What is Homologation? – It is the process by which a motor vehicle (which includes passenger cars, motorcycles, busses, trucks etc.) is evaluated against a set of standards and if found to comply will then be approved for use on public roads.
Why do we have it? – Following on the democratic elections held in 1994, South Africa was re-admitted to the United Nations. It then became a co-signatory to what is referred to as WP29, which is a permanent Working Party dealing with the “Harmonisation of Vehicle Regulations”. Then followed quite a lengthy process whereby South Africa adopted UN Regulations for motor vehicles. These regulations are referred to as UN-ECE. Although our SA standards are referred to as SANS, they are effectively a copy and paste of the similarly numbered ECE Regulations with maybe small modifications to account for local conditions.
The advantages of using UN-ECE regulations are amongst others that it makes it easier administratively to formulate regulations and keep them up to date. More importantly, because we use internationally accepted standards, it enables import and export of vehicles without unnecessary double testing to non-ECE standards, i.e. local standards do not become trade barriers.
For practical reasons at the time, the SABS/NRCS (National Regulator for Compulsory Standards) and NDOT conceded that UN-ECE regulations alone would be problematic as a single standard, because many motorcycle factories did not have all ECE test Reports available for all models. The best common denominator at the time were EEC (European) regulations, which were then adopted as “equivalent” standards. Practically this means that an Importer can either present EEC test reports, or UN-ECE, or a combination of both. EEC standards are generally higher than UN-ECE. Hard as the Industry tried, we could not get any other countries’ standards, such as US-DOT as second equivalent.
These regulations, which focusses on safety critical components, are encapsulated in what is referred to as VC9098 (Vehicle Compulsory Standards). From a public health and safety perspective, it is a vastly superior system to what existed previously, which was nothing better than a physical scrutiny to ensure that a motorcycle “looked” roadworthy, but it also created new problems for the Industry.
How does it work? – When an Importer decides to bring a specific model to South Africa, a sample unit gets inspected by the NRCS, and they then also scrutinize the suite of test reports as required by the VC9098. When everything is found to be in order, an approval is granted and that vehicle model is loaded on the e-NaTIS system. Without this process it is not possible to get a new model onto the Natis system. These procedures do not apply to off road vehicles not designed for use on public roads.
In order to sell new motor vehicles in South Africa one has to be registered as an MIB (Manufacturer/Importer/Builder). A company’s MIB is linked to Natis, and all new models are linked to a particular MIB, to which in turn specific VIN’s are linked. This is so that an MIB can be held accountable for those vehicles that they imported or built. If two different MIB’s were to import the same vehicle model, they would each have to homologate their own models. One cannot use the homologation approval of the other.
All this became law on 1 December 2011 with a two year phasing in period. All new models would have to comply with VC9098 from that date onwards. Existing models introduced under the old system had a two year grace period in which to be homologated, failing which it would no longer be possible to sell such “un-homologated” models for road use in South Africa.
What were the implications? – At the time, real examples such as the Kawasaki KLR650, Suzuki DR650 and Honda XR650 were mainly manufactured for the USA market. As they were unable to meet European emission standards, the Factories did not test these models to EEC standards, nor to UN-ECE standards. Although I simplify, USA standards are widely adopted throughout North and South America, and with some small variables, are also accepted in Australia.
Interestingly, USA emission standards are higher than the South Africa standard, but because the test reports, which has to refer to a particular standard, were not available, we “lost” these models, although it was not purely the absence of emission test reports. Other test reports were also not available.
Consequently, the SA Importers of these models could not obtain the necessary UN-ECE (or EEC) test reports for these models and were unable to homologate, therefore unable to sell. One positive was that the really cheap Chinese products could also not be homologated as some components could simply not pass the UN-ECE regulations, although some may argue that cheaper transport should have been a higher priority.
What are the costs and why can it be expensive? – To homologate a motorcycle in South Africa amounts to a direct cost of slightly under R4500 per model. Then there is the cost of technical staff, but the impact on the local consumers is not significant in the greater scheme of things.
The bigger costs are borne by the Factories and as this is spread over many units of production, it is not normally felt at local level. As for expensive see below.
Why do the SA Importers not test themselves? – There are several reasons. In order to comply with “Conformity of Production” rules, the Factories have to submit a model for testing. An interested 3rd party cannot as they are not the manufacturer. Similarly, the manufacturers of components must obtain test reports and provide these to the Motorcycle Factories. For example the manufacturer of a tail light is responsible for the testing of the component. The Factory is responsible for having the same component tested with regards to its position as mounted on the complete motorcycle. So you have similar scenarios for mirrors, hooters, head lights and indicators.
Apart from the fact that no motorcycle test laboratories exist in South Africa, the above scenario describes why a model cannot be homologated by an independent importer. Some Factories (but not all) will specifically homologate for a particular market. The cost is rumoured to be in excess of USD30k, which is roughly R450k. Not worth the cost unless volumes justify the expense, and South Africa is a relatively low volume market!
What about parallel/grey/second hand? – The adoption of VC9098 also had the implication of shutting down the so called grey and parallel import activities, essentially because Importers of these products were not sourcing from a Factory, and therefore had no access to the original test certification required for homologation. Second hand vehicles are not sourced from the Factory (although manufactured there originally), which means Factory obtained test reports cannot be used. Components may have been changed (think exhaust, indicators, OEM brake pads etc.) during initial ownership, which effectively means that every individual unit requires testing, which is practically and financially impossible.
Contrary to popular belief at the time, AMID was not the driving force behind the changes in legislation. The changes came about as described early on in this article, and the motorcycle industry was in fact the last automotive component which was able to import and sell second hand vehicles in South Africa.
In summary – The subject is quite complex and I have out of necessity tried to provide an explanation which most will understand. This means I had to leave out steps and technical points which a very technical person may find lacking. Kindly see my explanation above in this context and contact me should further information be required.
