In-service conformity

Emission conformity is not only covered by the type approval itself, but continues throughout the life of the product. There are several types of in-service activities that are performed after a vehicle is put on the market.

In-Service Conformity (ISC) Light Duty Vehicles (LDV)

Regulation (EU) 2023/443 sets out the ISC requirements for checking compliance against the emission limits for tailpipe and evaporative emissions throughout the normal life of the vehicle up to five years or 100 000 km, whichever is sooner.

This Part shall apply to M and N1 class I, II and III vehicles based on types approved after 01 September 2019.

ISC family definition

An ISC family shall be composed of the following vehicles:

  • For tailpipe emissions (Type 1, Type 1A and Type 6 tests), the vehicles covered by the PEMS test family.
  • For evaporative emissions (Type 4 test), the vehicles included in the evaporative emission family.

ISC testing

The manufacturer shall perform ISC testing for tailpipe emissions comprising at least the Type 1 test for all ISC families. The manufacturer may also perform Real Drive Emission (RDE), Type 4 and Type 6 tests for all or part of the ISC families. The manufacturer shall report to the granting type approval authority all results of the ISC testing. The time period between commencing two in-service conformity checks by the manufacturer for a given ISC family shall not exceed 24 months. The requirements for in-service conformity checks are applicable until 5 years after the last Certificate of Conformity.

The granting type approval authority shall check the Type 1 and RDE tests on a minimum of 5 % of the ISC families per manufacturer per year or at least two ISC families per manufacturer per year, where available.

Accredited laboratories or technical services may perform checks on any number of ISC families each year. The accredited laboratories or technical services shall report to the granting type approval authority all results of the ISC testing.

The granting type approval authority shall make available on a publicly accessible website, free of charge and without the need for the user to reveal their identity or sign up, a report with the results of all the finalised ISC investigations of the previous year, at the latest by the 31 March of each year.

In-Service Conformity (ISC) Heavy Duty Vehicles (HDV)

The conformity of in-service vehicles or engines of an engine family shall be demonstrated by testing vehicles on the road operated over their normal driving patterns, conditions and payloads. The in- service conformity test shall be representative for vehicles operated on their real driving routes, with their normal payload and with the usual professional driver of the vehicle. When the vehicle is operated by a driver other than the usual professional driver of the particular vehicle, the alternative driver shall be skilled and trained to operate vehicles of the category subject to be tested.

After the granting of type-approval for an engine family the manufacturer shall perform in-service testing on this engine family within 18 months from first registration of a vehicle fitted with an engine from that family. In case of multistage type-approval first registration means first registration of a completed vehicle.
The testing shall be repeated at least every 2 years for each engine family periodically on vehicles over their useful life period as specified in Article 4 of Regulation (EC) No 595/2009.
At the request of the manufacturer the testing may stop 5 years after the end of production.

The manufacturer shall report the schedule and the sampling plan for conformity testing at the time of the initial type-approval of a new engine family.

The manufacturer shall report the results of the in-service testing to the approval authority which granted the original type-approval in accordance with the initial plan submitted at type-approval. Any deviation from the initial plan shall be justified to the satisfaction of the approval authority.

In-Service Verification (ISV) Light Duty Vehicles (LDV)

Regulation (EU) 2023/2866 & 2023/2867 sets out the guiding principles and criteria for defining the procedures for verifying that the CO2 emission and fuel consumption values recorded in the certificates of conformity correspond to the CO2 emissions from and the fuel consumption of vehicles in-service. It also sets out the procedures for verifying the presence of any strategies on board or relating to the vehicles that artificially improve the vehicle’s performance in the tests performed for the purpose of type-approval (‘in-service verification’).

This Regulation also establishes detailed rules on the procedures for reporting deviations found in the CO2 emissions of vehicles in-service as compared to the specific emissions of CO2 recorded in the certificates of conformity as a result of in-service verification and for taking those deviations into account in the calculation of the manufacturer’s average specific emissions of CO2.

The number of in-service verification families selected each year by a granting type-approval authority shall be at least 2 % of the total number of in-service verification families for which that authority has issued emissions type-approvals in the three calendar years preceding the in-service verification.

For each in-service verification family selected in a given calendar year in accordance with Article 3, the granting type-approval authority shall undertake in that year at least one of the following tests on the vehicles selected, ensuring the following distribution:

  • chassis dynamometer tests for at least 75 % of the in-service verification families selected;
  • road load tests for at least 50 % of the in-service verification families selected, excluding in-service verification families for which the default road load calculation method has been applied for type-approval;
  • artificial strategies tests for at least 25 % of the in-service verification families selected.

The granting type-approval authority shall select test vehicles that, at the time of selection, meet all of the following criteria:

  • have a mileage between 3 000km and 40 000km;
  • are not older than two years counted from the date of their first registration.

In-Service Monitoring (ISM) Non-Road Mobile Machinery (NRMM)

Regulation (EU) 2022/2387 establishes detailed arrangements with regard to the selection of engines, test procedures and reporting of results relating to monitoring of gaseous pollutant emissions from in-service internal combustion engines installed in non-road mobile machinery using portable emission measurement systems. This Regulation applies to monitoring of the gaseous pollutant emissions from engines of emission Stage V installed in non-road mobile machinery regardless of when the EU type-approval for those engines was granted.

This Regulation applies to engine manufacturer.

For the carrying out of in-service testing, all engine types and engine families produced by the manufacturer shall be grouped in accordance with its sub-category.

The approval authority ensuring the compliance with this Regulation shall be either:

  • the approval authority that granted the type-approval of the engine type or engine family, in case that the ISM Group contains a single type-approval;
  • the approval authority that granted the type-approval of several engine types and/or engine families within the same ISM Group;
  • in the case that the ISM Group contains engine types, and/or engine families, approved by different approval authorities, the approval authority designated by all approval authorities involved.

Engines subject to in-service monitoring test shall:

  • be installed in one of the most representative categories of non-road mobile machinery for the selected engine type or, where applicable, engine family;
  • have a maintenance record to show that the engine has been properly maintained and serviced in accordance with the manufacturer's recommendations;
  • exhibit no indications of misuse ( e.g. overloading or misfuelling), or other factors (such as tampering) that could affect the gaseous pollutant emissions performance;
  • be in conformity with the EU type-approval documents with regard to the components of the emission control system(s) installed in the engine and in the non-road mobile machinery.

The manufacturer shall submit the initial plan for monitoring each ISM Group to the approval authority within:

  • for ISM Group A, one month of the start of production of any engine type or engine family within the ISM Group;
  • for any other ISM Group, the later date of the following:
    1. 26 June 2023;
    2. 1 month after the start of production of any engine type or engine family within the ISM Group.

The initial plan shall include the list of engine types and engine families in the ISM Group, together with the criteria used for and the justification of the selection of:

  • the engine families or engine types and category(ies) of non-road mobile machinery included in the plan;
  • the list of particular engine(s) and non-road mobile machinery selected for in-service monitoring test, if already identified;
  • the chosen testing scheme.