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26 January 2022

European vehicle type approval

EUROCOC team
26 January 2022 10 min read
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European vehicle type approval

 Certificate of Conformity – COC Document

Mandatory manufacturer’s homologation label and 2-stage homologation

EC type-approval number

Extension of type approval number

Eventual problems with incorrect entry of an extension of type approval

 Certificate of Conformity – COC Document

A COC is a document by which the manufacturer certifies that a particular vehicle was manufactured in accordance with the EU legislation in force at the time of its production. It also certifies that the vehicle has been manufactured in accordance with the technical specifications approved for the given type of vehicle.

If a manufacturer plans to produce several vehicles of the same type, they have the possibility to request type approval at type approval bodies. During the type approval process, the technical inspection service will test a vehicle sample of the type of vehicle being manufactured and verify that the vehicle conforms to the type described. If so, the type approval authority shall grant type approval for that type. It is therefore not necessary for each production vehicle which conforms to the approved type to be assessed separately. Once type approval has been granted, the manufacturer undertakes to ensure conformity of production so that each vehicle conforms to the approved type.

When the manufacturer completes the vehicle, or part thereof, the car should be accompanied with a certificate of conformity (COC) corresponding to the type described in the specific type approval:

typ 1 | European vehicle type approval | EUROCOC

(Excerpt from COC)

The COC document can therefore only be issued for vehicles that have been type approved and therefore have a type approval number. However, even if a vehicle conforms to a type but has not been type approved, there is no COC available for that vehicle. This can happen for vehicles that are pre-produced in series.

As European production standards for vehicles in series are homologated, type approval granted by an EU Member State is valid throughout the EU. A vehicle may even be manufactured outside the EU, but if the manufacturer has a representative in the EU and the vehicle is manufactured for the EU market in accordance with a valid type approval, the COC for such a vehicle is available and the vehicle can be registered in the EU with the COC without necessity to undergo further approvals. The fact that European type approval is global and not just national ensures the free movement of motor vehicles within the EU.

Mandatory manufacturer’s homologation label and 2-stage homologation process

How do I find out if my vehicle has been type approved?

typ 2 | European vehicle type approval | EUROCOCThe manufacturer is obliged to affix a compulsory manufacturer’s homologation label to the vehicle, which, in the case of a type approved vehicle, bears, inter alia, the EC-type approval number.

 

 

 

If it is a vehicle being completed in more than one stage, the vehicle may have 2 type approvals, each corresponding to one stage and therefore the car has 2 mandatory labels, one of which states Stage 2.

typ 3 | European vehicle type approval | EUROCOC

Multi-stage type approval can be granted for either an incomplete or a complete vehicle type, and there is a separate COC for each stage of approval, while each COC indicates for which stage it is intended, e.g. EC certificate of conformity for incomplete vehicles, or EC certificate of conformity for completed vehicles, or EC certificate of conformity for complete vehicles.

typ 4 | European vehicle type approval | EUROCOC(Excerpt from COC)

 

 

 

Therefore, there are 2 COC certificates for some vehicles. However, often the vehicle is completed or modified by different manufacturers and therefore it is not always possible to obtain a COC for both stages of approval from the very same manufacturer. In this case, the manufacturer who completed or modified the vehicle should be contacted as they have the technical details of the modification or completion carried out. It is possible to find out who finished the vehicle from the manufacturer’s homologation label, which shows the name of the manufacturer. If it is a modification to a vehicle that has been type approved, the manufacturer who carried it out will also issue a certificate of conformity (COC) for stage 2.

As mentioned above, the manufacturer is obliged to place a so-called mandatory manufacturer’s homologation label (also called an approval plate or type plate) on the vehicle. If the vehicle has been type approved, the type approval number is indicated on this label.

 

typ 5 | European vehicle type approval | EUROCOCEC type-approval number

consists of several parts separated by an ‘*’.

Example: e11*2007/2046*0004*02

 

 

 

Part 1: lower case letter e followed by the code of the country issuing the type-approval. In this case (e11*) it is a type approval granted by the United Kingdom.

Part 2: Number of the basic directive or regulation. In this case (*2007/2046*) it is an approval under Commission Regulation No. 2007/2046.

Part 3: Number of the last amending directive or regulation. (To be given only if the Directive has been amended)

Part 4: Four-digit sequential number designating the base approval number. The sequence starts from 0001 for each basic directive or regulation. In this case (*0004*), it is therefore the 4th type-approval.

Part 5: Two-digit sequential number to designate the extension of type approval. The sequence starts from 00 for each base approval number. In this case (*02) it is the 2nd extension of approval.

