News

Dutch license plate registrations

In this newsletter, we highlight several important matters regarding Dutch vehicle registration:

• Registration to holder is mandatory: a vehicle may never be driven on the road without a fully completed registration, thus including registration to holder.
• Registration for trailers under 750 kg: if according to the COC the vehicle is classified as category O2, a registration is still required.
• New RDW recognition scheme: some changes highlighted.

Registration to holder is mandatory
In the Netherlands, license plate registration consists of two steps. First, the vehicle is registered in the RDW database, which results in the registration number. In the next step, the vehicle (registration number) is linked to the owner/holder. This is called "registration to name"
Only after the second step the registration is complete and the vehicle is allowed on the road.

Under strict conditions, "blank" (not registered to name) license plates can be sent to Dutch companies. It is then their responsibility to ensure that vehicles are only put on the road after they have been registered to name.

If a vehicle is unexpectedly delivered without registration to name, this registration must be arranged for immediately. Delivery without registration to name is considered a serious offense, potentially resulting in you or your dealers no longer receiving license plates (temporarily or permanently). Since this can also affect our allowances, we will monitor this closely.

Registration for trailers under 750 kg
The Dutch Vehicle Regulations stipulate that the license plate requirement does not apply to trailers with a maximum permissible weight of no more than 750 kg. Consultations with the RDW (Netherlands Vehicle Authority) reveal that in this case, they do not consider the permissible weights stated on the COC (item 17).

In concrete terms, this means that a trailer classified on the COC as category O2 (or O3/4) must be registered. These trailers may not, under any circumstances, be delivered without a registration, and therefore also not without registration to name!

A trailer with a theoretical maximum weight exceeding 750 kg may only be delivered with "white plates" (i.e., unregistered) if:

• a COC has been issued as a category O1 vehicle for that chassis number (VIN), or
• the vehicle has first been registered including registration to name, after which the registered owner can submit a request for revocation, thus waiving the registration requirement.
  This option is currently under discussion at the RDW and may be discontinued.

It is therefore very important to clarify this before delivering the trailer.
Failure to comply with the regulations carries the risk of a penalty, significantly limiting your ability to deliver a trailer.

New RDW recognition scheme
The new RDW recognition scheme will take effect on January 1, 2026.
More information can be found at www.rdw.nl/zakelijke-partners/bedrijven-met-rdw-erkenning/vernieuwd-erkenningenstelsel

Not all details have been released yet, but we'd like to highlight a few points:

• The "Bedrijfspas" (company stock card) will be replaced by a Service Pass in December 2025;
• For the registration to name, the authorized company may only accept a (Dutch) driver's license, even when using an Order for Registration (OTT) from, for example, the leasing company.
  If the customer does not have a valid Dutch driver's license, the new vehicle must be registered to name at a RDW counter or inspection station.
• There will be an option to transfer responsibility for the vehicle to another authorized company.
  For new registration applications, we therefore always ask you to choose between transferring the vehicle to the stock of an RDW-approved dealer or registering it immediately to name.

Due to these RDW adjustments, there may be some delays in license plate applications in early 2026. In the long term, we expect to be able to serve you even better if the above points are carefully observed.

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The eCOC is coming!

Starting July 2026, the Certificate of Conformity (COC) must be provided digitally. The paper COC will no longer be required.

This eCOC is not simply a PDF file, but an XML file that must be signed with a separate digital certificate.

For which vehicles?
All vehicles with type-approval according to (EU) 2018/858 (or 2007/46/EC), including all types -and weight classes - of trailers. For those in the know: all vehicle categories M, N, and O.

Vehicles built in multiple stages, such as motorhomes, are also subject to this requirement. In such cases, a digital COC must be available for the base vehicle, any intermediate stages, and the completed vehicle.

Vehicles that are individually approved, as well as vehicles with a Small Series type-approval, are exempt.

What is changing?
From July 2026, a digital COC must be provided for deliveries within the EU (and possibly the UK).

Delivery will take place via so-called National Access Points. As a manufacturer, you request access to one NAP to upload all COCs. The access point then ensures that the COC is also sent to the other Member State (where necessary).

