Help needed for "homologation" of 2013 Model S with 7 seats in Belgium

[Sup3rt3sla]

Dear all,

Any of you with a 2013 Model S had any problems to pass the technical inspection due to:

1. COC "maximum continuous rated power" (point 27) of 69kW not being accepted?
2. extra 2 rear facing child seats in the trunk not showing up in the "carte grise"?

The CT/keuring refuses to give me a certificate with more than 3 months of validity, stating that I need to provide a COC with the value of "maximum net power" for my 2013 Model S.

Tesla says that there's no other COC for my model year Model S. What I have is what they can provide and should be accepted by the authorities.

At the DIV, I was asked to send a copy of my COC and registration documents to the "Homologations Office".

Sharing of similar experiences and the final outcome are welcomed.

Thank you.
Regards,
--
S3T3

 

[stev]

I have a 7 seater also, and before a volvo v70 with comparable children seats in the boot. Never had a coc indicating 7 seats. Is accepted bedause it was an official accessorie (fitted it myself in the volvo - no problems with insurance or technical exam).

 

[m0rph]

For some reason, my Roadster is registered as a 40kW car. Although it actually has 215kW. But no problems to get it through technical inspection...

 

[F500e]

The question is why they do not accept the CoC. Officially this document can only be issued once and can not be altered. In basis there is no reason to not accept it.

The 7 seats are mentioned also on the CoC as being optionally there. Some countries don’t put them in the documents, as probably in your carte Gris from France(?), this does not mean the Belgian authorities can refuse them. The CoC is always leading over car documents from previous countries.

 

[Sup3rt3sla]

Hi.

@F500e I got the Belgian, now yellow, "carte grise"! I'll keep the CoC together with the other documents, but in other countries if you don't have the number of seats on car documents, you'll most probably get a fine. I hope they're aware how things work in Belgium.

Speaking of which, do you know if there's any official publication (e.g. Moniteur Belge) where it says that the COC can't be refused?

The technical inspection center wrote on the certificate of inspection "COC erroné" and gave me a 3 months period to provide a "correct" COC. For them, even the older TMS must have a COC showing the "maximum net power" value, even if they had in front of them an original COC for my P85.

Regards,
--
S3T3

 

[.jg.]

Car registration documents and formalities

"Certificate of conformity for new cars

The certificate of conformity is issued by the manufacturer and shows that the technical characteristics of the vehicle meet safety and environmental standards. It can be either a European (EC) or a national certificate.

EC certificate of conformity

The EC certificate of conformity is valid in all EU countries. If your car has a valid EC certificate, national authorities cannot request any additional technical documentation - unless your car has been modified since leaving the factory, they can then require it to undergo a new approval."

My understanding is that a test centre does not have the authority to question the validity of a CoC previously accepted by the relevant national authority of another member state.

Why not raise this problem with SOLVIT? SOLVIT - welcome screen - European Commission
As this issue seems to be a barrier to freedom of movement in the single market (and potentially in breach of EU regulations), SOLVIT may be able to help. An EU report into the status of car registration within the the single market details a story where an EU citizen attempted to de-register a car in Belgium and register it in Romania but the Belgian authorities lost the documentation needed to de-register and the car ended up simultaneously registered in two EU states - the situation was resolved after intervention by SOLVIT.

 

[Tozz]

For some reason, my Roadster is registered as a 40kW car. Although it actually has 215kW. But no problems to get it through technical inspection...

215kW is probably peak power? In The Netherlands the rating is for "nominal continuous max. power". My S100D is registered as 79 kW.

 

[.jg.]

215kW is probably peak power? In The Netherlands the rating is for "nominal continuous max. power". My S100D is registered as 79 kW.

My understanding of the power figure is: there used to be some rule that national registration authorities could limit the power of cars being registered, measured as the "maximum net power" and not the "maximum instantaneous power". I think the limit was quite low - something like 80 kW. Although the power limiting rule has been removed, the net power figure is still the one used in CoCs. You can also see similar low numbers for Porsche, Ferrari, Mercedes, Bentley, etc.

In 2014, the relevant EU regulation was altered to allow the use of "30 minute power" for electric drivetrains:
Commission Regulation (EU) No 136/2014 of 11 February 2014 amending Directive 2007/46/EC of the European Parliament and of the Council, Commission Regulation (EC) No 692/2008 as regards emissions from light passenger and commercial vehicles (Euro 5 and Euro 6) and Commission Regulation (EU) No 582/2011 as regards emissions from heavy duty vehicles (Euro VI) Text with EEA relevance

 

[Sup3rt3sla]

The 2014 EU regulations ended up at the technical inspection center in the form of a word document called "How to calculate power for a Tesla" including a screenshot of a 2014 or 2015's Tesla dual motor COC showing points 27.1, 27.2 and 27.3.

Clearly, these guys don't know how to handle pre 2014/2015 Teslas. For them, my COC is wrong.

I'll try SOLVIT. By the end of the week I'll show up with as much evidence as I can gather about this mess. I wonder if they'll have the nerve to ask me to pay for the 2nd visit ...

 

[m0rph]

215kW is probably peak power? In The Netherlands the rating is for "nominal continuous max. power". My S100D is registered as 79 kW.

The Roadster has 306 HP (PK) / 225 kW peak power indeed.
That "nominal continuous max. power" is a joke imho.. Is it also used in Belgium?

 

[Sup3rt3sla]

Up to 2014, only the "maximum continuous rated power" was showing up in the EU conformity certification (CoC) for electric drive vehicles. Net power was for ICE only. From 1/1/2015, the net, hourly and 30min power ratings for electric drivetrains must also be specified in the CoC (in Belgium, for a P85D and from what I understood, they sum the max net power per axle for a total max net power of 543kW; This sounds like awesome power, but is it fair to compare it to the BMW's M5 500kW?).

Taxes should be calculated more on fuel/energy consumption and efficiency, not on maximum power like it happens in most countries.

S3T3

 

[Sup3rt3sla]

Problem solved, with 69kW on the paperwork. Apparently somebody still remembers why it's like this and the information was passed to the right people (EU regulations pre-2015, max net power not needed on CoC - at least for electric cars).

Thanks for sharing your own experiences on this matter.

Regards,
--
Luis Gois