By on March 8, 2010

The Japanese government floated a highly interesting idea in Geneva. It could possibly revolutionize international car trade. Except for the United States. According to today’s Nikkei [sub], the Japanese government has proposed that the World Forum for Harmonization of Vehicle Regulations, a working party of the United Nations Economic Commission for Europe, create a system for international whole vehicle type approval. The UNECE immediately began looking into the idea last Saturday, and as per the Nikkei, by Saturday evening, “a majority of the member countries had agreed to the proposal.” That was fast.

It did not need much work: An international mutual recognition framework already exists for automobile components. The USA and Canada are absent from this framework. Says the Nikkei: “But for vehicles themselves, automakers have to obtain for each model approval from their own government as well as the governments of the countries to which they export.” Well, not exactly.

In Europe exists something called European Community Whole Vehicle Type Approval (ECWVTA). A car that is legal in one country of the EU is automatically legal in the whole EU. The ECWVTA relies heavily on the UNECE framework and embodies most UNECE regulations into the Whole Vehicle Type Approval process. But, this applies only to Europe. The idea of a (more or less) worldwide Whole Vehicle Type Approval scheme had been floated at several times. It received the cold shoulder, especially from Japan. Until late, Japan, although a signatory to UNECE, had been dragging its heels. By the end of 2008, Japan had included only 35 of the 127 existing ECE regulations in its JASIC rules.

Recently, Japan became more activist. They made advances to include their EV standards into the ECE rules. When this happened, TTAC opined: “Hopefully, worldwide adoption of Japan’s standards for hybrid and electric vehicles will entice Japan to adopt more ECE rules. It would be a big step towards a world of internationally accepted safety and emission regulations, a world from which the U.S.A. decided to isolate itself.”

It is highly interesting that the initiative for an UNECE-wide whole car type approval comes from Japan at a time when its industry receives heavy flak from the U.S. As you can see from the immediate reaction, the other UNECE members had just been waiting for this. Adoption is basically guaranteed. This would allow manufacturers from other UNECE member countries instant access to Japan and South Korea, which currently have their own stringent type approval rules. It also would open the doors to the 52 member countries of UNECE.

Who will be left out (most likely to loud protestations)? The USA and Canada. The USA had deliberately chosen not to join UNECE. Canada, which is an adjunct of the U.S. auto industry, had no other choice and remained a non-member. Under Whole Vehicle Type Approval rules, a car is rigorously tested by a government agency before it is admitted to the road. The U.S. Federal Motor Vehicle Safety Standards (FMVSSs) embody no such checking.

NHTSA proudly proclaims on their website: “It is the responsibility of a manufacturer of vehicles and/or items of motor vehicle equipment to certify that each motor vehicle and/or equipment item is in full compliance with the minimum performance requirements of all applicable Federal Motor Vehicle Safety Standards (FMVSSs). This is a self-certification process as opposed to the type approval process which is used in some other countries such as Japan. The NHTSA does not issue approval tags, stickers or labels for vehicles or equipment items before or after the first sale. In order to provide certification, the manufacturer takes whatever actions it deems appropriate.” This policy is a disaster waiting to happen, and it is just as ambulance-chasing attorneys want it.

If UNECE goes to Whole Vehicle Type Approval, manufacturers of member states will have zero time to other UNECE markets, whereas US manufacturers must go through a separate type approval process and manufacture their export cars according to the worldwide standard.

America becomes increasingly isolationist; the rest of the world closes ranks and becomes more open – towards the rest of the world.

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29 Comments on “Japan Proposes International Whole Car Type Approval. USA Gets Isolated...”


  • avatar
    niky

    So… status quo for the USA while the rest of the world goes forward? What’s new?

  • avatar

    Ha ! Two things…remember the horrid DOT headlamps ? US kept those for a long time, citing easy to replace, but it was really a sop to the US makers…

    Crash issues…Euro has much stronger rollover and rear strike rules than US….which is why I prefer euro cars for that reason alone.

    Remember, kids, if it costs the US makers a dime a unit, they’ll fire up the lobbyists and fight tooth and nail.

  • avatar
    tced2

    Now that the folks in the District of Control are in the auto business (see GM and Chrysler), they will be interested in selling in overseas markets. They will eventually have to enter the UNECE world. Not so simple is it? – these folks think they know how to do everything well.

  • avatar
    crash sled

    Oh, it’s not costing the makers anything, as they just pass on the cost. It’s costing consumers.

