ASEAN Automotive Industry and JAMA Takes Up Issues of ASEAN MRA

Background

In November 2010, the ASEAN Automotive Federation Technical Committee 3 (AAF/TC3), one of the implementing working groups under the ASEAN Sectoral Protocol to harmonize technical regulations and certification systems of automotives in the Southeast Asia region, held a dialogue session with JAMA’s automotive regulations and type approval experts to exchange ideas on ways to resolve issues impeding technical harmonization, and ways to promote the harmonization process.
 
 
 
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During the bilateral meeting, the ASEAN MRA, a Mutual Recognition Agreement on type approval for automotive products and systems, which is expected to be drafted by ASEAN Member States (AMSs), was the focus of discussion.

The bilateral conference was conducted in three Working Groups: WG1 (Environment and Fuels); WG2 (Certification); WG3 (UNECE Regulations Adoption and Safety). The following paragraphs provide a snapshot of past discussion and the outcomes of the deliberation from these Working Groups and some insights. As there is a common issue between WG1 and WG3, they will be touched on first, followed by WG2.


WG1 (Environment and Fuels) calls for Fuels of Adequate Properties

Emission regulations are among the top priority vehicle regulations selected to be harmonized and incorporated under the ASEAN MRA draft. Prior to the discussion of ASEAN MRA, the WG1 had already accumulated experience in harmonizing emission standards at Euro 2 level around a decade ago. Its industry inputs to the respective governments in ASEAN have contributed to the implementation of Euro 2 emission regulations in most ASEAN countries by 2008. However, post-Euro 2 level emission standards are known to be more stringent and challenging with the use of OBD (On-board Diagnostic) systems among others.

OBD systems provide state of the art information for various vehicle sub-systems to the vehicle owner and repair technician. For the added systems in post-Euro 2 level vehicles to function well, the fuels to be used and their properties which are sensitive to these sophisticated systems are crucial. As such, the WG1 had deliberated and agreed on the appropriate fuel specifications for gasoline and diesel fuels provided by JAMA fuel experts. Ideally, each country should have fuels that meet the parameters of these specifications, especially the more important ones such as sulfur, prior to the implementation of Euro 4 level emission regulation. Euro 4 level emission regulations for both gasoline and diesel fuels operated vehicles are being considered for the ASEAN MRA. Although the targeted year for Euro 4 emission regulation is 2012 by most ASEAN countries, with understanding that some member countries may still be unable to supply the corresponding fuels by 2012, the WG1 is of view that the implementation timeline for Euro 4 emission regulation should be adhered to a given time range of between 2012 to 2016 rather than a fixed targeted timeline of 2012. The logic of this argument to have the corresponding fuels prior to the implementation of an emission regulation arises from the need to protect vehicle performance and safety.

However, even if the corresponding Euro 4 fuels were available and each AMS will be able to implement Euro 4 emission regulation, and in-turn harmonize their emission regulations implementation in ASEAN region, there may still be a problem of the versions of the regulation to be adopted under the ASEAN MRA. The following paragraphs on the discussion outcome of WG3 unfold some issues and insights of these issues.

WG3 (UNECE Regulations Adoption and Safety) on the Issues of UNECE Regulations’ Versions

With regards to the issues of WG3, to begin with, although AMSs have agreed that the UNECE Regulations1 should be the basis for harmonization of technical regulations of automotives in ASEAN region, there are 140 UNECE regulations as of today, in which some are only suitable for cold climates and are not suitable for the tropical region. The immediate adoption of all regulations at one go for the ASEAN MRA will be resourcefully exhaustive for both government administrators and industry players of each ASEAN country. Hence, the task of ASEAN countries will be the selection of UNECE regulations to be adopted in stages to cushion the burden. A four-step phase-adoption roadmap for this purpose has been proposed by JAMA and JASIC since the early 2000s to the AAF and respective ASEAN governments. The roadmap has been updated and re-proposed by JAMA experts in 2008 to better capture the needs of ASEAN countries. The AAF/TC3 members responded with their comments in the 2009 bilateral meeting with JAMA, and a roadmap of 47 UNECE regulations that span across the adoption period from 2010 to beyond 2018 was finalized by the AAF/TC3 and forwarded to the ACCSQ-APWG (ASEAN Consultative Committee for Standards and Quality-Automotive Product Working Group), a technical harmonization working group under the SEOM (Senior Economic Officers Meeting) of AMSs. Currently, the APWG has agreed on 19 regulations to be included in the draft of ASEAN MRA.

Nonetheless, as the latest version is the only version accepted under the 1958 Agreement MRA, the AAF/TC3, ACCSQ-APWG and JAMA are proposing the latest versions of UNECE regulations to be adopted in the ASEAN MRA draft. An immediate problem, however, surfaces: while ASEAN countries are looking at the Euro 4 emission standards, the latest UNECE emission regulation has already reached the level of Euro 5 and looking at Euro 6. Given the fact that there are already challenges in time and resources to upgrade refineries to produce Euro 4 fuels in support of Euro 4 emission regulations in some major ASEAN countries, there are doubts if it is even possible to adopt the latest version of emission regulation for the ASEAN MRA.

