Homologation – Part one

Righto – a bit of terminology. Homologation, certification, type-approval – they all mean roughly the same thing: getting an official body to grant approval to sell a road car to the general public. Even within car companies, the terms are used interchangeably and often mixed up. So let’s unmix them a bit.

There are two main systems of getting approval of road cars. There is homologation or type approval proper, which involves a government-certified agency independently testing vehicles submitted by manufacturers and granting approval of the ‘type’ of vehicles submitted. This is the system used in most countries of the world.

But there is also a second system – so-called self-certification. This is where the manufacturer itself is responsible for ensuring that its products meet the rules, and approval is granted on what is effectively self-declared compliance. This is the system in force in the USA and Canada, and although the principles are fundamentally different between the two systems, in practice they are not as different as they might seem.

So, how does it work? Well, we’ll take the example of getting approval for launching a vehicle in Europe first, before having a look at the differences – and similarities – with certifying a vehicle Stateside.

In the EU, all new cars have to conform to what’s called the European Whole Vehicle Type Approval or WVTA standards. Not so very long ago, each national government had its own set of laws. They were broadly similar, but many countries had little quirks – remember yellow French headlights? In Germany you had to be able to change headlamp bulbs in a certain time limit, without using tools. In the UK, you had to be able to fit a bowler hat on the parcel shelf. Kidding.

But in 2000, 27 European countries – then including the UK – managed to align the standards and agree on one Big Book of Rules. Not only that, they agreed to appoint Type Approval bodies that were certified by all national governments to approve cars on behalf of any member state. These bodies or agencies included the Vehicle Certification Agency or VCA in the UK, TüV in Germany, IDIADA in Spain and UTAC in France. These are effectively bodies who hold the delegated authority on behalf of all EU governments to uphold the laws applied to vehicle safety, and make sure car makers do not get up to any funny business.

At least a year before Start of Production – and probably 15 to 18 months before Start of Sales – car companies will apply to one of these Type Approval bodies to initiate the process of approval of their snazzy still-under-wraps new motor. Which body they apply to often stacks up on national lines, for reasons of history and convenience – German OEMs usually use TüV, UK-based car makers will tend to turn to the VCA, go to UTAC’s proving ground in Montlhéry and you’ll find a bunch of pre-production Renaults and Peugeots going through their regulatory paces, and so on. But it’s not always a guaranteed at-home game – I’ve worked on cars built in France but homologated by IDIADA in Spain, for example.

I said earlier that the Book of Rules is a big ‘un and believe me, it is. There are the obvious ones you know about like crash tests and exhaust emissions. But there are less obvious ones like dimensional details – the obscured angle of an A-pillar, the projected cone of vision of mirrors, as well as even more labyrinthine things like use of restricted materials such as certain compounds of Chromium. Radio frequency certification alone is a weighty tome – the car must neither emit rogue radio waves that might interfere with the telly, nor be susceptible to any radio waves with which it might be bombarded. Look at the back of your key fob and you’ll see a CE mark and lots of obscure small text and numbers – that’s proof it’s passed these radio frequency standards. There are many more of this ilk.

And the rules don’t apply just to the whole car – as the key fob shows. Look at the head or tail lights of your car, on the back of the mirrors or in the corner of the windscreen. You will see a lowercase ‘e’ mark and yet more serial numbers – proof that those components themselves pass the various European laws, before they are even bolted to the car.

Hopefully the process of designing the car has taken all these rules – component and vehicle-level – into account from day one. Next step is internal testing. No car maker in its right mind would run its first emissions tests with the government-approved agency man in the white coat standing in the corner, pen poised over the clipboard.

