Revision of Roadworthiness Control Package

The FNA essentially defends very small enterprises (VSEs) made up of fewer than 11 employees. The vehicle technical inspection branch represents more than 6,450 centres, made up of more than 12,918 approved inspectors in France (The source of these data is UTAC – OTC). With an average of 2 controllers per establishment, technical control is mainly carried out by VSEs. This delegated public service mission has for 30 years, clearly contributed to the improvement of road safety (8000 deaths/year on the roads in 1991 against 3000 today).

FNA representatives thank the European Commission for gathering stakeholders’ views regarding the Revision of Roadworthiness Package (RWP). The FNA presents the following observations regarding the impact of these European rules as well as the measures envisaged, and the possible impacts of the revision of these rules.

1 – Necessary reintroduction of minor failures during technical inspection

The classification between minor, major and critical failures is essential and makes motorists aware of the progressive state of their vehicle.

The level and assessment of failures introduced by Directive 2014/45/EU of 3 April 2014 on the periodic technical inspection of motor vehicles and their trailers have had both positive and negative effects.

1.1 First of all, the addition of the critical failure, an anomaly presenting an immediate danger to road safety or the environment, proved to be useful. It reinforces the road safety role of technical control.

1.2 The European Directive of 2014 also had the effect, more negative this time, of reducing the number of minor failures. For example, in the 9 functions, minor failures are missing (in the judgment of minor play in the steering and gear ball joints or in the brake lines). Indeed, FNA representatives believe that the more minor failures there are, the more the motorist will be able to anticipate damage and repairs to his vehicle. The FNA invites the European Commission to have a reflection on the reintroduction of minor failures in the different families of technical control. Minor failures fully contribute to road safety and the regular maintenance of the vehicle fleet. These three failures are effective only when they are complementary.

2 – Evolution of vehicle pollution control

FNA promotes and encourages a real strengthening of the methods of measuring exhaust gas emissions. However, the method must be simple and reliable. Simple in its technicality, reliable in its result. Today, pollution control is not effective enough and does not meet the objectives sought by the European Union.

2.1 On the pollution checks currently carried out

→First, when checking a diesel vehicle, the controller uses the NFR 10-025 2016 procedure which checks the opacity of the vehicle's smoke. Despite the improvements made by the directive, the control procedure is complex and decried by the profession. It does not analyze any gas coming out of the vehicle but only a thickness of smoke. This control does not give the correct information to the motorist on the state of the gas emissions of his vehicle.

→Secondly, when checking a petrol vehicle, there is a gas analysis (CO and lambda value analysis). The results are better with respect to the objectives sought by the European Union but there is no control of fine particles that the vehicle rejects.

2.2 Necessary strengthening of control through new equipment and the improvement of European regulations

FNA supports the European Commission's proposal aimed at strengthening control of vehicle emission levels. →This position presupposes reliable equipment, effective methods, and an appropriate level of sanction for motorists. It will support the European vehicle fleet renewal policy.

→However, regarding the inspection itself, the Commission must absolutely take care not to extend the duration of the inspection (45 minutes on average) under penalty of being more difficult to set up for both motorists and technical inspectors.

→In addition, this reinforcement must be a reasonable economic investment for technical control centers. It should not be too expensive in order to avoid more and more higher prices of technical control for motorists.

→FNA representatives highlight and promote 5-gas analysis among professionals so that they engage in this preventive and complementary approach to technical control. From the 5-gas analysis, the actual state of health of the vehicle is determined. Malfunctions and the possible risk of vehicle pollution are detected. Indeed, if the control of opacity has been reinforced in recent years, the analysis of the 5 gases and their control are not part of the information communicated to the motorist during technical inspections.

→FNA is also in favor of strengthening access to relevant vehicle data for EU Member State control authorities responsible for cross-border traffic.

3 – Scope of inspected vehicles

FNA is in favor of extending technical inspection rules to other vehicles, for example all light commercial vehicles, passenger vehicles, in particular cars, motor vehicles with two or three wheels (categories N1, M1 and L).

→The technical control of category N1, M1 and L vehicles must be part of a continuity of road safety and environmental preservation.

