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?

Yes

Type of Barrier

Operational barriers

Assessment Severity

Assessment

While relevant regulations are in place, the LAP is associated with economic and operational barriers when it comes to buses and trucks.
The experience from the so far only one bus project in Norway is that getting EU type approval took 3 months. Subsequent approval by national authorities did not take long. A physical inspection plus paper work that in total amounted to 1–2 weeks. For the ongoing project involving trucks, it is not known exactly what the implication of the lack of pre–existing whole vehicle type approval for trucks will be, in terms of time and cost. However, there is a good dialogue between the projects and the Norwegian Public Roads Administration.

Questions:

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

a - As a hydrogen vehicle.

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

b - As a hydrogen vehicle.

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

c - None exist in Norway, not applicable.

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

d - As a hydrogen vehicle.

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

a - EU type–approval is generally applicable.

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

b - National type–approval is applicable for small series.

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

c - Individual type–approval is applicable in a number of cases, specified in the national Regulation on approval of cars and towed vehicles (car regulation) / Forskrift om godkjenning av bil og tilhenger til bil (bilforskriften).

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 – The Directorate of Public Roads (Vegdirektoratet) b) for individual vehicle registration i. cars (incl. taxis) ii. buses iii. trolleybuses iv. trucks – The Norwegian Public Roads Administration (Statens Vegvesen) (the registration may be carried out by one of their local traffic stations, or by a car dealer with access to the system Autoreg.)

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 - Yes, there are special requirements for hydrogen vehicles, as defined by Regulation (EC) No. 79/2009 of the European Parliament and Regulation (EC) 406/2010 of the Council on type–approval of hydrogen–powered motor vehicles.

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

b - Yes, there are special requirements for hydrogen vehicles, as defined by Regulation (EC) No. 79/2009 and Regulation (EC) 406/2010 of the European Parliament and of the Council on type–approval of hydrogen–powered motor vehicles.

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

c - Not applicable.

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 - Yes, there are special requirements for hydrogen vehicles, as defined by Regulation (EC) No. 79/2009 and Regulation (EC) 406/2010 on type-approval of hydrogen-powered motor vehicles. Presently, no general type–approval for trucks has been made. The experience from an ongoing project in Norway is that while the components are approved, their combination in a truck requires a separate, individual-type approval. While it is likely that the regulations for cars may be applied, the requirements for trucks have not been specified yet and we have no specific data on duration and costs. )

Describe the comparable technology and its relevance with regard to hydrogen

Comparable technologies are vehicles using biogas or natural gas. Most of the requirements pertain to pressurized gas in general, but Regulation EC no. 79/2009 and regulation EC no. 630/2012 define specific test procedures for different types of hydrogen containers and components.

National legislation:

Regulation on change in the regulation of technical requirements and approval of vehicles, components and equipment (Vehicle Regulation) / Forskrift om endring i forskrift om tekniske krav og godkjenning av kjøretøy, deler og utstyr (kjøretøyforskriften), of 17.01.2012
The text is just a brief note, referring to the implemented change.
Regulation on approval of cars and towed vehicles (car regulation) / Forskrift om godkjenning av bil og tilhenger til bil (bilforskriften), last amended 09.02.2017
Paragraph 5 sets out the requirements for type approval of various vehicles. Approval of prototypes are valid for a limited time period of up to 2 years, and may be extended with another 1 year only.
Annex I, Technical requirements for prototypes, implements EC regulation 630/2012 .
A new vehicle may be presented for individual approval,
if it belongs in a group where EC type approval is not obligatory,
if they are individually presented for approval,
if all parts and components are EU approved,
if they are in vehicle group M1 and N1 and produced in large series for countries outside the EC/EEA (ref. regulation EC 183/2011),
if they are modified, after first being EC type approved or by national approval for cars and towed vehicles in small series,
if they are presented for individual approval following step–wise EC type approval or national small series type approval,
if they are individually approved in another EEA country.
Annex III defines technical and administrative requirements that may be used as alternatives to those of the framework directive.
Paragraph 10a, 10b and 10c; special exceptions.
Paragraph 20; Fees, specified for different categories of vehicles.
Regulation of technical requirements and approval of vehicles, vehicle components and vehicle equipment (vehicle regulation) / Forskrift om tekniske krav og godkjenning av kjøretøy, deler og utstyr (kjøretøyforskriften), of 1997, last amended 01.07.2017
Chapter 3; EEC type approval of cars and towed vehicles. Chapter 5; EC approval of tractors and trailers. Chapter 6; national approval. Chapter 8; special vehicles (including buses. Chapter 22; fuel system, Annex 1; List of technical requirements, with reference to the relevant EC regulations
Regulation on change in the Norwegian regulation of approval of cars and towed vehicles / Forskrift om endring i forskrift om godkjenning av bil og tilhenger til bil, of 14.05. 2013.

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