The starting point for the eCOC is the IVI (Initial Vehicle Information) format, which is already familiar. For example, in the Netherlands, the IVI-COC file can already be used to simplify license plate registration. The HESTOCON Portal will therefore offer a solution for the eCOC as well!

The eCOC will be IVI version 2.x. The message structure has been completely revised.
For example, all national data has been removed from the message. This data can still be requested when applying for a license plate.
All the content of the IVI file can be found at www.ereg-association.eu/topic-groups/topic-group-xii/.

Only in exceptional cases may authorities still request a paper version.
Advantage: the end customer can no longer lose the COC.
A public service is being established where the COC information for a vehicle can be requested.

Signing of the eCOC
All eCOCs must be signed with a digital certificate. Such certificates are issued by specialized bodies.

The first option is an eIDAS Signature. It's important that the certificate is issued to a person who is also listed in the approval as the signing authority. This name must also match the name (signature) in the eCOC.

A second option will likely be the eIDAS Seal. This is somewhat more expensive, but has the advantage of being issued at the company level. Here too, the company name must, of course, exactly match what is specified in the approval.

When?
Authorities must be able to receive the eCOC from September 2025.
Manufacturers must issue the eCOC for vehicles with a production date from July 5, 2026.

Without the eCOC, vehicle registration is not possible for vehicles with a production date of July 5, 2026 or later.

HESTOCON can offer you various services to help you apply for, maintain and keep your type approvals up-to-date. Should you have any questions, please do not hesitate to contact us.

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Mandatory check digit in chassis numbers

The introduction of UNECE Regulation 156 regarding Software Updates almost makes us forget that even more adjustments will be mandatory next year.

This newsletter focuses on the mandatory use of a so-called check digit in the VIN.
More information about the introduction of the eCOC in the next newsletter.

For which vehicles?
For all vehicles in categories M, N and O, including all trailers and semi-trailers (regardless of weight class).

In the Hestocon Portal you can find out which type approvals this adjustment applies to.

What is changing?
The new requirements for the chassis number concern the 9th character, which must be freed up for the check digit. The check digit can be calculated quite easily based on the remaining 16 characters. That value is then filled in as the 9th character of the chassis number.

Because the structure of the VIN is included in the type-approval, the type-approval will have to be adjusted accordingly. This is not an addition to the existing legislation, but a replacement by a new Regulation ((EU) 2021/535).

The check digit may already be used by you, but the type approval still mentions the old legislation. Also then, the approval must be supplemented to indicate that the new requirements are met.

Consider the impact this change will have on your internal registrations, processes or systems. Our advice is to adjust the approval well before the mandatory date, so that there is still time to convert the chassis number structure at a time that suits you.

Nothing else changes for the type plate.
However, we would like to mention here again that it is mandatory to state the contact details of the manufacturer (or representative within Europe) on the vehicle, although this does not have to be included on the type plate itself.

When?
Existing European type-approvals must be adapted to these new requirements before 7 July 2026. For vehicles that are not yet registered and do not meet the new requirements, a temporary end-of-series scheme will apply.

When applying for a new European approval, the VIN structure must already provide for a check digit as the 9th character.
Nationally, for example with individual approvals, countries can apply modified requirements.

HESTOCON can offer you various services to help you apply for, maintain and keep your type approvals up-to-date. Should you have any questions, please do not hesitate to contact us.

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Space for 2 registration plates mandatory for trailers and semi-trailers (O3/O4)

The introduction of Regulation 156 regarding Software Updates almost makes us forget that even more adjustments will be mandatory in the coming year.

In the following newsletters we will inform you about the (mandatory) adjustment of chassis numbers (VIN), and the introduction of the eCOC.

In this newsletter attention for the obligation for (heavy) trailers to provide space for 2 registration plates. Since this adjustment has consequences for the design of the rear, this must be prepared in time.

For which vehicles?
The new requirements apply to all types of trailers with a technical maximum mass greater than 3500kg (category O3 and O4). This includes semi-trailers, drawbar trailers and centre axle trailers.
For trailers with a lower maximum mass (O1 and O2, maximum 3500kg), space for one registration plate is still sufficient, and the requirements have in fact been relaxed.

What is changing?
Previously, towed vehicles (trailers, category O) had to provide space for the mounting of 1 registration plate at the rear, on the left or in the middle of the vehicle width.

