O1 Category Trailer - up to 750kg O2 Category Trailer - 750kg to 3500kg mass on the axles Trailer Type Approval Semin

1. 1

2. 2 Agenda Type Approval Process Type Approval Subjects Conformity of Production Support & Information services Application & Initial Contacts

3. 3

4. 4 ECWVTA Revised Framework Directive

5. 5 Which Type Approval route? As a Manufacturer, there are three options of approval available: IVA (Individual Vehicle Approval) - UK / Issuing member state only. Inspection of each vehicle, no limit on numbers, NO CoP NSSTA (National Small Series Type Approval) - UK only / Issuing member state only. A limit of 500 trailers belonging to one Type per year. There are however �eased� technical requirements ECWVTA (EC Whole Vehicle Type Approval) - Full technical & administrative requirements We will work through these in reverse order looking at the ones where we expect the least take up IVA � All vehicles need to be inspected, valid only in MS that issues, there are no limits on numbers and there is no requirement for a quality system - to be handled by VOSA, Now different kinds of type approval � we will explain type approval a bit more deeply shortly �Nat Small Series � Representative sample checked, valid only in MS that issues, limit on numbers in each MS, need a quality system �EC Small Series - (just for M1-cars NOT Special Purpose) but is mentioned here for completeness, sometimes people assume this is available to all categories - Representative sample checked, valid in ALL of EC, limit on numbers in EC, need a quality system �ECWVTA - Representative sample checked, NO limit on numbers, need a quality system, suited to high volume productionWe will work through these in reverse order looking at the ones where we expect the least take up IVA � All vehicles need to be inspected, valid only in MS that issues, there are no limits on numbers and there is no requirement for a quality system - to be handled by VOSA, Now different kinds of type approval � we will explain type approval a bit more deeply shortly �Nat Small Series � Representative sample checked, valid only in MS that issues, limit on numbers in each MS, need a quality system �EC Small Series - (just for M1-cars NOT Special Purpose) but is mentioned here for completeness, sometimes people assume this is available to all categories - Representative sample checked, valid in ALL of EC, limit on numbers in EC, need a quality system �ECWVTA - Representative sample checked, NO limit on numbers, need a quality system, suited to high volume production

6. 6 ECWVTA & NSSTA in a Nutshell Type Approval authorises a manufacturer to: Produce vehicles, systems and components to a proven specification and; Self-certify these as compliant with relevant legislation Two fundamental requirements: Meeting the technical and administrative requirements and capturing the design Ensuring that subsequent production is manufactured in conformance with the approved design Proof that the full range of vehicle specifications will comply with legislation Representative samples of a vehicle �Type� are selected and shown to meet the requirements Key design details are captured in a controlled �Information Document� Any change likely to affect the approved spec must be reviewed with VCA. Design, production, sourcing, critical processes etc Where necessary extensions or new approvals may be required prior to sale Proof that the full range of vehicle specifications will comply with legislation Representative samples of a vehicle �Type� are selected and shown to meet the requirements Key design details are captured in a controlled �Information Document� Any change likely to affect the approved spec must be reviewed with VCA. Design, production, sourcing, critical processes etc Where necessary extensions or new approvals may be required prior to sale

7. 7 Type Approval Hierarchy For NSSTA and ECWVTA there are three key steps to follow: Whole Vehicle Type Approval Trailer System Approvals Or Test Reports Brakes, Glass, Tyres, Lighting etc. Conformity of Production, Research & Development, etc. Type approval is a modular concept aimed at ensuring safety and environmental protection Components can be approved which in turn become part of a system which then are �wrapped up� in a whole vehicle approval Bulb ? Lamp ? Lighting Installation ? WVTAType approval is a modular concept aimed at ensuring safety and environmental protection Components can be approved which in turn become part of a system which then are �wrapped up� in a whole vehicle approval Bulb ? Lamp ? Lighting Installation ? WVTA

8. 8 Your Product Range and ECWVTA For NSSTA and ECWVTA your trailer range will be divided up using the following criteria. It is worth remembering that each Type needs its own Certificate of Approval. Type � Manufacturer Category Chassis (fundamental differences) Number of Axles Braking System (Braked, Un-braked) Variant � Body Style GVW difference >20% Steered Axles Version � Combination of Options Type approval is a modular concept aimed at ensuring safety and environmental protection Components can be approved which in turn become part of a system which then are �wrapped up� in a whole vehicle approval Bulb ? Lamp ? Lighting Installation ? WVTAType approval is a modular concept aimed at ensuring safety and environmental protection Components can be approved which in turn become part of a system which then are �wrapped up� in a whole vehicle approval Bulb ? Lamp ? Lighting Installation ? WVTA

9. 9 For ECWVTA and NSSTA the technical requirements cover the following:

