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Subject:
Application of dynamo / regeneration axles (E-axle) on whole vehicle type approvals (WVTA) for vehicle category O3 and O4.
1. Introduction
Up to this moment it was not possible to grant a WVTA for vehicle category O3 and O4 equipped with dynamo / regeneration axles due to missing safety requirements in annex II of Regulation (EU) 2018/858. The missing requirements were identified as subject A19 “In-use electric safety and subject C4 “braking”. Recently these missing requirements have been drafted and unofficially been published. The final publication and the implementation in Regulation (EU) 2018/858 will take additional time and effort. To shorten the possibility of the application of these types of e-axles which can contribute to lowering CO2 emissions, consensus has been reached in the FORUM for the Exchange of Information on Enforcement of the EU legislation on the approval and market surveillance of motor vehicles for a uniform approach for early adaption in a WVTA.
This RDW Guideline sets out the additional requirements for granting a WVTA for vehicle categories O3 and O4 equipped with a dynamo / regeneration axle (E-axle). It includes the additional technical and administrative requirements.
This Guideline is issued by the RDW in its capacity as Type Approval Authority pursuant to Regulation (EU) 2018/858.
This Guideline provides further clarification of the manner in which the RDW applies its assessment criteria within the applicable legal framework.
It forms part of the RDW policy framework governing the assessment of technical documentation submitted in support of a type-approval decision and is published to ensure transparency and consistent application towards manufacturers and Technical Services.
This Guideline is made publicly available, including via the RDW website (typeapproval.rdw.nl), in order to ensure its accessibility and to support equal treatment in the assessment of type-approval applications.
The objective of this Guideline is to ensure transparency, technical substantiation and legal verifiability, including in the context of administrative review, judicial proceedings and EU peer reviews, when reliance is placed on worst-case configurations or on previously obtained test results.
2. Legal framework
This Guideline is based on Regulation (EU) 2018/858 and in addition a completed Q&A from the 28th FORUM for the Exchange of Information on Enforcement of the EU legislation on the approval and market surveillance of motor vehicles.
(2026-02-23_NL_001_TAA_01 – QA E-axle trailers – completed reply.pdf)
3. Scope
This Guideline applies to all manufacturers submitting applications for whole vehicle type approval or extension of approval for vehicle category O3 and O4 under Regulation (EU) 2018/858 to the RDW.
4. Technical requirements
For the whole vehicle type approval of vehicle category O3 and O4 the normal requirements of annex II of Regulation (EU) 2018/858 are applicable, in addition to these normal requirements the following requirements will be applicable;
- Subject A19 “In-use electric safety“ is mandatory applicable according
UN R100.03 suppl. 4, UN R100.04 suppl.1 or higher. - Subject C4 “Braking” need to fulfill the normal requirement to the level of Regulation (EU) 2019/2144 and additionally need to be completed with a test report covering the new requirements set out for the dynamo / regeneration axle in the following adopted UN Regulation in WP.29 of March 2026. (not officially published)
a. UN R13.12 suppl. 8 or,
b. UN R13.13 suppl. 6 or,
c. UN R13.14 suppl. 3 or,
d. UN R13.15 suppl. 2 or higher.
5. Documentation
In the information document of the WVTA the following will be added;
- an appendix with a detailed description of the system and the reference to test reports or certification of the technical requirements mentioned in point 4 of this announcement.
- The reference test reports or certification are included in the WVTA.
- The technical parameters of the e-axle generator are stated in the UN-R13 test report, issued by designated Technical Services, with respect to the electrical power and provided brake torque.
- It is preferred that notification of the usage of an e-axle is mentioned in the CoC field 52.
6. Responsibilities of the Technical Service
The Technical Service remains fully responsible, within the meaning of Articles 80 and 81 of Regulation (EU) 2018/858, for the technical accuracy, completeness and reliability of the relevant information supporting its technical assessments and test reporting.
Where the justification is considered insufficient, incomplete or ambiguous, the RDW may, in accordance with Article 30 of Regulation (EU) 2018/858 and, where applicable, Articles 33 and 34 thereof, request additional information and/or require supplementary testing before granting a type approval or an extension thereof.
7. Traceability, auditability and legal certainty
The documentation requirements laid down in this Guideline are intended to ensure traceability, consistency and legal certainty in cases where testing is omitted or limited.
They ensure that the RDW’s decisions can be effectively reviewed in the context of national administrative objection and appeal procedures, internal audits and peer evaluations pursuant to Article 67 of Regulation (EU) 2018/858, reporting obligations pursuant to Article 90 of that Regulation, and international cooperation within the UNECE type-approval framework.
8. Entry into force
This Guideline shall apply to all applications for whole vehicle type approval and extensions of approval under Regulation (EU) 2018/858 for vehicle categories O3 and O4 submitted after the date of publication of this Guideline.
Questions
- For questions or remarks about this Guideline, please contact the Policy Department: [email protected].