APRA Europe blocks anti-remanufacturing regulation attempts

The reman industry has to be wary of laws which will make things more difficult and expensive for companies to operate. Peter Bartel explains how APRA is helping to put the industry’s case forward

One of the key elements of APRA Europe’s past and updated value proposition (see our new flyer at www.apra.org/europe) is to protect the industry and the public from misleading information and to actively influence law-making institutions. I would like to prove that we do not just talk about this, but also act. So, in this edition, please read about how we stopped a regulatory initiative at United Nations level which was out of place from our remanufacturering perspective. I am talking about several approaches by some original manufacturing companies to UNECE (United Nations Economic Commission for Europe). This is the organisation which defines and harmonises regulations for vehicle components and issues corresponding certificates. These approaches were first made about eight years back and it took until 2017 for a final decision to be reached.

Expensive tests

Their claim was this: if brake pads as well as brake discs have an ECE certification (reference ECE R90), then brake calipers should also be ECE-certified. It had been stated that there would be tremendous risks coming from non-OE or remanufactured calipers for heavy duty applications. If this approach had been successful it would have resulted - at the very least - in the requirement of expensive endurance tests for different products sold by a remanufacturer and these would have to be paid to prove product quality. In order to back up this claim with facts and figures, the corresponding UNECE working group requested the industry to come up with a position and to provide evidence illustrating such risks. At this point, we at APRA Europe clearly communicated our position. We started lobbying, aligned with other people and associations, and asked major companies to also make their arguments. The outcome was three key messages which we delivered to the responsible people at UNECE:

1) Necessity of caliper regulation

The brake system of a vehicle is designed in a way that critical parts are redundant: the failing of one of these parts will immediately be noticed by the driver and sufficient brake capabilities will remain to stop the vehicle safely. Without active mechanical manipulation of the vehicle brake caliper, a failing of the safety concept of a brake system is unlikely. Therefore, the industry cannot see the necessity for a vehicle brake caliper regulation!

2) Regulation for remanufactured calipers

Over the last decade, the automotive industry had a special focus within their product field observation on remanufactured calipers. Up to today, we have not found one single accident which was due to safety-relevant failing of a vehicle brake system due to a remanufactured, badly-rebuilt brake caliper. Therefore, the industry cannot justify regulations for remanufacturing of vehicle parts.

3) Proposal of critical parameters and tests representative for caliper certification

Each caliper is individually adapted to the individual braking system of the vehicle. Therefore, the industry cannot propose general critical parameters and tests representative for individual caliper certification.

Subsequent to communicating our position and as a final outcome of the working group, UNECE stated that there would not be any proven facts supporting a call for UNECE certification of remanufactured calipers. As you can see, with the support of our members and by acting together we are able to move things in the right direction. APRA Europe, the voice of remanufacturing since 1941, promotes and defends the remanufacturing industry.