Joint Position: No national fee structures for the type-approval of motor vehicles

National fee structures and a modified contractual relationship are not subject to the independence of the technical services. There is no causal link between the software manipulation of individual vehicle manufacturers and the objectivity of the technical services.
Typgenehmigung-type-approval2
© TÜV SÜD AG
A fundamental change of system in respect to the contractual relationship between technical services and manufacturers has been proposed in the EU Draft Proposal for a Regulation on the approval and market surveillance of motor vehicles.
VdTÜV and DEKRA e.V. consider national fee structures and, where applicable, a modified contractual relationship to be neither proportionate, nor necessary in order to ensure the independence of the technical services. There is no causal link between the software manipulation of individual vehicle manufacturers and the objectivity of the technical services. With the legislator interfering in the free setting of the prices of the technical services by means of fixed fee rates will foreseeably lead to adverse effects upon the further development of the provision of services (testing equipment and facilities as well as the qualifications of personnel) and will harm the continuous adaptation to technological progress.