European Organisation of Agricultural, Rural and Forestry Contractors
Gasthuisstraat/Rue de l'hÃ´pital 31 b2 - B-1000 Bruxelles +32 (0)2 274 22 06 - email@example.com
New EU regulation for a uniform European type-approval for agricultural and forestry vehicles enters in force in 2016.
The new European regulation for a uniform European type-approval has major consequences. Equipment and safety are being brought up to the level of large goods vehicles, with all that this implies for brakes, vehicle widths and axle loads. Since the new rules will come into effect as early as 2016 for new models and in 2018 for all new vehicles, the challenge is to anticipate them.
Simply looking at the practical consequences is the best way to understand the new rules. With this in mind, we paid a visit to the Staja plant in Hengelo in the Dutch province of Gelderland, where the Kaweco products are manufactured. An imposing line of Radium silage wagons were standing in the yard, ready for delivery, all kitted out with the familiar 40km/hour stickers, mudguards with width indicators, a good rear bumper and equally decent lights. It seems most of the machines have air brakes, but there are also several with hydraulic brakes. You get the impression that everything is fine.
Enforced by law
In fact, however, things are a little more complicated. Officially, the new European Regulation no. 167/2013 on the approval and market surveillance of agricultural and forestry vehicles will come into force on 1 January 2016 across Europe. The regulation applies to wheeled tractors (category T), track-laying tractors (category C), trailers for transport (category R) and interchangeable towed equipment (category S). The regulation does not apply to interchangeable equipment that is fully raised from the ground.
A Ã¢â‚¬ËœregulationÃ¢â‚¬â„¢ is a set of rules legally enforced in all the Member States of the European Union, with an officially announced introduction period of two years. The aim of the new regulation is to do away with the many arbitrary sets of rules for agricultural vehicles in the EU. The new regulation will ensure that the basic requirements are the same in all the European countries. This will make it possible for manufacturers to supply uniform products across Europe without needing to obtain approval separately in every Member State. This is conditional upon a Ã¢â‚¬Ëœtype-approvalÃ¢â‚¬â„¢. As is the case for private and business vehicles, the manufacturer will have the vehicles tested once and then, if they pass, a type-approval will be granted. In itself, that all seems to be perfectly logical, but it is not. In the Netherlands, for example, there is no arrangement in place at present. Manufacturers did not have to have their products tested in the past, and that is still the case today. Clearly there are requirements for brakes, dimensions, axle loads, lighting systems and so on, but these are the manufacturerÃ¢â‚¬â„¢s own responsibility. In Germany and Belgium, for example, there have been admissibility requirements for years, with national admissibility tests that vehicles have to pass. Manufacturers know the rules and so they are fundamentally prepared in advance.
Air brakes as standard
The brake requirements have been considerably tightened in the new rules. Currently, in the Netherlands, the minimum braking deceleration requirement is 3.1 m/s2 for a total combination that can travel faster than 30 kph. According to the new rules, both the tractor and the vehicle it is towing (considered separately) in the >30 kph class must have a braking deceleration of at least 5.0 m/s2. That is the same level as for trailers on commercial vehicles. There are also supplementary requirements, such as a maximum brake reaction time of 0.4 seconds. For the existing hydraulic brakes of the single-circuit type, that is a serious stumbling block. For agricultural tractors with a construction speed of more than 40 kph, ABS will be required from 2020 onwards. New towed vehicles will require an ALR system as well as side valances (underrun protection). Since we aim for a maximum construction speed of 40 kph in the Netherlands, this does not apply, unless a lot of agricultural and forestry tractors with a maximum construction speed of more than 40 kph are introduced, such as category T5 tractor units, agricultural freight vehicles and combines. For all categories of trailer, the rule is that if the brakes fail (for example if the tractor comes loose, the tow bar breaks etc.) the towed vehicle must brake automatically (breakaway system). In a dual-circuit air brake system, this is regulated through the pressure in the supply system, but no arrangements have been made to date for single-circuit hydraulic brakes. Sometimes, however, vehicles with hydraulic brakes do have a breakaway system. The regulation also states that hydraulic brakes can be fitted on new machinery until 2019, but will be prohibited from that point on. After 2019, new agricultural and forestry trailers will no longer be allowed to be fitted with a connection for trailers with single-circuit hydraulic brakes either.
Maximum mass per axle more limited
The new rules also have an impact on the maximum weight of trailers. The current standard is officially 10,000 kg per axle plus 4000 kg weight on the connection (tow bar), as long as that is permitted for the towing vehicle. After all, not all tractors are permitted to bear tow bar loads of 4000 kg. In the new situation for this category (R4 in this case, trailers with a total weight of more than 21 tonnes), the limit for a tandem with a distance of 1.00-1.30 metres between the axles is 8000 kg per axle, for 1.30 to 1.80 metres 9000 kg per axle, and for a wide-spread (axles more than 1.80 metres apart) 10,000 kg per axle. For a three-axle vehicle, an axle load of 8000 kg is standard with axles 1.30 to 1.40 metres apart. From this standpoint, the load for a four-axle vehicle is also 8000 kg per axle. This results in a considerable restriction on the three-axle and four-axle vehicle market. And what about all the vehicles on bulky tyres, such as those with four wheels next to each other instead of one set behind the other, two high tractor wheels instead of a tandem set or two 1050 tyres as opposed to two 650 tyres one in front of the other? In such situations, it does not make much sense to think in terms of axles.
