Challenges of Low-Volume Control
The following article explains the requirements for the application and the accompanying test documents. The type of test report to be used may vary. An initial sampling report can be just as suitable as a long-term load test or a maximum load result, for example. Ideally, the report should refer exactly to the part numbers or product family and vehicle model intended for the minimum quantity regulation. This is not always the case, as suppliers often only use internal component codes and not those of the OEM. This requires an individual solution in each individual case. All test reports must be notarized and translated into Portuguese before they are submitted to the authority, otherwise they will not be accepted by the authority (Inmetro).
Complete documentation is mandatory.
Conversion and Import with Low-Volume Control
A low volume enrollment is valid for four years. However, two years after the application has been filed, an application for renewal must be filed to maintain the application. For this extension, the authority requires a further test report which differs from the test report initially used and ideally reflects a more up-to-date test procedure. If the deadline for the extension of the application is missed, it will be declared invalid and a new procedure will be required to declare the registered component again as importable.
Assuming an average life cycle of an automotive spare part of 20 to 25 years, a large number of different tests are necessary, which must be carried out regularly. This poses problems for many manufacturers, either because a component test was only carried out initially for acceptance, or because enormous costs can arise for additional test procedures in relation to the sales volume. Thus, an initially very economical import solution can quickly turn into an expensive and unprofitable undertaking.
Continuous monitoring is essential.
Future development and outlook
The fundamentals of the minimum quantity regulation, such as the extension to most of the product categories subject to Inmetro certification or the maximum number of individual components, are subject to virtually no dynamics. Unless new categories are added or fall outside the relevance spectrum, no changes are to be expected. However, implementation and enforcement have intensified significantly in recent months. The need for notarized translations or continuously updated test reports are innovations that lead to considerable process and cost adjustments. Profitability compared to certification will have to be examined much more closely in the future, making the low-volume rule somewhat less attractive and slower than it seems at first glance.
