Hello aquabiologist,
what a pleasure to read from you! You're the first Swiss that crosses paths with me here on this forum - although I have to admit that I haven't been very active on here.
The EMV approval is a huge issue indeed, and I am glad you are mentioning this, maybe we can even share some experiences.
This is what I understand:
Although the EMV compliance has always been part of the legislation, most vehicles that have been tested before January 2019 didn't have to pass a full EMV test if they were built exclusively for private use and not for resale. As far as I know these vehicles have a "REMARK 178: CHANGE OF VEHICLE HOLDER PROHIBITED" in the field 14 of the vehicle licence. According to some sources, this practice has been abandoned as from 2019 on, requiring all builds to certify their EMV-compliance. I couldn't find out exactly what were the reasons for that change, as nothing in the legislation changed in that period of time.
I am currently following the following approaches:
- I have been in touch with my local MFK back in 2018 asking them what would be required, and at the time they didn't mention EMV compliance, but just CE compliance of the components. Based on this answer and on the fact that the underlying legislation didn't change from then, I will try to base myself on the principle of legal certainty. A very daring approach I know, but worth a try. In my experience, it's always worth trying and speaking with them rather than just complaining. I once imported a 1983 Renault 4 from France that apparently didn't meet the emission standards, and everybody told me that there's no chance it will ever be driving on Swiss roads... but see what happened:
- I am also documenting the build as good as I can in order to have all the technical documentation ready for inspection once the project will be finished. This might be important to prove that the CE marks are present also on hidden parts etc.
- I am trying to use components that have been used before in Switzerland and have the relevant CE marks and other certifications available. This is e.g. the problem with HPEVS products, as they don't have this kind of documentation available. My FIMEA motor e.g. is european built and has the relevant marks.
- If everything fails, I might have the possibility to export the car to my second home in Ireland, pass the NCT there.
- I also hope in changes of legislation and harmonisation with the rest of europe, although it is still patchy there as well, as the example of France showed recently.
I would be very interested to share some experience with you or other Swiss builders on that very topic - I think that we need to act together in order to solve these flaws in legislation or practice. Luckily, Switzerland usually approaches these kind of problems with some common sense. Not always, but most of the times ;-) !
Looking forward to hearing from you again!
Best regards,
Remi.
