@ Thomas Morus: "EG-Typegoedkeuring" .. Nee, inderdaad, het is een 'een klein-serie-individuele EU goedkeuring' :
"as we have learned you have contacted the Czech Ministry of Transport regarding the refusal of registration of the vehicles we have been together handling for some time now.
The Ministry of Transport have asked us to reply to your request as they do not have capacity to repeatedly communicate regarding these vehicles as they were not the authority issuing the e8 certificates for individual approval. However they feel right for us to reply to you/the Belgian authority as we were the ones who have been issued the approval for these vehicles.
We all know that the current situation in Belgium is not common and openly said they are just trying to find a reason to refuse the registration without having any objective reason for doing so. At the moment we can discuss with them regarding their objections as stated below, however I am not sure whether this would have any positive result.
Our comments to the „refusal of the validation request“:
Russian approval number TC RU E-RU.MT02.00124.P1 does contain reference to the number of the approvals or reports granted regarding the particular UNECE Regulations. These reports/approvals are not indeed part of the approval, however this is not necessary. These reports/approvals have been verified by the Russian authority E22 as is proven by their office stamp.
Russian authority E22 is the same authority with the same rights as any other participant of the UNECE Agreement 1958, the same as E8 (Czech Republic) or E6 (Belgium). Does this mean that Belgium is not willing to accept information given and verified by another participant of the UNECE Agreement 1958?
According to our knowledge this is basically against all the terms and conditions of the UNECE Agreement 1958, however if they are willing to do so, they should act in this matter during the meetings of WP.29 and not to pass this on any customer.
This means that all the relevant UNECE Regulations regarding particular requirements referred to in the Russian approval No TC RU E-RU.MT02.00124.P1 have been met. This we also demonstrate with attached report for Regulation R13 which was mentioned as an example in the refusal. The Technical Service has made all the necessary steps to conform that the submitted reports for permissible sound level (UNECE R51) and emissions (Regulation 715/2007) are relevant and applicable also for the vehicle to be approved. Based on this the Czech authority has granted individual approval certificate.
Is it a standard procedure in Belgium to doubt the conclusions of other Member States Authorities and their
respective Technical Services? UNECE Regulation No. 11 is one which requires destructive testing. The full compliance with this Regulation is not required even for type-approval of small series. The same applies for UNECE Regulation No. 12. This is in full compliance with paragraph 2, Article 24, Chapter X of Directive 2007/46/EC. Czech Authority has obtained all relevant data for granting the individual approval and has seen them as relevant and proving proportional compliance with these requirements.
All the respective requirements have been verified according to the Regulation No 1230/2012 even though the exact calculations have not been added as part of the Technical Service report. For the calculation manufacturer’s declared centre of gravity of the payload has been used in compliance with this respective Regulation and the calculations have been made with positive results. These respective individual approval certificates have not been granted with any exemptions which means that all the required information and test as stated in Annex IV have been verified to the extent needed for
granting an individual approval. No national law mitigations have been used and the respective vehicles are
in full compliance with Directive 2007/46/EC for individually produced vehicle.
@mava105: proficiat voor u. Wij hebben ook nooit problemen gehad. Zélfs een identiek voertuig werd nauwelijks een maand voor het onze nog gewoon gehomologeerd. Dealer heeft een zaak tegen het Gewest gewonnen en vervolgens worden tientallen voertuigen gewoonweg geblokkeerd.. verklaar het maar.
En de papieren zijn wel degelijk in orde. Tsjechië is een mede lidstaat en volgt de zelfde richtlijnen als België, in Nederland worden ze trouwens daarom ook gewoon ingeschreven!