8 January 2015, 00:00
THE CHALLENGE
Today’s agricultural tractors are complex and multifunctional tool carriers. Improper repair of a tractor or the changing of crucial software parameters can cause severe malfunctioning on critical systems with potentially dangerous safety effects on users and bystanders. For the moment, only ‘authorised’ dealers and repairers (who work under the auspices of the manufactures) have access to any vehicle information. They need to meet high qualification requirements before performing any repair and maintenance tasks.
As part of an alignment exercise with the other automotive sectors the European Commission proposed new rules which will oblige original manufactures from 2018 to provide repair and maintenance information (RMI) also to independent repairers and thus allow them to perform repairs and maintenance tasks on agricultural vehicles. In addition, manufacturers will also be obliged to provide information to external companies to develop generic diagnostic tools. This will enable the creation of a parallel circuit, i.e. repair and maintenance of vehicles including the necessary training, technical information, spare parts and tools will no longer be under the control of the original manufacturers.
IMPACT
The obligation of manufacturers to provide RMI to independent repairers and the creation of a parallel circuit for repairing agricultural vehicles will result in a number of substantial uncertainties and risks:
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The qualification levels of independent repair personnel cannot be controlled or determined by the manufacturer. Professional qualification levels are a national responsibility and differ greatly between EU Member States.
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The lack of traceability dramatically increases the risk of incorrect or non-compliant repairs (such as tampering of sensitive electronic systems for safety and emission control).
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The setting up of dedicated RMI websites, which many companies do not have, will be costly and without foreseeable benefits, certainly for SME’s.
CEMA POSITION & CALL FOR ACTION
CEMA is greatly concerned about the risks arising from the new RMI rules, particularly since these measures were introduced without impact assessment:
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The lack of traceability of independent repairers’ actions creates legal uncertainty: in case of an accident, liability questions are bound to arise, as it may not be possible to identify the culprit.
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The lack of supervision of the independent repairers’ qualifications will likely result in an increase in accidents on the road/field. CEMA urges EU Member States to reinforce their efforts to have adequate safety training schemes in place. The European Commission should promote harmonisation of quality and education levels for independent repairers.
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CEMA welcomes the Commission’s indication that additional measures related to anti-tampering are needed. Measures should include the enhancement of traceability of actions performed on tamper-sensitive controls.
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The EU needs to amend a technical mistake in the Regulation: by mistake, small manufacturers of towed vehicles were not exempted from RMI rules (while small-series tractor manufactures are). An urgent amendment is necessary to ensure alignment.
Source: CEMA