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    Presentation To The Motor Vehicle Working Group (MVWG)

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    American Import Agents Association
    Presentation by Anthony Cohen from American Car Imports, Chairman American Import Agents Association to the Motor Vehicle Working Group at the European Commission on 26th January 2009 about Individual Vehicle Approval in Europe

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    Presentation To The Motor Vehicle Working Group (MVWG)

    Uploaded by

    American Import Agents Association
    146 views12 pages
    Presentation by Anthony Cohen from American Car Imports, Chairman American Import Agents Association to the Motor Vehicle Working Group at the European Commission on 26th January 2009 about Individual Vehicle Approval in Europe

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    Presentation to the Motor Vehicle Working Group (MVWG)

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    Presentation by Anthony Cohen from American Car Imports, Chairman American Import Agents Association to the Motor Vehicle Working Group at the European Commission on 26th January 2009 about Individual Vehicle Approval in Europe

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    146 views12 pages

    Presentation To The Motor Vehicle Working Group (MVWG)

    Uploaded by

    American Import Agents Association
    Presentation by Anthony Cohen from American Car Imports, Chairman American Import Agents Association to the Motor Vehicle Working Group at the European Commission on 26th January 2009 about Individual Vehicle Approval in Europe

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 12

    INDIVIDUAL VEHICLE

    APPROVAL
    IN EUROPE
    A Presentation to the Motor Vehicle Working Group

    HIVA-The Problem And A Proportionate Solution


    Presented by Anthony Cohen
    Chairman - American Import Agents Association
    American cars, not marketed by the
    Manufacturers in Europe, improve
    consumer choice and are generally sold to
    enthusiasts.

    Only imported by SME’s and


    Individuals in very low volume,
    American cars are arguably the
    best American ICON in Europe.
    New American Vehicles in
    Europe

     Mainly bought by enthusiasts & collectors


     Imported for over 65 years
     Business conducted by 1000 micro-SME’s in Europe
     Service/parts/warranties/finance/insurance
     Very low Volumes (UK circa 500/year)
     UK-Ultra low volumes as LHD in RHD market
     No official Manufacturer support
     >250,000 FMVSS/CMVSS vehicles on EU roads
     No Safety and Environmental problems
     Hundreds of potential models
     300 American Car Clubs in Europe
    North American Automotive Safety
    “American cars are manufactured to the same high standards as Europe
    and low volume imports should be excluded. This was never the
    intention of the legislation.” Malcolm Harbour MEP

    For National reasons, some Member States accept equivalencies with


    North American standards more than others
    2007/46/EC
    29th April 2009

    Large
    Manufacturer

    ECWVTA
    EC Small Series

    Nat. Small Series


    Article 24
    “Equivalence
    Proportionate Manufacturer
    to the
    for Micro-SME’s NIVA greatest
    & Individuals SME extent
    practicable”
    EC Citizen
    Draft proposal 5.3 for HIVA
    Large
    Manufacturer

    ECWVTA
    EC Small Series
    Problem: Nat. Sm. Series Only
    Technical bar raised
    High Volume Manufacturer
    beyond capability
    of genuine IVA Importer can comply
    for Citizen or SME HIVA
    POTENTIAL COSTS &
    IMPLICATIONS OF HIVA
    for SME’s/Individuals

    • > 1,000 long-standing SME’s fail in domino effect

    • Circa 5000 people unemployed directly

    • Additional unemployment in multiplier effect

    • Maintenance Problems for 250,000 FMVSS vehicles on EU


    roads

    • Significant effect on personal freedom of choice

    • Effect on Transatlantic ties

    • Encourages import of older vehicle technologies


    Possible
    Approaches

    • Numerical Limits X
    very difficult to administer

    • Amend Article 24
    Disallow manufacturers from
    using National IVA for vehicles
    manufactured in large series
    -eg Landwind

    • Give MS discretion to

    define low Volume for NIVA


    Amendments
    • Continue to permit Member States, for
    genuine low volume imports, to offer an
    approval on a National basis under the current
    regime of Article 24.

    • Respects differing views held by Member


    States

    • Mutual Recognition applies as explained in


    Article 24 of the Directive.
    SUMMARY - AIAA’s Preferred SOLUTION

    • Permit Member States to maintain Low Volume National IVA only for SME/Individual
    Imports -respects national differences (mostly for North American Imports)

    • High Safety and Environmental standards maintained

    • Low Risk of Abuse-SME’s/Individuals only import in very low volume

    • Subsidiarity Respected- Regulations are targeted at correct level

    • CONSISTENT approach for all low volume imports <10 years old

    • Proportionality-No unintended consequences

    • Single Market rules respected - NIVA=MR

    • Small Business Act of Europe- “Think Small First”

    • Competition and Consumer Choice maintained

    • Follows principles of Better Regulation and Simplification


    In Europe,
    American
    With Cars are
    sincere thanks to the
    Motormainly
    Vehiclebought by Group
    Working
    enthusiasts and
    collectors

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