    We aren’t Euro-nannystatists here. We don’t need any more massive government bureaucracies than we already have, and we can’t afford even those. I check crash and rollover on my vehicles, so can you. I don’t need a government slug to do it for me, because he probably doesn’t know how to do it anyway, judging from the LaHoodish NHTSA’s performance recently.

    Frankly, I don’t care whether a multinational corporations makes more or less cash in foreign countries. If they do, great, and I hope my portfolio includes them. If they’re too stupid to do so, great, I hope they’re absent from my portfolio. That’s completely apart from what we as a society need here, and that need can and should be different from that of those who prefer the nanny state.

    • 0 avatar

      The technical checks are not performed by bureaucrats, but by very capable privately owned laboratories that need to obtain accreditation from the government. I work with them every day, and they are a joy to work with.

      I posit that one reason why you don’t have these massive scandals in Europe is that they check first instead of asking questions later. Of course, something like that would put thousands of lawyers out of business.

    • 0 avatar
      psarhjinian

      I posit that one reason why you don’t have these massive scandals in Europe is that they check first instead of asking questions later.

      This also explains why Americans pay so much for health care, but get such poor service.

    • 0 avatar
      crash sled

      Bertel, I’m charmed by your naivete. ;-)

      The “technical checks” are performed by bureaucrats, and are established by a bureaucracy, which is subject to all the external forces that work on any bureaucracy. Said bureaucracy’s first goal is to sustain itself at all costs and to be immortal and to grow, with all else holding secondary position, as any organizational behaviorist will attest.

      Establishing this system will grow the bureaucracy. Simple.

      Now, fine if the Euros prefer this, and I have no doubt your experience with the Euro reg bureaucrats has been solid. But, this also costs money, and is one of the reasons public employees in states like Greece and France go on strike, because the bureaucracies have grown to crushing mass, and have accompanying power. There is a social cost well beyond the gearhead aspect, and we must be mindful of this. They clearly are not over there.

      Now, as for your positions anti-lawyer, I’m right there with you, brotherman. But let’s treat the disease, not just its automotive industry symptom, because the litigations disease is parasitical across the spectrum of our society. Here’s where we can use some absolutely marvelous Euro ideas beneficially: loser pays, lawsuit abuse reform, etc. Stuff that will keep PLENTY of money in ALL of our pockets.

      .
      .

      And psar, Americans are quite pleased with the quality of their health care service, if you check the statistics, and certainly don’t want massive changes to that. Some changes to streamline? Certainly. Cost? Certainly, they want that dropped. But let’s not foolishly get into the game of comparing the US with the socialized medicine bureaucracies, and death rates of cancer victims as compared to here, because service wise, you’d be WELL off to be living here in the US, as opposed to those socialized medicine joints.

      Queued up for your MRI lately?

    • 0 avatar
      frodo_17

      Crash Sled you are missing the entire point of the article.

      A single set of safety and emissions standards (which has been bandied about for decades) would open up European and Asian markets to U.S. and Canadian built cars in a way we have never seen before. U.S. labor rates are very competitive with Europe (especially Western Europe) and Japan. We have demonstrated the ability to produce high quality products and there is no reason we could not go after those markets. The real goal will be to get into China and India but thus far the only way to get to those markets is by partnering with a native company and building factories locally.

      A single set of standards makes importation of products from one country to another much easier. The world isn’t getting smaller, it’s already there. It also makes it much cheaper for the automakers to design and build high quality cars. Hell, Ford Motor Company should be all over this. This is Alan Mulally’s dream writ large.

      If we in the U.S. and Canada don’t want to be part of that process then the world will move on and we will loose.

      As for your comments on health care well it’s not really the purview of an automotive enthusiast site but a couple of points need to be made.

      1. The U.S. has the highest cost of health care per capita in the world (17% of GDP) and that figure is rising.
      2. The U.S. is ranked number 37th in the world in global health measures (according the the WHO). This includes life expectancy, morbidity due to chronic diseases, infant mortality, etc.
      3. Japan and most of Europe have better health and health care statistics at half or less of the cost in the U.S. This is also true of Canada.
      4. There is no movement in any of these countries (including Canada) to adopt a U.S. style health care system.

      Normally, I wouldn’t post this on this website but it’s an area that I have expertise in and health care absolutely adversely impacts U.S. competitiveness in world markets. Oh by the way, federal Tort Reform would have very little impact on the cost of health care. In fact, malpractice insurance costs and pay-outs are largely decoupled.

    • 0 avatar
      crash sled

      Oh I get the point of the article, and attacked its point directly.

