One Europe, one type approval: Multi-stage type approval for wheelchair accessible vehicles explained
Wheelchair Accessible Vehicles (WAV’s) in vehicle category M1 can obtain EU Whole Vehicle Type Approval (WVTA) as special-purpose vehicles (subcat. SH acc. to Framework Directive 2007/46/EC Annex XI Appendix 3). For this purpose the vehicle type must fulfill all requirements in about 50 different EU and ECE regulations regarding diverse subjects like braking, emissions, safety glazing, sound level, etc. For special-purpose vehicles a number of exemptions are allowed in comparison with ‘ordinary’ M1 passenger vehicles and specific WTORS requirements are applied.
Usually this is combined with a multistage WVTA procedure (acc. to 2007/46/EC Annex XVII) which allows the WAV converter to only obtain approval for subjects which are modified during the conversion process. Partial approvals for untouched subjects may be carried over from the base vehicle.
In order to use this multistage procedure, both Stage 1 (OEM) and Stage 2 (converter) manufacturers have to conclude an multistage agreement with special attention to their mutual information exchange, including WVTA and relevant partial EU/ECE approvals from the base vehicle. Procedure for arranging this agreement is different for all OEM’s (Stage 1 manufacturers) but sometimes combined with the Letter of No Objection (LONO) application procedure and associated technical assessment.
Stage 2 WVTA can be arranged with type approval authorities in any EU member state and will be issued after all technical aspects of the Stage 2 conversion have been tested and/or inspected by an accredited technical service and test reports for all Stage 2 subjects are available.
Furthermore the Stage 2 manufacturer will need an Conformity of Production (CoP) acceptance based on 2007/46/EC Annex X. This ensures that the manufacturer is able to produce the type-approved vehicles exactly according to the type-approval specifications by implementing suitable CoP measures / procedures / work instructions / checklists (ISO 9001 certification is helpful but not mandatory for this purpose). Approval authorities will carry out initial assessments & CoP audits before CoP compliance statement is issued.
Once a Stage 2 WVTA has been granted, the manufacturer is allowed to issue a Stage 2 CoC form for any new vehicle converted acc. to this approval.
With this Stage 2 CoC, combined with the base vehicle’s Stage 1 CoC, hassle-free vehicle registration will be possible in all EU member states.
Only in some countries like France & Italy, registration is based on national homologation codes which have to be arranged after WVTA issue.
Please note that the Annex XI procedure for special-purpose vehicle may be used for an unlimited number of annual vehicle registrations.
No EU small-series type-approval is available for WAV’s, only alternatives being national small-series type-approval (NSSTA) or individual vehicle approval (IVA)with even more possible exemptions, if required.
Starting 1 September 2020 new WVTA’s will only be issued acc. to new Framework Reg. No 2018/858 Annex II but for the time being approval procedure and technical requirements will be very similar (if not identical) to previous WVTA procedure under 2007/46/EC.
By Misha Benschop
Tripod Mobility is an EMG Member - details here