If there are really just 250 vehicles for Germany per annum, there will be trouble ahead.
You are right for the status for small series manufacturers.Is that really the case? If you look into the EU regulations regarding type approval within the EU (regulation 2018/858 with the corresponding executive regulation 2020/683) you see that small batch manufacturers are allowed to register not more than 1500 units per year within the EU. In Germany the national limit is 250 units. The details for small batch manufacturers can be found there in article 3, 30 and appendix II., 1, V and in executive regulation appendix IV.
Or you check the book "Die Genehmigungsverfahren für Kraftfahrzeuge" (Type approval processes for vehicles) (ISBN 978-3-7812-2092-8) from the publisher "Kirschbaum" in Bonn, Germany, That publisher is a well known and accepted publisher of books regarding traffic, vehicle technology and vehicle regulations. The writers are lawyers and engineers and they publish for technical control boards, manufacturers, car builders, parts manufacturers etc. who need to know the regulations.
If IA is such a manufacturer it must have the letters "KS" in their type approval number for cars in Germany (assigned by the KBA, Kraftfahrt-Bundesamt). The whole number should look like:
e<country of approval><number of base regulation><number of modification><five digits continous number><extension of approval>
The first two digits of the number of the base regulation should be "KS" in case of a small batch manufacturer.
Example:
e4*540/2014*2017/1576B*00034*01
In case of a small batch manufacturer it should look like (just an example):
e4*540/2014*KS17/1576B*00034*01
AWo
Yes UKIs that really the case? If you look into the EU regulations regarding type approval within the EU (regulation 2018/858 with the corresponding executive regulation 2020/683) you see that small batch manufacturers are allowed to register not more than 1500 units per year within the EU. In Germany the national limit is 250 units. The details for small batch manufacturers can be found there in article 3, 30 and appendix II., 1, V and in executive regulation appendix IV.
Or you check the book "Die Genehmigungsverfahren für Kraftfahrzeuge" (Type approval processes for vehicles) (ISBN 978-3-7812-2092-8) from the publisher "Kirschbaum" in Bonn, Germany, That publisher is a well known and accepted publisher of books regarding traffic, vehicle technology and vehicle regulations. The writers are lawyers and engineers and they publish for technical control boards, manufacturers, car builders, parts manufacturers etc. who need to know the regulations.
If IA is such a manufacturer it must have the letters "KS" in their type approval number for cars in Germany (assigned by the KBA, Kraftfahrt-Bundesamt). The whole number should look like:
e<country of approval><number of base regulation><number of modification><five digits continous number><extension of approval>
The first two digits of the number of the base regulation should be "KS" in case of a small batch manufacturer.
Example:
e4*540/2014*2017/1576B*00034*01
In case of a small batch manufacturer it should look like (just an example):
e4*540/2014*KS17/1576B*00034*01
AWo
That’s my understanding and there is a lot on this subject on another much earlier thread somewhereYou are right for the status for small series manufacturers.
But there is another law made for Italian sports car manufacturers!
I remembered vague and searched now because of your post.
The status small series is here given for up to 10.000 cars and 22.000 light commercial vehicles. Within this boarders you are not obliged to pay the fine of 95€/gram CO2 exceeding the government’s goal as a manufacturer.
That’s by the way an explanation why it has been impossible for JLR to build a car like the Grenadier!!!
Here is a link in German. Below I put a deepl translation (maybe some words are missing as I had to remove all the advertisements)
Supercar-Hersteller und CO2-Emissionen: Aufschub für Ferrari und Co.
Für Autohersteller mit kleinen Stückzahlen gibt es eine Ausnahme, um die europäischen Emissionsvorschriften zu erfüllen.www.auto-motor-und-sport.de
There is an exemption for small-volume automakers to meet European emissions regulations.
Holger Wittich
06.07.2022
As part of the "Fit for 55" negotiations, the EU has not only decided on the de facto phase-out of combustion engines, but also an extension of the deadline for small-volume manufacturers. A corresponding amendment now allows CO2 emissions to be reduced by 2035 and no longer by 2030 as originally envisaged. Here, a reduction in CO2 emissions of 55 percent compared with 1990 comes into effect.
Small series manufacturers without CO2 targets
The deadline change affects those manufacturers that sell fewer than 10,000 passenger cars or 22,000 light commercial vehicles per calendar year in Europe. Generally exempt are car manufacturers with fewer than 1,000 models per year. The amendment reads:
"In view of the higher overall greenhouse gas emission reduction targets and in order to avoid potential market distorting effects, the reduction requirements should be aligned for all manufacturers present on the Union market, with the exception of those responsible for less than 1,000 new vehicles registered in a calendar year. Consequently, manufacturers responsible for between 1,000 and 10,000 passenger cars or between 1,000 and 22,000 light-duty vehicles newly registered in a calendar year should no longer be able to apply for a derogation from their specific emissions targets from 2036 onwards."
