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Engine Remaps And Chipsets


Silverback
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DOT%20Letter%20824769. pdf

 

 

A while back in the VW Scandal topic a few posts touched on the legalities of aftermarket remaps, so to try and get some transparency to these aftermarket Remaps and Chipsets devices I emailed the Department of Transport for clarification of this practice regarding the legalities of Type Approval and Construction And Use. The Department of Transport have now replied and given that I personally feel this is an important issue, especially with the ongoing VW scandal, I have decided to upload it above.

 

The Department of Transports letter is quite simple in its meaning and clearly states that anyone installing engine remaps or fitted chipsets, should make sure that the vehicle still complies with its original type approved emission requirement’s and in such, suggest submitting the vehicle to the relevant agencies for re-approval.

 

So who ever is offering the services of an engine remap or fitted chipset should be able to offer a letter of conformity that the vehicle still stays within its original type approval and does not breach construction and use regulations. Some remaps or chipsets may keep the vehicle type approval intact but the only way of knowing this, is by re-performing the EU tests. This applies to all offering these remaps / chipset services, regardless of the size or stature of their company.

 

Some have mentioned in posts that emergency vehicles such as police cars are remapped for better performance, but in practise a lot are not remapped or have chipsets fitted but regardless emergency vehicles or police vehicles are exempt from emission testing or Type Approval and on the V5 it will state Co2 emissions as 0 and Type Approval not available.

 

Insurances companies do insure cars that have had engine performance modifications and usually there is a set scale of performance against the drivers profile, but if the vehicle modification falls outside its original comformity and breaches construction and use, there lies another problem of voiding your policy.

 

So the way I personally understand this practice, Is anyone can have a remap or chipset fitted for performance or economy or both, just make sure that who ever carries out the modification can offer you a letter of comformity to keep it legal.

 

Also I questioned DPF deletion and MOT test to Department of Transport, their reply is to the bottom of their letter and basically highlights that MOT testing procedures are dynamic and can change for future requirements and implement practical procedures of future emission testing

 

SB

Edited by Silverback
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So would an emissions test be expected as part of a remap service so that a letter of ongoing conformity be issued?

 

Presumably the warranty issue would be a problem and I'm also guessing that manufacturers would be unwilling to amend plated weight figures to allow for extra towing capacity.

 

Good post by the way.

Edited by Caravanarfa
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A clear, unequivocal statement from DoT - but toothless as there's no form of enforcement - the MoT test only checks for "grossly polluting vehicles" (their words).

 

Given that the current EU test is now accepted as unrealistic, it'll be interesting to see the detail of the future real world test procedures.

 

Owners could insist on seeing a copy of the results of a retested mapped/chipped vehicle before proceeding with purchase but 99. 9% won't.

Edited by Black Grouse
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A clear, unequivocal statement from DoT - but toothless as there's no form of enforcement - the MoT test only checks for "grossly polluting vehicles" (their words).

 

Given that the current EU test is now accepted as unrealistic, it'll be interesting to see the detail of the future real world test procedures.

 

Owners could insist on seeing a copy of the results of a retested mapped/chipped vehicle before proceeding with purchase but 99. 9% won't.

 

The biggest vehicle fleet in the uk is owned by BT. They remap nearly all their own vehicles and offer a remap service through their service centres.

 

They approached the DoT to have their vehicles retested as they were confident that they have lowered CO2 emissions. Over 24000 vehicles.

 

The DoT response was there is no way to reclassify or retest a vehicles emissions after it's original type approval. Probably worried about lost tax revenue.

 

Even so BT received the Motor Transport Best Use of Technology award 2013 for its innovation in engine remapping and were praised by the DoT for their drive to lower CO2 output of the fleet.

Edited by logiclee

Yeti 2.0TDi EU6 150 DSG 4X4 L&K, Octavia TSi Manual, Fabia TSi DSG, Swift Challenger.

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It is unlikely that an ordinary MOT tester will ever be able to perform the full emmissions test to the standard which would constitute evidence in court, so this legislation is, for all practical purposes, unenforceable. As such it is legislation we would be better off without!

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The biggest vehicle fleet in the uk is owned by BT. They remap nearly all their own vehicles and offer a remap service through their service centres.

 

They approached the DoT to have their vehicles retested as they were confident that they have lowered CO2 emissions. Over 24000 vehicles.

 

The DoT response was there is no way to reclassify or retest a vehicles emissions after it's original type approval. Probably worried about lost tax revenue.

 

Even so BT received the Motor Transport Best Use of Technology award 2013 for its innovation in engine remapping and were praised by the DoT for their drive to lower CO2 output of the fleet.

They can't be reclassified after chipping/remapping but they could be retested to show they still don't exceed Euro limits

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It is unlikely that an ordinary MOT tester will ever be able to perform the full emmissions test to the standard which would constitute evidence in court, so this legislation is, for all practical purposes, unenforceable. As such it is legislation we would be better off without!

 

The technology required to perform an EU NEDC test is massively expensive and is far beyond MOT testing stations.

 

And with major players like BT actively approaching the DoT to arrange retesting of their vehicles to be told no you can't well what do we make of that?

They can't be reclassified after chipping/remapping but they could be retested to show they still don't exceed Euro limits

 

But from the DoT response to BT it was clear there was absolutely no point in doing that. The DoT wouldn't do a full NEDC test to check emissions and BT would gain no financial advantage in paying to have it done so a complete farce.

Edited by logiclee

Yeti 2.0TDi EU6 150 DSG 4X4 L&K, Octavia TSi Manual, Fabia TSi DSG, Swift Challenger.

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But most "consumer" remaps are to boost power/torque. Knowing BT, they will have remapped to make their engines run as lean as possible, and restrict top-end power. Quite the opposite of what most people want.

 

And being ex-BT, I recall when they first equipped their salesmen with company cars back in the 1980s. They were all given Talbot Horizons and Solaras. BT fleet management decided they would use the same monograde oil as the vans, most of which were Commer or Bedford vans.

 

The cars spent more time in the workshop than they did on the road, until the powers that be started using the correct multi grade oil.

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But most "consumer" remaps are to boost power/torque. Knowing BT, they will have remapped to make their engines run as lean as possible, and restrict top-end power. Quite the opposite of what most people want.

Actually many "consumer" remaps improve power/torque and real world fuel consumption at the same time. The only thing that would get worse would be the fuel consumption in an official test.

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Depends on the Map.

 

Leaving the fuel mixture the same and raising permissable maximum boost pressure and fueling rates gives torque and power increases across the rev range.

 

But at the light throttle settings used in the EU test no changes are made to the Map so the official test figures remain the same.

 

This is how some manufacturers such as Ford and BMW sell performance upgrades for some of there models quoting the same mpg and CO2 figures even though they have not been retested.

 

They could probably prove in software that no changes have been made to affect tested emissions without the need for a retest if it came to a legal challenge. Many engines nowdays have a boost cap across the rev range. Lifting that does not effect what happens at lighter throttle settings.

 

Lee

Edited by logiclee

Yeti 2.0TDi EU6 150 DSG 4X4 L&K, Octavia TSi Manual, Fabia TSi DSG, Swift Challenger.

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One of our cars had three modes - Economy/Normal/Sport - I imagine that the ECU used different settings to achieve that - but the official test would have been done in one mode only - does that make the other modes illegal?

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One of our cars had three modes - Economy/Normal/Sport - I imagine that the ECU used different settings to achieve that - but the official test would have been done in one mode only - does that make the other modes illegal?

 

 

That is a very good point.

 

They test the car in the default mode. So for our BMW with Eco, Comfort and Sport the EU test is done in Comfort. For the Ecodynamic model the default mode is Eco so the EU test is done in Eco mode.

 

Eco mode has a very sluggish throttle response, earlier gear changes and limited torque. It also limits demand to electrics and heating and enables coast function on the gearbox. Engine temperature is also raised.

 

Switch to Sport and the throttle mapping is much more agressive. An overboost feature is enabled giving higher torque. On petrol modelscontrol of the dumpvalve ensures more boost is retained and gear shift points are moved.

 

Between Eco and Sport there's a good 10mpg difference.

 

Lee

Yeti 2.0TDi EU6 150 DSG 4X4 L&K, Octavia TSi Manual, Fabia TSi DSG, Swift Challenger.

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The cars I've seen don't have a "default" - it's a physical switch that stays in that position until moved by the driver - I can understand that those with push on / push off with default should be tested in the default mode

Edited by Black Grouse
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What about informing your insurance company.

without doubt tell the insurance company. check with them first as some may not insure the extra bhp, mine would not so I changed insurance companies.

some people may say not to bother the insurance company wont find out, in the event of a claim you never know.

 

macafee2

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Your insurance company will require you to declare an engine performance upgrade . . but to ensure your modification complies to the vehicles original Type Approval and Construction Of Use classification, any modification should come with a letter of conformity, or a letter stating compliance of conformity that the modification of the engine emission controls (Remap or Chip) still complies with the vehicles original Type Approval.

 

Its also been mentioned in posts, that a vehicles performance "mode options" could contradict legal requirements in emissions and their test procedures, but these views are inaccurate. The vehicles Type Approval is based upon the vehicles natural submitted cycles, these are submitted by the manufacture for approval . .. Other performance or economy modes are a option to the driver, to automatically control an economy drive, or an performance drive, which are selected solely by driver. Other than "Eco Mode" most driver select modes are related to automatic transmissions and their gear hold. Basically these options you've selected are dictating the "mode" you've selected, regardless how you actually drive outside them, but they will not increase the vehicle base emissions required by law.

 

Regarding MOT testing for Diesel Particle Filters (As in the Department Of Transport letter attached above) The full Dyno emissions' test would be deemed an impractical addition to an MOT test. But the question to the Department of Transport was a test solution to insure the present of a Diesel Particle Filter. This equipment is easy found to test particles, using laser scanning of particles.

