Turkey keeps its automotive technical regulations aligned with Europe

What happened

On May 14^th, 2020, the Turkish Ministry of Industry and Technology has published on the Official Gazette the replica of the European Regulation No (EU) 2019/2144 on Type-Approval Requirements for Motor Vehicles and Their Trailers, and Systems, Components and Separate Technical Units Intended for such Vehicles, as regards Their General Safety and the Protection of Vehicle Occupants and Vulnerable Road Users.

The publication of the Regulation is one more step ahead on Turkey’s efforts to keep the Turkish legislation fully parallel to Acquis Communautaire, especially pertaining to the automotive and manufacturing sectors.

What does it mean

In the last two months, Turkey has first changed its product safety law, then adapted its type approval regulation to Europe’s new directive on 2018/858. Now, with the new regulation, Turkey is keeping its automotive industry and market aligned with the advanced driver assistance systems (“ADAS”) of the European Union.

This regulation can be seen as a preparatory text for introduction of autonomous and automated vehicles and specifies the fitment of following features / systems to the vehicles, regardless of their vehicle category:

• Driver availability monitoring systems,
• Systems to replace the driver’s control,
• Systems to monitor the area surrounding the vehicle,
• Systems to provide safety information to other road users,
• Communication systems and protocols for platooning.

Background

Following replacement of the existing vehicle fleet in the market from 2022 onwards, autonomous and automated vehicled traffic will be more visible. Calculating the replacement ratio of the vehicle fleet, by 2030, one can expect that such net of autonomous vehicles in the daily traffic would be the new normal. It will not be bold to say that it will be like the transition from horse carts to motor vehicles in the beginning of the 20^th Century and the next generations will look at today’s cars and traffic as we do to horse carts of the past.

In light of this vision, the European regulation makes several ADAS mandatory in new models from June 2022 onward and in all new vehicles from June 2024 onwards. The regulation also foresees retrofit ADAS systems for the existing vehicle fleet in the market, in order to compensate the slow renewal pace.

The European Commission, starting back from 2015 and introducing a solid proposal on 2018, had been working the third wave of the “European on the move” package of measures to significantly decrease the number of fatal and serious injuries in road crashes until 2030. The initiative aims a transition towards a mobility system that is safe, clean, connected and automated. It follows the low emission mobility strategy, which is reflected in the directive 2018/858.

What does it change in our lives

Now, the European efforts have matured into the regulation no 2019/2144, that necessitates road vehicles (cars, vans, truck and buses) to have standard equipment of advanced vehicle safety features in order to be sold on the European market.

Those standards include intelligent speed assistance, electronic stability control (ESC) system, alcohol interlock installation facilitation, driver drowsiness and attention warning, lane departure warning systems (LDWS), emergency stop signal, reversing detection, advanced emergency braking systems (AEBS) and event data recorder. Additional safety measures are designated for those specific vehicle groups of trucks and buses such as vulnerable road user detection. The regulation also repeals the General Vehicle Safety Regulation, the Pedestrian Protection Regulation and the Hydrogen-powered Motor Vehicles Regulation and replaces several directives with United Nations Economic Commission for Europe (UN ECE) regulations.

The ADAS introduced with the new legislation can be visualized as follows:

The changes introduced by the new Regulation generally fall into one of the following four categories:

1. UN ECE Regulations on Components

The list of UN ECE Regulations is expanded to following additional UN ECE Regulations:

• ECE 45.01 on headlamp cleaners.
• ECE 108.00 on retreaded tyres for passenger cars and their trailers.
• ECE 109.00 on retreaded tyres for commercial vehicles and their trailers.
• ECE 114.00 on replacement airbags.
• ECE 115.00 on LPG and CNG retrofit systems.
• ECE 124.00 on replacement wheels.
• ECE 126.00 on partitioning systems.
• ECE 129.00 on enhanced child restraint systems.

2. UN ECE Regulations on Occupant Protection

The list of UN ECE Regulations is expanded to following additional UN ECE Regulations:

• ECE 135.01 on pole side impact performance.
• ECE 137.01 on frontal collision with a focus on the restraint system (full width barrier impact), with the scope expanded to include both M1 and N1 category vehicles.

3. Existing UN ECE Regulations

• ECE 34.03 on the prevention of fire risks – scope of rear impact testing expanded to include all M1 and N1 category vehicles with a maximum mass not exceeding 3,500 kg.
• ECE 94.03 on the protection of occupants in the event of a frontal collision – scope expanded to include all M1 and N1 category vehicles with a maximum mass not exceeding 3,500 kg.
• ECE 95.03 on the protection of occupants in the event of a lateral collision – scope expanded to include all M1 and N1 category vehicles, regardless of the height of the R points above the ground.
• ECE 125.01 on forward field of vision – scope expanded to include all M1 and N1 category vehicles.

4. New Regulation Requirements

• Advanced emergency braking systems (AEBS) for M1 and N1 category vehicles capable of detecting moving vehicles and stationary obstacles.
• Advanced emergency braking systems (AEBS) for M1 and N1 category vehicles that are capable of detecting pedestrians and cyclists.
• Blind spot information systems and pedestrian / cyclist collision warning systems for M2, M3, N2 and N3 category vehicles.
• Direct vision requirements for M2, M3, N2 and N3 category vehicles.
• Reversing detection systems (e.g. revering cameras) for all categories of vehicle.
• Emergency lane keeping systems for M1 and N1 category vehicles.
• Tyre pressure monitoring systems (TPMS) for all vehicle categories other than M1 category.
• Intelligent speed assistance (ISA) systems for all M and N category vehicles.
• Emergency stop signals for all M and N category vehicles.
• Alcohol interlock installation provisions for all M and N category vehicles.
• Driver drowsiness and attention detection systems for all M and N category vehicles.
• Advanced driver distraction recognition systems for all M and N category vehicles.
• Event data recorders (EDR) for all M and N category vehicles.
• Protection against cyber-attacks for all M and N category vehicles.
• Enlarged pedestrian protection head impact protection zone for M1 and N1 category vehicles.

The majority of the new requirements will be compulsory starting 6^th July, 2020 for all new type approvals and 7^th July 2024 for all new registrations.

The exemptions are:

1. The implementation date of 7^th July 2024 for all new type approvals and 7^th July 2026 for all new registrations;
   • • ECE 125.01 on forward field of vision (N1).
     • Enlarged pedestrian protection head impact protection zone (M1 + N1).
     • Advanced emergency braking systems (AEBS) capable of detecting pedestrians and cyclists (M1 + N1).
     • Advanced driver distraction recognition systems (M + N).
2. The implementation date of 7^th January 2026 for all new type approvals and 7^th January 2029 for all new registrations;

1. • Direct vision requirements (M2, M3, N2 + N3).
   • Event data recorders (EDR) (M2, M3, N2 + N3).

How will it be applied

As was in 2018/858 directive, the 2019/2144 regulation is also a bible for the European automotive industry. Therefore, Turkey has adapted it identically, making references to the future amendments in the European and UN ECE legislation to be adapted into national law by the Ministry. Even in the interpretation of the national text, EC/2019/2144 text will be taken as the original version.

As a principle, any type approval granted in Europe automatically is valid in Turkey; whereas manufacturers may choose to obtain national type approvals from Turkey if they deem so. However, Turkey will follow the same calendar with implementation dates of the European regulation in its national type approval application, meaning the rules in the Turkish market will keep identical to the European.

A bilingual comparison of the Turkish and European legislation is here.