FIGIEFA Monitoring Upcoming Euro 7 Regulation
The Euro 7 Emission Regulation would impact directly on the Parts Trade in several key emissions-related parts which independent distributors and wholesalers sell in quantity today.
The issue relates to the introduction of tamper protection measures under Euro 7, whereby authorities at EU level will require manufacturers to protect vehicle systems/components that record the emissions performance of their vehicles over the first 200,000 Km and during 10 years of its life. The Commission wants to be sure that the data collected is correct and ensure integrity for this data. Both hardware and software measures are considered for tamper protection implementation. Euro 7 Regulation requires tamper protection measures to be implemented in the engine and engine control units, fuel injection systems, vehicle pollution control device and systems, propulsion systems, traction battery, odometer, OBFCM (On-board Fuel Consumption Monitoring) or OBD/OBM (On-Board Monitoring) devices. In addition to the general identification of tamper protection relevant systems, the Regulation also aims to identify some specific components under OBM that needs protection. This is likely to include (but not limited to) components like : NOx Sensors, DPF filters, EGR components, catalytic converters, turbo chargers and air mass meters.
For the implementation, it seems that the Commission will opt to make vehicle manufacturers responsible for deciding precisely what measures they would use on their own vehicles. From what we heard in the Commission’s AGVES Working Group (dealing with the implementation) it seems that the European Commission intends to use the mechanisms of the UN R155 (the UN cybersecurity regulation) and the ISO 21434 (the cybersecurity engineering standard). This would mean that the implementation of such measures is left to vehicle manufacturers, i.e. proprietary implementation measures would be used to ensure tamper protection. This would be a serious concern for independent parts producers (but also T1), as without specific legislation, they would not be able to develop OBM/OBFCM-compatible replacement parts. Independent operators need access to the info, tools & processes required to remain interoperable with such vehicles (this is fully in line with the Cybersecurity amendments FIGIEFA/AFCAR had drafted already one year ago).
In addition to tamper protection, Euro 7 also aims to introduce additional measures for measuring tyre abrasion and checking particulate emissions from brake components. For tyres, there is a possibility that even non-Euro 7 relevant vehicles will need to be fitted with Euro-7 compliant tyres.
What this means for the independent aftermarket?
- Under the Euro 7 scheme, aftermarket operators would have no reference for implementation for tamper protection measures used on emission relevant parts, as these are implemented by each vehicle manufacturer in a proprietary manner. This can result in a situation where independent and original replacement parts would not be compatible any longer with the security implementation of the vehicle.
- For brakes systems/components, we expect the Commission to define additional ‘Euro 7 type-approval’ requirements around particulate emission which will also be relevant for all replacement parts associated with brake systems.
- Introduction of Euro 7 could mandate that only Euro 7 compliant tyres can be fitted in all vehicles, including older vehicles. If this was to happen, independent parts distributors would need to be vigilant to the impact on their stock of pre-Euro 7 tyres.
FIGIEFA is participating in the Commission's AGVES working group, where these issues are discussed. We are currently in the process of analysing the impact of such provisions and would like to reach out to you and companies to get some operational and market insights and the potential impact on distributor’s product portfolios. We would also wish to discuss with technical experts the ramifications of anti-tampering measures that may happen at a physical level, but could also in many cases be software-based, and the question whether an R155 style risk assessment based approach is the normal engineering way to address this or not.