FIGIEFA monitoring upcoming Euro 7 Regulation
The Euro 7 Emission Regulation would impact directly on the parts market for several key emissions-related parts, currently sold in quantity by independent distributors and wholesalers.
The issue concerns the introduction of tamper protection measures under Euro 7, where authorities at EU level will require manufacturers to protect vehicle systems/components that record the emissions performance of their vehicles over the first 200,000 km and 10 years of its life. The Commission wants to be certain that data collected is correct and to ensure integrity for this data. Both hardware and software measures are being considered for tamper protection implementation. Euro 7 Regulation requires tamper protection measures to be implemented in the engine and engine control units, fuel injection systems, vehicle pollution control device and systems, propulsion systems, traction battery, odometer, OBFCM (on-board fuel consumption monitoring) or OBD/OBM (on-board monitoring) devices. In addition to the general identification of tamper protection relevant systems, the Regulation also aims to identify some specific components under OBM that need protection. This is likely to include (but is not limited to) components such as NOx Sensors, DPF filters, EGR components, catalytic converters, turbo chargers and air mass meters.
For implementation, it seems likely that the Commission will opt to make vehicle manufacturers responsible for deciding precisely what measures they will use on their own vehicles. From what FIGIEFA has heard in the Commission’s AGVES Working Group (dealing with the implementation), it seems that the European Commission intends to use the mechanisms of UN R155 (the UN cybersecurity regulation) and ISO 21434 (the cybersecurity engineering standard). This would mean that the implementation of such measures would be left to vehicle manufacturers, i.e. proprietary implementation measures would be used to ensure tamper protection. This would be a serious concern for independent parts producers (but also Tier 1), as without specific legislation, they would not be able to develop OBM/OBFCM-compatible replacement parts. Independent operators need access to the information, tools and processes required to remain interoperable with such vehicles (this is fully in line with the Cybersecurity amendments FIGIEFA/AFCAR drafted a year ago). [Comment from FIGIEFA Secretariat: we had recently a case where a NOX sensor was encoded by the OEM, with all independent supply sources being excluded (parts were rejected), but also, T1 NOX sensors were not available for supply to the IAM].
In addition to tamper protection, Euro 7 also aims to introduce additional measures for measuring tyre abrasion and checking particulate emissions from brake components. For tyres, there is the possibility that even non-Euro 7 relevant vehicles will need to be fitted with Euro-7 compliant tyres.
What does this mean for the independent aftermarket?
Under the Euro 7 scheme, aftermarket operators would have no reference for implementation for tamper protection measures used on emission relevant parts, as these are implemented by each vehicle manufacturer in a proprietary manner. This can result in a situation where independent and original replacement parts would no longer be compatible with the security implementation of the vehicle.
For brakes systems/components, FIGIEFA expects the Commission to define additional ‘Euro 7 type-approval’ requirements around particulate emission which will also be relevant for all replacement parts associated with brake systems.
Introduction of Euro 7 could mandate that only Euro 7 compliant tyres can be fitted in all vehicles, including older vehicles. If this were to happen, independent parts distributors would need to be vigilant with regard to the impact on their stock of pre-Euro 7 tyres.
FIGIEFA is participating in the Commission's AGVES working group, where these issues are discussed. They are currently in the process of analysing the impact of such provisions and would like to contact national trade associations and their member companies to get some operational and market insights and the potential impact on distributor’s product portfolios. FIGIEFA would also like to discuss with technical experts the ramifications of anti-tampering measures that may happen at a physical level, but could also in many cases be software-based, and the question of whether an R155 style risk assessment based approach is the normal engineering way to address this or not.