CLEPA Proposal for an Amendment to EU5/6 Implementing Regulation (EC) 692/2008 with Regard

CLEPA proposal for an Amendment to EU5/6 Implementing Regulation (EC) 692/2008 with regard to IUPR requirements - harmonization with CARB IUMPR - VVT special denominator

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Version 1 18.8.2011

1. Introduction

With the EU5/6 Implementing Regulation (EC) 692/2008 for EOBD also IUPR requirements were introduced.They were based on the CARB OBD II IUMPR regulation before 2007, mostly copied, albeit with modifications and adaptations.

To our understanding the intention of the EU Commission was an EOBD IUPR regulation as far as possible harmonized with CARB IUMPR.
CARB has updated the OBD II regulation in 2007 ("biennial review"), and this also included some amendments to IUMPR requirements.

2. VVT Special Denominator

A specific example of a difference between the current CARB and EOBD requirements is the special denominator for VVT.
EOBD section 3.3.2. (c) of Annex XI of Regulation (EC) 692/2008.

"3.3.2. In addition to the requirements of section 3.3.1:
(c) The denominator(s) for monitors of Variable Valve Timing (VVT) and/or control systems shall be incremented if the component is commanded to function (e.g., commanded ‘on’, ‘open’, ‘closed’, ‘locked’, etc.) on two or more occasions during the driving cycle or for a time greater than or equal to 10 seconds, whichever occurs first;"

The requirements are identical to the CARB IUMPR provision in the OBD II regulation before the "biennial review" 2007 changes.

With the OBD II update in 2007 ("biennial review") the boldunderlinedtext was added

(F) In addition to the requirements of section (d)(4.3.2)(B) above, the
denominator(s) for the following monitors of output components (except
those operated only at engine start-up and subject to the requirements of
the previous section (d)(4.3.2)(E)) shall be incremented if and only if the
component is commanded to function (e.g., commanded “on”, “open”,
“closed”, “locked”, etc.) on two or more occasions for greater than two
secondsduring the driving cycle or for a cumulativetime greater than or
equal to ten seconds, whichever occurs first:
...
(ii) Variable valve timing and/or control system (sections (e)(13) and (f)(13))

Apparently, the special denominator conditions for VVT in the current CARB regulation is different than for EOBD IUPR, but that was probably not the intention of the EOBD legislator.

This is only a small item, but could be the starting point to ensure further and future harmonization.

3. Amendment proposal

CLEPA is proposing to harmonize the EOBD VVT special denominator with the current CARB requirement, i.e. adopt the CARB requirement.

Amend Section (c) of § 3.3.2. of Appendix 1 of Annex XI of Commission Regulation (EC) 692/2008 to read

"(c) The denominator(s) for monitors of Variable Valve Timing (VVT) and/or control systems shall be incremented if the component is commanded to function (e.g., commanded ‘on’, ‘open’, ‘closed’, ‘locked’, etc.) on two or more occasions for greater than twosecondsduring the driving cycle or for a cumulative time greater than or equal to 10 seconds, whichever occurs first;"

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