Edited by Silverback
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Your insurance company will require you to declare an engine performance upgrade . . but to ensure your modification complies to the vehicles original Type Approval and Construction Of Use classification, any modification should come with a letter of conformity, or a letter stating compliance of conformity that the modification of the engine emission controls (Remap or Chip) still complies with the vehicles original Type Approval.

 

Its also been mentioned in posts, that a vehicles performance "mode options" could contradict legal requirements in emissions and their test procedures, but these views are inaccurate. The vehicles Type Approval is based upon the vehicles natural submitted cycles, these are submitted by the manufacture for approval . .. Other performance or economy modes are a option to the driver, to automatically control an economy drive, or an performance drive, which are selected solely by driver. Other than "Eco Mode" most driver select modes are related to automatic transmissions and their gear hold. Basically these options you've selected are dictating the "mode" you've selected, regardless how you actually drive outside them, but they will not increase the vehicle base emissions required by law.

 

Regarding MOT testing for Diesel Particle Filters (As in the Department Of Transport letter attached above) The full Dyno emissions' test would be deemed an impractical addition to an MOT test. But the question to the Department of Transport was a test solution to insure the present of a Diesel Particle Filter. This equipment is easy found to test particles, using laser scanning of particles.

 

Sorry . . Just to add

 

Also mentioned were engine remaps that burn lean . ... The increase in oxygen in the combustion process may well give better mpg and less CO2, but a by-product would be a possible increase in NOx . . So if the vehicle had a set NOx limit within its Type Approval, the only way to check for a increase in NOx, would be a conformity test.

 

I've posted this before but here's a Statement by Steve Bridges of Mercedes UK . .

 

Steve Bridge, managing director of Mercedes-Benz Vans, says: “We do not approve any amendment in the vehicle’s engine control software and any unapproved modification breaches the terms in our manufacturer guidelines.

“Automatically, this then invalidates the warranty of the engine, drivetrain, exhaust system and electrical control units and any other associated components, so as a result, any modifications remain the responsibility of the entity carrying out the conversion.”

 

Bridge also stressed that any owner or operator considering such modification should understand the full extent of legislation such as Construction and Use Regulations, especially the issue of the emissions approval owing to ‘in-service conformity’ and ‘durability of pollution control devices’ requirements in both European and local legislation as accountability for operation of a non-compliant vehicle would remain with them.

 

He says: “We would advise that operators should obtain written confirmation from the nominated convertor in respect to having obtained the necessary approvals from the regulatory authorities to remain in compliance with the requirements of both European and local legislation for the purposes of both type approval and in-service conformity

 

SB

Edited by Silverback
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It is unlikely that an ordinary MOT tester will ever be able to perform the full emmissions test to the standard which would constitute evidence in court, so this legislation is, for all practical purposes, unenforceable. As such it is legislation we would be better off without!

 

There is no "Ordinary MOT tester" . . He or She would be a Vehicle Examiner and to if he or she deems the none presence of a DPF visually exists, then that is a refusal of a certificate. The MOT Examiner doesn't have to prove his decisions in court but a owner of a vehicle that's been issued a refusal of a certificate, is entitled to appeal. https://www. gov. uk/getting-an-mot/problems-with-your-test-result

 

 

SB. ..........

Edited by Silverback
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Insurance companies are an unpredictable lot.

 

I gave my broker a full list of the factory-fit options fitted to my new car, including towbar and air suspension - some insurers wouldn't cover it because it was "modified" from standard specification, others wanted increased premium because it was "modified" but many were happy to accept that a factory-fit option doesn't count as a modification so no increase in premium.

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There is no "Ordinary MOT tester" . . He or She would be a Vehicle Examiner and to if he or she deems the none presence of a DPF visually exists, then that is a refusal of a certificate. The MOT Examiner doesn't have to prove his decisions in court but a owner of a vehicle that's been issued a refusal of a certificate, is entitled to appeal. https://www. gov. uk/getting-an-mot/problems-with-your-test-result

 

 

SB. ..........

The presence or absence of a DPF is a matter of fact, and can be confirmed or denied by relatively simple testing for particulates in the exhaust. The effect of a remap on emmission gasses can only be measured by a full emmissions test. Whether you call the Vehicle Examiner by his proper title or an "Ordinary MOT tester" makes no difference, a full emmissions retest is far too expensive to ever be done just to secure a conviction against an individual motorist.

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On the insurance issue many larger tuning companies have insurance partners that will give competative quotes.

 

Some like Ford/Mountune agree not to increase your premium.

 

Also some companies like Ford/Mountune, Volvo/Polestar and BMW have the upgrades listed with the ABI so they are listed as actual models.

 

So for example if you have a 1. 0 Fiesta and have the MR165 165ps upgrade then instead of finding insurance companies that allow modifications you can insure it as a Fiesta MR165 model as it's listed on the ABI's database and has it's own insurance group rating.

 

Lee

Edited by logiclee

Yeti 2.0TDi EU6 150 DSG 4X4 L&K, Octavia TSi Manual, Fabia TSi DSG, Swift Challenger.

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