Fedecom Proposal to the Ministry of Infrastructure and Water Management Regarding Progress on National Type Approval

Fedecom Proposal to the Ministry of Infrastructure and Water Management Regarding Progress on National Type Approval

Is a national type approval system still relevant in the Netherlands? That is the question, given the approval by European institutions of the legislative proposal for harmonized road admission requirements and procedures for mobile machinery, the expected publication of the framework regulation around September/October 2024, and the planned implementation in 2027.

The resulting delay in the implementation of Dutch type approval has significant consequences for manufacturers’ interest in investing in Dutch type approval. Many no longer consider the payback period to be feasible.

An interim solution—as an alternative to the implementation of Dutch type approval in its original form—is desirable until the introduction of a harmonized European system.

Fedecom, BMWT, FMIB, and the RAI Association, with the support of Cumela and Transport and Logistics Netherlands, propose maintaining the temporary arrangement and opening it up to interested market parties, provided that participating suppliers handle this in a responsible manner. One way to achieve this could be an accreditation system combined with random inspections. This is similar to the APK system, which allows the RDW to verify the correct registration of mobile machinery and, where necessary, to revoke accreditation and require a supplier to undergo an individual inspection.

As representatives of mobile machinery suppliers in the Netherlands, we look forward to engaging with stakeholders to explain this alternative and develop it further.

On behalf of the industry associations: