Responsibility and requirements for market investigation were reformed by the new framework regulation (EU) No. 2018/858, which comes into force on 1 September 2020. Further 25 delegated acts are still in the loop. The EU is pursuing the comprehensive reform of the EU type approval system, with the main focus on the further European harmonisation of type approval and the expansion of market investigation. As part of market investigation, vehicles that are already available on the market will be randomly inspected by the member states and the EU Commission. The Commission will also increase its supervision of the type-approval procedure, as it will be able to introduce regular inspections and an exchange of information on this subject in future.
The content of Annex XI, which is important for caravans and motor caravans, has also been incorporated unchanged into the new framework regulation in Annex II Part III enclosure 1. So-called “special-purpose vehicles” include, for example, motor caravans as well as vehicles of category M1, but are exempt from some regulations due to their special purpose. As a rule, motor caravans are built on commercial truck chassis and can therefore not fully comply with the M1 regulations for passenger cars, e.g. with regard to emissions.
In order to measure how much fuel a car consumes and whether it complies with the exhaust emission limits, standardized test procedures are prescribed. Since September 2017, the new “Worldwide Harmonized Light-Duty Vehicles Test Procedure” (WLTP) is in force throughout Europe in order to type-approve new cars. This replaces the NEDC (New European Driving Cycle), which has been in force since 1992. For new motor caravans built on commercial vehicle chassis of classes N1 III and N2, WLTP will be introduced on 1 September 2019.
The measurement of emissions such as particulates or nitrogen oxide will also be converted to WLTP in future. The aim is to reduce nitrogen oxide and particulate pollution in real driving conditions. To achieve this, cars must be type-approved and driven on the road with a PEMS (Portable Emissions Measurement System). With RDE, only nitrogen oxides and particle loads are to be measured, consumption is irrelevant. In future, this will still be determined in the laboratory using the WLTP (Worldwide Harmonized Light-Duty), which is much more dynamic and realistic than the measurement method currently in use. The fuel consumption values and nitrogen oxide values for RDE will continue to be provided by the basic vehicle manufacturers.
Most motor caravans are manufactured using the so-called multi-stage process. Put simply, the motor caravans (stage 2) is built on a commercial vehicle chassis (stage 1). In the WLTP, the emissions approval continues to be the responsibility of the base vehicle manufacturer. The coordination between base vehicle and body manufacturers is therefore of central importance.