      And what’s with this royal “we”? I don’t care about a multinational corporation… any multinational corporation…that’s neither “me” nor “we”. If that multinational succeeds, fine. If it doesn’t. Fine. If the Euros have a set of bureaucratic hoops they want to set up. Fine. Jump through them. Or not. Platform your vehicles accordingly. Fine. Or not.

      You’re right about the Asian markets though, and I suspect this is why Japan has come around on this. They have a 1.3B market next door, and they want a place at that sushi counter. I think their akita is barking up the wrong tree, however, as the Chicoms will game this same as they game everything else. And that’s fine as well. As long as my taxpayer dollars aren’t used at the poker game table.

      Mullaly didn’t dream up homolagation. Ford was on that bandwagon years ago, and dear old Jag and other acquisitions were a part of that. Fine. They can and are handling the necessary platform harmonization, and we can do without the added federal bureaucracy. Fine, again.

      We’ll be fine, no need to be frantic about the terrible hole we’re moving into here in NA. I don’t see it. We got 400M people here doing their thing, and the Euros have something similar doing their thing. Fine. And the Chicoms and Indians will of course be doing THEIR thing, driving around in whatever soupcans they cobble together.

      Engineering standards are always best employed at a high level. If FMVSS xeroxes portions of the Euros work, where it’s simple and workable, that’s wonderful. Heck, the Mexicans xerox US EPA standards and use them all the time, been doing it for years.

      But anything more than that builds in a nanny statism that simply isn’t what we’re about here.

      .
      .

      No interest in pursuing a long health care discussion, suffice to say that the American people disagree with you, and at the state levels have enacted legislation in contradiction to much of what you’re describing. Are you still waiting in that MRI queue?

  • avatar

    I’m all for it if it allows me to import a Toyota Crown from Japan to Texas. How about giving us the option to buy a Kei car.

    Ford and GM are already looking for more ways to use their European and Asian designs in the US market. GM pretty much wants to bring several of their Opel products over as Buicks. Ford is FINALLY building the European version of the Focus in the US (it is vastly better than the current Focus)

    • 0 avatar
      crash sled

      Yes, the Detroit 3 have had a “homologation” effort underway for many years, with world class standards and other such gobbldeygook acronyms, which amounts to making platforms that cross borders seamlessly. Good. They’re handling this, as they should be. No need to nanny them. Heck, we here can even leverage the Euro nannies’ work, and spare the cost of new bureaucratic burdens here.

      Sort of like the Euros have historically leveraged medical innovations developed and paid for here in the US.

  • avatar
    Robert Schwartz

    Rick: Only if you like driving on the wrong side of the road:-)

    More to the point, I don’t see the US participating in this type of exercise so long as it owns two thirds of the American automobile industry.

    • 0 avatar

      Then we don’t want to hear them ever again crying that they are prevented from entering foreign markets by rules which are foreign to them ….

    • 0 avatar
      crash sled

      “Then we don’t want to hear them ever again crying…”

      .
      .

      Bertel, the Detroit 3 will NEVER stop crying. If it’s not over this, it’ll be over something else. They’ve been crying my entire lifetime. When I go out on the road away from SE Michigan, I have trouble falling asleep without the soft whimpering of Ford, GM and Chrysler lulling me to sleep. ;-)

  • avatar
    psarhjinian

    I don’t think this is as much a conspiracy of the bigger automakers as it’s exemplar of American (and especially American governmental) NIH syndrome.

    No one likes to admit that perhaps they haven’t been doing things the right way, but it’s a little different to be told it when you’re a superpower.

  • avatar
    criminalenterprise

    If this never happens, it’ll be due to the corporate tendency to remain a Newtonian “object at rest.” The U.S. auto market has been a place to collect rent.

    I’m reminded of the charts and graphs in An Inconvenient Truth showing global MPG and emissions averages, where the U.S. industry lagged behind glaringly, but with the excuse that such regulations would make them unprofitable and uncompetitive.

    The next slide showed their performance in domestic market share over recent years.

  • avatar
    jkross22

    And in other news, the US government has decided to outlaw calculators in favor of bringing back the abacus.

    We have few leaders with courage in government or private industry, and this is the result of that vacuum.

  • avatar
    Bill Wade

    crash sled
    March 8th, 2010 at 8:48 am

    Oh, it’s not costing the makers anything, as they just pass on the cost. It’s costing consumers.

    We aren’t Euro-nannystatists here. We don’t need any more massive government bureaucracies than we already have, and we can’t afford even those. I check crash and rollover on my vehicles, so can you. I don’t need a government slug to do it for me, because he probably doesn’t know how to do it anyway, judging from the LaHoodish NHTSA’s performance recently.

