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INTERNATIONAL ASSOCIATION OF THE BODY AND TRAILER BUILDING INDUSTRY

CLCCR

CLCCR advocates the various interests of trailer manufacturers and body builders and and non-captive OEM Bus & Coach builders.

Lobbying Activity

Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

6 Nov 2025 · Regulatory topics on trucks and trailers

Response to Extension of manufacturer reporting on new HDV to cover certain lorries, buses, coaches and trailers

10 Jun 2024

CLCCR would like to propose in Annex I point (2) the "1/1/2025" as "starting year of monitoring and reporting period" and "2025" as "starting year of reporting" instead of 1/1/2024. Trailer manufacturers (vehicle category O3 and O4) as well as bus manufacturers appeal for an adjustment according to Annex I point (2) regarding the starting year of monitoring and reporting. As stated within the recitals point (6) the European Commission requested reliable CO2-related reporting data. However, this is not given for trailers and buses in the phasing-in of the monitoring due to several reasons: New data to be reported (e.g. item 109 "Make of refrigerating unit") are neither requested in the current VECTO version nor in the current EU-Certificate-of-conformity (CoC) and thus actually not available. This point is crucial for a consistent monitoring process. Format of data transfer is not specified and leads to uncertainty for all manufacturers. This is especially important for manufacturers which are obliged to provide CO2 data from the beginning without any test phase. In some cases, the authorities did not provide the VECTO license in time and manufacturers got the official permit late, which leads to a late implementation of this software into their own company processes. The European commission shall take note this aspect. The process to get the official type approval takes normally 6-8 weeks, that is imminent because data has to be provided for EU-Certificate-of-conformity (CoC) as well. Since the start of the legal declaration for trailers/buses/ coaches on 1/1/2024 numerous feedback on mistakes and failures during the implementation of the VECTO software has been reported, which resulted in disruptions and additional burden for many affected manufacturers. There was an inconsistency in the several VECTO versions (buses, trailers) with regard to the tyres and most non-European tyre manufacturers did not recognized this in-time. Some tyre-XML-files which were provided by tyre manufacturers were incompatible with the current VECTO for trailer version. In current VECTO regulations (EU) 2022/1362 and (EU) 2017/2400 transitional provisions are defined. That means vehicles may be registered without determination of the CO2-value (e.g. trailers until 1st July 2024). Furthermore, please note, that according to recitals point (5) the mandatory date for reporting is published through Regulation 2017/2400 that have enabled manufacturer of vehicles of category N2/N3 enough time for establishing a data base and reporting process. This is not the case for trailer and bus manufacturer. For equal treatment of all vehicle classes the European Commission should allow the manufacturers of category O3/O4 and manufacturers of buses at minimum 12 months for setting up a reliable data base and processes for CO2-related reporting. Starting the legal reporting obligations with vehicles from 1/1/2025 would provide minimum required lead time for all manufacturers to prepare for the reporting and it would not contradict the definition of a baseline for the new vehicle subgroups from Mid of 2025. Editorial note: Please not a mistake in Annex I point (4) * Additional Information item 102. We think this is not applicable for "All" vehicles but with exception of category O. The requested sum exec data file is not generated by the VECTO for Trailer software.
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Response to Type-approval templates for certain motor vehicle safety systems

30 Nov 2023

CLCCR The International Association of the Body and Trailer Building Industry thanks the European Commission for the opportunity to comment on this draft proposal amending Regulation (EU) 2021/535. CLCCR wishes to comment on the requirements for the 2nd rear registration plate space on large trailers. CLCCR does not support this measure for practical and technical reasons Firstly, only one European nation requires a 2nd trailer rear registration plate to be fitted (in use), therefore this requirement does not appear to be cost effective or proportionate for other Member States or their consumers. Secondly, there is very little space on the rear of many trailers to locate a 2nd type approved space, when considering the placement of obligatory rear lamps, markerboards, warning signs, and other national requirements. Examples of such trailers, and further justifications from CLCCR can be found in the attached paper. CLCCR remains open to discuss any points raised in their response with the Commission.
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Response to Revision of the Directive on Driving Licences

30 May 2023

CLCCR, the International Association of the Body and Trailer Building Industry, is pleased that the commission has made a proposal for driving licences. To make the text in the new directive clear and also in line with regulation about the vehicle type approval CLCCR has some feedback on the proposal of the commission . The CLCCR feedback on the EC proposal is in the document that is included to this feedback.
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Response to Review of the CO2 emission standards for heavy-duty vehicles

