EU debates parts approval

Your choice of spare parts is under threat

Published:  02 April, 2015

By Neil Pattemore

When I first started in this glorious motor industry, many moons ago, I was an enthusiastic young man working at a local motor factors (parts distributor to you and I) supplying a wide range of replacement parts to many workshops, fleet operators, accessory shops, bodyshops and a host of other customers. I never once had a complaint that the parts didn't fit or didn't work correctly. There was the odd warranty claim, but even these were few and far between.

In other words, what we supplied fitted and worked as intended and we offered a competitive choice of parts and components to our customers and in turn, to their customers - everyone was happy. This is the key point of the aftermarket - we offer consumers competitive choices, pure and simple.

It appears that because the vehicle manufacturers have to pass whole vehicle type approval, then aftermarket replacement parts will also need to be type approved, to ensure they fit and function correctly, ensuring a vehicle continues to meet its original safety, security and environmental requirements. The MOT verifies that a vehicle and its systems continue to work correctly, that it's safe and secure with acceptable emissions levels, but this is not how type approved parts and components would be checked.

There are some key replacement parts which already need to be type approved. These include windscreens, tyres, headlamps, catalysts, DPF's and brake disks, drums, shoes and pads. They are 'E' marked to show they meet the standards (the number after the 'E' denotes the EU Member State where the type approval was conducted (e.g. 11 is the UK). However, the legitimacy of the 'E' marking is the responsibility of the workshop that fits the part - who, if challenged, needs to be able to show an audit trail from their supplier back to the original manufacturer's certificate.

The development which is rearing its ugly head comes from the 'L-Category' European type approval legislation (powered two wheelers - motorcycles to you and I) and contains an annex that lists parts which could affect power/performance, emissions or noise and which will require not only type approval, but have an identity label to allow a random (i.e. roadside) inspection to check if the vehicle has been modified, by checking the labelled parts and components against a database of what should be fitted to a particular vehicle. Equally as bad, is that the legislation empowers the vehicle manufacturers or their agents to conduct 'market surveillance' to ensure their vehicles continue to comply with their original type approval requirements.

If this wasn't bad enough, it gets worse. Vehicle manufacturers obtain whole vehicle type approval either by providing a certificate that the sub-system conforms (separate technical unit type approval) or by testing the complete vehicle where brakes, steering etc. are checked as complete systems. However, for parts and components manufacturers, they may have to conduct testing on all individual applications, even if the same part or component is fitted to a range of similar vehicles. Even for OEM parts suppliers, they may still have to submit their parts and components for type approval if they want to sell them in the aftermarket.

For the vehicle manufacturer, if their replacement parts are offered for sale as replacement parts, then they already conform, as they were part of the original whole vehicle type approval. The claim is that by type approving aftermarket replacement parts it creates a level playing field between the vehicle manufacturers and the aftermarket parts and components suppliers, but I don't see it that way - this creates a significant proportionately issue.

For the existing range of replacement parts and components which are already subject to type approval, there is a specific aftermarket type approval procedure but, bizarrely, this can mean that replacement brake system components provided by the vehicle manufacturers themselves do not have to meet their own original vehicle type approval requirements.

The existing vehicle type approval legislation is currently under revision and it is the intention of the European Commission to introduce similar requirements for both passenger cars and heavy duty vehicles as already exists in the L-category legislation, especially concerning safety, security and environmental aspects.

These proposals in the revised type approval legislations have been vigorously challenged by FIGIEFA (the European association of spare parts distributors), who have claimed that these proposals are both unnecessary and disproportionate. Additionally, they will create unfair competition, rather than resolve it and will raise costs with little proven benefit. At worst, it will increase costs for legitimate European manufacturers, whilst incentivising repair workshops to buy original parts from their local dealer - undermining the competitive choice of the aftermarket and increasing consumer costs. Just remind me - who will benefit from all of this?

So, supporting one of the aftermarket organisations who help FIGIEFA to fight this issue is more important than ever - your competitive choices are worth fighting for!

xenconsultancy.com

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