Relics of the Past: Paper Processes

Digitalization efforts can be slow and frustrating for vehicle manufacturers, especially when it comes to Homologation and governmental rules and regs. If you're comfortable with paper-based "traditional" processes, there seems to be a lot of investment looming ahead without any obvious benefit.  But is that true?

The change is coming slowly, and the signs of change might still easily be overlooked. But if one looks closely, it is hard to deny that an era is coming to an end for vehicle homologation and registration. An era of paper processes, where ownership of a vehicle was bound to the possession of paper certificates, where correctness of data was secured by signatures and copy-proof paper, and where official documents were part of a vehicle manufacturer's corporate design. It was also the era of Word and Excel. But old paper processes are giving way to the processes of the digital age.

What are the signs?

First of all, e-government processes in vehicle registration have already been introduced by many countries within the EU. Here in Germany, for instance, you can register your vehicle online although you will still receive a paper registration document via conventional mail afterwards. 
 
Secondly, the paper Certificate of Conformity (COC) is being replaced by its electronic successor. Already, many governments in the EU have started introducing the electronic COC.  
Let’s take another look at the situation in Germany: manufacturers of any type approved vehicle are by law required to transmit the electronic COC since 2019, making registration data available for the German government in one central source. Thus, for market surveillance or police control, physically looking into the official COC paper or  official registration document will no longer be necessary once the transition is complete. 
In 2026, electronic COCs will become mandatory throughout the EU for all manufacturers of cars, trucks and trailers. Other vehicle categories are bound to follow suit. The paper COC, which is currently still mandatory, will, in exchange, become completely optional. It is not hard to imagine that paper registration documents will, sooner or later, disappear entirely. 
 
Thirdly, interdisciplinary teams have already formed, developing an optimal format for a complete set of digital type approval documentation. The completion of this project is, at this time, still pending, but a clear path is already being laid out for us. It would mark the final step of the transition into the new era of e-government in Homologation.

Turbulences ahead

As with every change, no matter how good and necessary, the end of this era will cause minor or major turbulences. Moving away from paper processes is a major change, not only for governments, but also for the manufacturers. And while large enterprises will have the capital and the lobby to easily navigate through those turbulences, the smaller and mid-size competitors are at risk of being left behind.

Of course, the old paper documents bring along some "advantages" which easily allow for manual and semi-manual processes: 
 
The documents are strictly intended for human readability. That means on one side, that a human can easily read, understand and maintain the document, which is why Word and Excel solutions are still well established at a large number of manufacturer's. On the other side, human readability allows for flexibility. Instead of formally listing specific data, you might as well reference to some attachments or blueprints providing said data implicitly, knowing that the one reading the document next, will understand. Neither data nor its presentation are formally strictly binding. As a result, individual short-cuts and workarounds are implemented everywhere within these processes. 
 
The digital successors do not allow for that kind of carelessness. Every piece of information must be provided in its correct place and format without exceptions. This means two things for manufacturers: They will have to invest more than before in the formal accuracy of the provided data than they used to, and secondly, they have to adapt their existing processes to the new world. 
 
This is where Excel and Word will not be of much help anymore. Consequently, even the most hesitant manufacturers will have to invest in their IT, some of them may not have the necessary budget to do that. 
 
It may therefore appear as if these future-driven changes are designed for the benefit of large companies rather than in the interests of broad competition.

A promise of a bright future

To be clear: The change is worth the investment. If you once start mentally disconnecting from the old ideas of paper government, a lot of "problems" companies are now struggling with, will just dissolve into thin air. 
 
Having to deal with paper documents puts high emphasis on document layout. Formal prerequisites - like getting all the information on two A4 pages, avoiding unruly line and page breaks, and maintaining a page layout in accordance with the company's corporate design - were equally as crucial as the formal correctness of the data on the documents. In the end, this was a huge driver of manual processes based on Word templates, because Word allows you to individually handle format adjustments. IT solutions on the other hand always struggle here, having to find compromises to achieve the goal of more automation. For industry-wide comprehensive digital formats, all of this is irrelevant, making room for smart automation. 
 
The layout of the documents was not only important to the eye, it also became formal proof of the validity of the documents. Every application for type approval had to be accompanied by a COC example. A COC in a different layout consequently lost its validity. This meant that the type approval had to be renewed if the corporate design was changed. Or, as we often encounter, when a standard solution such as VCX is introduced, an additional investment has to be made in adapting the COC layout because the "standard layout" provided by default would not be accepted as a valid COC. To make it clear once again: The format of a document should have no relation to the validity of its content. Moving away from paper documents will lead to the whole discussion going up in smoke.

The need to create an "original" and "official" paper document also entails the need to provide tools and procedures to protect against counterfeiting. It is strictly required that only one original document is produced, which must be designed in such a way that it cannot be easily copied. Manufacturers invest in special paper or even special printers to meet this requirement. In addition, manufacturers must have procedures in place to provide valid duplicates in case the original is lost. As the respective manufacturer is the sole owner of the data and format, they alone can be held responsible. Manufacturers are also formally obliged to provide a duplicate of each COC for up to 10 years after the original was provided, and informally even far beyond that. In future, when vehicle data is available centrally from the registration authorities and paper documents are no longer distributed, such a procedure will be completely superfluous. 
 
These are only examples, the list could go on for quite some time. But it should make clear that paper government comes with its specific burdens, which are in the end highly unnecessary and a major blocker for any attempt to automate processes. The digital transformation to e-government processes promises a much brighter future.

A bright future for everyone

All this goes to show that the paper state is really just a relic of the past - that is still being kept alive, but no longer has much of a story ahead of it. And that's a good thing. The digital future really does promise tangible and measurable improvements for everyone involved. 
 
In the end, it all boils down to a single unanswered question: how can we ensure that no manufacturer gets lost along the way? As previously mentioned, the requirements of digital transformation carry the risk of major investments in IT, and not every company will have the resources to make these investments alone. 
 
The way we look at it, there is only one solution: standard IT solutions that every manufacturer can use on their own terms. This is why we developed VCX in the first place. By providing a standard cloud solution for type approvals and vehicle registrations, the IT investment is spread evenly across many manufacturers, making the transition effortless and cost-effective.  
This means that every manufacturer, no matter how big or small, can share equally in the benefits of the new era of e-government processes. 
 
Digital transformation is good. Let's make sure it's good for everyone.

1) For an overview over the status of implementation in European, see reference link of the topic group, and especially reference link for the implementation. 
2) "Vierte Verordnung zur Änderung der Fahrzeugzulassungsverordnung und anderer straßenverkersrechtlicher Vorschriften", §45a: https://www.bgbl.de/xaver/bgbl/start.xav#__bgbl__%2F%2F*%5B%40attr_id%3D%27bgbl119s0382.pdf%27%5D__1635429777276 
3) Regulation (EU) 2018/858, Article 37: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02018R0858-20210926&qid=1635430086484

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Jens Cram is spearheading the development of the Homologation Software VCX ("Vehicle Compliance Expert") as Product Owner since 2017.

In his role, Jens Cram has experienced all the advantages and pitfalls of this transformation process and expertly applies his insights to prepare and support manufacturers for upcoming challenges in the world of vehicle homologation.

Jens Cram

Product Manager VCX

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