IN our global economy, many trailer manufacturers are finding favorable markets in Canada and Europe.
But the protocol and regulations can constitute a minefield for those who haven't done it before. To ease the process, the NATM held a workshop to cover the pre-clearance process for exporting to Canada and type certification approval for trailers to be exported to European Union member countries, featuring NATM technical director Clint Lancaster on the Canadian requirements and Chuck Gepper, a European trailer expert with the Vehicle Certification Agency (VCA), on the EU requirements.
Any company that wants to export into Canada has to deal with Transport Canada, the governmental department that is assigned to enforce provisions of the Motor Vehicle Safety Act (MVSA), which was passed in Parliament in 1971 to regulate the manufacture and importation of motor vehicles to reduce the risk of death, injury, and damage to property or the environment.
The regulations that are enabled by the Act are referred to as Canada Motor Vehicle Safety Standards (CMVSS), and they apply to all vehicles designed to operate on the public roads, from motorcycles through to trucks and trailers.
“Transport Canada is Canada's version of NHTSA,” Lancaster said. “In the US, we have FMVSS. In Canada, they have CMVSS. They are harmonized with the US except a few items, so when we have FMVSS 108, they have CMVSS 108.”
Lancaster said he tells manufacturers to go through NATM's compliance program, obtain certification, and then submit to Canada for pre-clearance. Under the pre-clearance system, authorized Canadian importers can avoid the cost and inspection of the Registrar of Imported Vehicles (RIV) system, if the Canadian importer purchases Canadian specification vehicles directly from the foreign manufacturer. The foreign manufacturer must have a certification program in place, which ensures that all the vehicles produced for Canada complies with the applicable Motor Vehicle Safety Regulations (MVSR). The Canadian importer ensures that only the Canadian specification vehicles from the foreign manufacturer are imported under this pre-clearance “contract.”
Appendix G is a list used by CBSA to verify if a Canadian importer and a foreign manufacturer are included in Transport Canada's pre-clearance system. Appendix G indicates the name of the foreign manufacturer and the types of vehicles that the Canadian importer is authorized to import. CBSA will have a copy of Appendix G at every border crossing. A copy of Appendix G can also be obtained from the Transport Canada website (www.tc.gc.ca).
Transport Canada offers frequently asked questions regarding the importation of new Canadian specification trailers under Transport Canada's pre-clearance program.
Q: What are the stages for an importer and a foreign manufacturer to be included in the pre-clearance system?
A: Working with the foreign manufacturer, gather and submit to Transport Canada all the applicable information listed in the document titled “Request Form for a Foreign Trailer Manufacturer to Register With Transport Canada.” If the information submitted demonstrates that the foreign manufacturer has a certification program in place, Transport Canada will register the foreign manufacturer. The Canadian importer must also complete the form titled “Application for entry into the Transport Canada vehicle importation pre-clearance system for new Canadian specification vehicles” and send or fax it in to Transport Canada. The Canadian importer and the foreign manufacturer will then be placed on Appendix G of Customs memorandum D19-12-1. The Canadian importer will also receive a pre-clearance letter as confirmation of this inclusion. When the Canadian importer arrives at the border with the foreign manufactured vehicles, the Canadian importer must complete the Vehicle Import Form 1 and present it to CBSA, which will also require a pre-clearance letter to verify the registered importer.
Q: What is a Vehicle Import Form 1?
A: Transport Canada requires that a “form 1” be completed and presented to CBSA when a new or used vehicle is imported into Canada. The “form 1” is used to keep track of all vehicles imported into Canada. The Provinces also require the “Form 1” as a condition of first time registration.
Q: If my company intends to import trailers that are equipped with air brakes, what extra information is required?
A: Working with the foreign manufacturer, gather and submit to Transport Canada the information listed in question 7 in the document titled “Request Form for a Foreign Trailer Manufacturer to Register With Transport Canada.” Transport Canada will use this information to determine if the foreign manufacturer's vehicle production complies with CMVSS 121-Air Brake Systems. These records of testing are just a sample of the foreign manufacturer's air-brake certification capability. The foreign manufacturer must be capable of keeping these records current to reflect any changes in the manufacturer's vehicle production.
Q: What extra information is required for flat-deck trailers with a GVWR of 10,000 kg or more?
A: Working with the foreign manufacturer, gather and submit to Transport Canada the information listed in question 6 in the document titled “Request Form for a Foreign Trailer Manufacturer to Register With Transport Canada.” Transport Canada will use this information to determine if the foreign manufacturer's vehicle production complies with CMVSS 905-Trailer Cargo Anchoring Devices. These records of testing are just a sample of the foreign manufacturer's certification capability. These records must be kept current to reflect any changes in the foreign manufacturer's vehicle production.
Trailer Type Approval Process in the EU
Gepper said VCA's main role is to assist companies in the type approval of motor vehicles, their components, and their systems to international standards — a function it has been performing since 1977.
Gepper said there are two different type approvals in Europe: EC (European Community) and ECE, which are United Nations regulations accepted not only in Europe but throughout the world. Not every country listed has to accept every one of the directives. They get to pick and choose. In Europe, there is list of directives that every European community must accept and adopt, with no choosing.
“The EC Whole Vehicle Type Approval (WVTA) procedure is when you have a complete trailer you want to sell in Europe and your desire is to sell to an end user or dealer,” Gepper said. “That is a whole vehicle. The component level is coupling devices, tires, lights, brakes.
“For ECE, there is no Whole Vehicle Type Approval. Until April 2009 in Europe, when you wanted to sell a trailer in Europe, you would get bits and pieces of approvals — one for lights, one for tires, one for the installation of fenders, one for the fifthwheel.”
Technical tests are performed according to EC directives that prove a company is in compliance with the coupling device, brakes, lights, installation of fenders and tires, and the dimensions.
“The big thing is ISO 9002 COP — conformity of production,” he said. “In Europe, when VCA issues a certificate, it is our responsibility to know that every vehicle you make is going to be equal to the one we inspected. One way is that VCA will inspect your quality assurance process. You have to have a method written into your process where you're online and find out what's changed. You don't want to be selling something that outdated by six months. That will get you into big trouble.
“Once we have the items passing and the quality assurance program taken care of, then you are granted EC type approval that's valid in all EC member states. Then comes the Certificate of Conformity issued by the manufacturer. That's only if you have that quality assurance program. The other way of getting whole vehicles into Europe is when we come in and do testing on the brakes and installation of all components. You would give the range of sizes and we would look at each one of the individual trailers before you ship it and make sure that the right lights are on and nothing is over dimension. Then we would issue a Certificate of Conformity and Certificate of Origin.”
Other specific EC type approvals:
- Multi-stage type approval.
“It applies when a manufacturer makes a chassis and ships it somewhere and somebody installs a piece of equipment. We would need information on all equipment, so that when we do the braking test we can simulate that load to make sure the ABS function and air-brake timing are all compliant after somebody else puts this piece of machinery on your chassis.”
- Partial type approval for systems.
“A good example is the ABS controller. When you sell an ABS controller, it has an electromagnetic compatibility test and other complex electronic system testing that is done so that it is not going to fail. We do not test ABS controllers other than for electromagnetic compatibility. Brakes are another partial system. Brakes can also be considered a component. Not the axle. We're not there to test the loading capability of the axle. We're there to test brake function.”
- Type approval for components.
“People call us up, saying they have a coupling device that needs to be approved. A lot of times I send them a matrix and say, ‘Here is a list of all directives.’ We have a program called Vista, a software package that has these compiled. In Europe, they have an amendment to an amendment to an amendment. VCA takes them and melds them together so you only have to read one document.
“Then it's time to do all the tests and measurements. You submit information. Most directives have information on documents with questions. You fill out papers and send them to us, and we put them together with our reports and turn them into a certificate. We don't have to send anything to Europe, and we don't have to bring anybody from Europe to do the work. It's all contained in the US and makes life much easier.”
He gave the vehicle categories for trailers:
01: trailers with a maximum mass not exceeding 750 kg. No brake system needed.
02: trailers with a maximum mass exceeding 750 kg but not exceeding 3500 kg. They can be multiple axles, and the brake system usually is activated by a surge device. It can be activated mechanically with levers or cables but most of time is hydraulically activated.
03: trailers with a maximum mass exceeding 3500 kg and not exceeding 10,000 kg. Must have ABS.
04: trailers with a maximum mass exceeding 10,000 kg. Must have ABS.
A sampling of the whole vehicle type approval directive matrix:
- Installation of lights.
“Europe will not allow Christmas trees and all these lights that blind you as you drive by. You are very limited about where you put the lights, and the lights have to be type approved, and the locations have to be approved. There is conspicuity-marking reflective tape, but it is not the reflective tape we have in America. It is special European tape. It's only allowed in certain places and can have no reflective writing or numbers.”
- Mass and dimensions.
“The widest trailer is 2.55 meters and no more than 4 meters tall.”
- Coupling devices.
“Testing is much more stringent for devices and their fifthwheel pins.”