Organisation Europeenne des Constructeurs des Vehicules Accessibles
OECVA
To represent the Wheelchair Accessible Vehicles (Special Purpose Vehicles) sector within the European Automotive Industry.
ID: 892674125475-52
Lobbying Activity
Response to Update of references to regulatory acts in the Annexes to the General Vehicle Safety Regulation
7 Jan 2025
The EU trade association representing wheelchair accessible vehicle manufacturers, (OECVA) wishes to raise some concerns regarding the proposed amendments to the regulations. We believe that these proposed changes will significantly increase the regulatory burden on manufacturers of wheelchair accessible vehicles across the EU, many of whom are SMEs, and therefore have a negative impact on access to personal, independent mobility for disabled travelers who travel in passenger cars whilst seated in their wheelchairs. We are therefore asking the EU Commission to review some of the proposed new requirements, as they relate to wheelchair accessible vehicles. The attached document explains our concerns in greater detail.
Read full responseResponse to Interim Evaluation of the Single Market Programme (SMP)
12 Dec 2023
OECVA is grateful for the opportunity to contribute. Many of its members, making wheelchair accessible vehicles are SMEs who would like to benefit from the Single Market, so the call for evidence is of great interest to them. The attached document explains the views of OECVA members on the barriers that make this difficult, in more detail.
Read full response21 Nov 2022
OECVA proposed response to Commission Consultation on Draft implementing regulation - Ares(2022)7364802 Regarding the secure exchange of data of the certificate of conformity in electronic format and read-only access to the certificate of conformity, and amending Commission Implementing Regulation (EU) 2021/133 OECVA is an EU trade association representing wheelchair accessible vehicle (WAV) manufacturers. We note (and support) the intention to move towards electronic certificates of conformity. In order to achieve this, we anticipate the need to exchange various vehicle data, securely and accurately. However, most EU WAV manufacturers are small operations without the IT resources available to invest in bespoke software, if such software is necessary to allow this exchange of data to take place. We note that the new draft implementing regulation to which this consultation refers, contains a provision in Article 4, and an amendment has been proposed as follows: Article 3a Exemption for manufacturers of particular vehicle categories and types of vehicle that are produced in small series By way of derogation from Articles 1 and 2, for manufacturers of particular vehicle categories and types of vehicle that are produced in small series, it shall be sufficient to make available the data elements of the electronic version of the certificate of conformity by means of manual input or through the upload of an IVI XML file. Despite producing vehicles in relatively small numbers, wheelchair accessible vehicle manufacturers (in fact, all Special Purpose Vehicle manufacturers) are prohibited from utilising the EU Small Series type approval scheme by Paragraph 2 of Article 42 of Commission Regulation 2018/858. However, as small companies, we remain similarly resourced to manufacturers who produce vehicles in small series. We therefore ask if the Commission could consider extending the proposed derogation, to also include manufacturers of Wheelchair Accessible Vehicle (or perhaps all Special Purpose Vehicles), allowing us to also submit data in XML format, if we find ourselves unable to use other means? We therefore propose the following small amendment to the proposed derogation, to include the text between the asterisks below: Article 3a Exemption for manufacturers of particular vehicle categories and types of vehicle that are produced in small series *AND SPECIAL PURPOSE VEHICLES*" By way of derogation from Articles 1 and 2, for manufacturers of particular vehicle categories and types of vehicle that are produced in small series *AND FOR SPECIAL PURPOSE VEHICLES AS DEFINED IN PART 'A', PARAGRAPH 5, OF ANNEX I TO COMMISSION REGULATION 2018/858*, it shall be sufficient to make available the data elements of the electronic version of the certificate of conformity by means of manual input or through the upload of an IVI XML file. We would be grateful if the Commission could consider this request, as it will provide some flexibility for our members in allowing data to be uploaded using commonly available software.
Read full response19 Apr 2022
OECVA would like to thank the Commission for its ongoing engagement with us on the subject of regulations affecting wheelchair accessible vehicles. We welcome the proposals, and attach a document with some small proposals for minor detail amendments to the draft annex.
We have also noticed the splitting up of the emissions requirements in what appears to be a number of separate type approval items, and have raised some questions in the attached document, relating to this.
Finally, we welcome the proposal for the 2 year delay in the draft regulation, for Special Purpose vehicles, as this should give the mainstream manufacturers of the Stage 1 vehicles that we use, adequate time to perfect compliance of the base vehicles with the new regulatory requirements, prior to having to address the same challenges with second stage manufacturers. We feel this will greatly aid a smooth transition from the existing to the new requirements for multi-stage vehicles.
Read full response11 Nov 2019
For multi-stage vehicles, 2018/858 Article 36, Paragraph 9, contains a requirement for the second stage manufacturer to “only fill in those fields of the certificate of conformity in paper format that concern the additions or changes carried out at the current stage of approval”. The addition of Field 0.11 (“Date of Manufacture”) raises questions for multi-stage vehicles.
Question 1 – the Stage 1 and Stage 2 vehicles are likely to have different dates of manufacture. Which date must be put on the certificate?
Question 2 - the “Date of manufacture” is likely to be used by authorities to determine (for example) derogation entitlement, and also, further into the vehicle’s life, perhaps access to congestion or low emissions zones in various cities, or perhaps, in-service roadworthiness requirements, etc. If, for example, a multi-stage vehicle was built (as a complete vehicle) at Stage 1 in (say) April 2019, but the Stage 2 date of manufacture was (say) September 2019, which date of manufacture would be used to determine emissions requirements? (In this example, the second stage manufacturer makes no changes to the emissions certification at Stage 2, so when granting the type approval the approval authority deems that the Stage 1 emissions approval remains valid). Naturally, the same situation could arise with any type approval subject where a regulatory deadline passed in between the time of the Stage 1 and Stage 2 manufacture).
Field 42 (Number of seating positions) refers to Note 111. This note excludes positions for wheelchairs. A typical small wheelchair accessible vehicle might have a total of 5 seating positions including the driver, but will not be able to accommodate a wheelchair user seated in their wheelchair when driven in such a configuration. It may be necessary to fold or remove some seats before a wheelchair can be carried. Such a vehicle would have the entry “5” as the entry in Field 42 and “1” as the entry in Field 42.3. However, it must be understood that it could not carry 5 persons plus 1 occupied wheelchair simultaneously (either due to weight or space constraints, or both).
Within 2018/858, Part III, Appendix 3, Item 44A (Masses and dimensions) refers to Footnote W8. At the end of Footnote W8 is the entry: “Any limitation in the passenger capacity resulting from the use of wheelchair(s) is to be recorded in the owner’s handbook, on side 2 of the EU type-approval certificate and in the certificate of conformity.
Where, on the CoC should this be recorded? Is It permissible to insert a table into the CoC next to Fields 42, 42.1 and 42.3 along the lines of the attached?
Read full response