How to successfully get your E-Mark

We've covered in our last columns, why a focus on other markets than America, and a focus on after sales in general are essential for success in the parts business. The parts industry needs to change its focus fast as bad news keeps coming in. You’ve heard the bad sales news. The truth may be worse. For instance, a Credit Suisse analysis now says that the December Seasonally Adjusted Annual Rate (SAAR) in the U.S.A. may actually have been 9.9 million if adjusted for the unusually high “fleet sales.”  Fleet sales are a euphemism for sales to car rental companies, a dumping ground for cars in distress. The outlook for U.S. sales in the first quarter of 2009 is no brighter than the 2008 exit rate. Both Ford and GM suggest that sales could run in the 10 to 11 million range in the first part of 2009. The German new car market on the other hand only lost a mild 1.8 percent in 2008. Repair shops report brisk business as people drive their cars longer.

You want to be in the European market with your parts, and you want to be in the huge after sales market with your parts. As explained in last week’s column, this means for many if not most parts that you receive an E-Mark, as the ECE certification is commonly called. For many parts, an E-Mark is the key to unlock Europe and more than 50 nations of the world as your markets.

Let’s look at how to get an E-Mark.

Before we do that, let’s look at how to definitely not get an E-Mark. As E-Marks get increasingly important, there is also an increase of forged E-Mark documents. Forging one does not require a lot of skill. An E-Mark certificate is a simple document, anyone with a computer can make one up. Don’t even think of doing it. As easy as it is to forge the document, as easy it is to find out that it is forged. Our company does not rely on any E-Mark document. All E-Marks and their holders are kept in readily accessible databases. It takes us just a few minutes to key-in the E-Mark number and to find out whether the E-Mark is real or not. We check every E-Mark, and every serious professional buyer will do the same. Fake E-Marks get reported and news travels fast. Only amateurs get duped by a fake E-Mark, and only fools will fake one. 

Let’s follow the route of acquiring an E-Mark using the example of a brake pad.  Your brake pad needs to fulfill the requirements of ECE Regulation 90, which can be found here. You will also find 5 amendments, which are likewise important.

According to the rules, your brake pad should behave comparable to the original OEM brake pad. “Comparable” usually means that it doesn’t deviate more than 15 percent from the braking characteristics of the original part. Of course, it also needs to fit like the original part. 

One thing should be firmly kept in mind: ECE does not make a difference between “OEM” and “OES” and “Aftermarket Parts.”  The ECE rules are the same for all. Europe typically does not differentiate between “OEM” and “OES,” at least not as far as E-Marks and ECE rules go.

When you develop your part, you need to get as close as possible to the performance characteristics of the original part. Your brake pad must stay firmly within the limits set by ECE Regulation 90.  How you do this, which friction material you use, which production process you use, all of this is your choice. It will have no influence on whether the E-Mark will be successfully awarded or not. What counts is the performance of the part. 

When you develop your part, you should obtain several samples of the original part and compare your part against it, using the rules in the E-Mark documentation. Do not compare your part to an aftermarket part. The aftermarket part is legal if it deviates not more than 15 percent from the original part. If it deviates 14.9 percent, it is still legal. If your part would then deviate just 5 percent from that part, it would be illegal. Always test against the OEM part. Actually, always test against several of the same OEM parts, because OEM parts can and do have deviations.

When you are sure that your part is ready for testing, then you need to have it verified by an accredited testing lab. How to find one was covered in my last column.  After a successful test, the testing lab will file a technical report with their government agency, and you will receive the coveted E-Mark.

If this is your first E-Mark, then the technical service typically has to perform an audit of your company. They are not interested in your trade secrets. For instance, with a brake pad, you don’t need to tell them the secret formulation of your friction material. The idea of the audit is to make sure that your company is capable to maintain the quality of the part.

Here are some things the auditor will look for:

Are you set up to control the quality of your part? The auditor will visit your testing lab and will check whether the lab is being actively used.

Are the quality parameters documented and readily accessible to those who perform the tests? Auditors like signs that spell out the rules clearly.

Does your testing lab perform regular tests and document the results? If an auditor will visit your lab and notice in the testing protocol that the last test was two weeks ago, he will not be happy. If there is no testing protocol, he will not be happy at all.

Are the batches clearly identified? Auditors like containers or parts bins with clear written markings.

Are bad parts clearly separated from good parts?  Auditors will give you points if bad parts are kept as far away as possible from good parts, and kept in bins or containers clearly marked as “Scrap. Do not use!”

Have you undertaken all precautions that the same product is being produced as tested? For instance, with a brake pad, have you made sure that the exactly same friction material in the exact same mixture is being used at all times? Can you demonstrate to the auditor how you control this?

This is just a short overview. You should discuss the audit with your technical service before it is performed. A good technical service will give you the proper advice and assist you in making changes necessary to successfully complete an audit.

At the end of the audit, the auditor will usually tell you whether the audit was successful or not. If it was not successful, he will point out why. If the audit was not an absolute disaster, the auditor may give you the go-ahead to continue the E-Mark process subject to a successful second audit which the auditor will schedule with you.

Passing the audit and receiving your E-Mark certification is like successfully completing an exam.  But this is where the similarities end. After an exam, you typically quickly forget most of what you have learned, and typically, you will never ever be asked again. Different with the E-Mark certification. Getting the E-Mark is the first step. Keeping your E-Mark is the all-important second step.

We will talk about keeping your E-Mark next week.