→However, each Member State should be given sufficient time for enterprises to adapt and have training on new regulations so that to provide technical inspection services.

→Regarding technical inspection of light commercial vehicles, FNA is in favor of the introduction of an annual inspection from the 8th year. These vehicles currently have a higher rate of major failures. FNA representatives also call on the European Commission for a full technical inspection every year for N1 vehicles, instead of subjecting them to an additional pollution inspection every year. This control, which has a very low counter-visit rate, does not appear to be “very effective”.

4 – Recognition between Member States

FNA considers that it is essential for the effectiveness of the European "technical control package” that there be a standardization of rules between Member States. Currently, rules are too disparate (example of the rules governing the approval of controllers).

→For the sake of efficiency, the translation of technical control reports or official documents relating to the approval or training on European provisions must precisely use technical terms used in the Member States. Some translations are inaccurate and therefore are not understood by repair centers or operators involved in the mandatory return visit.

→FNA also questions the European Commission on the obligation for an M1 vehicle to pass the technical inspection in its country of registration. This obligation is contrary to the principle of mutual recognition.

→In the same spirit of cooperation, FNA also supports access to relevant vehicle data for EU Member State enforcement authorities responsible for cross-border traffic.

→In addition, always with the aim of efficiency and proper functioning of the “roadworthiness test” package, FNA advocates for improving the exchange of data on roadworthiness tests between the Member States in electronic form.

→FNA welcomes the new measures allowing the owner of a vehicle to obtain a valid technical inspection certificate, which will be accepted throughout the EU, in a Member State other than that in which the vehicle is registered. However, all the Member States must respect the same method under penalty of seeing a French vehicle which has passed its technical inspection in France, be refused in another country of the European Union.

5 – Vehicle approval and technical inspection

FNA calls on the European Commission to oblige car manufacturers, in order to obtain the approval of a new vehicle, to pass a valid technical inspection. This new obligation could be inserted either in Regulation 2018/858 of 30 May 2018 relating to the approval and market surveillance of motor vehicles, or in the technical inspection package. It would force car manufacturers to design models compatible with technical control legislation (passage on the benches [wheelbase of vehicles], access during pollution control, OBD connector, etc.).

→At the same time, technical inspection networks should receive all the technical information necessary to carry out the inspection as soon as the vehicle is approved. A controller is not an automotive expert, he does not have time to search for all the information of the different families on the sites of car manufacturers (example: new vehicle dashboards). This information must be easily accessible to the controller.

5.1 Car manufacturers’ recalls of vehicles

FNA supports the European Commission's proposal to entrust the control center with checking whether car manufacturers' recalls have been carried out, without however sanctioning users. Simple information to car manufacturer's network and/or the local repairer of his choice, in particular for the update impacting the safety of the vehicle, should be given priority.

5.2 Separation of repair activities

Finally, FNA does not want a Member State to call into question the principle of separation between the activities of technical control and vehicle repairs.

6 – Future of technical control

FNA takes note the various developments related to collecting data (emissions, energy consumption, use, driving aids, etc.) of vehicles. The latter being more and more connected.

→FNA encourages the “technological” development of roadworthiness testing and calls for better access to relevant vehicle data for Member State inspectors but also for EU Member State control authorities responsible for cross-border traffic.

→FNA representatives draw the Commission's attention to the need to have new methods for reading the on-board data stored in vehicles. In the future, this will be essential with the new technologies that are appearing.

→FNA is in favor of extending (or clarifying) the existing rules on access to on-board data for the purposes of periodic technical inspection, with guarantees in terms of data protection. In addition, it advocates a new method to fight against odometer fraud. It is absolutely necessary that there is a register to avoid any disputes in the event of intra-Community transactions.

→FNA does not want the European Commission to require technical control centers to obtain the consent of the vehicle owner to collect these data. Vehicle inspection centers are very small enterprises that cannot support such formalism. FNA representatives prefer that this consent be given at the time of sale or upon resale of the vehicle and archived by car manufacturers themselves.

7 – Enforceability of European provisions

FNA calls on the European Commission to maintain the choice of a European Directive instead of a Regulation. Operators will thus have the possibility of keeping certain specificities (i.e minor failures, separation of activities) depending on the Member State national provisions.