One of the reasons is the increasing delivery times of vehicles, because truck manufacturers temporarily stop production due to lack of parts. RAI CarrosserieNL has received signals from bodybuilders that in some cases the superstructures of these vehicles are already finished and if the vehicle can only be inspected after 1 September due to the late delivery, this means that the bumper does not meet the new requirements according to R58.03. Another reason is that it is not yet clear whether the current exception for loading wagons for the bumper requirements will also apply in the new situation. But also whether there will be other exceptions for, for example, recovery vehicles with a 'spoon'. For this, a lead time of 6 months from publication in the RDW 'Wijze van Keuren' is normally used.
After discussions with the RDW, the RDW informed RAI CarrosserieNL that the planned implementation date of 1 September for individual authorizations in the Netherlands will not be met and will be postponed. For individually admitted vehicles, the bumper may also meet the current requirements (R58.02) that apply since 2010 after 1 September 2021. It is not yet known until when this postponement will apply. For the time being (in most situations) nothing will change for individual admissions.
RAI CarrosserieNL has also raised this issue with the European umbrella organization CLCCR. Several Member States have indicated that their planned implementation date of 1 September 2021 will also be postponed for individual authorizations. RAI CarrosserieNL is collecting data of this and will inform TRTA as soon as this has been completed.
It is not yet known when the new requirements for bumpers for individual approvals (via the RDW inspection station or at home inspections) will take effect according to R58.03. Probably only in the course of 2022, but RDW has yet to provide a definite answer.
Vehicles with type approval
For vehicles with a type approval (which are no longer individually inspected), the date of 1 September 2021 does apply. From that date, these (new) vehicles must therefore have a bumper in accordance with R58.03.
Conclusion
As long as the current bumper requirements (R58.02) are still applicable until a date to be determined by the RDW (probably in 2022), the situation mostly remains unchanged. Which means:
• The R58.02 (FOCWA / RAI) bumper type approvals of bodywork and trailer builders can be used for an individual admission of a vehicle
• It is possible to request and use an individual approval for the bumper from RAI
• Bodywork and trailer builders can request individual bumper approval from RDW
There are also situations where bodybuilders deliver vehicles that are already fitted with a bumper from factory. The bumper will likely be in the vehicle's type approval. There are two situations here:
1. The bumper of the chassis / cab vehicle meets the current R58.02 requirements: Vehicle must be registered by the manufacturer / importer in the remaining stock.
2. Bumper of the chassis / cab vehicle meets the new R58.03 requirements: If a vehicle has a European type approval with a 58.03 bumper in it, the (moved) bumper must continue to comply with 58.03 after mounting the superstructure.
Source: RAI CarrosserieNL.
Read here more about the change in the requirements for the bumpers in a completed project of the UNDERCARRIAGE committee.