Tricks of the ECE trade. Part 3

Ready to submit your part for ECE or E-Mark testing? Read this before you send the part in. It can save you aggravation and money.

The North American car market is still in the dumps with no sign of recovery. Europe is coming back with three months of back-to-back growth. Small, but increasing growth. No wonder that more and more Chinese parts manufacturers recognize the importance of Europe. As a whole, Europe is the largest car market of the world. However, there is a price of admission: Many parts exported to Europe need ECE certification, also known as E-Mark.

Not only Europe requires this. 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. If you want to sell your parts to a worldwide market, ECE certification should be of the top of your list of priorities. Even if a country does not (yet) require ECE certification: A valid ECE number on your part is a sign of quality. It gives your customer an extra level of trust. Even if you export to North America where ECE certification is not required, you will be at a competitive advantage if your product is ECE certified.

In the last two installments of this series, we have talked about the general aspects of ECE certification, and about how to successfully pass the initial assessment, which is necessary if your company wants a product ECE approved. Today, let’s talk about how to quickly and successfully get your product ECE-approved.

Last chance: You really want that E-Mark? An ECE approved or E-marked product is legal as a replacement part for clearly specified makes and models. In most cases, having one or just a few of your products ECE certified is a waste of money. You usually need a large portfolio of E-marked products which covers a high percentage of cars on the road in your target market. I said “most cases” and “usually” because there is one exception to this: If you have a customer who is willing to give you a contract for a certain type of product, and who is willing to wait until the certification process is over. This can take a while. A large portfolio of E-marked products is a large investment. A good coverage of the cars on Europe’s streets usually starts with 200 – 300 certified products in your portfolio – depending on the type of your product. For this article, we will be using brake pads as an example.

Budget for a big investment: An ECE certification for a brake pad costs you anywhere between 10,000 and 25,000 Yuan. Now multiply this by 200 brake pads for a halfway significant portfolio, and you will be looking at 2,000,000 to 5,000,000 Yuan total – if everything goes right. This is a lot of money, and you want to make sure that you are not wasting it.

Test before you let test: I have talked to many certification labs. Again and again, they are shaking their heads about receiving product that clearly does not comply with the standard. “They just send it the product in the hope that it will be certified” is a comment often heard. The certification lab will go through the tests, charge you for them, and give you a negative result. Money and time wasted. Before you send in the product for testing and certification, make sure it complies with all the rules and regulations. The regulations are available on-line (click here for the text.) Be careful to you read the various addenda, these rules are constantly updated. Follow the described test routine carefully.

Careful with OEM parts: In most cases, certainly with brake pads, the OEM Original Part is the benchmark against your part will be tested. Your part is allowed a certain deviation from the reference OEM part. With brake pads, it is usually 15 percent deviation in the braking performance. Now, for the careful part: The certification lab will buy the part from a dealer in their country (and charge you for it.) Make sure you test against the same part. Don’t rely on the fact that the OEM part you buy in China will have the same characteristics as the part bought in Europe. What’s more, OEM parts also vary in quality. We had cases where a series of OEM parts had a 30 percent deviation. Buy several. If the OEM part varies, a cooperative certification lab can use this for your advantage by testing a borderline part of yours against a hand-picked OEM part. Technically, this is legal. But it is a dangerous game: If your part is retested and found out of spec, you can lose your certification.

Do not use other E-marked parts as a reference. You may have a hard time finding the OEM part locally, but an already E-marked part from another supplier is available. You can use this part as a crude first line reference, but for nothing else. Remember, a brake pad for instance is ECE legal if it does not deviate more than 15 percent plus or minus in its braking characteristics from the OEM part. If it deviates 14 percent, it is legal. But if your part then deviates just 2 percent from that replacement part, you part would be illegal. Always use the OEM part, and always use the results of several OEM parts to establish a solid baseline for testing.

Cut a deal for negative tests: Many times, a part does not have to go through the whole testing routine. For instance, a brake pad will show on the dyno whether it is good. If it is bad, you can save yourself the mandatory road test. The part will not test better. Cut a deal with the testing lab to give you a much lower price for a negative test. They want your repeat business and usually agree to a lower price for a negative result. But you need to ask first.

If it won’t fit, it won’t finish: If a part does not fit, it is automatically disqualified. The best test for fitting is to install it into the car the part is intended for. Very often, these cars are hard to find in China. Sometimes, the make and model you find in China is different from the one you find in Europe. Always perform a mounting test on the car the part is intended for.

Submit your drawings in English: Most of the times, you need to submit drawings and technical data with your part. Very often, testing and certification are delayed, because the documents are in Chinese. To save you the laborious work of translation, create a template for your drawings that is both in Chinese and English. Now, the engineer simply enters the measurements (in the metric system) into the data box, and no more translation is needed.

Talk to your testing lab: This article can give only general advice, and the devil is in the details. Each ECE regulation is different. Regulations do change. Certain sections may be interpreted differently. Ask your testing lab what to watch out for, and what tests they recommend for you to perform in your factory before submitting your part for certification. A reputable testing lab will give you this advice, most of the time for free. A disreputable testing lab you don’t want to work with anyway.

Next time: How to keep your ECE approval.

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.