A recent European Union (EU) and United States of America (USA) joint statement regarding fair and equal trade, including mutual recognition of vehicle standards, received very little coverage or interest here in Australia, however it received much attention in the countries of origin.
The EU and the USA released a joint statement about a “Framework on an Agreement on Reciprocal, Fair, and Balanced Trade.”
Item 8 relating to vehicles detailed, “with respect to automobiles, the United States and the European Union intend to accept and provide mutual recognition to each other’s vehicle standards.”
The announcement sparked much interest in Europe as the agreement would allow European vehicles to be sold in the USA without any of the current regulatory restrictions, seemingly side-stepping any of the actual/proposed USA tariffs being put in place by the Trump administration, contradicting it seems, current USA trade policy.
Conversely, USA vehicles would be allowed to be imported and sold in the EU, at the same specification levels as sold in the USA.
This sparked comments such as those by Antonio Avenoso, Executive Director of the European Transport Safety Council who was quoted as saying: “By signing up to mutual recognition of vehicle standards with the United States, the European Union has waved the white flag on road safety. This is not a technical detail — it is a political choice that puts trade convenience ahead of saving lives.
“Europe’s mandatory requirements for life-saving technologies such as automated emergency braking, lane-keeping assistance and pedestrian protection have made our cars safer and our roads less deadly. None of these protections are guaranteed under USA rules.
“Allowing American vehicles onto the EU market on the basis of ‘mutual recognition’ of standards is a betrayal of Europe’s safety leadership, and it will cost lives. Europe now risks being flooded with oversized, under-regulated US pick-up trucks and SUVs, vehicles that are heavier, more dangerous to other car drivers, pedestrians and cyclists, and completely out of step with Europe’s vision for safer, more sustainable mobility.”
In theory, the same would happen the other way around, meaning the USA will welcome any vehicles manufactured in the EU to be allowed to be sold within its borders.
Allowing higher specification European vehicles unrestricted access to the lucrative American market.
This all seems quite simple, however there are some key aspects that have to be considered, such as the homologation/approval processes in each market.
In Europe, automakers have to follow a Type Approval model that only allows a vehicle to be sold if it passes the certification process established by the EU. In the USA, a Self-Certification model exists.
Essentially, if the automaker says a given product complies with all standards and regulations, the government just believes it does.
There is a quite rigorous auditing regime that is administered by the USA National Highway Traffic Safety Administration (NHTSA). NHTSA conduct audits and their own tests to ensure that the USA vehicle manufacturers are producing vehicles at the regulatory levels set by the American authorities.
The Australian automotive standards generally aligned with European regulations where possible.
This is almost 100 per cent in the case of light vehicles, somewhat less for trucks here in Australia.
Our unique heavy vehicle combinations and desire to take vehicles from Asia, Europe, North America, as well as our locally manufactured trucks, requires more Australian unique regulations.
There are simply, some Euro centric vehicle regulations that don’t work locally.
The Australian regulators, prodded by industry associations such as the Truck Industry Council (TIC), allow alternative global standards, where these are shown to provide the same safety and/or environmental benefits as the European base regulation.
Standards from the USA and Japan are options in many of our Australian Design Rules (ADRs).
This simplifies truck certification, allows greater vehicle choice and keeps the cost of trucks as low as possible, by not requiring vehicle manufactures outside of Europe to design and test to Euro specific regulations.
All in all, Australia has developed a vehicle certification system that recognises the world’s best practices, rather than being locked into one region’s regulatory system.
As for Europe and the USA agreeing to mutually recognise each other’s vehicle regulations, it will be interesting to watch how that unfolds!
Tony McMullan CEO,
Truck Industry Council
.png){kind=small}
