I have been asked the same question more times than I can count: does my product actually need NG-eCall certification? The askers include T-Box manufacturers, solution companies, head unit suppliers, and even dashcam vendors. Some people say the scope is enormous and any vehicle-related electronic product must comply. Others say only whole vehicles need it. Both extremes are wrong.
The current governing regulation is a single document: (EU) 2024/1180. The old (EU) 2015/758 has been repealed. For product scope, focus on the 2024 parent regulation and the (EU) 2025/1871 amendment. No need to dig through archived files for comparison.
The regulation hard-mandates two vehicle categories: M1 passenger vehicles and N1 light commercial vehicles under 3.5 tons. Sedans, SUVs, MPVs, pickups, light vans, none of them escape. After January 1, 2026, the EU no longer accepts pure 2G/3G CS-eCall solutions for new type approval applications. Push forward to January 1, 2027, and existing CoC compliance certificates based on 2G/3G schemes are all voided. Vehicles cannot be registered. For M1/N1 vehicles exported to the EU, NG-eCall is a hard gate with no workaround.
Three vehicle types qualify for compliance exemption:
·Low-volume custom vehicles with extremely low production numbers can go through the EU small-series approval channel.
·Single-vehicle individual approval covers personal modified vehicles and scattered parallel imports.
·Structurally constrained vehicles where the body layout physically cannot accommodate crash sensors and eCall hardware. A technical explanation must be submitted to the certification body for review and approval. The manufacturer cannot simply declare it infeasible on their own authority.
Scattered single parallel imports have a catch. These vehicles lack original factory certified T-Boxes, so component certificate test waivers do not apply. Full independent testing is required, and the cycle and cost run about 40% higher than batch-export models. Buses, heavy trucks, and two-wheel motorcycles are not yet on the mandatory list, but the EU is already discussing bringing M2 and M3 passenger buses into scope. It is only a matter of time.
2. Component E-Mark Certification
The eCall domain has two certificate types: component E-mark and whole-vehicle WVTA. An E-mark cannot replace whole-vehicle certification. I have seen plenty of manufacturers who thought getting an E-mark meant they could ship and install. They show up at the assembly plant, get asked for the whole-vehicle certificate, and freeze.
Three product types need E-mark certification:
·Integrated eCall T-Box: the highest-volume product, combining 4G/5G communication, positioning, and emergency calling. Pass protocol, MSD encoding/decoding, call, and positioning tests at the lab to get certified.
·Standalone IVS emergency call box: external eCall control unit, more common in commercial vehicles.
·Vehicle head units with built-in cellular and emergency calling: the entire unit falls within certification scope.
Mandatory component test items include: IMS latency under 3 seconds, MSD V3 full-field verification, backup power 66-minute full cycle, EMC UN R10, end-to-end link, and fault simulation documentation.
One common misread: MSD V3 reserves video transmission fields, but regulations do not mandate onboard cameras or real-time video uploads. No need to add video hardware for certification.
The thing component manufacturers most easily miss: transition period E-mark certificates issued in 2025-2026 under the old CEN/TS draft are uniformly voided on January 1, 2028. Supplementary testing against the full EN 17184:2024 standard must be completed before that date. If mid-to-long-term supply planning does not account for this testing cycle and budget, shipments stop after 2028, and the downstream OEM supply chain breaks. That trouble is far bigger than the original certification.
3. Components That Do Not Need Separate Certification
Bare 4G/5G and GNSS communication modules that are internal components of a T-Box or IVS and are not sold separately to vehicle makers as finished products do not need individual certification. The terminal device manufacturer handles unified certification. The module vendor's job is to provide complete technical documentation and test data to support the terminal certification.
4. Aftermarket Replacement Parts
Replacement T-Boxes or IVS units supplied in bulk to European repair shops, auto parts chains, and OEM aftermarket channels require E-mark. Without it, they cannot enter the supply chain. Individual retail-level online modifications are not legally mandated to hold certificates, but most brands pursue compliance certification for aftermarket risk management. If an uncertified product is involved in a safety incident, product liability falls entirely on the manufacturer. Do not gamble.
5. Modified Vehicles and Special-Purpose Vehicles
Changes limited to interior, exterior, or paint that do not affect the eCall antenna, power supply, CAN bus, or crash sensors do not require recertification. Changes to relevant hardware or wiring that cause eCall functionality to fail mean the vehicle cannot pass type approval and existing certificates cannot be used. Special-purpose fire trucks and police vehicles may have independent communication systems that do not necessarily use the public eCall channel, but if the chassis is derived from an M1/N1 base, eCall mandates still apply.
6. Dual-Market and Joint Certification
China's GB 45672-2025 AECS standard takes effect July 1, 2027, for domestic M1/N1 vehicles. AECS requires BeiDou-first positioning. NG-eCall has no such restriction and accepts any positioning constellation. Hardware modules can be shared, but software positioning strategy and data compliance require two independent configurations with separate testing.
For multi-country export, M1/N1 vehicles and T-Box components can take a UN R144 plus NG-eCall joint testing path. Communication RF and GNSS positioning baseline tests are shared. GDPR privacy and EU-specific PSAP compatibility are tested separately. The overall timeline shrinks noticeably.
Change management is tiered. Replacing communication modules, T-Box backup power, or major IMS protocol stack revisions count as major changes requiring partial retesting and E-mark certificate updates. Minor UI adjustments go through a simplified filing process without retesting.
Complete test reports, GDPR privacy documents, change records, and annual CoP materials must be stored at the EU authorized representative's office for at least 10 years. Notified bodies can audit at any time. Storing them is not the end of it. You must be able to produce them on demand.
Quick Self-Check: Four Rules
·M1/N1 whole vehicles exported to the EU: WVTA mandatorily includes eCall. No exceptions.
·Finished T-Boxes, standalone IVS, head units with eCall function exported to the EU: get component E-mark.
·Bare communication modules embedded in terminals: no individual certificate needed. Aftermarket parts in bulk supply to European channels: must get certified.
·Retail-level individual sales: not legally mandated, but you bear full product liability risk.
BlueAsia Testing is a Huawei HiCar authorized certification organization, recognized with the "Excellent Certification Organization" award in 2025. We help automakers and component manufacturers determine NG-eCall product scope and navigate the certification process.
For NG-eCall product scope consultation, contact BlueAsia Testing: 13632500972 (Benson)
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