That manufacturer will carry out many digital simulations, and hopefully a few real physical dry runs of each test as well. Not only that, but car makers (least those that want to stay in business) do not merely test to the letter of the test standard, either. Take our previous example of radio emissions. The legal standard defines a certain emissions level (measured in dB) across a defined frequency range. The line is a black-and-white go/no-go legal test limit. Car makers will set internal standards that are quite a bit stricter – maybe up to 10 per cent below the legal threshold – just to ensure that they have a bit of margin for production tolerances, test equipment deviation and sheer bad luck on the day. It’s fairly career-limiting to have to go to the boss after having spent $1.5 billion on the new car to tell him that the Bluetooth hub was 0.1 dB over the line and the car cannot be sold.

Next up, a ton of paperwork. There are reports to be submitted to the certification body on everything you can imagine and a few you probably can’t. These range from drawings to crash test reports, endless lists of substances used, parts numbers, software versions, you name it. Every tiny thing on the car has to be documented, signed and sealed. I still have calluses on my index finger from signing reams of these things over the years.

And then, the big day. Remember, this is not self-certification – this is independent third party validation. You have to submit ‘production representative’ cars to the authorities, and leave them to it for what are known as the witness tests.

Now, those two words in quotes are very, very important. Remember, we’re not in production yet – you can’t actually build production cars until you have the green light from the authorities. So these are usually the very last batch of pre-production cars. But by submitting them to the authorities you are declaring that you effectively change nothing before starting production that might possibly change any of the characteristics that are being homologated. And this, folks, is a very murky area. So you might tweak a paint colour after this point – paint colours don’t affect safety and are hence not homologated, but changing an airbag calibration would be clearly illegal.

But between these two clear extremes there is a gaping abyss of grey zones. What about changing the softness of the seat foams a tad because some bloody smartarse road-tester journo complained that the seats in the press car were a bit soft? No harm in that, surely? Wrong. Changing that could alter the hip-point of the crash-test dummy used in the crash test – Mr 95 per cent might sit a millimetre higher or lower than the homologated position, which could theoretically alter the crash test results. Car makers have to be very careful indeed in changing anything at all after this day.

So: you submit your babies to the authorities and hand the keys over to the folks in the white coats. And they test them. And crash them. They brake test them, put them in EMC chambers, heat them up and analyse the vapours they emit, weigh them, prod them and poke them like dogs at Crufts – all the tests you have already done (hopefully) and already passed (even more hopefully). And all going well, the chief boffin comes out, pushes his glasses up his nose and gives you the big thumbs up. You can go back to the boss and not need to fluff up your CV.

Your car is now an officially approved ‘Type’. That type approval number is what you typically see on the second line of a VIN plate – something that looks like e1*2001/116*000 (this happens to be a BMW type approval number). From this day on, your car is legal and can be sold to the clamouring public, who are hopefully queuing up outside the dealers, fighting to put down their orders. Congratulations. Roll the (steel) presses.

Now, let me tell you that it’s a lot less linear and fluid than the A to B to C summary I’ve presented here. Hiccups, misunderstandings, misinterpretations of the myriad rules and mere typos in the many test reports can cause unbelievable stress, very late in the very long day that it takes to develop a car. And it’s got even more stressful in recent years. In the Old Days (I was there, and have the grey hairs to prove it) there was a little bit of wiggle room with the authorities. If your car was right on the line for this or that test result, or a geometrical characteristic could be interpreted favourably or unfavourably, there was a little room for negotiation. A sympathetic inspector – if they were convinced you had no evil intentions – might accept a small deviation or give the benefit of the doubt in an interpretation of an ambiguous regulation.

All that ended with Dieselgate – see Gavin Green’s excellent piece Scandal! Dieselgate if you don’t recall the details. Thanks to VW’s shenanigans, however, today there is precisely zero wiggle room. Zilch. The rules are applied to the absolute letter – no amount of charm and pleading will get any of the agencies to budge an inch. Overall, probably a good thing for the buying public, even though a small and probably irresponsible part of me regrets that there is no room for discussion even on very low volume sports cars.

Later this week, we’ll see how this is done in the US, and take a quick tour around the world to tip our hat to some odd quirks in other countries.

Now read Homologation – Part two