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, Economic barriers

Assessment Severity

Assessment

Additional level of certification (including test and validation) for all forms of FCEVs . Additional time and cost for certification at EWVTA or small series / IVA level

Questions:

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

a - fuel cell electric

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

b - as a Fuel Cell Electric Bus

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

c - trolleybus is not a UK classification – ‘bus and coach’ is used as the certification category

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

d - there is no experience with trucks in the UK (only vans) so far. It is expected it will be consistent with other vehicle classes - so as a fuel cell electric (light, medium or heavy duty) truck

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

a - EU – based on EWVTA where available for the classification of vehicle

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

b - Small Series – national level for vehicles / vehicle types where the vehicle volume is low and the cost of seeking EWVTA is high (or the vehicle is a ‘retrofit’ ) in which case National Small Series Type Approval is appropriate

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

c - Individual Vehicle Approval is for manufacturing or importing single vehicles or very small numbers. IVA does not require Conformity of Production (CoP) as it us based on inspection of each vehicle.

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 UK Vehicle Certification Agency (VCA) is the designated UK Approval Authority and a Technical Service for all type approvals to automotive EC Directives and most UN Regulations b) for individual vehicle registration i. cars (incl. taxis) ii. buses iii. trolleybuses iv. trucks – Driver & Vehicle Licensing Agency DVLA

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 - In principle all vehicle follow the same EWVTA process and there is typically a 60% carry over for vehicle standard parts and equipment (brakes, lights, controls, steering, etc.) and the balance is for electrical drive (FC system) and H2 storage. With the H2 storage the most significant item requiring specific review against homologation requirements.. The first FCEV to obtain EWVTA was in 2010 and there has since been a variety of ‘templates’ to follow that make this more straightforward but it is still time consuming and costly (up to 12 months depending on the vehicle carry over from already approved parts – and up to 1M Euro depending on the extent of unique and witnessed test and validation work required to cover key components and full system)

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

b - Directive 2007/46/EC, as amended, introduced the basis of a European wide certification scheme for the Bus and Coach category of vehicle

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

c - In principle there is no difference; but note that the UK does not use the trolleybus category (bus & coach instead)

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 - In principle there is no difference - but there is no expereince with tucks at this stage in the UK

Describe the comparable technology and its relevance with regard to hydrogen

Hybrid and electric vehicles or gas fuelled vehicles

National legislation:

The Road Vehicles (Approval) Regulations 2009 (UK)
Section 4.1 substantially extends and revises the systems currently in operation under which new vehicles are approved for use on the road in the UK
Department for Transport – Vehicle Certification Agency - Vehicle Type Approval
VCA is the designated UK Approval Authority and Technical Service for type approval to all automotive European Community (EC) Directives and the equivalent United Nations Economic Community for Europe (ECE) Regulations. Vehicle Type Approval is the confirmation that production samples of a design will meet specified performance standard
Road Vehicle Registration and Licensing Regulations 2002
Legal obligations for registering, insuring and taxing any road going vehicle, for driver licensing, and for driving licenses and mandatory safety and service checks on all vehicles

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