19 May 2023

CLCCR recognizes the importance of further steps for CO2 reduction by considering potentials to optimize trailers. CLCCR welcomes the opportunity to contribute comments on the upcoming regulation for CO2 standards. Although standard trailers do not typically emit any CO2, it is recognized that energy efficient trailers can help reduce emissions from the entire vehicle combination. However, the Commission's proposal raises a number of questions about its practical feasibility and its agenda. The proposed CO2 reduction targets (minus 7.5% for drawbar and central axle trailers and minus 15% for semi-trailers) is far above what is considered feasible so much so that it cannot be delivered for trailers with the current options of the VECTO for TRAILER simulation tool and cannot be achieved across all trailer groups with all previously approved technical solutions in the trailer. The proposed target values from the impact assessment require further clarification because they ignore the limited input variables and the missing capability to assess all measures in the VECTO for TRAILER tool. The influencing parameters of weight, rolling resistance and air resistance that are possible for trailer optimization cannot be reduced indefinitely, since the trailer must fulfill transport operations and forms a unit with the towing vehicle in real driving operations. As a consequence, with the revision of (EU) 2019/1242, the mandate must also be given for a regular and timely revision of the VECTO for TRAILER simulation tool in order to conceive, validate and include new technologies that go beyond lightweight construction, tyres/rolling resistance and aerodynamics. It is not acceptable to ignore new technologies in the simulation tool and thus possibly create market-distorting structures that run against the CO2 optimization of the trailer fleet. The CLCCR proposes that the respective sub-groups of trailers are fairly evaluated according to their potential for improvement, which can be determined in the VECTO calculation method, with well-adjusted CO2 fleet limits per subgroup and not with a flat rate of minus 7.5% or minus 15%. Following the stepwise approach developed for trucks and coaches, trailers must also be brought up to a final CO2 fleet limit value using five-year steps from 2030 onwards. This offers trailer manufacturers the opportunity to develop and gradually introduce new technologies and at the same time to develop them further in the up-coming five years periods. However, new technologies cannot be brought onto the market in the short term and therefore cannot initially contribute to achieving the CO2 reduction targets, since extensive validations and implementation of the approval process are still required. Furthermore, they could prove very expensive, have an influence on payload and may only be used for certain transport operations. The CLCCR therefore proposes setting a 5% CO2 reduction target for all trailers in 2035, based on the potential that can currently be considered in VECTO for TRAILER, and increasing this target for individual trailer groups to 7.5% in 2040.
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Response to Transitional measures for smart tachograph 2 regarding its use of OSNMA

7 Mar 2023

Dear sir, madam, on behalve of CLCCR, the International Association of the Body and Trailer Building Industry, we want give feedback on this initaitive. We fully support the joint industrie feedback of ACEA. Next to that we have our own response developed. Please find it attached. Kind regards Roelof de Haan
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Response to Commission Regulation on the influence of heavy-duty trailers on the CO2 emissions of towing trucks

14 Apr 2022

CLCCR is the International association of trailer manufacturers, body builders and non-captive OEM Bus & Coach builders. CLCCR representing thousands of SMEs, mainly across Europe via the national associations organized in CLCCR. CLCCR recognizes the importance of further steps for CO2 reduction by considering potentials to optimize trailers. CLCCR welcomes the opportunity to contribute comments on the upcoming regulation for a CO2 certification of trailers. Please see our detailed comments in the attached document.
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Response to Extension of scope of procedures for determination of CO2 emissions of heavy-duty vehicles

11 Nov 2021

We are commenting on behalf of the member companies of CLCCR – the International Association of the Body and Trailer Building Industry – which represents and advocates the various interests of vehicle bodybuilders and trailer manufacturers. Representing the non-captive OEM Bus & Coach builders, CLCCR recognizes the importance of extending the scope of the current HDV CO2 certification regulation to include buses and coaches for the first time, so to deliver CO2 reductions from this very important sector. While CLCCR welcomes the inclusion of buses and coaches within the forthcoming amendments to Regulation (EU) 2017/2400, we would like to highlight the additional burdens that will be applied to the smaller non-captive bus manufacturers and bodybuilders by the current Commission proposal. CLCCR believes the proposal applies disproportionate costs of compliance and regulatory burden to our members. This is primarily because CLCCR member companies produce far fewer vehicles than the larger OEMS, meaning that compliance costs will be disproportionately higher as they are amortized across a much smaller production run. Most non-captive bus manufacturers and body builders are small volume manufacturers, who have more limited financial and technical resources compared to the larger OEMS. Requirements for the frequency and scope of Conformity of CO2 emissions and fuel consumption (Articles 20, 22 and table 17 of Annex VIII, app. 5) especially, each present significant burdens and disproportionate costs for the small volume manufacturers. For the non-captive OEM bus and coach builders to compete with the larger OEMs on equal terms, CLCCR proposes some amendments – as per the Annex attached - in order to protect these smaller businesses in the market and ensure their long-term viability and security. CLCCR remains at your disposal for any further exchange of views.
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Response to Technical specifications for the construction and type-approval of the second version of the smart tachograph

15 Mar 2021

CLCCR would like to draw the European legislators attention to some specific issues for the bodybuilding industry, around the intended application date of this proposal and the impact it has on the bodybuilders who construct vehicles as a second (or subsequent) stage of vehicle type approval. CLCCR strongly recommends European legislators introduce a split into the proposed entry into force date and/or the date of application, so to provide flexibility for vehicles built through the ‘multi-stage’ process, which in most cases require a longer than normal assembly period. Please see the attached position paper for further details.
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