Global Crisis: Multi-Stage Type Approval and Intelligent Speed Assistance (ISA) Application

Intelligent Speed Assistance (ISA) is mandatory for M and N category vehicles as of July 7, 2024. However, significant issues have been identified in multi-stage type approval processes. Let’s delve into the details.

What is Intelligent Speed Assistance (ISA)?

As mandated by the EU 2021/1958 regulation, Intelligent Speed Assistance (ISA) is a vehicle system designed to prevent speeding by utilizing sensors, cameras, or map data to detect speed limits and assist drivers in adhering to them. This technology provides visual and auditory warnings or actively limits the vehicle’s speed, contributing to enhanced road safety and compliance with regulations.

Explore: What are the GSR II Regulations?

What is Multi-Stage Type Approval?

Multi-stage type approval is the process of certifying a vehicle’s compliance with technical requirements, enabling its transformation for a different purpose. For instance, converting an N2 category vehicle to an M2 category vehicle is an example of a multi-stage type approval process.

Manufacturers complete vehicle production by obtaining approval under Annex IX of EU 2018/858 regulation, based on modifications made to base vehicles produced by base vehicle manufacturers.

Challenges in Multi-Stage Type Approval Processes Related to ISA

Recently, in the implementation of GSR2 regulations, base vehicle manufacturers and second-stage manufacturers have been collaborating. However, this has led to a global issue.

In manufacturing processes involving category changes, the ISA system present in the base vehicle could not meet the new category requirements.

The issue primarily emerged in N1 and N2 category base vehicles being converted to M2 and M3 categories.

It was observed that the ISA systems in some base vehicle manufacturers, certified according to N1 and N2 categories, were not approved for the new vehicle category after conversion. Some brands failed to include M2 and M3 categories in their system type approval while obtaining certification, disregarding second-stage processes.

Following this realization, the need for testing and certifying STU-approved components to be installed in vehicles became evident.

In some vehicle brands, even if the system type approval included M2 and M3 categories, manufacturers could not provide clear answers on how to address the issue after conversion.

Thus, the process of ensuring that vehicles converted from N1 and N2 categories to M2 and M3 categories comply with EU 2021/1958 regulation remains unresolved.

While this situation goes unnoticed in many countries, some nations are trying to enforce compliance. Consequently, many vehicles are being produced without adhering to the relevant regulation.

Two Active ISA Systems in One Vehicle

An additional issue arises in vehicles requiring the installation of extra components, as it leads to two active ISA systems. According to regulations, the ISA system in the base vehicle cannot be deactivated. However, when second-stage manufacturers install additional devices, the system displays warnings on its own screen.

In this situation, the vehicle user is presented with two different speed sign warnings.

For instance, while the ISA system in an N2 category vehicle provides a speed warning of 90 km/h, a device installed for the M2 category may issue an 80 km/h warning. The reverse scenario is also possible.

Since this situation conflicts with the regulations, such vehicles are essentially produced in non-compliance with type approval standards.

Increased Vehicle Costs

During the conversion to M2 and M3 categories, second-stage manufacturers face an average cost increase of €1000 per vehicle. Suppliers only accept orders in bulk, resulting in significant investment costs.

Disagreements Among Technical Services

Accredited technical services disagree on the compliance of these conversions, citing that the installation of such devices leads to dual warnings in the base vehicle, rendering them unsuitable. 

Challenges in Complying with EU Regulations Outside EU Countries

Some countries outside the EU (such as Turkey and Israel) are striving to align with European Union regulations. However, these regulations are limited to the borders of EU member states. As a result, many component manufacturers lack the necessary mapping permissions, causing the systems to fail to operate fully in these countries. Nevertheless, these nations expect the systems to function in compliance with the regulations.

Both base vehicle manufacturers and second-stage manufacturers face significant challenges in these regions.

Authorities may impose severe penalties due to these non-compliances.

Manufacturers Awaiting New Regulations

2nd stage manufacturers are expecting an exemption under the EU 2021/1958 regulation. They advocate against applying the regulation to multi-stage type approval processes due to issues such as system incompatibilities, integration challenges, and high investment costs. It is reported that base vehicle manufacturers are exerting significant pressure, and there is talk of a global crisis within the industry.

Authorities, however, remain silent.