Artur said:
chucho said:
bzhwindtalker said:
There is two different things, EU (CE in France) certification, that is mandatory for any product/assembly/kit you sell, wether it is built or imported, and road certification.
To make your product comply with CE norms, you have to make some test and reports for the different applicable norms, a declaration of conformity and keep the test reports, test can be from either internal or external laboratories.
For road legal, there is indeed national or EU-wide certifications. In France there is a certification for small series of vehicles but it does not make much sense as costs are about the same as EU certification and you are limited to 50 bikes/year.
Did not now they where national only certifications. That means you can not use them in other countries of EU? or that you can not have them registered outside france?
Is there a max voltage for L1e certification?
From what I have heard you are correct. Only EU cert. will let sell and register bike outside the country of origin.
In fact a national registration allows to sell a limited amount of pcs depending on the category (50 pcs per each specific country in the L1e (A or B) segment. but there is a supposedly simplified procedure to extend the national approval to other country of the EU to which the manufacutrer would like to extend the certificate. For the national authorities where the first national approval has been registered, is mandatory to send all the papers and documents of that registration to the ones of the countries requested by the manufacturer. At this point, for the target countries is mandatory to reply in 3 months, if not, I believe the reply is assumed automatically as a consensus, and they anyway "shall accept" the approval and refuse only under specific and well explained circumstances where the relative national approval is in explicit contrast with the target's National regulations.
This route will probably allows a simplified procedure and a step by step increase of the max quantity of pcs. As an eaxmple I would start with my country (Italy) and then try to extend one by one to France, Malta, Spain, Greece, Cyprus, Portugal and/or to the countries that I believe or know that will accept the Italian National approval easier based on my vehicle characteristics and on the various national regulations. At a certain point, if the business has success and is boosted up over the critical mass (50 per each country per year), I'll be ready for the EU registration and probably with less efforts compared to a EU registration from the beginning.
All that should be good to lower the costs because some requirements are not mandatory for this kind of approval; some directly from the EU regulation itself(N. 168/2013) and some other eventually derogated by the single country authorities.
As an example, all the article n.57 (12 subarticles) of the regulation is not intended for a National approval:
ACCESS TO REPAIR AND MAINTENANCE INFORMATION
Article 57
Manufacturers’ obligations
1. Manufacturers shall provide unrestricted access to vehicle repair and maintenance information to independent operators through websites using a standardized format in a readily accessible and prompt manner. In particular, this access shall be granted in a manner which is non-discriminatory compared to the provision given or access granted to authorised dealers and repairers. This obligation shall not apply if a vehicle has been approved as a small series vehicle.
......OMISSIS
than follows 11 sub-articles that does not have interest at all for a National registration. (sub. 2 to 12)
Here's the National approval article:
Article 42
National type-approval of small series
......OMISSIS
6. The validity of a national type-approval of small series shall be restricted to the territory of the Member State whose approval authority granted the approval.
7. However, at the request of the manufacturer, a copy of the type-approval certificate and its attachments shall be sent by registered mail or by electronic mail to the approval authorities of the Member States designated by the manufacturer.
8. Within three months of receipt of the request referred to in paragraph 7, the approval authorities of the Member States designated by the manufacturer shall decide whether or not they accept the type-approval. They shall formally communicate their decision to the approval authority which granted the national type-approval of small series.
9. The approval authorities of the Member States shall accept the national type-approval unless they have reasonable grounds to believe that the national technical requirements in accordance with which the vehicle was approved are not equivalent to their own.
10. At the request of an applicant who wishes to place on the market or register a vehicle with national type-approval of small series in another Member State, the approval authority that granted the national type-approval of small series shall provide the national authority of the other Member State with a copy of the type-approval certificate including the information package. Paragraphs 8 and 9 shall apply.