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
Is it a barrier?
Yes
Type of Barrier
Economic barrier
Assessment Severity
1
Assessment
It is not a regulatory barrier because the process is the same as of a conventional vehicle. It is however very costly to obtain a type approval. This makes it for a small company less attractive to have a development. E.g. Type approval for a bus could cost up to > €250.000. For a component such as a tank it already adds up to €30.000. Less costly it is if you buy certified components and than the type approval is only needed for the system. Unless there are no changes compared to the recent situation costs for specific, could be small series, type approval are high.

Questions:

Question 1 How is a hydrogen vehicle classified? (as an electric/gas/hydrogen vehicle?) a - cars (incl. taxis)
Applicable is the Regulation (EC) No. 79/2009 on type approval of hydrogen powered motor vehicles a ‘hydrogen-powered vehicle’ means any motor vehicle that uses hydrogen as fuel to propel the vehicle; ‘propulsion system’ means the internal combustion engine or fuel cell system used to propel the vehicle. There is NL guidance with regard to classification through the registration number, this must be in accordance with the fuel for the vehicle: for hydrogen this is a W. This is not the same as the type approval classification. https://kentekencheck.me/rdw-ovi/
Question 1 How is a hydrogen vehicle classified? (as an electric/gas/hydrogen vehicle?) b - buses
b - W for hydrogen is purely related to what must be included in the vehicle registration. For hydrogen, that is, as fuel category: W and is applicable for all categories M, N, O and L vehicles referred to in 2007/46 EG.
Question 1 How is a hydrogen vehicle classified? (as an electric/gas/hydrogen vehicle?) c - trolleybuses
c - W for hydrogen is purely related to what must be included in the vehicle registration. For hydrogen, that is, as fuel category: W and is applicable for all catgories M, N, O and L vehicles referred to in 2007/46 EG.
Question 1 How is a hydrogen vehicle classified? (as an electric/gas/hydrogen vehicle?) d - trucks
W for hydrogen is purely related to what must be included in the vehicle registration. For hydrogen, that is, as fuel category: W and is applicable for all catgories M, N, O and L vehicles referred to in 2007/46 EG.
Question 2 What type of type-approval is applicable? a - EU
a - In Europe the car or tank manufacturers can choose between the two regulations for the type–approval for hydrogen of their product: 1. The EC regulation n° 79/2009 on type–approval of hydrogen–powered motor vehicles, and its implementing directive EU406/2010 and 2. UN Regulation No. 134 Uniform provisions concerning the approval of motor vehicles and their components with regard to the safety–related performance of hydrogen fuelled vehicles.
Question 2 What type of type-approval is applicable? b - National
b - In Europe the car or tank manufacturers can choose between the two regulations for the type–approval for hydrogen of their product: 1. The EC regulation n° 79/2009 on type–approval of hydrogen–powered motor vehicles, and its implementing directive EU406/2010 and 2. UN Regulation No. 134 Uniform provisions concerning the approval of motor vehicles and their components with regard to the safety–related performance of hydrogen fuelled vehicles.
Question 2 What type of type-approval is applicable? c - Individual
c - It is possible to have a single or small series national type approval and it is then forbidden to use the vehicle outside the national boundaries.
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 - (Road Safety Directorate (RDW) b - for individual vehicle registration i. cars (incl. taxis) ii. buses iii. trolleybuses iv. trucks - This is also RDW, for a single or small series type approval you can obtain a national approval from RDW.
Question 4 Is there a difference in the type approval process for a hydrogen vehicle compared to a conventional vehicle? a - cars (incl. taxis)
a - The process is the same however, there are additional requirements because of the hydrogen system.
Question 4 Is there a difference in the type approval process for a hydrogen vehicle compared to a conventional vehicle? b - buses
b - The process is the same however, there are additional requirements because of the hydrogen system.
Question 4 Is there a difference in the type approval process for a hydrogen vehicle compared to a conventional vehicle? c - trolleybuses
c - The process is the same however, there are additional requirements because of the hydrogen system.
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?
d - The process is the same however, there are additional requirements because of the hydrogen system.
Describe the comparable technology and its relevance with regard to hydrogen
Conventional and electric vehicles.

National legislation:

EU Legislation: