GB Type Approval Scheme

This page was last updated on 20th August 2024

Emissions Strategy Assessment for GB Type Approval

VCA have a statutory obligation as the Type Approval Authority to assess and approve emissions strategy documentation in relation to GB type approvals for light-duty and heavy-duty vehicles under retained regulations (EC) 715/2007 and (EC) 595/2009 respectively. This strategy documentation, in the form of formal and extended documentation packages, contains information relating to the auxiliary emissions strategies (AES) and base emissions strategies (BES) employed on a given vehicle, component or separate technical unit, hence the frequently applied terminology of ‘AES/BES document’ or ‘AES/BES review’.

The detailed technical requirements applying to strategy documentation are set out in the retained legislation referenced above, but this page provides an overview of the process by which VCA will conduct GB type approval assessments of the documentation as part of approval applications.

Note: In the case that UNECE type approvals are used to cover emissions subjects as part of a GB whole vehicle type approval, these will be accepted at face value with no need for additional assessment of emissions strategy documentation as this has already been assessed by the granting UNECE type approval authority and is subject to mutual recognition obligations.

As set out in the Administrative Guidance for Applicants manufacturers have two routes to apply for GB type approvals:

1. Via VCA’s internal technical service
2. Direct to the VCA type approval authority (when working with an external technical service)

AES/BES review applications may be submitted in advance of, or alongside associated emissions type approval applications. Applications should be made via the VCA Portal, with manufacturers selecting the ‘AES BES Assessment Application’ application type.

Due to the nature of these application routes, different approaches apply in each case as set out in further detail below. In either case, emissions type approvals will not be granted until the relevant emissions strategy documentation has been approved by VCA.

 

Applications via the VCA Technical Service

GB type approval applications made via the VCA internal technical service follow the same process as those for UNECE type approval and EU technical service activity. Emissions strategy documentation should be supplied a minimum of 8 weeks in advance of target type approval issuing date, and a comprehensive assessment will be made of every application prior to approval issue.

This assessment will be led by a technical specialist within VCA who will analyse the information and data presented and compile a tracking document of any outstanding questions or requests that must be actioned prior to document approval. The process may require the provision of additional test data, and/or follow meetings between VCA and manufacturer representatives to discuss outstanding issues in more detail.

 

Applications Direct to VCA Type Approval Authority

Applications made directly to the VCA type approval authority are subject to a shorter initial technical review prior to approval being granted, in expectation that documentation has already been reviewed and approved by either an external technical service or another type approval authority prior to submission. Following initial review and approval, annual audits will be conducted with manufacturers in order to provide a robust ongoing compliance checking mechanism in addition to initial documentation checks.

Note: Applications where manufacturers cannot supply evidence of approval by either an external technical service or type approval authority will be subject to the comprehensive review procedure set out above in relation to applications made via the VCA technical service.

 

Preliminary Information Report and Initial Review

Alongside the relevant emissions strategy documents, manufacturers are required to submit a package of information to aid with initial review and approval, the ‘preliminary information report’. This information will be supplied as part of the online application form for AES/BES assessment, with documentation supplied at the end of the application process. Information required as part of the application is set out in the table below:

Light Duty (715/2007) Applications	Heavy Duty (595/2009) Applications
v RDE Certificate of Compliance (2017/1151, Ann. 3A, App. 9)	v Statement of Off-Cycle Emission Compliance (582/2011, Ann. VI, Para. 7)
v Absence of Defeat Device Declaration (if not within the extended documentation package itself)	v Absence of Defeat Device Declaration (if not within the extended documentation package itself)
v Written evidence that the documentation package has been approved by an EU type approval authority or technical service	v Written evidence that the documentation package has been approved by an EU type approval authority or technical service
v AES impact evidence – emissions status from 2 RDE trips run at: o   Low ambient temperature (between minus 7°C and 0°C) o   High payload (80-90%) and/or high driver aggression (85-95% V*aPos)	v AES impact evidence – emissions status from testing at: o   Low ambient temperature (between minus 7°C and 0°C) o   High payload (80-90%) or low payload (10-20%)

 

Once the complete application has been submitted, VCA will conduct a technical review and either notify manufacturers of any follow up information required, or that the documentation package has been approved for the vehicle or engine types in question. Confirmation of approval will be returned to applicants via email confirming validation of the customer order in question.

Technical reviews will be conducted according to VCA’s normal timescales of four weeks from receipt of complete and correct documentation, and manufacturers will be billed for technical time spent according to VCA’s standard hourly rate.

 

Ongoing Compliance Audit

Manufacturers who submit applications via the direct to type approval authority route will be subject to ongoing compliance audits on an annual basis, to reinforce the technical review carried out prior to approval being granted. Audits do not need to take place prior to type approvals being granted, with scheduling taking place at the time of the first type approvals being granted to a manufacturer.

Compliance audits will provide VCA with the opportunity to review processes and information relating to the approval of emissions strategies in more detail, with audits expected to cover the following activities as a minimum:

• Spot check of two full documentation packages (one each of gasoline and diesel applications where applicable)
• Review of general emissions control philosophies (software and hardware)
• Review of emissions validation and robustness processes
• Review of any emissions related in-service update campaigns
• Forward look to future programmes and upcoming mid-cycle updates

Following the audit, VCA will produce an audit report to summarise findings for the manufacturer. While the audit is intended to be a supplementary activity that is not directly linked to any one approval application, VCA reserves the right to take action in relation to any existing type approvals or future applications as appropriate based on the findings of the audit.

One audit is required per manufacturer per year, irrespective of the number of individual emissions applications being made, and can be scheduled flexibly as far as VCA resource permits. Audits are anticipated to take 4 days including preparation time, and manufacturers will be billed according to VCA’s standard hourly rate, in addition to cost recovery of any overseas travel expenses.

 

Notification of non-emissions-critical changes

There may be occasions where manufacturers make minor changes to their AES/BES documentation such as administrative corrections or minor modifications that have no impact on vehicle emissions. In these cases, additional technical review is not required but documentation should be submitted to VCA for validation and record keeping purposes. When submitting documentation subject to such a change, the details of the change should either be clearly described in the versioning table of the AES/BES document itself, or in a separate covering letter, such that VCA are able to make a determination of whether further technical review is required.

 

In need of further assistance?

If you have questions relating to the processes described above or are in need of support in relation to an AES/BES application, please contact aes.bes@vca.gov.uk. If your question relates to an ongoing application, please reference the application job number or work order number in the email subject line for traceability purposes.