Under the modified requirements, space must be provided for the mounting and attachment of 2 rear registration plates. These may be mounted next to or above each other as long as both spaces separately meet all the requirements, taking into account a "wide" (520x120 mm) or a "high" (340x240 mm) plate.

In deviation from the "old" requirements, the mounting of the registration plate(s) on the right-hand side of the vehicle is now also permitted. All of course within the visibility angles as indicated in the relevant Regulation (EU) 2021/535, Annex III.

Where the 2nd plate is mounted, sufficient illumination of the plate must also be provided (installation of registration plate lighting in accordance with UNECE R48).

The introduction of this requirement does not mean that every country requires the actual mounting of 2 registration plates. Regulation (EU) 2021/535 only includes requirements for offering the possibility to do so.

When?
Existing European type approvals must be adapted to these new requirements before 7 July 2026 When applying for a new European type approval, vehicles must already be equipped with space for 2 registration plates at the rear.
Nationally countries may apply modified requirements, for example in case of individual approval.

HESTOCON can offer you various services to help you apply for, maintain and keep your type approvals up-to-date. Should you have any questions, please do not hesitate to contact us.

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Height-adjustable support under the drawbar is mandatory for centre-axle trailers

Although some Member States have already deviated from this, a height-adjustable drawbar support was previously only mandatory when a towing eye was fitted. This will change with the entry into force of UNECE R55.03.

What is changing?
The new requirement includes that a height-adjustable support must always be present if the coupling load may be >50 kg. This does not concern a height-adjustable drawbar, but for example a nose wheel or fall support.

In many cases, such a support is already installed, but this is not visible in the vehicle approval. Based on confirmation that a height-adjustable support is indeed always installed, the approval can be administratively adjusted to the latest state of this legislation, so that it is visible to all authorities that these new requirements are met.

For components such as drawbars, an update to R55.03 is not required. The technical requirements for this have not changed. What therefore only needs to be adjusted is the approval for the installation of couplings.

For which vehicles?
This new requirement applies to all types of centre axle trailers with a (maximum) load on the coupling of more than 50 kg.

When?
From September 22, 2024, it is possible to obtain approval according to R55.03.
In both new and existing European type-approvals, the requirements of R55.03 must demonstrably have been applied from 1 September 2025 onwards.
Nationally, for example in the case of individual approvals, countries may have modified requirements.

HESTOCON can offer you various services to help you apply for, maintain and keep your type approvals up-to-date. Should you have any questions, please do not hesitate to contact us.

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Expiring Type Approvals - Remember to apply for the "end-of-series" scheme!

A lot is set to change in the field of vehicle legislation this year. This includes the requirements regarding Software Update (R156), the introduction of TPMS (R141) and the Vecto simulation for trailers in accordance with (EU) 2022/1362.

The first only applies if you install software on vehicles, which software makes a connection with the vehicle systems (e.g. braking system, steering system) or the CAN bus of the towing vehicle. The last two only apply to trailers and semi-trailers in categories O3/O4 (mass > 10000kg). Please refer to the newsletters we previously sent about this.

Approvals that do not (yet) include this new legislation will expire on July 7, 2024. Based on a vehicle type approval that has not yet been adjusted as of July 6 2024, the registration of vehicles after that date can be refused!

Check immediately whether your European vehicle type approvals meet the new requirements.

End-of-series vehicles
Vehicles built in conformity with an expired type approval can be registered in the "end-of-series" scheme. Based on this scheme, it is possible to register license plates for previously completed vehicles for a period of 12 months.

Only vehicles for which it is not economically or technically feasible to meet the new requirements are eligible. In various countries there is an additional requirement that the COC must be issued 3 months before the entry into force date.

In this case, only vehicles for which the COC was issued before April 7 2024 remain eligible for registration!

Make an inventory of which vehicles are not yet registered and whether they meet the requirements.

HESTOCON helps
HESTOCON can offer you various services to help you apply for, maintain and keep your type approvals up to date. We can also relieve you of the burden of managing the input data and running the simulation according to (EU) 2022/1362.
Don't hesitate to contact us!

