Homologation process – key regulations and requirements for vehicle manufacturers

Homologation process – key regulations and requirements for vehicle manufacturers

The whole vehicle homologation process is quite complex, involving a series of tests on the vehicle itself and its components, as well as verification of the entire organization’s operations. One of the most important documents describing the scope of tests to be performed depending on the type of vehicle is Regulation (EU) 2018/858. This regulation outlines the rules that must be taken into account in the approval process. Another significant document, which came into effect on July 6, 2022, is Regulation 2019/2144 (describing the so-called General Safety Regulation, GSR).

 

Depending on the vehicle category, the scope of testing varies. The regulation distinguishes the following sets of requirements.

Category M includes motor vehicles intended for the transport of passengers, having at least four wheels, with the following subcategories:

  • Category M1: vehicles for passenger transport, with no more than eight seats in addition to the driver’s seat,
  • Category M1 small series: M1 category vehicles produced in smaller quantities. It is worth noting that the small series is only applicable to M1 and N1 categories and is characterized by a smaller scope of testing and easier approval requirements, but it also imposes a limit on the manufacturer to produce no more than 1,500 units annually. This limit applies to all vehicles produced by the manufacturer, not just those with small series approval,
  • Category M2: vehicles designed and constructed for passenger transport, with more than eight seats in addition to the driver’s seat and a maximum total mass not exceeding 5 t,
  • Category M3: vehicles designed and constructed for passenger transport, with more than eight seats in addition to the driver’s seat and a maximum total mass exceeding 5 t.

 

Category N includes motor vehicles having at least four wheels and designed and constructed for the transport of goods, including:

  • Category N1: vehicles designed and constructed for the transport of goods with a maximum total mass not exceeding 3.5 t,
  • Category N1 small series: N1 category vehicles produced in smaller quantities, with the same limitations as for the M1 small series,
  • Category N2: vehicles designed and constructed for the transport of goods with a maximum total mass exceeding 3.5 t but not exceeding 12 t,
  • Category N3: vehicles designed and constructed for the transport of goods with a maximum total mass exceeding 12 t.

 

It is important to note that the driver’s license categories do not directly relate to vehicle categories. For example, in Poland, it is possible to drive an electric vehicle with a GVW of 4.25 t with a category B driver’s license, which is a vehicle in category N2.

 

To obtain type-approval for a vehicle in the N1 small series category, the following regulations must be met:

