Mother Regulation, an important set of rules
The new EU regulation, which applies in particular to certain types of machinery, entails a considerable adjustment effort for various industries, which affects production costs. However, the Mother Regulation introduces some technical requirements that make the machinery more performing and flexible in their use. FederUnacoma underlines the importance of raising awareness also with users, to promote the value of the introduced innovations
For the European agricultural machinery sector, 2018 will be a “memorable one”, together with the previous one. Since January 1st, Regulation 167/2013 (commonly known as Mother Regulation) has become the only EU regulatory reference for the approval of tractors, trailers and interchangeable towed equipment. A very current topic in recent months, the new regulation is still little known in its technical content and deserves an analytical reading that highlights its improvement and material aspects together with the critical issues.
This is undoubtedly the most important legislative change in recent years, and closely affects not only the machinery manufacturers, who are working hard to complete the approvals according to the new standards, but the whole chain linked more or less directly to agricultural mechanization, which must now come to terms with this sort of regulatory “revolution”.
In fact, Mother Regulation entails a demanding adjustment effort for the industry, not only from a technical point of view, but also in economic terms, and the increase in costs is obviously reflected in the final price of the machinery and therefore on its accessibility for the buyer. Beyond the cost, the user is not always able to focus on the advantages associated with the new approval criteria, and risks perceiving the regulation as a sort of bureaucratic process that is not very significant on a material level.
There is no doubt that the tight succession of EU legislation puts pressure on the industry, and that agricultural work has peculiarities that in many cases require specific legislation rather than the literal application of provisions created for other sectors, a particular example being that of the automotive industry; it is also true that farmers must be allowed time to assimilate the new concepts and thus appreciate the new construction characteristics of the machines. However, beyond the problems related to the timing in the application of the rules, the Mother Regulation deserves to be analysed in its technical contents.
FederUnacoma recognizes the value of many technical elements contained in Reg.167/2013 and has not failed to promote them with seminars and meetings aimed at highlighting how the new rules can improve the performance of the machines, improve their safety and reduce their environmental impact.
Just to give a concrete example, there is one figure above all that at the moment is still underestimated mainly by end users (probably due to lack of information), which is linked to the significant increase in the maximum mass allowed for R and S vehicles (trailers and towed equipment). Just to give a macroscopic idea of the figure, for the R and S vehicles the maximum values are now the following*: for single axles, from 6 to a maximum of 14 tonnes (including the vertical load on the FV hitch); for tandems, it goes from 14 to a maximum of 24 tonnes (including FV); for the tridem, it goes from 20 to a maximum of 34 tonnes (including FV); finally, for the four axes, it goes from 20 to a maximum of 44 tonnes (including FV).
It should also be noted that important amendments to the delegated acts (which contain the specific technical content of the new Regulation), obtained “at the expiration”, and which will be officially published in a few months, have clarified some aspects that were otherwise of dubious interpretation, obtaining positive results.
Among the various items, we can mention two of the most recent major changes (as already mentioned, it is not published yet, and it will probably take place between April and May, but no substantial changes are expected). As for the ABS, in 2017 (see MW Year 2017 Issue 5-6, “Mother Regulation, towards a new EU homologation”) there were discussions to make this device mandatory for all new vehicles with a design speed between 40 and 60 km/h: today we can state that the lobbying activity conducted both by FederUnacoma and by the other national associations has borne the desired results, and that the requirement will lapse for this speed range, while the requirement will remain in effect for design speeds higher than 60 km/h.
Regarding trailer brakes, the last date to be able to mount a single hydraulic line (either of the “French” or CUNA type) on a tractor, always and only in addition to the double hydraulic/pneumatic line, has been postponed to 31/12/2024. Inevitably, at the turn of such an important regulatory step, when we really come to terms with the application of regulatory updates, there are many aspects of a procedural nature that have not yet been tested and therefore create some initial confusion. Approval authorities are moving efficiently, but there are still several situations where one interpretation can also differ radically from another, and both are considered correct; we can say that we are not yet totally aligned with the highly sought-after Community harmonization, cardinal principle of this European project, but we are working hard in that direction. In detail, as regards the approval of T vehicles (tractors), we can say that the situation has reached a sufficient degree of clarity, and the last intervention chronologically is the ministerial circular with the list of companies that received authorization for the end-of-series procedure (Circ. reg. 731 of 12/01/2018). Please note that this procedure (Art.39 of Reg.167/2013) allows up to 1st January 2020 the registration, sale and purchase of end-of-series machinery approved under the old directive 2003/37 EC, in the amount of 10 percent of the total vehicles sold by the manufacturer in the previous two years.
For R&D vehicles (trailers and towed equipment) some minor corrections have been necessary (and further actions are planned) to try and clarify a regulatory framework that still has some incongruities, starting from the definition of “R” and “S”, which is extremely arbitrary in the allocation of the main function of the vehicle in question (a fertilizer spreader, for example, may be classified as R or S if approved in one or in another Member State depending on whether the competent authority identifies them the main function as “transport” or instead “processing” of material. This situation forced the Ministry of Transport to issue a special circular clarifying (Circ. reg. 134 of 4/01/2018), where, greatly simplifying, the scope of the Rs is scaled down and the scope of the Ss is expanded.
In conclusion, it will be very important in the next few months to be vigilant and to follow in detail the activities of the Federation, because several important scenarios that are still in progress should become clearer. The applicability and timing of EU regulations remain the subject of attention and negotiation by FederUnacoma in terms of politics, but for all the technical details, the Technical Office of the Federation is immediately available to companies and users to provide clarifications and specific guidelines, in order to contribute to making the transition to the new regulatory scheme as linear and organic as possible for the farming equipment supply chain.
by Lorenzo Iuliano