    Frankly, I don’t care whether a multinational corporations makes more or less cash in foreign countries. If they do, great, and I hope my portfolio includes them. If they’re too stupid to do so, great, I hope they’re absent from my portfolio. That’s completely apart from what we as a society need here, and that need can and should be different from that of those who prefer the nanny state.
    ___________________________________________________________________

    I like the thought of organizations like this: http://www.smf.org/stds.html testing my motorcycle helmets versus the manufacturer claiming it’s good, nanny state or not.

    • 0 avatar
      crash sled

      That is the generic system we use here in this country, Bill. Self reporting, and independent verification where required. We tend to trust the different engineering societies and organizations, industry groups and other technically proficient folks. I’m not at all surprised to see such a group involved with motorcycle helmets, nor that governmental legislation and administrative actions would be platformed upon their work. That’s as it should be.

  • avatar
    Tricky Dicky

    One more nail in the coffin of American industry IMO. Trade is the basis of wealth creation. Choosing to not trade is like putting a gun to your own head and inviting someone else to pull the trigger.

    The age of unilateralism is past and I sincerely believe that the US can make a much better future for itself by learning a new way of dealing with other markets. Isolationism will never allow the US to show it’s real strength as a confident competitor….

  • avatar
    bmoredlj

    ***removed***

  • avatar
    50merc

    If this issue didn’t have a connection to an organization with “United Nations” in its name, it’d be an easier sell in the US. Most Americans don’t give much thought to the UN, but when they do, they see it as overpaid and ineffective sinecures for Global Government tea-sippers and a forum for fleabag dictatorships to beat up on America. Most Americans like America, and resent it being depicted as the Big Bad Wolf of the world. Ironically, the US is a founding member of the UNECE, which was established as part of America’s efforts to resuscitate Europe from its Second Civil War.

    But in general, the American public couldn’t care less as to whether international whole car type approval is adopted here. Opposition comes from–
    1. Firms that fear more competition from abroad;
    2. Labor, which fears the effects on industry of more competition;
    3. Lawmakers and bureaucrats who like having their own thing; and
    4. America-firsters, who are suspicious of what furriners might do.
    Of the four groups, only the first three have much influence. In fact, here in Flyover Country, we like international trade. We export stuff like wheat.

    And I can’t understand why Canadians are so angry about health care in the United States. After all, they get the benefit of our pharma R&D at bargain rates. And as a certain provincial Minister recently did, they can slip over the border to partake of our “ready when you are” facilities. (Which is strange, considering that Cuba’s health care is so much better, according to Fidel.)

    • 0 avatar
      psarhjinian

      If this issue didn’t have a connection to an organization with “United Nations” in its name, it’d be an easier sell in the US.

      This gets back to my point about NIH syndrome. America has a serious case of it, as did Japan until the Lost Decade. Europe does, but it’s member states don’t. It’s very hard for many nations to admit that the way they do things is perhaps not the best, and that they should adopt another nation’s model**. You cover this much more succinctly in your points than I do here.

      There’s no real reason for the American marques to fight homologation as the big European competitors have shown they have no interest in trying to design vehicles Americans want to buy and, as such, they aren’t really fighting this fight.

      What is driving it is partly smaller players, but mostly hubris on the part of American administrators for whom adopting UN or Euro rules would be a loss of face and a ceding of power.

      Off-topic alert!

      And I can’t understand why Canadians are so angry about health care in the United States.

      Because our system is continually dragged through the mud by people who can’t understand why making a rich guy wait for a hip replacement is not worse than seeing hundreds of poor people get sick and die or mortgage themselves into financial oblivion.

      And as a certain provincial Minister recently did, they can slip over the border to partake of our “ready when you are” facilities.

      This is the bit that Americans don’t understand. The American system works really well if you can pay cash or have really, really good insurance, but isn’t available or works very badly if you are poor and/or have bad insurance. The Canadian system doesn’t work as well for rich Canadians, but it works for all Canadians.

      In the case of Danny Williams, yes, he hopped the border. What options does an uninsured American have? Can he/she go to Canada?

      (Which is strange, considering that Cuba’s health care is so much better, according to Fidel.)

      It is, if you’re poor or don’t need a specialist. Poor Cubans have better health care than poor and uninsured middle-class Americans. I’ve been to Cuba (I go yearly to see friends) and what they lake in pharmaceutical and high technology they make up for in preventative and prenatal/neonatal. Cuba’s pre- and neo-natal care shames Canada’s and, by inference, that of the US, especially for the poor.

