On 27 January 2016 the Commission published its paper 2016/0014 (COD) containing its proposal for a regulation. The proposal is intended to improve the type approval procedure with regard to the following points which have proved controversial in the past:
- standardization of the interpretation of the provisions by the type approval authorities,
- more stringent and uniform processes for cases of non conformity.
In order to secure these aims, the Commission is planning to introduce the following points in the type approval process or to design them more stringently:
- market surveillance by the member states and the Commission,
- the introduction of national scales of fees for the purpose of imposing national fees for the type approval of passenger cars. The proceeds are to finance the type approval procedures and, in addition, market surveillance,
- the establishment of a procedure in cases of non-conformity or of differing interpretations,
- the validity of type approvals is in future to be limited to a maximum of five years.
German industry gives its express support to the objective of improving the type approval system along the lines of the Commission's objectives as outlined above. However, in the process consideration should be given to the following points:
- a transparent and balanced system should be devised for the implementation and funding of the market surveillance;
- the funding of market surveillance should not be linked to national type testing charges. Since the extent of type checking is limited, the member states would have to raise these charges to an exorbitant level;
- the introduction of national fee scales is to be rejected since among other factors these run counter to the consistent application of the common legal framework for the marketing of products (decision 768/2008/EC) and would in no way contribute to an improvement in the European type approval system;
- the testing procedures in the type approval procedure must be practicable and be subject to uniform interpretations;
- measures in cases of non-conformity should be appropriate – a distinction should be drawn between safety-critical and formal divergences;
- appropriate and EU-wide harmonized procedures should be established for end-of-series vehicles as well as for step-by-step manufactured vehicles;
- the highest permitted quantity for small series in vehicle class N2 should be raised for vehicles with alternative propulsion systems or adapted to vehicle class N1;
- according to the Commission, after a five-year term at the latest a new type must be homologated. This is quite unacceptable. Instead of the five-year validity, a review of complete vehicle type approvals should be implemented by another type approval authority.