  • Noise levels – Regulation (EU) No 540/2014 and UN ECE Regulation R51.03,
  • Fire protection (liquid fuel tanks) – Regulation (EC) No 661/2009 and UN ECE Regulation No 34,
  • Rear Underrun Protection Devices (RUPD) and their installation; rear underrun protection (RUP) – Regulation (EC) No 661/2009 and UN ECE Regulation No 58,
  • Mounting and attachment points for rear license plates – Regulation (EC) No 661/2009 and Regulation (EU) No 1003/2010,
  • Steering systems – Regulation (EC) No 661/2009 and UN ECE Regulation No 79,
  • Locks and door retention components – Regulation (EC) No 661/2009 and UN ECE Regulation No 11,
  • Audible warning devices and signals – Regulation (EC) No 661/2009 and UN ECE Regulation No 28,
  • Indirect vision devices and their installation – Regulation (EC) No 661/2009 and UN ECE Regulation No 46,
  • Vehicles and trailers in terms of braking – Regulation (EC) No 661/2009 and UN ECE Regulation No 13,
  • Passenger cars in terms of braking – Regulation (EC) No 661/2009 and UN ECE Regulation No 13-H,
  • Electromagnetic compatibility – Regulation (EC) No 661/2009 and UN ECE Regulation No 10,
  • Protection against unauthorized use of motor vehicles – Regulation (EC) No 661/2009 and UN ECE Regulation No 116,
  • Protection of drivers against the steering system in case of collision – Regulation (EC) No 661/2009 and UN ECE Regulation No 12,
  • Seats, their anchorages, and head restraints – Regulation (EC) No 661/2009 and UN ECE Regulation No 17,
  • Access to the vehicle and its maneuverability (reverse gear) – Regulation (EC) No 661/2009 and Regulation (EU) No 130/2012,
  • Speedometer assembly and its installation – Regulation (EC) No 661/2009 and UN ECE Regulation No 39,
  • Manufacturer’s plate and VIN – Regulation (EC) No 661/2009 and Regulation (EU) No 19/2011,
  • Seatbelt anchorages, ISOFIX anchorages, and ISOFIX top tether anchorages – Regulation (EC) No 661/2009 and UN ECE Regulation No 14,
  • Installation of lighting and light-signaling devices in motor vehicles – Regulation (EC) No 661/2009 and UN ECE Regulation No 48,
  • Reflective devices for motor vehicles and their trailers – Regulation (EC) No 661/2009 and UN ECE Regulation No 3,
  • Front and rear position lamps, stop lamps, and upper contour marker lamps for motor vehicles and their trailers – Regulation (EC) No 661/2009 and UN ECE Regulation No 7,
  • Daytime running lamps for motor vehicles – Regulation (EC) No 661/2009 and UN ECE Regulation No 87,
  • Side-marker lamps for motor vehicles and their trailers – Regulation (EC) No 661/2009 and UN ECE Regulation No 91,
  • Direction indicator lamps for motor vehicles and their trailers – Regulation (EC) No 661/2009 and UN ECE Regulation No 6,
  • Rear registration plate illumination devices for motor vehicles and their trailers – Regulation (EC) No 661/2009 and UN ECE Regulation No 4,
  • Sealed beam headlamps for motor vehicles with European asymmetric dipped-beam or main-beam headlamps or with both these types of headlamps – Regulation (EC) No 661/2009 and UN ECE Regulation No 31,
  • Filament lamps for use in approved lamp units of motor vehicles and their trailers – Regulation (EC) No 661/2009 and UN ECE Regulation No 37,
  • Headlamps for motor vehicles equipped with gas-discharge light sources – Regulation (EC) No 661/2009 and UN ECE Regulation No 98,
  • Gas-discharge light sources for use in approved gas-discharge lamp units of motor vehicles – Regulation (EC) No 661/2009 and UN ECE Regulation No 99,
  • Headlamps for motor vehicles equipped with filament lamps or LED modules emitting asymmetric dipped-beam or main-beam headlamps – Regulation (EC) No 661/2009 and UN ECE Regulation No 112,
  • Adaptive front lighting systems (AFS) for motor vehicles – Regulation (EC) No 661/2009 and UN ECE Regulation No 123,
  • Front fog lamps for motor vehicles – Regulation (EC) No 661/2009 and UN ECE Regulation No 19,
  • Towbar – Regulation (EC) No 661/2009 and Regulation (EU) No 1005/2010,
  • Rear fog lamps for motor vehicles and their trailers – Regulation (EC) No 661/2009 and UN ECE Regulation No 38,
  • Reversing lamps for motor vehicles and their trailers – Regulation (EC) No 661/2009 and UN ECE Regulation No 23,
  • Parking lamps for motor vehicles – Regulation (EC) No 661/2009 and UN ECE Regulation No 77,
  • Seat belts, restraint systems, child restraint systems, and ISOFIX child restraint systems – Regulation (EC) No 661/2009 and UN ECE Regulation No 16,
  • Location and identification of hand controls, tell-tales, and indicators – Regulation (EC) No 661/2009 and UN ECE Regulation No 121,
  • Defrosting and demisting systems for the windscreen – Regulation (EC) No 661/2009 and Regulation (EU) No 672/2010,
  • Windscreen wiping and washing systems – Regulation (EC) No 661/2009 and Regulation (EU) No 1008/2010,
  • Heating systems – Regulation (EC) No 661/2009 and UN ECE Regulation No 122,
  • Spray-suppression systems – Regulation (EC) No 661/2009 and Regulation (EU) No 109/2011,
  • Safety glazing materials and their installation in vehicles – Regulation (EC) No 661/2009 and UN ECE Regulation No 43,
  • Tyre installation – Regulation (EC) No 661/2009 and UN ECE Regulation No 64,
  • Tyres for motor vehicles and their trailers – Regulation (EC) No 661/2009 and UN ECE Regulation No 117,
  • External projections of vehicles – Regulation (EC) No 661/2009 and UN ECE Regulation No 26,
  • Exterior protective systems for cars (bumpers, front and rear protection systems) – Regulation (EC) No 661/2009 and UN ECE Regulation No 42.

 

In each case, it is necessary to individually analyze which of the mentioned regulations apply to the specific vehicle case and the specifics of the manufacturer, which, for example, depends on the vehicle’s equipment.

The full list of regulations and requirements is found in Regulation 2018/858, which is available at the link.

It should be noted that since the entry into force of this regulation, amendments or supplementary regulations have been published, changing the scope of the required type-approval tests, and it is necessary to continuously monitor the status of individual Regulations to obtain a complete picture of the type-approval requirements that are in force at any given time.

 

The tests according to the type-approval regulations are conducted by specialized entities holding accreditations for the respective regulations. For the testing entity to carry out the individual tests, it must have the appropriate infrastructure and equipment.

 

As an example, below we present a view of the cabin before testing according to Regulation R29, which checks the strength of the cabin.

 

Cabin of the vehicle before the strength test according to the UN ECE R29 regulation

 

Not every regulation requires such a specialized testing setup. In some cases, the vehicle manufacturer submits technical documentation, which is subject to verification and assessment, and based on the submitted documentation, a test report is issued. An example is Regulation R121 regarding the information displayed on the dashboard.

 

View of the vehicle’s electrical display with a description of the controls according to UN ECE R121 regulations
View of the vehicle’s electrical display with the displayed message according to UN ECE R121 regulations

 

After conducting the tests, these entities submit the technical documentation along with the test reports to the authority issuing type-approval certificates. In Poland, type-approval certificates are issued by the Director of the Transport Technical Supervision (TDT).

On July 6, 2022, the safety regulations specified in Regulation 2019/2144, known as the General Safety Regulation package (GSR, GSR2), came into force.

The last few years have been a very dynamic period in the area of type-approval regulations and very demanding, especially for vehicle manufacturers, as it forces a series of changes on them, meaning that manufacturers must constantly modify vehicle designs and adapt them to the new reality.