1. Verification measures for CO2 HDV, COP and Ex-post verification provisions
ACEA Comments to Commission’s note of April
Editing Board
Brussels, april 26th

2. Verification measures for CO2 HDV
Background
Manufacturers obligations under the HDC CO2 regulation are to:
Determine the properties of the vehicle components etc. of major importance for fuel consumption and CO2 emissions (i.e. engines, transmissions, axels, body (air drag), auxiliaries and tyres) and apply for type approval of these the data
Apply for certification of the process to calculate the fuel consumption and CO2 emissions of each vehicle covered by the regulation by the means of the VECTO simulation tool provide by Commission
Ensure that the production of the components etc. conforms to the approved type, and the approved processes are maintained over time
The verification measures for the HDV CO2 regulation must be effective and proportionate, considering the regulatory requirements and the required efforts of customers, authorities and manufacturers

3. Verification measures for CO2 HDV
Commission's proposal Note on the conformity of production and ex-post verification provision in the procedures for the certification of the Co2 emissions form heavy duty vehicles, 14 March 2016
Commissions proposal; multi-level verification
Certification testing and approval, following principles of
Component + Process for CO2/FC determination
COP verification, following principles of 2007/46
Component + Process for CO2/FC determination
Ex-post verification of customer vehicles, in production - New procedure
Vehicle test comparing tested values with simulated values
Analysis of discrepancy to identify the root cause of a discrepancy
Independent data verification – New procedure? (re-calculation, vehicle tests?)
The purpose and added value is not clear
Periodic VECTO software and procedure verification – Provision in regulation?
Software and procedure verification by Commission
ACEA asks for further clarification/evaluation of these verification procedures

4. Verification measures for CO2 HDV
Principles
For efficient type approval verification measures:
The TAA granting the approval is the main intermediate of the manufacturer
Providing data should only be an obligation toward those parties that have an official role in the HDV CO2 type approval scheme
Verification measure outside of normal procedures in 2007/46 must be justified considering the objective of the test as well as the time required, the costs and the consequences for the customer and manufacturer
This should be considered especially for measures including vehicle testing; Ex-post verification and air drag type approval re-testing
These tests require specific test conditions, are complex, expensive and time consuming

5. Ex-post verification ACEA comments
The SICO test method is to be defined. Number of vehicles tested should be proportionate to the objective, see separate ACEA presentation
Test requirements results in a delayed delivery and an used vehicle to customers
Re-testing of air drag coefficient is not possible for many configurations, for practical and physical reasons
Verification of the rolling resistance of tyres should not be task of the vehicle manufacturer, but of the tyre manufacturer
Analysis of the results. Discrepancy will require analysis of the root cause (2nd draft regulation “until the root cause … has been identified).
Measures to be taken by the manufacturers need to be clearly defined. Measures must be restricted to verifying the provisions for the component and process approval
The appropriate way of verifying the input values provisions should be agreed with the TAA.(not automatically assuming re-testing)
The vehicle manufacturer must have the right to request a component manufacturer to verify the certified values of it’s component

6. Independent data verification
ACEA comments
Independent re-calculation by TAA for any vehicle. Please clarify :
What additional verification is expected by TAA and the added value, considering that re-calculation of CO2 values already is part of the process approval and COP checks by TAA?
The need for an additional procedure to the general safeguard clause in 2007/46?
Possibilities for TAA to independent test any vehicle (Ex-post verification?)
Consequences/burdens associated for manufacturers and customers need to be evaluated
Vehicle OEM cannot be made liable toward Member states for seprate activities outside of TA
Unrestricted access to data by national authorities of the Member states
ACEA support the principles, but normal procedures must be applied and data confidentiality must be ensured. TAA granting the approval is the main intermediate of the manufacturer .
Draft regulation suggest reporting of CO2 values to TAA for each vehicle covered by the regulation and placed on the market in EU
ACEA regards this as a new procedure, not according to normal TA reporting procedure
The TAA that grants the process approval will have to set up new databases to store the values (CoC of individual vehicles are not reported or stored at the TAA today)
The EEA will in parallel set up an European database to store the CO2 output values for the monitoring purposes

7. Verification measures for CO2 HDV
ACEA Recommendation/Conclusion
The proposed multi–level verification scheme needs to be further clarified and evaluated to decide on the appropriate scope, considering
The extent and burdens associated with the Ex-post verification vehicle test(s)
The need of yet another new procedure (independent data verification), in addition to Ex-post verification?
The obligations of the manufacturers, suppliers and authorities ( type approval authorities, and other Member state authorities)
The aim to minimize the necessary number of production vehicles needed for verification test (and cost /delay associated with the tests)