Extension of type-approval

Every manufacturer naturally tries to improve the vehicles they produce and, in addition, the requirements that vehicles must meet change over time. Therefore, over time, manufacturers change the approved type and add additional features to it. However, the manufacturer must immediately inform the approval authority of any change.

The approval authority shall then assess the change and decide whether it requires a change in the form of a revision or extension of the type approval. If the approval authority considers that the changes to the data in the information package are significant to the extent that they cannot be covered by an extension of the existing type approval, it shall refuse to modify the EU type approval and shall require the manufacturer to apply for a new EU type-approval.

A change shall be marked as a ‘revision’ if, despite the change of data, the vehicle type concerned continues to comply with the applicable requirements for that type and no repeated inspections or tests are necessary. This means that the type approval remains the same.

However, if the changes extend beyond the validity of the current type approval and further inspections or new tests are required, the change shall be designated as an extension of the type approval. In this case, the approval authority shall extend the existing type approval and the extension shall be indicated by increasing the extension number by one (Part 5: e11*2007/2046*0004*02). In this case, the extension, also known as an addendum, would therefore be changed from 02 to 03.

After the extension of the type approval, the manufacturer shall continue to manufacture vehicles in accordance with the type described in the current extension. In this case, therefore, in accordance with the third extension of the type approval. For vehicles conforming to the extended type, the manufacturer shall issue a certificate of conformity (COC) bearing the current extension number. The type approval number is normally displayed on the manufacturer’s statutory plate without the extension number.

The type approval may be extended up to 99 times, but the extension number shall only ever be given for vehicles that were manufactured after the extension was approved. For existing, already manufactured vehicles, no information relating to the data with which the vehicle was manufactured may be changed. This means that even the extension number (supplement) is never changed for a manufactured vehicle.

For example, if the vehicle was manufactured in accordance with type approval e11*2007/2046*0004*02, this type approval number including the extension number will be shown on the COC document issued at the time of production. If the owner of the car requests a COC document after any period of time, the manufacturer will issue a duplicate COC which will still bear the same type approval number as was on the original COC. This means that even if, for example, after 15 years, the manufacturer produces this type of vehicle with the extension *58, i.e.: e11*2007/2046*0004*58, the owner of a vehicle produced 15 years ago will receive a COC duplicate showing the number with which his vehicle was produced, i.e., e11*2007/2046*0004*02.

In the past, some registration offices were sometimes unaware of this fact and entered an extension number on the registration certificate, which they only estimated…

Possible problems with incorrect entry of an extension of type approval

A real case to illustrate the problem:

A vehicle that was manufactured in conformity with the type approval e1*2001/116*0242*09 was sold and re-registered by a new owner several years after its production. The registration office only had the previous registration certificate and assumed that the extension number had increased over time and therefore only estimated how much the extension may have increased in the meantime. Consequently, they vehicle had been registered the vehicle with the type approval number: e1*2001/116*0242*17. The car was resold and exported a few years after this registration. For registration in the new country, the buyer needed a COC document and therefore requested a duplicate of COC from the manufacturer, which the manufacturer issued. The type approval number on the COC document was, of course, e1*2001/116*0242*09 and hence there was a mismatch between the COC document and the previous registration certificate. This mismatch caused the new owner problems when registering abroad. Since the specifications with which the vehicle was manufactured are “preserved” in the Certificate of Conformity (COC), the COC document is the most relevant source of information needed to register the vehicle. Therefore, in the end, the registration authority accepted that the type approval extension number on the technical certificate was incorrect and registered the vehicle on the basis of the correct information in the COC duplicate.

However, if the registration office refuses to register the vehicle because of different extension numbers (on the registration certificate and on the COC), the solution is also to contact the original registration office that entered the incorrect extension number on the registration certificate and ask it to correct this document or to confirm that the incorrect extension number has been indicated on the previous registration certificate.

The manufacturer may also provide vehicle data electronically directly to the registration authority. Registration authorities can then also draw information for vehicle registration from the shared data. However, it may happen that for some approved vehicle types the registration authority has no data in its system and therefore refuses to register such a vehicle even though it has the possibility to draw information from the COC document. In such a case, the registration authority is obliged to manually enter the data from the COC into the registration certificate. Refusal to register a vehicle on the grounds that the registration authority has no data on the vehicle when a COC is available is unjustified and the owner seeking registration of his vehicle based on the data in the COC document has the right to apply directly to the European Commission in Brussels. The registration authority is in breach of the EU directive under which the vehicle was type approved.

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