Not to mention that the emission regulation is but only one of the examples of issues of versions among regulations agreed for the ASEAN MRA. Other examples on the issues of versions related to climatic incompatibilities identified during the Manila Meeting include: Example 1, the latest version of R48 (installation of light) includes the installation of rear fog lamp, which are rarely required by ASEAN region; example 2, R83’s (Euro4) minus 7 degree Celsius cold start testing is unnecessary in tropical countries of ASEAN region.

With regards to the above issues, the WG3 during the Manila Meeting has agreed to continue to recommend AMSs to adopt the latest version for the function of MRA but bear in mind the appropriate version for domestic needs. During their wrap-up on this issue, the following options to recommend AMSs and the ACCSQ-APWG have been agreed upon:

Option 1
To adopt the latest version of UNECE Regulation with sufficient lead time.
 
Option 2
To adapt the current latest version (as of 2010) of UNECE Regulation, with the exemption of some its requirements, as a national regulation and, as an alternative of the latest version.
 
Option 3
To adapt the earlier version of UNECE Regulation into your national regulation as an alternative to the latest version.

However, a question remains among WG3 members with regards to whether or not the ASEAN MRA should fix the definition of the appropriate version or earlier version. On this matter, JAMA experts have proposed AAF/TC3 members to encourage their respective countries’ authorities to participate the WP29’s Informal Group for IWVTA (International Whole Vehicle Type Approval) that is currently debating on revising 1958 Agreement to accept earlier versions or appropriate versions of UNECE regulations. Another important reason for JAMA experts to encourage ASEAN members’ participation in the Informal Group for IWVTA is because the experts see a potential in ASEAN MRA to extend its Agreement from vehicle parts and system to the whole vehicle in the future.

WG2 (Certification) on the Issues of Technical Services (TS) for the ASEAN MRA

Although the issues of on type approval certification for the ASEAN MRA may be less complicated than those encountered in WG3, they are not necessarily easier to solve. The relative lack in Technical Services(TS) in the ASEAN region has always been an obstacle given by regulators to hold back on the implementation of UNECE regulations as the type approval certificates for these regulations have to be issued by TS. Without TS, the regulators are reluctant to implement. Although the 1958 Agreement, which the UNECE regulations are annexed to, does not stipulate that a CP needs to have a TS in order to adopt the regulations, ASEAN members find it costly to engage TS outside their region to test their products in turn for their respective certificates. Hence, there has been a general preference among AMSs to build their own TS and use their own TS in the region.

Since the signing of the ASEAN Sectoral Integration Protocol for Automotives by the ASEAN Economic Ministers that includes the plan to harmonize automotives regulations in 2004, there has been a slight increase in the construction of testing facilities. However, till now there are only a few emission testing facilities that can be seen in the region. The few emission test facilities in the region may satisfy AMSs‘ needs to certify vehicle emission system and the subsequent facilitation of MRA in vehicle emission certificates, but that would be only for one UNECE regulation under the ASEAN MRA. There are at least 18 other more UNECE regulations under the ASEAN MRA Draft that require the construction of testing facilities. Should ASEAN members wish to implement the full ASEAN MRA by the 2015 target date, the recognition of TS outside of ASEAN region is inevitable.

Furthermore, as Malaysia and Thailand has already acceded to the 1958 Agreement, they are obligated to recognize the TS authorized by Contracting Parties outside of ASEAN region.

As a consequence, during the Manila Meeting, the WG2 has agreed to recommend that AMSs and the ACCSQ-APWG accept test reports or certificates issued by TS listed under the United Nation’s WP29 document titled ECE/TRANS/WP.29/1059. The WG2 also proposed that the ASEAN MRA should not limit the use of TS to be within ASEAN region only, but allow the use of TS from the non-ASEAN region mentioned under ECE/TRANS/WP.29/1059 as well.

Conclusion

The draft of the ASEAN MRA is scheduled to be completed by the end of 2011, and be ready to be submitted to the SEOM (Senior Economic Official Meeting) and AEM (ASEAN Economic Minister) Submit by 2012. If all the issues mentioned above are able to be resolved by the end of this year, the ASEAN MRA will not only boast ASEAN intra-trade in the automotive sector but also ASEAN automotive exports to non-ASEAN countries that has adopted UNECE regulations or Global Technical Regulations (which are transferred to UNECE regulations), such as South Korea, Japan, Australia, New Zealand, European Union, US and others. The ASEAN MRA compounded with the already established AFTA (ASEAN Free Trade Area) and the to-be-established ASEAN Economic Community in 2015 will also attract further business opportunities from abroad to its region.

As the ASEAN MRA is a major project that benefit almost, if not all industry players of both ASEAN and non-ASEAN regions, JAMA experts are very excited about its development and have been impartial in offering their support to ASEAN industry members. In the past decade, JAMA experts have been actively providing their knowledge and technical advice to the ASEAN industry forum via the AAF/TC3-JAMA Meeting and the government forum via the Dialogue Partners Session with ACCSQ-APWG. As shown above, there are still some challenging issues that need to be solved urgently by the end of this year. JAMA experts will waste no time to support ASEAN industry members again by exchanging updates and opinions on the UNECE regulatory regime and ways to resolve the issues that impedes the development of the ASEAN MRA. The next AAF/TC3-JAMA Meeting will be held from 22-23 March 2011 in Singapore.

1The UNECE regulations are the regulations annexed to the 1958 Agreement, which is the only legally binding international framework under the United Nation’s WP29 (World Forum for Harmonization of Vehicle Regulations).
 

 
    
 


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