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Within the series of documents released on November 28th 2023 are
allowances for small volume manufacturers to continue using the
present test procedures and limit values that have existed for
several years.  That is until a threshold of 300 units per model
year is exceeded, thus rendering them as regular volume
manufacturers.

In the document relating to OBD are further details as to the
requirements and expectations that will apply as a small volume
manufacturer transitions to regular volume status.  The details
therein give a small volume manufacturer greater lead time and
business confidence to make the necessary changes and ensures that
a supplier with the technology and expertise to help achieve the
new (Euro5+) requirements can be sourced.  For various reasons, not
least the low volumes of parts sold, such suppliers typically
decline to work with small volume manufacturers making the task
very difficult indeed.

However, in the documents relating to tailpipe and evaporative
emissions, no such transitory provisions are present for small
volume manufacturers.  As currently written, they would mean a hard
and immediate transition to regular volume status and thus would
mean an immediate requirement to comply with the Euro5+ standards
proposed.  

Given that the exceedance of the 300 unit figure could be a
temporary one in a single or one-off model year, the three model
year average seen in the OBD document affords a small volume
manufacturer both lead-time and business confidence to commit to
the extensive changes and additional costs needed.  It should be
noted that the technological aspects of the Euro5+ standard are
inextricably linked, especially in software/calibration terms, and
so a soft transition in only one area of the regulation is of
dubious benefit. It is requested therefore that the very clear and
sensible small volume provisions in the OBD document are also
applied to tailpipe and evaporative emission requirements.