GoKawiilAs the European Union and the US try to negotiate a satisfactory resolution to the trade war President Trump started last year, a new complication has emerged. It seems the American auto industry is not happy about pending changes to EU vehicle regulations that could make it impossible for Detroit to export its full-size pickups across the Atlantic. Restricting the flow of F-150s to the continent “could breach the spirit of the trade deal,” according to US negotiators, the Financial Times reported this morning.
No, I won’t take your word for it
Bringing a new vehicle to market is a rather different process in the EU than in the US. Here, the National Highway Traffic Safety Administration practices something called self-certification. Essentially, an OEM tells NHTSA that its new car or truck complies with all the relevant federal motor vehicle safety statutes, then NHTSA takes that company at its word and the car goes on sale. Should that vehicle later turn out to have a defect, NHTSA can order a recall to remedy it. But there’s no pre-approval process by the government before sales can begin.
As you might imagine, self-certification is great for companies but less great for consumer safety.
The EU (and China) have a different system: type approval. Before being allowed to market a new vehicle in Europe, an automaker has to satisfy regulators in at least one EU country that its new vehicle does, in fact, conform to the relevant regulations. This is either done directly by a national type-approval authority or subcontracted out to specialist engineering firms. Either way, it means there are independent checks to ensure that the new model doesn’t pollute too much, that the safety and advanced driver assistance systems are validated for local use, and so on. And with the shift to software-defined vehicles and regular over-the-air updates, this will become an ongoing process rather than a one-off.
At least, that’s how it works for a mainstream model. For much lower volumes—typically 1,000 or less—there’s Individual Vehicle Approval. These have more relaxed standards than type-approval, although in 2012, the EU harmonized IVA requirements across member nations, and in 2024, it began another review to tighten safety standards.