10. 10 Regulation or Directive

11. 11 2007/46 Whole Vehicle Information Document

12. 12 Whole Vehicle Approval Hierarchy Three fundamental whole-vehicle Type Approval categories are available under both ECWVTA and NSSTA Complete vehicle approval - covers single-stage manufacture of a fully finished product 2. Incomplete vehicle approvals - controls the specification of a partially assembled vehicle - multiple approvals sometimes required - can reduce Type Approval requirements for the final stage manufacturer 3. Completed vehicle approval - final assembly of a multi-stage vehicle as a fully finished product There are 3 kinds of approval that are available The identified an subtly different ways The main bulk of vehicles will probably have EC Type Approval for single stage manufacture � panel vans, pick ups, etc. We assume people such as OEMs will get ECWVTA for Incomplete Vehicle and Body Builders will finish it off � the start of a Multi Stage Build process Body builders vehicle converters will get approval for COMPLETED vehicles - This is the end of the Multi Stage Build process There are 3 kinds of approval that are available The identified an subtly different ways The main bulk of vehicles will probably have EC Type Approval for single stage manufacture � panel vans, pick ups, etc. We assume people such as OEMs will get ECWVTA for Incomplete Vehicle and Body Builders will finish it off � the start of a Multi Stage Build process Body builders vehicle converters will get approval for COMPLETED vehicles - This is the end of the Multi Stage Build process

13. 13 The following information is to be used only as a guide. It should not be used as a substitute to the legislation.

14. 14 Fuel Tanks & Rear Protection Devices

15. 15 Rear Registration Plate Space

16. 16 Steering Effort

17. 17 Braking

18. 18 Braking

19. 19 Radio Interference

20. 20 Statutory Plates

21. 21 Statutory Plates

22. 22 Installation of Lighting

23. 23 Installation of Lighting

24. 24 Installation of Lighting

25. 25 Heating Systems

26. 26 Spray Suppression Systems

27. 27 Safety Glazing

28. 28 Tyre Installation

29. 29 Masses and Dimensions

30. 30 Masses and Dimensions

31. 31 Couplings

32. 32 Drawbars Drawbars need to be approved if they are a separate technical unit. The widely held view that bolt-on drawbars are separate technical units and drawbars welded to the main frame are not is incorrect The method of attachment is disregarded when determining if the drawbar is a separate technical unit

33. 33 What is classed as a Drawbar and requires approval?

34. 34 Couplings

35. 35 Couplings

36. 36 Transportation of Dangerous Goods

37. 37 A Plan of Action Work out what to do plan for going forward 2.Ensure that your product can meet the requirements �This shouldn�t be too difficult, most will be covered by C&U and RVLR, but it links understanding the legislation with your products �Create the necessary documentation � your trade bodies are likely to have a role here and VCA will produce samples and guides 3.the modular type approval process (as explained earlier) kicks in, �you need to get the things you are responsible for tested and reports prepared by a Technical Services (a competent test body notified to the EC) � in UK VCA is a TS and manages the appointment of others, there has to be confidence in test results �you take these forward to the final Whole Vehicle Approval whether it be IVA or one of the TA options plan for going forward 2.Ensure that your product can meet the requirements �This shouldn�t be too difficult, most will be covered by C&U and RVLR, but it links understanding the legislation with your products �Create the necessary documentation � your trade bodies are likely to have a role here and VCA will produce samples and guides 3.the modular type approval process (as explained earlier) kicks in, �you need to get the things you are responsible for tested and reports prepared by a Technical Services (a competent test body notified to the EC) � in UK VCA is a TS and manages the appointment of others, there has to be confidence in test results �you take these forward to the final Whole Vehicle Approval whether it be IVA or one of the TA options

38. 38 Questions..???

39. 39

40. 40 Change before you have to. Jack Welch Change brings opportunity. Nido Qubein If there is no struggle, there is no progress. Frederick Douglass Change is such hard work. Billy Crystal Change?

41. 41 Agenda Glossary What is CoP? What does it affect? Should I be worried? What do I need to do? The quality elements Control Plans The audit Support and Information Services

42. 42

43. 43 CoP � What does it affect?

44. 44 CoP � What does it affect?

45. 45 Rear Protection Device Registration Plate Space Steering Effort Braking Radio Interference Statutory Plates Installation of Lighting Heating Systems Spray Suppression Safety Glazing Tyres Masses and Dimensions Couplings Transport of Dangerous Goods But what if I make��.. What does CoP affect

46. 46 CoP � What does it affect? Multi stage builds Second stage not responsible for base vehicle, only the components or systems added by the second stage Close tie�s required Base builder may change something that could affect 2nd stage approval, without this tie up 2nd stage approval may become invalid. Example, change of load rating on tyres Proof that the full range of vehicle specifications will comply with legislation Representative samples of a vehicle �Type� are selected and shown to meet the requirements Key design details are captured in a controlled �Information Document� Any change likely to affect the approved spec must be reviewed with VCA. Design, production, sourcing, critical processes etc Where necessary extensions or new approvals may be required prior to sale Proof that the full range of vehicle specifications will comply with legislation Representative samples of a vehicle �Type� are selected and shown to meet the requirements Key design details are captured in a controlled �Information Document� Any change likely to affect the approved spec must be reviewed with VCA. Design, production, sourcing, critical processes etc Where necessary extensions or new approvals may be required prior to sale

