Tricks of the ECE trade

There is the easy way and the hard way to get your ECE (or E-Mark) certification. Let me show you the easy way.

I have written many times about the importance of ECE certification for the parts business. More than 50 countries are part of the ECE. Many countries, even if they are no formal members, recognize the ECE Regulations and either mirror the ECE Regulations' content in their own national requirements, or permit the use and importation of ECE-approved vehicles. The notable exceptions are the USA and Canada, they live on their own planet and do their own thing. If you want to sell your parts elsewhere in the world, better make yourself familiar with the ECE regulations.

In this and the following columns, I will talk about some secrets of ECE certifications.

In this column, let’s get the general questions out of the way:

How do I know whether my part needs ECE certification?

There is no easy way to find out. Sure, you could work your way through all (at the time of this writing) 126 regulations (click here for the text.) But apart from a good knowledge of either English, Russian, or French (those are the official languages of the documents,) you also need a law degree to understand the dense writing, and an engineering degree to understand the specs.

What’s more, not all ECE members have adopted all ECE regulations. Europe usually adopts all of them, other countries just adopt a few. Japan for instance is a full ECE member, but has adopted less than 20 regulations.

The only way to find out whether a part needs to be certified in the importing country is to ask their governmental agency that is responsible for these matters.

My part does not need to be certified. Can I rely on this?

No, you cannot. New regulations are constantly being added. What’s more, different parts are being added to current regulations. For instance, brake pads are covered by ECE R-90. Brake disks are not. However, there is on-going discussion to add brake disks to the ECE R-90 regulations. Other changes are being contemplated in other regulations. You should tightly monitor the regulations concerning your products. A good technical service will be able to give you enough advance warning.

Is there a difference between the type approvals issued by individual countries?

Theoretically, no. Theoretically, an E-1 issued by Germany is just as good as an E-39 issued by Azerbaijan. The main idea behind ECE is that participating countries agree on a common set of ECE Regulations for type approval of vehicles and components. When an item is type approved for a regulation by one participating country, then the approval is accepted by all other participating countries. So far the theory.

In the real world of marketing, where perceptions count more than legal texts, there are differences. Wikipedia says: “Although all countries' type approvals are legally equivalent, there are real and perceived differences in the rigor with which the regulations and protocols are applied by different national type approval authorities. Some countries have their own national standards for granting type approvals, which may be more stringent than called for by the ECE regulations themselves. Within the auto parts industry, a German (E1) type approval, for example, is regarded as a measure of insurance against suspicion of poor quality or an undeserved type approval.” The German E1 approval is widely regarded as the toughest certification to get. An E1 certified product will be an easier sell.

How do I go about having my product certified?

The first step in ECE certification is to contract a technical service that is accredited to do ECE certification work for your type of product in the country from which you would like your ECE certification. Keep in mind that not all technical services are accredited to do ECE certification work for all products. The technical service must have the laboratories and know-how for your type of product. Some countries that are members of the ECE don’t even have their own labs. Some labs are accredited in several countries.

What is the first step in receiving ECE certification?

The first step in receiving ECE certification is called “initial assessment.” An inspector of the technical service will visit your factory and will check whether your factory is able to produce the product in the consistent quality required by the ECE. As with any exam, you should prepare yourself for it. In the next column, we will tell you the dos and don’ts of the initial assessment.

About the author: Bertel Schmitt, Gasgoo's columnist, is CEO of Hong Kong based parts sourcing company Sinamotive. Before founding Sinamotive, with the assistance of U.S. venture capital, Mr. Schmitt was a marketing consultant to Volkswagen AG.