness tests for motor vehicles and their trailers and repealing Directive 2009/40/EC Text with EEA relevance (with effect from 20 May 2018)
This Directive establishes minimum requirements for a regime of periodic roadworthiness tests of vehicles used on public roads. This applies to vehicles with a design speed exceeding 25 km/h of the following categories: M1, M2 and M3 (passenger motor vehicles, N1, N2 and N3 (motor vehicles for the carriage of goods, O3 and O4 (trailers over 3,5 tonnes) L (two or three wheels over 125cm3).
Commission Regulation (EU) 2017/1151 of 1 June 2017 supplementing Regulation (EC) No 715/2007 of the European Parliament and of the Council on type-approval of motor vehicles with respect to emissions from light passenger and commercial vehicles (Euro 5 and Euro 6) and on access to vehicle repair and maintenance information, amending Directive 2007/46/EC of the European Parliament and of the Council, Commission Regulation (EC) No 692/2008 and Commission Regulation (EU) No 1230/2012 and repealing Commission Regulation (EC) No 692/2008
Commission Regulation (EU) 2018/1832 of 5 November 2018 amending Directive 2007/46/EC of the European Parliament and of the Council, Commission Regulation (EC) No 692/2008 and Commission Regulation (EU) 2017/1151 for the purpose of improving the emission type approval tests and procedures for light passenger and commercial vehicles, including those for in-service conformity and real-driving emissions and introducing devices for monitoring the consumption of fuel and electric energy
Regulation (EC) No 715/2007 of the European Parliament and of the Council of 20 June 2007 on type approval of motor vehicles with respect to emissions from light passenger and commercial vehicles (Euro 5 and Euro 6) and on access to vehicle repair and maintenance information