47. 47 Should I be worried? Type approval is a modular concept aimed at ensuring safety and environmental protection Components can be approved which in turn become part of a system which then are �wrapped up� in a whole vehicle approval Bulb ? Lamp ? Lighting Installation ? WVTAType approval is a modular concept aimed at ensuring safety and environmental protection Components can be approved which in turn become part of a system which then are �wrapped up� in a whole vehicle approval Bulb ? Lamp ? Lighting Installation ? WVTA

48. 48 What do I need to do? A Quality System

49. 49 What do I need to do? The quality system: Formal quality system ISO9001/TS16949 + Control plans However, formal quality system not mandatory, therefore: Quality documentation (manual) + Detailed control plans + On-site assessment Type approval is a modular concept aimed at ensuring safety and environmental protection Components can be approved which in turn become part of a system which then are �wrapped up� in a whole vehicle approval Bulb ? Lamp ? Lighting Installation ? WVTAType approval is a modular concept aimed at ensuring safety and environmental protection Components can be approved which in turn become part of a system which then are �wrapped up� in a whole vehicle approval Bulb ? Lamp ? Lighting Installation ? WVTA

50. 50 Quality Documentation Informal Quality System Quality Manual or documents used to ensure product consistency should contain, but not be limited to at least the following: Approved suppliers How does the company select and monitor suppliers? Incoming goods How does the company ensure supplied goods conform?

51. 51 Quality Documentation Non-conforming goods How does the company ensure that goods purchased or manufactured that do not conform are not used for production? Staff training How does the company ensure staff are properly trained? How is this recorded? Calibration How does the company ensure that all relevant equipment is calibrated?

52. 52 Quality Documentation Change Control Important one this one. How does the company ensure that any changes to the design or performance of the product which might affect the validity of the approval is notified to the authority? Final inspection How does the company ensure that the final product conforms? This is a minimum list, quality documentation should be sufficient for the product and have continual improvement in mind

53. 53 What do I need to do? Control Plans

54. 54 Control Plans What is a control plan? A control plan is a documented description of the procedures, checks and activities necessary to verify that the production unit continues to conform to the type approval requirements with regard to specification, marking and performance

55. 55 Control Plans (continued) Control plan layout There is no mandatory layout, you choose what suits your needs best Electronic or paper copies acceptable The control plan should become part of your quality system, the results generated will be inspected during any surveillance audit

56. 56 Control Plans. Trailers

57. 57 Control Documents

58. 58 Procedure

59. 59 Control Plans. Trailer

60. 60 What�s a good control plan Clear and unambiguous Suitable for the subject In a format that suits the manufacture and is acceptable to the VCA Demonstrates compliance Flexible

61. 61 What�s a poor control plan Disjointed B.O.M (Bill of material is not a control plan) Rigid Insufficient information Test/measurement description Method of recording Frequency Responsibility

62. 62 Typical Audit Schedule Opening Meeting � Outline of Audit Quality/procedure manual review Overview of CoP system/ Control plans Site visit. Production line work instructions /equipment / end of line testing Document control. EC legislation / drawings / obsolete documents

63. 63 Typical Audit Schedule Records. Test reports / calibration / suppliers Change control. Design / development / documentation Purchase. Supplier selection / supplier monitoring Calibration. In-house/external/ process/traceability

64. 64 Typical Audit Schedule Control of N/C goods. Supplier/production. Quarantine area Product storage. Stock rotation/storage Review / Questions Audit summary Close

65. 65 Audit result: CoP Clearance granted CoP Clearance pending � non-conformances to be addressed Clearance granted for 1-3 years depending on risk rating and evidence of conformity.

66. 66 And Finally (nearly) Look at VCA as your partner. VCA has over 25 years experience in dealing with type approval and CoP around the world Experience in every sector (car, bus, truck, trailer, motorcycle, agricultural) We can help you interpret legislation (we are linked to policy makers in London and Europe) Advise on quality documentation Advise on control plans Help you through the process in the most efficient and cost effective way Your success is our success

67. 67 Tools available: www.dft.gov.uk/vca Conformity of Production guidance Legislation information notices Type Approval information

68. 68 Tools available: VISTA � legislation database

69. 69 Tools available: CMS � Compliance Management System

70. 70 What is CMS? VCA�s web based collaborative system Helping manufacturers manage their type approval process

71. 71 How does CMS help? Guidance through the type approval process Exchange type approval documentation Exchange supporting data Track the type approval process and monitor progress

72. 72 How does CMS help? Allows manufacturers to: Receive alerts and prompts for information and documents to be supplied to VCA Securely store and have easy access to all completed approvals Store and keep track of Conformity of Production (CoP) documentation

73. 73 Questions? Nicholas.Clay@vca.gov.uk 01179524136

74. 74 Costs? Audit: �800-1600 (1-2 days) Paperwork clearance: �250

75. 75 Support & Information Sources VCA website - www.dft.gov.uk/vca Address: VCA Midlands Centre Watling Street Nuneaton Warwickshire CV10 0UA Telephone: 0247 632 8421