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Trailers and the climate goals; HESTOCON can be of assistance

We previously informed you about new legislation for (closed) trailers with a maximum mass of 8,000 kg and more (see our earlier news item). With the ultimate goal of reducing CO2 emissions from vehicle combinations, manufacturers are obliged to inform their customers about the aerodynamic efficiency of the trailers supplied.

To help you meet the extensive requirements of this Regulation, HESTOCON will offer services on our Portal presented this year.

Do you want:

• To receive detailed information per vehicle based on the calculation results, so that you can easily provide your customer with the required data?
• An overview that gives insight into the input and output data per vehicle and, for example, the cryptographic hashes that should be included on the COC?

Send us a message if you are interested in this service and we will contact you shortly.

With the new platform we are ready for the future.
Some services are already available in the HESTOCON Portal, such as:

• Monitoring changes in the Regulations and the consequences for your type approvals;
• Uploading digital COCs (IVI-COC) for license plate registration.

In the background we are still working on further expansions.
Follow us to stay informed!

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Trailers and the climate goals; new requirements

In the context of the European climate objectives, the CO2 emissions of vehicle combinations, among other things, must be drastically reduced.

As part of this, regulations have been published to determine the influence of towed vehicles on the emissions of the motor vehicle. This influence is calculated with a calculation tool provided by the EU, in which the built trailer is compared with a reference trailer.

For the time being, these new requirements apply to a limited group of vehicles:

• Semi-trailer, Central Axle or Complete Trailer (no link trailers as the middle vehicle of a combination)
• Maximum mass >8000kg (so only category O3 and O4)
• Maximum 3 axles (of which no driven axles)
• Closed body (body codes 03, 04, 05, 06 or 32)
• Only vehicles not exceeding the maximum authorised dimensions

From July 2024 at the latest, manufacturers of these vehicles are obliged to inform their customers about the efficiency of the trailer compared to a standard reference trailer. For new approvals (issued after 25-08-2022), the requirements already apply from 01-01-2024.

Manufacturers with type-approval who build more than 30 vehicles within the scope described above each year must set up a managed process to be able to perform these calculations. The other manufacturers may also have the calculation carried out by a designated Technical Service, but of course remain responsible for the information provided.
Certified data of tyres and aerodynamic devices are used in the calculation, which are supplied by the relevant suppliers.

When a new vehicle is delivered from July 2024 (regardless of the approval date!), the customer must receive prescribed information about the calculation input and results of the trailer. This information can be found on the COC and in the separate Customer Information File.
A marking must also be affixed to the vehicle itself

By providing insight into the influence of the semi-trailer or trailer on the consumption and emission values of the towing vehicle, the market should be stimulated to use more efficient vehicles

For those interested, CLCCR has released a video on this topic: CLCCR promo EU CO2 trailer legislation - YouTube

HESTOCON can offer you various services to help you apply for, maintain and keep your type approvals up to date. If you have any questions, please do not hesitate to contact us.

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TPMS systems also mandatory for trailers and semi-trailers

A Tyre Pressure Monitoring System (TPMS) monitors pressure loss in one or more tires by means of sensors.

Soon you will also find the system standard on heavy semi-trailers and trailers (category O3 and O4 trailers). In operation, the system sends standard signals to the towing vehicle so that operation can be monitored from the driver's seat.

As of July 2022, the system has already become mandatory for new type approvals, and from 07 July 2024 the requirements apply to all new O3/O4 vehicles with type-approval that are entered into service in Europe.

The technical requirements are described in ECE Regulation R141. In addition to TPMS, this regulation also covers TPRS (Tyre Pressure Refill Systems) and CTIS (Central Tyre Inflation Systems).

An addition was recently made to the regulations, so that the component supplier can already have a test report issued on parts of the system. The vehicle manufacturer then only needs to apply for an installation approval.

Please note: If the vehicle approval has not been extended with TPMS before 07 July 2024, the type approval will lose its validity! In connection with the residual stock scheme, it is even desirable to have completed this addition before April 7, 2024.

In the short term, the new CO2 legislation will also become mandatory for the same categories. More about this soon, but it is therefore recommended that you also address this change immediately.

HESTOCON can offer you various services to help you apply for, maintain and keep your type approvals up to date. If you have any questions, please do not hesitate to contact us.

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