Concessions to Italy
This decision taken is seen as a concession to Italy, which months before the "Fit for 55" negotiations was promoting this derogation for small-volume manufacturers and originally wanted to push for an extension until 2040. Last but not least, current Italian Environment Minister Roberto Cingolani and former non-executive director at Ferrari stated that the transition would be challenging for Ferrari and Co. as the companies reportedly hardly use economies of scale.
Also, the extension of the deadline is seen as a success for the European Small Volume Car Manufacturers Alliance (ESCA), which includes McLaren, Aston Martin, Pagani, Bugatti, Ineos, Rimac, Koenigsegg but also Wiesmann, Alpina and Donckervoort. ESCA argues that these low-volume manufacturers build vehicles that have a much longer life cycle and, due to the low volumes, have a limited impact on emissions than
Lambo and Ferrari to have e-sports cars starting in 2025
Lamborghini has already announced plans to reduce CO2 emissions by 50 percent by 2025 and to completely hybridize its model range by 2024. After 2025, the first electric model will be a Gran Turismo. Ferrari's first electric model will also be launched in 2025.
CONCLUSION
The smallest and low-volume manufacturers may take a little more time to reach the CO2 limits. The deadline extension from 2030 to 2035 is considered a success by Italy and the ESCA lobbying association. The changeover for Ferrari and Co. is a challenge, it is claimed, because the companies can hardly take advantage of economies of scale. Of course, this argument is somewhat misleading when one considers that Bugatti or Lamborghini, as well as Ferrari, are parts of large corporations
That national regulation is for German manufacturers which register the car in Germany, not in the EU.If there are really just 250 vehicles for Germany per annum, there will be trouble ahead.
In Erics case, yes. But for other EU countris it still apllies. So it still may be of interest for others in this forum living in such countries.Eric's post is about UK, so looking at EU regulations are pointless.
I think my post #62 should explain why we are talking of a small batch manufacturer all the time.First of all - there is a lot of speculation. To what @AWo wrote:
(Quoted)
Example:
e4*540/2014*2017/1576B*00034*01
In case of a small batch manufacturer it should look like (just an example):
e4*540/2014*KS17/1576B*00034*01
In my humble opinion - after some research - I did not find any "KS" or anything that would indicate Ineos as a small batch manufacturer. Any of those fellows here in the forum owning a Grenadier already - can you verify in your documents if there is something that would indicate a small batch manufacturer?
Seriously I doubt Ineos as a small batch. My speculation they have some grace period where they can start but must develop some EV to compensate this in some time ahead.
Some other manufacturers in Germany in the list I found a remark from KBA referring to a small batch manufacturer e.g. some brand for recreational vehicles - at Ineos I did not find such a remark.
Indeed that I was looking for... the ams magazine link is paywalled. (subscription) .I think my post #62 should explain why we are talking of a small batch manufacturer all the time.
Right but you seemed to be challenging Eric's statement "is that really the case?"In Erics case, yes. But for other EU countris it still apllies. So it still may be of interest for others in this forum living in such countries.
Cheers
AWo
I couldn't follow the point you were making in this regard, can you explain?That’s by the way an explanation why it has been impossible for JLR to build a car like the Grenadier!!!
As long as we all in the forum get our vehicles be it M1, N1 within our allotted year ( silly me I nearly said allotted timescale) then that is what matters.Right but you seemed to be challenging Eric's statement "is that really the case?"
Do we have an allotted year ? I’ve handed over all the money with absolutely no idea when it will be delivered. Too trusting or stupid ? I don’t knowAs long as we all in the forum get our vehicles be it M1, N1 within our allotted year ( silly me I nearly said allotted timescale) then that is what matters.
I would say you were just naturally very keen.Do we have an allotted year ? I’ve handed over all the money with absolutely no idea when it will be delivered. Too trusting or stupid ? I don’t know
I copied the article and inserted it in full as an English translation in my post. The law was made for the Italians but can of course be claimed by all European companies.Indeed that I was looking for... the ams magazine link is paywalled. (subscription) .
The exception law that the Italian manufacturers are using may be valid for all EU based companies.
But I also saw e.g. Bugatti and other with a small volume remark. KBA website is ugly to navigate.
Sometime there is a remark sometimes there is none... - we will see. Still I expect Ineos not to stay in(very) low volume segment.
JLR couldn’t have build a real Defender any more because they are just too big. It would cost them 95€ x (ca.) 200 (grams of CO2 that the Grenadier exhausts more than the allowed level) = 19000 € per vehicle as a penalty tax.I couldn't follow the point you were making in this regard, can you explain?