      ** like the Canadian banking regulation regime. We schooled the lot of you on that one, eh?

  • avatar
    faygo

    harmonized world regs would be a _very_ good thing.

    the US manufacturers would (eventually) be able to ramp down their in-house certification groups and whatever outside certification provider(s) would take their place. the costs might go up/down/remain the same. they would flow to the consumer either if they went up, probably not if they went down (no surprise).

    I don’t see any difference from legal standpoint – people sue now because a car didn’t meet future regs when sold (people crash cars without side airbags, sue because they weren’t installed, car company replies that they weren’t required and the customer didn’t spend on a more expensive car which had them, car company loses anyway) or because the regs aren’t good enough (rollover standards).

    this wouldn’t change if the vehicles were tested by someone other than the car companies. I don’t believe anyone has ever accused the car companies of claiming to meet regs when they actually had internal testing which indicated that they didn’t.

    AFAIK, global vehicles designed as such from the start do not have significant extra certification costs now.

    emissions regs vs safety/crash regs are significantly different, tho it’s easier to to emissions different by market than it is to do safety. I would imagine that even if we were to agree to global safety regs, emissions would be too contentious and would remain regional/national.

    • 0 avatar
      crash sled

      “harmonized world regs would be a _very_ good thing.

      the US manufacturers would (eventually) be able to ramp down their in-house certification groups…”

      No, I don’t think so. The OEMs must meet the regs. To do that, their product development teams perform certification… that’s part of their job. You can’t turn out a vehicle, then throw it over the wall and hope it passes somebody else’s cert. It don’t and won’t work that way. You must know all along during development.

      CERT is and would remain a core activity, and will/would be fully paid for by the OEM, with our without the addition of a costly eurocracy.

      You’re correct that emissions regs would be one of the most contentious aspects of this eurocracy. The Euros would of course prefer an alarmist interpretation of emissions requirements, supported by all of the state-supported Gilbertine “science”.

      And I just now put a trademark patent on “Gilbertine”, so don’t even think about about using it without paying me. ;-)

  • avatar
    George B

    How much difference is there between the UNECE and FMVSS standards? I’m used to designing RF circuits for products that have to pass both US FCC and European ETSI requirements. It really helps when regulatory bodies agree on how measurements are done so lab work can be reused. Designing a “world” product then usually just means meeting the tougher requirement from the two camps so one product can pass both sets of standards.

    The big negative I would worry about would be any effort by the Europeans to restrict the choices of cars Americans can buy. We’re already seeing ugly big nose less aerodynamic cars designed to meet pedestrian safety requirements that seem laughably unnecessary for pedestrian-free US roads. It’s easy to see someone somewhere trying to regulate Americans into smaller, less powerful cars.

    • 0 avatar
      crash sled

      “Designing a “world” product then usually just means meeting the tougher requirement from the two camps so one product can pass both sets of standards.”

      .
      .

      Precisely. It really is a simple process. You pick the tightest envelope in your total market, and go from there.

      Some seem to be thinking that designing to multiple standards is some sort of chore, and that a massive cost savings arises from removing such an obviously imposing obstacle. I don’t see it.

      Try engineering to the standards of a State, a County, a municipality, multiple Federal agencies and a few other funcitonal groups I can think of, all on a one-off project the costs of which can’t be spread out over millions of vehicles sales but must rather stand alone, and then get back with me as to why you believe that automotive engineering to multiple standards is some sorta tough task. It ain’t.

  • avatar
    niky

    US roads aren’t pedestrian-free. Unless you don’t count deer.

    -

    Signing in to this and ending the historical rift in US and European regulations would make both Ford and GM stronger. Building to one set of standards means that you don’t have to spend extra money and find another supplier for headlights or tail-lights for different markets… or designing to meet different crash-test criteria (which costs money… and confusion… the BMW brouhaha a few years back comes to mind).

    Whatever losses they get in local sales (which aren’t that much… most people are going to buy domestic or domestically produced imports due to taxes anyway) they’ll regain by increasing harmony between US and Global operations, leading to cost-savings and possibly more sales.

  • avatar
    James2

    Shrug. Instead of multiple global regulatory standards there would just be two. Ours and theirs. Since most of the major automakers choose to sell their wares globally, this certainly simplifies their lives. Exactly how does the American automakers suffer, again? Ford and GM will find their European engineers doing more useful stuff other than ensuring compliance –and since both carmakers have already started harmonizing their products when and where possible… again, how are the automakers suffering?

    Jeez, is this even an issue? The rest of the world moved to the metric system how many decades ago… and the U.S. didn’t… and somehow, amazingly, the world didn’t come to end.


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