Dimensions for uniform large goods vehicles
For many manufacturers that export their products, the new box dimensions are not that much of a problem, because they are already used to building to a 2.55m exterior for Germany and Belgium, for example. That will become the new maximum dimension, taken directly from the rules for freight transport. This immediately begs an important question: does this also apply to tyres? For category R trailers used for transport, the rule is that the maximum exterior dimension including tyres (and the deflected part of the tyre) is 2.55 metres. For category S, all interchangeable towed equipment that lends the tractor a function other than merely that of transport is subject to a width of maximum 3.00 metres measured to the tyre tread. Hay tedders come under this rule, for example. However, there is a grey area: this rule would mean that a silage trailer (only used for transport) has a maximum exterior width of 2.55 metres including the tyres, but a loader wagon has a maximum width of 3.00 metres including the tyres, because it also has a loading function. However it is also stated that where a stipulated load-specific weight ratio is exceeded, the vehicle comes under category R. An empty loader or manure spreader combination would therefore be allowed to be 3.00 metres wide, but a full one would not.
This covers the main points of categories R and S (over 21 tonnes, maximum 40 kph) that are important for us. However, the regulation includes comparable rules for agricultural vehicles in category R/S 1, 2 and 3 (over 1500 kg, 1500-3500 kg and 3500-21,000 kg respectively).
Strict testing requirements
Manufacturers can still deliver untested vehicles Ã¢â‚¬ËœfreelyÃ¢â‚¬â„¢ in the Netherlands: there is no obligation to have them tested, no registration system and little enforcement. Manufacturers who want a type-approval must first be accredited by means of a Ã¢â‚¬ËœCompliance StatementÃ¢â‚¬â„¢ indicating that the company is a manufacturer that produces, documents, services and traces its vehicles according to all the rules. You are already familiar with ISO and VCA. The RDW (Dutch vehicle registration authority) is authorised to test this and grant compliant status. This involves a whole process of documentation and tracing. The manufacturer must also be able to initiate recall campaigns at any time. Then there is the test itself. In principle, it is a type-approval. The manufacturer must have the type of vehicle tested and then a type-approval with a detailed description will follow. This is subject to strict field trials for the brakes and rear bumper testing. If the vehicle passes, the manufacturer then has the right to produce and supply products to those specifications all over the EU. For example, the specifications also describe the tyre size with a load and speed index. If the manufacturer wants to fit different tyres for once, the vehicle will have to be tested separately again. It is useful here for manufacturers to obtain as broad an approval as possible.
A second option is a separate, Ã¢â‚¬ËœindividualÃ¢â‚¬â„¢ approval or small series type-approval. This is done to respond to a significant bottleneck for agricultural tool manufacturers: many machines are built to customersÃ¢â‚¬â„¢ individual requirements.
EU Member States may not reject approved trailers. The RDW, which already issues type-approvals for wheeled trailers, is preparing for the extension of this regulation (track-laying tractors, trailers and interchangeable towed equipment). Many manufacturers also approach the TÃƒÅ“V for testing work, because they have worked with them in the past for Germany. Type-approval can also be requested from the RDW or from another Member State of the European Union in that case.
It is still uncertain whether all the European countries will adopt the rules in a uniform manner. The regulation does leave space for Member States to apply their own supplementary rules. The RDW has pointed out that this regulation is not (yet) applicable to individual approvals. For as long as registration plates are not obligatory in the Netherlands, making it impossible to check technical tests, manufacturers can continue to build to customer specifications. However, once it becomes clear that obligatory registration plates are on their way and that technical tests are required to get them, there will be catching up to do.
The consequences for our sector are clear. Making the transition to air brakes is the first problem you will have to deal with. Then you need to think hard about choices of tyres and maximum axle loads. If these change, agricultural or forestry tractors, mobile machinery or interchangeable towed equipment will have to be approved all over again. Opting for 2.55 metre boxes is also sensible, since wider vehicles are unlikely to be allowed on public roads in the long term. We believe that a robust European lobby to obtain an exemption for agricultural vehicles in category R for three metres on the tyres and axle loads of at least ten tonnes per axle independently of axle spacing Ã¢â‚¬â€œ or even better, per tyre related to size Ã¢â‚¬â€œ would be a good idea, although the latter point will be difficult.
The question is, of course, is how much worse EuropeÃ¢â‚¬â„¢s bark is than its bite. Since this is a regulation, it is certainly not optional for the Netherlands. But because there is another two yearsÃ¢â‚¬â„¢ leeway to introduce it and it is not yet being enforced, the Netherlands does still have a little time to get its affairs in order, and this may include extra regulations for this country.
Staja has confirmed that, nevertheless, there will probably be a different range of Radiums next year. That will partly be because Germany is already further on in the process. They will almost certainly all be fitted with air brakes and have an exterior box size of 2.55 metres. That is purely to avoid causing problems for users in the future. Doubtless we will be hearing more about this issue before long.
Text: Gert Vreemann (CUMELA)